At Global Switch we take your privacy seriously and we are committed to protecting it.
This policy explains when and why we collect personal information about individuals, how this information is used, with whom we share that information and the rights they have over it.
This policy may change from time to time so please check this page occasionally to ensure that you are happy with any changes. Please also see Changes to this Policy below.
For the purposes of data protection law, Global Switch Limited (“we”, “our” or “us”) is the ‘controller’ in relation to the processing activities described below. A ‘controller’ is an organisation that decides why and how your personal information is processed.
Please see the section at the end of this policy for our contact and legal information.
We collect personal information from you in the following ways:
Personal information you give to us:
This is information about you that you give to us when:
This information is provided by you entirely voluntarily and includes personal information. We may also ask you for information when you report a problem with our Websites. The information you give to us may include your name, address, email address and phone number, enquiry details and other business and contact information, and may include records of any correspondence and responses to any surveys.
If we do not receive this information, you may be unable to use or interact with certain parts of our Websites or communicate with us effectively.
Personal information we collect about you:
We may automatically collect the following information during your visits to our Websites or social media pages: traffic data, location data, device data, weblogs and other communication data, and details of the resources you access.
We may also collect any personal information which you post or allow to be shared on third party social media networks, including text, images, videos and links.
Personal information we may receive from other sources:
We obtain certain personal information about you from other sources (including those outside of our business) which may include other companies in our group, our suppliers, commercial partners, our customers and social media networks.
We process different types of personal information about you. To make it easier to understand the information that we use about you, we have categorised this information in the table below and provided a short explanation of the type of information each category covers.
Category of personal information
our activities, actions and behaviours.
information which can be used to address, send or otherwise communicate a message to you.
information contained in our correspondence or other communications with you or your work colleagues.
information contained in a formal identification document or other unique reference number relating to you, including any cookie identifications (IDs).
information relating to legal claims made by or against you or the organisation for whom you work or the claims process.
your preferences in respect of any marketing communications from us from time to time in relation to products or services which we believe may be of interest to you.
information relating to the surveillance or monitoring of your activities.
Data protection law requires us to have a valid reason to process your personal information for each of the different purposes for which we use that information. The law refers to each reason as a ‘lawful basis’. The purposes for which we use your personal information and the lawful basis under data protection law on which we rely to do this are explained below.
Where you have provided consent
We may use and process your personal information where you have consented for us to do so.
If you work for an unincorporated business (e.g. sole trader or unincorporated partnership), we will contact you via email with marketing information about our products and services if you subscribe to receive our email marketing communications by ticking the relevant box or when you refresh your marketing preferences when responding to a request from us to do so and consent to continue receiving marketing emails from us.
If you consent to our use of any non-essential cookies, we will use the cookies described in our Cookies Policy to collect Behavioural and Identity information from you.
You may withdraw your consent for us to use your information in any of these ways at any time. Please see Withdrawing your consent for further details.
Where processing is necessary for us to pursue our legitimate interests
We may use and process your personal information where it is necessary for us to pursue our legitimate interests as a business, for the following purposes:
Processing necessary for us to promote our business as well as our products and services
Processing necessary for us to support our customers and prospects with sales and other enquiries
Processing necessary for us to respond to changing market conditions and our customers’ needs
Processing necessary for us to operate the administrative and technical aspects of our business efficiently and effectively
Where required to comply with our legal obligations
We will use your personal information to comply with our legal obligations:
Other companies in our group
We may share your information with other companies in our group. They may use your personal information in the ways set out in How we use your personal information, in connection with the services they provide, including where they complement our own range of services.
Our suppliers, service providers and other recipients
We may share your information with our third party service providers, agents, subcontractors and other organisations (as listed below) for the purposes of providing services to us or directly to you on our behalf.
|Recipient / relationship to us||Industry sector and (sub-sector)|
|Advertising and public relations agencies||Media (advertising)|
|Cloud storage service providers||IT (cloud services)|
|Insurance services providers||Insurance (brokers/underwriting/experts)|
|Legal advisers||Professional services (legal services)|
|Market research and analytics services providers||Media (research and analytics)|
|Online email marketing, campaign management and customer relationship management platform services||IT (cloud services)|
When we use third party service providers, we only disclose to them any personal information that is necessary for them to provide their service and we have a contract in place that requires them to keep your information secure and not to use it other than in accordance with our specific instructions.
When we share your personal information with third parties that are controllers of that information, they may disclose or transfer it to other organisations in accordance with their data protection policies. This does not affect any of your data subject rights as detailed below. In particular, where you ask us to rectify, erase or restrict the processing of your information, we take reasonable steps to pass this request on to any such third parties with whom we have shared your personal information.
Other ways we may share your personal information
We may transfer your personal information to a third party as part of a sale of some or all of our business and assets to any third party or as part of any business restructuring or reorganisation. We may also transfer your personal information if we are under a duty to disclose or share it in order to comply with any legal obligation, to detect or report a crime, to enforce or apply the terms of our contracts or to protect the rights, property or safety of our visitors and customers. We will always take steps with the aim of ensuring that your privacy rights continue to be protected.
All information you provide to us may be transferred to countries outside the UK and European Economic Area (EEA). By way of example, this may happen where any of the companies in our group are located in a country outside of the UK and EEA or if any of our servers or those of our third party service providers are from time to time located in a country outside of the UK and EEA. These countries may not have similar data protection laws to the UK and so may not protect the use of your personal information to the same standard.
If we transfer your information outside of the UK and EEA in this way, we will take steps to ensure that appropriate security measures are taken with the aim of ensuring that your privacy rights continue to be protected as outlined in this policy. These steps include:
Please contact us using the details at the end of this policy for more information about the protections that we put in place and to obtain a copy of the relevant documents.
If you use our Websites whilst you are outside the UK and EEA, your information may be transferred outside the UK and EEA in order for you to access the Websites.
The length of time for which we retain your personal information is determined by a number of factors including the purpose for which we use that information and our obligations under other laws. We do not retain personal information in an identifiable format for longer than is necessary.
We may need your personal information to establish, bring or defend legal claims. For this purpose, we will always retain your personal information for seven years after the date it is no longer needed by us for any of the purposes listed above under How we use your personal information.
The exceptions to the above are where:
We implement appropriate technical and organisational measures to keep your personal information safe and secure.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your information transmitted to our Websites and any transmission is at your own risk. Once we have received your personal information, we put in place reasonable and appropriate controls to ensure that it remains secure against accidental or unlawful destruction, loss, alteration, or unauthorised access.
Our Websites may contain links to other websites run by other organisations. This policy does not apply to those other websites‚ so we encourage you to read their privacy statements. We cannot be responsible for the privacy policies and practices of other websites even if you access them using links that we provide. In addition, if you linked to our Websites from a third party website, we cannot be responsible for the privacy policies and practices of the owners and operators of that third party website and recommend that you check the policy of that third party website.
We do not envisage that any decisions that have a legal or significant effect on you will be taken about you using purely automated means, however we will update this policy and inform you if this position changes.
You have a number of rights in relation to your personal information under data protection law. In relation to certain rights, we may ask you for information to confirm your identity and, where applicable, to help us to search for your personal information. Except in rare cases, we will respond to you within one month from either the date that we have confirmed your identity or, where we do not need to do this because we already have this information, from the date we received your request.
You have the right to ask for a copy of the information that we hold about you by emailing or writing to us at the address at the end of this policy. We may not provide you with a copy of your personal information if this concerns other individuals or we have another lawful reason to withhold that information.
The accuracy of your information is important to us and we are working on ways to make it easier for you to review and correct the information that we hold about you.
In the meantime, if you change your name or address / email address, or you discover that any of the other information we hold is inaccurate or out of date, please let us know by contacting us in any of the details described at the end of this policy.
Where we rely on your consent as the legal basis for processing your personal information, as set out under How we use your personal information, you may withdraw your consent at any time by contacting us using the details at the end of this policy. If you would like to withdraw your consent to receiving any direct marketing to which you previously opted-in, you can do so using our unsubscribe tool. If you withdraw your consent, our use of your personal information before you withdraw is still lawful.
Where we rely on your legitimate business interests as the legal basis for processing your personal information for any purpose(s), as set out under How we use your personal information, you may object to us using your personal information for these purposes by emailing or writing to us at the address at the end of this policy. Except for the purposes for which we are sure we can continue to process your personal information, we will temporarily stop processing your personal information in line with your objection until we have investigated the matter. If we agree that your objection is justified in accordance with your rights under data protection laws, we will permanently stop using your data for those purposes. Otherwise we will provide you with our justification as to why we need to continue using your data.
You may object to us using your personal information for direct marketing purposes and we will automatically comply with your request. If you would like to do so, please use our unsubscribe tool.
In certain circumstances, you may ask for your personal information to be removed from our systems by emailing or writing to us at the address at the end of this policy. Unless there is a reason that the law allows us to use your personal information for longer, we will make reasonable efforts to comply with your request.
You may also ask us to restrict processing your personal information where you believe it is unlawful for us to continue processing, you have objected to its use and our investigation is pending or you require us to keep it in connection with legal proceedings. In these situations we may only process your personal information whilst its processing is restricted if we have your consent or are legally permitted to do so, for example for storage purposes, to protect the rights of another individual or company or in connection with legal proceedings.
Where we rely on your consent as the legal basis for processing your personal information or need to process it in connection with your contract, as set out under How we use your personal information, you may ask us to provide you with a copy of that information in a structured data file. We will provide this to you electronically in a structured, commonly used and machine readable form, such as a comma separated values (CSV) file.
You can ask us to send your personal information directly to another service provider, and we will do so if this is technically possible. We may not provide you with a copy of your personal information if this concerns other individuals or we have another lawful reason to withhold that information.
You have the right to lodge a complaint with a data protection regulator, in particular in a country you work or live or where your legal rights have been infringed. However, we encourage you to contact us before making any complaint and we will seek to resolve any issues or concerns you may have. Please see the European Data Protection Board website for contact details regarding the data protection regulators in the European Union. The relevant regulator in: the United Kingdom is the UK Information Commissioner; Hong Kong is the Office of the Privacy Commissioner for Personal Data; Singapore is the Personal Data Protection Commission; and in Australia is the Australian Information Commissioner.
This policy was last updated on 15 May 2023. We may update this policy from time to time by posting a copy of the updated policy on our Websites or, if we have a record of your details, we may send you an email. Unless we state otherwise, any changes to this policy will take effect seven days after the date of our email or the date on which we post the updated policy on our Websites, whichever is earlier. We recommend you regularly check for changes and review all updates to this policy.
Please direct any queries about this policy or about the way we process your personal information to our Data Protection Manager using our contact details below.
If you wish to write to us, please write to Data Protection Manager, Global Switch, 2nd Floor, Nova North, 11 Bressenden Place, London, United Kingdom, SW1E 5BY.
Our email address for data protection queries is DPM@globalswitch.com.