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This Policy is provided in a layered format, so you can click through to the specific areas set out below that may be of most interest to you.
Protecting your privacy is important to us and is a responsibility that we take very seriously.
Who are we? Tata Communications Ltd. is the controller of and responsible for the Services. References to "we", “our," or "us" in this Policy refer to this company who is responsible for processing your personal data.
Additional information on our personal data practices may be provided in contractual agreements, supplemental privacy statements, or notices provided to you prior to or at the time of collection of your personal data.
Your use of our Services, and any dispute over privacy, is subject to this Policy, our Terms of Service (which are incorporated by reference into this Policy) and any written contract for services between you and us or any person who provides you with access to our Services.
We may collect or receive from JLR different types of personal data based on your use of our Services. The following is an overview of the categories of information that we might collect or receive:
We set out below some of the ways in which we process personal data:
Manage your application and determine your eligibility to be given access to our Services. This includes taking action regarding illegal activities, KYC/fraud, threats to our property or personnel and violations of our Terms of Service and/or applicable law and also to meet our legal and regulatory obligations.
This includes communicating with you and providing you with the Services requested,
This includes communicating with you about your use of our Services, responding to your inquiries, providing any information that you request, addressing technical support tickets, and providing customer service support.
Obtain and process payments, this includes taking action against fraudulent activities and complying with our legal and regulatory obligations.
Keep things secure, protect your personal data against any loss, damage, theft or unauthorized access, prevent crime and fraud, prosecute offenders and protect national security.
Manage our network and your use of our network. This includes managing the flows of data going through our network to ensure the best possible quality of Service is available to you.
Improve our (and third party partner) Services and develop new ones with the help of statistics on the usage of our Services.
Send you information about our Services. Where we rely on your consent for these activities, you have the right to withdraw such consent at any time by contacting us at the contact details set out in this Policy.
We can use your personal data to respond to request from law enforcement authorities or other public authorities. This may require us to disclose your contact details and/or information about your usage of our Services to such authorities or to block, intercept or otherwise interfere with your use of our Services and any personal information generated by the usage.
In the EU, our justification (or legal basis) for processing your personal data will vary depending on the information itself, our relationship with the subject of the personal data, the Service being provided, the specific legal and regulatory requirements of the country in which the Services is being provided or the personal data processed as well as many other factors. It is difficult to provide an exhaustive list however we have endeavoured to provide an indicative guide below:
Relying on our legitimate interests
We have carried out balancing tests for all the data processing we carry out on the basis of our legitimate interests, which we have described above. You can obtain information on any of our balancing tests by contacting us using the details set out in this Policy.
We may share or disclose your personal data as necessary for the purposes described above and as further detailed below:
Tata Communications may transfer personal data across national borders. In doing so, your personal data may be transferred to and processed by other Tata Communications entities and/or unrelated third parties.
All Tata Communications entities have signed an intra-group agreement applicable to transfer of personal data outside of the EU. This agreement is based on the EU Commission standard contractual clauses (and which therefore contractually impose a standard of protection for the personal data that is equivalent to that offered within the EU). This way we ensure that adequate protections are in place for the security of your personal data when we transfer it to one of our affiliates, wherever they may be located in the world.
When we share your personal data with third parties unrelated to the Tata Communications Group, we require all such third parties to respect the security of that personal data and to treat it in accordance with applicable data protection laws. Where we engage third-party service providers to process your personal data on our behalf, we do not allow them to use that personal data for their own purposes and only permit them to process it for our own specified purposes and in accordance with our instructions. When initiating such processor relationships, we will ensure that adequate protections are in place for your personal data using the data transfer mechanism most appropriate to the personal data and the countries within or to which the personal data may be transferred. This mechanism may include: the use of the EU approved contractual clauses; ensuring that the recipient has implemented EU approved Binding Corporate Rules governing transfer or personal data; or (in the US) is Privacy Shield Certified; or confirming that the country in which the recipient is located has been formally confirmed as providing adequate protections for personal data by the EU.
Under the law of many countries, you have certain rights in relation to your personal data that is held by us and we respect and observe these rights. Such rights may include the rights to: ask us for a copy of your personal data; to correct, delete or restrict (stop any active) processing of your personal data; and to, and to ask us to share (port) your personal data to another person, such as another provider or telecommunications services.
In addition, you can object to the processing of your personal data in some circumstances (in particular, where we don’t have to process the data to meet a contractual or other legal requirement, or where we are using the data for direct marketing).
These rights may be limited, for example if fulfilling your request would reveal personal data about another person, where they would infringe the rights of a third party (including our rights) or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping
To exercise any of these rights, or to obtain other information, you can get in touch with us, see contact details above. If you have unresolved concerns, you may have the right to complain to your relevant national data protection authority. Please do contact us before making such a complaint however as we would appreciate the opportunity to investigate and address your concerns first.
We retain personal data for as long as and/or for no longer than we are permitted to do by applicable law, regulation, tax or accounting practice or the terms of any governmental telecoms licences to which we may be subject. We also delete personal data in accordance with any contractual obligations that we may be subject to.
Where maximum or minimum data retention periods are not otherwise stipulated, we determine appropriate retention period for the personal data by considering: the amount, nature and sensitivity of the personal data contained in the records; the potential risk of harm from unauthorised use or disclosure of personal data; the purposes for which we process the personal data and whether we may be able achieve those purposes through other means.
We may make changes to this Policy from time to time. To ensure that you are always aware of how we use your personal data we will update the online version of this Policy from time to time to reflect any changes to our use of your personal data. We may also make changes to comply with changes in applicable law or regulatory requirements. Where it is practicable, we will notify you by other means prior to changes materially affecting you such as by posting a notice on our sites or sending you a notification. However, we encourage you to review this Policy periodically to be informed of any changes to how we use your personal data. This Policy was last amended on [date].