Privacy Notice and Consent
This notice explains how information about you is used.
The Company will be the data controller and can be contacted as follows:
Data Protection Manager, DOCOMO Europe Limited, 1 King William Street, London EC4N 7AR
Data Protection Manager, firstname.lastname@example.org
+44 (0)33 0588 7700
The information we gather
The Company gathers certain information about you. Information about you is also used by our affiliated entities and group companies, including NTT DOCOMO, INC. in Japan (our ‘group companies’). When we do so we are regulated under the UK GDPR (as defined in the Data Protection Act 2018) and other UK data protection legislation and we are responsible for that personal information for the purposes of those laws.
In this notice, references to ‘we’ or ‘us’ means the Company and our group companies.
Information that we gather about you may include without limitation your name and contact details. The provision of information by you is entirely voluntary. However, should you choose not to provide certain data to us, such as documents required under money laundering regulations, then we may not be able to enter into a business relationship.
We may also obtain information about you from third parties, such as your employer and our group companies.
We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
The legal basis for
The processing will take place based on our legitimate interests. Our legitimate interests are that we are carrying or may carry on business with your employer. There is a limited privacy impact on you, and we think that you will expect that we will process your data in this way.
Where you have given consent to any data processing, you have the right to withdraw that consent at any time.
Systems used to
We gather information directly from you and also via our technical systems. These may include, for example, our:
- computer networks and connections
- communications systems
- intranet and Internet facilities
- telephones, voicemail, mobile phone records
Reasons for processing
We process information about you for the following reasons:
- to provide our services
- compliance with legal, regulatory and corporate governance obligations and good practice
- gathering information as part of investigations by regulatory bodies or in connection with legal proceedings or requests
- ensuring business policies are adhered to
- operational reasons, such as recording transactions, training and quality control
- ensuring the confidentiality of commercially sensitive information
- security vetting, investigating claims, complaints and allegations of criminal offences
- statistical analysis
- preventing unauthorised access and modifications to systems
- marketing our business and those of our group
- analysing purchasing preferences and improving services
- providing customer services
Disclosures and exchange of information and transfers outside the UK
Information may be held at our offices and those of our group companies, and service providers, representatives and agents as described above. Information may be transferred internationally to Japan and other countries around the world, including those without data protection laws equivalent to those in the UK, for the reasons described above. We have advanced security measures in place to seek to ensure that there is appropriate security for information we hold including those measures detailed in our Information Management Policy, which is available on request. We also have in place to protect the data being transferred internationally, as per UK GDPR Article 46(2) but this may not be the case where there are adequacy regulations in respect of the country to which the data is transferred (the existence of adequacy regulations means that the country is deemed to provide an adequate level of protection for the data).
If you would like further information please contact our Data Protection Manager (see above). We will not otherwise transfer your personal data outside of the UK or to any organisation (or subordinate bodies) governed by public international law or which is set up under any agreement between two or more countries.
Your data will be held in accordance with the Company’s retention policy, which is available on request. In general, your data will be stored for the duration of your relationship with us, plus 6 years.
Please contact the Data Protection Manager if you would like to correct or request (in accordance with applicable law) information that we hold relating to you or if you have any questions in relation to the above.
You have a number of important rights, which can be exercised free of charge. You have the right to request:
- access to your personal information and to certain other supplementary information that this Privacy Notice is already designed to address
- require us to correct any mistakes in your information which we hold
- require the erasure of personal information concerning you in certain situations
- receive the personal information concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations
- object at any time to processing of personal information concerning you for direct marketing
- object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you
- object in certain other situations to our continued processing of your personal information
- otherwise restrict our processing of your personal information in certain circumstances.
Where you have given consent to any data processing, you have the right to withdraw that consent at any time. We will not do anything with your data not outlined in this notice.
For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the UK GDPR.
If you would like to exercise any of these rights, please contact our Data Protection Manager in writing (see above), providing enough information to identify you and let us know which information to which your request relates.
If you are not satisfied with any complaint you have with us, you also have the right to make a complaint to the Information Commissioners Office, which is the supervising authority in the UK in relation to data processing. You can contact the Information Commissioner at ico.org.uk/concerns/ or by telephone: 0303 123 1113 for further information about your rights and how to make a formal complaint.
We may change this privacy notice from time to time, when we do we will inform you via e-mail.
If you have any concerns regarding our disclosure and international transfer of information as described above, please send the Company an email to let us know so we can address your concerns.