We are committed to protecting and respecting your privacy.
Everyone has rights with regard to the way in which their personal data is handled. During the course of our activities we will collect, store and process personal data about our customers, suppliers and other third parties, and we recognise that the correct and lawful treatment of this data will maintain confidence in the organisation and will provide for successful business operations.
This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
For the purpose of UK data protection laws, the data controller is L3 Communications ASA Limited, Rusint House, Harvest Crescent, Fleet, GU51 2QS, hereinafter refer to as L3 ASA.
Data protection principles
When processing your information, we must comply with the six enforceable principles of good practice. These provide that your personal data must be:
- processed lawfully, fairly and in a transparent manner,
- processed for specified, explicit and legitimate purposes,
- adequate, relevant and limited to what is necessary,
- accurate and kept up-to-date,
- kept for no longer than is necessary, and
- processed in a manner than ensures appropriate security.
Information you give to us
You may give us information such as your name, address, email address, phone number, signature by:
- filling in forms on our website,
- applying for a job on our website or through 3rd parties such as recruitment agencies,
- participating in discussion boards or other social media functions on our website,
- entering a competition, promotion or survey organised by us,
- giving us your business card, or
- corresponding with us by phone, email, letters or otherwise.
For job applicants you may give us information such as educational and employment history, date of birth, marital status, nationality, other information contained on your CV or other documents or information you submit to us, information to confirm your identity and right to work, such as a copy of your passport.
We may use the information you give to us for a number of different purposes. For each purpose, we are required to confirm the ‘legal basis’ that allows us to use your information, as follows:
|Purposes for which we will use the information you give to us||Legal basis|
|To register you as a new customer, supplier or other party with whom we enter into a contract||It will be necessary in order to take steps at your request prior to entering into a contract between you and us.|
|To register and process your job application||It will be necessary for our legitimate business interests, namely to enable us to comply with our legal and regulatory obligations and to make recruitment decisions, also to prevent and detect fraud and other wrongdoing, to establish exercise or defend our legal rights.|
|To process your instructions and provide goods and services to you||It will be necessary for the performance of the contract between you and us|
|In cases where you are acting as a representative of a company or organization, we may process your information in the course of communicating with that company or organisation, and providing goods and services to that company or organisation||It will be necessary for our legitimate business interests, namely with a view to performing our contractual obligations|
|In cases where you have supplied your contact information to us with an expectation that we may contact you, we may do so in the course of communicating with your company or organisation with a view to providing goods and services to that company or organization||It will be necessary for our legitimate business interests|
|To collect and recover money owed to us||It will be necessary for our legitimate business interests, namely to ensure we receive payment for goods and services we have provided|
|To communicate with you via telephone, email or letter or otherwise||It will be necessary for our legitimate business interests, namely to conduct day-to-day business communications with you as a representative of your company or organisation.|
We will only use your personal information for the purpose(s) for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
It is also a contractual requirement for you to provide us with certain information. If you do not provide us with that information, we may not be able to continue to provide goods and services to you, or the company or organization you represent.
All other information you give us is given entirely as your discretion. If you do not provide that information, then we may not be able to make contact with you in order to discuss legitimate business interests.
Information we collect about you from other sources
When you visit our website, we may collect information about you such as; the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform.
When you visit our premises, we may collect information about you such as; CCTV footage through our security cameras in and around our building, your name, the company or organisation that you represent, and your vehicle registration information.
We may also collect information about you by conducting searches of public records (e.g. Companies House, electoral roll, DVLA database, Dun and Bradstreet), or in the process of confirming your identity via our online ID verification provider.
We may use the information we collect about you for a number of different purposes. For each purpose, we are required to confirm the ‘legal basis’ that allows us to use your information, as follows:
|Purposes for which we will process the information||Legal basis for the processing|
|To administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes, to allow you to participate in interactive features of our service, when you choose to do so, to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you and to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them||It will be necessary for our legitimate business interests to ensure you receive the best experience possible when accessing and using our website.|
|To obtain further information about you, any organisation you represent, with a view to us entering into a contract with you or the organisation you represent||It will be necessary for our legitimate business interests to ensure we are fully aware of all issues relating to the matter that is the subject of the legal services you have requested from us.|
|To maintain a secure and safe working environment||In some instances, it will be necessary in order for us to comply with the legal obligations placed on us under UK employment and/or health and safety law. Where that is not the case, it will be necessary for our legitimate business interests to ensure that we have a safe environment for our staff to work in|
You can change the settings on your internet browser to restrict the amount of information that we can collect when you visit our website. If you do not allow us to collect this information, then we may be unable to offer you the best experience possible when accessing and using our website.
‘Special category’ data
During the course of dealing with you, we may collect information about you relating to your criminal convictions, or certain types of genetic or biometric data (such information is known as ‘special category’ data).
This is most likely to occur, for example, if during the course of your duties as a supplier of products or services to us, you are required to work unsupervised in a restricted area.
We will use any ‘special category’ data that we collect about you:
- provided we have your explicit consent to use it, or
- where we believe that we need to use that data to protect your vital interests where you are not able to provide us with your explicit consent, or
- where you have previously made that data public knowledge, or
- where it is necessary for reasons of substantial public interest (for example, detecting or preventing crime), or;
- where it is necessary to protect the public from improper conduct, incompetence, mismanagement or failures in service, or;
- we need to use that data to establish, exercise or defend legal claims.
Disclosure of your information
You agree that we have the right to share your personal information with:
- HM Revenue & Customs, the Information Commissioner’s Office and any other regulatory bodies which govern any part of our business;
- our professional advisers (including solicitors, bankers and auditors);
- our auditors and quality assurance assessors;
- selected third parties including; business partners, customers, suppliers and sub-contractors to the extent we reasonably consider that it is in your best interests for us to do so, or it is necessary for our legitimate business interests, analytics and search engine providers that assist us in the improvement and optimisation of our site
We will disclose your personal information to third parties:
- in the event that we enter into negotiations to sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets;
- if L3 ASA or substantially all of its assets are acquired by a third party, in which case personal data held by it about you will be one of the assets transferred to the third party; or
Identifying you as a customer
If you are a business customer, we may identify you as a customer of the firm in our marketing material or in legal directories, unless specifically stated otherwise per contract. We will never publicly disclose any confidential information about your legal matters without having obtained your prior consent. If you do not agree to us identifying you as a customer of the firm, please notify us in writing to the address detailed at the top of this policy, or email us at firstname.lastname@example.org
Where we store your personal data
All information you provide to us is stored on our secure internal network folders on servers in the United Kingdom or the United States.
We will take all steps reasonably necessary to ensure that your data is treated securely, including taking the following safeguards:
- Entry controls. Our buildings have restricted access with security controls on multiple points throughout each building
- Secure lockable desks and cupboards. Desks and cupboards are kept locked when not in use if they hold confidential information of any kind.
- Our internal policies require that individual monitors do not show confidential information to passers-by and that users lock or log-off from their computer when it is unattended.
- Transferring data outside the EEA. Should we have a requirement to transfer your personal information outside the United Kingdom, we ensure a similar degree of protection is afforded to it by ensuring that we apply appropriate safeguards (either by transferring data only to recipients in the European Union, to recipients in countries approved by the European Commission, to recipients that are party to the EU-US Privacy Shield, or by using specific contracts approved by the European Commission).
Some of the data that we collect from you may be transferred to, and stored at, a destination outside the United Kingdom. It may also be processed by personnel operating outside the United Kingdom who work for us, our group companies or for one of our suppliers. This includes staff engaged in, among other things, the fulfilment of your orders, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. If you are concerned about the levels of data security in any of those countries, please let us know and we will endeavour to advise what steps will be taken to protect your data when stored overseas.
You may request the indication of the countries to which the personal information is transferred as well as the specific privacy measures adopted by L3 ASA.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
How long we will store your personal data
The length of time that we will store your data will depend on the ‘legal basis’ for why we are using that data, as follows:
|Legal basis||Length of time|
|Where we use/store your data because it is necessary for the performance of the contract between you and us||We will use/store your data for as long as it is necessary for the performance of the contract between you and us|
|Where we use/store your data because it is necessary for us to comply with a legal obligation to which we are subject||We will use/store your data for as long as it is necessary for us to comply with our legal obligations|
|Where we use/store your data because it is necessary for our legitimate business interests||We will use/store your data until you ask us to stop. However, if we can demonstrate the reason why we are using/storing your data overrides your interests, rights and freedoms, then we will continue to use and store your data for as long as it is necessary for the performance of the contract between you and us (or, if earlier, we no longer have a legitimate interest in using/storing your data)|
|Where we use/store your data because you have given us your specific, informed and unambiguous consent||We will use/store your data until you ask us to stop|
You have various legal rights in relation to the information you give us, or which we collect about you, as follows:
- You have a right to access the information we hold about you free-of-charge, together with various information about why and how we are using your information, to whom we may have disclosed that information, from where we originally obtained the information and for how long we will use your information.
- You have the right to ask us to rectify any information we hold about you that is inaccurate or incomplete.
- You have the right to ask us to erase the information we hold about you (the ‘right to be forgotten’). Please note that this right can only be exercised in certain circumstances and, if you ask us to erase your information and we are unable to do so, we will explain why not.
- You have the right to ask us to stop using your information where: (i) the information we hold about you is inaccurate; (ii) we are unlawfully using your information; (iii) we no longer need to use the information; or (iv) we do not have a legitimate reason to use the information. Please note that we may continue to store your information or use your information for the purpose of legal proceedings or for protecting the rights of any other person.
- You have the right to ask us to transmit the information we hold about you to another person or company in a structured, commonly-used and machine-readable format. Please note that this right can only be exercised in certain circumstances and, if you ask us to transmit your information and we are unable to do so, we will explain why not.
- Where we use/store your information because it is necessary for our legitimate business interests, you have the right to object to us using/storing your information. We will stop using/storing your information unless we can demonstrate why we believe we have a legitimate business interest which overrides your interests, rights and freedoms.
- Where we use/store your data because you have given us your specific, informed and unambiguous consent, you have the right to withdraw your consent at any time.
- You have the right to object to us using/storing your information for direct marketing purposes.
If you wish to exercise any of your legal rights, please contact us by writing to the address detailed at the top of this policy, or by emailing us at email@example.com
You also have the right to lodge a complaint with the Information Commissioner’s Office if you believe we are not complying with the laws and regulations relating to the use/storage of the information you give us, or that we collect about you.
We do not use automated decision-making processes.
Changes to our policy
Any changes we make to our policy in the future will be posted on our website and, where appropriate, notified to you by post, email or via social media. Please check our website frequently to see any updates or changes to our policy.
We take your privacy and experience of our website and services seriously.
Our website provides information about our company, products and services. We want to make your experience easy, safe and reliable. All over the internet, websites sometimes place small amounts of information on your computer to help tailor your experience. These include small files known as cookies. They cannot be used to identify you personally, nor can they retrieve information outside of the realm in which they are set.
These cookies are used to make our website easier to use, for example;
- to gauge interest in our services and information about our company
- using the information gathered to identify how users navigate the site so that the site’s structure can be improved to provide popular information more quickly
If you wish to restrict or block the cookies which are set by our website, or any other website, you can do this through your browser settings. Please be aware that restricting cookies may impact the functionality of most websites.
- Webnetism_cookie. This cookie is left on your computer when you dismiss the cookie alert we show on our website. This allows us to ensure you are not reminded about cookies when you next visit our website.
- NET_SessionId. General purpose cookie, could be used for anything.
- Microsoft’s explanation of this cookie
Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org
Questions, comments and requests regarding this policy are welcomed. To do so, write to the address detailed at the top of this policy, or by emailing us at firstname.lastname@example.org