Privacy Policy

Introduction

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.

If you submit any information to us relating to a job role, including via careers@globalswitch.com, our separate Job Applicant Privacy Policy will apply to our processing of your personal information. A separate on-site privacy policy will apply if you are visiting our or our group companies’ premises.

Who We Are

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.

How We Collect Your Personal 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:

submitting information via our websites (including our customer and bondholder portals) located at www.globalswitch.com, www.globalswitch.cn, www.globalswitch.de, www.globalswitch.es, www.globalswitch.fr, www.globalswitch.hk, www.globalswitch.nl, globalswitch.service-now.com/gs_portal and any other website on which this policy, or a link to it, appears (our “Websites”);
following us and posting on our social media pages including our LinkedIn and Twitter pages; and
corresponding with us by phone, email or in another way using the contact information we make available online.

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 also automatically collect technical information, including anonymous data collected by the hosting server for statistical purposes, the Internet protocol (IP) address used to connect your computer or device to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform. Please see our Website Cookie Policy and Customer Portal Cookie Policy for further information.

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.

Categories of Personal Information We Process About You

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	Description
Behavioural	our activities, actions and behaviours.
Contact	information which can be used to address, send or otherwise communicate a message to you.
Correspondence	information contained in our correspondence or other communications with you or your work colleagues.
Identity	information contained in a formal identification document or other unique reference number relating to you, including any cookie identifications (IDs).
Legal	information relating to legal claims made by or against you or the organisation for whom you work or the claims process.
Marketing Preferences	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.
Monitoring	information relating to the surveillance or monitoring of your activities, including telephone call recordings and CCTV footage of activity within our and our group companies’ premises.

How We Use Your Personal Information

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

to create a profile of you and analyse this to obtain insight about market or industry trends, customer behaviours which inform our marketing strategy, and to enhance and personalise your experience as a visitor (as well as the marketing information we contact you with in the ways described in the paragraph below);
if you work for a corporate business, to contact you by email, post or by telephone with marketing information about our products and services. We may use your personal information to tailor or personalise the marketing communications you receive to make them relevant to you or the organisation for whom you work;
if you work for an unincorporated business, to contact you by post or by telephone with marketing information about our products and services. We may use your personal information to tailor or personalise the marketing communications you receive to make them relevant to you or the organisation for whom you work;

Processing necessary for us to support our customers and prospects with sales and other enquiries

to correspond and communicate with you when supporting you in connection with our products or services or your queries in relation to them;

Processing necessary for us to respond to changing market conditions and our customers’ needs

for market research in order to improve the products and services that we and other companies in our group deliver;
to notify you about changes to our business as well as our products and services;

Processing necessary for us to operate the administrative and technical aspects of our business efficiently and effectively

to administer our Websites and our social media pages and for our internal operations, including troubleshooting, testing and statistical reporting purposes;
for the detection and prevention of fraud and other criminal activities;
to verify the accuracy of information we hold about you and create a better understanding of you as a visitor to our Websites;
to authenticate your identity to allow you to access security-controlled areas of our Websites;
for network and information security purposes in order for us to take steps to protect your and our information and property against loss or damage, theft or unauthorised access and to share limited information with our customers (e.g. CCTV footage) so that they can do the same (see our on-site privacy policy for visitors for further information);
to comply with a request from you in connection with the exercise of your rights (for example where you have asked us not to contact you for marketing purposes, we will keep a record of this on our suppression lists in order to be able to comply with your request);
for training and monitoring purposes, including by reviewing audio recordings of inbound and outbound telephone calls that you make to us;
for the purposes of a corporate restructure or reorganisation or sale of our business or assets;
for efficiency, accuracy or other improvements of our databases and systems e.g. by combining systems or consolidating records we or other companies in our group hold about you;
to place and read cookies that are essential for our Websites to function properly, as described in our Cookies Policy;
to enforce or protect our contractual or other legal rights or to bring or defend legal proceedings;
for general administration including financial planning, control and reporting and managing your queries, complaints, or claims, to send service messages and to provide you with important information about our business.

Where required to comply with our legal obligations

We will use your personal information to comply with our legal obligations:

to assist any public authority or criminal investigatory body, where we are under a legal obligation to do so;
to identify you when you contact us;
to verify the accuracy of data we hold about you; and
to respond to and resolve your complaints in relation to our services.

Others Who May Receive or Have Access to Your Personal Information

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.

Please see section 10.2 of our Terms of Use for the details of our group companies with whom we may share your personal information, including their locations.

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.

Where We Store Your Personal Information

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:

ensuring the non-UK / non-EEA countries to which transfers are made have been deemed adequately protective of your personal information for the purposes of data protection law by the relevant bodies;
imposing contractual obligations on the recipient of your personal information using provisions formally issued by relevant bodies for this purpose. We use these provisions to ensure that your information is protected when transferred to our group companies outside UK and EEA; or
ensuring that the recipients are subscribed to ‘international frameworks’, such as the EU/UK-US Data Privacy Framework that aim to ensure adequate protection.

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.

How Long We Keep Your Personal Information For

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:

you exercise your right to require us to retain your personal information for a period longer than our stated retention period (see further Erasing your personal information or restricting its processing);
you exercise your right to have the information erased (where it applies) and we do not need to hold it in connection with any of the reasons permitted or required under the law (see further Erasing your personal information or restricting its processing below);
we bring or defend a legal claim or other proceedings during the period we retain your personal information, in which case we will retain your personal information until those proceedings have concluded and no further appeals are possible; or
in limited cases, existing or future law or a court or regulator requires us to keep your personal information for a longer or shorter period.

Security and Links to Other Sites

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.

Cookies

Like many other websites, our Websites use cookies. Cookies are small pieces of information sent to your computer or device and stored on its hard drive to allow our Websites to recognise you when you visit. Some of the cookies we use are necessary for our Websites to function properly whilst others are not essential but enhance your experience of our Websites or allow us to improve them by allowing us to obtain an overall view of visitor habits and visitor volumes to our Websites.

We request your consent for any non-essential cookies, which you can withdraw at any time. It is also possible to switch off cookies by setting your browser preferences. For more information on how we use cookies and how to switch them off on your device, please visit our Website Cookie Policy and Customer Portal Cookie Policy.

Automated Decision Making

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.

Your Rights

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.

Accessing your personal information

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.

Correcting and updating your personal 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.

Withdrawing your consent

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.

Objecting to our use of your personal information

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.

Erasing your personal information or restricting its processing

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.

Transferring your personal information in a structured data file ('data portability’)

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.

Complaining to a data protection regulator

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.

Changes to This Policy

This policy was last updated on 22 July 2024. 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.

Contact Us and Company Information

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.