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GDPR: DATA PRIVACY NOTICE

Introduction

Cerberus Networks Ltd ("We") are committed to protecting and respecting your privacy.
This policy (together with our terms and any other documents referred to in it) 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.
The rules on processing of personal data are set out in the General Data Protection Regulation (the “GDPR”). 

Definitions

Data controller - A controller determines the purposes and means of processing personal data.

Data processor - A processor is responsible for processing personal data on behalf of a controller.

Data subject – Natural person

Categories of data: Personal data and special categories of personal data

Personal data - The GDPR applies to ‘personal data’ meaning any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier (as explained in Article 6 of GDPR). For example name, passport number, home address or private email address. Online identifiers include IP addresses and cookies.

Special categories personal data - The GDPR refers to sensitive personal data as ‘special categories of personal data’ (as explained in Article 9 of GDPR). The special categories specifically include genetic data, and biometric data where processed to uniquely identify an individual. Other examples include racial and ethnic origin, sexual orientation, health data, trade union membership, political opinions, religious or philosophical beliefs.

Processing - means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Third party - means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.

Who are we?

In general Cerberus Networks is the data controller. This means we decide how your personal data is processed and for what purposes. Our contact details are: 

Cerberus Networks Ltd
9 Walmgate Road
Greenford
Middx
UB6 7LH

Tel: 0345 257 1333
Fax: 0345 257 1334

For all data matters contact Erik Carlson by the above means. 

For a minority of customers we may be considered a processor rather than a controller. Where this is the case additional terms apply which vary this Notice. 

The purpose(s) of processing your personal data

We use your personal data for the following purposes:

Cerberus’ provision of service to the customer, support of that service and billing.  Informing the customer about new products and services.

The categories of personal data concerned

With reference to the categories of personal data described in the definitions section, we process the following categories of your data:

  • Personal data: Data relating to individuals provided to Cerberus (eg contact data) and data derived from usage of the services.
  • Special categories of data: NONE
In most cases we have obtained your data directly from you, or from your employer, usually the party who is paying for the service.

What is our legal basis for processing your personal data? 

Personal data (article 6 of GDPR)
Our lawful basis for processing your general personal data:

Consent of the data subject; In rare cases, for instance marketing, we may buy in data for which there is demonstrable consent of the subject. This may include written consent or a recording of a telephone call where consent was provided.  
Processing necessary for the performance of a contract with the data subject or to take steps to enter into a contract For instance quoting for and subsequent supply of Broadband Internet Connectivity. Delivery of Equipment. Registration of a support or maintenance contract for equipment located with the data subject or other services provided to the data subject. 
Processing necessary for compliance with a legal obligation For instance compliance with law enforcement requests or court orders for data on the user of an IP address at a given time.
Processing necessary to protect the vital interests of a data subject or another person For instance Fraud Detection & Prevention, or Information & Systems Security.
Processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller For instance government agencies request for anonymised statistics. 
Processing necessary for the purposes of the legitimate interests of the data controller or a third party, except where such interests are overridden by the interests or fundamental rights or freedoms of the data subject For instance Fraud Detection & Prevention, or Information & Systems Security. Defence of Claims.

Sharing your personal data 

Your personal data will be treated as strictly confidential, and will be shared only as absolutely necessary. For instance limited contacts information must be supplied to Royal Mail or other logistics firms to deliver equipment. Contact data may be supplied to our telecoms partners (for instance BT Wholesale, Talktalk Business, Virgin Media Business) for the purposes of their providing service on our behalf to you. 

We absolutely will not sell your data to any 3rd Party. The only marketing use we may make of your data is marketing of our Services to you where there is a lawful basis to do so. 

How long do we keep your personal data?

We keep your personal data for no longer than reasonably necessary, for instance in order to quote you for a service, to serve you as a customer, in case of any legal claims/complaints; for safeguarding purposes etc.

Providing us with your personal data

We require your personal data as it is a requirement necessary to quote for some types of service, enter into a contract or provide services. If you do not wish to provide us with some or all of the data that is usually required we may not be able to provide you with some or all types of quotes for service, provide the service itself, or be able to enter into some types of contract.

Your rights and your personal data

  • Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data:
  • The right to request a copy of the personal data which we hold about you.
  • The right to request that we correct any personal data if it is found to be inaccurate or out of date.
  • The right to request your personal data is erased where it is no longer necessary to retain such data.
  • The right to withdraw your consent to the processing at any time where consent was the lawful basis for processing the data.
  • The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), (where applicable i.e. where the processing is based on consent or is necessary for the performance of a contract with the data subject and where the data controller processes the data by automated means)
  • The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing.
  • The right to object to the processing of personal data, (where applicable i.e. where processing is based on legitimate interests (or the performance of a task in the public interest/exercise of official authority); direct marketing and processing for the purposes of scientific/historical research and statistics).

Transfer of Data Abroad

We use a company in India who host staff in India who provide technical support, operations support and software development. Cerberus’ UK management team is responsible for hiring, training and managing these staff and they work as if part of our company, although legally they employed by the Indian Company. Minimal data are transferred to India. No payment data are ever transferred. All data transferred to India is done in a lawful manner under a binding contract with appropriate safeguards and meets the requirements set out in Chapter V of the GDPR.

Automated Decision Making

We use Experian to provide credit scores for new customers. Where the score is good account setup usually proceeds. Where the score is not good it is always reviewed by management and mitigating factors considered. 

Further processing

If we wish to use your personal data for a new purpose, not covered by this Data Privacy Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions. 

Changes to our Privacy Notice

Any changes we may make to our Privacy Notice in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our Privacy Notice.

How to make a complaint

To exercise all relevant rights, queries or complaints please in the first instance contact:

Erik Carlson
Cerberus Networks Ltd
9 Walmgate Road
Greenford
Middx
UB6 7LJ


If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioners Office on 03031231113 or via email https://ico.org.uk/global/contact-us/email/ or at the 
Information Commissioner's Office, 
Wycliffe House, 
Water Lane, 
Wilmslow, 
Cheshire, 
SK9 5AF

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