Legal and privacy policies
Introduction
Telecom Infra Project (TIP) is a collaborative telecom community. Launched in February 2016, TIP was started with the goal of accelerating the pace of innovation in the telecom industry.
TIP respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data and tell you about your privacy rights and how the law protects you.
This privacy policy is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.
1. Important Information and who we are
2. Data we collect about you
3. How we collect your personal data
4. How we use your personal data
5. Disclosures of your personal Data
6. International transfers
7. Data security
8. Data retention
9. Your legal rights
10. Glossary
1. Important Information and who we are
Purpose of this Privacy Policy
This privacy policy aims to give you information on how TIP collects and processes your personal data when you become a member, or when you attend our events, or use or apply to use our services as well as your use of this website. It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.
Controller
TIP is the controller and responsible for your personal data (referred to as “we”, “us” or “our” in this privacy policy). TIP is headquartered in Massachusetts, in the United States. This will mean that data you provide us will be processed outside the European Economic Area (EEA).
Privacy questions
If you wish to exercise any of your legal rights, please contact [email protected]
Telecom Infra Project
401 Edgewater Pl # 600
Wakefield, MA 01880
[email protected]
+1(781) 246-0500
You have the right to make a complaint at any time to the supervisory authority responsible for data protection. In the UK this is the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Changes to this privacy policy
This version was last updated on May 22, 2018.
We recognize that information privacy is an ongoing responsibility, and so we will update this Privacy Policy as we undertake new personal data practices or adopt new privacy policies. We will notify you of these changes.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Third-party links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
2. Data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes first name, last name or similar identifier, title, job title and photograph.
- Contact Data includes work address, email address and telephone numbers.
- Financial Data includes bank account and payment card details.
- Technical Data includes internet protocol (IP) address, the region or general location where your computer or device is accessing the internet, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
- Profile Data includes your username and password, the Project Groups you join, your interests, preferences, and feedback responses.
- Usage Data includes information about how you use our website and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
- Member Contribution data includes information about you and which is posted on message boards, chat rooms or other message areas or in feedback.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
Data we do not collect about you
We do not collect:
- information about children;
- any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data);
- information about criminal convictions and offenses.
3. How we collect your personal data
We use different methods to collect data from and about you including through:
Direct interactions You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email, fax, in person, or otherwise. This includes personal data you provide when you:
- apply to become a member;
- submit any items to us;
- create an account on our website;
- complete a grant application;
- request marketing to be sent to you;
- register for, speak at, or attend TIP Summits or virtual events; or
- give us some feedback.
Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our Cookie Policy for further details.
Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
- Technical Data from the following parties:
(a) analytics providers [such as Google based outside the EU];
(b) advertising networks such as Google Ads based outside the EU; and
(c) search information providers such as Google based outside the EU.
- Identity and Contact Data from the TIP Community based both inside and outside of the EU.
- Membership Contribution Data from other members or users of our website based both inside and outside of the EU.
4. How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where you have asked us for information or to contact you.
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
More information about the types of lawful basis that we will rely on to process your personal data is included below.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Purpose/Activity
|
Type of data
|
Lawful basis for processing including basis of legitimate interest
|
| To process your application to become a member and to register you as a new member |
(a) Identity
(b) Contact
(c) Financial
(d) Marketing and Communications |
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (for the administration of our community) |
| To process and fulfill requests and enquiries made by you through our contact form |
(a) Identity
(b) Contact
(c) Financial
(d) Marketing and Communications |
(a) Necessary for our legitimate interests (for the administration of our community)
(b) Performance of a contract with you |
| To process grant applications |
(a) Identity
(b) Contact
(c) Profile |
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (for the administration of our community) |
To manage our relationship with you, including:
(a) Notifying you about changes to our terms or privacy policy
(b) Notifying you of Project Groups and Working Groups
(c) Notifying you of events and TIP Summits |
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Membership Contribution |
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how our members use our website and services and interact) |
| To provide you with website features and functionality such as message boards, chat rooms or other message areas of the ability to leave feedback for other members. |
(a) Identity
(b) Profile
(c) Usage
(d) Membership Contribution |
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (for the administration of our website) |
| To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) |
(a) Identity
(b) Contact
(c) Technical |
(a) Necessary for our legitimate interests (for running our community, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise)
(b) Necessary to comply with a legal obligation |
| To deliver relevant website content to you, including our blogs, and measure or understand the effectiveness of this content |
(a) Identity
(b) Contact
(c) Usage
(d) Profile
(e) Marketing and Communications
(f) Technical |
(a) Necessary for our legitimate interests (to study how our website users or members use our website and services, to develop them and to grow our community) |
| To use data analytics to improve our website, marketing, user/member relationships and experiences |
(a) Technical
(b) Usage |
Necessary for our legitimate interests (to keep our website updated and relevant; to develop our community and to inform our marketing strategy) |
| To make suggestions and recommendations to you about events, groups or services that may be of interest to you |
(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile |
Necessary for our legitimate interests (to develop our services and grow our community) |
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:
Promotional offers from us
We may use your Identity, Contact, Technical and Usage Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or have not opted out of receiving that marketing.
Third-party marketing
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
Opting out
You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.
Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.
Change of purpose
We will only use your personal data for the purposes 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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data 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 data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. Disclosures of your personal data
We do not sell personal information to anyone. TIP will only share your personal data with the parties set out below for the purposes set out in the table (at paragraph 4) above:
- Internal Third Parties as set out in the Glossary.
- External Third Parties as set out in the Glossary.
- Third parties to whom we may choose to sell, transfer, or merge parts of our company or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. International transfers
TIP is based in the United States. Information we collect from you will be processed by us in the United States. This is not a regulated data transfer for data protection purposes. We will however always protect the privacy and security of your personal data and use your personal data only as described in this privacy policy.
Where we share information globally, both internally within the TIP Community and externally with External Third Parties, information controlled by TIP will be transferred or transmitted to, or stored and processed in, the United States or other countries outside the European Economic Area (EEA) for the purposes as described in this privacy policy. These data transfers are necessary to provide the services.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
- Where we use certain service providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
7. Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. We update and test these security measures on an ongoing basis. In addition, we restrict access to your personal data to those employees who need to know that information to provide benefits or services to you. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. Data retention
We will only retain your personal data for the duration of your membership, business relationship, or other active engagement (e.g., subscription to our newsletters, or attendance at TIP conferences and events) with TIP and for a reasonable period of time afterwards (typically one to two years) (unless you request erasure sooner), after which we will delete the personal data we hold with the following exceptions:
- Content you have posted in our discussion forums and other collaboration spaces (e.g., Workplace by Facebook) that are visible to other participants of such collaboration spaces may continue to be visible indefinitely.
- If you have consented to receive marketing communications from us, we may continue to use your contact information for such communications until you revoke your consent. We may retain some of your personal data to the extent required under applicable laws and regulations and to the extent necessary to document our compliance with such laws and regulations.
- We may retain some of your personal data to the extent necessary for tax, accounting, financial reporting, and auditing purposes.
- We may need to retain some of your personal data indefinitely to support the services we offer. For example, if you have unsubscribed from marketing communications or opted out of certain types of processing (i.e. a suppression list), we would need to retain your unsubscribe or opt-out request indefinitely in order to comply with such request.
In some circumstances you can ask us to delete your data: see “Your legal rights” below for further information.
In some circumstances we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further policy to you.
9. Your legal rights
You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of your legal rights, please contact TIP’s Data Protection Officer.
10. Glossary
LAWFUL BASIS
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
THIRD PARTIES
Internal Third Parties:
TIP community means our members, operators and sponsors within the TIP community as listed on our website here and updated from time to time.
External Third Parties:
Service providers acting as processors based outside of the EU who provide the following services on our behalf:
- CRM platform: Salesforce.com, Inc, a company based in the US.
- Mail Server: Rackspace US, Inc., a company based in the US
- Collaborative platform: Workplace by Facebook, Inc., a company based in the US; Atlassian Corporation Plc, a company based in Australia; Slack Technologies, Inc.,, an company based in the US; LogMeIn, Inc., a company based in the US; Zoom Video Communications, Inc., a company based in the US; Workplace by Facebook, Inc, a company based in the US; Discourse, an open source internet forum developed by Civilized Discourse Construction Kit, Inc.
- Hosting: Azure by Microsoft, Inc., a company based in the US; GitHub, Inc, a company based in the US; Fancy Chap, Inc. dba Flywheel, a company based in the US
- Direct marketing: Rocket Science Group (trading as MailChimp), a company based in the US; SVMK Inc., dba SurveyMonkey, a company based in the US
- Event management: vandePoel Productions USA LLC, a company based in the US; OneClipboard, Inc., (trading as Splash), a company based in the US; Hopin, a company based in the UK;
- Business/document management: Quip by Salesforce, Inc., a company based in the US; DocuSign, Inc., a company based in the US; Brandfolder, Inc., a company based in the US; Google Drive by Google, Inc., a company based in the US; Dropbox, Inc., a company based in the US
- Identity/security management: Auth0, Inc., a company based in the US.
- Rybbon as TIP Data Processor
Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based either in or outside the EU and outside of the EU who provide consultancy, banking, legal, insurance and accounting services.
HM revenue & customs, regulators and other authorities acting as processors or joint controllers based either in or outside the EU who require reporting of processing activities in certain circumstances.
Other members or website users acting as joint controllers based both inside and outside of the EU as part of us operating message boards, chat rooms or other interactive services.
