Privacy Policy

ONLINE PRIVACY POLICY

Effective Date: 25 May 2018

1. Your Privacy

At Trilogy Communications Limited (“Trilogy”, “we” or “us”), we believe that you have a right to know our practices regarding the information we collect when you visit our websites and what type of information is collected. The statements contained herein apply to your visits to any of our websites or online access points such as widgets and mobile applications operated by Trilogy (collectively, the “Site”), which includes www.trilogycomms.com/en.

While Trilogy does not generally require that you provide us with personally identifiable information in order to visit and use the Site, in order to participate in some activities it will be necessary for you to provide this information.

For the purposes of the EU General Data Protection Regulation 2016 (the “GDPR”) the Data Controller is Trilogy Communications Limited a company incorporated in England and Wales, with company number 01897343 and registered address at Walworth Industrial Estate, 26 Focus Way, Andover, Hampshire, SP10 5NY;

If you have any questions or concerns about this Privacy Policy, please contact us using the Contact Us section on our Site.

2. Collection of Information: Cookies; Personal Information

When you visit the Site, Trilogy servers automatically receive and record information on our server logs from your browser or mobile platform, including but not limited to your IP address, cookie information and the page you requested. We do not treat this data as personally identifiable information, except where we are required to do otherwise under applicable law. Unless otherwise stated in this Privacy Policy, Trilogy only uses this data in aggregate form to understand visitor traffic patterns through the Site for the purposes of enhancing its usability.

The Site stores “cookies” for analytical purposes, in order to be able to offer you a more comprehensive function range and make the use of the Site more convenient. “Cookies” are small files stored on your computer with the aid of your browser. When you access the Site from certain jurisdictions you will receive a clear notice advising you that we intend to use “cookies” and your continued use of the Site will constitute your agreement to us placing those cookies as described in our Cookies Policy.

We do not use technology that recognizes a “do-not-track” signal from your web browser.

Additionally, Trilogy will ask you to provide "personal information" meaning individually identifiable information such as your e-mail address, name, mailing address, telephone number, fax number or persistent identifier (such as a customer number held in a cookie) associated with individually identifiable information, to enable you to participate in contests, to complete a registration form or to order products and services using the Site. This includes information that you give us by filling in forms on the Site or by corresponding with us by phone, e-mail or otherwise. Trilogy may combine the personal information you provide on the Site with other information we collect from you offline so that we can more effectively tailor the Site, our products and services and our offerings to you.

If you provide Trilogy with personal information, you have the right, on reasonable prior notice, to inspect, change, amend or delete such personal information. Instructions on how to update personal information will be given at the point of data collection.

Unless you instruct us otherwise, Trilogy will provide you information about products, services, promotions, contests or other activities or offerings that may be of interest to you. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your personal information or by contacting us using the Contact Us section on our Site

3. Security

Trilogy takes steps to maintain the security of your personal information and prevent unauthorized access to it through the use of appropriate technology and internal procedures, but Trilogy cannot guarantee that unauthorized access will never occur.

4. Children’s Privacy

Trilogy does not knowingly collect personal information from children under the age of 13. If we learn that we have collected personal information of a child under the age of 13, we will delete that data from our systems.

5. How We Use Your Personal Information

We use your personal information according to the terms of the Privacy Policy in effect at the time of our use. We will only process your personal information, including sharing it with third parties, where (1) you have provided your consent which can be withdrawn at any time, (2) the processing is necessary for the performance of a contract to which you are a party, (3) we are required by law, (4) processing is required to protect your vital interests or those of another person, or (5) processing is necessary for the purposes of our legitimate interests, provided your interests and fundamental rights do not override those interests.

We will use your personal information for the following purposes:

  • to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;
  • to respond to your questions and provide related customer services;
  • to provide you with information about other goods and services we offer that are similar to those that you have already purchased, provided you have not opted-out of receiving that information;
  • to provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you, provided you have given your consent;
  • to notify you about changes to our service; and
  • to ensure that content from our site is presented most effectively for you and your computer.
  • to administer our Site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
  • to improve our site to ensure that content is presented most effectively for you and your computer;
  • as part of our efforts to keep our site safe and secure;
  • 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.

6. When We Share Your Personal Information

Where necessary, we will share your personal information for the purposes described in this Privacy Policy with:

  • a member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006;
  • business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you;
  • and search engine providers that assist us in the improvement and optimisation of our site;
  • reference agencies to assess your credit score where this is a condition of us entering into a contract with you; and
  • third-party companies and individuals to help us provide, analyse, and improve the site and our services (including but not limited to data storage, maintenance services, database management, web analytics and payment processing).

We will only transfer your personal information to trusted third-parties who provide sufficient guarantees in respect of the technical and organisational security measures governing the processing to be carried out and who can demonstrate a commitment to compliance with those measures.

Where third parties are processing personal information on our behalf, they will be required to agree, by contractual means or otherwise, to process the personal information in accordance with the applicable law. This contract will stipulate, amongst other things, that the third party and its representative shall act only on our instructions, or as permitted by law.

We will not transfer personal information, relating to individuals within the European Economic Area (“EEA”), to group companies or third parties (i.e. those outside of our group), located outside of the EEA without ensuring adequate protection under European law.

Where a third party is located in a country not recognised by the EU Commission as ensuring an adequate level of protection, we will take appropriate steps, such as enforcing standard contractual clauses recognised by the EU Commission, to safeguard your personal information and to ensure legally enforceable remedies are available.

Personal information will be shared with members of our group outside of the EEA, including our ultimate holding company HM Electronics, Inc. which is based in the United States, for the purposes described in this Privacy Policy. For transfers to HM Electronics, Inc., we utilise standard contract clauses recognised by the European Commission. If you would like to obtain a copy of the standard contract clauses, please contact us using the Contact Us section on our site.

We may also disclose your personal information to third parties:

  • the event that we sell or buy any business or assets, in which case we will disclose your personal information to the prospective seller or buyer of such business or assets;
  • Trilogy or substantially all of its assets are acquired by a third party, in which case personal information held by it about its customers will be one of the transferred assets; or
  • we are under a duty to disclose or share your personal information in order to comply with any legal obligation, or in order to enforce or apply our online terms and other agreements; or to protect the rights, property, or safety of Trilogy, our customers, or others. This includes exchanging information with other companies and organisations for fraud protection and credit risk reduction.

7. Links

The Site contains links to other Internet sites on the World Wide Web. Trilogy provides such links for your convenience only, and Trilogy is not responsible for the content of any website linked to or from the Site.

Links from the Site to any other website do not mean that Trilogy approves of, endorses or recommends that website. Trilogy disclaims all warranties, express or implied, as to the accuracy, legality, reliability or validity of any content on any other website.

8. Your Individual Rights

You have the right to ask us not to process your personal information for marketing purposes. We will inform you (before collecting your personal information) if we intend to use your personal information for such purposes or if we intend to disclose your information to any third parties for such purposes.

You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your personal information or by contacting us using the Contact Us section on our Site.

Under the GDPR, in certain circumstances, you have the right to: (a) request access to any personal information we hold about you and related information (“Subject Access Request”), (b) obtain without undue delay the rectification of any inaccurate personal information, (c) request that your personal information is deleted provided the personal information is not required by Trilogy for compliance with a legal obligation under European Union or Member State law or for the establishment, exercise or defence of a legal claim, (d) under certain circumstances prevent or restrict processing of your personal information, except to the extent processing is required for the establishment, exercise or defence of legal claims, and (e) under certain circumstances, request transfer of your personal information directly to a third party where this is technically feasible.

In addition, where you believe that Trilogy has not complied with its obligation under this Privacy Policy or European law, you have the right to make a complaint to an EU Data Protection Authority, such as the UK Information Commissioner’s Office.

You can exercise any of these rights by contacting us using the Contact Us section on our site.

9. Retention of Personal Information

We will only retain your personal information, in a form which permits us to identify you, for as long as necessary to fulfil the purposes we collected it for. We will retain and use your personal information as necessary to satisfy any legal, accounting or reporting requirements, to resolve disputes or to enforce our agreements and rights. In line with this Privacy Policy, we will either securely delete or anonymize your personal information so that it cannot be linked back to you.

10. Policy Governs Use; Changes to Privacy Policy

This Privacy Policy governs the use of any information collected on the Site while it is in place. Trilogy reserves the right to change this Privacy Policy at any time, so please re-visit this page as often as you wish. In case of any material change, we will make a notation near the "Privacy Policy" link on the home page of the Site. Changes to this Privacy Policy are effective at the time they are posted to the Site, and your continued use of this Site after posting will constitute acceptance of, and agreement to be bound by, those changes.

11. Questions

If you have any questions or comments about our personal information practices or about this Privacy Policy or any statements herein, please contact us using the Contact Us section on our Site.

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