GTS Group Privacy Policy

Scope of application of this Policy
At GTS Group we are committed to respect and safeguard all private and confidential information which we obtain when dealing with any third parties, including but not limited to personal data of individuals (i.e. information relating to an identified or identifiable individual, i.e. a natural person).

GTS Group is composed of local companies providing telecommunication and data center services in Central and Eastern Europe, including Czech Republic, Hungary, Poland and Romania (“GTS Companies”).

This Privacy Policy (“Policy”) will help you understand what kind of information we collect in connection with the use or our websites, communication with third parties or other forms of interaction and provision of our services and how we process such information. 

The types of personal data GTS Companies may collect include details of your name, address, telephone number, e-mail address, fax number or any other professional information that may be provided to us. Each of the GTS Companies has its own privacy policy implemented based on local legal requirements. In the event of any conflict, such privacy policy of GTS Company will prevail over this Policy when you deal with particular GTS Company.

Web users and visitors must read carefully this Policy before sending any personal information and/or filing in any electronic form posted on this web site. By using GTS websites and/or by submitting personal data to us, you express your consent to the processing of your personal data in the manner provided in this Policy.  If you do not agree with this Policy, please do not provide us with your personal data.

Use of personal data
GTS Telecom SRL, member of the GTS Group, is committed to respect and safeguard all private and confidential information which we may obtain when dealing with third parties, including personal data, as defined by the provisions of Law 677/2001 concerning the protection of individuals with regard to the processing of personal data and the free movement of such data, as amended (the "Law").

We may collect personal data from you through the use of enquiry and registration forms, direct personal contact with you (for example, over the telephone) and when you send us e-mail messages reflective of your details.  We will only use your personal data in accordance with applicable laws and regulations and where such use is relevant to the interaction between you and GTS, for example to supply to you any of the agreed services, for invoicing, network management, to protect our rights and legitimate interests and in other instances where we are allowed to do so without your prior consent, or otherwise where your consent has been provided. GTS will not sell, trade or rent your personal data to others.

By this policy, you benefit, through the above details, of the right to information provided by art. 12 of the Law.

In accordance with the provisions of ANSPDCP President’s Decision ("Authority") No. 100/2007 for establishing the cases in which notification is not required for processing personal data, GTS Telecom SRL is exonerated from notifying the Authority, considering that the processing of personal data concerns the contact persons for public or private entities exclusively for professional and protocol activities, by keeping track of contact data.

Also, in certain situations, GTS Telecom SRL can act as the authorized person in the meaning of art. 3 letter f) of the Act.

Provision of products and services
We may use your personal data to fulfill your requests, process your orders or as otherwise may be necessary to perform or enforce the contract between you and GTS, to ensure the functionality and security of our products and services, to identify you and to prevent and investigate fraud and other abuses.

Development of services 
We may use your personal data to develop our services.  However, for the most part we only use aggregate and statistical information in the development of our services.  We may also use your personal data to personalize our offering and to provide you with service more relevant to you, for example, to make recommendations and to display customized content and advertising available services on our websites. We may combine personal data collected in connection with your use of a particular GTS service with other personal data we may hold about you, except where such personal data was collected for a different purpose.  We may create aggregate and statistical information based on your personal data. 

Communicating with you and marketing 
We may use your personal data to communicate with you, for example, to provide information relating to products or services you are using or to contact you for customer satisfaction surveys.  We may use your personal data for marketing or research purposes, for example, to conduct market research and we may, in accordance with applicable laws, contact you to inform you of new services or promotions we may offer.  Also, some of our products and services may be used to promote services of other companies.  However, GTS will not disclose your personal data to any other company for marketing purposes without your prior consent.

Use of "Cookies"
GTS may use "cookies" on its websites. A "cookie" is information that a website leaves on a hard drive of users’ computer, so that it can remember certain information about you when you next visit the website or a related website.  GTS will not use your personal data sent in a cookie for marketing purposes and will not share such personal data with third parties without your consent.  GTS may use cookie for statistic purposes. If it is your preference not to receive cookies from the websites of GTS, you can set your browser to warn you before accepting cookies and refuse the cookie when your browser alerts you to its presence.  You can also turn cookies off in your browser or delete installed cookies, but this may impair your web site experience.

Means of data processing and data security
GTS Companies have implemented appropriate technical and organizational information security measures to prevent unauthorized or unlawful disclosure or access to, or accidental or unlawful loss of or destruction, or alteration, transfer or unauthorized disclosure of or access to, or other damage to your personal data.  Such measures include the use of firewalls, secure server facilities, encryption, proper access rights management systems and processes, careful selection of processors and other technically and commercially reasonable measures to provide appropriate protection for your personal data against unauthorized use or disclosure.  Where appropriate, we may also take backup copies and use other such means to prevent accidental damage or destruction to your personal data.  These measures ensure an appropriate level of security in relation to the risks inherent in the processing and the nature of the personal data to be protected.  Your securely held personal data will only be accessible by selected authorized personnel of GTS.

Transfer of personal data
GTS is an international group of companies operating across multiple jurisdictions, commonly known as GTS Central Europe. Our products and services may be provided using resources and servers of these enumerated GTS Companies, therefore, your personal data may be transferred across borders outside the country where you use our services to one or more GTS Companies.  If the level of personal data protection in a specific country is not equal to that in the European Economic Area, we take steps to ensure that there is a legal basis for a transfer of data and that adequate protection is afforded your personal data as required under applicable laws.

Your rights to your personal data held by GTS
GTS will only keep your information for as long as we are required to do so by law, or as is relevant for the purposes for which the information was collected, however no longer than ten years. Your rights with respect of the collected and processed Personal Data are set specifically in the applicable local laws and regulations in relation to personal data protection.  You have the right to access your personal data as was collected and is being processed by GTS Companies and to request information on the processing of your personal data by GTS Companies.

In the event you wish to know what personal data we hold about you or you wish to replenish, rectify, anonymize or delete any incomplete, incorrect or outdated personal data, or you wish us to cease processing your personal data for any purpose, you may exercise such rights by contacting us through the contact points referred on this website.  Please note that, in some cases, particularly, if you wish us to delete or cease the processing of your personal data, this may also mean that we may no longer be able to continue provision of services to you.

Enforcement of this Policy
GTS has appointed a data protection officer.  Upon your request, we will be able to put you in contact with such officer.  If you have a question or enquiry about this Policy or a complaint about the way GTS has used your personal data, he or she will be able to assist you.

If you make a complaint to GTS data protection officer and your complaint is unable to be resolved to your complete satisfaction, your complaint will be passed to the Chief Legal Officer of GTS to be resolved.  If your complaint is still unable to be amicably resolved, it will be escalated.  Any finding of abuse of your personal data by GTS will be remedied as soon as reasonably practicable.