Revised September 27, 2019
ST Engineering iDirect, Inc. dba iDirect and ST Engineering (Europe) CY NV (collectively referred to as “iDirect”), and its affiliates ( “we,” “us,” or “our”), respect the privacy of your information and Personal Data that we collect through websites operated by us from which you are accessing this Privacy Notice (“Notice”), through our social media pages and apps, other services provided by us both online and offline, when you use www.idirect.net or www.newtec.eu (“Websites”), when you purchase our satellite products or when you use our professional services (“Services”). “Personal Data” is information that identifies you as an individual or relates to an identifiable individual, including: name, title, company name, job function, expertise, postal address, telephone number, picture or email address.
This Notice applies to iDirect and any entities doing business under the iDirect name worldwide which collect, process and/or store information or personal data that is governed by the EU General Data Protection Regulation (“GDPR”) (for example, if you reside in the EU). iDirect is the controller for your Personal Data collected through our Websites and Services.
This Privacy Notice explains how we collect and use information or personal data that you provide via our Websites when you sign up, download content, register for events or webinars or purchase products or Services, as well as how you can exercise your rights in respect of that data.
This Privacy Notice does not apply to the practices of third parties that iDirect does not own or control, or to individuals that iDirect does not employ or manage. The personal data processing of third parties not controlled by us is governed by the privacy policies and procedures of those third parties. We may make changes to this Privacy Notice from time to time and will post any changes to this Notice on our website. If we make any material changes to this Notice we will try to provide you with reasonable notice about the changes, for instance by posting a prominent notice on our Website or through your email address we have on record. Where required by law, we will obtain your consent or give you the opportunity to opt out of such changes.
You may request a copy of this Notice by emailing email@example.com
TYPES OF INFORMATION WE COLLECT
We collect, process and retain Personal Data from you and any device you may use when you use or interact with our Website or Services, and in the ways described below.
Personal Data You Provide. The Personal Data you provide us helps us learn more about, and provide you with, the use of the Website or Services. We collect Personal Data that you submit to us voluntarily in the course of correspondence, registration and as otherwise identified below. We receive and store Personal Data you enter on our Services or give us in any way including questions or comments you submit via our online forms or fill out a request form such as a survey or contact request. If you submit any Personal Data relating to other people to us or to our service providers in connection with the website you represent that you have informed these third parties about the content of this privacy notice, and have the authority to submit Personal Data relating to other people and to permit us to use the information in accordance with this Privacy Notice.
We also collect and store Personal Data you may provide when applying for a position with iDirect, which (depending on the circumstances), can include your name, address, telephone number, e-mail address, desired salary, education level, professional experience and other Personal Data. Please see our Candidate Notice for more information.
If you email us (or contact us otherwise), we may retain a record of such email (or other) communication (including attachments), including your email address, name, content of your email and our response.
For some Services, a registered user may be provided a unique username and password that enables access to the Services. We may track the use of those usernames and passwords in order to collect and maintain records of individual transactions conducted through the Services.
Personal Data requested on a form or application is required in order to fulfill your request or perform our contractual obligations to you. If you do not provide such Personal Data, we will be unable to respond to your request or perform our obligations to you.
We use navigational data like Uniform Resource Locators (URL) to gather information regarding the date and time of your visit and the solutions and information for which you searched and viewed.
IP Addresses. An “Internet protocol address” or “IP Address” is a number that is automatically assigned to your computer when you use the Internet. In some cases your IP Address stays the same from browser session to browser session; but if you use a consumer internet access provider, your IP Address probably varies from session to session. We, or our service providers, may track your IP Address when you access the Website or Services.
Cookies. “Cookies” are small files containing a string of characters that are sent to your browser and stored to your computer’s hard drive while you are viewing a website. We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience with the Website or Services. Persistent Cookies can be removed by following your Internet browser help file directions. If you choose to disable Cookies, some areas of the Website or Services may not work properly so that we might not be able to provide you with out content or Services at all.
Third-Party Content. Some content or applications on the Website or Services may be served by unaffiliated third parties. These third parties may use technologies to automatically collect information (including Personal Data) about you when you use the Website or Services. They may collect information about your online activities over time and across different websites and other online services. They may also use persistent identifiers to track your Internet usage across other websites in their networks beyond the Website or Services. They may use this information to provide you with interest-based advertising or other targeted content. While we do not knowingly provide these entities with information that personally identifies you such third parties may, with sufficient data from other sources, be able to personally identify you, unknown to us. We do not control these third parties’ tracking technologies or how they may be used. We are not responsible for the content or privacy practices on any website not operated by us to which our Website or Services link or that link to our Website or Services.
Do-Not-Track Signals. Your browser or device may include a “Do Not Track” functionality. Please note that we do not change system behavior in response to browser requests not to be tracked and our information collection and disclosure practices, and the choices that we provide to visitors, will continue to operate as described in this Privacy Notice.
Other Information. “Other Information” is any information that is not Personal Data because it does not reveal your specific identity or does not directly relate to an identifiable individual. This might include, for instance, aggregate or statistical data; certain types of information collected through cookies, pixel tags, and other technologies; or aggregated information. We use this information to facilitate our operation of the Website and for other purposes described below.
Location Information. When you use our installation services, we receive information about the location of the satellite antenna or terminal(s) you own or are authorized to access. This location information is necessary to provide the services.
Information From Social Media. When you interact with us through a social media platform, we may collect the personal information that you make available on that platform, including your account ID or username and other information included in your posts.
Information from Other Sources. We may receive Personal Data about you from other sources like telephone, fax or email, from third-parties that provide services for us in connection with the Website or Services, as well as from third parties to whom you have voluntarily provided information. We may supplement this information we collect with information from such third parties or collected offline, such as information collected over the phone or in person. We may also collect information about you from credit reporting agencies in order to determine your creditworthiness, credit score and credit usage. We do not control the privacy practices of third parties when you use their services.
Reasons and Legal Basis for Use of Your Personal Data
Whenever we use Personal Data, that use is justified by a ‘lawful ground’. The lawful grounds and reasons why we use Personal Data are as follows:
Lawful ground – To perform a contract with you or take pre-contractual steps at your request:
- communicate with you and respond to your inquiries or requests (e.g. requested materials, a requested newsletter), including as part of the “Contact Us” feature on our Website;
- send administrative information to you, (e.g. information regarding the changes to our terms and conditions);
- provide you with customer service and customer support related to troubleshooting in connection with our Services;
- carry out our obligations and enforce our rights arising from contracts entered into between you and iDirect, including for billing and payment collection;
- Lawful ground – Our legitimate interests:
- except when your consent is required (see below), send you marketing communications, including via email and SMS in compliance with applicable laws, that we believe may be of interest to you;
- present products and offers tailored to you;
- tailor your experience with the Website or Services to meet your special interests and needs;
- engage in one of the following activities: data analysis, audits, fraud monitoring and prevention, developing new products, enhancing, improving or modifying our Website and Services, identifying usage trends, determining the effectiveness of our promotional campaigns and operating and expanding our business activities;
- help diagnose problems with our server, to manage our Website and to enhance our Website based on the usage pattern data we receive;
- protect our operations or those of any of our affiliates;
- protect our rights, privacy, safety or property, and/or that of our Affiliates, you or others;
- pursue available remedies or limit the damages that we may sustain.
When the lawful ground is our legitimate interests, those interests are to process Website and Services user data to conduct, develop and grow our business activities with customers, users and with others, and to improve our services and profitability, while limiting the use of personal data to those purposes that strictly support the conduct and development of our business as described in this Notice.
Lawful ground – Consent:
- in some cases applicable law requires us to obtain your consent to send you marketing communications, including via email and SMS, and in these cases we rely on your consent to process your data for marketing purposes;
Lawful ground – When we are required to comply with an EU law:
- keep business records (such as tax and accounting)
- comply with legal process;
- respond to requests from public and government authorities including public and •government authorities
- protect privacy, safety or property, as and when specifically required by EU.
TRANSFERRING YOUR PERSONAL DATA. The Personal Data that we collect from you may be accessed in, or transferred to, and stored in United States, Canada and Singapore. The United States and Singapore do not benefit from a decision of the European Commission stating that they provide adequate protection to Personal Data. Canada benefits from an adequacy decision of the European Commission finding that Canadian laws afford adequate protection to personal data. The Personal Data may be stored by iDirect or its service providers, or processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff maybe engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of Services. We will take all steps reasonably necessary to ensure that your data is treated with an adequate level of protection in the jurisdictions in which we process it. Personal Data transferred among iDirect, and its affiliates will be made on the basis of standard contractual clauses as approved by the European Commission. Other Personal Data will be transferred under suitable safeguards, depending on the circumstances and the recipient, such as standard contractual clauses as approved by the European Commission, Binding Corporate Rules or the EU-US Privacy Shield. A copy of such safeguards may be obtained by contacting firstname.lastname@example.org.
Security. The Security of your Personal Data is important to us. All information (including Personal Data) is stored on our servers and we have implemented safeguards that aim to protect this information. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Website, we encourage you to choose a strong password and to keep this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect information (including your Personal Data), we cannot guarantee the security of your data transmitted to our Website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.
DISCLOSURE OF YOUR INFORMATION
How we share your Personal Data
We may disclose your personal information to any iDirect affiliates or third parties as set out below:
- Affiliates and Service Providers. We engage Affiliates and third party providers who may perform functions on our behalf such as: hosting, content management, marketing, analytics, customer service and fraud protection. These third parties may have access to your personal information when needed to perform their functions.
- Business Transfer. In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
- If the iDirect group of companies or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
- Anonymized/Aggregated Data
YOUR CHOICES. You may update or correct your account information at any time by logging in to your account. You may also adjust or change the settings or display of information about you. Please see below on how to make these changes and choices.
- Email Communications.
- Inactive or Deleted Accounts
- Targeted Advertising
- Access and Correct Your Data. You may contact us to request access to or a copy of your Personal Data, or to request that we correct (rectify) your Personal Data.
- Deletion and Restriction. You have the right under certain circumstances to have us delete your Personal Data, or restrict (block) its processing.
- Data Portability. You also have the right under certain circumstances to request that certain personal data be provided in machine readable format, and exported to another controller where technically feasible.
- Withdraw Consent. If you have provided consent for the processing of your data you have the right to withdraw such consent at any time, which will not affect the lawfulness of the processing before your consent was withdrawn.
Right to Object. To the extent that our legitimate interests are the lawful ground for using your Personal Data, you have the right to object to such use on grounds relating to your particular situation, and we must stop such processing unless we can either demonstrate compelling legitimate grounds for the use that override your interests, rights and freedoms or where we need to process the data for the establishment, exercise or defense of legal claims.
In addition, you can object to the processing of your personal data for direct marketing purposes, which includes profiling to the extent that it is related to such direct marketing, without providing any reason. We will then cease the processing of your personal data for direct marketing purposes.
- Lodge a Complaint. You have the right to lodge a complaint with your supervisory authority.
Please note that certain services will not be available if you withdraw your consent, or otherwise delete or object to our processing of certain Personal Data.
If you wish to exercise any of your rights you may contact us with your request at email@example.com (or at the CONTACT US information shown below). We will respond to your request in accordance with applicable law, and we will inform you if we do not intend to comply with your request.
Retention of Your Personal Data. We apply a general rule of keeping personal data only for as long as required to fulfil the purposes for which it was collected. In general, we retain your personal data for a period of time corresponding to a statute of limitation setting out the period during which legal claims may be filed in court. For example, we’ll retain your personal data during the statute of limitation period, to maintain an accurate record of your dealings with us or raise or defend claims in court. However, in some circumstances we may retain personal data for other periods of time, for instance where we are required to do so in accordance with legal, tax and accounting requirements, or if required to do so by a legal process, legal authority, or other governmental entity having authority to make the request, for so long as required.
We will retain your Personal Data for marketing purposes for a period of 90 days to 25 months depending on the type of activity (e.g. visited web page or sent an email). For more information, please email firstname.lastname@example.org
Third-Party Websites. Our website may, from time to time, contain links to and from the websites of our partner networks, advertisers and Affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
OTHER IMPORTANT INFORMATION
Users Under 18. The Website and our Services are not directed at users under the age of 18. We do not knowingly collect or maintain Personal Data from users we know are under 18 years old. If we become aware that we have collected personal information from a user under the age of 18 without verification of parental consent, we will take steps to remove such user’s information from our systems.
If you have questions or concerns about our Privacy Notice or wish to exercise your rights, please contact us by email or by postal mail:
ST Engineering iDirect, Inc. dba iDirect
Attn: Marketing Department re: Privacy Notice
13861 Sunrise Valley Drive, Suite 300
Herndon, VA 20171 USA
ST Engineering iDirect (Europe) CY NV
Attn: Legal re: Privacy Notice
Laarstraat 5, 9100 Sint-Niklaas, Belgium
While we do not have a Data Protection Officer, our Data Protection Manager may be contacted at email@example.com