Privacy Policy
Telecom Infrastructure Partners: Privacy Policy.
Telecom Infrastructure Partners respects your privacy and strives to protect your personal data.
1. About Telecom Infrastructure Partners
The Telecom Infrastructure Partners group is made up of different legal entities.
These entities are listed in the Annex to this policy. Together, these entities are known as the “Group TIP”. This privacy policy is published on behalf of the TIP Group.
When we mention “TIP”, “we”, “us” or “our” in this privacy policy, we are referring to the relevant TIP Group company responsible for processing your data. The Annex also shows the relevant TIP Group company responsible for processing your personal data. This company is called “responsible for the treatment”.
2. Purpose of this privacy policy
This privacy policy informs you about:
a. how TIP, as a data controller, uses and shares the personal data we collect when we interact with potential candidates, Interest Holders (land owners, and persons with real estate interests in land, clients and potential clients, including employees and representatives of these), current and former partners/suppliers, website visitors, subcontractors and visitors, (collectively “you/your”) by TIP, in each case, during the course of its business activities; and
b. your data protection rights under applicable data privacy legislation and laws (including, but not limited to, the EU General Data Protection Regulation 2016/679 (the “GDPR”), the UK GDPR, the Data Protection Act 2018 (UK) and other applicable privacy laws to the extent they apply to the data processing and business operations of the data controller) (the “Data privacy laws”).
We ask you to read this policy or any other fair processing policy we may send you when we collect or process personal data about you, so that you are fully aware of how and why we use your data. This policy supplements other notices. It is not intended to replace them.
3. Sources of personal data
We will collect and process the following personal data about you in the following ways:
| Categories of personal data / Personal information | How we collect your data |
| TIP interest holders, lessees or concessionaires | Directly from you while TIP is dealing with you |
| Personal data or personal information of business partners/suppliers | Directly from you while the TIP is receiving your services |
| Potential candidates | Directly from you, if you have contacted us directly; from third parties or other sources (for example, through recruitment agencies), but in each case only to the extent legally permitted and necessary. This can also include public sources such as professional networking platforms or job portals. Also when required by applicable local legislation. From companies that carry out background checks, credit reference agencies and organizations that provide disclosure and access restriction services. |
| Visitor information | Directly from you at the time of visiting our facilities or by a TIP employee |
| Website data | Directly from you when you voluntarily fill out your information on the website through forms provided so that you can receive information from us, or so that we can contact you |
| Website Cookies | Consult our Cookies policy for information about how we collect information through cookies on our website. |
| Data and marketing initiatives | Directly from you when you interact with any TIP representative: through websites; by phone; by email; through online portals; in person; or through professional networking platforms. |
4. Purpose and legal basis of the processing
Your Personal Data is stored and processed by us in the following ways and for the following legal purposes:
a. where you have applied for a job with us, to process your application for employment with us and (only where legally permitted and strictly necessary to assess your suitability for the relevant position) to carry out background checks on you.
b. where you are an Interest Holder, to negotiate transactions in relation to real estate interests you hold, and so that we can manage our interests in relation to such transactions.
c. where you are a concessionaire or lessee of land in which TIP has an interest, to negotiate transactions in relation to such land, and so that we can manage our interests in respect of it.
d. provide you with our services.
e. comply with the legal and regulatory obligations that concern us.
f. to exercise or defend our legal rights or for the purposes of legal proceedings.
g. when you are an employee or visitor to our facilities, to record and monitor your use of our facilities and/or computer systems in order to maintain their security and protect them against fraud or unauthorized entry.
h. so that we can use it for our interests legitimate business, such as: the operation of our website; the efficient management of our operations, the carrying out of marketing activities aimed at improving the services we offer you; the maintenance of business relationships; and managing the security of our business (“Legitimate business interests”); and
i. use it to prevent and respond to actual or potential fraud or illegal activities.
We may transfer Personal Information as an asset through a merger, acquisition, bankruptcy or other transaction in which a third party assumes control of the company in whole or in part. In such case, the third party may not materially alter the way it uses or shares the Personal Information acquired, subject to certain exceptions.
We process your personal data on the basis of the following legal bases, in accordance with Article 6 of the GDPR:
| Categories of personal data | Purpose of collection | Legal basis |
| Data of interest holders | To fulfill contractual obligations to persons with real estate interests in land, for example: to manage existing accounts; make payments; and allow us to process payments in relation to existing real estate interests. For potential customers and business contacts, we will process your personal data to determine whether you might be interested in conducting a transaction with us or how we can help you. | Execution of the contract and/or adoption of measures prior to the conclusion of a contract. TIP’s legitimate interest in maintaining a commercial relationship with the Interested Parties |
| Personal data of partners/suppliers | To receive services from suppliers/partners in order to: receive products and services from you; and allow TIP to process payments and orders in respect of any goods or services you provide to us. | Contract execution |
| Personal data of potential candidates | When you have applied for a job with us: to process your job application and carry out background checks (only where legally permitted and strictly necessary to assess your suitability for the position in question); for diversity and inclusion purposes; or to make appropriate adjustments that may require us to process special categories of data, such as disability information (only where required by applicable national law). | Legitimate interest in managing the effective operation of TIP and taking measures prior to entering into a contract. |
| Personal data of visitors | If you visit our facilities, to record and monitor your use of our facilities or computer systems in order to maintain your security and protect against fraud or unauthorized entry. As a visitor to a TIP website, you may provide us with certain personal data, for the purpose of dealing directly with you, for example when: you ask us to send you marketing material. | Consent, legitimate interest in carrying out TIP marketing activities |
| Personal data of data subjects in the context of marketing initiatives and data. | To engage in marketing and business development activities related to our products and services. This includes email and SMS marketing, other marketing communications, as well as the organization of events. Use it for our legitimate business interests, managing the efficient administration and operation of our business, carrying out marketing activities designed to improve the services we offer to you. | Consent, legitimate interest in carrying out TIP marketing activities |
| Website Cookies | When you use the functionality or visit our website, including (subject to acquiring your prior consent where legally required) the use of cookies on our website (see our Cookies policy for more information). | Consent, legitimate interest in carrying out TIP marketing activities and managing the website |
If we process your personal data to satisfy one or more of TIP’s (or a third party’s) legitimate interests set out in this section, TIP will ensure that those interests do not override your fundamental rights or interests. If you would like more information about the legitimate interest assessments we have carried out, please contact us using the contact details below.
5. Special categories of personal data
As we have said, where permitted by law, we process your special categories of personal data based on the following legal bases:
a. Your explicit consent is obtained when required by applicable local law or in specific circumstances for one or more of the specific purposes described above (Article 9(2)(a) GDPR); and
b. When the processing is necessary for the fulfillment of obligations and the exercise of specific rights of the controller or the data subject in the field of employment and social security and social protection legislation, to the extent authorized by law. local data protection laws or by a collective agreement in accordance with local data protection laws that provide adequate guarantees for the fundamental rights and interests of the data subject (Article 9(2)(b) GDPR).
6. Conservation periods
TIP will retain your personal data, including marketing data, only for as long as we need it to fulfill the purposes for which we collected it. This includes its retention to satisfy legal, accounting or reporting requirements.
We determine the appropriate retention period for personal data by evaluating a series of criteria. These criteria include: the nature and sensitivity of the personal data; the amount of personal data we have; the risk of harm associated with unauthorized use or disclosure of your personal data; the purpose of processing your personal data; whether we can achieve that purpose in other ways; and relevant legal requirements.
For candidates, if they accept a position at TIP, we will retain the information they provided during the application process. This information will become part of your employee file and will be maintained in accordance with TIP’s employee privacy policy or applicable law.
If your request is not accepted, TIP will retain the information you have provided to us for six (6) months following the date on which we have communicated our decision to you. We do this so that (in the event of a legal claim) we can demonstrate that we have not discriminated against candidates on prohibited grounds and that we have carried out the recruitment process fairly and transparently.
After six months, we destroy personal information securely and in accordance with our data retention policy and our legal and regulatory obligations.
7. Children’s privacy on the Internet
We do not direct our website to minors and we do not knowingly collect personal data from children under the age of 13, or as defined by local legal requirements. If we learn that we have mistakenly collected or received personal data from a minor without appropriate consent, we will delete it. If you believe that we have mistakenly or inadvertently collected information from or about a minor, please contact us at personaldata@telecom-ip.com.
Note: On our website we do not collect, use or process personal data of persons under 18 years of age. If you are under 18 years of age, we do not want you to provide your personal data through our website.
8. Disclosure and recipients of your personal data
TIP will not reveal or give third parties access to the personal data we have about you, except in the following cases:
a. TIP sells any part of its business or assets. In such case, we may disclose personal data to any buyer or potential buyer;
b. it is necessary to disclose information to companies of the TIP Group, or to members of the board of directors of said companies;
c. to third parties who provide services to us, such as IT services or professional services who need to see that information and/or other services that help process data on our behalf for the purposes listed above
d. to the extent required by law, regulatory body or court order, for example, if we are required to disclose your personal data to comply with a legal obligation.
9. International transfers
In some cases, we may transfer any of your personal data located in the UK or the European Economic Area (EEA) outside the UK or the EEA.
TIP has a subsidiary based in the United States. From time to time, we may transfer personal data to this entity and its employees. Please see the full list of third countries in part B of the annex below.
The UK Secretary of State has considered that some countries outside the UK offer an adequate level of protection for the transfer of personal data outside the UK. (“UK adequacy decision”)
Similarly, the European Commission has adopted an adequacy decision with respect to certain countries to which we may transfer personal data outside the CEA. (“Decision on adequacy of the CEA”)
But if we transfer personal data out of the UK or the European Economic Area to countries where there is no UK Adequacy Decision or European Economic Area Adequacy Decision, we will ensure that it is protected in a similar way to any transfer. that we make to countries where there is a UK Adequacy Decision or an European Economic Area Adequacy Decision. Where appropriate, this means that we complete standard contracts approved by the Secretary of State in the United Kingdom or (where applicable) the European Commission.
If you require further information about how closely we will protect your data when transferring it outside the UK/EEA, please email us at personaldata@telecom-ip.com.
10. Data security: how we store and protect your data
We have taken measures to ensure the security of the personal data we collect and store about you. We will take reasonable steps to protect your personal data from unauthorized access or disclosure. The measures we will take include the use of appropriate physical, electronic and administrative safeguards. We store all personal data you provide to us behind firewalls on servers that employ security protections.
11. Consent and right to withdraw consent.
If TIP processes your personal data based on your consent, you have the right to withdraw that consent at any time.
If you withdraw your consent, this will not affect the legality of processes based on consent before such withdrawal. To withdraw your consent or stop receiving marketing communications, please contact us by email at personaldata@telecom-ip.com or follow the unsubscribe instructions included in electronic commercial communications.
Once we have received notification that you have withdrawn your consent, we will stop processing your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis to do so under the law. And we may need to retain some information to fulfill your request (for example, retaining your email address to ensure you are not on our marketing list).
12. Your data protection rights in the CEA and the UK.
Under data protection legislation, you have the following rights in relation to your personal data:
a. Right of access – You have the right to request that TIP send you copies of your personal data.
b. Right to rectification – You have the right to request that TIP correct any information that you believe is inaccurate. You also have the right to request that TIP complete information that you believe is incomplete.
c. Right to deletion – You have the right to request that TIP delete your personal data, under certain conditions.
d. Right to restrict processing – You have the right to request that TIP restrict the processing of your personal data, under certain conditions.
e. Right to object to processing when we rely on a legitimate interest or that of a third party. You have the right to object to the processing of your personal data by TIP, under certain conditions.
f. Right to data portability – You have the right to request that TIP transfer the data we have collected to another organization, or directly to you, under certain conditions.
13. How to contact the competent authority
In the CEA and the UK, you have the legal right to complain at any time to the relevant data protection regulator (or supervisory authority) of the Member State in which you live, work or where the alleged infringement occurred. In this link
you will find a complete list of supervisory authorities.
However, we would appreciate it if you would contact us before approaching the relevant regulatory authority so that we can see if we can resolve your concerns first. In the UK this authority is the Information Commissioner’s Office (ICO), which you can contact here.
14. How to get in touch with us
If you have any questions about TIP’s privacy policy, the data we hold about you, or if you wish to exercise your rights or make a complaint, please do not hesitate to contact us.
Send us an email to: personaldata@telecom-ip.com
15. Changes to our privacy policy
We will post any changes we make to our privacy policy on this page. Please visit us frequently for updates or changes to our privacy policy.
This privacy policy was last updated on June 29, 2023
Exhibit 1
Part A – UK and EEA entities
Belgium:
Telecom Infrastructure Partners Belgium BV
Czech Republic:
Telecom Infrastructure Partners Czech Republic, s.r.o.
Denmark:
Telecom Infrastructure Partners (Denmark) ApS
France:
Telecom Infrastructure Partners France SAS
Italy:
Telecom Infrastructure Partners Italia Srl Unipersonale
Immobiliare Senza Fili Alfa S.r.L.
Poland:
Telecom Infrastructure Partners, Sp. Z.o.o
Spain:
Telecom Infrastructure Partners S.L.U.
UNITED KINGDOM:
Nile UK Service Company Limited
TIP Alpha Limited
Entities in Luxembourg:
Nile Topco S.à r.l.
Nile Midco S.à r.l.
Nile Finco S.à r.l.
TIP Alpha S.à r.l.
Part B – third country entities
Colombia:
Telecom Infrastructure Partners Colombia S.A.S
Chili:
Telecom Infrastructure Partners Chili, SpA
Peru:
Telecom Infrastructure Partners Peru, S.A.C.
South Korea:
Telecom Infrastructure Partners Korea LLC
USA:
TIP Alpha USA,LLC