This statement explains how The London Internet Exchange Limited (“LINX”, “we” and “our”) handles and uses data we collect about the representatives of our prospective members (“you” and “your”). We will refer to the company you represent as “your company”. In broad terms, we use your data:
(1) to manage the potential relationship between LINX and your company, including keeping in touch with you, keeping up to date on you and your company’s needs and how we are meeting these, and engaging with you on what is needed for your company to join LINX.
(2) to invite you and/or your company to take part in selected activities and services normally available to LINX members, in advance of your company becoming a member – both for the purposes of better evaluating the benefits of LINX membership and to provide for a smooth transition into membership; and also to enable us to provide those activities and/or services;
(3) If when you provided us with your data, you also gave consent for marketing activities, we will in addition send you information about LINX and LINX activities we believe will be of interest to you, but which are not strictly relevant to your company becoming a LINX member.
We will retain your data until your company is clearly no longer likely to be joining LINX or until we are made aware that you no longer work for your company. If your company becomes a member of LINX, we will then hold your data on the terms described under “For Members of LINX”. When changes are made to this statement, we will publish the updated version to our website and notify you by other communications channels as we deem appropriate or necessary.
The controller for your personal data is the London Internet Exchange Ltd, Trinity Court, Trinity Street, Peterborough, PE1 1DA, United Kingdom. The person responsible for data protection at the time of issue, and the person who is responsible for monitoring compliance with relevant legislation in relation to the protection of personal data, is Howard Fisher. You can contact us in this regard by emailing firstname.lastname@example.org.
The legal basis for processing your personal data in respect of (1) above is that it is necessary for the purposes of our legitimate interests, where we have concluded that our interests do not impact inappropriately on your fundamental rights and freedoms, except where elsewhere in this statement we have indicated otherwise.
Where we also hold your data in respect of (2) above The legal basis for processing your personal data is that you have given your consent. You may withdraw your consent at any time in respect of (2) by contacting us.
You may ask us to explain our rationale at any time.
How your data is used by LINX
We collect and process your personal data, as specified below, for a number of purposes, including:
- to contact you in connection with your company’s prospective membership;
- where you have given your explicit consent, to advise you of events and activities that will be of interest to a company considering joining LINX;
- depending on the role you carry out, this may include technical, sales, satisfaction and governance matters.
- Where you have provided us your personal details directly, the details will include your name, job title, email address(es), contact address and phone numbers you have provided to us, together with details of the role you carry out in connection with the prospective membership.
- Where your details have been provided by another representative of your company, unless you later provide further details, we will only keep on record your name, job title, email address(es), contact address and phone number, together with details of the role you carry out in connection with the prospective membership.
- We have subsidiary companies London Internet Trading Limited and LINX America Inc with whom we share your data. LINX America Inc operates in the USA.
- The provision of your personal data was not part of a statutory obligation or a contractual obligation with you.
- No decisions are automated within the scope/meaning of the GDPR.
You have the right: to ask us for access to, rectification or erasure of your data; to restrict processing (pending correction or deletion); to object to communications or direct marketing; and to ask for the transfer of your data electronically to a third party (data portability). Some of these rights are not automatic, and we reserve the right to discuss with you why we might not comply with a request from you to exercise them.
Where your personal details were supplied by a third party or taken from publicly accessible sources you have the right to be informed of the source.
Where you opt out of all future communications or exercise your right to erasure, we may continue to maintain a core set of personal data (name, member, email addresses) to ensure we do not contact you inadvertently in future.
You retain the right at all times to lodge a complaint about our management of your personal data with the Information Commissioner’s Office at https://ico.org.uk/concerns/