Privacy Policy

Last updated June 2018

This website is operated by: NTT COM MANAGED SERVICES, S.A.U. who is committed to protecting and respecting your privacy. This Privacy Policy (the “Policy”) explains how we collect and use your personal data and what rights and options you have in this respect.

For the purpose of the General Data Protection Regulation, the data controller is NTT COM MANAGED SERVICES, S.A.U., company number A62396908, whose registered office address is Avda. Diagonal nº 575 5ª planta 08029 Barcelona, Spain (collectively referred to in the Policy as “NTT”, “We” or “Us”).

This Policy applies to the Website operated by NTT, accessible via and any mobile applications or other online and/or mobile applications or Website operated by Us that are related to Us (collectively, the “Website”).

When you provide Us with information whilst visiting Website operated by or under instruction of NTT, or direct to Us by other means, it may contain personal data.  We will protect your personal data in accordance with this Policy. Personal data means any information from which a person can be identified directly or indirectly by reference to an identifier such as your name, identity number, e-mail address or IP address.

1. Information We may collect from you  

1.1. We may collect and process the following data about you:

1.1.1. Information that you provide by filling in forms on our Website. This includes information provided at the time of registering to an application process. The information that We collect is, for example, name, address, email address, telephone number, job experience, demographic information and/or other information that may identify you as an individual. You can choose not to provide Us with some of this information but doing so may affect your ability to use our Website and our services.

1.1.2. Details of your visits to our Website including, but not limited to, traffic data, location data, weblogs and other communication data, whether this is required for our own purposes or otherwise and the resources that you access.

1.1.3. Your contact details: postal address, telephone numbers (including mobile number) and email address, so that We can communicate with you via telephone, email, or in person.

2. Uses made of the Information

2.1. We use information provided by you and/or held about you (including your personal data) in the following ways:

2.1.1. To ensure that content from our Website is presented in the most effective manner for you and for your computer.

2.1.2. For any specific purpose for which it was provided or volunteered.

2.1.3. To perform analysis and research in relation to transactions, including without limitation, analyzing and conducting research on our user’s demographics and interests, information about your browsing and viewing preferences.

2.1.4. When you submit information and/or your CV for a job application (for instance), this will contain personal data and may contain sensitive information submitted by you. We will use information held about you to provide you with updates on the status of your application and provide you with information about job opportunities.

2.2. We use information on the basis that its use is necessary:

2.2.1. to fulfil a contract that we will have with you or in order to take steps at the request of the data subject prior to entering into a contract.

2.2.2. Legitimate Business Interest:

  • To offer our global range of IT managed services to companies and parties that may be interested.
  • To offer information about our company to individuals who visit our website and advertise job vacancies to fill such vacancies and provide employment for individuals/jobseekers.
  • Maintaining a database of candidate CVs at their consent to be accessed by NTT subsidiaries to help fill their job vacancies and provide employment for the said candidates.

3. Where We store your personal data

3.1. The information that We collect from you is processed and stored inside European Economic Area (“EEA”). All information you provide to Us is stored on our secure servers.

3.2. In certain cases, the information may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who work for the NTT Group.  By submitting your personal data, you can decide about this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your personal data is treated securely and in accordance with this Policy.

4. Sensitive information

Unless We request it, We ask that you not send Us, and you not disclose, any sensitive Personal Information (e.g., information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Services or otherwise to Us.

5. Security

While We have implemented reasonable technical and organizational precautions to protect the security and integrity of personal data provided to our Website, due to the inherent nature of the internet as an open global communications vehicle, We maintain physical, electronic and procedural safeguards to protect your personal data. We strive to protect information transmitted on or through the Website or services.

6. Disclosure of your information

6.1. We may disclose your personal data to any member of the NTT Group, which means our subsidiaries, our ultimate holding company and its subsidiaries (both direct and indirect).

6.2. We may also use your personal data to maintain our internal record keeping and/or share it with our affiliates for selection processes or other purposes.

6.3. We may disclose your personal data to third parties:

6.3.1.  If We are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms and other agreements; or to protect the rights, property, or safety of NTT, or others.

6.3.2.  We may disclose user information to government authorities, and to other third parties when compelled to do so by government authorities or otherwise as required or permitted by law, including but not limited to in response to court orders and subpoenas. We also may disclose user information when We have reason to believe that someone is causing injury to or interference with our rights or property, other users of our Website, or anyone else that could be harmed by such activities. Additionally, We cooperate with law enforcement inquiries and other third parties to enforce laws, intellectual property rights and other rights.

7. Retention

7.1. Your personal data will be retained for as long as reasonably necessary for the purposes listed above or as required by applicable local law.

7.2. The criteria used to determine our retention periods include:

  • The length of time we are doing the selection process where you are part of it or for your benefit.
  • Whether there is a legal obligation to which we are subject (for example, certain laws require Us to keep records of transactions for a certain period before we can delete them).
  • Whether retention is advisable considering our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).

7.3. We may keep an anonymized form of your personal data, which will no longer refer to you, for statistical purposes without time limits, to the extent that we have a legitimate and lawful interest in doing so.

8. Your rights

You have the right to:

8.1. Request information on and access to all the personal data we hold about you;

8.2. request that any inaccurate personal data we hold be corrected;

8.3. to object to certain types of processing of your personal data we carry out;

8.4. request that We delete the personal data We hold about you; and

8.5. to request a copy of your personal data in a machine reasonable, commonly used format (or to request We transfer your personal data in such a format to a third-party service provider).

8.6. In order to exercise these rights, you will need to Contact Us:

  • By means of a written letter sent to NTT COM MANAGED SERVICES, S.A.U., Avda. Diagonal nº 575 5ª planta 08029 Barcelona, quoting reference “Data Protection”.
  • By email to the address specifying in the subject line “Data Protection”.

We will consider such responses and respond to you within 30 days. We may require verification of your identity for providing a copy of your information as permitted by law.

9. Changes to our Privacy Policy

9.1. Any changes We may make to our Privacy Policy in the future will be posted on this page and will be effective upon posting and as reflected in the “Last revised” date shown in the revised Policy. Your continued use of our Website after any such changes are posted will be considered acknowledgment by you of such changes. Under certain circumstances, We may also elect to have such changes notified to you by e-mail or by posting a notice on the front page of our Website. You should regularly check back to this page.

10. Contact

10.1. Questions, comments and requests regarding this Policy are welcomed and should be sent via email to You also have a right to lodge a complaint with your local data protection authority, however, We recommend you contact Us before doing so as We may be able to resolve any issues with you directly in a more efficient manner.