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Home > Privacy Policy
TELIT CINTERION GROUP PRIVACY POLICY AND NOTICE
Last Revised: 12 December 2024
CONTENTS:
WHO IS RESPONSIBLE FOR PROCESSING YOUR DATA AND HOW TO CONTACT US?
WHAT PERSONAL DATA WE COLLECT AND WHY?
* Representatives of our Existing or Prospective Customers, Distributors and
Vendors
* Personal Data Related to the Services We Offer
* Visitors to our Premises
* Website Visitors
* Whistleblowing Procedures
* Job Applicants
WHO DO WE SHARE YOUR PERSONAL DATA WITH?
WHERE DO WE STORE YOUR DATA?
INTERNATIONAL TRANSFERS OF PERSONAL DATA
YOUR RIGHTS (EEA/UK/SWITZERLAND)
YOUR RIGHTS AND ADDITIONAL DISCLOSURES (U.S. STATES, INCLUDING CALIFORNIA,
VIRGINIA, COLORADO, CONNECTICUT, UTAH, TEXAS, IOWA, MONTANA, INDIANA, DELAWARE,
OREGON, NEW JERSEY, NEW HAMPSHIRE)
RETENTION PERIOD
SECURITY AND STORAGE OF INFORMATION
GENERAL
ANNEX: TELIT CINTERION ENTITIES
SECTION 1: WHO IS RESPONSIBLE FOR PROCESSING YOUR DATA AND HOW TO CONTACT US?
This Privacy and Data Protection Policy and Notice (“Notice”) describes the
steps the Telit Cinterion group (collectively, “Telit Cinterion”, “we”, “our”,
or “us”) take to protect the personal data that we process about our customers,
partners and other business-related personal data.
We are committed to the protection of your personal data in accordance with the
data protection principles set out in the European Union’s (“EU”) General Data
Protection Regulation 2016/679 (which has been incorporated into United Kingdom
(“UK”) law in a substantially similar form) (“GDPR”), the California Consumer
Privacy Act of 2018 (as amended by the California Privacy Rights Act of 2020)
and its implementing regulations (“CCPA”) and other applicable data protection
laws. In respect of certain personal data that is collected or otherwise
processed as part of the services and products that we offer (see Section 2.2
(personal data related to the services and products that we offer) below), the
Data Controller (as defined under the GDPR) or business (as defined under the
CCPA) in respect of your personal data is the entity with which your employer
has a contractual relationship with for the provision of those services and
products. The Data Controller(s) in respect of all other processing activities
outlined in this Notice is, depending on the context, any/all of the Telit
Cinterion entities provided here as Annex 1 below. If you are unsure which
entity is the Data Controller in respect of your personal data, you may contact
us by using the following email address: privacy@telit.com. Please note we
maintain a separate privacy notice concerning the processing of the personal
data of our employees.
SECTION 2: WHAT PERSONAL DATA WE COLLECT AND WHY?
We may source, use, and otherwise process your personal data in different ways.
In all cases, we are committed to protecting the personal data that we process.
In each of the sub-sections listed below, we describe how we obtain your
personal data and how it is handled by us.
Section 2.1: Representatives of our Existing or Prospective Customers,
Distributors, Subcontractors and Vendors
Sources of Personal Data
We may obtain your personal data from various sources, including: directly from
you when you provide it through means such as our website’s lead collection
forms, subscribing to our newsletters or webinars, registering to our online
technical documentation portal (the “Download Zone”), contacting us via phone or
email, or participating in webinars, networking events, or exhibitions that we
host, sponsor, or attend, including when you provide your business card or have
your badge scanned at such events. Additionally, we may collect personal data
when you seek support or provide feedback on our services and products, such as
through customer satisfaction surveys. We may also receive your personal data
from your employer, if they are a customer, vendor, or partner of ours, or from
other business partners with whom we have a relationship. Furthermore, we may
obtain data from publicly available sources, such as your employer’s website or
social media platforms, as well as from other third parties, including credit
reference agencies, financial institutions, bodies involved in anti-money
laundering compliance, export control compliance, and third party contact list
vendors.
Personal Data that We Collect and Process
We may collect personal data related to employees, officers, authorized
signatories, and other individuals associated with our existing and prospective
customers, distributors, subcontractors, vendors and other business partners.
This may include details such as personal names, employer information, job
title, country and business contact details like addresses, email addresses and
telephone numbers. Additionally, we may collect the contents of correspondence,
including mail and emails, exchanged with these individuals. This information is
gathered to perform marketing outreach and to establish and manage business
relationships and communications effectively.
When you register to our Download Zone, you provide us with the above details,
in addition to your area of interest in our services and products and login
credentials to the Download Zone. The data you provide in this context is used
to verify your identity, provide you with secure access to the Download Zone and
present you with tailored content and updates as relevant to your area of
interest in our services and products, such as user guides, application notes,
product change notices, software and firmware releases.
For the purposes of fulfilling anti-money laundering and export control
compliance requirements, we may collect personal data from individuals
associated with the business, such as principals, executives, or key
stakeholders. This data may include identifying details such as full name, date
of birth, and address, as well as nationality and residency status. We may also
gather documentation to verify identity and address, such as passports, driver’s
licenses, utility bills, and bank account information. In some cases, we may
collect additional data such as tax identification numbers, proof of business
ownership, or legal records, including police contact certificates, when
required by law. All data is collected to ensure compliance with regulatory
obligations and to verify the legitimacy of the business relationship.
As part of our creditworthiness assessments for prospective clients, we may
collect and process certain information about the entity and, where necessary,
individuals associated with the business, such as principals, executives, or key
stakeholders. This information may include, but is not limited to, full names,
ID numbers, title, date of appointment to present position, contact details,
year of birth, education details and qualifications, as relevant to assess the
financial stability of the business. We may also obtain reports from credit
reference agencies or financial institutions. All information collected is used
solely to evaluate the business’s ability to meet its financial obligations.
The aforementioned types of personal data we collect correspond to the following
categories of personal information collected by us and disclosed for business
purposes within the past 12 months in our role as a “business” (as defined in
the CCPA) or as a “controller” (as defined in other US state privacy laws):
* Identifiers and information that relates to, describes, or is capable of
being associated with, a particular individual;
* Professional or employment-related information; and
* Commercial information, including products or services purchased, obtained,
or considered.
* Sensitive personal information (as defined under the CCPA or other applicable
US state privacy laws): government-issued IDs, financial account information
and contents of mail and email.
Why Do We Collect Your Personal Data and What are the Lawful Bases?
Purpose for Processing of Your Personal DataLawful Basis for Processing of Your
Personal Data Our Legitimate Interest in the Processing of Your Personal Data /
Additional DetailsProviding you with our products or services or receiving
products or services from you; managing our business relationship with
youPerformance of contract; legitimate interestsEfficiently fulfil our
contractual obligations, account management, exercising or defending against
legal claims, market evaluation, management reporting (including at an
intra-group level)Providing our Download ZoneLegitimate Interests; Consent (for
receiving Download Zone updates)Verifying your identity and providing you with
secure access to the Download Zone, presenting you with content and updates as
relevant to your area of interest in our services and productsAssessing the
financial stability of our clientsLegitimate InterestsEnsuring the business’s
ability to meet its financial obligationsSending you customer satisfaction
surveys, increasing internal awareness and analytics about how our products and
services may be used in order to maintain and improve our services and
productsLegitimate InterestsUnderstanding the market in which we operate,
product and customer satisfaction improvement, account management and management
reporting (internally and externally)Security managementLegitimate
InterestsEnsuring the security of our products and services, risk and crime
prevention, management reporting (internally and externally)Marketing
communications: establishment and management of our business relationship with
you by increasing your awareness about products, services, and events that may
be of interest to you through marketing communications by letter, phone, email,
or other forms of electronic communicationLegitimate Interests or Consent*
(according to applicable law)Promoting our products and services, establishment,
maintenance and management of our business relations, management reporting
(internally and externally)General business managementLegitimate
InterestsManagement reporting and assessmentsCompliance with legal
obligationsLegal ObligationReporting to applicable bodies/entities as required
by law, compliance with other legal obligations (e.g. tax laws, bookkeeping
laws, anti-money laundering laws, export control compliance regulation, etc.)
* Certain direct marketing purposes may be based on your consent (if required by
law). For example, when you submit a ‘contact us’ form directly to our sales,
analyst relations or media relations teams, inquire about our products and
services, provide us your business card or badge for scanning purposes or
contact us following an event. Sometimes, we rely on the consent you’ve provided
to third parties to receive marketing communications from companies like ours.
If we’ve relied on consent, you are entitled to withdraw your consent at any
time.
We may also rely on our legitimate interests to contact you in order to offer
you services or products similar to the ones you have bought from us, requested
an offer, or inquired about, or to invite you to future events of a similar
nature to the one you’ve registered to.
If you object to our use of your personal data for the aforementioned purposes,
including for direct marketing purposes, please contact us by using the
following email address: privacy@telit.com. You can also unsubscribe from our
marketing communications by emailing unsubscribe@telit.com.
We will seek your prior consent, when required by applicable law, when, for
direct marketing purposes, we use (a) cookies or other similar tracking
technologies, and/or (b) your email address to communicate marketing information
to you.
The following are the CCPA business or commercial purposes for which we use the
categories of personal information included under this section:
* All information, including sensitive personal information, is used only as
necessary to perform our services, provide our products and conduct our
business operations, and is not sold or shared.
* Auditing related to a current interaction with the consumer and concurrent
transactions.
* Providing customer service, processing or fulfilling orders and transactions,
verifying customer information.
* Detecting security incidents, protecting against malicious, deceptive,
fraudulent, or illegal activity, and prosecuting those responsible for that
activity.
* Undertaking activities to verify or maintain the quality or safety of a
service or device that is owned, manufactured, manufactured for, or
controlled by us, and to improve, upgrade, or enhance the service or device
that is owned, manufactured, manufactured for, or controlled by us.
Section 2.2: Personal Data Related to the Services and Products We Provide
Sources of Personal Data
Your personal data may be processed by us when our customers or their customers
use the services and/or products that we provide, including, but not limited to,
the following (to the extent the data being processed via these services and/or
products relates to you):
* Connectivity – a cloud-based management platform for cellular connectivity
(SIM) services provided to customers.
* IoT Platform (deviceWISE/IoT Portal) and related Professional Services – a
cloud-based solution that allows customers to connect an array of IoT devices
and handle data collected by these devices.
* secureWISE – a solution providing customers (OEMs) secure remote access to
administer and measure the performance of factory floor machines of their
contracting FABs.
* IoT Suite – a remote eSIM management solution which allows customers to
remotely manage cellular network operator subscriptions by allowing them to
provision so-called operator profiles into an eSIM throughout the lifecycle
of the IoT devices through a dedicated web portal.
* Fleet Manager – a cloud-based remote IoT fleet management web portal, based
off of the IoT Suite, which allows customers to store and manage activation
codes by means of configurable business rules.
Personal Data that We Collect and Process
We collect the following categories of personal data as part of providing our
services and products:
1. Customer User Data: data related to the authorized users of our services on
behalf of our customers or customers’ customers (“Customer Users”),
including, as applicable:
* Account Data: account login credentials (email, password), name (first and
last), work title, company name, country, phone number;
* Activity Log Data: logs of Customer User activity within the applicable
service, such as logins, event and activity timestamps and descriptions,
file downloads.
2. IoT Device End User Data: highly pseudonymized data relating to customers’
(or customers’ customers’) end-users of the IoT devices connected to certain
Telit Cinterion solutions (“End Users”), to the extent such End Users are
natural persons.
For clarification, we are an IoT company specializing in M2M solutions. We do
not sell our products or services to End Users, but rather to corporate
customers across various industries including medical, energy and agriculture.
Our customers, or our third party providers’ (e.g. Mobile Network Operators) and
underlying platforms’ (e.g. Connected Device Platforms) customers integrate our
solutions and products into their IoT devices and machinery for operational
purposes. Given our business model, we have no access to identifying data of End
Users and cannot reasonably identify them in any way. The extent to which data
processed by us may constitute potentially identifiable personal data depends on
the specific circumstances, purposes and contexts in which our customers (or end
customers) utilize our services. Regardless, we do not process End User data for
the purpose of identifying individuals, and it is the sole determination of our
customers whether to utilize this data for such purposes.
End User data may be applicable to the following services, as follows:
* Connectivity Data: data related to the cellular connectivity of modules,
associated SIM cards or virtual eSIMs embedded in IoT devices and machines,
including:
* Module, SIM, subscription and network identifiers (MSISDN, ICCID, EID,
IMEI, IMSI, MCC, MNC, device certificate);
* Transmission Metadata: session duration and volume, source and destination
number, MNO cell tower data/signaling information, cell ID location, GPS
location, IP address, metadata logs of technical operational commands via
applicable connectivity service (SMS, voice, data and volt), such as
destination, time sent, status and type.
* Content Data: content of technical operational commands via applicable
connectivity service (SMS, voice, data and volt); and, any other data
customer chooses, at its own discretion, to input in free text custom
fields and labels.
* IoT Platform (deviceWISE/IoT Portal) and related Professional Services: data
related to the IoT devices managed by Telit Cinterion’s IoT Platform. While
the categories and nature of the datapoints defined within the IoT Platform
are wholly determined by the customer using this service, and customers are
instructed not to share end-user personal data on the platform, in certain
circumstances, certain datapoints may indirectly indicate highly
pseudonymized personal data (e.g. IoT device geolocation history, when such a
device is used consistently by a certain individual, such as a vehicle).
* IoT Suite Data: data related Telit Cinterion’s remote eSIM management
solution, including:
* Module, SIM, subscription and network identifiers (MSISDN, ICCID, EID,
IMEI, IMSI, MCC, MNC, device certificate);
* Operation metadata: GPS location, cell ID location, IP address, logs;
* Content Data: any other data customer chooses, at its own discretion, to
input in free text custom fields and labels.
* Fleet Manager Data: data related Telit Cinterion’s fleet management solution,
including:
* Module, SIM, subscription and network identifiers (module, SIM,
subscription and network identifiers (MSISDN, ICCID, EID, IMEI, MCC, MNC);
* Operation metadata: IP address, logs;
* Content Data: any other data customer chooses, at its own discretion, to
input in free text custom fields and labels.
The aforementioned types of personal data we collect from you correspond to the
following categories of personal information collected by us within the past 12
months and disclosed for business purposes in our role as a “business” (as
defined in the CCPA defined below):
* Identifiers and information that relates to, describes, or is capable of
being associated with, a particular individual; and
* Professional or employment-related information.
Why Do We Collect Your Personal Data and What are the Lawful Bases?
Purpose for Processing of Your Personal DataLawful Basis for Processing of Your
Personal DataOur Legitimate Interest in the Processing of Your Personal Data/
additional informationProviding our servicesContractual obligation Processing of
data necessary for the operation of the services, account management, billing
and collecting fees, enforcing the agreementGeneral business management
Legitimate Interests Conducting administrative and technical activities
necessary to maintain and improve our services, exercise or defend legal
claimsEnsuring the performance and security of our services Legitimate
InterestsProviding secure access to the services, preventing fraud,
misappropriation, infringements, identity theft or misuse of the
servicesStatutory reporting obligationsLegal obligationReport to relevant bodies
or entities where required by law
The following are the CCPA business or commercial purposes for which we use the
categories of personal information included under this section:
* Auditing related to a current interaction with the consumer and concurrent
transactions.
* Providing customer service, processing or fulfilling orders and transactions,
verifying customer information.
* Detecting security incidents, protecting against malicious, deceptive,
fraudulent, or illegal activity, and prosecuting those responsible for that
activity.
* Undertaking activities to verify or maintain the quality or safety of a
service or device that is owned, manufactured, manufactured for, or
controlled by us, and to improve, upgrade, or enhance the service or device
that is owned, manufactured, manufactured for, or controlled by us.
We note that certain End User datapoints processed as part of our services are
processed by us as a Data Controller, as this data is necessary to ensure
accurate invoicing and billing for our services. This data includes module, SIM,
subscription and network identifiers as well as certain transmission metadata.
The remaining End User data under this section, such as Content Data and certain
transmission and operation metadata (cell ID location, GPS location, device IP
address and associated logs), in addition to Customer User Data, are processed
by us as a Data Processor on behalf of our customers, who are the Data
Controllers of such data pursuant to the GDPR and other applicable laws. As
such, our customers are responsible to determine the lawful basis and purposes
for the processing of such data. Similarly, when processing such data, we are
merely a ‘service provider’ of our customer pursuant to the CCPA.
Section 2.3 Visitors to Our Premises
Sources of Personal Data
We may obtain your personal data from (a) you directly, and/or (b) from our
systems’ records
Personal Data that We Collect and Process
Your (a) name, (b) business contact details, (c) organization, (d) job title,
and/or (e) image(s) (for example, from CCTV cameras at some of our premises).
The aforementioned types of personal data we collect from you correspond to the
following categories of personal information collected by us within the past 12
months and disclosed for business purposes in our role as a “business” (as
defined in the CCPA defined below):
* Identifiers and information that relates to, describes, or is capable of
being associated with, a particular individual; and
* Professional or employment-related information.
Why Do We Collect Your Personal Data and What are the Lawful Bases?
Purpose for Processing of Your Personal Data Lawful Basis for Processing of Your
Personal DataOur Legitimate Interest in the Processing of Your Personal
DataSecurity managementLegitimate InterestsSecurity management and risk and
crime preventionMaintaining records of visitors to our premisesLegitimate
InterestsManagement reporting and risk managementStatutory reporting
obligationsLegal obligationReport to relevant bodies or entities where required
by law
If you object to our use of your personal data for the aforementioned purposes,
please contact us by using the following email address: privacy@telit.com.
The following are the CCPA business or commercial purposes for which we use the
categories of personal information included under this section: Detecting
security incidents, protecting against malicious, deceptive, fraudulent, or
illegal activity and prosecuting those responsible for such activity.
Section 2.4: Website Visitors
Sources of Personal Data
We may obtain your personal data from (a) your device and browser, whenever you
visit our website (b) you directly, for example, when you complete the contact
forms on our website, subscribe to our newsletter via our website, post content
and comments on our Technical Forum, etc.
Personal Data that We Collect and Process
Your (a) name, (b) business inquiry, (c) email address, (d) phone number, (e)
address, (f) company name, (g) job title, (h) operating system, (i) browser
type, (j) device information, (k) viewed or searched products or services, (l)
other website data, including page response times, download errors, length of
visits to certain pages, page interaction information (such as scrolling,
clicks, and mouse-overs), and methods used to browse away from the page, (m)
cookie data (for more information about our use of cookies, please see our
Cookie Notice at www.telit.com/cookie-policy), (n) list of website pages visited
by you with timestamps, (o) IP address.
The aforementioned types of personal data we collect from you correspond to the
following categories of personal information collected by us and disclosed for
business purposes within the past 12 months in our role as a “business” (as
defined in the CCPA):
* Identifiers and information that relates to, describes, or is capable of
being associated with, a particular individual;
* Professional or employment-related information;
* Commercial information, including products or services purchased, obtained,
or considered;
* Device and browser information;
* General geolocation data;
* Internet or other electronic network activity information, including, but not
limited to, browsing history, search history, and information regarding a
consumer’s interaction with an internet website, application or
advertisement.
Why Do We Collect Your Personal Data and What are the Lawful Bases?
Purpose for Processing of Your Personal DataLawful Basis for Processing of Your
Personal DataOur Legitimate Interest in the Processing of Your Personal
DataEstablishment and management of our relationship with youLegitimate
InterestsEfficiently fulfilling our contractual and legal obligations, providing
support, exercising or defending against legal claims, market evaluation,
management reporting (internally and externally)Increasing internal awareness
about how our products, services and website may be usedLegitimate
InterestsUnderstanding the market in which we operate, improving our website and
presenting its contents to you,
management reporting (internally and externally)Security managementLegitimate
InterestsSecurity management and risk and crime prevention, including anti-money
laundering, export control compliance, and management reporting (internally and
externally)Increasing your awareness about products, services, and events that
may be of interest to you by letter, phone, email, or other forms of electronic
communicationLegitimate InterestsPromoting our products and servicesGeneral
business managementLegitimate InterestsManagement reporting and
assessmentsStatutory reporting obligationsLegitimate InterestsReporting to
applicable bodies/entities as required by law
If you object to our use of your personal data for the aforementioned purposes,
including for direct marketing purposes, please contact us by using the
following email address: privacy@telit.com.
We will seek your prior consent, when required by applicable law, when, for
direct marketing purposes, we use (a) cookies or other similar technologies,
and/or (b) your email address to communicate marketing information to you.
The following are the CCPA business or commercial purposes for which we use each
category of personal information. Details about the information we collect for
each category are provided above.
Categories of Personal InformationBusiness or Commercial Purposes Pursuant to
the CCPAIdentifiers and information that relates to, describes, or is capable of
being associated with, a particular individual; professional or
employment-related information.Performing services, including providing customer
service, verifying customer information.
Auditing related to a current interaction with the consumer who is a job
applicant.Device and browser information, Internet or other electronic network
activity informationDetecting security incidents, protecting against malicious,
deceptive, fraudulent, or illegal activity and prosecuting those responsible for
such activity. Improving our website and presenting its contents to you.
Undertaking internal research for technological development and demonstration.
Conducting business analysis, such as analytics, projections, identifying areas
for operational improvement.
Undertaking activities to verify or maintain the quality of the service and to
improve, upgrade, or enhance the service.
Debugging to identify and repair errors.
Section 2.5: Whistleblowing Procedures
Sources of Personal Data
We may obtain your personal data from (a) you directly, for example, when you
submit a whistleblower report through our internal reporting channel or through
external reporting channels (such as designated authorities), and/or (b) another
individual who submitted a whistleblower report referencing you through our
internal reporting channel or through external reporting channels.
Personal Data that We Collect and Process
Whistleblower data: Telit Cinterion provides a fully anonymous internal
whistleblowing reporting channel. If you decide to remain anonymous as a
reporter by using this channel, we will not have access to your identity.
However, please be aware that, depending on the content of the report, it may be
possible to draw conclusions about your identity. Also, if you don’t provide us
with your contact details, we will not be able to provide you with feedback
regarding your report.
If you choose to report using your identity, we will process your (a) name, (b)
email address (c) employee number (to the extent you are our employee), and (d)
any other personal information you choose to provide in the report. Please note
that reported information is handled confidentially. Within the scope of
applicable laws (such as the EU Whistleblower Protection Directive (Directive
(EU) 2019/1937) the identity of the reporting person will not be disclosed to
anyone beyond authorized staff members who are competent to receive or follow-up
on reports, unless explicit consent is provided by the reporting person or where
it is necessary and proportionate under applicable laws (such as EU or Member
State law), particularly in the context of investigations by national
authorities or judicial proceedings. This does not apply to persons reporting
false information willfully or in gross negligence. If necessary to engage
external expertise (e.g., legal and auditing services), we may forward personal
data to such parties.
Other data: We will also process personal data of accused individuals, witnesses
or other data subjects included in whistleblowing allegations, as contained in
whistleblowing reports submitted to us and in the documentation and evidence
collected during the investigations of such procedures, including data collected
from our information systems, as well as any other personal data required in
order to manage such procedures.
For further information please see our Whistleblowing Policy.
The aforementioned types of personal data we collect correspond to the following
categories of personal information collected by us and disclosed for business
purposes within the past 12 months in our role as a “business” (as defined in
the CCPA) or as a “controller” (as defined in other US state privacy laws):
* Identifiers and information that relates to, describes, or is capable of
being associated with, a particular individual;
* Professional or employment-related information; and
* Sensitive personal information (as defined under the CCPA or other applicable
US state privacy laws): contents of mail and email.
Why Do We Collect Your Personal Data and What are the Lawful Bases?
Purpose for Processing of Your Personal DataLawful Basis for Processing of Your
Personal DataOur Legitimate Interest in the Processing of Your Personal Data/
other detailsProcessing required by applicable whistleblower laws (e.g. EU
Whistleblower Protection Directive and corresponding national laws) and
statutory reporting obligationsLegal ObligationManagement of whistleblowing
procedures, when the processing is not required under applicable lawsLegitimate
InterestsInvestigating misconduct, effectively enforcing whistleblower
compliance standards and requirements, Internal business process optimization,
exercising or defending legal rightsDisclosing the identity of the reporting
person (when such disclosure is not a statutory obligation)Explicit
consentIdentity of reporting person is disclosed to a controlled and limited set
of parties for the purpose of the investigation, such as internal investigation
team, senior management and external legal counselProcessing special category
dataPublic Interest (if applicable) or explicit consent
Section 2.6: Job Applicants
Sources of Personal Data
When you apply to a position at Telit Cinterion, you provide us with your
personal data. Please note that, in most cases, we receive the information
directly from you (such as through our website career portal, mail or email), or
record data in interview records, but we may also receive information from
recruitment service providers and consultants, online professional networks
(e.g. LinkedIn), references or background check companies. This information is
necessary to initiate, carry out or terminate the application process, to
exercise and fulfill legal and contractual obligations and, if necessary, for
the purpose of legal prosecution. If you do not provide us with this data, we
will not be able to assess you as a candidate and advance your recruitment
process.
Personal Data that We Collect and Process
When you apply for a job with us, we may collect and process the following
personal data:
* Basic Information: Your name, contact details, and gender.
* Employment Details: Employment history, education background, qualifications,
training, certifications, skills, and any other relevant information included
in your resume (C.V.) and job application.
* Application Insights: Desired salary expectations, personal characteristics
(e.g., reliability), career priorities (e.g., opportunities for advancement,
job preferences), availability, preferred start date, and type of desired
employment.
* Correspondence and References: Email communications, information from
references, and notes from job interviews.
* Assessment and Background Checks: Responses to assessments (such as integrity
tests) and results from background checks, as permitted by applicable law.
In certain situations, we may also collect special categories of personal data,
including national origin, citizenship status, health information (e.g.,
disability status, pregnancy), and gender identity. If you apply through our
website career portal, we will also gather technical data, including your IP
address, the destination URL, the content of your request, and the access status
or HTTP status code.
The aforementioned types of personal data we collect from you correspond to the
following categories of personal information collected by us and disclosed for
business purposes within the past 12 months in our role as a “business” (as
defined in the CCPA):
* Identifiers and information that relates to, describes, or is capable of
being associated with, a particular individual, such as your name, contact
information and gender;
* Professional or Employment-Related Information: This includes your skills,
employment history, education, qualifications, and training, professional
experience, salary expectations, career priorities, availability, and job
preferences;
* Sensitive Personal Information: As defined under the CCPA and applicable
state privacy laws, this includes government-issued IDs, health data, and
other sensitive information you may provide;
* Technical Data: Information collected from our website career portal, such as
IP address, browsing history, device information, and access status or HTTP
status codes.
Why Do We Collect Your Personal Data and What are the Lawful Bases?
Purpose for Processing of Your Personal DataLawful Basis for Processing of Your
Personal DataOur Legitimate Interest in the Processing of Your Personal Data/
other detailsCarrying out the recruitment and employment evaluation
processProcessing is necessary for the performance of a contract to which the
data subject is party or in order to take steps at the request of the data
subject prior to entering into a contract (in conjunction with GDPR Article
9(2)(b) for special category data)Evaluating employment candidates, digital
processing of application, communication with applicants, obtaining background
checks and references, recruitment tests.Processing and temporary storage of
website access logsLegitimate InterestTo secure our information technology
systems, ensure the functionality and security of our website and enable the
delivery of the website to your end deviceTo comply with our legal obligations
as an employer (e.g. to check your eligibility to work), to respond to legal
proceedings, subpoenas or inquiries from supervisory authorities or other
competent authoritiesLegal obligationLegal prosecutionLegitimate interestTo
enforce our own legal claims or defend ourselves against legal claimsAdding your
details to our applicant poolConsentRetaining your data on a long-term basis for
future vacancies
SECTION 3: WHO DO WE SHARE YOUR PERSONAL DATA WITH?
Summary: we share personal data with our service providers, partners, group
companies, and authorities, where required.
Affiliates
We may share your personal data internally with our affiliated companies to the
extent necessary to fulfill the purposes listed above in Section 2 (‘what
personal data we collect and why?’), including our business representatives or
of any of our affiliated companies, whether wholly or partially owned by us or
co-owned companies. Sharing your personal data will always take place under an
approved transfer mechanism, such as the relevant standard contractual clauses,
if applicable.
Our Service Providers
We transfer personal data to third parties under a variety of circumstances. We
endeavor to ensure that such third-party recipients use your personal data only
to the extent necessary to perform their functions and to have an agreement in
place with them to govern such processing on our behalf. These third parties
include business partners, suppliers, affiliates, agents and/or sub-contractors
for the performance of any agreement we enter into with you or with your
employer. They assist us in providing the services and products we offer,
processing transactions, fulfilling requests for information, receiving and
sending communications, analyzing data, providing IT and other support services,
and other tasks from time to time. These third parties may also include
analytics and search engine providers that assist us in the improvement and
optimization of our websites and for marketing purposes.
We periodically add and remove third-party service providers. At the present
time, we may share your information with the following types of service
providers:
* our distributors in your area who distribute Telit Cinterion’s products and
services, and who may contact you to offer Telit Cinterion’s products and
services;
* technical support providers who assist with our website and IT
infrastructure;
* third party software providers, including ‘software as a service’ solution
providers, where the provider hosts the relevant personal data on our behalf;
* professional advisers such as legal consultants, accountants, tax advisors,
debt collection agencies, auditors and insurance brokers;
* providers that help us generate and collate reviews in relation to our
products and services;
* our advertising and promotional agencies and consultants and those
organizations selected by us to carry out marketing campaigns on our behalf;
and/or
* providers that help us store, collate and organize information effectively
and securely, both electronically and in hard copy format (e.g. cloud service
providers), and for marketing purposes.
Content that you post on Telit Cinterion’s Technical Forum may be viewable by
other users of the website and Internet users in general, along with your
username on the website. For the avoidance of doubt, we may transfer and
disclose non-personal data to third parties at our own discretion.
Mergers and Acquisitions
We may disclose your personal data to third parties if some or all of our
companies or assets are acquired by a third party, including by way of a merger,
share acquisition, asset purchase, or similar transaction in which personal data
will be one of the transferred assets.
Protection of Rights, Compliance and Legal and Regulatory Obligations
We will transfer your personal data to third parties if we are under a duty to
disclose or share such data (a) in order to comply with any legal, auditory, or
compliance obligation, (b) in the course of any legal or regulatory proceeding
or investigation, (c) in order to enforce or apply our terms and other
agreements with you or with a third party, or (d) in order to assert or protect
our rights, property, or safety or those of others. This includes exchanging
information with other companies and organizations for the purposes of complying
with our legal and regulatory obligations, asserting or protecting our rights,
fraud protection, credit risk reduction, and the prevention of cybercrime.
SECTION 4: WHERE DO WE STORE YOUR DATA?
Summary: we store your personal data across multiple global locations.
We store your personal data on servers owned or controlled by us or have such
data processed by third parties on behalf of us, such as by reputable cloud
service providers (see Section 5 (transfers of personal data outside the
EU/European Economic Area) regarding international transfers).
SECTION 5: INTERNATIONAL TRANSFERS OF PERSONAL DATA
Summary: we transfer personal data internationally, including to and from the
EEA, UK, US, Israel, China, Taiwan, Japan, Australia, South Korea, Brazil and
elsewhere with appropriate safeguards in place.
We transfer personal data internationally in order to:
* Store or backup the information;
* Enable us to fulfill our contractual commitments to you or your employer;
* Enable us to fulfill any legal, auditory, ethical, or compliance obligations
which require us to make such a transfer;
* Facilitate the operation of our group business, where it is in our legitimate
interest, and we have concluded that such interest(s) are not overridden by
your right(s);
* Serve our shareholders across multiple jurisdictions; and
* Operate our affiliates in an efficient and optimal manner.
Transfers from EU/UK: Your personal data may be transferred to, stored, and
processed at a location outside of the European Economic Area (“EEA”) and the
UK. We will only do so using one of the following safeguards:
a.) the transfer is to a non-EEA country (or non-UK country) that has been the
subject of an adequacy decision by the European Commission or by the UK (as
applicable);
b.) the transfer is covered by a contractual agreement, which covers the GDPR
requirements relating to transfers to countries outside the EEA/UK, such as the
Standard Contractual Clauses (“SCCs”) published by the European Commission or
the UK’s International Data Transfer Addendum to the EU Commission;
c.) the transfer is to an organization which has binding corporate rules
approved by an EU or UK, data protection authority; or
d.) the transfer is to an organization in the US that is EU-US Privacy Shield
certified.
International transfers to our affiliates, subsidiaries and parent company are
governed by applicable Standard Contractual Clauses for Controllers and, where
relevant, for Processors.
We may also transfer your data to third-party vendors outside the EU/UK, such as
our customer relationship management (CRM) system and due diligence providers
(e.g., Salesforce and Amazon Web Services (AWS)). Where we do so, the SCCs or
other safeguards are in place to safeguard that personal data.
For more information about these safeguards, please contact us by using the
following email address: privacy@telit.com.
Transfer of personal Data from P.R. China: Personal data originating from the
People’s Republic of China (P.R. China) may be transferred to locations outside
P.R. China only under certain circumstances. These circumstances include
conducting an internal assessment of the receiving entity and its safeguards and
ensuring compliance with applicable laws of P.R. China regarding the outbound
transfer of personal data.
SECTION 6: YOUR RIGHTS (EEA/UK/SWITZERLAND/OTHER APPLICABLE LOCATIONS)
Summary: depending on the law applicable to your personal data, you may have
various data subject rights, such as rights to access, erase, and correct your
personal data, in addition to information rights. We will respect any lawful
request to exercise those rights.
If the GDPR (or other applicable data protection laws) applies to the processing
of your personal data, subject to the circumstances and legal exemptions that
may apply, you have certain rights in relation to the processing of your
personal data by us as a controller. These rights may vary depending on your
location and applicable laws, and may include the rights to:
* Access – the right to request confirmation that personal data about you is
being processed by us and, if so, what types and for what purposes, as well
as for how long and with whom your personal data is being shared with. This
enables you to receive a copy of the personal data we hold about you and to
check that we are lawfully processing it.
* Rectification – the right to request correction or updating to any of the
personal data that we hold about you. This enables you to have any incomplete
or inaccurate information we hold about you corrected.
* Erasure – the right to request the deletion of any personal data about you
held by us.
* Portability – the right to request that any personal data about you held by
us be transferred to you or any third party in a machine-readable formatted
copy.
* Restriction of Processing – the right to request that your personal data held
by us cease being processed. This may be exercised to allow the accuracy of
such data to be confirmed or while you evaluate a legal basis for processing.
* Objection – the right to object to the processing of your personal data by us
under certain circumstances. This right may apply where the processing of
your personal data is based on our legitimate interests (including for direct
marketing), as explained above, or where decisions about you are based solely
on automated processing, including profiling.
* Withdrawal of Consent – the right to withdraw your consent at any time to our
processing of your personal data where such processing relies on your
consent. For example, if we collected your consent to receive our marketing
communications, you can also unsubscribe from such communications by emailing
unsubscribe@telit.com.
If at any time you decide that you would like to exercise any of your rights as
set out above, you can contact us by emailing the following email address:
privacy@telit.com. We will respond to such requests without undue delay as
required by applicable law. Please note that we may have to undertake an
authentication process prior to facilitating the exercise of any requested
right(s). Furthermore, please note that personal data held by us may be either
deleted or retained in an aggregated manner without being linked to any personal
identifiers depending on specific technical and commercial capabilities. Such
data may continue to be processed by us.
Please note that these rights only apply under certain circumstances and may be
limited by law, as well as subject to exceptions. For example, where accepting
your request to exercise a right would adversely affect other individuals,
expose our trade secrets or intellectual property, where there are overriding
public interests, or where we are required by law to retain your personal data.
In addition, such rights cannot be exercised by data subjects in a manner
inconsistent with the rights of our staff or third-party rights. For example,
job references, reviews, internal notes and assessments, documents and notes,
including proprietary information or other forms of intellectual property,
cannot be accessed, erased, or rectified by data subjects. In addition, these
rights may not be exercisable where they relate to data that is not in a
structured form, such as emails, or where other exceptions apply.
Data subjects in the EU, the UK and other jurisdictions have the right to lodge
a complaint with a local data protection supervisory authority. If such
authority fails to respond to such a complaint, the applicable data subject may
have the right to an effective judicial remedy.
SECTION 7: YOUR RIGHTS AND ADDITIONAL DISCLOSURES (U.S. STATES, INCLUDING
CALIFORNIA, VIRGINIA, COLORADO, CONNECTICUT, UTAH, TEXAS, IOWA, MONTANA,
INDIANA, DELAWARE, OREGON, NEW JERSEY, NEW HAMPSHIRE)
Summary: We share limited website user data with third parties for online
advertising and analytics purposes. California and other US state consumers have
certain rights in relation to their personal information. They may exercise such
rights by contacting us.
This section provides additional details about the personal information we
collect about consumers in California, Virginia, Colorado, Connecticut, Utah,
Texas, Iowa, Montana, Indiana, Delaware, Oregon, New Jersey, New Hampshire and
other applicable US states and the rights afforded to them under the CCPA and
other applicable US state privacy laws.
Subject to certain limitations, if you are a resident of one of the US states
mentioned above, or of other states with applicable privacy laws, you have the
following rights in relation to personal information we process about you (other
than processing personal information as a service provider of a corporate
customer):
* Access – The right to know what personal information we have collected about
you, including the categories of personal information, the categories of
sources from which the personal information is collected, the business or
commercial purpose for collecting, selling, or sharing personal information,
the categories of third parties to whom we disclose personal information, and
the specific pieces of personal information the we have collected about you.
This may also include under certain laws the right to obtain the personal
information in a portable and, to the extent technically feasible, readily
usable format.
* Delete – The right to delete personal information that we have collected from
you, subject to certain exceptions.
* Correct – The right to correct inaccurate personal information that we
maintain about you.
* Opt Out of Sale or Sharing of Personal Information – The right to opt-out of
the sale or sharing of your personal information, including from the use of
your personal information for cross-contextual behavioral advertising,
targeted advertising (as defined by applicable laws) or certain types of
profiling. Please note we do not engage in such types of profiling of
individuals.
* Limit Use of Sensitive Information – If we use or disclose sensitive personal
information for reasons other than standard business purposes (such as
purposes set forth in section 7027, subsection (m) of the California Consumer
Privacy Act Regulations), the right to limit the use or disclosure of your
sensitive personal information. Please note we do not use sensitive personal
information for such purposes.
* Non-discrimination – The right not to receive discriminatory treatment by us
for the exercise of privacy rights conferred by applicable laws.
If you would like to exercise any of your rights as described above, you should
email us to: privacy@ telit.com. We may ask you for additional information to
confirm your identity and for security purposes before disclosing the personal
information requested by you, such as by using a two-or three-point data
verification process, depending on the type of information being requested. If
we refuse your request, you may have the right to appeal our decision using the
same email address described above. You may also designate an authorized agent
to make a request on your behalf. To do so, you need to provide the authorized
agent written permission to do so and the agent will need to submit to us proof
that they have been authorized by you.
For details about personal information that we have collected as a business and
disclosed for business purposes over the last 12 months, please see Section 2
(‘what personal data we collect and why?’) above. We share this information with
the categories of third parties described in Section 3 (‘who do we share your
personal data with?’) above. In the last 12 months, we have not sold or shared
any personal information, aside from website visitor information, as described
in the next paragraph (‘Notice of Right to Opt-out of Sale/Sharing’). We do not
use or disclose sensitive personal information for reasons other than standard
business purposes, such as the purposes set forth in section 7027, subsection
(m) of the California Consumer Privacy Act Regulations. We do not knowingly or
willingly share or sell (for cross-contextual behavioral advertising or targeted
advertising purposes) data of users under 16 years of age.
Notice of Right to Opt-out of Sale/Sharing
We do not sell your personal information in the conventional sense, such as for
monetary gain. However, like many companies, we use advertising and analytics
services that are intended to analyze your interactions with our website, based
on information obtained from cookies or other trackers as further described in
detail in our Cookie Policy. Please note that these activities constitute
“sharing” and “selling” website visitor information (as described under Section
2 above) with third parties for the purpose of cross-context behavioral
advertising (as defined in the CCPA), targeted advertising (as defined in other
applicable US state laws) and website analytics purposes. Such third parties
consist of analytics, marketing and search engine providers that assist us in
the improvement and optimization of our websites and for marketing purposes. If
you are a resident of California, Virginia, Colorado, Utah, Connecticut, Texas,
Iowa, Montana, Indiana, Delaware, Oregon, Indianna and other applicable
jurisdictions, you may opt out of the sharing or selling of your data for such
purposes by clicking here, or within our Cookie Storage Preferences tool
(located by clicking the floating cookie icon to the bottom left of the web
page) by switching the toggle under “Do Not Sell or Share My Personal
Information” to the right and clicking save. This signal will apply to your
browser and device in a frictionless manner. If you switch browsers or devices
you will need to opt-out again. You may also set the Global Privacy Control
(GPC) to opt out of the “sale” or “sharing” of your personal information for
targeted advertising for each participating browser system that you use.
SECTION 8: RETENTION PERIOD
Summary: we retain your personal data according to our data retention policy, as
required to meet our obligations, protect our rights, and manage our business.
We will keep and process your personal data only for as long as is necessary for
the purposes for which it was collected in connection with your relationship
with us, unless we have a legal right or obligation to retain the data for a
longer period, or the data is necessary for the establishment, exercise or
defense of legal claims or the enforcement of agreements. This includes
retaining your personal data in order to meet any audit, compliance and business
best-practices obligations.
Your personal data that is no longer needed to be retained will be anonymized or
deleted. For example, metadata or statistical information that are not subject
to deletion pursuant to this policy may be retained but it will be impossible to
identify you from this data. Lastly, some data may be retained on the servers of
our third-party service providers until deleted pursuant to their applicable
policies, as well as in our back-up drives until overwritten.
SECTION 9: SECURITY AND STORAGE OF INFORMATION
Summary: we take data security very seriously, invest in security systems, and
train our staff in data security procedures. In the event of a breach, we will
notify the appropriate individuals as required by law.
We take great care in implementing, enforcing and maintaining the security of
the personal data we process. We implement, enforce, and maintain security
measures, technologies, and policies to prevent the unauthorized or accidental
access to or destruction, loss, modification, use, or disclosure of personal
data. We likewise take steps to monitor compliance of such policies on an
ongoing basis. Where we deem it necessary in light of the nature of the data in
question and the risks to data subjects, we encrypt data. Likewise, we maintain
cybersecurity standards that exceed industry standards to ensure our website
and platforms are safe.
Please note, however, that no data security measures are perfect or
impenetrable, and we cannot guarantee that unauthorized access, leaks, viruses
and other data security breaches will never occur.
Within Telit Cinterion, we endeavor to limit access to personal data to those of
our personnel who: (i) require access in order for us to fulfil our obligations,
including also pursuant to our agreements, and as described in this Notice; (ii)
have been appropriately and periodically trained with respect to the
requirements applicable to the processing, care and handling of the personal
data; and (iii) are under confidentiality obligations as may be required under
applicable law.
We shall act in accordance with our policies and with applicable law to promptly
notify the relevant authorities and data subjects in the event that any personal
data processed by us is lost, stolen, or where there has been any unauthorized
access to it, all in accordance with applicable law and on the instructions of
qualified authority and we shall promptly take reasonable remedial measures.
SECTION 10: GENERAL
Children Under 16. We do not knowingly collect or solicit information or data
from or about children under the age of 16 or knowingly allow children under the
age of 16 to register for our services. If you are under the age of 16, do not
register or attempt to register for any of our services or send any information
about yourself to us. If we learn that we have collected or have been sent
personal data from a child under the age of 16, we will delete that personal
data as soon as reasonably practicable without any liability to us. If you
believe that we might have collected or been sent information from a minor under
the age of 16, please send an email immediately to privacy@telit.com.
Changes this Notice. The terms of this Notice will govern the use of the
services, websites, and any information collected in connection with them. We
may amend or update this Notice from time to time. The most current version of
this Notice will be available at: https://www.telit.com/privacy-policy/. Changes
to this Notice are effective as of the stated “Last Revised” date above and your
continued use of our services will constitute your active acceptance of the
changes to and terms of the Notice.
Contact Us. We aim to process only adequate, accurate and relevant data limited
to the needs and purposes for which it is gathered. We also aim to store data
for the time period necessary to fulfill the purpose for which the data is
gathered. We only collect data in connection with a specific lawful purpose and
only process data in accordance with this Notice. For any questions, complaints
or comments concerning this Notice, you are welcome to contact us (details
below) and we will make an effort to reply within a reasonable timeframe.
Our Data Protection Officer (DPO) may be contacted at: privacy@telit.com.
Our details are as follows:
Telit IoT Solutions Holding Ltd. (or other Telit Cinterion entities and branches
as listed in Annex 1 below)
Cannon Place, 78 Cannon Street, London, England, EC4N 6AF
ANNEX 1: TELIT CINTERION ENTITIES AND BRANCHES
EU ENTITIES
Telit EntityCountryTelit Communications SpAItalyTelit Wireless Solutions
GmbHGermanyTelit Cinterion Deutschland GmbHGermanyTelit Communications Spain
SLSpainTelit Communications Cyprus Ltd.CyprusTelit Technologies (Cyprus)
Ltd.CyprusTelit IoT Solutions Filial (Branch)SwedenTelit Wireless Solutions Gmbh
(Branch)France
ENTITIES OUTSIDE THE EU
Telit EntityCountryTelit IoT Solutions Holding Ltd.United KingdomTelit IoT
Solutions Ltd.United KingdomTelit IoT Ltd.United KingdomTelit Communications
LimitedUnited KingdomTelit IoT Solutions, Inc.United StatessecureWISE, LLCUnited
StatesTelit Wireless Solutions Tecnologia E Serviços LtdaBrazilTelit Cinterion
Brasil LtdaBrazilTelit Wireless Solutions Co LtdRepublic of KoreaTelit Wireless
Solutions Ltd.IsraelTelit Wireless Services Ltd.IsraelTelit Wireless Solutions
Hong Kong LimitedHong KongTelit Wireless Solutions (Australia) Pty
LimitedAustraliaTelit Wireless Solutions (Shenzen) Ltd.ChinaTelit Wireless
Solutions (Shanghai) Ltd.ChinaTelit Wireless Solutions (Shanghai) Ltd. Beijing
Branch office )ChinaTelit Wireless Solutions Japan KKJapanTelit Wireless
Solutions Taiwan LimitedTaiwanTelit Communications India Private LimitedIndia
MODULES
* Modules Overview
* Cellular 5G
* Cellular LTE
* Cellular LPWA
* Wi-Fi & Bluetooth®
* Positioning
* Smart Modules
* NExT™ Modules
CONNECTIVITY
* Global Connectivity Plans & Services
* eSIM Provisioning
* Connectivity Management Platform
* Coverage Map
PLATFORMS
* Platforms Overview
* Connected Factories
* Connected Machines
* Artificial Intelligence
* SCADA & HMI Visualization
* Semiconductors
* OneEdge™
SOLUTIONS
* Solutions Overview
* Device Manufacturing and Supply Chain Management
* Engineering and R&D
* Device Compliance and Certification
* IoT Gateways
* IoT Security
SUPPORT & TOOLS
* Download Zone
* Development & Evaluation Kits
* IoT AppZone
* IoT University
RESOURCES
* Blogs
* Case Studies
* Partners
* White Papers
* Webinars On Demand
© Telit Cinterion 2024 All rights reserved.
* | Compliance Policies
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