What kind of data and personal information do we collect, and for what purpose?
First and foremost, data and personal information is collected so that we can manage our business and our relationships with yourselves as customers, employees, suppliers etc. Information may also be collected to comply with certain laws, improve products or services as well as resolve any legal and/or commercial matters or disputes.
In general, personal information which may be asked for and collected includes your contact information (name, address, e-mail, phone number) and identification details. If we ask for special categories of personal information such as medical and health information, we will ask for your explicit consent and inform you of the purpose of the processing, if required.
Due to the varying nature of 9Lives’s services, different data and personal information may be collected. However, all data collected is deemed necessary for 9Lives to carry out its specific business purpose, and each service area has its own privacy notice relevant to the data and personal information being collected.
Data is generally collected directly from you as an individual via electronic means such as use of websites, forms and emails, or during phone calls with yourselves, or other correspondence methods.
We may also ask you to supply information to us from time to time, including when you report a problem with our services and when we ask you to complete surveys, questionnaires and feedback forms that we use for quality monitoring and research purposes.
It is your right to choose to provide us with personal information and to identify yourself to us, however if you choose not to provide personal information we request, we may not be able to provide you with the services you require.
What do we do with your data and personal information?
We are committed to ensuring your data and personal information is secure, preventing unauthorized access or disclosure, and have in place physical, electronic and managerial procedures to safeguard the information.
All data provided is held in a secure and relevant business system or archive appropriate to the purpose of the business and processing needs. This may be in electronic or paper format, where safeguards have been put into place to protect your data and personal information from loss, misuse and unauthorized access.
Some of your data may be transferred and processed by certain suppliers, e.g. IT suppliers, who process the information on behalf of 9Lives. 9Lives has carefully selected and agreed data processing agreements with our suppliers to ensure an adequate level of data protection is adhered to.
We may transfer some of your data to recipients in countries outside EU/EEA as we may use external suppliers to host/store some of our data and personal information. When transferring to recipients outside EU/EEA adequate safeguards will be provided such as in accordance with the US privacy shield schedme or on the basis of EU’s“Standard Contractual Clauses”.
The standard agreement is available in different languages via this link
Disclosure to 3rd parties may be carried out in some business areas where there is a specific and legitimate purpose and in compliance with applicable legislation and where all reasonable steps will be taken to ensure the 3rd parties are bound by confidentiality and privacy obligations in respect to the protection of personal information.
9Lives, in some specific cases, may use your data for direct marketing use in accordance to the applicable consent regulations in each business area and country. Please see the local consent and privacy notice for further details.
How do we retain, amend and delete your data and personal information?
We retain your data and personal information for as long as necessary to fulfill the stated purpose, and/or be in compliance with legislative requirements. Personal information comes under periodic review to ensure it is still necessary to retain. Each of 9Lives´s business and services has specific legislation and retention guidelines to adhere to.
We endeavor to hold information which is accurate, up to date and relevant. You should contact us via the relevant business or service if you think your personal information is incorrect, for us to take the appropriate steps to correct it.
What are your rights regarding your data and personal information?
It is your right to choose what information to provide us, however, if you choose not to provide the personal information we request, we may not be able to provide you with the services or information you require.
You have the right to access your personal data, to rectify incorrect information, delete, limit and data portability. You may also object to the processing of your personal data including automated and individual decisions.
You also have a right to lodge a complaint with the relevant supervisory authority.
Who should I contact for further information
Date: 23.5.2018. Version 1.