Privacy Notice. (POL-090)

Last updated: 13th Nov 2023

1. What does AST Networks do?

AST Reygar is a part of AST Networks, a full-service communications integrator, headquartered in the UK, with group companies in the U.S., Singapore, and Australia. We integrate cutting edge services and applications with the world's leading communications providers to solve complex problems; enabling our customers greater connectivity and control over their satellite and GSM networks and the ability to remotely track, monitor and control their assets.

For more information about AST Networks, please see the "About Us” section of our Website at https://www.ast-networks.com/about-us.

2. Personal data we collect and process

a) The personal data we collect from you, either directly or indirectly, will depend on your relationship with us, the services you use or engage us to provide, and how you interact with us and/or with our Website. We collect personal data about you from the following different sources:

Information that you provide directly We collect personal data directly from you when you choose to provide us with this information online and through our other interactions with us (such as data collected when you subscribe to the latest updates from AST Networks, where we engage with you as a current customer or supplier/service provider to manage our relationship or where you are a prospective customer or suppliers/service providers, any enquiries and communications you have with us).
Information that we collect indirectly We collect your personal data indirectly, including through automated means from your device when you use our Website and when your visit our offices (via CCTV cameras). We also collect data indirectly from your device when you use our services. Some of the information we collect indirectly is captured using cookies and other tracking technologies, as explained further in the "Cookies and similar tracking technology" section below.
Information from third parties We also collect your personal data from third party sources, i.e., our service providers, and others who provide assistance to us in provision of our services. Where you use our service provided by your employer or a re-seller, we will also collect information from them in order to provide our services to you. Information received from third parties will be checked to ensure that the third party either has your consent or are otherwise legally permitted or required to disclose your personal data to us.

To the extent you engage with us through your social media account, we may collect information from your social media account.

In general, we will use the personal data we collect from you only for the purposes described in this Privacy Notice or for purposes that we explain to you at the time we collect your personal data. However, we may also use your personal data for other purposes that are compatible with the purposes we have disclosed to you (such as archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes) if and where this is permitted by applicable data protection laws.

b) The below describes the categories of personal data we collect from and about you when you use our services and/or interact with AST Networks.

Personal data description: Identity and Contact Data such as your name, email address, phone numbers, work address, company details.
Source: Directly from you, Third parties, Automatic collection
Personal data description: Business relationship Data such as billing information, financial information, company details and any other information needed to manage our business relationship, including account information to give you access to any online services we provide.
Source: Directly from you, Third parties
Personal data description: Customer Service Data such as any communications with us through our customer service agents, any queries you raise, including through our live chat, email or call history with us. This will include information as to how you contact us and the channel of communication that you use and any information that you send us (for example, if you provide a screenshot).
Source: Directly from you
Personal data description: Communications Data such as details about your device, when you use our services including phone number, SIM number, IMEI number, device specific plan information, records containing date, duration, apps used, and calls made and other such data usage data. This also includes internet connections records such as applications that are using data on the network.
Source: Automatic collection
Personal data description: Content Data such as the content of text messages or voice calls is not collected or processed by AST, save where necessary to comply with law (such as an interception warrant under policy investigatory powers).
Source: Automatic collection
Personal data description: Advertising and Marketing Data such as your interests based on your use of our Website, services, survey responses, preferences in relation to receiving marketing materials from us, communication preferences, your preferences for particular products or services and your subscription details.
Source: Directly from you, Automatic collection
Personal data description: CCTV Data collected in our facilities to prevent theft and fraud and more generally to protect our property and assets, employees, customers, suppliers, and visitors.
Source: Automatic collection
Personal data description: Device Data collected using tags and pixels, including your IP address, your ISP, and the browser you use to visit our Website, device type, unique device identification numbers or other identifiers including advertising identifiers.
Source: Automatic collection
Personal data description: Website Usage Data such as activity and Website page interaction, information that we capture using cookies and similar technologies (see the "Cookies and similar tracking technology” section below). This will include page views and searches, log-in information, clicks, operating system, information about content viewed, watched, or downloaded for offline access (as applicable), length of visits to certain pages, length of Website use, and other functional information on Website performance (for example, application version information, diagnostics, and crash logs).
Source: Automatic collection
Personal data description: Location Data collected when using our services or Website from which we can identify your precise geographic location.
Source: Automatic collection

We do not collect any sensitive personal data about you, such as health-related information or information about your race or ethnicity, or sexual orientation.

3. How we use your personal data (our purposes) and our legal basis for processing it

We use the personal data that we collect from and about you only for the purposes described in this Privacy Notice or for purposes that we explain to you at the time we collect your information. Depending on our purpose for collecting your information, we rely on one of the following legal bases:

Contract - we require certain personal data in order to provide our services and support the services you purchase or request from us;
Consent – in certain circumstances, we may ask for your consent (separately from any contract between us) before we collect, use, or disclose your personal data, in which case you can voluntarily choose to give or deny your consent without any negative consequences to you;
Legitimate interests – we may use or disclose your personal data for the legitimate business interests of either AST Networks or a third party, but only when we are confident that your privacy rights will remain appropriately protected. If we rely on our (or a third party's) legitimate interests, these interests will normally be to: operate, provide and improve our business, including our services and Website; communicate with you and respond to your questions; use insights to improve or develop marketing activities and promote our products and services; detect or prevent illegal activities (for example, fraud); and/or to manage the security of our IT infrastructure, and the safety and security of our employees, customers, suppliers and visitors. Where we require your data to pursue our legitimate interests or the legitimate interests of a third party, it will be in a way which is reasonable for you to expect as part of the running of our organisation and which does not materially affect your rights and freedoms. We have identified below what our legitimate interests are; or
Legal obligation – there may be instances where we must process and retain your personal data to comply with laws or to fulfil certain legal obligations.

The following provides more details on our purposes for processing your personal data and the related legal bases. The legal basis under which your personal data is processed will depend on the data concerned and the specific context in which we use it.

Customers / Suppliers / Service Providers (prospective, existing and former)

Purpose/Activity: To engage you to provide services to you or to receive services from you.
Type of personal data: Identity and Contact Data, Business Relationship Data
Lawful basis for processing including basis of legitimate interest: Performance of a contract with you, Our legitimate interests to operate and provide our business and to communicate with you, where our communications are not necessary to perform or enter into a contract with you.
Purpose/Activity: Provision of services to you or receipt of services from you.
Type of personal data: Identity and Contact Data, Business Relationship Data, Customer Services Data
Lawful basis for processing including basis of legitimate interest: Performance of a contract with you. Our legitimate interests to operate and provide our business and communicate with you, where our communications are not necessary to perform or enter into a contract with you.
Purpose/Activity: Respond to your communications regarding our or your business engagement, including service updates, confirmations, invoices, and support and administrative messages, communicating with you in respect of your enquiries, requests, or complaints.
Type of personal data: Identity and Contact Data, Business Relationship Data, Customer Services Data
Lawful basis for processing including basis of legitimate interest: Performance of a contract with you. Our legitimate interests to operate and provide our business and to communicate with you or your employer -where our communications are not necessary to perform or enter into a contract with you.
Purpose/Activity: To provide you access to any online services we provide such as a customer portal or platform.
Type of personal data: Identity and Contact Data, Business Relationship Data, Customer Services Data
Lawful basis for processing including basis of legitimate interest: Performance of a contract with you. Our legitimate interests to provide you with access to our online services, to assist you in managing your account with us.

End Users

Purpose/Activity: Provision of services and management of your use of the services on your behalf and/or on behalf of our customers.
Type of personal data: Identity and Contact Data, Customer Service Data, Communications Data, Location Data
Lawful basis for processing including basis of legitimate interest: Performance of a contract with you (where you engage with us directly), Our legitimate interests to operate and provide our services, including providing access to you or our customer to our online services such as our portal.

Visitors

Purpose/Activity: To keep the AST Networks' premises secure through CCTV.
Type of personal data: CCTV Data
Lawful basis for processing including basis of legitimate interest: Our legitimate interests to detect or prevent illegal activities and ensure the safety and security of our staff, customers, suppliers, service providers and visitors.
Purpose/Activity: Register you as a visitor at our premises including in relation to an event or meeting held at our premises or online.
Type of personal data: Identity and Contact Data
Lawful basis for processing including basis of legitimate interest: Our legitimate interests to ensure the safety and security of all individuals visiting us on-site and to provide you with registration information to fulfil a request to attend an event.

Website visitors

Purpose/Activity: Manage our use of tracking technologies, such as cookies (including enabling you to manage your cookie preferences) and analyse collected data to learn about our Website to improve our Website. This includes website analytics.
Type of personal data: Device Data, Website Usage Data
Lawful basis for processing including basis of legitimate interest: Consent (where required under applicable law). Otherwise (for strictly necessary cookies) our legitimate interests to operate, provide and improve our business including our Website or use the insights to improve or develop marketing activities and promotions.
Purpose/Activity: Contact you about our services or in response to your queries when you reach out through our Website or sign up to our updates.
Type of personal data: Marketing and Advertising Data, Customer Service Data
Lawful basis for processing including basis of legitimate interest: Consent (where required under applicable law). Otherwise (for strictly necessary cookies) our legitimate interests to operate, provide and improve our business including our Website or use the insights to improve or develop marketing activities and promotions.
Purpose/Activity: Personalise and customise your experience on our Website
Type of personal data: Device Data, Website Usage Data, Marketing and Advertising, Location Data
Lawful basis for processing including basis of legitimate interest: Consent (where required under applicable law). Otherwise, our legitimate interests to operate, provide and improve our Website and to use the insights to improve or develop marketing activities and promote our business.

All

Purpose/Activity: Comply with legal and regulatory obligations to which we are subject, including our obligations to respond to your requests under data protection law.
Type of personal data: Identity and Contact Data, Business Relationship Data, Content Data
Lawful basis for processing including basis of legitimate interest: Legal obligation.
Purpose/Activity: Protect our legal rights (including where necessary, to share information with law enforcement and others), for example to defend claims against us and to conduct litigation to defend our interests.
Type of personal data: Identity and Contact Data, Business Relationship Data, Customer Service Data, CCTV Data, Communications Data
Lawful basis for processing including basis of legitimate interest: Our legitimate interests to protect our business interests.
Purpose/Activity: To carry out any marketing or improvement of AST Networks' current service offering and business.
Type of personal data: Marketing and Advertising Data
Lawful basis for processing including basis of legitimate interest: Our legitimate interests to improve our services and promote AST Networks.
Purpose/Activity: To keep our business, including our Website, premises, staff, customers, suppliers, service providers and visitors secure offline and online and address threats to safety or safety of others, as well as to detect and prevent fraudulent or illegal activities.
Type of personal data: Identity and Contact Data, Business Relationship Data, Customer Service Data, CCTV Data, Device Data, Website Usage Data
Lawful basis for processing including basis of legitimate interest: Our legitimate interests or those of a third party to operate and provide our business, including our Website. To detect or prevent illegal activities and/or to manage the security of our IT infrastructure, and the safety and security of our staff, customers, suppliers, service providers and visitors.

4. Who we share your personal data with

We share your personal data with the following categories of recipients:

our group companies https://www.ast-networks.com/locations, who provide data processing services necessary to provide you with our services (for example, to support the delivery of our services) or who otherwise process personal data for purposes described in this Privacy Notice;
third party service providers and partners to support the delivery of, provide functionality for our services or Website, or who otherwise process personal data for purposes described in this Privacy Notice. Our third-party service providers and partners include: Suppliers of transmission capacity and connectivity services who we engage to provide communications services to you. They are responsible for the operation of the networks and services that they provide access to and for any processing of personal data that may occur in the delivery of their services. A list of the networks we use can be provided here: https://www.ast-networks.com/network-services. Couriers and freight forwarders where necessary for delivery of goods. IT service providers who support our systems and services. Banks, financial institutions, payment service providers who process data as part of the running of our business and provision of our services. Professional advisers such as outside counsel, accountants, and auditors
third party services when you use third party services linked through our Website, your personal data will be collected by the provider of such services. Please note that when you use third party services, their own terms and privacy notices will govern your use of their services;
any competent law enforcement body, regulatory, government agency, court or other third party (such as our professional advisers) where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person;
a buyer (and its agents and advisers) in connection with any actual or proposed purchase, merger, or acquisition of any part of our business, provided that we inform the buyer it must use your personal data only for the purposes disclosed in this Privacy Notice; or
any other person with your consent to the disclosure (obtained separately from any contract between us).

5. Cookies and similar tracking technology

What is a cookie? A cookie is a simple text file that is stored on a user’s computer (or mobile device) and is created when a user visits a website using a program called a browser (for example Internet Explorer, Firefox or Safari). A cookie isn’t a program itself and doesn’t actively do anything on a user’s computer. A cookie cannot be used to identify a user personally but they do contribute to improving a user’s experience of a website. A cookie simply allows the website to read the contents of the cookie text file. The text file itself simply contains a unique identifier code; the site name and some digits and numbers.
Why are Cookies used? Most websites will use cookies in order to improve the user experience by enabling the website to ‘remember’ the user, either for the duration of the visit or for repeat visits. Cookies do lots of different jobs, such as: Remembering what items a user may have added to a shopping basket or an itinerary as the user moves between pages on a website Saving a user’s preferences to allow them to customise a website Measuring what users do on a website to ascertain which parts of a website are popular, how long they spend on a website, how often users return, where they come from etc.
What Cookies are used by this site? Cookies are set by this website (first party cookies) but may also be set by other websites (e.g. You Tube) that run content on the website’s pages (third party cookies). Cookies can be set to remember a visitor for the duration of their visit (session cookies) or to remember a visitor for repeat visits (persistent cookies).
How do I disable cookies? All recent versions of popular browsers give users a level of control over cookies. Users can set their browsers to accept or reject all, or certain, cookies. Users can also set their browser to prompt them each time a cookie is offered. Please note that by deleting our cookies or disabling future cookies you may not be able to access certain areas or features of our site. Instructions links for the main browser types are listed here: Internet Explorer Firefox Chrome Safari (OS X) Safari (iOS)

6. How we keep your personal data secure

We use appropriate technical and organisational measures to protect the personal data that we collect and process about you. The measures are designed to provide a level of security appropriate to the risk of processing.

7. International data transfers

In some cases, where your personal data is transferred to another AST Networks' company or third parties, it is processed in countries other than the country in which you are resident. These countries may have data protection laws that are different to the laws of your country (and, in some cases, may not be as protective).

Specifically, our group companies are located in the UK, Singapore, U.S., and Australia. Our third-party service providers and suppliers operate around the world. This means that when we collect your personal data, we will process it in any of these countries.

Where we transfer your personal data to countries and territories outside of the European Economic Area and the UK, we ensure that we only do so in compliance with applicable data protection laws.

Where we provide communications services that enable the transmission of communications data internationally, it is your or your organisation's responsibility to ensure that you have in place lawful grounds to transfer any personal data in your communications to the intended recipients of your communications.

8. Data retention

We retain the personal data we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements).

In certain circumstances, we will need to keep your information for legal reasons after our contractual relationship has ended. The specific retention periods depend on the nature of the information and why it is collected and processed and the nature of the legal requirement. For example: we keep your information when we have a legal obligation to do so; where we need to in accordance with our contractual obligations with you and/or where we need to maintain a record of Communications Data to evidence usage for billing and invoice queries; to deal with and resolve requests and complaints; to protect individuals' rights and property and for litigation or regulatory matters (for example we would retained your information if there was an ongoing legal claim and the information was relevant to the claim. This information would be retained until the legal claim had been concluded.).

When we have no ongoing legitimate business need or legal reason to process your personal data, we will either delete or anonymise it or, if this is not possible (for example, because your personal data has been stored in backup archives), then we will securely store your personal data and isolate it from any further processing until deletion is possible.

9. Your data protection rights

Individuals located in the UK and EEA have the following data protection rights. To exercise any of them see specific instructions below or contact us using the contact details provided under the “How to contact us” heading below.

You may access, correct, update or request deletion of your personal data.
You can object to processing of your personal data, ask us to restrict processing of your personal data or request portability of your personal data, (i.e. your data to be transferred in a readable and standardised format.
You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you. To opt-out of other forms of marketing (such as postal marketing or telemarketing), please contact us using the contact details provided under the “How to contact us” heading below. If you choose to opt out of marketing communications, we may still send you non-promotional emails, such as emails about your account or our ongoing business relations.
If we have collected and processed your personal data with your consent, then you can withdraw your consent at any time by using the contact details provided under the “How to contact us” heading below. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal data conducted in reliance on lawful processing grounds other than consent
You have the right to complain to a supervisory authority about our collection and use of your personal data. For more information, please contact your local supervisory authority. Contact details for supervisory authorities in Europe are available here and for the UK here. Certain supervisory authorities may require that you exhaust our own internal complaints process before looking into your complaint.

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

10. Updates to this Privacy Notice

We may update this Privacy Notice from time to time in response to changing legal, regulatory, technical, or business developments. When we update our Privacy Notice, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material Privacy Notice changes if, and where, required by applicable data protection laws.

You can see when this Privacy Notice was last updated by checking the “last updated” date displayed at the top of this Privacy Notice.

11. How to contact us

If you have any questions or concerns about our use of your personal data, please contact us using the following details: dataprotectionoffice@ast-networks.com. You may also write to us at AST Networks, Satellite House, Bessemer Way, Harfrey’s Industrial Estate, Great Yarmouth, NR31 0LX, UK.

The data controller of your personal data is Applied Satellite Technology Networks., which is registered with the UK Information Commissioner's Office with registration number: Z6203886

For contact details of our group companies, please visit https://www.ast-networks.com/locations.