Privacy Policy

Telecom Infrastructure Partners respects your privacy and strives to protect your personal data.

About Telecom Infrastructure Partners

The Telecom Infrastructure Partners’ group is made up of different legal entities. These entities are listed in the Schedule of this policy. Together these entities are known as the “TIP Group”. This privacy policy is issued on behalf of the TIP Group. When we mention “TIP”, “we”, “us” or “our” in this privacy policy, we are referring to the relevant company in the TIP Group responsible for processing your data.  The Schedule also shows the relevant TIP Group company responsible for processing your personal data. That company is known as the “data controller”.

The Purpose of this Privacy Policy

This privacy policy informs you about:

1. how TIP, as a data controller, uses and shares the personal data we collect when we interact with prospective candidates, Interest Holders (owners of sites, and persons with real estate interests in land, clients and potential clients, including employees and representatives of these), current and previous partners/vendors, website visitors, sub-contractors and visitors, (together “you”/ “your”) by TIP, in each case, during the course of its business activities; and
2. your data protection rights under applicable data privacy laws and legislation (including but not limited to EU General Data Protection Regulation 2016/679 (the “GDPR”), the UK GDPR, the Data Protection Act 2018 (UK) and other applicable privacy laws to the extent that they apply to data controller’s data processing and business operations) (the “Data Privacy Laws”).

Please read this policy or other fair processing policy we may send you when we collect or process personal data about you, so that you are fully aware of how and why we are using your data. This policy supplements other notices. It is not meant to override them.

Sources of personal data

We will collect and process the following personal data about you in the following ways:

Categories of Personal Data / Personal Information	How We collect your data
Interest Holders, TIP’s tenants, or grantees	Directly from you while TIP is dealing with you
Business Partner/Vendor Personal Data or Personal Information	Directly from you while TIP is receiving services from you.
Prospective Candidates	Directly from you, if you have directly applied to us; from third parties or other sources (for example via recruitment agencies) but in each case only as far as legally permissible and only as far as is necessary. This may also include public sources such as professional networking platforms or job portals. Also when we are required to do so under applicable local law. From companies that carry out background checks, credit reference agencies and organisations that provide disclosure and barring services.
Visitor information	Directly from you at the time of visiting our premises or by a TIP employee.
Website Data	Directly from you when you voluntarily fill out your information on the website through forms which are provided so you can receive information from us, or so we can contact you.
Website Cookies	Refer to our Cookie Policy for information about how we collect information through our website cookies.
Marketing Data, and Initiatives	Directly from you when you interact with any TIP representative: via websites; by telephone; by email; via online portals; in person; or via professional networking platforms.

Purpose and legal basis of processing

Your Personal Data is stored and processed by us in the following ways and for the following lawful purposes:

1. where you have applied for a role with us, to process your job application with us and (only where legally permissible and where strictly necessary to assess your suitability for the relevant role) to conduct background screening checks on you,
2. where you are an Interest Holder, to negotiate transactions in relation to the land interests you hold, and so that we can manage our interests in relation to those transactions.
3. where you are a grantee, or tenant of a site in which TIP has an interest, to negotiate transactions in relation to that site, and so we can manage our interests in respect of that site.
4. to provide our services to you.
5. to comply with any legal and regulatory obligations that we have to discharge.
6. to exercise or defend our legal rights or for the purpose of legal proceedings.
7. where you are an employee or visitor to our premises, to record and monitor your use of our premises and/or information technology systems in order to maintain its security and protect them against fraud or unauthorised entry.
8. so we can use it for our legitimate business interests, such as: operating our website; managing our operations efficiently, conducting marketing activities designed to improve the services we offer to you; maintaining commercial relationships; and administering the security of our business (“Legitimate Business Interests”); and
9. to use it to prevent and respond to actual or potential fraud or illegal activities.

We may transfer Personal Information as an asset through a merger, acquisition, bankruptcy or other transaction in which a third party assumes control of the business in whole or in part. In such event, the third party cannot materially alter how it uses or shares the acquired Personal Information subject to certain exceptions.

We process your personal data based on the following legal bases pursuant to Article 6 GDPR:  

Categories of Personal Data	Purpose of Collection	Legal Basis
Interest Holders’ data	To fulfil the contractual obligations with persons with real estate interests in land for example: to administer existing accounts; make payments; and allow us to process payments in connection with existing real estate interests. For potential clients and business contacts, we will process your personal data to determine whether you might be interested in entering into a transaction with us or how we can help you	Performance of the contract and/or taking steps prior to entering into a contract. TIP´s legitimate interest in maintaining a commercial relationship with Interest Holders
Partner/vendor personal data	For receiving services from vendors/ partners so as to: receive products and services from you; and enable TIP to process payments and orders in respect of any goods or services you provide us with	Performance of the contract
Personal data on prospective candidates	Where you have applied for a role with us: so as to process your job application to us, and conduct background screening checks on you (only where legally permissible and where strictly necessary to assess your suitability for the relevant role); for diversity and inclusion purposes; or for making appropriate adjustments which may require us to process special categories of data such as information about disabilities (only when required under applicable national law).	Legitimate interest of managing the efficient operation of TIP and taking steps prior to entering into a contract
Visitor personal data	Where you are a visitor to our premises, to record and monitor your use of our premises and/or IT systems in order to maintain their security and protect them against fraud or unauthorised entry. You may be a visitor to a TIP Website, you may provide us with certain personal data, for the purpose of direct dealings with you, for example when: you ask us to send marketing materials to you.	Consent, Legitimate interest of conducting marketing activities of TIP
Personal data on data subjects in the context of marketing data, initiatives.	To engage in marketing and business development activities in relation to our products and services. This includes email and SMS marketing, other marketing communications as well as organising events. Use it for our legitimate business interests, managing the efficient management and operation of our business, conducting marketing activities designed to improve the services we offer to you.	Consent, legitimate interest of conducting marketing activities of TIP
Website Cookies	Where you use functionality or visit our website including (subject to acquiring your prior consent where legally necessary) the use of cookies on our website (see our Cookie Policy for more information).	Consent, legitimate interest of conducting marketing activities of TIP and operating the website

If we are processing your personal data in order to fulfil one or more of the legitimate interests of TIP (or a third party) set out in this section, then TIP will ensure that those interests do not override your fundamental rights, or interests. If you want to learn more about the legitimate interest assessments we have carried out, please contact us using the contact details below.

Special Categories of Personal Data

As we have said, we, where legally permissible, process your special categories of personal data on the following lawful bases:        

Retention periods

TIP shall retain your personal data, including marketing data, for only as long as we need it to fulfil the purpose(s) we collected it for. This includes retention of it in order to meet legal, accounting, or reporting requirements.

We determine the appropriate retention period for personal data, by assessing a number of criteria. Those criteria include: the nature, and sensitivity of the personal data; the amount of personal data we hold; the risk of harm associated with the unauthorised use or disclosure of your personal data; the purpose of processing of your personal data; whether we can achieve that purpose in other ways; and the relevant legal requirements.

For candidates, if you take up a role with TIP, we will retain the information you provided during the application process. This will become part of your employee file and held in line with TIP’s employee privacy policy or applicable laws.

If your application is unsuccessful, the information you have provided will be retained by TIP for six (6) months after we have communicated our decision to you. We do this, so that (in the event of a legal claim) we can demonstrate that we did not discriminate against candidates on prohibited grounds; and we conducted the recruitment process fairly and transparently.

After the six months have elapsed, we destroy personal information in a secure way, and in line with our data retention policy and our legal and regulatory obligations.

Children’s Online Privacy

We do not direct our website to minors and we do not knowingly collect personal data from children under 13 years old, or as defined by local legal requirements. If we learn we have mistakenly collected or received personal data from a child without appropriate consent, we will delete it. If you believe we have mistakenly or unintentionally collected any information from or about a child, please contact us at personaldata@telecom-ip.com. Note: We do not collect, use nor process, Personal data of Individuals under the age of 18 on our website. If you are below the age of 18, then we do not want you to provide any of your personal data via our website.

Disclosure and Recipients of Your Personal Data

TIP will not disclose or give access to personal data we hold about you to any third party, except where:

1. TIP sells any part of its business or assets. In this case, we might disclose personal data to any buyer or perspective buyer;
2. it is necessary to disclose information to companies in the TIP Group, or to board members of those companies;
3. to third parties who are providing services to us, such as IT services, or professional services that need to see that information and/or other services that help process data on our behalf for the listed purposes above
4. to the extent required by law, regulatory body or court order, for example if we are under a duty to disclose your personal data in order to comply with any legal obligation.

International Transfers

In some cases, we may transfer any of your personal data which is held in the UK or the European Economic Area (EEA) outside of the UK or EAA.

TIP has a subsidiary based in the United States. Occasionally, we may transfer personal data to this entity and employees of it. Please see the complete list of third countries in Part B of the Schedule below.

The Secretary of State in the UK has deemed that some countries outside of the UK provide an adequate level of protection for transfer of personal data outside of the UK. (“UK Adequacy Decision”).

Similarly, the European Commission has made an adequacy decision in respect of certain countries to whom we may transfer personal data outside of the EAA. (“EAA Adequacy Decision”).

But where we are transferring personal data outside of UK or EAA to countries where there is not an UK Adequacy Decision or an EAA Adequacy Decision, then we shall ensure it is protected in a similar way to any transfer we make to countries where there is an UK Adequacy Decision or an EAA Adequacy Decision. In appropriate cases this means that we complete standard contracts approved by the Secretary of State in the UK or (where appropriate) the European Commission.

If you need further information on how precisely we will protect your data when transferring your personal data out of the UK/EEA, then please email us at personaldata@telecom-ip.com.

Data Security: How we store and protect your data

We have implemented measures to ensure the security of the personal data we collect and store about you. We will take reasonable steps to protect your personal data from unauthorised disclosure or access. The steps we will take include using appropriate physical, electronic, and administrative safeguards We store all personal data you provide to us behind firewalls on servers employing security protections.  

Consent and the right to withdraw consent.

If TIP processes your personal data on the basis of your consent, you have the right to withdraw such consent at any time.

If you withdraw your consent, this will not affect the lawfulness of processes based on consent before that withdrawal. To withdraw your consent or to opt out of receiving marketing communications, please contact us by email at personaldata@telecom-ip.com or follow the unsubscribe instructions included in electronic marketing communications.

Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law. And we may need to keep some information to fulfil your request (for example, keeping your email address to make sure it’s not on our marketing list).   

Your data protection rights within the EAA and UK.

Pursuant to Data Privacy Laws, you have the following rights regarding your personal data:

1. The right to access – You have the right to request that TIP sends you copies of your personal data.
2. The right to rectification – You have the right to request that TIP correct any information you believe is inaccurate. You also have the right to request that TIP completes the information you believe is incomplete.
3. The right to erasure – You have the right to request that TIP erases your personal data, under certain conditions.
4. The right to restrict processing – You have the right to request that TIP restricts the processing of your personal data, under certain conditions.
5. The right to object to processing where we are relying on a legitimate interest or that of a third party. You have the right to object to TIP’s processing of your personal data, under certain conditions.
6. The right to data portability – You have the right to request that TIP transfer the data that we have collected to another organization, or directly to you, under certain conditions.

How to contact the appropriate authority

In the EAA and UK, you have a legal right to complain at any time to the relevant regulator (or supervisory authority) for data protection issues in the Member State where you live, work, or where the alleged infringement took place. Please find a complete list of supervisory authorities at this link.

However, we would be grateful if you contact us before you contact the relevant regulator so we can see if we can address your concerns first. In the UK, this authority is the Information Commissioner’s Office (ICO) which can be contacted here.

How to contact us

If you have any questions about TIP’s privacy policy, the data we hold on you, or you wish to exercise rights or complain please do not hesitate to contact us. Email us at: personaldata@telecom-ip.com

Changes to Our Privacy Policy

We will post any changes we may make to our privacy policy on this page. Please check back frequently to see any updates or changes to our privacy policy.

This privacy policy was last updated on 29^th June 2023

Schedule 1

Part A – UK and EEA entities

Belgium: Telecom Infrastructure Partners Belgium BV

Czech Republic: Telecom Infrastructure Partners Czech Republic, s.r.o.Denmark: Telecom Infrastructure Partners (Denmark) ApS

France: Telecom Infrastructure Partners France SAS

Italy: Telecom Infrastructure Partners Italia Srl Unipersonale; Immobiliare Senza Fili Alfa S.r.L.

Poland: Telecom Infrastructure Partners, Spzoo

Spain: Telecom Infrastructure Partners S.L.U.

UK: Nile UK Service Company LimitedTIP Alpha Limited

Luxembourg: Nile Topco S.à r.l.; Nile Midco S.à r.l.; Nile Finco S.à r.l.; TIP Alpha S.à r.l.

Part B – third country entities

Colombia: Telecom Infrastructure Partners Colombia S.A.S

Chile: Telecom Infrastructure Partners Chile, SpA

Peru: Telecom Infrastructure Partners Peru, S.A.C.

South Korea: Telecom Infrastructure Partners Korea LLC

USA: TIP Alpha USA,LLC