TCS Superhero Competition 2018 Privacy Notice

WHAT IS THE PURPOSE OF THIS DOCUMENT

Tata Consultancy Services Netherlands B.V (“TCS” or “we”) are committed to protecting the privacy and security of your personal data.

This privacy notice describes how we collect and use personal data you submit in your nomination for the TCS Superhero 2018 competition in accordance with the General Data Protection Regulation (GDPR) and the applicable National Data Protection legislation.

TCS is a “data controller”. This means that we are responsible for deciding how we hold and use personal data about you. We are required under data protection legislation to notify you of the information contained in this privacy notice.

This notice applies to nominations registered through the Portal.

It is important that you read this notice, together with any Terms and Conditions and TCS Privacy Policy.

DATA PROTECTION PRINCIPLES

We will comply with applicable data protection laws. This means that the personal data we hold about you must be:

  • 1. Used lawfully, fairly and in a transparent way.
  • 2. Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
  • 3. Relevant to the purposes we have told you about and limited only to those purposes.
  • 4. Accurate and kept up to date.
  • 5. Kept only as long as necessary for the purposes we have told you about.
  • 6. Kept securely

THE KIND OF INFORMATION WE HOLD ABOUT YOU

Personal data means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (aka anonymous data).

We will collect, store, and use the following categories of personal data about you and your partner/guest:

  • Last Name
  • First Name
  • Email address
  • Shoe Size
  • Address
  • Mobile
  • Telephone no
  • IP Address

If you have nominated a child you must have parental responsibility, and give your consent to the child’s personal data being processed in accordance with this notice.

HOW IS YOUR PERSONAL DATA COLLECTED

We collect personal data about from your entry on the private TCS registration portal

HOW WE WILL USE INFORMATION ABOUT YOU

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • 1. To support your application to enter the competition
  • 2. Where we need to comply with a legal obligation.
  • 3. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • 4. Prior to, during and after the event to promote the competition winners

We may also use your personal data in the following situations, which are likely to be rare:

  • 1. Where we need to protect your interests (or someone else’s interests).
  • 2. Where it is needed in the public interest or for official purposes.

Situations in which we will use your personal data

We process personal information for certain legitimate business purposes, which include some or all of the following:

  • Administering your application to participate in competition.
  • To conduct post competition analytics studies to review and to improve future events
  • Digital images including photographs and video may be used during and after the event to promote and provide a historical record

Some of the above grounds for processing will overlap and there may be several grounds, which justify our use of your personal data.

Whenever we process data for these purposes we will ensure that we always keep your Personal Data rights in high regard and take account of these rights. You have the right to object to this processing if you wish (see below). Please bear in mind that if you object this may affect our ability to carry out tasks above for your benefit.

If you fail to provide personal data

If you fail to provide certain information when requested, we may not be able to administer your nomination via the portal.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis, which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

DATA SHARING

We may have to share your data with third parties, including third-party service providers and other entities in the group. We require third parties to respect the security of your data and to treat it in accordance with the law. We may transfer your personal data outside the EU/EEA. If we do, you can expect a similar degree of protection in respect of your personal data.

Why might you share my personal data with third parties?

We will share your personal data with third parties where required by law, where it is necessary to administer the competition or where we have another legitimate interest in doing so.

Which third-party service providers process my personal data?

”Third parties” include the portal provider MOMICE B.V and the Amsterdam Marathon organiser Le Champion Third-party service providers carry out the following activities:

  • Portal provision and data capture

How secure is my information with third-party service providers and other entities in our group?

All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal data in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

When might you share my personal data with other entities in the group?

We will share your personal data with other entities in our group as part of our regular reporting activities directly related to this event

What about other third parties?

We may share your personal data with other third parties. We wiil need to share your personal data with “le Champion” who is the race organizer. We may also need to share your personal data with a regulator to comply with the law.

Transferring information outside the EU/EEA

We will transfer the personal data we collect about you to the following countries outside the EU/EEA: India and the United States in order to promote and report on nominations to. There is not an adequacy decision by the European Commission in respect of India. This means that the entities in India to which we transfer your data are not deemed to provide an adequate level of protection for your personal data. However, to ensure that your personal data does receive an adequate level of protection we have put in place data transfer agreements to ensure that your personal data is treated by those third parties in a way that is consistent with and which respects the EU/EEA laws on data protection. If you require further information about these protective measures, you can contact our EU Data Protection Officer via email at DPO.Europe@TCS.COM

DATA SECURITY

We have put in place measures to protect the security of your information. Details of these measures are available upon request from the DPO in this notice. Third parties will only process your personal data on our instructions and where they have agreed to treat the information confidentially and to keep it secure.

We have put in place appropriate technical, organizational and security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

DATA RETENTION

How long will you use my information for?

Personal information you submit to the registration portal will be retained for 30 days after the nominations close.

In some circumstances, we may anonymize your personal data so that it can no longer be associated with you, in which case we may use such information without further notice to you.

DATA SUBJECT RIGHTS

Your duty to inform us of changes

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Your rights in connection with personal data

Under certain circumstances, by law you have the right to:

  • Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
  • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see below).
  • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation, which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal data for direct marketing purposes.
  • Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it.
  • Request the transfer of your personal data to another party.

If you want to exercise, a data subject right please contact our EU DPO at DPO.EUROPE@TCS.COM

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal data is not disclosed to any person who has no right to receive it.

RIGHT TO WITHDRAW CONSENT

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact our EU DPO at DPO.EUROPE@TCS.COM

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.

DATA PROTECTION OFFICER

We have appointed a data protection officer (DPO) to oversee compliance of TCS with applicable data protection laws and with this privacy notice. If you have any questions about this privacy notice, or how we handle your personal data, please contact the DPO at DPO.EUROPE@TCS.COM

DATA PROTECTION SUPERVISORY AUTHORITY

You have the right to make a complaint at any time to the relevant data protection supervisory authority. For example in the Netherlands you can contact:

Autoriteit Persoonsgegevens
Postbus 93374
2509 AJ DEN HAAG
Telephone number: (+31) - (0)70 - 888 85 00

CHANGES TO THIS PRIVACY NOTICE

We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal data.