PRIVACY Policy

Last updated: October 31, 2023

PLEASE READ THIS POLICY CAREFULLY TO UNDERSTAND HOW WE TREAT YOUR PERSONAL INFORMATION AND YOUR RELATED CHOICES AND RIGHTS. IF YOU DO NOT AGREE WITH THE TERMS AND CONDITIONS OF THIS POLICY, YOU SHOULD NOT ACCESS OR USE OUR WEBSITE.

Introduction

COMSAT, a Goonhilly company, (referred to as the “Company,” “we,” “us,” and “our”) is committed to protecting the privacy and security of the personal information we collect, use, share, and otherwise process as part of our business. We also believe in transparency, and we are committed to informing you about how we treat the data we collect and process.


When Does this Policy Apply? This Privacy Policy (the “Policy”) describes our practices and how we may use information about you (“Personal Information”) that we collect or process.


This policy applies to information we collect:

  • On https://www.comsatteleports.com/, (the “Website”) operated by us from which you are accessing this Privacy Policy;
  • Through email, text, and other electronic correspondence between you and the Company.

 

It does not apply to information collected by:

  • The Company offline or through any other means, including on any other website operated by Goonhilly, its affiliates and subsidiaries;
  • Any software application made available by us for use on or through smartphones or other mobile devices; or
  • Any third-party (including our affiliates and subsidiaries), including through any application or content that may link to or be accessible from or through the websites.

 

By accessing or using the Websites, you hereby agree and consent to the terms of this Privacy Policy. Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, please refrain from using our Website. This policy may change from time to time. Updates to this policy will made apparent to you by the “Last Updated” date listed at the top of this policy. It is your responsibility to monitor for changes to this policy. Your continued use of these Websites after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

What information do we collect?

We may collect the information listed below for the purposes described in the “How Do We Use and Share Your Information?” section of this Policy.

Category Description
Name, Contact Information, and Identifiers Identifiers such as a real name, alias, unique personal identifier, online identifier, Internet Protocol address, email address, or other similar identifiers.
Other information you submit to us Other information you submit to us Information that you submit to us in communications via email or online form.
Usage Data Information about how you interact with the Websites, such what functions you use in the Websites. We also collect information about the devices used to access the Websites, such as the device type, browser and operation system, and IP address.
Cookies and Similar Technologies Please see the “How We Use and How You Can Restrict Local Storage, Cookies and Other Internet Technologies” section of this Policy for more information.

How do we use and share your information?

How do we use the information described in this Policy? To the extent permitted by applicable law, we may use the information described in the “What Information Do We Collect?” section above for the following purposes:

 

  • Inform you about our products and services;
  • Communicate with you and respond to your requests or inquiries;
  • Provide you with services if you are or become a customer of the Company;
  • Consider you for current or future job opportunities if you reply on our Contact Us page;
  • Provide customer support or troubleshooting in connection with your use of our services;
  • Conduct market research and tracking of sales data;
  • Solicit your opinions or feedback on our business activities;
  • Support our educational, networking, marketing, social, recruiting, and other business purposes;
  • Improve our marketing and promotional efforts;
  • Create and improve our products or services;
  • Carry out our obligations and enforce our rights arising from any contracts entered into between you and GES Ltd, including for billing and collection;
  • Fulfil any other purpose for which you provide your consent;
  • Manage our Websites and Services and assess feedback, including to analyze our web performance and improve our Website;
  • Protect us and our customers against error, fraud, theft, and damage to our goods and property; and
  • Comply with applicable law or regulatory requirements.

 

How do we disclose or share the information described in this Policy? To the extent permitted by applicable law, we may share the information described in the “What Information Do We Collect?” section above for purposes listed below.

Category Description
Affiliates We may share your information with our subsidiaries and affiliates and with their respective officers, directors, employees, and agents.
Acquisitions and Similar Transactions We may disclose your information in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Company assets. If our business is acquired by or merged with another company, your information may be transferred to the new owners.
Disclosures with Your Consent We may ask if you would like us to share your information with other unaffiliated third parties who are not described elsewhere in this Policy. We will only disclose your information in this context with your consent.
Legal Obligations and Rights (Subpoenas, Court Orders, and Warrants) We may disclose information in response to subpoenas, warrants, court orders or other legal process, or to comply with relevant laws. We may also share information in order to establish or exercise our legal rights or claims; to defend against a legal claim; and to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property, or a violation of our contracts.
Professional Advisors We may share your information with our and our affiliates’ insurers, auditors, and professional advisors, including attorneys and accountants, that need access to your information to provide operational or other support services on our behalf.
Deidentified or Aggregated Data We may disclose aggregated information or de-identified information that does not identify any specific individual, such as groupings of demographic data or customer preferences.
Service Providers We may share information with our service providers that need access to information to provide operational or other support services on our behalf (e.g., for managing or hosting services and/or underpinning technology for the Services we are providing). Among other things, service providers help us to administer the Website; support our operations; provide technical support; send communications to you; provide payment processing; and assist with other legitimate purposes permitted by law.

How we use and how you can restrict cookies and other internet technologies

Our Website uses common browser local storage technologies, including cookies, to manage your identity, store your preferences, and track how you interact with us.


Cookies and Similar Technologies

 

 First and Third-Party Cookies


A “cookie” is a small file created by a web server that can be stored on your device (if you allow) for use either during a particular browsing session (a “session” cookie) or a future browsing session (a “persistent” or “permanent” cookie). “Session” cookies are temporarily stored on your hard drive and only last until they expire at the end of your browsing session. “Persistent” or “permanent” cookies may remain stored on your hard drive until they expire or are deleted by you. Local shared objects (or “flash cookies) may be used to collect and store information about your preferences and navigation to, from, and on the site. First-party cookies are set by the website you’re visiting, and they can only be read by that site. Third-party cookies are set by a party other than that website.


 Other Similar Technologies


In addition to cookies, there are other automatic data collection technologies, such as Internet tags, web beacons (clear gifs, pixel tags, and single-pixel gifs), and navigational data collection (log files, server logs, etc.) that can be used to collect data as users navigate through and interact with a website. For example, web beacons are tiny graphics with unique identifiers that are used to understand browsing activity. In addition, UTM codes are strings that can appear in a URL when you move from one web page or website to another. The string can represent information about browsing, such as which advertisement, page, or publisher sent the user to the receiving website.

 

 What Cookies Are in Use and Why Do We Use Them?


First-party cookies are exempt from privacy consent requirements and are typically used to remember your user data and preferences to deliver services, including session ID cookies, authentication cookies, UI customization cookies and statistical cookies not used for personal data tracking. Third-party cookies are those set and controlled by outside parties other than the Company.

We use first-party cookies and other similar technologies for purposes such as to improve Site functionality, to measure and track how users interact with the Site, and to perform similar analytics. We may also use first-party and similar technologies on the Site in order to otherwise tailor our communications with you. We do not use third-party cookies on our Website.


We May Use Several Types of Cookies on Our Website:


Necessary cookies are essential for the Websites to function and cannot be switched off in our systems. These cookies do not store your name, e-mail or phone number, IP address or device identifier, or other directly identifying personal information and are deleted when you close your browser.


Functional cookies are set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, or filling in forms. You can set your browser to alert you about these cookies, but some parts of the Websites will not work if you block these cookies.



CookieBot is a tool we use to help you understand the types of cookies we use on our website. CookieBot regularly scans our website to provide this information to you. Cookiebot has created the following declaration to support you in making informed choices about cookie consents on our website:


 How Can You Control Cookies?

You can control how local storage works in the settings or tools offered on your internet browser, including denying some capabilities. Most browsers have an option for limiting or restricting cookies, which will prevent your browser from accepting new cookies, and may allow you to decide on acceptance of each new cookie in a variety of ways. You can also delete all cookies that are already on your device. If you do this, however, it may impact the overall functionality of some features of the Websites and Services. You can also visit the link below for an overview of how to block or delete cookies on the most common browsers: http://www.allaboutcookies.org.


Most browsers automatically accept cookies, but this is typically something you can adjust:


Google Analytics


We may employ Google Analytics internet tools to collect information about usage of our Sites. Google Analytics collects the IP address assigned to you or device identifier on the date you visit our Site. The Google Analytics tools do not identify or collect your name, e-mail address, or other directly identifying information.


Google Analytics tools also collect specific visitor cookie data, such as the source, medium, and keywords used to visit the Sites, and other information, such as how often users visit the Sites, what pages they visit when they do so, and what other websites they used prior to coming to the Sites. Although Google Analytics creates a cookie to identify you as a unique user the next time you visit the Sites, the cookie cannot be used by anyone but Google.

For specific information about how Google Analytics may be used to track your Personal Information and how to restrict it, please see Google’s privacy practices website. To opt out of being tracked by Google Analytics across all websites, visit https://tools.google.com/dlpage/gaoptout.

How long do we store and use your information?

We retain and use your information for as long as is necessary to fulfill the purposes for which it was collected, to comply with our business requirements and legal obligations, to resolve disputes, to protect our assets, to operate our business, and to enforce our agreements.



To the extent permitted by law, we may retain and use anonymous, de-identified, or aggregated information for performance reporting, benchmarking, and analytic purposes and for operational improvement.

How do we protect your information?

We have put security measures in place to protect the personal information that you share with us from being accidentally lost, used, altered, disclosed, or accessed in an unauthorized manner. From time to time, we review our security procedures to consider appropriate new technologies and methods.


While our security measures seek to protect the personal information in our possession, no security system is perfect, and no data transmission is 100% secure. As a result, while we strive to protect your information, we cannot guarantee or warrant the security of any information transmitted to or from the Website. Your use of the Website is at your own risk. We cannot guarantee that your data will remain secure in all circumstances.


If a data breach compromises your personal information, we will notify you and any applicable regulator when we are required to do so by applicable law.



Your information collected through the service may be stored in the UK or any other locality in which we or our service providers maintain facilities. We may transfer information that we collect about you, including personally identifiable information, across borders and from your country or jurisdiction to other countries or jurisdictions around the world that may not have the same data protection laws as your jurisdiction. We rely on legally provided mechanisms to lawfully transfer data across borders.

Your rights and choices regarding personal information

Please use the “Contact Us” details provided at the end of this Policy to exercise your rights and choices under this Policy. We honor such requests when we are required to do so under applicable law.


Depending on the jurisdiction, you may have the following rights with respect to your personal information:

  • To access and request certain information about the processing of your personal information;
  • To obtain a portable copy of your personal information;
  • To correct personal information;
  • To delete personal information;
  • To restrict processing of certain personal information;
  • To object to the processing of personal information;
  • To withdraw consent, where this was the lawful reason for processing; and
  • To lodge a complaint with the relevant supervisory authority.

 

Please bear in mind that if you exercise such rights, our ability to provide our products and services to you may be impacted.


For inquiries about your personal information, please contact us at info@goonhilly.org. While we will make reasonable efforts to accommodate your request, we also reserve the right to impose certain restrictions and requirements on such requests, if allowed or required by applicable laws. In the event that we cannot take action with respect to a request relating to your personal information, in certain jurisdictions, you may have the right to appeal that decision by contacting us.


Please note that it may take some time to process your request, consistent with applicable law.


If you choose to exercise these rights, we ask you to provide sufficient information, including the products and services you have used in the past, your state and country of residence, and contact information, in order for us to verify your identity and process your request. Depending on the types of requests, additional information may be requested.


You may use an authorized agent to submit a request on your behalf related to your personal information. If you choose to use an authorized agent, you should supply your agent with written permission to act on your behalf in relation to your request, and your agent must provide us with proof of such authorization before we process your request.


Email Opt-Out. We may send you emails about our services and other updates. If you no longer wish to receive communications from us via email, you may opt-out by clicking the “unsubscribe” link at the bottom of our emails, if applicable, or by submitting a request via the “Contact Us” details at the end of this Policy and providing your name and email address so that we may identify you in the opt-out process. Once we receive your instruction, we will promptly take corrective action. Please note that registered users cannot opt out of receiving transactional e-mails related to their account.


Complaints. If you believe your rights relating to your personal information have been violated, please contact us via the “Contact Us” details provided at the end of this Policy.

Third-party websites and services

This Policy only applies to the Website, and it does not apply to any third-party websites or applications. Any information provided by you or automatically collected from you by a third party will be governed by that party’s privacy policy and terms of use.


The Website may contain links to, and media or other content from, third parties. These links are to external resources and third parties that have their own privacy policies. We cannot and do not (1) guarantee the adequacy of the privacy or security practices employed by or the content and media provided by any third parties or their websites, (2) control third parties’ independent collection or use or your information, or (3) endorse any third-party information, products, services or websites that may be reached through embedded links on the Website.

Minors' personal data

THIS WEBSITE IS NOT INTENDED FOR CHILDREN UNDER 18 YEARS OF AGE. NO ONE UNDER THE AGE OF MAJORITY IN THEIR JURISDICTION MAY ACCESS, USE THE SERVICES OF, OR OTHERWISE PROVIDE ANY INFORMATION THROUGH THIS WEBSITE.

 

Our Website and services are not directed to minors, nor do we knowingly collect information from or about minors. No one under the age of majority in their jurisdiction may access, browse, or use the Website or provide any information to or on the Website. If you believe we might have any information from or about a minor, please contact us via the “Contact Us” details provided at the end of this Policy.


BY ACCESSING THIS WEBSITE, YOU REPRESENT YOU ARE AT LEAST 18 YEARS OF AGE OR THE AGE OF MAJORITY IN YOUR JURISDICTION.

Updates and changes to this policy

We may add to, change, update, or modify this Policy to reflect any changes to how we treat your information or in response to changes in law. Should this Policy change, we will post all changes to this Policy on this page. Any such changes, updates, or modifications will be effective immediately upon posting. The date on which this Policy was last modified is identified at the beginning of this Policy.


Continued use of the Website after the “Last Updated” date will constitute your acceptance of and agreement to such changes and to our collection and sharing of your information according to the terms of the then-current Policy. If you do not agree with this Policy and our practices, you should not use the Website.

Contact us

For more information, or if you have any questions or concerns regarding this Policy, you may contact us using the information below, and we will do our best to assist you.


By Postal Mail:     

COMSAT

Goonhilly Earth Station Ltd. 
Goonhilly Downs
Helston
Cornwall
UK
TR12 6LQ

 

By Email: info@goonhilly.org         

By Phone: +44 1326 334 263

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