As we are based in the USA, Cradlepoint, UK Ltd. is our representative within the EEA. Their contact details are:
- Office Manager, EMEA
- Cedar House, Apex Court,
- Camphill Road, West Byfleet,
- Surrey, KT14 6SQ, United Kingdom
- UK Phone Number +44 (0) 1932 548410
- Cradlepoint UK website: https://www.cradlepoint.com
- Cradlepoint email: firstname.lastname@example.org
Personal Data Collection & Use
If we collect sensitive EEA Personal Data, we will obtain your opt-in consent, including if we disclose your sensitive EEA Personal Data to third parties, or before we use your sensitive EEA Personal Data for a different purpose than we collected it for or than you later authorised.
How long your EEA Personal Data will be kept
We will hold your name, address and contact details for the period we are required to retain this information by applicable UK tax law. With that Cradlepoint established four (4) unique categories to maintain personal information to include:
Prospects & Leads (e.g. NCM trials):
- With your implied single opt-in consent (e.g. from a tradeshow), Cradlepoint will maintain your personal contact information for 6 months following our initial contact.
- With your explicit, double opt-in, consent Cradlepoint will consider you as a valid lead and potential customer and retain your personal information, for two (2) years.
Customers of a product or service:
- While in a legitimate business relationship, Cradlepoint’s has a valid and mutual business need to maintain your personal information continually during the business contract.
- Cradlepoint will maintain your personal information associated with the contract agreement until your company instructs us to change or replace your information.
- Cradlepoint will maintain your personal information for two (2) years following the end of our mutual and legitimate business interest.
- To accommodate relevant financial or tax laws and/or legal requirement for six (6) years.
- Cradlepoint will maintain your personal information from application and interview process for one (1) year.
- When hired, Cradlepoint will maintain your personal information during the initial job application, through the end of employment.
- Following the end of employment, Cradlepoint will retain (archive) personal information for two (2) years.
Partners & Third-party providers:
- Cradlepoint will maintain your personal information from initial contact to the point where we enter into negotiations and will retain your personal information for two (2) years following the end of negotiations.
- Cradlepoint will continually maintain personal information during the active contractional business relationship.
- If and when the contract ends, Cradlepoint will retain Data Subject information for two (2) years.
Data Transfers to Third Parties
We enter into written agreements with those third-party agents and service providers limiting their use of the data to the specified services provided on our behalf. We take reasonable and appropriate steps to ensure that third-party agents and service providers process EEA Personal Data in accordance with our obligations to you and to stop and remediate any unauthorised processing. Under certain circumstances, we may remain liable for the acts of our third-party agents or service providers who perform services on our behalf for their handling of EEA Personal Data that we transfer to them.
Disclosures for National Security or Law Enforcement. Under certain circumstances, we may be required to disclose your EEA Personal Data in response to valid requests by public authorities, including to meet national security or law enforcement requirements.
We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
Under the General Data Protection Regulation, you have many important rights free of charge. In summary, the rights include:
- Fair processing of information and transparency over how we use your use personal information
- Access to your personal information and to certain other supplementary information that this Privacy Notice is already designed to address
- Require us to correct any mistakes in your information which we hold
- Require the erasure of personal information concerning you in certain situations
- Receive the personal information concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations
- Object at any time to processing of personal information concerning you for direct marketing
- Object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you
- Object in certain other situations to our continued processing of your personal information
- Otherwise restrict our processing of your personal information in certain circumstances
- Claim compensation for damages caused by our breach of any data protection laws
For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) concerning individual rights under the General Data Protection Regulation.
If you would like to exercise any of those rights, please:
- File a complaint or make a request;
- Let us have enough information to identify you;
- Let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); and
- Let us know the information to which your request relates, including any account or reference numbers, if you have them.
- Unsubscribe from any Cradlepoint marketing communication or update your communication preferences.
You may have the right to access the EEA Personal Data that we hold about you and to request that we correct, amend, or delete it if it is inaccurate or processed without a legitimate ground for such processing. These access rights may not apply in some cases, including where providing access is unreasonably burdensome or expensive under the circumstances or where it would violate the rights of someone other than the individual requesting access. If you would like to request access to, correction, amendment, or deletion of your EEA Personal Data, you can submit a written request to the contact information provided below. We may request specific information from you to confirm your identity. In some circumstances we may charge a reasonable fee for access to your information.
Questions or Complaints
We hope that we can resolve any query or concern you raise about our use of your information.
The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred.
If you have any questions about this Policy or would like to request access to your EEA Personal Data, please contact us as follows:
- You may also contact our European affiliate, Cradlepoint / UK, at the contact details outlined above, with any questions or concerns.
Supervisory Authority - ICO
You may contact the Information Commissions Office (ICO), the supervisory authority, via helpline, live chat, email or telephone from:
- ICO Contact page
- Telephone: 0303 123 1113
- Information Commissioner's Office (ICO)
- Wycliffe House
- Water Lane
- Wilmslow, Cheshire, SK9 5AF
This Policy was originally published, 23 May 2018 and last updated on 31 October 2018.
We may change this Policy from time to time, when we do we will inform you, the Data Subject, via email and linking you to an announcement identifying the change.