Privacy Notice (EU)

Privacy Notice (EU)

United Launch Alliance (ULA) takes data protection and privacy responsibilities seriously. This privacy notice explains how we collect, use and share your personal data as a result of your use of our web sites, including:

• What personal data we collect and when and why we use it
• How we share personal data at ULA, with service providers, regulators and other third parties
• How we protect and store personal data
• Legal rights available to help manage your privacy
• How you can contact us for more support

We may amend this notice from time to time to keep it up to date with legal requirements and the way we operate our business. Please regularly check these pages for the latest version of this notice. 

1.0 WHAT PERSONAL DATA WE COLLECT AND WHEN AND WHY WE USE IT

1.1 When we collect information
We collect information about you if you register with or use one of our website and we do so via the following methods:

• By recording details you provide to us - e.g. in responding to a job posting, your communications with us through emails or calls, and/or
• By observing your use of our products and services and our website.  Our website uses a tracking technology known as “cookies”.

1.2 Personal data we collect and use if you use our websites

1.3 The legal basis for using your personal data

We will only collect, use and share your personal data where we are satisfied that we have an appropriate legal basis to do this. This may be because:
• You have provided your consent to us using the personal data for example by signing up to receive communications from us;
• Our use of your personal data is in our legitimate interest as a commercial organization (for example our legitimate interests in communicating with you - in these cases we will look after your information at all times in a way that is proportionate and respects your privacy rights and you have a right to object to processing as explained in the “Legal Rights Available to Help Manage Your Privacy” section below;
• Our use of your personal data is necessary to perform a contract or take steps to enter into a contract with you; and/or
• Our use of your personal data is necessary to comply with a relevant legal or regulatory obligation that we have for example fulfilment of a court order.

2.0 SHARING YOUR PERSONAL DATA

We share your information in the manner and for the purposes described below:

• Within ULA, where such disclosure is necessary to provide you with our services or to manage our business
• With third parties who help manage our business and deliver services. These third parties have agreed to confidentiality restrictions and use any personal data we share with them or which they collect on our behalf solely for the purpose of providing the contracted service to us. These include IT service providers who help manage our IT and back office systems;
• With regulators, to comply with all applicable laws, regulations and rules, and requests of law enforcement, regulatory and other governmental agencies; and
• We may share in aggregate, statistical form, non-personal data regarding the visitors to our website, traffic patterns, and website usage with our partners, affiliates or advertisers.

3.0. HOW WE PROTECT AND STORE YOUR INFORMATION

3.1 Security
We have implemented and maintain appropriate technical and organizational security measures, policies and procedures designed to reduce the risk of unauthorized disclosure or access to such information appropriate to the nature of the information concerned. As the security of information depends in part on the security of the computer you use to communicate with us and the security you use to protect User IDs and passwords please take appropriate measures to protect this information.

3.2 Storing your personal data
We will store your personal data for as long as is reasonably necessary for the purposes for which it was collected, as explained in this notice. In some circumstances we may store your personal data for longer periods of time, for instance where we are required to do so in accordance with legal, regulatory, tax, or accounting requirements.

In specific circumstances, we may store your personal data for longer periods of time so that we have an accurate record of your dealings with us in the event of any complaints or challenges, or if we reasonably believe there is a prospect of litigation relating to your personal data or dealings.

4.0 LEGAL RIGHTS AVAILABLE TO HELP MANAGE YOUR PRIVACY
Subject to certain exemptions, and in some cases dependent upon the processing activity we are undertaking, you have certain rights in relation to your personal data. This may include the right to:

4.1 Access personal data –
You have a right to request that we provide you with a copy of your personal data that we hold and you have the right to be informed of; (a) the source of your personal data; (b) the purposes, legal basis and methods of processing; (c) the data controller’s identity; and (d) the entities or categories of entities to whom your personal data may be transferred.

4.2 Rectify / erase personal data –
You have a right to request that we rectify inaccurate personal data. We may seek to verify the accuracy of the personal data before rectifying it.  You can also request that we erase your personal data in limited circumstances where: (a) it is no longer needed for the purposes for which it was collected; (b) you have withdrawn your consent (where the data processing was based on consent), and where there is no other legal ground for the processing; (c) following a successful right to object (see right to object); (d) it has been processed unlawfully; or (e) to comply with a legal obligation to which ULA is subject.

We are not required to comply with your request to erase personal data if the processing of your personal data is necessary for compliance with a legal obligation; or for the establishment, exercise or defense of legal claims.

4.3 Restrict the processing of your personal data –
You can ask us to restrict your personal data, but only where: (a) its accuracy is contested, to allow us to verify its accuracy; (b) the processing is unlawful, but you do not want it erased; (c) it is no longer needed for the purposes for which it was collected, but we still need it to establish, exercise or defend legal claims; or (d) you have exercised the right to object, and verification of overriding grounds is pending.

We can continue to use your personal data following a request for restriction, where: we have your consent; to establish, exercise or defend legal claims; or to protect the rights of another natural or legal person.

4.4 Transfer your personal data –
You can ask us to provide your personal data to you in a structured, commonly used, machine-readable format, or you can ask to have it transferred directly to another data controller, but in each case only where: (a) the processing is based on your consent or on the performance of a contract with you; and (b) the processing is carried out by automated means.

4.5 Object to the processing of personal data –
You can object to any processing of your personal data which has our legitimate interests as its legal basis, if you believe your fundamental rights and freedoms outweigh our legitimate interests.  If you raise an objection, we have an opportunity to demonstrate that we have compelling legitimate interests that override your rights.

4.6 Object to how we use your personal data for direct marketing purposes –
You can request that we change the manner in which we contact you for marketing purposes.  You can request that we do not transfer your personal data to unaffiliated third parties for the purposes of direct marketing or any other purposes.

4.7 Lodge a complaint with your local supervisory authority –
You have a right to lodge a complaint with your local supervisory authority if you have concerns about how we are processing your personal data.  We ask that you please attempt to resolve any issues with us first, although you have a right to contact your supervisory authority at any time.

5.0 Contact ULA
Please contact us at privacy@ulalaunch.com to exercise your rights in your personal data.  We may ask you for additional information to confirm your identity and for security purposes, before disclosing the personal data requested to you. In some instances, we may not be able to fully address your request; for example, if your request for access to Personal Data affects ULA’s duty of confidentiality owed to others or if your request is to erase Personal Data that is still required to fulfill a contractual obligation. Furthermore, we reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive.

Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly or inform you if we require further information in order to fulfill your request.