This Privacy Statement is effective as of May 2018.
At IBM we recognize the importance of protecting your personal information and are committed to processing it responsibly and in compliance with applicable data protection laws in all countries in which IBM operates.
This Privacy Statement describes IBM’s general privacy practices that apply to personal information we collect, use and share about consumers and other individuals within our clients, business partners, supplier and other organizations with which IBM has or contemplates a business relationship.
This Privacy Statement is supplemented by the IBM Online Privacy Statement, which provides more information in the online context, including recruitment. We may provide additional or more specific information on the collection or use of personal information on websites or related to a specific product or service.
Why and how we collect and use your personal information
We may collect your personal information as an individual for various purposes, such as the following:
Where we reference that we use your personal information in relation to marketing, improvement or development of our products or services, for reasons of safety and security, or regulatory requirements other than in connection with your agreement or request, we do this on the basis of our or a third party’s legitimate interests, or with your consent. When we collect and use your personal information subject to the EU Privacy Legislation this may have consequences for Your Rights (see below).
Sharing of Personal Information
As a global organization offering a wide range of products and services, with business processes, management structures and technical systems that cross borders, IBM has implemented global policies, along with standards and procedures, for consistent protection of personal information. As a global company, we may share information about you with our subsidiaries world-wide and transfer it to countries in the world where we do business in accordance with this Privacy Statement.
Between IBM controlled subsidiaries we only grant access to personal information on a need-to-know basis, necessary for the purposes for which such access is granted. In some cases, IBM uses suppliers located in various countries to collect, use, analyze, and otherwise process personal information on its behalf.
Where appropriate, IBM may also share your personal information with selected partners to help us provide you, or the company you work for, products or services, or to fulfill your requests, or with your consent. When selecting our suppliers and partners, we take into account their data handling processes.
If IBM decides to sell, buy, merge or otherwise reorganize businesses in some countries, such a transaction may involve the disclosure of personal information to prospective or actual purchasers, or the receipt of such information from sellers. It is IBM’s practice to require appropriate protection for personal information in these types of transactions.
Please be aware that in certain circumstances, personal information may be subject to disclosure to government agencies pursuant to judicial proceeding, court order, or legal process. We may also share your personal information to protect the rights or property of IBM, our business partners, suppliers or clients, and others when we have reasonable grounds to believe that such rights or property have been or could be affected.
The international footprint of IBM involves a large number of transfers of personal information between different subsidiaries, as well as to third parties located in the countries where we do business. Some countries have implemented transfer restrictions for personal information, in connection with which IBM takes various measures, including:
Information Security and Accuracy
We intend to protect your personal information and to maintain its accuracy. IBM implements reasonable physical, administrative and technical safeguards to help us protect your personal information from unauthorized access, use and disclosure. For example, we encrypt certain sensitive personal information such as credit card information when we transmit such information over the Internet. We also require that our suppliers protect such information from unauthorized access, use and disclosure.
We will not retain personal information longer than necessary to fulfill the purposes for which it is processed, including the security of our processing, complying with legal and regulatory obligations (e.g. audit, accounting and statutory retention terms), handling disputes, and for the establishment, exercise or defense of legal claims in the countries where we do business.
Because the circumstances may vary depending on the context and the services, the information provided in IBM Online Privacy Statement or provided in a specific notice may provide more detailed information on applicable retention terms.
How to contact us
If you have a question related to this Privacy Statement, please contact us by using this form. Your message will be forwarded to the appropriate member of IBM’s Data Privacy Team, such as Data Protection Officers or members of their teams.
For the purposes of the EU General Data Protection Regulation (GDPR), the controller of your personal information is International Business Machines Corporation (IBM Corp.), 1 New Orchard Road, Armonk, New York, United States, unless indicated otherwise. Where IBM Corp. or a subsidiary it controls (not established in the European Economic Area (EEA)) is required to appoint a legal representative in the EEA, the representative for all such cases is IBM United Kingdom Limited, PO Box 41, North Harbour, Portsmouth, Hampshire, United Kingdom PO6 3AU. IBM Corp. is not the controller in situations such as:
You can request to access, update or correct your personal information. You also have the right to object to direct marketing. You can access the request process here.
You may have additional rights pursuant to your local law applicable to the processing. For example, if the processing of your personal information is subject to the EU General Data Protection Regulation (“GDPR”), and your personal information is processed based on legitimate interests, you have the right to object to the processing on grounds relating to your specific situation. Under GDPR you may also have the right to request to have your personal information deleted or restricted and ask for portability of your personal information.
Right to Lodge a Complaint
In the event you consider our processing of your personal information not to be compliant with the applicable data protection laws, you can lodge a complaint:
Changes to our Privacy Statements
From time to time we may update this Privacy Statement, as well as any other specific privacy statement. When making changes to this Privacy Statement, we will add a new date at the top of this Privacy Statement.