1. Policy Statement
PLEASE NOTE THAT BY USING THE EDGECONNEX SERVICES OR VISITING OUR WEBSITE, YOU SIGNIFY YOUR AGREEMENT WITH THIS POLICY. IF YOU DO NOT AGREE TO THE TERMS OF THIS POLICY, PLEASE DO NOT USE THE SERVICE AND/OR REFRAIN FROM VISITING THE WEBSITE.
2 Collection of personal Information
2.1 CUSTOMERS’ PERSONAL INFORMATION
We request our customers provide us with Personal Information and other information to understand your needs and provide you with better services.
For purposes of this Policy, “Personal Information” shall mean any information relating to an identified or identifiable natural person and refers to any information that identifies, directly or indirectly, or that can be used to identify, contact, or locate the person to whom such information pertains. Examples of Personal Information include name, address, email address, telephone number, social security number, and computer IP address, amongst others.
EdgeConneX only collects Personal Information when you voluntarily provide it. This may occur when you voluntarily fill out a form, submit a ticket through the EdgeOS portal, or otherwise send information from your cell phone to EdgeConneX.
In our provision of Services, we may collect and retain the following information from our customers:
- Your first and last name, job title and employer name;
- Contact information, including phone number, postal and email addresses;
- Government issued ID, type and number;
- Biometric identifier (vascular print, hand shape, iris scan, etc.);
- Demographic information such as preferences and interests;
- Other information relevant to customer’s use of, and support for, our Services.
To the extent EdgeConneX collects Sensitive Information, such as, information related to race, ethnic origin, sexual orientation, political opinions or affiliations, religious beliefs, national identification, health and biometrics, we will do so only with your express consent and where you provide such information voluntarily.
2.2 HUMAN RESOURCES DATA
EdgeConneX also collects Personal Information from its employees in the context of an employment relationship (“HR Data”) for the purposes of administering its human resources programs and functions, and communicating with its employees. With respect to the collection of such HR Data, EdgeConneX respects the national laws of the European Union (EU) country where the information was initially collected or processed prior to transfer and all such transfers of HR Data related to EU nationals shall abide by the principles of the Privacy Shield set forth hereunder.
3 use of personal Information
EdgeConneX may use or disclose your Personal Information for the following purposes:
- Support services requests and record keeping;
- Authorizing access into our data centers and for data center security and other related colocation services;
- Customer contact database for internal use only;
- Improvements in our Services;
- Promotional emails about new products, special offers or other information which we think you may find interesting using the email address which you have provided. You have the right to opt out of these messages;
- Contact you for market research purposes. You have the right to opt out of this use of your information.
Your Personal Information will never be sold or disclosed to third parties for any other use or purpose except as set forth above unless you have specifically authorized such use.
4 commitment to EU-US privacy shield
EdgeConneX and its affiliated and subsidiary entities comply with the EU-US Privacy Shield Framework (“Privacy Shield”) as set forth by the U.S. Department of Commerce regarding the collection, use and retention of Personal Information transferred from the European Economic Area (EAA) to the United States. EdgeConneX has certified to the Department of Commerce that it adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access and Recourse, Enforcement and Liability. To learn more about the Privacy Shield Program, and to view our certification, please visit https://www.privacyshield.gov/.
With respect to Personal Information received or transferred pursuant to the Privacy Shield, EdgeConneX is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission.
4.1 Onward Transfers
EdgeConneX complies with the Privacy Shield Principles for all onward transfers of Personal Information from the EU, including the onward transfer liability provisions. EdgeConneX ensures that all such third parties receive information only as described in Section 5.1 of this Policy and shall remain liable for any loss, claim or damage (“Loss”) arising from such Personal Information transferred to an EdgeConneX third party acting as an agent on EdgeConneX’s behalf, except to the extent EdgeConneX can show it was not responsible for the events giving rise to the Loss.
Under the Privacy Shield, you have an opportunity to opt out of EdgeConneX’s collection of Personal Information where (i) EdgeConneX discloses your information to a third party, or (ii) where information will be used in a manner materially different from that which it was originally collected. EdgeConneX will not provide an opt-out option when disclosure is made to a third party that is acting as an agent to perform task(s) on behalf of EdgeConneX. EdgeConneX shall always enter into a contract with such agent to protect the confidentiality and security of your Personal Information, as more thoroughly described below.
If you wish to opt-out of EdgeConneX’s collection of your Personal Information, please reach out to the Privacy Officer listed in Section 12 below. Should you request access to, opt-out of, or revoke your consent (as more specifically described below) to our collection of Personal Information, EdgeConneX may request that you provide certain information in order to confirm your identity with respect to the request. Please allow EdgeConneX a reasonable amount of time to comply with your request and for such request to take effect.
(A) NON-HR DATA RECOURSE MECHANISM: EdgeConneX has committed to refer any complaints regarding your Personal Information that have not been resolved after contacting the EdgeConneX Privacy Officer to a dispute resolution provider. EdgeConneX has appointed the International Centre for Dispute Resolution (“ICDR”), a division of the American Arbitration Association (“AAA”), located in the United States, as its independent dispute resolution provider. If you do not receive timely acknowledgement for your complaint from EdgeConneX, or if EdgeConneX has not addressed your complaint to your satisfaction, please contact or visit AAA at www.icdr.org for more information or to file a complaint. The services of AAA/ICDR are provided at no cost to you.
In limited circumstances, it may be possible for you to invoke binding arbitration for complaints regarding Privacy Shield compliance not resolved by any of the other Privacy Shield mechanisms.
(B) HR DATA RECOURSE MECHANISM: EdgeConneX has further committed to cooperate with EU Data Protection Authorities (DPAs) established pursuant to the Privacy Shield to address employee complaints and provide employees with a recourse mechanism free of charge with respect to any HR Data complaints that cannot be resolved internally.
5 DISCLOSURE OF PERSONAL INFORMATION
5.1 third parties
In order to provide the Services, EdgeConneX may share your Personal Information and/or aggregate information with our affiliates, technical consultants, third party auditors, and other third party service providers. All such third parties may access, process, or store personal information in the course of providing their services. All such third party service providers have entered into agreements with EdgeConneX agreeing to respect and maintain the safety and security of all Personal Information they may receive and are bound by the same or equally stringent terms as set forth herein. EdgeConneX discloses only that information it believes in its reasonable discretion is necessary for the third party to carry out its obligations to EdgeConneX.
5.2 Compelled disclosures
Notwithstanding any protections to Personal Information herein, EdgeConneX may disclose Personal Information if disclosure is required by (i) a valid and lawful order of a court or other governmental or public body having jurisdiction, or (ii) to meet national security or law enforcement requirements. EdgeConneX will endeavor to use reasonable efforts to disclose only that which is required to comply with the request.
6 INFORMATION SECURITY
We are committed to ensuring that your Personal Information is secure. In order to prevent misuse, unauthorized access or disclosure, alteration and/or destruction, we have put in place suitable physical, logical and managerial procedures to safeguard and secure the information we collect. Our information security program is designed and certified to an internationally recognized standard, ISO 27001:2013. All EdgeConneX business systems and processes have also been certified as SOC2 Type 2, PCI, DSS, and HIPAA compliant. Systems and processes have been scrutinized for limiting access to only required personnel, and the proper protections and restrictions to physical accessibility have been implemented to secure your Personal Information from accidental loss and from unauthorized access, use, alteration or disclosure.
6.1 Notice OF SECURITY BREACH
In the event of any unauthorized access or disclosure of your information, EdgeConneX will endeavor to promptly notify you of any such unauthorized access or disclosure and to take reasonable steps to ameliorate such unauthorized access or disclosure.
7 information storage
The length of time EdgeConneX may store your information may vary depending on our use of the Personal Information. EdgeConneX represents that unless otherwise required by law, we will not maintain your information for longer than is reasonably necessary for the purposes for which information was collected.
8 USE OF OUR WEBSITE
A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyze web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences. We use traffic log cookies to identify which pages are being used. This helps us analyze data about webpage traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.
Cookies help us provide you with a better website experience, by enabling EdgeConneX to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us. You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can modify your browser setting to decline cookies if you prefer. Declining cookies may prevent you from taking full advantage of the website.
8.2 Links to other websites
Our website may contain links to other websites of interest. However, once you have used these links to leave our site, we do not have any control over external websites. External sites are not governed by this Policy. Therefore, we will not be responsible for the protection and privacy of any information which you provide when visiting such other sites. You should exercise caution and read the privacy statement applicable to the website in question.
9 CONTROLLING YOUR PERSONAL INFORMATION
9.1 RIGHT OF ACCESS/UPDATING PERSONAL INFORMATION
At any time during the provision of the Services and to the extent EdgeConneX stores Personal Information, you may notify EdgeConneX in writing of your request to:
- (i) obtain confirmation as to whether or not EdgeConneX stores any Personal Information related to you;
- (ii) obtain access to such Personal Information so that you may verify its accuracy; or
- (iii) access your Personal Information so that you may correct, amend or delete the information provided to EdgeConneX or request EdgeConneX make such change. You can correct, amend, or delete your Personal Information in the “Customize your EdgeConneX Account” page on our website.
Upon reasonable request, EdgeConneX shall provide you with access to your Personal Information, provided, however, that pursuant to the Privacy Shield, EdgeConneX may, in limited circumstances, deny access to your Personal Information.
Should you request deletion of any Personal Information, keep in mind that even if the account is deleted from EdgeConneX records, there may be residual information that will remain within EdgeConneX databases, access logs, proprietary software programs and other records, which may or may not contain Personal Information. EdgeConneX will maintain the confidentiality of such remaining information to the extent it cannot permanently delete it from its systems. EdgeConneX is not responsible for updating or removing any information contained in third party lists or databases.
If you have previously agreed to us using your Personal Information for direct marketing purposes, you may change your mind at any time by writing to us and we shall promptly remove you from our direct marketing programs.
We will not sell, distribute or lease your Personal Information to third parties unless we have your permission or are required by law to do so. We may use your Personal Information to send you EdgeConneX promotional information which we think you may find interesting if you authorize us to send you such promotional material.
Under no circumstance will EdgeConneX be liable for any information it merely transmits and does not collect from you during your use of the Services. Furthermore, except as required under the Privacy Shield, EdgeConneX shall not be responsible for the accuracy of any information you may submit to us during your use of the Services.
11 CHANGES IN THE POLICY
EdgeConneX reserves the right to change this Policy from time to time at its sole discretion. If as the result of such changes, you wish to alter the ways in which EdgeConneX is allowed to use your Personal Information, you can do so by following the procedure described in Section 9.1. You will be deemed to have been made aware of, and will be subject to, the changes to this Policy by your continued use of the relevant EdgeConneX Services.
12 privacy-related inquiries
EdgeConneX takes its customers’ privacy concerns seriously. If you believe that EdgeConneX has not complied with this Policy with respect to your Personal Information or other information submitted to us, you may write directly to the EdgeConneX Privacy Officer indicated below:
You may also relay any other inquiries or concerns you may have pertaining to our above stated policies to our Customer Service Department by e-mailing us at support@EdgeConneX.com.
Effective Date: May, 2017