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General Data Protection Regulation (GDPR) – Compliant Data Protection Policy

Introduction

Phoenix NAP LLC (“PNAP”) needs to gather and use certain information about individuals. This information can include customers, suppliers, business contact, employees and other people the organization has a relationship with or may need to contact. This policy describes how this personal data must be collected, handled and stored to meet the company’s data protection standards – and to comply with the law.

Why this policy exists

This data protection policy ensures phoenixNAP:

  • Complies with data protection law and follows good practice
  • Protects the rights of staff, customers, and partners
  • Is transparent about how it stores and processes individuals personal data
  • Protects itself from the risk of a data breach

The General Data Protection Regulation

The EU General Data Protection Regulation (GDPR) replaces the Data Protection Directive 95/46/EC and was designed to harmonize data privacy laws across Europe, to protect all EU citizens’ data privacy and to reshape the way organizations across the world approach data privacy. The GDPR aims primarily to give control back to citizens and residents over their personal data and to simplify the regulatory environment for international business by unifying the regulation within the EU.

What is “Personal Data”?

“Personal data” is defined in both the Directive and the GDPR as any information relating to a person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that person. So in many cases online identifiers including IP address, cookies and so forth will now be regarded as personal data if they can be (or are capable of being) without undue effort linked back to the data subject.

1. Information collection and tracking

1.1. When you visit our website.

You can visit our website (www.devtest.phoenixnap.com) without giving away your personal information. phoenixNAP uses Google Analytics and Cookies in order to improve our service, user experience and analyze how our website is used. Aside from the approximate location (IP address), the information collected by Google Analytics is mostly anonymous traffic data including browser information, device information, language. We do not collect additional information, such as your age, gender, interests, bank details or clickstream.

The collected information is used to provide an overview of how people are accessing and using the phoenixNAP website. It is not used for any additional purpose, such as to profile those who access our website.

2. When you contact us

While you can use our website without giving out your personal information, once you contact us via the phoenixNAP website, phoenixNAP collects information about you.

The information you fill in (personal information such as your name, email address, organization) will be processed and stored so that it is possible for us to contact and respond to your request, and/or allow you access to our services.

2.1. Recruitment

If you apply for a job with phoenixNAP, we will collect, process and store the information you have sent us for recruitment-related purposes, such as contacting you. Additionally, phoenixNAP may keep your data for a period of time for the purpose of considering you for a different opportunity.

3. Social media plug-ins

​Our website features two plug-ins for easy sharing and following our social media pages: Facebook, operated by Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA; and LinkedIn, operated by LinkedIn, 2029 Sterling Court Mountain View, CA 94043 United States.

Being on our website does not automatically result in sharing data on these social media networks. These plugins remain inactive (idle) until clicked upon. Once clicked upon, you will be taken to the said social media networks with their own specific privacy policies you are recommended to consult.

4. Information security

When PNAP collects information about you, we also make sure that your information is protected from unauthorized access, loss, manipulation, falsification, destruction or unauthorized disclosure. This is done through appropriate technical measures.

5. Data Sharing

We might share your personal information with the following third parties for the purposes of providing you with the best service possible:

  • other companies within the Group
  • occasionally we may receive a request to disclose information about you with law enforcement, regulators and supervisory authorities where we are legally required to do so.

All our entities in the group are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

5.1 Where we might send your data (geographically)

We process data within the EEA and countries deemed by the European Union as having adequate safeguards for protecting personal data. These countries are recognized by the EU as having suitable safeguards for the rights and freedoms of individuals and recourse processes by which data subjects can exercise their rights.

We will only consider transferring your data outside of the EU if the following conditions are met.

  • Made with your explicit informed consent
  • Necessary for the performance of an agreement between you and us
  • Necessary for important reasons of public interest
  • Necessary for the establishment, exercise or defense of legal claims
  • Necessary to protect your vital interests or those of other persons, where you are physically or legally incapable of giving consent
  • Request access to information that PNAP has about you
  • Correct any information that PNAP has about you
  • Delete information that PNAP has about you

6. Access to information

You have the right to request access to the information we have on you. You can do this by contacting us at dpo@devtest.phoenixnap.com. We will make sure to provide you with a copy of the data we process about you. In order to comply with your request, we may ask you to verify your identity. We will fulfil your request by sending your copy electronically, unless the request expressly specifies a different method. For any subsequent access request, we may charge you with an administrative fee.

7. Information Correction & Deletion

If you believe that the information we have about you is incorrect, you are welcome to contact us so we can update it and keep your data accurate. Any data that is no longer needed for the purposes specified in Information Collection and Use or for any Regulatory Reporting purposes will be deleted.

If you have any queries about the personal data that phoenixNAP stores, you can simply contact us at dpo@devtest.phoenixnap.com.

8. When this Privacy Policy Applies

This Privacy Policy is applicable to the services offered by PNAP directly via our website. Our website may contain links to other websites. Once redirected to another website, this Policy is no longer applicable.

This version of the Privacy Policy is effective from June 2020.

9. Changes

We reserve the right to change this Privacy Policy. We constantly review our Privacy Policy and strive towards making it better. PNAP will not reduce your rights stated in this Policy without asking for explicit prior consent to the changes. All changes to our Privacy Policy will be available on this website. You can access the previous versions of this Policy here.

10. To sum up

In accordance with applicable law, we only collect a limited amount of information about you that is necessary for improving our service. We do not use profiling, we do not sell or in any way spread your data to third parties, unless we permit them to process your personal data for specified purposes and in accordance with our instructions, and we do not use your data for purposes other than what we specified. We also make sure that your data is stored securely. We delete all information deemed no longer necessary. We constantly review our Privacy Policy in order to make it better and protect you more.

11. You can contact us at any time to:

  • Request access to information that PNAP has about you
  • Correct any information that PNAP has about you
  • Delete information that PNAP has about you

If you have any additional questions about PNAP’s collection and storage of data, please contact us at:

phoenixNAP | 3402 East University Drive | Phoenix, Arizona USA | 85034 | DPO@devtest.phoenixnap.com

Glossary of terms

Cookies
Cookies are small files or other pieces of data which are downloaded or stored on your computer or other device that can be tied to information about your use of our website (including certain third party services and features offered as part of our website).

Device
A device is what you use to reach our website, such as a smartphone, tablet or computer.

IP address
Internet Protocol (IP) address is a number that is connected to your device. An IP address can be used to determine the location of your device typically within a 40km radius, thus not being an exact determination of your location. IP addresses are basically how the Internet functions.

Personal information
Personal information is information that can identify you. This can be your name, email, contact information or other type of information that can be traced back to you.

v.3 June 2020