Leaseweb

PRIVACY STATEMENTVERSION:LSW_GL_V. 1 NOV2020,LEASEWEB GLOBALB.V.,1of 2,COMPLIANCE WITH INTERNATIONAL DATA PROTECTION LAWS,IN PARTICULAR THEGDPR,Leaseweb Globalcomplieswith international data protection laws, in particular theRegulation 2016/679/EU of the European Parliament and of the ,Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data,(“GDPR”).Leaseweb Globalhas implementedthefollowingrequirements under the GPDR, including but not limited to:,▪A record of our Personal Data processing activities. ,▪Adequate organizational and technical protection measures (more information can be found in this privacy statement).,▪Request forms and internal instructions for Privacy byDesign &amp. Default, Data Portability, Data Subject Rights like the Right to be Forgotten.,▪Updated Sales Terms andConditionsand Master Procurement Agreement.,▪Data Processor Agreementsfor your position as controller or processor.,▪A data breachprocedure.,▪An internalLeaseweb globalprivacy policy.,WHENLEASEWEB G LOBALMAY PROCESS PERSONAL DATAABOUT YOUIN OUR ROLE AS DATA CONTROLLER,Leaseweb Globalmay collect yourPersonalData when:,▪You browse or use Leaseweb Global’s website www.leaseweb.com.,▪You use Leaseweb Global’s Customer Portal at www.secure.leaseweb.com.,▪You enter and we apply our Compliance and Financial procedures,▪You participate in a Leaseweb Global survey.,▪Yousubscribe to a Leaseweb Global marketing newsletter.,▪You use the Leaseweb Global API.,Leaseweb Globalalso collects Personal Data about youfrom Leaseweb branded companies, including LeasewebNetherlands B.V., Leaseweb,Deutschland GmbH, LeasewebUK Ltd., LeasewebCDN B.V.,LeasewebNetwork B.V.,LeasewebUSA, Inc., LeasewebAsia Pacific PTE. Ltd.andLeaseweb,Australia Pty Ltd, Leaseweb Hong KongLtd(“LeasewebAffiliates”). Leaseweb is the brand name under which the various independent Leaseweb ,companies operate. LeasewebGlobal B.V. is a separate and distinct entity incorporateda particular geographic area. ,WHAT PERSONAL DATALEASEWEB G LOBALMAY PROCESS ABOUT YOU IN OUR ROLE AS DATA CONTROLLER,Leaseweb Globalmay collect the following information about your business:,▪Your businesss contact persons names,address, phone number, date of birth, email address and personal identification numbersor legally ,authorized representatives.,•Personal Data about how you interact with Leaseweb Global. This includes data such as, the website features you use, the servicesyou purchase,from the Leaseweb Affiliates, the web pages you visit, the time you spend on these pages, and the search terms you enter. This also includes ,data about your device, including IP address, device identifiers, regional and language settings, and data about the network, operating system, ,browser or other software you use to connect to the Leaseweb Global. ,•Your account information with the various Leaseweb Affiliates –such as Leasewebservices you ordered, domain name registration information, ,the IP addresses assigned to you, your customer IDs, service charges owed and received, the use of Leaseweb services or any other information ,related to your account.,•Information about your payment method, such as credit cardnumber, bank account number or other banking information.,•Documents and information that certify your identity.,LEGAL GROUNDS,To process your information as described above, we rely on the following permissive legal grounds:,•Performance of a contract: the use of your information may be necessary to perform the contract that you have with us. For example, if you ,use our services, we will use your information to carry out our obligation to complete and administer that serviceunder the contract that we ,have with you.,•Legitimate interests:the processing is necessary for the purposes of the legitimate interests pursued by us, namely for information security. ,We also want to provide you with the best suitable content of the website, emails and newsletters, to improve and promote our products and ,services and the content on our website, and for administrative, fraud detection and legal purposes.,•Consent: For certain marketing purposes, you are free to withdraw your consent at any time.,See also the section ‘ C ONSENT AND WITHDRAWAL OF CONSENT’.You are free to decide whether or not to share certain Personal Data (if any) with us for ,directmarketing purposes. However, if you decide not to provide certain Personal Data. or if you withdraw your consent thereto at alatter moment, ,this may affect how you experience our marketing for similar services.,WHY LEASEWEB G LOBALPROCESSES YOUR PERSONAL DATAIN OURROLE AS DATA CONTROLLER,Leaseweb Globalprocesses your Personal Data for the following purposes: ,•Conducting market research, conducting retention and customer satisfaction surveys, conducting marketing activities (including through email ,newsletters and social mediaand onsite/offsite and online/offline advertisement), conductingmarketing activities (including analyzing your ,Data and your use of LeasewebAffiliates’ services for making and/or maintaining, renewing or expanding a customer relationship with a ,LeasewebAffiliate.,▪The (i) provision of accessto the Customer Portal for customersof the various LeasewebAffiliates (ii)making available to customers, through ,these closed areas, information the use of services of LeasewebAffiliates, including information concerning Leaseweb Affiliates like invoices, ,orders name and contact details, and (iii) making available, through these closed areas information, tools to manage the services from the ,various LeasewebAffiliates and any (iv) financial procedures and (v) any Compliance procedures.,SHARING YOUR PERSONAL DATA WITH THIRD PARTIES IN OURROLE AS DATA CONTROLLER,Leaseweb Globalmay share PersonalData about you with:,Your privacy is important to Leaseweb Global B.V. (hereinafter “Leaseweb Global”). Leaseweb Globalis therefore pleased to provide this Privacy ,Statementto inform you of Leaseweb Global’spractices with respect to the collection, storage and use of your personal information (“Personal ,Data”)if any. This Privacy Statement applies to Leaseweb Global’s website www.leaseweb.com, Customer Portal at secure.leaseweb.com, ,LeasewebGlobal API and Leaseweb Globalnewsletters and Leaseweb Global BV departments.,PRIVACY STATEMENTVERSION:LSW_GL_V. 1 NOV2020,LEASEWEB GLOBALB.V.,2of 2,▪LeasewebAffiliates.The LeasewebAffiliatesoffer tools and services that may be used to order or to communicate with Leaseweb Global. ,Leaseweb Global may share your Data with LeasewebAffiliatesin connection with said tools and services.Please review thePrivacy Statements,of the various Affiliatesto learn about theirpractices with respect to the collection, storage and use of your Personal Data.,▪Lawenforcement agencies, regulatory organisations, courts or other public authorities to the extent required by law.,▪Credit and Compliance KYC reference agencies.,DATA TRANSFERS,Since Leaseweb Global may procure from suppliers located in many different countries around the world, it is important that we comply with data ,privacy laws in many jurisdictions. In our role as data processor we may require to implement theStandard Contractual Clausesto enable the lawful ,transfer of Personal Dataprocessed by suppliers from the European Economic Area and Switzerland to other countries globally. In additon, Leaseweb ,Affiliates outside of the EEA and Switzerland may implement Standard Contractual Clauses upon request of their EU based customer to set out the ,Leaseweb Affiliate commitment to privacy and data protection when (sub) processing data in connection with the provision of products and services ,in connection with the provision of such products and servicesunder the applicable Sales Contracts.,RETENTION PROCEDURES ,Leaseweb Globalwill storeand retainyour Personal Dataas long as necessary to perform the purposes of processing as stated in thisPrivacy,Statement.,TECHNICAL AND ORGANISATIONAL MEASURES,In accordance with internationaldata protection laws, in particular theGDPR, we aim to observe adequateprocedures to prevent unauthorized access ,to, and the misuse of, Personal Data. We use appropriate business systems and procedures to protect and safeguard the Personal Dataand apply our ,entity split approach. We also use security procedures and technical and physical restrictions for accessing and using the Personal Data on our servers. ,Our privacy policy is to grant only authorized personnel permissionto access Personal Data in the course of their work. Our business processes apply ,a series of security services are compliant with the industry security standards, including ISO 27001.Leaseweb Globalis frequently being audited by ,external parties to ensure it complies with relevant normative frameworks and controls within the Leaseweb Circle of Trust model. See ,www.leaseweb.com/certificationsfor more information.,Leaseweb Globalhas implemented the following generic information security measures across its organisation: ,network segmentation, next generation firewalls, anti-virus software, full disk encryption of end-points, encrypted communication via SSL or VPN, ,Security Information and Event Management solutions, dedicated Security Operating Centre, security awareness training, segregation of duties, ,role-based access permissions (based on least-privilege), secure disposal facilities of confidential information, periodic pentesting of public facing ,services, secure development training, integrated security monitoring during development, tools to enable employees to work secure (such as ,password managers), physical security zones.Per application or communication, additional security measures can be implemented.,DATAPROTECTION OFFICER (DPO),Our Data Protection Officer (“DPO”) is positioned in ourLeaseweb Globalheadquartersin Amsterdam, The Netherlands. This office serves as our ,international center of expertise for internationaldata protection lawscompliance, in particular GDPR compliance, effectively centralizing our ,connection with the Dutch privacy authorityas the permitted one-stop shop facilityfor the DPO.,YOUR RIGHTS,In accordance with data protection laws, as a data subject you have a number of rights regarding your Personal Dataand the processing thereof:,•You can view and, if necessary, change your Personal Data in your account.You will keep the Personal Data up to date and correct. ,▪If you wish to know what information Leaseweb Globaland other Leaseweb entitieshave collected about you.,•You also have the right to obtain from us the erasure of your Personal Data(right to be forgotten)in case permitted and mandatory.,•In addition, you may, under certain circumstances, have the right to restrictionsof the processing of your Personal Data.,•You have the right to object,at any time to processing of your Personal Datain case permitted and mandatory.,•You have the right to receive your Personal Data, which you have provided to us, in a structured, commonly used and machine-readable format.,•You have the right to lodge a complaint with the competent supervisory authority for purpose of data portability.,If you have any requests regarding the abovementioned or if you want to exercise any of the rights set forth above, please contact us using the contact ,details belowfor privacy questions. If we do not grant your request, we will inform you about the reason why. , C ONSENT AND WITHDRAWAL OF CONSENT,You are entitled to withdraw your consent at any time by giving us noticein relation to communication based on your consent as legal ground. Upon ,receipt of a notice where your consent is withdrawn, we will without undue delay stop processing your Personal Data to the extent it is required ,under law. Please use the contact information at the bottom of the page should you wish to withdraw your consent given under this privacy statement.,STATEMENTCHANGES ,Leaseweb Globalreserves the right to change the Privacy Statement, and will post any revisions on the Leaseweb website https://www.leaseweb.com.,Leaseweb Globaladvisesyou to check this page regularly to see if any changes have been implemented., C ONTACT INFORMATION,If you have any requests, questions or suggestions about Leaseweb Global’sprivacy practices, please sendan email to privacy@leaseweb.com.,LeasewebGlobalB.V., a private limited liability company, incorporated under the laws of the Netherlands and withits offices at Hessenbergweg,95, 1101 CXAmsterdam, The Netherlands, listed with the Chamber of Commerce under number 60593652.,This Privacy Statement was most recently changed on 1 November 2020.