Leaseweb

Privacy Statement CDN Services




PRIVACY STATEMENTVERSION:LSW_CDN_B2B_V.1 NOV2020,LEASEWEB CDNB.V.,1of 3,COMPLIANCE WITH INTERNATIONAL DATA PROTECTION LAWS,IN PARTICULAR THEGDPR,Leaseweb CDNcomplieswith 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 CDNhas 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 tobe Forgotten.,▪A Data Processor Agreement in our role as data controller and data sub-processor.,▪A data breachprocedure.,▪An internal privacy policy.,HOW LEASEWEB CDNMAY COLLECTINFORMATION ABOUT YOUIN OURROLE AS DATA CONTROLLER,Leaseweb CDNmay collect yourPersonalData when:,▪You ordera service from Leaseweb CDN.,▪You enter a promotional game of chance with Leaseweb CDN.,▪You participate in a Leaseweb CDNsurvey.,▪You subscribe to a Leaseweb CDNnewsletter.,▪You ask Leaseweb CDNfor more information about a LeaseWeb service, or contact Leaseweb CDNwith aquestion, comment or complaint.,▪You submit an abuse notification to Leaseweb CDN.,▪You use the Leaseweb CDNnetwork, Leaseweb CDNinfrastructure and/or other Leaseweb CDNservices.,Leaseweb CDNalso collects Personal Data about youfrom LeaseWeb Global B.V. (hereinafter “Leaseweb Global”) and other affiliates of Leaseweb ,CDN. In addition, Leaseweb CDNmaycollectPersonal Data about you from fraud-prevention agencies, referral partners, business directories and ,credit reference agencies.,WHAT KINDOF INFORMATION LEASEWEB CDNMAY COLLECTABOUT YOUIN OURROLE AS DATA CONTROLLER,Leaseweb CDNmay collectthe following information about you:,a.Yourname, (business/private) address, phone number, date of birth, email address and personal identification numbers.,b.YourLeaseweb CDNaccount information –such as Leaseweb CDNservices youordered, domain name registration information, the IP addresses ,assigned to you, your customer ID, service charges owed and received, the use of Leaseweb CDNservices or any other information related to ,your account.,c.Your contact with Leaseweb CDN–such as a note or recording of a call you make to Leaseweb CDN, a chat recordwhen you engage in a chat ,session with Leaseweb CDN, an email or letter you send to Leaseweb CDNor other records of any contact you have with Leaseweb CDN.,d.Information about your payment method, such as credit card number, bank account number or other banking information.,e.Information provided by you to Leaseweb CDNwhen you notify Leaseweb CDNof a (suspected) breach of Leaseweb CDN’s acceptable use ,policies.,f.Video footage of youwhen you are in a Leaseweb CDNdatacenteror the public space outside and inside our offices.,g.Documents and information that certify your identity.,LEGAL GROUNDS,To process your information as described above, we rely on the following legal bases:,1.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.,2.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, toimprove and promote our products and ,services and the content on our website, and for administrative, fraud detection and legal purposesand for sales and marketing processes with ,Affiliates including Leaseweb Global.,Consent: For certain marketing purposes, you are free to withdraw your consent at any time. ,You are free to decide whether or not to share certain Personal Data (if any) with usfor direct marketing purposes. However, if you decide not to ,provide certain Personal Data. or if you withdraw your consent thereto at a latter moment, this may have affect how you experience our marketing ,for similar services.,WHY LEASEWEB CDNPROCESSES YOUR PERSONAL DATAIN OURROLE AS DATA CONTROLLER,Leaseweb CDN processes your Personal Data for, among others, the purposes as described below. For the purpose of clarity, the letters indicate which ,information may be processed for such purpose(see our section ‘WHAT KINDOF INFORMATION LEASEWEB CDNMAY COLLECTABOUT YOU IN OUR ROLE AS DATA ,CONTROLLER‘) and the numbers behind each processing purpose indicate on which legal ground the processing takes place (see our section ‘LEGAL ,GROUNDS’):,▪Processing of Orders contracts and provision of services, including full customer verification.,▪Conducting market research, conducting retention and customer satisfaction surveys, conducting marketing activities (including through email ,newsletters, social media and onsite/offsite and online/offline advertisement), conducting sales activities (including analyzing your Personal ,Data and your use of Leaseweb CDNservices for making (personalized) offers and quotes with the aim of entering into a customer relationship, ,and/or maintaining, renewing or expanding a customer relationship) and offering promotional games of chance.,GDPR and privacy is important to LeaseWeb CDNB.V. (hereinafter “Leaseweb CDN”)and its business relations. Leaseweb CDNduly informs you ,of Leaseweb CDN’s practices with respect to the possible processing of personal data while doing business with you(“Personal Data”). ,PRIVACY STATEMENTVERSION:LSW_CDN_B2B_V.1 NOV2020,LEASEWEB CDNB.V.,2of 3,▪Communicating with customers (i) to provide information about services of Leaseweb CDNand affiliated companies, (ii) to provide information ,about offers, orders, provision of services, order status and payment, (iii) to provide support and maintenance services, (iv) to handle complaints, ,and (v) to answer questions from (potential) customers.,▪Performing financial processes, including (i) calculating, invoicing and collecting of service charges, (ii) processing financial transactions regarding ,the acceptance of orders, and (iii) granting debt collection rights to third parties.,▪Investigating creditworthiness and risk management, including prevention of overextending credit to (potential) customers and verifying ,whether (potential) customers will be able to comply with financial obligations.,▪Investigating and processing suspected violations of Leaseweb CDN’sPolicies.,▪Ensuring the security of persons, goods and objects, and performing fraud detection.,▪Conducting legal processes, including (i) conducting legal proceedings, and (ii) collecting evidence for civil legal proceedings relating to you.,▪Complying with statutory obligations, including (i) provision of data to authorized authorities in the context of criminal investigations, (ii) ,complying with (applicable) data retention obligations, and (iii) the provision to third parties of Data concerning customersin connection with ,an infringement of these third parties’ rights.,▪Establishing the identity of customers or third parties, including in relation to the provision of access to data centers andour offices.. ,SHARING YOUR PERSONAL DATA WITH THIRD PARTIES IN OURROLE AS DATA CONTROLLER,Leaseweb CDNmay share Data about you with:,▪It’s group affiliates including Leaseweb Globalfor the purposes of financial, tax, sales, marketing and operational tools andservices (including ,the websites www.leaseweb.com, the Leaseweb Customer Portal and the Leaseweb API) that may be used to order or manage Leaseweb CDN,Services or to communicate with Leaseweb CDN. Please review the Privacy Statementof Leaseweb Globalon our website to learn about its ,practices with respect to the collection, storage and use of your Data.,▪Suppliers or agents involved in delivering the services you’ve ordered with Leaseweb CDN.,▪ C redit reference, fraud prevention or business scoring agencies, or other credit scoring agencies.,▪Domain name registries when Leaseweb CDNregisters a domain name on your behalf.,▪Debt collection agencies or other debt recovery organisations.,▪Law enforcement agencies, regulatory organisations, courts or other public authorities to the extent required by law.,▪ALeaseweb CDNcustomer, if you notify Leaseweb CDNthat this customer use of Leaseweb CDNservices violates the Leaseweb CDN’s Policies ,or applicable law.,▪A third party that has claimed that your use of the Leaseweb CDNservices violates the Leaseweb CDN’s Policiesor applicable law (to the extent ,such sharing is required by law).,LEASEWEB CDNIN ITS ROLEAS SUB-PROCESSOR,Personal Data hosted, transmitted or processed on infrastructureowned by you orleased from Leaseweb CDNis governed by this paragraph. The ,customer of Leaseweb CDNthat owns or has leased Leaseweb CDNinfrastructure, will be responsible for determining the purposes and means of the ,processing of Personal Data, and this Leaseweb CDNcustomer (or its customers) will be the data controller in regards to such processing. If at any ,time Leaseweb CDNhas access to personal data stored on infrastructure owned by a Leaseweb CDNcustomer or leased from Leaseweb CDN, then ,Leaseweb CDNshall be a data sub-processor, and any actions performed by Leaseweb CDNin relation to such data shall be solely governed by the ,agreement concluded between Leaseweb CDNand itscustomer.,RETENTION PROCEDURES ,Leaseweb CDNwill store your Personal Dataas long as necessary to perform the purposes of processing as stated in thisPrivacyStatement.,TECHNICAL AND ORGANISATIONAL SECURITY PROCEDURESANDDATA TRANSFERS,In accordance with internationaldata protection laws, in particular theGDPR, we 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 Data. We also use ,security procedures and technical and physicalrestrictions for accessing and using the Personal Data on our servers. Only authorized personnel are ,permitted to 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, SOC 1, HIPAA and PCI DSS, and NEN 7510.,Leaseweb CDNhas implemented the following, but not limited to, generic informationsecurity 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.,Leaseweb CDNis 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.,DATA PROTECTION OFFICER (DPO),Our Data Protection Officer (“DPO”)is positioned in the Leaseweb Global headquarters 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 authority as the permitted one-stop shop facility for the DPO.,YOUR RIGHTS,In accordance with data protection laws, 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 at any time. ,▪Ifyou wish to know what information Leaseweb CDN,Leaseweb Globaland other affiliates of Leaseweb CDNhave collected about you.,PRIVACY STATEMENTVERSION:LSW_CDN_B2B_V.1 NOV2020,LEASEWEB CDNB.V.,3of 3,▪Ifyou want to make changes to the Personal Datayou have seen you cannot change in your account.,▪You also have the right to obtain from us the erasure of your Personal Data(right to be forgotten).,▪In addition, you may, under certain circumstances, have the right to restriction of the processing of your Personal Data.,▪You have the right to object, on grounds relating to your particular situation, at any time to processing of your Personal Data.,▪You have the right to receive your Personal Data, which you have provided to us, in a structured, commonly used and machine-readable format ,and have the right to transmit those data to another controller when the processing is based on your consent or isnecessary for the performance ,of a contract.,If you have any requests regarding the abovementioned, please contact us using the contact details below. If wedonot grantyour request, wewill ,inform you about the reason why.,STATEMENTCHANGES ,Leaseweb CDNreserves the right to change the Privacy Statement, and will post any revisions on the Leaseweb website www.leaseweb.com. ,Leaseweb CDNadvisesyou 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 CDN’sprivacy practices, please sendan email to privacy@leaseweb.com.,LeaseWeb CDNB.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 55685986.,This Privacy Statement was most recently changed on 1November 2020.





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