THIS POLICY APPLIES ONLY TO THE COLLECTION OF PERSONAL INFORMATION BY INAP. EXCEPT AS STATED OTHERWISE, THIS POLICY DOES NOT APPLY TO THE COLLECTION OF PERSONAL INFORMATION BY INAP CUSTOMERS AND CLIENTS, INCLUDING CLIENTS THAT RECEIVE MANAGED HOSTING, COLOCATION, NETWORK, STORAGE, OR OTHER SERVICES FROM INAP.
|Context||Types of Data||Primary Purpose for Collection and Use of Data|
|Account Information and Information about Clients||We collect the name, and contact information, of our clients and their employees with whom we interact.||We have a legitimate interest in contacting our clients and communicating with them concerning normal business administration such as projects, services, and billing.|
|Client Information||We provide managed hosting solutions. In that role we may receive personal information from one of our clients.||When we receive personal information from one of our clients in order to carry out a project or a service we process that information on their behalf. When we act in this capacity, our client determines the purpose for which the information was collected and how we should use it.|
|Cookies and Third Party Tracking||1. We participate in behavior-based advertising, this means that a third party uses technology (e.g., a cookie) to collect information about your use of our website so that they can provide advertising about products and services tailored to your interests on our website, or on other websites.||We have a legitimate interest in engaging in behavior-based advertising.|
|Email Interconnectivity||If you receive email from us, we may use certain tools to capture data related to when you open or interact with our messages.||We have a legitimate interest in understanding how you interact with our communications to you.|
|Employment||If you apply for a job posting, or become an employee, we collect information necessary to process your application or to retain you as an employee. This may include, among other things, your Social Security Number. Providing this information is required for employment.||We use information about current employees to perform our contract of employment, or the anticipation of a contract of employment with you. In some contexts, we are also required by law to collect information about our employees. We also have a legitimate interest in using your information to have efficient staffing and work force operations.|
|Feedback/Support||If you provide us feedback or contact us for support we will collect your name and e-mail address, as well as any other content that you send to us, in order to reply.||We have a legitimate interest in receiving, and acting upon, your feedback or issues.|
|Mailing List||When you sign up for one of our mailing lists we collect your email address or postal address.||We share information about our products and services with individuals that consent to receive such information. We have a legitimate interest in sharing information about our products or services.|
|Online Registration||We collect your name and contact information when you create an online account. We also collect information relating to the actions that you perform while logged into your account.||We have a legitimate interest in providing account relating functionalities to our users.|
|Web logs||We collect information, including your browser type, operating system, Internet Protocol (IP) address (a number that is automatically assigned to a computer when the Internet is used), domain name, click-activity, referring website, and/or a date/time stamp for visitors.||We have a legitimate interest in monitoring our networks and the visitors to our websites.|
INAP will only retain your data for as long as is necessary or as otherwise provided in INAP’s internal Retention Policy. For example, INAP will only store data being processed pursuant to its legitimate interests for as long as such interests are present.
The Site is a general audience web site. The Site does not knowingly collect any Personal Information from children younger than the age of thirteen (13), and INAP will delete any information later determined by us to be collected from a user younger than age thirteen (13).
The Site may provide you the opportunity to participate and post content publicly through interactive features. You may choose, through such features or otherwise, to submit or post reviews, comments, or suggestions related to INAP’s services, or post free-form comments (collectively, “User Content”). Please note that certain information, such as your name and state of residence, and a link to any website URL you provide may be publicly displayed on the Site along with your User Content. However, INAP will not publish your e-mail address with these comments.
We may also receive information about you from third parties. For example, if you are on another website that provides information about service providers like INAP and you request to receive information from INAP, that website will forward your contact and other information to us so that we may contact you as requested. Third parties may also provide information about you in connection with a marketing arrangement we may have with those third parties.
In addition to any Personal Information or other information that you choose to submit to the Site, we and our third-party service providers, including any third-party content, advertising, and analytics providers, may use a variety of technologies that automatically or passively collect certain information about your use of the Site whenever you visit or interact with the Site (“Site Usage Information”). Site Usage Information may include the browser and operating system you are using, the URL or advertisement that referred you to our Site, the search terms you entered into a search engine that led you to our Site (if applicable), actions you take on the Site and all of the areas within our Site that you visit, and the time of day you visited the Site, among other information. Site Usage Information may also include the unique IP address or other unique identifiers (“Device Identifier”) for any computer, mobile phone, or other device (any, a “Device”) used to access the Site. A Device Identifier is a unique value that is automatically assigned to your Device, so that our servers can identify your Device by its Device Identifier.
We may use Site Usage Information for a variety of purposes, including enhancing or otherwise improving the Site and our products and services. We may associate Site Usage Information with you as a specific and identifiable person. When we do so, we treat the combined information as Personal Information.
Although the sections above describe our primary purpose in collecting your information, in many situations we have more than one purpose. For example, we may collect your information to perform our contract with you, but we also collect your information because we have a legitimate interest in understanding who our clients are and what services we perform on their behalf. As a result, our collection and processing of your information is based in different contexts upon your consent, our need to perform a contract, our obligations under law, and/or our legitimate interest in conducting our business.
We may share information with third parties so that they may provide services to you, INAP, and the Site. Examples include conducting website usage analysis, sending e-mail or other communications on our behalf, providing sales and marketing assistance, or performing other administrative or support services. When we do so, the information is only to be used to provide services or help us provide services.
We may offer sweepstakes, contests, and other promotions (any, a “Promotion”) that may require registration. By participating in a Promotion, you are agreeing to the official rules that govern that Promotion, which may contain specific requirements of you, including, except where prohibited by law, allowing the sponsor(s) of the Promotion to use your name, voice, likeness, or other indicia of persona in advertising or marketing associated with the Promotion. If you choose to enter a Promotion, your Personal Information may be disclosed to third parties or the public in connection with the administration of such Promotion, including, without limitation, in connection with winner selection, prize fulfillment, and as required by law or permitted by the Promotion’s official rules, such as on a winners list.
We may transfer and disclose information, including your Personal Information, Usage Information, and your Device Identifier, to third parties: (i) to respond to subpoenas or other legal process or if in our opinion such disclosure is required by law; (ii) at the request of governmental authorities conducting an investigation (including to meet national security or law enforcement requirements); (iii) to enforce applicable Site terms and policies; or (iv) to respond to an emergency or otherwise to protect the safety, rights, property, or security of INAP, third parties, Site visitors, or the public. We may also use Device Identifiers to identify users, and may do so in cooperation with a court order or law enforcement agencies when legally compelled to do so.
INAP may share information, including Personal Information, as applicable, among its subsidiaries and affiliates, primarily for business and operational purposes. INAP may also disclose and transfer your information, including Personal Information: (i) to a subsequent owner, co-owner or operator of the Site or applicable database; or (ii) if INAP (or any of its affiliated subsidiary companies) assigns its rights regarding any of your information to a third party; or (iii) in connection with a corporate merger, consolidation, restructuring, the sale of certain of our ownership interests, assets, or both, or other corporate change, including, without limitation, during the course of any due diligence process.
We may ask if you would like us to share your information with other unaffiliated third parties who are not described elsewhere in this policy.
For information that we collect on our own behalf we will grant you, where required by law, reasonable access to the personal information that we have about you. You may request access to your personal information by contacting us at the address described below. If we are processing your information on behalf of one of our clients we will forward your request to that client and await instructions on whether access should be granted.
We rely on you to update and correct your personal information. Most of our websites allow you to modify or delete your account profile. If our website does not permit you to update or correct certain information, you contact us at the address described below in order to request that your information by modified. Note that we may keep historical information in our backup files as permitted by law.
We typically retain personal information that we collect on our own behalf for the period necessary to fulfill the purposes outlined in this policy, unless a longer retention period is required or permitted by law. You may request information about how long we keep a specific type of information, or request that we delete your personal information, by contacting us at the address described below. If we are processing your information on behalf of one of our clients we will forward your request to that client and await instructions from them on whether your information should be deleted.
You may revoke consent to processing (where our processing is based upon consent), or object to our processing (where our processing is not based upon your consent) by contacting us at the address described below. If you revoke your consent / object we may no longer be able to provide you services. In some cases we may limit or deny your request to revoke consent / object if the law permits or requires us to do so, or if we are unable to adequately verify your identity. If we are processing your information on behalf of one of our clients we will forward a revocation of consent to that client and await instructions from them on whether the processing to your information should cease.
We do not currently recognize automated browser signals regarding tracking mechanisms, which may include “Do Not Track” instructions.
You may choose to provide us with your email address for the purpose of allowing us to send free newsletters, surveys, offers, and other promotional materials to you, as well as targeted offers from third parties. You can stop receiving promotional emails by following the unsubscribe instructions in e-mails that you receive. If you decide not to receive promotional emails, we may still send you service related communications.
If at any time you do not want to receive offers and/or circulars from us you can remove yourself from our mailing lists by emailing us (our contact information is below) with “NO SNAIL MAIL” in the subject line along with your name, address and zip code. Please note that our mailings are prepared in advance of their being sent. Although we will remove your name from our mailing list after receiving your request, you may still receive mailings from us that had been initiated prior to your name being removed.
If you receive a text message from us that contains promotional information you can opt-out of receiving future text messages by replying “STOP.”
Certain content on the Site may be hosted and served by third parties and the Site may contain links to third-party websites that INAP does not control. The Site may also contain certain third-party content or applications. These links and applications may use an INAP logo as part of a co-branding agreement. In addition, INAP widgets or other INAP content may be included on web pages and websites that are not associated with INAP and over which we have no control. These third parties may collect Site Usage Information through the use of their own cookies and web beacons, independently collect data or solicit Personal Information, and may have the ability to track your use of their sites and services. INAP is not responsible for the privacy practices employed by any third party.
If you apply for a job through the Site, we, or a human resources company assisting us, may ask you to provide self-identifying information (such as veteran status, gender, and ethnicity) in conjunction with laws and regulations enforced by the Equal Employment Opportunity Commission (“EEOC”), the Office of Federal Contract Compliance Programs (“OFCCP”), and similar state and local regulatory agencies. Providing self-identifying information is voluntary, but if you do provide us with that information, we may submit it to the EEOC, the OFCCP, and similar state and local regulatory agencies for business-related purposes, including responding to information requests, fulfilling regulatory reporting requirements, and defending against employment related complaints.
If you are located in the European Union, Canada, or elsewhere outside of the United States, please be aware that any information you provide to us may be transferred to and processed in the United States. By using the Site, or providing us with any information, you consent to this transfer, processing and storage of your information in the United States, a jurisdiction in which the privacy laws may not be different than those in the country where you reside or are a citizen.
Pursuant to the Privacy Shield Frameworks, EU and Swiss individuals have the right to obtain our confirmation of whether we maintain personal information relating to you in the United States. Upon request, we will provide you with access to the personal information that we hold about you. You may also may correct, amend, or delete the personal information we hold about you. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data transferred to the United States under Privacy Shield, should direct their query to email@example.com. If requested to remove data, we will respond within a reasonable timeframe.
Your right to access your Personal Data may be restricted in exceptional circumstances, including, but not limited to, when the burden or expense of providing this access would be disproportionate to the risks to your privacy in the case in question, or when the rights of persons other than you would be violated by the provision of such access. If we determine that your access should be restricted in a particular instance, we will provide you with an explanation of our determination and respond to any inquiries you may have.
INAP’s accountability for personal data that it receives under the Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles. In particular, INAP remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process the personal data on its behalf do so in a manner inconsistent with the Principles, unless INAP proves that it is not responsible for the event giving rise to the damage.
In compliance with the Privacy Shield Principles, INAP commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to Privacy Shield. European Union and Swiss individuals with Privacy Shield inquiries or complaints should first contact INAP at:Legal Department
INAP has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint. This service is provided free of charge to you.
If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction.With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, INAP is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission.
California Civil Code 1798.115(c), 1798.130(a)(5)(c), 1798.130(c), and 1798.140 indicates that organizations should disclose whether certain categories of information are “sold” or transferred for an organization’s “business purpose” as those terms are defined under California law. You can find a list of the categories of information that we collect and share here. Please note that because this list is comprehensive it may refer to types of information that we share about people other than yourself. California residents may be entitled, if applicable, to opt-out of having their information sold to third parties. We do not discriminate against California consumers who exercise any of their rights described in this policy.
INAP complies with the E.U. General Data Protection Regulation (“GDPR”) in effect on and after May 25, 2018. For more information concerning INAP’s compliance with GDPR, including the exercise of any data subject rights which may be available to you in the event some or all of your data is personal data subject to GDPR, please visit INAP’s GDPR FAQ, available at https://www.inap.com/legal/gdpr/.
INAP may receive personal data from data subjects, including through use of the Site. These categories of data may include:
As set forth more fully on INAP’s GDPR page, INAP complies with applicable GDPR requirements in its capacity as a “processor” and a “controller.” Should you have any additional questions concerning GDPR, or should you wish to exercise any data subject right which may apply to your personal data, please contact us at the following address: firstname.lastname@example.org.Last Updated: June 2020