Your privacy is important to Leaseweb Network B.V., trading under the name FiberRing (hereinafter “Leaseweb Network”). Leaseweb Network is therefore pleased to provide this privacy statement to inform you of Leaseweb Network’s practices with respect to the collection and use of your personal information (“Personal Data”)
COMPLIANCE WITH INTERNATIONAL DATA PROTECTION LAWS, IN PARTICULAR THE GDPR.
Leaseweb Network complies with international data protection laws, in particular the Regulation 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 Network has implemented the following requirements 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 by Design & Default, Data Portability, Data Subject Rights like the Right to be Forgotten.
- A Data Processor Agreement in our role as data controller and data sub-processor.
- A data breach procedure.
HOW LEASEWEB NETWORK MAY COLLECT INFORMATION ABOUT YOU IN OUR ROLE AS DATA CONTROLLER
Leaseweb Network may collect your Personal Data when:
- You order a service from Leaseweb Network.
- You enter a promotional game of chance with Leaseweb Network.
- You participate in a Leaseweb Network survey.
- You subscribe to a Leaseweb Network newsletter.
- You ask Leaseweb Network for more information about a Leaseweb service, or contact Leaseweb Network with a question, comment or complaint.
- You submit an abuse notification to Leaseweb Network.
- You use the Leaseweb Network network, Leaseweb Network infrastructure and/or other Leaseweb Network services.
Leaseweb Network also collects Personal Data about you from LeaseWeb Global B.V. (hereinafter “Leaseweb Global”) and other affiliates of Leaseweb Network. In addition, Leaseweb Network may collect Personal Data about you from fraud-prevention agencies, referral partners, business directories and credit reference agencies.
WHAT KIND OF INFORMATION LEASEWEB NETWORK MAY COLLECT ABOUT YOU IN OUR ROLE AS DATA CONTROLLER
Leaseweb NL may collect the following information about you:
- Your name, (business/private) address, phone number, date of birth, email address and personal identification numbers.
- Your Leaseweb Network account information – such as Leaseweb Network services you ordered, domain name registration information, the IP addresses assigned to you, your customer ID, service charges owed and received, the use of Leaseweb Network services or any other information related to your account.
- Your contact with Leaseweb Network – such as a note or recording of a call you make to Leaseweb Network, a chat record when you engage in a chat session with Leaseweb Network, an email or letter you send to Leaseweb Network or other records of any contact you have with Leaseweb Network.
- Information about your payment method, such as credit card number, bank account number or other banking information.
- Information provided by you to Leaseweb Network when you notify Leaseweb Network of a (suspected) breach of Leaseweb Network’s acceptable use policies.
- Video footage of you when you are in a Leaseweb Network datacenter or the public space outside and inside our offices.
- Documents and information that certify your identity.
To process your information as described above, we rely on the following legal bases:
- 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 service under 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: we may rely on your consent to use your Personal Data for certain direct marketing purposes. Whenever we rely on your consent for processing your Personal Data, you are free to withdraw your consent at any time. See also the section ‘CONSENT AND WITHDRAWAL OF CONSENT’.
You are free to decide whether or not to share certain Personal Data (if any) with us. 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 services and, in some cases, whether we can provide you our services.
WHY LEASEWEB NETWORK PROCESSES YOUR PERSONAL DATA IN OUR ROLE AS DATA CONTROLLER
Leaseweb Network 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 KIND OF INFORMATION LEASEWEB NL MAY COLLECT ABOUT 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 and provision of services: a-d, g and 1, 2.
- 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 Network services 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: a-d, g and 2, 3.
- Communicating with customers (i) to provide information about services of Leaseweb Network and 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: a-d, g and 1, 2.
- 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: a-d, g and 1, 2.
- 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: a-d, g and 1, 2.
- Investigating and processing suspected violations of Leaseweb Network’s acceptable use policy: 1, 2.
- Ensuring the security of persons, goods and objects, and performing fraud detection: a-d, g and 1, 2.
- 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 customers in connection with an infringement of these third parties’ rights: a-g and 2.
- Establishing the identity of customers or third parties, including in relation to the provision of access to data centers and our offices: a, f-g and 1, 2.
SHARING YOUR PERSONAL DATA WITH THIRD PARTIES IN OUR ROLE AS DATA CONTROLLER
Leaseweb Network may share Data about you with:
- Leaseweb Global. This affiliate of Leaseweb Network offers tools and services (including the websites www.leaseweb.com, the LeaseWeb Customer Portal and the LeaseWeb API) that may be used to order or manage Leaseweb Network Services or to communicate with Leaseweb Network. Leaseweb Network may share your Data with Leaseweb Global in connection with said tools and services. Please review the privacy statement of Leaseweb Global on our website to learn about its practices with respect to the collection, storage and use of your Data.
- Other Leaseweb entities. The other LeaseWeb entities offer tools and services that may be used to order or manage Leaseweb Network Services or to communicate with Leaseweb Network. Leaseweb Network may share your Data with other LeaseWeb entities in connection with said tools and services. Please review the privacy statement of the other LeaseWeb entities on our website to learn about its practices with respect to the collection, storage and use of your Data.
- Partners or agents involved in delivering the services you’ve ordered with Leaseweb Network.
- Credit reference, fraud prevention or business scoring agencies, or other credit scoring agencies.
- Domain name registries when Leaseweb Network registers 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.
- A Leaseweb Network customer, if you notify Leaseweb Network that this customer use of Leaseweb Network services violates the Leaseweb Network’s Acceptable Use Policies or applicable law.
- A third party that has claimed that your use of the Leaseweb Network services violates the Leaseweb Network’s Acceptable Use Policies or applicable law (to the extent such sharing is required by law).
Because we are a global company with customers 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 have implemented the Standard Contractual Clauses to enable the lawful transfer of Personal Data from the European Economic Area and Switzerland to other countries globally. The Standard Contractual Clauses set out the Leaseweb affiliate commitment to privacy and data protection when processing data in connection with the provision of products and services to our customers and partners, and dealing with the transfer of Personal Data outside the EEA and Switzerland in connection with the provision of such products and services.
If you as EU customer or partner specifically require the implementation of Standard Contractual Clauses directly with one of our entities outside of the EEA, where appropriate and where this affiliate is a data processor for the customer or partner, please contact us using the contact details below.
LEASEWEB NETWORK IN ITS ROLE AS PROCESSOR
Personal Data hosted, transmitted or processed on infrastructure owned by you or leased from Leaseweb Network is governed by this paragraph. The customer of Leaseweb Network that owns or has leased Leaseweb Network infrastructure, will be responsible for determining the purposes and means of the processing of Personal Data, and this Leaseweb Network customer (or its customers) will be the data controller in regards to such processing. If at any time Leaseweb Network has access to personal data stored on infrastructure owned by a Leaseweb Network customer or leased from Leaseweb Network, then Leaseweb Network shall be a data processor, and any actions performed by Leaseweb Network in relation to such data shall be solely governed by the agreement concluded between Leaseweb Network and its customer.
Leaseweb Network will store your Personal Data as long as necessary to perform the purposes of processing as stated in this privacy statement; unless otherwise required by law. Therefore, the exact retention period of your Personal Data may vary on case-by-case basis.
TECHNICAL AND ORGANISATIONAL SECURITY PROCEDURES
In accordance with international data protection laws, in particular the GDPR, we observe adequate procedures 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 physical restrictions 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 Network has implemented the following, but not limited to, 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.
Leaseweb Network is 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/certifications for more information.
Our privacy counsel is positioned in our head quarter in Amsterdam, The Netherlands. The head quarter is located at Luttenbergweg 8, 1101 EC Amsterdam, the Netherlands. This office serves as our international center of expertise for international data protection laws compliance, in particular GDPR compliance, effectively centralizing our connection with the Dutch privacy authority. You can reach our privacy counsel by sending an e-mail to firstname.lastname@example.org.
In accordance with data protection laws, you have a number of rights regarding your Personal Data and the processing thereof:
- You can view and, if necessary, change your Personal Data in your account at any time.
- If you wish to know what information Leaseweb Network, Leaseweb Global and other Leaseweb entities have collected about you.
- If you want to make changes to the Personal Data you 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 is necessary for the performance of a contract.
- You have the right to lodge a complaint with the competent supervisory authority.
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 below. If we do not grant your request, we will inform you about the reason why.
CONSENT AND WITHDRAWAL OF CONSENT
You are entitled to withdraw your consent at any time by giving us notice. 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.
Leaseweb Network reserves the right to change the privacy statement, and will post any revisions on the Leaseweb website www.leaseweb.com. Leaseweb Network advises you to check this page regularly to see if any changes have been implemented. If Leaseweb Network implements a change in how we deal with Personal Data with respect to which we require your consent, we will re-request your consent.
If you have any requests, questions or suggestions about Leaseweb Network’s privacy practices, please send an email to email@example.com.
LeaseWeb Network B.V., a private limited liability company, incorporated under the laws of the Netherlands and with its offices at Luttenbergweg 8, 1101 EC Amsterdam, The Netherlands, listed with the Chamber of Commerce under number 30188570.
This privacy statement was most recently changed on 1 May 2018.