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Last Updated: October 2019

ZENLAYER.COM PRIVACY POLICY

 

Introduction

Thank you for accessing the zenlayer.com website operated by Zenlayer, Inc. (“Zenlayer,” “we,” “our,” or “us”). We respect your privacy and want to protect your personal information. This Privacy Policy governs the Zenlayer.com and portal.zenlayer.com websites and their subdomains (the “Site”), portals, applications, products, services, events, and any interactive features, applications, and/or other services (“Services”) that reference this Privacy Policy. This Privacy Policy also applies to Personal Information we may collect from you on our website, our portal, while visiting our booth during an event, while accessing a white paper online, via telephone calls with our office, through online payments, or in any other instance when you contact us. This Privacy Policy does not apply to any products, services, websites, or content that are offered by third parties (“Third Party Services”), which are governed by their respective privacy policies.

This Privacy Policy does not apply to the “content” processed, stored, or hosted by our customers using the Zenlayer portal (“Customer Content Data") in connection with a Zenlayer account. (See the Master Service Agreement (“MSA”) governing access to your Zenlayer account for more information about how we handle content and how our customers can control their content through the Services.) Zenlayer is only a processor of Customer Content Data – data directly resulting from the provision of service – and works at the direction of its controller customers.

This Privacy Policy describes what information we collect from you, why we collect it, how we use it, under what circumstances we may share it with third parties, and how we protect that information. To the extent we provide you notice on our Site of different or additional privacy policies or practices (e.g., at the point of collection of your information), those additional terms shall govern such data collection and use. If you voluntarily provide your information in the course of using or interacting with our Site, purchasing our products, or using our Services, we will take that as your agreement to our collection, use, and disclosure of your information as set forth in this Privacy Policy.

In addition, please review the Site’s Terms of Use, which govern your use of the Site. By using our Site, you consent to our Privacy Policy and agree to our Terms of Use.

 

Table of Contents

What Information We Collect

Why We Collect Information

When We Disclose Information

Location of Personal Information

Where Zenlayer Acts as a Data Processor for EU/EEA and/or Switzerland Customers

For Zenlayer Services Users

Your Choices About the Information We Collect

Your California Privacy Rights

California/Delaware Do Not Track Disclosures

For Visitors Within the European Economic Area

Visitors to the Site Outside of the United States

Updating Personal Information

Links

Security

Questions/Changes in Privacy Policy

 



 
 

What Information We Collect

(a) Information You Provide to Us

In connection with the products and Services we provide, we may ask you to provide us with (i) your first and last name, email address, company, title, home or business address, other shipping or billing addresses, telephone number, mobile number, your purchase/order history, or other information that could reasonably be used to identify you personally or identify your household (hereinafter, “Personal Information”); and/or (ii) demographic information, such as your country, state, or county of residence or business operation (“Demographic Information”). We may collect this information when you:

  • Register and/or order products or Services on our Site;
  • Login to obtain access to products or Services ordered from Zenlayer;
  • Contact us regarding a question, concern, or inquiry, such as when you make inquiries concerning our Site, products and/or Services;
  • Sign up or request to be placed on our mailing and/or email marketing lists; and/or
  • Otherwise interact with the Site or our staff.

Your decision to provide us with information is voluntary, but if you choose not to provide any requested information, you may not be able to take advantage of all of the Site’s features or our Services, including ordering products, submitting inquiries, or signing up for newsletters or marketing lists.

Zenlayer further recognizes the importance of children’s safety and privacy. The Site is not designed to attract children and is not intended for use by any children under the age of 18. We do not request, or knowingly collect, any personally identifiable information from children. Minors under the age of 18 may use the Site only under the supervision of a parent or legal guardian who agrees to be bound by the Site’s Terms of Use.

(b) General Browsing

In addition to information that you choose to submit to us, we and/or our service providers may automatically collect and/or store certain information when you visit or interact with the Site (“Usage Information”). This Usage Information may be stored and/or accessed from your personal computer, laptop, tablet, mobile phone or other device (a “Device”) whenever you visit or interact with our Site.  Usage Information may include:

  • your IP address, UDID or other unique identifier (“Device Identifier”);
  • your Device functionality (including browser, operating system, hardware, mobile network information);
  • the areas within our Site that you visit and your activities there, including remembering you and your preferences;
  • your Device location;
  • your Device characteristics; and
  • certain other Device data, including the time of day you visit our Site.

(c) Use of Cookies and other Tracking Technologies

We may use various methods and technologies to store or collect Usage Information (“Tracking Technologies”). Tracking Technologies may set, change, alter or modify settings or configurations on your Device. A few of the Tracking Technologies used on the Site, include, without limitation, the following (and subsequent technology and methods later developed):

  • Cookies. A cookie is a file placed on a Device to uniquely identify your browser or to store information on your Device.  Our Site may use HTTP cookies, HTML5 cookies, Flash cookies and other types of cookie technology to store information on local storage.
  • Web Beacons. A Web Beacon is a small tag (which may be invisible to you) that may be placed on our Site’s pages and messages.
  • Embedded Scripts. An embedded script is programming code that is designed to collect information about your interactions with the Site, such as the links you click on.
  • ETag, or entity tag. An Etag or entity tag is a feature of the cache in browsers.  It is an opaque identifier assigned by a web server to a specific version of a resource found at a URL.
  • Browser Fingerprinting. Collection and analysis of information from your Device, such as, without limitation, your operating system, plug-ins, system fonts and other data, for purposes of identification.
  • Recognition Technologies. Technologies, including application of statistical probability to data sets, which attempt to recognize or make assumptions about users and devices (g., that a user of multiple devices is the same user).

We may use Tracking Technologies for a variety of purposes, including:

  • To allow you to use and access the Site, including for the prevention of fraudulent activity and improved security functionality or to allow you to make use of shopping cart or payment functionality;
  • To assess the performance of the Site, including as part of our analytic practices or otherwise to improve the content, products or services offered through the Site;
  • To offer you enhanced functionality when accessing the Site, including identifying you when you sign into our Site or keeping track of your specified preferences or to track your online activities over time and across third-party sites; and
  • To deliver content relevant to your interests on our Site and third‑party sites based on how you interact with our advertisements and/or content.

Please see our Cookie Policy for more information.

(d) Information We Collect When You Interact with Third-Party Sites

The Site may include functionality that allows certain kinds of interactions between the Site and your account on a third-party website or application. The use of this functionality may involve the third-party site providing information to us. For example, we may provide links on the Site to facilitate sending a communication from the Site or we may use third parties to facilitate emails or postings to social media. We may use third parties to deliver products to you. We also may provide links to allow third parties to process credit card and/or electronic payments. These third parties may retain any information used or provided in any such communications or activities and these third parties’ practices are not subject to our Privacy Policy. Zenlayer may not control or have access to your communications through these third parties. Further, when you use third-party sites or services, you are using their services and not our services and they, not we, are responsible for their practices. You should review the applicable third-party privacy policies before using such third-party tools on our Site.


 
 

Why We Collect Information

We may use your Personal Information, Demographic Information, or Usage Information for various purposes, including:

  • Registering and maintaining your account;
  • Processing your order(s) and providing you with customer service, including responding to your inquiries regarding our products and Services and/or communicating with you regarding orders, purchases, and payments;
  • Complying with legal obligations, including, for example, collecting address information for identity verification for credit card billing;
  • Sending you marketing information about Zenlayer and our affiliated entities;
  • Sending you email communications such as electronic newsletters about our products, Services, events, and promotions;
  • Improving the effectiveness of our Site, marketing endeavors, and product and service offerings;
  • Identifying your product and service preferences, providing personalized content and ads and informing you of new or additional information, products and services that may be of interest to you;
  • Assisting us in communicating about Zenlayer to a friend using the referral “tell a friend” function;
  • Allowing you to participate in interactive discussions and public forums;
  • Helping us address problems with and improve our Site and our products and services;
  • Providing mobile marketing messages and other communications and messages;
  • Protecting the security and integrity of the Site;
  • For internal business purposes; and
  • For purposes disclosed at the time you provide your information or as otherwise set forth in this Privacy Policy.


 
 

When We Disclose Information

We may share non-Personal Information, such as aggregated user statistics and your Device Identifiers with third parties along with data related to you and your activities. Also, we may share your information, including your Personal Information, with third parties, such as companies with whom we have marketing or other relationships, for the third parties’ direct marketing purposes. (If you are a California resident, you have the right to request additional information. Please see the Section below entitled “Your California Privacy Rights” below about these rights.) In addition, we may share the information we have collected about you, including Personal Information, as disclosed at the time you provide your information and as described in this Privacy Policy. Examples of when Zenlayer may share your information include as follows:

(a)        Third Parties Providing Services to Zenlayer. We may use Third-Party Service providers to perform certain services on behalf of us or the Site, such as: (i) shipping products and ensuring delivery; (ii) processing credit cards and/or electronic payments; (iii) assisting us in Site operations; (iv) managing a database of customer information; (v) hosting the Site; (vi) designing and/or operating the Site’s features; (vii) tracking the Site’s activities and analytics; (viii) enabling us to send you special offers or perform other administrative services; and (ix) other services designed to assist us in maximizing our business potential. We may provide these vendors with access to user information to carry out the services they are performing for you or for us. Those vendors may have additional or different privacy policies and/or Terms of Use. You should be sure that you read and agree to those policies and Terms.

(b)        To Protect the Rights of Zenlayer and Others. To the fullest extent permitted by applicable law, we may also disclose your information if we believe in good faith that doing so is necessary or appropriate to: (i) protect or defend the rights, safety or property of Zenlayer or third parties (including through the enforcement of this Privacy Policy, our Terms of Use, and other applicable agreements and policies); or (ii) comply with legal and regulatory obligations (e.g., pursuant to law enforcement inquiries, subpoenas or court orders). To the fullest extent permitted by applicable law, we have complete discretion in electing to make or not make such disclosures, and to contest or not contest requests for such disclosures, all without notice to you.

(c)        Affiliates and Business Transfer. We may share your information with our parent, subsidiaries and affiliates. As part of this sharing of information with our parent, subsidiaries and affiliates, this means that once you provide us with information, any one of our related entities may use your information including for marketing purposes, pursuant to the terms of this Privacy Policy. We also reserve the right to disclose and transfer all such information: (i) to a subsequent owner, co-owner or operator of the Site and/or our Services; or (ii) in connection with a merger, consolidation, restructuring, the sale of substantially all of our interests and/or assets or other corporate change, including during any due diligence process.


 
 

Location of Personal Information

Zenlayer, Inc. is located in the United States, and our affiliated companies are located throughout the world.  Depending on the scope of your interactions with the Zenlayer Services, your personal information may be stored in or accessed from multiple countries, including the United States. Whenever we transfer personal information to other jurisdictions, we will ensure that the information is transferred in accordance with this Privacy Policy and as permitted by applicable data protection laws.


 
 

Where Zenlayer Acts as a Data Processor for EU/EEA and/or Switzerland Customers

When providing infrastructure as a service (IaaS), Zenlayer may process personal data controlled by its customers or customers of Zenlayer entities located in the European Union/European Economic Area (“EU/EEA”). Zenlayer does not determine or have knowledge of the types of data stored by customers and/or how that data is accessed, exchanged, processed or the classification of that data. Zenlayer customers are the data controllers of such personal data and are responsible for compliance with applicable data protection principles. Zenlayer processes data as a data processor at the direction of its customers in accordance with the terms of the MSA.

The provision of IaaS may, at the direction of the customer, include the transfer by the customer of its personal data outside of the EEA to jurisdictions which may not provide the same level of legal protection as in the EEA. The customer is responsible for ensuring that it has all necessary consents and agreements in place with data subjects for international transfers of personal data that it directs as part of its receipt of IaaS.

The terms “process,” “data controller,” “data processor,” and “data subject” have the meanings given to them in the EU General Data Protection Regulation (“GDPR”).

On occasion, employees of Zenlayer Inc. that are located in the U.S. may have temporary access to Customer Content Data in connection with providing maintenance or support services to you. This access will only be accomplished by way of your explicit permission and instructions (as the Controller of the Customer Content Data) and only for so long as the employee is providing services to you. As a Processor, Zenlayer will not access the Customer Content Data for any purpose beyond providing you with support as described above and will not disclose it to any person or entity for their own purposes except by explicit consent.


 
 

For Zenlayer Services Users

You are solely responsible for any processing or international transfer of Personal and Demographic Information in the Customer Content Data, including in any Third Party Services, and you agree to comply with all applicable rules, laws, and regulations in any and all applicable regions or countries related to the transfer of such Personal and Demographic Information. To the extent, this Personal and Demographic Information is subject to rules, laws, regulations, or the like, including GDPR, Zenlayer will be considered a “data processor” and will, as such, act on your instructions as the data controller, and implement security measures in accordance with the MSA.


 
 

Your Choices About the Information We Collect

At any time, you can request access to your personal information, request that any inaccuracies be corrected, and request that comments or explanations be added to records about you.

You can also ask about:

  • whether and why we have your personal information;
  • how we got your personal information;
  • what we have done with your personal information;
  • to whom we have communicated your personal information;
  • where your personal information has been stored, processed or transferred;
  • how long we will retain your personal information, or how that retention period will be determined; and
  • the safeguards in place to protect your information when it is transferred to third parties or third countries.

Finally, you can ask us not to collect or use your personal information for certain purposes, you can ask us to delete your personal information, or you can ask us to provide your personal information to a third party. To do so, please log in to your account to contact us through your Customer Portal. You may also email us at privacy@zenlayer.com or contact us at the postal address below. We will respond to your request within a reasonable time or advise you why our processing may be delayed.

If you would prefer that we not share your name and mailing address with third parties (other than with our affiliates) to receive promotional offers, you have the option to opt out of such sharing.  To do so, please email us at privacy@zenlayer.com. Your choice will not affect our ability to share information in other ways described in this Privacy Policy.

Zenlayer reserves the right to take reasonable steps to verify customer identity prior to granting access or processing changes or corrections.

We may refer any of these requests to our customer if your personal information was collected on behalf of that client and we operate as a processor for that controller customer.

Depending on which laws apply to your personal information, we or our customer may only be able to do some of these things for you. If you request one of these things and we refuse to do it, we will explain your legal rights, the reason for our refusal, and any recourse you may have.

Contact us at the address or email below. We will respond to your request within a reasonable time or advise you why our process may be delayed.  Zenlayer reserves the right to take reasonable steps to verify customer identity prior to granting access or processing changes or corrections.

If you would prefer that we not share your name and mailing address with third parties (other than with our affiliates) to receive promotional offers, you have the option to opt out of such sharing.  To do so, please email us at marketing@zenlayer.com. Your choice will not affect our ability to share information in other ways described in this Privacy Policy.

If you do not wish to receive e-mails about special offers, events, and other promotions from us, email us at marketing@zenlayer.com to opt out, or if you do not wish to receive other marketing materials by regular mail from us, please write us at:

Zenlayer, Inc.

21680 Gateway Center Drive

Suite 350

Diamond Bar, CA  91765

 


 
 

Your California Privacy Rights

Zenlayer collects various types of personal information about you during your relationship with Zenlayer as a customer. Under California law, if you are a resident of California, you may make a written request to Zenlayer about how we have shared your information with third parties for their direct marketing purposes. If this law applies to you, you may obtain the categories of personal information shared by us and the names and addresses of all third parties that received personal information for their direct marketing purposes from us during the immediately prior calendar year (e.g., requests made in 2021 will receive information about 2020 sharing activities). To make such a request, please provide enough information for us to determine if this applies to you, attest to the fact that you are a California resident and provide a current California address for our response.

To make such a request (limit one request per year), please send an email to: privacy@zenlayer.com with “California Privacy Rights” as the subject line or mail us a letter to: Zenlayer, Inc., 21680 Gateway Center Drive, Suite 350, Diamond Bar, CA 91765, Attn: California Privacy Rights. You must include your full name, email address, and postal address in your request.

Email Address:

privacy@zenlayer.com

Postal Address:

Zenlayer, Inc.

21680 Gateway Center Drive

Suite 350

Diamond Bar, CA  91765

Attn: Privacy Rights Administrator

Toll-Free:

800-858-7986

 


 
 

California / Delaware Do Not Track Disclosures

Various third parties are developing or have developed signals or other mechanisms for the expression of consumer choice regarding the collection of information about an individual consumer’s online activities over time and across third-party websites or online services (e.g., browser do not track signals). Currently, we do not monitor or take any action with respect to these signals or other mechanisms.


 
 

For Visitors Within the European Economic Area

If you are in the EEA, you should contact us at the contact information below. If you are not satisfied with our resolution of your complaint, you may contact the privacy regulator in your country. Most privacy regulators can be contacted online using the resources provided at https://icdppc.org/participation-in-the-conference/members-online/.

Zenlayer Inc.,

Attn: Legal Department/Data Protection Officer

Address: 21680 Gateway Center Drive, Suite 350, Diamond Bar, CA 91765

Fax: 909-860-9490

Email: privacy@zenlayer.com

If at any time you decide that you no longer desire that we hold, use, correct or supplement any of your Personally Identifiable Information (“PII”), receive information regarding any PII processed in relation to you or you wish to change the manner in which your PII may be used, please let us know by contacting us as set forth above.


 
 

Visitors to the Site Outside of the United States

If you are visiting the Site from a location outside of the U.S., your connection will be through and to servers located in the U.S. All information you receive from the Site will be created on servers located in the U.S., and all information you provide will be maintained on web servers and systems located within the U.S. The data protection laws in the United States may differ from those of the country in which you are located, and your information may be subject to access requests from governments, courts, or law enforcement in the United States according to laws of the United States. By using the Site or providing us with any information, you consent to the transfer to, and processing, usage, sharing and storage of your information in the United States and in other countries, as set forth in this Privacy Policy.


 
 

Updating Personal Information

We prefer to keep your Personal Information accurate and up to date. If you would like to change your contact information, please contact us at privacy@zenlayer.com.

If so, we will make good faith efforts to make requested changes in our then-active databases as soon as reasonably practicable (but we may retain prior information as business records). Please note that it is not always possible to completely remove or delete all of your information from our databases and that residual data may remain on backup media or for other reasons, such as a legitimate business reason.


 
 

Links

For your convenience, the Site may contain links to other websites. Zenlayer is not responsible for the privacy practices, advertising, products, services, or the content of such other websites. None of the links on the Site should be deemed to imply that Zenlayer endorses or has any affiliation with the links.


 
 

Security

Zenlayer is concerned with the security of the data we have collected and utilizes reasonable measures to prevent unauthorized access to that information. These measures include policies, procedures, employee training, physical access and technical elements relating to data access controls. In addition, Zenlayer uses standard security protocols and mechanisms to facilitate the exchange and the transmission of sensitive data, such as credit card details. Zenlayer does not process Personal Information in a way that is incompatible with the purposes for which it has been collected or subsequently authorized by the individual.

In the event that Personal Information is acquired, or is reasonably believed to have been acquired, by an unauthorized person and applicable law requires notification, Zenlayer will notify the affected individual of the breach by email or ticket on the Customer Portal or, if Zenlayer is unable to contact the individual by email or ticket on the Customer Portal, then by regular mail.Notice will be given promptly, consistent with the legitimate needs of law enforcement and any measures necessary for Zenlayer or law enforcement to determine the scope of the breach and to ensure or restore the integrity of the data system. Zenlayer may delay notification if Zenlayer or a law enforcement agency determines that the notification will impede a criminal investigation, and in such case, notification will not be provided unless and until Zenlayer or the agency determines that notification will not compromise the investigation. Zenlayer will cooperate with you in the investigation and/or remediation of any security breach.

Please note that while we incorporate commercially reasonable safeguards to help protect and secure your Personal Information, no data transmission over the Internet, mobile networks, wireless transmission, or electronic storage of information can be guaranteed 100% secure. As a result, Zenlayer cannot guarantee or warrant the security of any information you transmit to or from our Site, and you provide us with your information at your own risk. If you must transmit confidential information to us for any reason, please contact us for instructions for a secure file transfer protocol.


 
 

Questions / Changes in Privacy Policy

If you have questions or concerns with respect to our Privacy Policy, you may contact us at privacy@zenlayer.com. We may elect to change or amend our Privacy Policy; in such event, we will post the policy changes in our Privacy Policy on the Site, and they will become effective on the date posted. If you are concerned about how your personal information is used, please visit our Site often for this and other important announcements and updates.