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PRIVACY POLICY

TELEHOUSE INTERNATIONAL CORPORATION OF AMERICA

PRIVACY POLICY

This Privacy Policy explains how we use the personal information that Telehouse International Corporation of America collects or generates both in relation to our website www.telehouse.com and our products and services.

The list below sets out what is covered in this Privacy Policy.

  1. BACKGROUND
  2. THE PRODUCTS AND SERVICES WE PROVIDE 
  3. THE TYPES OF PERSONAL DATA WE COLLECT 
  4. HOW WE USE YOUR INFORMATION
  5. DISCLOSURE OF YOUR INFORMATION TO THIRD PARTIES
  6. INTERNATIONAL TRANSFERS OF PERSONAL DATA
  7. HOW WE SAFEGUARD YOUR INFORMATION
  8. HOW LONG WE KEEP YOUR PERSONAL DATA
  9. YOUR RIGHTS
  10. DESIGNATED REPRESENTATIVE
  11. QUESTIONS AND CONCERNS 

 

  1. BACKGROUND

1.1 Telehouse International Corporation of America with its registered office at The Teleport, 7 Teleport Drive, Staten Island, NY 10311 collects and uses certain Personal Data (as defined below). Telehouse is responsible for ensuring that it uses Personal Data in compliance with data protection laws.  For the purposes of data protection laws, Telehouse acts as a “data controller” with respect to certain Personal Data and may receive such information about you.
1.2 At Telehouse, we respect the privacy of our clients and we are committed to keeping all your Personal Data secure. This Privacy Policy governs the handling of Personal Data by Telehouse in the course of carrying on commercial activities.

1.3 We use the following definitions in this Privacy Policy:

“we”, “our” or “us” means Telehouse.
“Personal Data” means any data which relates to a living individual who can be identified from that data or from that data and other information which is in the possession of, or is likely to come into the possession of, Telehouse (or its representatives or service providers). In addition to factual information, it includes any expression of opinion about an individual and any indication of the intentions of Telehouse or any other person in respect of an individual.

  1. THE PRODUCTS AND SERVICES WE PROVIDE

2.1 This Privacy Policy concerns the following categories of information that we collect about you when providing the following products and services:
(A) Information we receive through our website (“Telehouse Website“);
(B) Information we receive through our products (“Telehouse Products“); and
(C) Information we receive through our co-location, support, cloud-based, system integration and network services (“Telehouse Services“).

  1. THE TYPES OF PERSONAL DATA WE COLLECT 

3.1 Many of the services offered by Telehouse require us to obtain Personal Data about you in order to perform the Telehouse Services we have been engaged to provide. In relation to each of the services described in paragraph 2.1 above, we will collect and process the following Personal Data about you:

  • Information that you provide to Telehouse. This includes information about you that you provide to us (whether by filling in forms on the Telehouse Website (including our “Contact Us” form), during telephone calls with us, or otherwise). The nature of the services you are requesting (in the case of customers) will determine the kind of Personal Data we might ask for, though such information may include (by way of a non-exhaustive list):

– Basic Personal Data (such as first name; family name; position in the company; company name; business email address; business phone number; business address; city; zip code; country).

– Our websites are not directed at children. We do not knowingly collect Personal Data from children under the age of 16. If you are a parent or guardian and believe your child has provided us with Personal Data without your consent, please contact us by GDPR@telehouse.com, and we will take steps to delete such Personal Data from our systems.

  • Information that we collect or generate about you. This includes (by way of non-exhaustive list):

For customers and suppliers:

Information collected during the course of maintaining the security of our sites (including CCTV images).

For customers only:

  • A file with your contact history to be used for inquiry purposes so that we may ensure that you are satisfied with the services which we have provided to you;
  • Through our cloud security services, traffic and security reports that include information on the internet usage of the organization’s computer users (e.g. what websites were visited by each user, any documents downloaded, security incidents, prevention measures taken by the gateway, etc.); and
  • Activity data relating to the use of protected documents, such as altering a document’s permissions and information regarding the individual that performed the activity.

 

Information we obtain from other sources

  • Cookies

– When you visit the Telehouse Website, cookies are used to collect technical information about the services that you use, and how you use them.

– For more information on the cookies used by Telehouse please see our Cookie Policy

 

  • Anonymized data

– In addition to the categories of Personal Data described above, Telehouse will also use other information and data that is not personal data., such other information and data is not used by reference to a specific individual.

 

  • List brokers

– We receive personal data from list brokers from time to time in order to build our contact database.

 

  •  Industry Events

– When we sponsor industry events such as trade shows, delegates are issued with badges with a barcode, which we can scan to collect their contact details when they visit the Telehouse stand at the event. The event organizers collect the data from our scanners and provide it to us in the form of an Excel document.  This data is then uploaded to our marketing automation system.

  1. HOW WE USE YOUR INFORMATION

4.1 Your Personal Data may be stored and processed by us in the following ways and for the following purposes:

  • To communicate with you in order to provide you with services or information about Telehouse and Telehouse Products (including to notify you about changes to existing Telehouse Products and Services that you purchase from us);
  • To set up customers to use Telehouse Products;
  • For the management and administration of our business;
  • For ongoing review and improvement of the information provided on the Telehouse Website to ensure they are user-friendly and to prevent any potential disruptions or cyber attacks;
  • To allow you to use and access the functionality provided by the Telehouse Products for the purposes of assessing whether Telehouse Products are suitable for your purposes;
  • To assess your application for Telehouse Products, where applicable;
  • To conduct analysis required to detect malicious data and understand how this may affect your IT system;
  • For statistical monitoring and analysis of current attacks on devices and systems and for the on-going adaptation of the solutions provided to secure devices and systems against current attacks;
  • To understand feedback on Telehouse Products and to help provide more information on the use of those products and services quickly and easily;
  • For in-depth threat analysis;
  • To understand your needs and interests;
  • In order to comply with and in order to assess compliance with applicable laws, rules and regulations, and internal policies and procedures; or
  • For the administration and maintenance of databases storing Personal Data.

 

4.2 However we use Personal Data we make sure that the usage complies with the law and the law allows us and requires us to use Personal Data for a variety of reasons. These include:

  • We need to do so in order to perform our contractual obligations with our customers and suppliers (as applicable);
  • We have obtained your consent;
  • We have legal and regulatory obligations that we have to discharge;
  • We may need to do so in order to establish, exercise or defend our legal rights or for the purpose of legal proceedings;
  • The use of your Personal Data as described is necessary for our legitimate business interests, such as:
    • Allowing us to effectively and efficiently manage and administer the operation of our business;
    • Maintaining compliance with internal policies and procedures;
    • Monitoring the use of our copyrighted materials;
    • Enabling quick and easy access to information on Telehouse Products;
    • Offering optimal, up-to-date security solutions for mobile devices and IT systems; and
    • Obtaining further knowledge of current threats to network security in order to update our security solutions and provide these to the market.

4.3 We will take steps to ensure that the Personal Data is accessed only by employees of Telehouse that have a need to do so for the purposes described in this Privacy Policy.

  1. DISCLOSURE OF YOUR INFORMATION TO THIRD PARTIES 

5.1 We may also share your Personal Data outside of the Telehouse group for the following limited purposes:

  • With third-party agents and contractors for the purposes of providing services to us (for example, Telehouse’s accountants, professional advisors, IT and communications providers and debt collectors). These third parties will be subject to appropriate data protection obligations and they will only use your Personal Data as described in this Privacy Policy;
  • To the extent required by law, for example, if we are under a duty to disclose your Personal Data in order to comply with any legal obligation (including, without limitation, in order to comply with tax reporting requirements and disclosures to regulators), or to establish, exercise or defend its legal rights;
  • If we sell our business or assets, in which case we may need to disclose your Personal Data to the prospective buyer for due diligence purposes; and
  • If we are acquired by a third party, in which case the Personal Data held by us about you will be disclosed to the third party buyer.
  1. INTERNATIONAL TRANSFERS OF PERSONAL DATA

6.1 Telehouse is a global business. Our suppliers, customers and our operations are spread around the world. As a result we collect and transfer Personal Data on a global basis. That means (except where the terms of the contract between us expressly prohibit us from doing so), that we may transfer your Personal Data to locations outside of your country.
6.2 Where we transfer your Personal Data to another country outside the US, we will ensure that it is protected and transferred in a manner consistent with legal requirements. In relation to data being transferred outside of America, for example, this may be done in one of the following ways:

  • The country that we send the data to might be approved by the American Commission as offering an adequate level of protection for Personal Data (Israel is an approved country);
  • The recipient might have signed up to a contract based on “model contractual clauses” approved by the American Commission, obliging them to protect your Personal Data;
  • Where the recipient is located in the US, it might be a certified member of the EU-US Privacy Shield scheme; or
  • In other circumstances, the law may permit us to otherwise transfer your Personal Data outside America.

6.3 You can obtain more details of the protection given to your Personal Data when it is transferred outside America (including a copy of the standard data protection clauses which we have entered into with recipients of your Personal Data) by contacting us as described in paragraph 11 below.

  1. HOW WE SAFEGUARD YOUR INFORMATION

7.1 We have extensive controls in place to maintain the security of our information and information systems. Client files are protected with safeguards according to the sensitivity of the relevant information. Appropriate controls (such as restricted access) are placed on our computer systems. Physical access to areas where Personal Data is gathered, processed or stored is limited to authorized employees.
7.2 As a condition of employment, Telehouse employees are required to follow all applicable laws and regulations, including in relation to data protection law. Access to sensitive Personal Data is limited to those employees who need to it to perform their roles. Unauthorized use or disclosure of confidential client information by a Telehouse employee is prohibited and may result in disciplinary measures.
7.3 When you contact a Telehouse employee about your file, you may be asked for some Personal Data. This type of safeguard is designed to ensure that only you, or someone authorized by you, has access to your file.

  1. HOW LONG WE KEEP YOUR PERSONAL DATA 

8.1 How long we will hold your Personal Data for will vary and will be determined by the following criteria:

  • The purpose for which we are using it – Telehouse will need to keep the data for as long as is necessary for that purpose; and
  • Legal obligations – laws or regulation may set a minimum period for which we have to keep your Personal Data.
  1. YOUR RIGHTS 

9.1 In all the above cases in which we collect, use or store your Personal Data, you may have the following rights and, in most cases, you can exercise them free of charge. These rights include:

  • The right to obtain information regarding the processing of your Personal Data and access to the Personal Data which we hold about you;
  • The right to withdraw your consent to the processing of your Personal Data at any time. Please note, however, that we may still be entitled to process your Personal Data if we have another legitimate reason for doing so. For example, we may need to retain Personal Data to comply with a legal obligation;
  • In some circumstances, the right to receive some Personal Data in a structured, commonly used and machine-readable format and/or request that we transmit those data to a third party where this is technically feasible. Please note that this right only applies to Personal Data, which you have provided directly to Telehouse;
  • The right to request that we rectify your Personal Data if it is inaccurate or incomplete;
  • The right to request that we erase your Personal Data in certain circumstances. Please note that there may be circumstances where you ask us to erase your Personal Data but we are legally entitled to retain it;
  • The right to object to, or request that we restrict, our processing of your Personal Data in certain circumstances. Again, there may be circumstances where you object to, or ask us to restrict, our processing of your Personal Data but we are legally entitled to refuse that request;
  • The right to lodge a complaint with the relevant data protection regulator if you think that any of your rights have been infringed by us; and
  • The right to deny the processing of personal data

9.2 You can exercise your rights by contacting us using the details listed in paragraph 11 below.

  1. DESIGNATED REPRESENTATIVE

10.1 Telehouse’s registered office may be contacted using the following contact information:
Address:  Telehouse Corporation of America, The Teleport, 7 Teleport Drive, Staten Island, NY 10311

Email Address: marketing@telehouse.com

 

10.2 Telehouse’s designated representative in the US may be contacted using the following information:

Address: Telehouse International Corporation of America, The Teleport, 7 Teleport Drive, Staten Island, NY 10311

Email Address: GDPR@telehouse.com

  1. QUESTIONS AND CONCERNS 

11.1 If you have any questions or concerns about Telehouse’s handling of your Personal Data, or about this Policy, please contact us using the following information:
Address:  Telehouse International Corporation of America, The Teleport, 7 Teleport Drive, Staten Island, NY 10311

Email Address: GDPR@telehouse.com

  • Responses will be sent within 30 days of receipt
  • If a time extension is needed for a response, the time extension request will be provided within thirty days of the receipt of the initial request.
  • The extension may not extend beyond two (2) additional months.

We are usually able to resolve privacy questions or concerns promptly and effectively. If you are not satisfied with the response you receive from our Marketing Director, you may escalate concerns to the applicable privacy regulator in your jurisdiction. Upon request, Telehouse’s Marketing Director will provide you with the contact information for that regulator.