Last Updated: October 16, 2020
1. Who We Are
This Global Privacy Statement is being provided on behalf of Vantage Data Centers Management Company, LLC (“Vantage Americas”) and Vantage Data Centers Luxembourg Holding Company SARL (“Vantage Europe”) and their respective affiliates, collectively (“Vantage”).
2820 Northwestern Parkway
Santa Clara, California 95051 USA
Attention: Privacy Office
2 rue Peternelchen
Attention: Data Protection Office
2. About this Statement
At Vantage, we are committed to protecting all the personal information that is entrusted to us. We have a Global Privacy Program that guides our handling of personal information and assures that we only use personal information for appropriate business purposes. We are also committed to complying with all applicable privacy and data protection laws.
This Global Privacy Statement explains how Vantage handles personal information about our customers, suppliers, business partners and other individuals who visit our data centers or use our websites, applications, and customer portals (collectively, our “Websites”). This Statement describes the personal information we collect, why we need it, how we use it and what protections are in place to keep it secure. It also explains how you can exercise your privacy rights and contact us if you have any questions or complaints.
3. Personal Information
“Personal information” is any information that we can use to identify, contact or locate you, along with other associated information. We collect the following categories of personal information:
- Contact information, such as your name, email address and phone numbers
- Information about your relationship with Vantage, including your location and communication preferences
- Transaction information, such records of emails and calls and data center access log files
- Online and technical information, such as your IP address, and network activity
Additionally, if you access our secure data centers, we may also collect government-issued identification data, biometric data and video records from our CCTV cameras.
4. How We Collect Your Personal Information
We collect personal information directly from you. For example, you may contact us, visit us, sign up to receive messages from us, or provide your personal information to us so we can do business with you. We may also collect personal information that you post publicly, such as reviews posted on social media.
We collect personal information when you visit our Websites, use our mobile apps or engage with our emails or digital ads. You can learn more by reading about our Cookies.
If you visit our data centers, we will collect personal information from and about you for premises security purposes. For example, we may scan your government-issued identification document, collect biometric data and record your images using CCTV or other video surveillance systems as permitted by law.
5. How We Use Your Personal Information
We only process personal information when we have a legal basis to do so. We use personal information:
- To provide you with the products, services, programs, offers or information requested by you or your employer, and for closely-related purposes such as customer service,
- To provide services to our customers, such as authenticating customer personnel in connection with our data center security procedures, and to ensure the security of our data centers,
- Based on your choices, to deliver commercial communications, marketing, personalized content and interest-based ads to you, and
- For our legitimate business interests and everyday business needs, such as for account management, quality control, website administration, business continuity and disaster recovery, security and fraud prevention, corporate governance, reporting and legal compliance.
Please note that we may also use and disclose information that is not personally identifiable. For example, we may prepare reports that contain aggregated or statistical data, such as reports regarding data center access trends. These reports do not contain any personal information
6. Why We Share Your Personal Information
We may share your personal information with our affiliates, which use your personal information for the purposes described in this Statement. We may also share your personal information with our third-party service providers, which only use your personal information to provide services to us and which are contractually required to protect such personal information.
If you are employed by a Vantage customer, we may share your personal information with that customer, such as when we provide the customer with information about individuals who have accessed the data center.
We may share your personal information with other third parties as permitted by law, such as when we sell or transfer business assets, enforce our contracts, protect our property or the rights, property or safety of others, or as needed for audits, compliance and corporate governance.
We will also disclose personal information when required to do so by law, such as in response to a subpoena, including to law enforcement agencies, regulators and courts in the United States and other countries where we operate.
7. Online Privacy
When you visit our Websites, use our mobile applications or engage with our emails and digital ads, we may collect information by automated means, using technologies such as cookies, pixel tags, browser analysis tools, server logs and web beacons.
In some cases, the information we collect is only used in a non-identifiable way. For example, we use information we collect about all website users to optimize our Websites and to understand website traffic patterns. We do not use this information to profile you or target our ads.
In other cases, we may use the information in an identifiable way. For example, we may authenticate you or your device, deliver personalized content or use the information for analytics, fraud detection and security. We may also use the information for online ad targeting. The section on Cookies provides more information about our online data collection technologies and your choices.
Vantage Websites obtain consent for cookies as required by law. When you visit our Websites, you can “Accept All Cookies” or you can select which types of cookies are permitted. The section on Cookies explains how to manage your preferences and how to disable previously accepted cookies.
As described in the section on Cookies, we have relationships with third-party advertising companies. These third parties may track you, your browser or your device across different websites and applications. If you consent to advertising cookies, we will place cookies or tags on your device when you visit our Website so that they can display targeted advertisements to you on other websites. The use of your data by these companies is subject to their own privacy policies.
Our Websites may also enable you to interact with us and others via social media platforms. We collect information from these platforms as permitted by the sites’ legal terms. We may also display interest-based ads to you when you are using these platforms. The platforms allow us to personalize the ads that we display to you, and they may gain insights about individuals who respond to the ads we serve.
8. International Transfers
Vantage has offices and data centers in the United States, Canada, Switzerland, the United Kingdom and the European Economic Area (EEA). We have affiliates and service providers around the world. Your personal information may be transferred to other countries, which may not have similar privacy or data protection laws. However, we will always protect your information as described in this Global Privacy Statement, no matter where it is stored.
We generally use approved Standard Contractual Clauses to assure that personal information is adequately protected when it is transferred out of the EEA, the UK, or Switzerland to countries without an adequate level of data protection, but we may also make transfers to recipients using other approved data transfer mechanisms. To learn more about our cross-border transfers of personal information, please contact us.
9. Information Security
We use physical, technical, organizational and administrative safeguards to help protect your personal information against unauthorised or unlawful processing of personal information and against damage to, accidental loss or destruction of, your personal information. These security measures include storing sensitive personal information on secure servers, encrypting transfers of personal information to or from our servers, and only granting access to your personal information where necessary.
The terms of our contracts with third-party contractors obligate them to secure the personal information they process for us and to comply with applicable laws.
10. Data Retention
We will retain your personal information for as long as the information is needed for the purposes listed above and for any additional period that may be required or permitted by law, such as for business, legal, accounting, or reporting requirements.
The length of time your personal information is retained depends on the purpose(s) for which it was collected, how it is used, and the requirements to comply with applicable laws. If you would like us to delete your personal information, please contact us. If we do not have a legal basis for retaining your information, we will delete it as required by applicable law.
11. Your Rights and Choices
You have many choices about how we use your personal information.
- In most cases, you can choose what personal information to provide to us. You are not required by law to provide any personal information to Vantage. Our data collection forms indicate what personal information is required for the particular processing activity.
- If you have an online account with Vantage, you can access and update your personal information at any time by logging into the platform. You can also update your communications preferences.
- You can always opt-out of receiving marketing communications from us. Every commercial electronic message we send includes an opt-out link. You can also have your name removed from our email marketing lists any time by sending an email to firstname.lastname@example.org. Please enter your email address and type “Please remove me from all email lists.”
We respect your rights to access, correct and request erasure or restriction of your personal information as required by law. This means:
- You have the right to be informed about our collection, use and disclosure of your personal information.
- You have a right to know if we maintain your personal information. If we do have your personal information, we will provide you with a copy (subject to the rights of others) as required by law. If your personal information is incorrect or incomplete, you have the right to ask us to update it.
- You have the right to object to our processing of your personal information. If we are processing your personal information based on your consent, you may withdraw your consent at any time.
- You may also ask us to delete or restrict your personal information.
Depending on where you reside, you may have additional rights under applicable law. To learn more and to exercise your rights, please contact us. We will need to confirm your identity before we can fulfill most requests, as we need to be sure that your personal information is not disclosed to an unauthorized recipient.
Please understand that these rights are subject to some limitations, such as when we are processing or retaining data to comply with our own legal obligations.
12. Links to Other Websites
This Global Privacy Statement explains how Vantage handles your personal information. Our Websites may have links to other websites and social media platforms. These third-party websites and platforms have their own privacy statements, and we do not have any control over them. Please read the privacy statements provided by these sites before you give them your information.
13. Automated Decision-making
We will not use profiling techniques or make automated-decisions about you that may significantly affect you, unless (1) the decision is necessary as part of a contract that we have with you, (2) we have your explicit consent, or (3) we are required by law to use the technology.
14. Vantage as a Data Processor
In some cases, Vantage receives personal information from its customers about the individuals that they authorize to access their data center assets. In this situation, Vantage acts as a data processor for the customer. We treat this information as confidential information of the customer and only use and disclose it as needed to provide the services to the customer.
15. Vantage Employees and Job Applicants
If you are a prospective, current, or former Vantage employee, your personal information is used for customary human resources purpose. Please contact us for more information about our HR Privacy Program and to receive a copy of the appropriate privacy notice.
16. Children’s Data
Vantage’s services and Websites are not directed to children, and we do not knowingly collect information from children under 18. If you believe that we are processing a child’s information inappropriately, please contact us.
17. Changes to the Global Privacy Statement
We may update this Global Privacy Statement from time to time. We will post an alert online if the changes are material, and we will use good faith efforts to post these changes at least 30 days before they come into effect. If the changes will materially affect the way we use personal information that we have already collected, we will notify you.
If you have questions or comments about our privacy practices, or if you would like help exercising your privacy rights, please contact us.
Residents of the US, Canada or other countries, please contact the Vantage Privacy Office:
2820 Northwestern Parkway
Santa Clara, California 95051 USA
Attention: Privacy Office
Residents of the European Economic Area, Switzerland, or the United Kingdom, please contact the Vantage Data Protection Office:
2 rue Peternelchen
Attention: Data Protection Office
If you believe that we have processed your personal information in violation of this Global Privacy Statement or applicable law, you may file a complaint.
- If you are a resident of the European Economic Area, Switzerland or the United Kingdom, please contact the Vantage Data Protection Office by email to email@example.com. You may also file a complaint directly with the supervisory authority in your country.
- Residents of other countries should contact the Vantage Privacy Office at firstname.lastname@example.org.
When you visit our Websites, use our mobile apps, engage with our online ads or emails. we collect information, using technologies such as cookies, pixel tags (also called web beacons), browser analysis tools, and server logs. Each of these technologies is explained below.
The data we collect with cookies and other tools is used for many different purposes.
- Necessary cookies and tags are the essential cookies used by Vantage to make our Websites and apps work. They enable core functions, such as authentication, security, network management, and accessibility. You may be able to disable these by changing your browser settings, but this may affect how the Websites function.
- Analytics and performance cookies and tags are used by us and our service providers to manage our Websites. This may include collecting analytics cookies about visitors to our Website and collecting information about Website usage. We use the information to compile reports and to help us improve the Website. These cookies help us gather data to optimize our Websites’ performance. We do not use the data collected by these cookies for targeted marketing.
- Marketing cookies are used to enable social sharing and to deliver interest-based ads to you online.
- Advertising cookies and tags are used by us, our service providers, and third parties to personalize the ads delivered to you on our site and on other sites. These cookies collect data about your online activity and allow ads to be displayed that may be of interest to you. These cookies also record which ads you have seen and whether you engaged with the ad. These cookies help make sure that the ads you see are relevant and not repetitive.
While we do not give any personally information to the third-party advertising companies, we may place cookies and tags for them when you visit a Vantage Website. This allows these third parties to collect personal information from you using these technologies on our Websites. The information they collect is subject to their own privacy policies.
Your Cookie Choices
- You can manage the non-essential cookies placed by and for Vantage using the cookie management tool that appears in our cookie banner or by clicking on the icon in the lower left hand-corner of our Website.. Vantage Europe’s Websites only place non-essential cookies if you explicitly except them. Vantage America’s Websites may place essential and analytics cookies, but they only place marketing, personalization and advertising cookies if you explicitly accept them. You can accept or reject cookies when you first visit the Website or at any time simply by adjusting the settings in the control platform.
- You can also manage cookies and delete cookies from Vantage and companies using your browser settings. Browsers such as Chrome, Internet Explorer, Firefox and Safari give you the ability to accept, reject or delete cookies. Visit the “help center” for your browser to learn more. Please note that your browser settings are not used to manage Flash or Silverlight cookies. To manage Adobe Flash Cookies, visit the Flash Player help page. To manage Microsoft Silverlight Cookies, visit the Silverlight section of Microsoft’s privacy statement.
- You can also take advantage of industry programs that allow you to control the way companies advertise to you.
- The Network Advertising Initiative (NAI) manages an opt-out program for many third-party advertising companies. You can opt out of being targeted by NAI members by visiting https://www.networkadvertising.org/consumer/opt_out.asp.
- On some Websites, you may see an AdChoices icon, which may appear on certain targeted ads. You may click on this AdChoices icon to learn more information about the collection and use of your information or to opt-out of such collection in the future. To learn more about the Digital Advertising Alliance Consumer Choice tool, please visit http://optout.aboutads.info.
- Additional choices are offered by:
Adobe Marketing Cloud: If you would like more information on how to remove yourself from the tracking and reporting functions performed for this Website by Adobe Marketing Cloud, please visit the Opt-Out page at http://www.adobe.com/privacy/marketing-cloud.html.
Google: For information on how Google Analytics uses data please visit “How Google uses data when you use our partners’ sites or apps”, located at https://www.google.com/policies/privacy/partners.
In most cases, the choices you make are linked to your browser. If you use different browsers or different devices, you will need to set your preferences on each one. Even if you opt-out, you may still receive ads that are not customized for you.
Although our Websites currently do not have a mechanism to recognize the various web browser Do Not Track signals, we do offer our customers choices to manage their cookie preferences as described in the previous section. To learn more about browser tracking signals and Do Not Track please visit https://www.allaboutdnt.com.
Residents of some states and countries have additional privacy rights. Please contact us if you would like to learn more.
Social Media and other Platforms
Our Websites may enable you to interact with us and others via social media platforms, such as Facebook, Twitter, and LinkedIn. This functionality is enabled using social media cookies and tags. For example, some Vantage Websites allow you to sign in using social media platform credentials. Please read the privacy statements provided by your social media platforms to understand how they use your information and to manage your choices.
We may display interest-based ads to you when you are using platforms such as Facebook and Google. These platforms allow us to personalize the ads that we display to you. To enable delivery of these ads, we convert your email address into a unique number. The platforms also convert their user emails into unique numbers using the same process. This allows the records to be matched without any exchange of data elements that can identify you on their own. The platforms perform the matching as a service provider to Vantage, and they do not retain or use the file that we send them for their own purposes. This process allows the platform to deliver our ads to our customers on the platform. The platforms may gain insights about individuals who respond to the ads we serve.
Other Types of Online Data Collection
Our server logs record information about users to our Websites. We may use these logs for internal purposes, such as Website administration, optimization and security. We may also use the data for fraud-protection, personalization and ad advertising
We collect device identifiers and other device-related information, including your device’s advertising ID if available. This information is used to identify the device and authenticate you. We may also use device-related information to associate you with different devices that you may use, including for fraud-protection purposes and to better target advertising. In many cases, you can reset your device’s advertising ID. Both Android and iOS devices enable you to reset your device identifier under the “settings” menu.
A Guide to Cookies and Other Technologies
Cookies are small text files that websites send to your computer or other Internet-connected device to uniquely identify your browser or to store information or settings in your browser. Cookies allow us to recognize you when you return. They also help us provide a customized experience and can enable us to detect certain kinds of fraud.
- First-party cookies are those cookies that are placed by Vantage. These cookies are used by Vantage and include all the essential cookies.
- Third-party cookies are placed by another company, including service providers, social media cookies and third-party advertising companies. Cookies placed by third parties can be read by these third parties when you visit other sites in the advertising network, allowing a profile of your online behavior to be created so that the third-party can deliver targeted ads from all its customers.
Flash Cookies and Silverlight Cookies
A Flash Cookie (also known as a Local Stored Object) is a small data file placed on a computer using Adobe Flash technology. A Silverlight Cookie is a small data file placed on a computer using Microsoft’s Silverlight technology. Flash and Silverlight are applications that allow delivery of dynamic content, such as video clips and animation. These cookies are used to personalize and enhance your online experience, deliver dynamic content, and for security purposes. They differ from “regular cookies” in that they are not managed using your browser settings. See Your Cookie Choices above for how to manage these types of cookies.
Pixel Tags and Web Beacons
Pixel tags (also called web beacons) are tiny graphic images and small blocks of code placed on website pages, ads, or in emails that allow us to determine whether you have performed a specific action. When you access the pages or you open an email, the tag lets us know you have accessed the web page or opened the email. These tools allow us to measure response to our communications and improve our web pages and promotions.
Server logs record activities on our Websites. Other types of logs collect similar information from our apps. These logs record information about the device you use to access our Website, your operating system type, browser type, domain, and other system settings, as well as the language your system uses and the country and time zone where your device is located. Our logs also record the IP address of the device you use to connect to the Internet. An IP address is a unique identifier that devices require to identify and communicate with each other on the Internet. We may also collect information about the Website you were visiting before you came to Vantage and the Website you visit after you leave our site.
21. Information for California Residents
The California Consumer Privacy Act provides California consumers with specific privacy rights. As a business-to-business service, Vantage does not collect personal information about California consumers. California residents who have questions about how Vantage uses their commercial or professional data may contact us to learn mo