A. Introduction

  1. The privacy of our website visitors is very important to us, and we are committed to safeguarding it. This policy explains what we will do with your personal information.
  2. Consenting to our use of cookies in accordance with the terms of this policy when you first visit our website permits us to use cookies every time you visit our website.

B. Privacy statement

This statement is issued on behalf of Peering Partner and when we use Peering Partner, “we”, “us” or “our” in this statement we are referring to the relevant company, Peering Partner, who is responsible for processing your data. Peering Partner is the controller and is responsible for this website.

This privacy statement describes why and how we collect and use personal data and provides information about individuals’ rights. It applies to personal data provided to us, both by individuals themselves or by others. We may use personal data provided to us for any of the purposes described in this privacy statement or as otherwise stated at the point of collection.

Personal data is any information relating to an identified or identifiable living person. Peering Partner processes personal data for numerous purposes, and the means of collection, lawful basis of processing, use, disclosure, and retention periods for each purpose may differ.

When collecting and using personal data, our policy is to be transparent about why and how we process personal data. To find out more about our specific processing activities, please go to the relevant sections of this statement.

C. Collecting personal information

The following types of personal information may be collected, stored, and used:

  1. information about your computer including your IP address, geographical location, browser type, and version, and operating system;
  2. information about your visits to and use of this website including the referral source, length of visit, page views, and website navigation paths;
  3. information, such as your email address, that you enter when you register with our website;
  4. information that you enter when you create a profile on our website—for example, your name, profile pictures, gender, birthday, relationship status, interests and hobbies, educational details, and employment details;
  5. information, such as your name and email address, that you enter in order to set up subscriptions to our emails and/or newsletters;
  6. information that you enter while using the services on our website;
  7. information that is generated while using our website, including when, how often, and under what circumstances you use it;
  8. information relating to anything you purchase, services you use, or transactions you make through our website, which includes your name, address, telephone number, email address, and credit card details;
  9. information that you post to our website with the intention of publishing it on the internet, which includes your username, profile pictures, and the content of your posts;
  10. information contained in any communications that you send to us by email or through our website, including its communication content and metadata;
  11. any other personal information that you send to us.

Before you disclose to us the personal information of another person, you must obtain that person’s consent to both the disclosure and the processing of that personal information in accordance with this policy

D. Collection of personal data: Business contacts

Peering Partner processes personal data about contacts of businesses (existing and potential customers) using a customer relationship management system (the “CRM”).

The collection of personal data about business contacts and the addition of that personal data to the CRM is initiated by a Peering Partner user and will include name, employer name, contact title, phone, email and other business contact details.  In addition, the CRM may collect data from Peering Partner email (sender name, recipient name, date and time) and calendar (organizer name, participant name, date and time of event) systems concerning interactions between Peering Partner users and contacts or third parties.

Use of personal data

Personal data relating to business contacts will be visible to and used by Peering Partner users to learn more about an account, customer or opportunity they have an interest in, and may be used for the following purposes:

  • Administering, managing and developing our businesses and services.
  • Providing information about us and our range of services.
  • Making contact information available to Peering Partner users.
  • Identifying customers/contacts with similar needs.
  • Describing the nature of a contact’s relationship with Peering Partner.
  • Performing analytics, including producing metrics for Peering Partner management, such as on trends, relationship maps, sales intelligence, and progress against business goals.

In addition, Peering Partner uses an algorithm to evaluate the strength of interactions between Peering Partner and business contact.  This ranking is primarily based on interaction frequency, duration, time since last interaction, and response time.

Peering Partner does not sell or otherwise release personal data contained in the CRM to third parties for the purpose of allowing them to market their products and services without consent from individuals to do so.

Data retention

Personal data will be retained on the CRM for as long as it is necessary for the purposes set out above (e.g. for as long as we have, or need to keep a record of, a relationship with a business contact). We may also retain your data to ensure that you are no longer contacted if you wish to opt-out, or to record that your email address is no longer in operation. 

E. Collection of personal data: Corporate Customers

Our policy is to collect only the personal data necessary for agreed purposes and we ask representatives of our corporate customers to only share personal data where it is strictly needed for those purposes.

Where we need to process personal data to perform a service for a corporate customer, such as to contact them, we ask our customers to provide the necessary information to the data subjects regarding its use. Our corporate customers may use relevant sections of this privacy statement or refer data subjects to this privacy statement if they consider it appropriate to do so.

Generally, we collect personal data directly from our corporate customers. 

Use of personal data

We use personal data for the following purposes:

  1. Providing services
  2. We provide a range of services (go to https://www.peeringpartner.com/ for information on our range of services).  All of our services require us to process a limited set of personal data in order to perform the service and to provide deliverables.  For example, we will require the name and contact details of someone to send our invoices to, for arranging a site visit to install equipment, or to call back concerning the resolution of a system fault.
  3. Administering, managing and developing our businesses and services
  4. We process personal data in order to run our business, including:
  5. – managing our relationship with customers;
  6. – developing our businesses and services (such as identifying customer needs and improvements in service delivery);
  7. – maintaining and using IT systems;
  8. – hosting or facilitating the hosting of events; and
  9. – administering and managing our website and systems and applications.
  10. Security, quality and risk management activities.
  11. We have security measures in place to protect our and our customers’ information (including personal data), which involve detecting, investigating and resolving security threats.  Personal data may be processed as part of the security monitoring that we undertake; for example, automated scans to identify harmful emails.  We monitor the services provided to customers for quality purposes, which may involve processing personal data stored on the relevant customer file.  We have policies and procedures in place to monitor the quality of our services and manage risks in relation to customer engagements.  We collect and hold personal data as part of our customer engagement and acceptance procedures.  As part of those procedures we carry out searches using publicly available sources (such as internet searches and sanctions lists) to identify politically exposed persons and heightened risk individuals and organisations and check that there are no issues that would prevent us from working with a particular customer (such as sanctions, criminal convictions (including in respect of company directors), conduct or other reputational issues).  
  12. Providing our customers with information about us and our range of services.
  13. Unless we are asked not to, we use customer business contact details to provide information that we think will be of interest to them about our business and our services, such as, industry updates and technology insights, other services that may be relevant and invites to events.  Where we do this we principally rely on legitimate interest as the basis for processing after carrying out a balancing exercise to ensure that our processing is not unreasonably intrusive.
  14. Complying with any requirement of law, regulation or a professional body of which we are a member.
  15. As with any provider of communications services, we are subject to legal, regulatory and professional obligations. We need to keep certain records to demonstrate that our services are provided in compliance with those obligations and those records may contain personal data.

We are always looking for ways to help our customers and improve the relevancy and impact of our business and services.  Where agreed with our customers, we may use information that we receive in the course of providing services for other lawful purposes, including analysis to better understand a particular issue, industry or sector, provide insights back to our customers, to improve our business, service delivery and offerings and to develop new Peering Partner offerings. To the extent that the information we receive in the course of providing services contains personal data, we will take reasonable steps using commercially available methods to anonymize the data prior to using the information for these purposes. 

F. Individuals whose personal data we may obtain incidental to providing our services to a business

Collection of personal data

Our policy is to collect only the personal data necessary for agreed purposes and we ask our customers only to share personal data where it is strictly needed for those purposes.

Where we need to process personal data to provide our services, we ask our customers to provide the necessary information to the data subjects concerned regarding its use, such as to explain that we are a supplier.  

We collect and use contact details for our customers in order to manage and maintain our relationship with those individuals.  Please see the Business Contacts section of this privacy statement for more information about our processing of this type of data.

Generally, we do not collect personal data of any of our customers’ customers unless it is necessary and for agreed purposes, such as contacting them to make an appointment to visit a site, not under the control of our customer.

Where we may obtain personal data incidentally and not for agreed purposes is when fault finding on a network that we are managing for a customer or when co-operating with an organization that has legal authority to receive our co-operation for their purposes.  

Use of personal data

We use personal data for the following purposes:

  • Providing communications services;
    We provide a range of services, including communications services. Some of our services require us to fault-find and resolve a technical situation for a customer, during which we may incidentally be exposed to personal data. In this case, we expect our customers to provide the necessary information to the data subjects concerned regarding its use.
  • Administering, managing and developing our businesses and services;
  • Security, quality and risk management activities;   
  • Complying with any requirement of law, regulation or a professional body of which we are a member;
    As with any provider of communications services, we are subject to legal, regulatory and professional obligations.  We need to keep certain records to demonstrate that our services are provided in compliance with those obligations and those records may contain personal data. We may also need to intercept communications traffic in order to comply with an order from a lawfully authorized organization. 

Data retention

We retain the personal data processed by us for as long as is considered necessary for the purpose for which it was collected (including as required by applicable law or regulation).   

For incidentally gathered personal data, we have no baseline retention period and act to remove it as soon as we become aware.

G. Others who get in touch with us

We collect personal data when an individual gets in touch with us with a question, complaint, comment or feedback (such as name, contact details, and contents of the communication). In these cases, the individual is in control of the personal data shared with us and we will only use the data for the purpose of responding to the communication.

Suppliers (including subcontractors and individuals associated with our suppliers and subcontractors)

Collection of personal data

We collect and process personal data about our suppliers (including subcontractors and individuals associated with our suppliers and subcontractors) in order to manage our relationship with them, to receive services from them and, where relevant, to provide services to our clients.

Use of personal data

We use personal data for the following purposes:

  • Receiving services:

We process personal data in relation to our suppliers and their staff as necessary to receive the services. For example, where a supplier is providing us with secure off-site data storage services, we will process personal data about those individuals that are providing services to us.

  • Providing services to our corporate customers:

Where a supplier is helping us to deliver services to our customers, we process personal data about the individuals involved in providing the services in order to administer and manage our relationship with the supplier and the relevant individuals and to provide such services to our customers (for example, where our supplier is providing engineers to go to a customer site to install equipment).

  • Administering, managing and developing our businesses and services:

We process personal data in order to run our business, including:

– managing our relationship with suppliers;

– developing our businesses and services (such as identifying customer needs and improvements in service delivery);

– maintaining and using IT systems;

– hosting or facilitating the hosting of events; and

– administering and managing our website and systems and applications.

  • Security, quality and risk management activities:

We have security measures in place to protect our and our customers’ information (including personal data), which involve detecting, investigating and resolving security threats. Personal data may be processed as part of the security monitoring that we undertake; for example, automated scans to identify harmful emails. We have policies and procedures in place to monitor the quality of our services and manage risks in relation to our suppliers.  We collect and hold personal data as part of our procurement procedures. We monitor the services provided for quality purposes, which may involve processing personal data.

  • Providing information about us and our range of services:

Unless we are asked not to, we use business contact details to supply information that we think will be of interest about us and our needs.

  • Complying with any requirement of law, regulation or a professional body of which we  are a member:

As with any provider of communications services, we are subject to legal, regulatory and professional obligations.  We need to keep certain records to demonstrate that our services are provided in compliance with those obligations and those records may contain personal data.

Data retention

We retain the personal data processed by us for as long as is considered necessary for the purpose for which it was collected (including as required by applicable law or regulation).   

Personal data may be held for longer periods where extended retention periods are required by law or regulation and in order to establish, exercise or defend our legal rights.

 

H. Visitors to our website

Collection of personal data

Visitors to our website (https://www.peeringpartner.com/) are in control of the personal data shared with us except where, in common with other website operators, cookies are active.  We may capture limited personal data automatically via the use of these cookies.  Please see the section on cookies below for more information.  We also generate site usage statistics which is not personally identifiable information. Please see the section on site statistics below for more information.

We collect personal data, such as name, job title, company address, email address, and telephone number, from website visitors; for example when an individual subscribes to updates from us.

Visitors are also able to send an email to us through the website. Their messages will contain the user’s screen name and email address, as well as any additional information the user may wish to include in the message.    

Visitors are also able to contact us via telephone. Calls received via telephone will be monitored or recorded for record-keeping, training and quality assurance purposes. 

Important: Please do not provide sensitive information (such as race or ethnic origin; political opinions; religious or philosophical beliefs; trade union membership; physical or mental health; genetic data; biometric data; sexual life or sexual orientation; and, criminal records) to us when using our website; if you choose to provide sensitive information to us for any reason, the act of doing so constitutes your explicit consent for us to collect and use that information in the ways described in this privacy statement or as described at the point where you choose to disclose this information.

I. Cookies

In addition to the information gathered as described above, there is a technology called “cookies” which can be used to provide you with tailored information from a website. A cookie is an element of data that a website can send to your browser, which may then store it on your system. We make use of cookies on the website so that we can better serve you when you return to the website. You can set your browser to notify you when you receive a cookie, giving you the chance to decide whether to accept it. However, please note that disabling cookies may prevent you from taking advantage of certain features on the website.

J. Site Statistics

In addition to the information you knowingly provide, we keep track of the domains and IP addresses from which people visit us. We also collect site usage statistics such as Web browser types and page requests. This data is not personally identifiable and is used to more efficiently operate our business, prepare for network load demands, promote our services and administer the website. We may share with our affiliates aggregated statistical information about the use of the website.

Use of personal data

When a visitor provides personal data to us, we will use it for the purposes for which it was provided to us as stated at the point of collection (or as obvious from the context of the collection).  Typically, personal data is collected to:

  • register for certain areas of the site;
  • subscribe to updates;  
  • enquire for further information;
  • distribute requested reference materials;
  • submit curriculum vitae;
  • monitor and enforce compliance with our terms and conditions for use of our website;
  • administer and manage our website, including confirming and authenticating identity and preventing unauthorized access to restricted areas, paid-for content or other services limited to registered users; and
  • aggregate data for website analytics and improvements.

Unless we are asked not to, we may also use your data to contact you with information about our business, services and events, and other information which may be of interest to you.  Should visitors subsequently choose to unsubscribe from mailing lists or any registrations, we will provide instructions on the appropriate webpage, in our communication to the individual, or the individual may contact us by email to info@peeringpartner.com.

Our websites do not collect or compile personal data for the dissemination or sale to outside parties for consumer marketing purposes or host mailings on behalf of third parties.  If there is an instance where such information may be shared with a party that is not a group company, the visitor will be asked for their consent beforehand.

Data retention

Personal data collected via our websites will be retained by us for as long as it is necessary (e.g. for as long as we have a relationship with the relevant individual).