RagingWire Data Centers Privacy Shield Policy

This Privacy Shield Policy (“Policy”) describes how RagingWire and its subsidiaries and affiliates in the United States (“US”) (collectively, “RagingWire,” “we,” or “us”) collect, use, and disclose certain personally identifiable information that we receive in the US from the European Economic Area (“EEA”) (“Personal Data”). This Policy supplements our Privacy Policy (the “Privacy Policy”).  Unless specifically defined in this Policy, the terms in this Policy have the same meaning as the Privacy Policy.

RagingWire recognizes that the EEA has established strict protections regarding the handling of Personal Data, including requirements to provide adequate protection for Personal Data transferred outside of the EEA. To provide adequate protection for certain Personal Data about customers, vendors, affiliates, etc., RagingWire has elected to self-certify to the EU-US Privacy Shield Framework administered by the US Department of Commerce (“Privacy Shield”). RagingWire adheres to the Privacy Shield Principles of Notice; Choice; Accountability for Onward Transfer; Security; Data Integrity and Purpose Limitation; Access; and Recourse, Enforcement, and Liability.

RagingWire complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union to the United States.  RagingWire has certified to the Department of Commerce that it adheres to the Privacy Shield Principles.  If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.  To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.

For purposes of enforcing compliance with the Privacy Shield, RagingWire is subject to the investigatory and enforcement authority of the US Federal Trade Commission. For more information about the Privacy Shield, see the US Department of Commerce’s Privacy Shield website located at: https://www.privacyshield.gov. To review RagingWire’s representation on the Privacy Shield list, see the US Department of Commerce’s Privacy Shield self-certification list located at: https://www.privacyshield.gov/list.

Please note we often process information at the direction, and subject to the control, of our customers and thus may be subject to additional privacy-related laws and requirements. To the extent that your personal information is shared with us as part of our provision of services to a customer, we encourage you to refer to the privacy policy and dispute resolution processes of that customer.

PERSONAL DATA COLLECTION

We obtain and process personal information in different capacities.

  • As a data controller, we collect and process Personal Data directly from individuals, including through our website, marketing, and customer and service provider relationships.
  • As a data processor, we process and store Personal Data obtained from our customers when providing our colocation services. In that context, we only process personal information on behalf of and at the instructions of our customers, which are the data controllers.

DATA INTEGRITY AND PURPOSE LIMITATION

We will only use Personal Data for the purposes indicated in our Privacy Policy or as otherwise notified to you. We will not process Personal Data in a way that is incompatible with these purposes unless authorized by you. We take reasonable steps to limit the collection and usage of Personal Data to that which is relevant for the intended purposes for which it was collected, and to ensure that such Personal Data is reliable, accurate, complete, and current. We will adhere to the Privacy Shield Principles for as long as we retain the Personal Data collected under the Privacy Shield.

When we process Personal Data in the context of our services to our customers, we process and retain Personal Data only as necessary to provide our services or as required or permitted under applicable law.

DATA TRANSFERS TO THIRD PARTIES

Third-Party Agents or Service Providers. We may transfer Personal Data to our third-party agents or service providers who perform functions on our behalf as described in our Privacy Policy. Where required by the Privacy Shield, we enter into written agreements with those third-party agents and service providers requiring them to provide the same level of protection the Privacy Shield requires and limiting their use of the data to the specified services provided on our behalf. We take reasonable and appropriate steps to ensure that third-party agents and service providers process Personal Data in accordance with our Privacy Shield obligations and to stop and remediate any unauthorized processing. Under certain circumstances, we may remain liable for the acts of our third-party agents or service providers who perform services on our behalf for their handling of Personal Data that we transfer to them.

Disclosures for National Security or Law Enforcement. Under certain circumstances, we may be required to disclose your Personal Data in response to valid requests by public authorities, including to meet national security or law enforcement requirements.

Human Resources Data. We commit to cooperate with EU data protection authorities (DPAs) and comply with the advice given by such authorities with regard to human resources data transferred from the EU in the context of the employment relationship.

SECURITY

RagingWire maintains reasonable and appropriate security measures to protect Personal Data from loss, misuse, unauthorized access, disclosure, alteration, or destruction in accordance with the Privacy Shield.

ACCESS RIGHTS

You may have the right to access the Personal Data that we hold about you and to request that we correct, amend, or delete it if it is inaccurate or processed in violation of the Privacy Shield. These access rights may not apply in some cases, including where providing access is unreasonably burdensome or expensive under the circumstances or where it would violate the rights of someone other than the individual requesting access. If you would like to request access to, correction, amendment, or deletion of your Personal Data, you can submit a written request to the contact information provided below. We may request specific information from you to confirm your identity. In some circumstances we may charge a reasonable fee for access to your information.

QUESTIONS OR COMPLAINTS

You can direct any questions or complaints about the use or disclosure of your Personal Data to the contact information set forth below. We will investigate and attempt to resolve any complaints or disputes regarding the use or disclosure of your Personal Data within 45 days of receiving your complaint. For any unresolved complaints, we have agreed to cooperate with TRUSTe LLC (“TRUSTe”), an alternative dispute resolution provider located in the US. If you do not receive timely acknowledgement of your complaint from us or are unsatisfied with the resolution of your complaint, you may contact TRUSTe at at https://feedback-form.truste.com/watchdog/request (free of charge) for further information and assistance, or to file a complaint.  The services of TRUSTe are provided at no cost to you.

BINDING ARBITRATION

You may have the option to select binding arbitration for the resolution of your complaint under certain circumstances, provided you have taken the following steps: (1) raised your complaint directly with RagingWire and provided us the opportunity to resolve the issue; (2) made use of the independent dispute resolution mechanism identified above; and (3) raised the issue through the relevant data protection authority and allowed the US Department of Commerce an opportunity to resolve the complaint at no cost to you. For more information on binding arbitration, see US Department of Commerce’s Privacy Shield Framework: Annex I (Binding Arbitration).

CONTACT US

If you have any questions about this Policy or would like to request access to your Personal Data, please contact us at:

Information Assurance Department
RagingWire Data Centers
1625 National Dr.
Sacramento, CA 95834
Email: infosec@ragingwire.com
Tel: 1-916-286-3000

CHANGES TO THIS POLICY

We reserve the right to amend this Policy from time to time consistent with the Privacy Shield’s requirements.