At Global Cloud Xchange we take your privacy and our responsibility to protect it very seriously. We have created this statement in order to demonstrate our firm commitment to making sure your personal information is safe and secure with us.

This Privacy Policy explains which personal data we collect and how and for which purposes we process and use such personal data when you use the Global Cloud Xchange website (www.globalcloudxchange.com – hereinafter referred to as “Our Website”). As used in this Privacy Policy “personal data” means any information (either alone or in combination with other information which we possess or can reasonably access) that relates to you as an identified or identifiable individual. It is our promise to you that, unless you permit us otherwise, any personal data you provide to us via Our Website will be processed solely in accordance with applicable laws and this Privacy Policy.  This website is intended to address businesses and is not intended for children and we do not knowingly collect data relating to children.

WHO WE ARE AND CHANGES TO THIS PRIVACY POLICY

We respect your right to privacy and will only process your personal data in accordance with our Privacy Policy subject to applicable data protection and other applicable privacy laws.

The controller for the data processing on this website is:

Reliance FLAG Telecom Ireland DAC a company incorporated under the laws of Ireland,
having its registered office at 6th Floor, South Bank House, Barrow Street,
Dublin 4
Ireland

GCX is made up of different legal entities. This privacy notice is issued on behalf of the GCX Group so when we mention GCX, “we”, “us” or “our” in this privacy notice, we are referring to the relevant company in the GCX Group responsible for processing your data. This only relates to general processing activities described in this privacy policy. When referring to the processing activities on our website, only the controller listed above is the controller under data protection laws]

We will post any modifications or changes to the Privacy Policy on Our Website. This version was last updated on the date set out below and historic versions can be obtained by contacting us. We reserve the right to modify this Privacy Policy at any time, so we encourage you to review it from time to time. This Privacy Policy supplements our other  privacy notices and is not intended to override them.’

INFORMATION COLLECTION

We collect information every time a visitor comes to Our Website (User). This information is used for specific purposes, which we list together with the respective information below. The specific types of personal data we collect depend upon your activities on Our Website.

User disclosed information: As described below this information is only collected if you choose to provide this information in an enquiry form, in a newsletter subscription form or the dedicated customer portal and may include company, your user name, full name, title, department, postal and email addresses, phone and fax number, industry, your country and any questions or comments you decide to input. You will be clearly asked to provide this information and will be aware of the fact that you provide it in the respective situation.

Automatically collected information: When you use Our Website we may also collect certain further information automatically as described in the sections below for the purposes described, e.g. providing Our Website and improving overall performance, providing and managing our services, improvement of our products and software services and troubleshooting bugs. Such information may include demographics (language, country, city), audience information (affinity, in market segments), system information (browser, operating system, service provider), mobile information (operating system, service provider, screen resolution, time stamp), user behaviour (source, search tems, page visits, engagement and users flow) and your IP address.

USE OF INFORMATION

• Use of IP address

We use your IP address to let you use Our Website, to help diagnose problems with our server and administer Our Website and in conjunction with Cookies as detailed under Use of Cookies.

If you agree we may also use your IP address to create a personal profile of your use of Our Website by use of certain cookies as detailed under Use of Cookies using Act-On.

• Use of Cookies

Global Cloud Xchange uses cookies, a standard Internet technology that allows us to improve our information and services and save information and preferences so you do not have to re-set each time you visit Our Website.

“Cookies” are small text files that are stored by your web browser on your computer’s hard drive. They allow websites to store such things as user preferences. Our Website generally uses both session cookies and persistent cookies. Session cookies are temporary cookies that expire (and are automatically erased) when you close your browser. Persistent cookies usually have an expiration date far into the future and thus stay in your browser until they expire, or until you manually delete them.

Cookies are useful because they help make your website experience more personal and more enjoyable. They allow us to recognise your device (e.g. your laptop or mobile device) so that your experience of Our Website can be tailored to your device. Cookies do not typically identify you as an individual, just the device you are using.

The first time you visit Our Website you will see an overlay which explains that by clicking “Accept” you consent to the use of cookies as described in the below section on use of cookies. You can also refrain from clicking “Accept”, in this case no persistent cookies will be placed on your device but only such necessary for providing our website. In particular no analyses cookies will be placed. Alternatively, most Internet browsers allow you to block cookies from your browser. Please note, however, that if you choose not to accept any cookies, you may encounter difficulties using certain parts of Our Website – certain parts of Our Website may not work at all, or may not work correctly.

Our Website uses the following types of Cookies:

Functional cookies

We use cookies to save information and preferences, so you do not have to re-set it each time you visit Our Website, and to deliver content tailored to your needs. These cookies are there to make Our Website function on its best.

You can opt out of providing us with this information if you wish. Please note, however, that if you choose not to accept these cookies, you may encounter difficulties using certain parts of Our Website.

Cookies name: _icl_current_language=en

Cookies name: wpACCT# (e.g. wp9883)

Analytics cookies

We use Google Analytics and Act-On, which also places a cookie on your machine, to help us analyse how Our Website is used.  See below under the heading “Google Analytics” and “Act-On”for further information.

Anonymous data about your visit is collected and amalgamated with that of other visitors so we can better understand how visitors use Our Website.

You can opt out of providing us with this information if you wish, with no impact on your experience of Our Website.

Cookie name: __utm*=

• Google Analytics & Act on

Our Website uses Google Analytics, a web analysis service provided by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”). Google Analytics uses “cookies”. The information generated by the cookie regarding your use of Our Website is normally transferred to a Google server in the USA, and is stored there. As the IP anonymize function is activated on Our Website, your IP address will, within Member States of the European Union or other contracting states of the Agreement on the European Economic Area, first be shortened by Google. Only in exceptional cases will Google transfer the full IP address to a Google server in the USA, and will shorten it there.

On behalf of the operator of Our Website, Google will use this information in order to analyse your usage of Our Website, to compile reports on website activities, and to provide further services to the website provider relating to the usage of Our Website and the internet. The IP address transferred by your browser within the framework of Google Analytics will not be combined by Google with other data. You can prevent collection by Google of the data generated by the cookie and relating to your use of Our Website (including your IP address), as well as processing of these data by Google, by downloading and installing the browser plug-in provided under the following link: https://tools.google.com/dlpage/gaoptout?hl=de

Our Website uses Act-On, a web analysis service provided by Act-On Software, Inc. a Delaware corporation whose principal place of business is at 121 SW Morrison Street, Suite 1600, Portland, Oregon 97204 U.S.A. (“Act-on”). The information generated by the cookie regarding your use of Our Website is normally transferred to an Act-On server in the Republic of Ireland, and is stored there. On behalf of the operator of Our Website, Act-On will use this information in order to analyse your usage of Our Website, to compile reports on website activities, and to provide further services to the website provider relating to the usage of Our Website and the internet. The cookie is set to expire after 1 year. As described in this policy you are given a choice to either opt-in to having tracking information saved, or to opt-out of having tracking information saved. In this case a one-time opt-out cookie will be placed to ensure you receive no further requests for permission to save the tracking information after you denied permission. Alternatively you can prevent the storage of cookies by setting your browser software accordingly. 

• Use of Registration Information

In order to access certain downloads of Our Website reserved for customers and their employees, users are asked to register and provide us with certain information e.g. Whitepapers. Our registration program requests users to give us contact information and information about your position (e.g. gender, full name, title, department, company, industry, phone and fax number and postal and email addresses), and demographic information. We use this contact information to process your enquiry and to send out updates about Global Cloud Xchange, if you agreed to receive such communication or as lawful without consent. You may choose to opt out of receiving mailings at any time (see the choice/opt-out section below). In case you gave us your consent, you can revoke your consent at any time. If you revoke your consent, this does not affect the lawfulness of the data processing until this point in time.

• Customer Platform/Portal

On behalf of our customer you may be required to log into our Customer Web Portal in order to access certain services that GCX provides online. We will only process your personal data if and to the extent this is necessary for the provision of our services to our customer and accounting purposes, how exactly we process the data of the users inside the portal depends on the individual service which the user accesses or requests.

• Newsletters and Product Information

Our Website allows you to subscribe to our newsletter and other product information. In such case, we will use the personal data you enter (e.g. gender, title, first and last name, company, industry, country, email address) to send you the respective mailing.

You may have given us the following consent:“I have read the GCX Privacy Policy and agree to receiving Reliance FLAG Telecom Ireland DAC’s digital company & product announcements on telecommunications- and IT-services which are offered by entities belonging to GCX Group. I am aware that I can withdraw my consent anytime by clicking “unsubscribe” or manage my preferences in any email received from GCX. If you revoke your consent this will not affect the lawfulness of the data processing until this point in time.””

• Contact Form

We provide a contact form on Our Website which you can use to contact us, e.g., in order to ask questions about our products. We will use the data you enter (e.g. title, first and last name, company, industry, country, postal and email addresses, phone number) in order to process your request and respond to it. Your data may be forwarded from Reliance FLAG Telecom Ireland DAC to its relevant affiliate in your region who is the competent entity for your respective request. E.g., if you require support in Hongkong, your request will be forwarded to FLAG Telecom Asia Limited. All affiliates are listed on our website under Contact Us.

• Public Forums

Our Website may provide chat rooms, forums, message boards, and/or news groups to you in the future. Please remember that any information that you disclose in these areas becomes public information and you should exercise caution when deciding to disclose your personal information.

• Non Personal Data and Statistical Analysis

We use your non personal data information to technically administer Our Website and to identify abuse or bug fixing.

We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your usage data with usage data of other users to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

LAWFUL BASIS

We process your personal data as described above on one of the following legal bases:

• Art. 6 section 1 lit. b GDPR, if the processing of your personal data is necessary in order to carry out the contract concluded between you and us or in order to take steps at the request of you prior to entering into a contract (e.g., when requesting information about one of our services);
• Art. 6 section 1 lit. c GDPR, if the processing of your personal data is necessary for us in order to comply with a legal obligation we are subject to (E.g., laws on money laundering or similar compliance requirements might require us to process certain of your personal data);
• Art. 6 section 1 lit. f GDPR, since processing is necessary for purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child. These legitimate interests are:
  • Fulfilling our contract with the company you are working for;
  • our interest in managing our business contacts in order to make our business processes more effective; and
  • complying with legal requirements outside the EEA; or
• Art. 6 section 1 lit. a GDPR, since you have been informed about the intended processing of your personal data, and have given us your consent. You can always withdraw your consent. You can withdraw your consent to all processing, or for individual purposes of your choosing. The withdrawal of consent will not affect the lawfulness of processing based on your consent before the withdrawal. You can withdraw your consent by sending an email to the email address below under Contacting Us.

HOW LONG WILL USE YOUR PERSONAL DATA FOR

We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

We, generally, store your personal data for one of the following time periods :

If the processing of your personal data is necessary in order to carry out the contract concluded between you and us or in order to take steps at the request of you prior to entering into a contract (e.g., when requesting information about one of our services), we will process your personal data until it is not needed anymore for carrying out the contract;

if you are an employee working for a customer and a contact in this regard, we store the personal data for the term of the contractual relationship with you or the company you are working for;

if we have a statutory legal obligation to process your data, we will deleted it once the specific legal obligation does not apply anymore;

if we have a legitimate interest to process your personal data outside of such a contractual relationship, we process it for as long as we still have a legitimate interest in processing this data. The exact period depends on the company you are working for and your position in the company; or

if you have given us your consent, we will process your personal data based on this consent, until you revoke your consent. You can withdraw your consent to all processing, or for individual purposes of your choosing. The withdrawal of consent will not affect the lawfulness of processing based on your consent before the withdrawal. You can withdraw your consent by sending an email to the email address below under Contacting Us.. Depending on the content on your consent, the data collected based on your consent might still be deleted;

If longer retention periods apply after the time periods listed above (e.g., because we are obliged to store the data for tax purposes) we block your data for all other purposes and keep it until the end of the respective retention period.

In some circumstances you can ask us to delete your data: see below (User Rights) for further information.

THIRD PARTY WEBSITE LINKS AND FEATURES

Our Website may contain links to other sites that provide products and services to enrich your experience at Global Cloud Xchange. We assume no responsibility for such linked third party content. Please rest assured that we will remove any inappropriate links if this comes to our attention. Please feel free to notify us any time (see under Contact).

Our Website contains plugins of the social platforms Facebook, Twitter, LinkedIN and Google+. Please note that these plugins (the “buttons”) transfer certain information to the provider of the respective service. Such information may include date and time of your visit to Our Website IP Address, browser info, operating system, screen resolutions, installed browser plug e.g. Adobe Flash player, origin of user (referrer), url of current page. However, the respective provider remains responsible for the data processing, which occurs on the platform and is caused by the buttons and controls this processing entirely. Therefore, please consult the information provided by the provider in question for detailed information about the data processing, which is caused by these buttons. We have only explained the basic functionalities of the buttons below.

Our Website contains so-called „Share Buttons”. These buttons are plugins from the provider of the respective social platform. If you click a Share Button, the respective content provided on Our Website is shared with the people connected to you in the respective social network. Furthermore, as detailed above certain information is transferred to the respective social network. We are not responsible for such data and can in no way control how such data will be processed. Please see the privacy policy of the respective service for more information. You need to be logged into the respective social network before you can share the content. You will also be provided with a confirmation page before you share the content.

We use a special Software in order to prohibit any transfer of your data to social media providers, unless you chose to make use of these social plug-ins and activity feeds. If you choose to use these social plug-ins or activity feeds, the plug-ins will only be activated when clicking on them. The transfer of data takes place in order to enable you to use and connect with the services of these social media providers.

SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

CHOICE: OPT-OUT

Opt out: If you receive communications, our Website gives you the opportunity to opt out of receiving such communications. Just send us an email at [unsubscribe@globalcloudxchange.com] from your relevant email address or by managing your preferences on your personal link or click the unsubscribe link in our mailings if you would no longer like to receive communications from us. Communication by email will also inform you about this possibility and contain a link which allows you to opt out.

POSSIBLE RECIPIENTS OR CATEGORIES OF RECIPIENTS OF YOUR PERSONAL DATA

We may transmit your personal data in parts or as a whole to other entities. This largely depends on the scope of your request, in particular, which entities you interacted with. E.g., if you are a customer of a particular Global Cloud Xchange entity, we will forward the request to such entity, in order to collect the necessary information to respond to it.

Possible Recipients are

• Other group companies belonging to the Global Cloud Xchange group if such a transfer of personal data is required for the specific purpose;
• Service providers who process personal data on our behalf but have to follow our instructions on such processing; these service providers will not be allowed to use your personal data for other than our purposes;
• Authorities, who we are obliged to provide your personal data to, e.g., data protection authorities; and

Auditors or similar external consultants like lawyers or tax advisers.

INTERNATIONAL DATA TRANSFERS

We may transfer your personal data in parts or as a whole to recipients in third countries, which are not Member States of the European Union, or international organisations. Such countries / international organisations are other Global Cloud Xchange entities which process your personal data for the purpose listed above (see also section “Recipients” of this privacy policy.

With regards to data transfers to all further countries we have provided appropriate safeguards in order to secure your personal data to a degree that equals the level of data protection in the European Union. Such safeguards include so-called model contracts issued by the European Commission, a consent by the data subject (in which case the respective consent is provided to you) or a certification under the EU-U.S. Privacy Shield Frameworks.

LEGAL PROCESS DISCLOSURE

If GCX is legally required to permit any relevant authority to inspect User content or traffic, GCX can do so; provided however that, where possible without breaching any legal or regulatory requirement, we give reasonable prior notice of such requirement.

GCX may, without notice, report to the appropriate authorities any conduct that GCX reasonably believes to violate applicable law, and – to the extent allowed by applicable laws – provide any information GCX has about the User or the User’s traffic and cooperate in response to a formal request from a law enforcement or regulatory agency investigating any such activity, or in response to a formal request in a civil action that on its face meets the requirements for such a request.

USER RIGHTS

You have the rights listed in our Privacy Policy listed under below. We would only levy charges if we are entitled under law. Please see below on contacting us.

Please click on the links below to find out more about these rights:

• Request access to your personal data.
  You may obtain information on the personal data we hold, the origin, the purpose and the recipients thereof.
• Request correction of your personal data.
  You may demand correction of your personal data at any time.
• Request erasure of your personal data.
  Under the requirements set out in Art. 17 GDPR you have the right to request from us the eras-ure of your personal data. In particular you may ask us to erase personal data, if (i) it is no longer necessary in relation to the purposes for which it was collected or otherwise processed; (ii) the personal data has been unlawfully processed, (iii) you object to the processing pursuant to Art. 21(1) GDPR and there are no overriding legitimate grounds for the processing, (iv) the personal data has to be erased for compliance with a legal obligation in Union or Member State law to which we are subject or (v) you withdraw your consent on which the processing is based and there is no other legal ground for the processing.
• Object to processing of your personal data.
  Pursuant to Art 21 GDPR, you have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on point e) or f) of Art 6 para. 1 GDPR. We will no longer process your personal data unless we demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or the processing serves the purpose of establishing, exercising or defending legal claims.
• Request restriction of processing your personal data.
  You have the right to obtain from us restriction of processing, where one of the following ap-plies: (i) The accuracy of the personal data is contested by you, processing will be restricted for a period enabling us to verify the accuracy of the personal data, (ii) the processing is unlawful and you oppose the erasure of the personal data and request the restriction of their use instead, (iii) we no longer need the personal data for the purposes of the processing, but are required by you to keep them for the establishment, exercise or defence of legal claims or (iv) you have objected to processing pursuant to Art. 21(1) GDPR and the verification whether our legitimate interests override yours is pending. Please send your request to the postal or email address below under Contacting Us.
• Right to data portability
  According to Art 20 GDPR you have the right to receive the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format. Please send your request to the postal or email address stated above.
• You may withdraw your given consent to any data processing activity any time
  In case you gave us your consent, you can revoke your consent at any time. If you revoke your consent, this does not affect the lawfulness of the data processing until this point in time.
• Right to lodge a complaint
  You also have the right to lodge a complaint with a supervisory authority. The responsible supervisory authority is:
  Office of the Data Protection Commissioner.
  Canal House, Station Road, Portarlington, Co. Laois,
  R32 AP23,
  Ireland.
  Phone +353 (0761) 104 800
  email info@dataprotection.ie

If you wish to exercise any of the rights set out above, please Contact Us.

CONTACTING US

If you have any questions about this privacy statement, the practices of Our Website, or your dealings with Global Cloud Xchange, you can contact us at enquiry@globalcloudxchange.com

Last modified on 23 May 2018