Information Collected Through Services
Use of Information
Legal Basis for Processing (EU)
Information We Share
Third Party Sites
Information about International Transfers
Your Choices and Opt-Outs
Other Data Rights
Your California Privacy Rights
Retention of Your Personal Information
Updates to this Policy
How to Contact Us
Through Our Services, Hostway collects certain personal information, as follows:
You may provide personal information to Us through the Services – for example, when You create a Hostway account, contact customer support, send Us an email, or communicate with Us in any other way. When setting up a Hostway account, You will be asked to provide certain basic information such as a name, email address, username, password, company name, occupation, location and phone number (e.g. if You are using two-factor authentication). If You purchase one of Our paid plans, You may also need to provide Us with payment and billing information such as the Customer’s credit card details and billing address. As a Customer, Hostway will also maintain a record of Your purchases, transactional information, Services history and usage, and any communications and responses. We may also collect personal information, such as Your contact information, employment details, and feedback.
Hostway Customers may also input or upload certain personal information to the Hostway platform which We will process as a data processor on Our Customers’ behalf. For example, when Our Customers use Our cloud hosting platform to upload contact information relating to their own customers or other personal information about their own end-users, We will act as a data processor and only process such information on Our Customer’s behalf and in accordance with their instructions (as defined in Our Customer agreements). We will use such personal information to:
In such cases, it is the Customer (or, as the case may be, other third parties) who remain responsible for the handling of the personal information and with compliance with any applicable data privacy laws. If You have questions or concerns about how such personal information is handled, You should contact the relevant entity that is using the Services, and refer to their separate privacy policies.
From time to time, We may receive personal information about You from third-party sources (including public databases, third-party analytics partners, and social media platforms), but only where We have checked that these third-parties either have Your consent or are otherwise legally permitted or required to disclose Your personal information to Us. The types of personal information We collect from third-parties may include name, title, company name, job function, expertise, telephone number, or email address. In addition, we may obtain information about your internet connection and phone number from third-party sources, such as connection type or phone line type, details of the ISP or phone service provider, and location of the internet or phone service. We use the information We receive from these third-parties to improve the security of Our Services, and to deliver relevant customer service information and marketing offers.
We may use the information We collect through the Services for a range of reasons, which include:
If You are from the European Economic Area (“EEA”), Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which We collect it.
However, We will normally collect personal information from You only where We have Your consent to do so, where We need the personal information to perform a contract with You, or where the processing is in Our legitimate interests and not overridden by Your data protection interests or fundamental rights and freedoms. In some cases, We may also have a legal obligation to collect the personal information in question.
If We ask You to provide personal information to comply with a legal requirement or to perform a contract with You, we will make this clear at the relevant time and advise You whether the provision of Your personal information is mandatory or not (as well as of the possible consequences if You do not provide Your personal information).
Similarly, if We collect and use Your personal information in reliance on Our or a third party's legitimate interests and those interests are not already listed above (in the "Use of Information" section), We will make clear to You at the relevant time what those legitimate interests are.
If You have questions about or need further information concerning the legal basis on which We collect and use Your personal information, please contact Us using the contact details provided in Section 15 below.
We may share and disclose Your personal information to third parties in the following select circumstances:
We will not share personal information collected through the Services with third party companies for marketing purposes. We do not display targeted advertisements or other targeted marketing content on our website. The only marketing communications received from Us will be related directly to Services that You have subscribed to, previously used, or requested information about.
We maintain reasonable and appropriate security measures to protect Your personal information from loss, misuse, and unauthorized access, disclosure, alteration and destruction. We will take all reasonable steps to ensure the safety of Your personal information. For further information about Our security practices, please see Our Data Security statement.
Hostway does not knowingly solicit or collect, and You should not provide, any information regarding an individual’s medical or health condition, race or ethnic origin, political opinions, religious or philosophical beliefs or other sensitive data, as such term is defined in the Hostway Terms of Service.
Your personal information may be stored and processed by Us in any country where We have facilities or where We engage service providers, and by reading this Policy and using the Services, You acknowledge that Your personal information may be transferred to countries outside of Your country of residence, including the United States, which may have different data protection rules to those of Your country. Where We do so, Our collection, storage and use of Your personal information will be in accordance with the purposes set out in this Policy.
The Services are not directed at children under the age of 16. We do not knowingly solicit or collect personal information from children under the age of 16.
You can opt out of receiving marketing emails from Us at any time. You can opt out of Our marketing emails by clicking the ‘unsubscribe’ link at the bottom of Our marketing messages. Also, all opt out requests can be made by emailing Us at firstname.lastname@example.org. Please note that it may take up to 3 days to remove Your contact information from Our marketing communications lists, so You may receive correspondence from Us for a short time after You make Your request. Please note that some communications (such as service messages, account notifications, billing information) are considered transactional and necessary for account management and You cannot opt out of these messages unless You request to deactivate Your Hostway account.
Hostway takes reasonable steps to ensure that the data We collect is reliable for its intended use, accurate, complete and up to date. You can manage many of Your account and profile settings within the dashboard provided as part of the Hostway platform. However, if You want to contact Us directly about accessing, changing or deleting Your personal information, or altering Your data or marketing preferences, please email Us at email@example.com. We will respond to Your request in accordance with applicable laws.
If You are from certain territories (such as the European Union), You may have additional data protection rights, such as broader rights to access and deleted Your personal information, as well as rights to:
If You would like to exercise the above rights, please write to Us using the contact details in Section 15 below and We will consider Your request in accordance with applicable data protection laws. We may ask You to verify Your identity in order to help Us respond to Your request.
You also have the right to raise questions or complaints with Your data protection authority at any time.
Please note that if We are processing Your personal information on behalf of Our Customers as a data processor, then You should direct any data rights requests to Our Customer who holds the Hostway account. We will not be able to respond directly to such requests and will refer any such requests to the relevant Customer.
We will retain your personal information for the period necessary to fulfil the purposes outlined in this Policy unless a longer retention period is required or permitted by law, for legal, tax or regulatory reasons, or other lawful purposes.
Where We have no ongoing legitimate business need to process Your personal information, We will either delete or anonymize it or, if this is not possible (for example, because Your personal information has been stored in backup archives), then We will securely store Your personal information and isolate it from any further processing until deletion is possible.
Any personal information that We process on behalf of Our Customers is retained in accordance with the timeframes set out in the relevant Customer agreements.
We reserve the right to change or update this Policy from time to time. If material changes are made, We will place a prominent notice on Our Website or Services for at least 30 days prior to the change taking effect, or communicate with You directly by email or through the Services, and will update the last revised date at the top of this Policy. We encourage You to regularly check back on this page to ensure You are up to date with any changes.
If You have any questions or concerns regarding the use or disclosure of Your personal information through the Services, You can contact Us by sending an email to firstname.lastname@example.org, Our Data Protection Officer by sending an email to email@example.com, or by mail at: 3923 W. 6th St., Suite 315, Los Angeles, CA 90020, U.S.A.
Last Updated May 14, 2018