Infrascale, Inc. is committed to protecting the privacy and data of its customers. We recognize the importance of appropriate policies and procedures to protect customer data and the privacy of our website users. We have therefore created this statement to describe Infrascale’s privacy practices and procedures relating to the use of its website and the customer data it receives, process, maintains, or transmits in connection with the backup, archiving, and failover services it provides.
By “customer data,” we are referring to information and data we receive, process, maintain, or transmit on behalf of a customer when delivering Infrascale’s services to a customer or other information and data customers otherwise provide to Infrascale. For instance, customer data includes data customers upload to our services for backup, archival, or failover purposes. It also includes personal information about customer representatives. Finally, “customer data” includes metadata and other system data generated by our systems in connection with the delivery of Infrascale’s services.
“Website user personal information,” or “personal information” for short, refers to information we collect in connection with our website or your communications with us.
This statement summarizes the types of data and personal information we collect, how we process them, the circumstances in which we will disclose them, how we safeguard them, gaining access to them, updating or correcting them, and resolving disputes relating to Infrascale’s privacy practices concerning them.
US-EU Safe Harbor Certification.
Infrascale has certified its compliance with the US-EU Safe Harbor Framework and the US-Swiss Safe Harbor Framework developed by the U.S. Department of Commerce. Infrascale’s privacy practices are in accordance with these Frameworks, and customer data and personal information will be processed in accordance with them.
Infrascale has implemented the principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view Infrascale’s certification, please visit http://www.export.gov/safeharbor/.
Nonetheless, an October 2015 European Court of Justice invalidating the US-EU Safe Harbor has created a rapidly changing policy environment, but Infrascale will, for now, continue to adhere to the US-EU Safe Harbor Framework and the US-Swiss Safe Harbor Framework while monitoring developments in law and policy.
Types of Data and Information Infrascale Collects.
Infrascale provides its customers with data backup, archiving, and failover solutions with offerings that include hardware, software, and cloud-hosted functionality. Its applications help customers to manage disaster recovery and business continuity functions while increasing the efficiency of data storage via de-duplication of data. Infrascale’s solutions work with private, public, and Infrascale-hosted cloud facilities.
In general, Infrascale collects two categories of customer data. First, Infrascale collects data processed by its hardware and applications for backup, archival, or failover purposes. If the customer is using Infrascale’s cloud, Infrascale also hosts this customer data. Second, Infrascale collects customer data relating to customer accounts and their management. For instance, Infrascale collects personal information about representatives and contacts at its customer organizations, including their contact information (name, address, telephone numbers, and email addresses), job title, and name of employer. Infrascale also collects payment card information for processing payments for Infrascale’s products and services.
Infrascale also generates customer data in the form of metadata and system data in connection with the delivery of its services.
We collect information from users of our website via web forms and other communications as described in Section 5 below.
Infrascale’s Role as a Data Processor.
If and when customers upload customer data containing personally identifiable information to Infrascale’s services, it is the customers that are data controllers with respect to such personally identifiable information. That is, the customer has the direct contact with the individuals whose personally identifiable information was uploaded to the applicable service. Customers are the ones who would collect the personally identifiable information from their customers, personnel, patients, or other data subjects. Infrascale has no such contact with these individuals.
We may process any personally identifiable information, among other data, when customers use the services for backup, archiving, and failover purposes. When performing its services, Infrascale processes data strictly in accordance with the actions or instructions of the applicable customer.
As a data processor, with certain exceptions, Infrascale has an obligation under its agreement with the customer not to disclose or otherwise transfer data to a third party except to provide the service or the customer has instructed us to disclose or transfer the data. Except as noted below, Infrascale processes any personally identifiable information and other customer data solely for the purpose of delivering services to customers. Infrascale may use third party data processors to assist it in delivering the service to its customers
How Infrascale Collects Customer Data and Personal Information.
Data Collected by Infrascale’s Solutions. We receive customer data from customers’ systems when they use our services for backup, archiving, and failover purposes or otherwise transmit customer data to us.
Account-Related Information. We receive account-related contact information from customer representatives and contacts when they provide it to us. Customer representatives may provide Infrascale with payment card information in order to pay for our services. We may also obtain biographical information about representatives and contacts through our review of information they post to the Internet. We may obtain additional information about our customer representatives from public sources and third-party databases.
Personal Information Sent via Our Website and Email. We will collect the personal information of website visitors who complete web forms to communicate with us to submit a support ticket or use the chat function to communicate with a support representative. When a customer submits a ticket or chats with a support representative, we collect information such as name, contact information (email and phone), account user name, and comments. On our website, we also encourage website visitors to send us email inquiries, both to learn about our products and services and to consider careers at Infrascale. If you send us email, we will collect whatever personal information you include in your email. If a communication prompts follow-up communications, we may collect additional information that you provide to us.
Cookies. Your browser has settings by which you can choose how it manages cookies. For instance, you may decide not to accept cookies or to receive notifications about cookies allowing you to choose whether or not to accept it. If you decide not to accept cookies, however, some of the websites’ features or functions may not be available to you.
Website Data. We also review information logged by our web servers to understand our website visitors better. It is very common for websites to collect these kinds of logs. For example, we collect information such as your Internet Protocol address, your location, domain name, the type of web browser and operating system you are using, the pages on our websites that you view, when you visit, and how long you view each page visited.
Data-Appending Methods. We may add to the information we receive from customer representatives and website users by information they provide to us at other occasions and using other means. Examples include information they provide to us at educational programs, trade shows, or meetings, as well as information gathered using other data-appending methods. We may also review and collect biographical information about representatives and users that they post to the Internet.
Metadata and Other System Data. Our systems generate certain metadata and other system data concerning customers’ account, such as logs showing when files are transmitted to our services and when they are recovered from our services.
Use of Customer Data and Personal Information.
Data Collected by Infrascale’s Solutions. We process customer data collected by our solutions for the purpose of delivering backup, archiving, and failover services and functionality to our customers. Our systems process customer data to perform these functions based on the actions and instructions of our customers.
Account-Related Information. We use account-related information in order to market our services, establish relationships, set up our services for customers’ use, deliver the services, obtain payment for the services, provide customer and technical support for the services, and otherwise communicate with customers.
Personal Information from Website Visitors. We will use personal information collected as described in Section 5(c)-(f) above solely with the objective of fulfilling those purposes specified above, unless we obtain your consent. In specific, we may use your personal information to communicate with you. Our communications may relate to Infrascale’s products and services or, in the case of job candidates, possible employment opportunities at Infrascale.
General Use of Customer Data and Personal Information. Infrascale uses customer data and personal information for the following general purposes: (i) identification; (ii) establishment and maintenance of our relationship with you, (iii) to provide you with ongoing news, publications and information, to respond to your requests and inquiries, to fulfill your requests to register for services, use our products and services, request publications or other information from us, sign up for newsletters, and obtain or provide user access credentials; (iv) marketing purposes, such as your activity, browsing, and usage information concerning our websites and/or your demographic information that you may have voluntarily provided to us, in order to better tailor our marketing activities and to implement and maintain loyalty programs; (v) providing information to third-party administrators or other providers necessary to optimize our services and operation of our website; (vi) maintaining business records for reasonable periods, and generally managing and administering our business; (vii) meeting legal, regulatory, insurance, security, and processing requirements and court or administrative orders; and (viii) otherwise with consent or as permitted or required by law. We may keep any and all of your personal information on hand for as long as permitted by law for any and all of the purposes described in this Section.
Metadata and Other System Data. Infrascale uses metadata and other systems data to manage its services and deliver its services to customers.
Third Party Hosting of Customer Data.
We use certain third party service providers to host and maintain customer data that we may receive from you. More specifically, we may use Amazon Web Services, Google Cloud Platform and other cloud platform providers to host the Infrascale cloud solutions and to collect and maintain customer data uploaded to our services. In addition, we upload some account-related information to cloud service providers to maintain and analyze information about our relationships with our customers, undertake Infrascale marketing campaigns, and provide customer and technical support.
We enter into agreements with third parties hosting customer data. These agreements bind such third parties to confidentiality restrictions requiring them to use customer data only for purposes of delivering their services to us, not to disclose customer data without authorization, and to adhere to the kinds of privacy practices summarized in this privacy statement.
Disclosure or Transfer of Customer Data or Personal Information.
Customer data and personal information may be disclosed to: (a) our employees, agents, representatives, advisors, affiliates, and independent contractors, in connection with their performance of services for or on behalf of our customers; and (b) service providers who help us with our business operations, sales and marketing, information technology, or professional services.
We do not sell or rent customer data or personal information to anyone. Nonetheless, we may sell, transfer, or otherwise share some or all of its Infrascale’s assets in connection with a merger, acquisition, reorganization, or sale of assets of our business, or in the event of bankruptcy. These assets may include customer data or personal information collected by Infrascale as described above.
Also, we may disclose customer data or personal information when required by a subpoena, court order, search warrant, other legal process, requests by law enforcement agencies, or applicable law. Moreover, we may disclose customer data or personal information to the extent necessary to maintain the security of our websites, products, or services; resolve disputes; or investigate possible misconduct.
How Infrascale Safeguards Customer Data and Personal Information.
We will take reasonable measures to ensure that your customer data and personal information collected, used, disclosed, or otherwise processed for us or on our behalf is protected and not used or disclosed for purposes other than as directed by Infrascale, subject to legal requirements in foreign jurisdictions applicable to those organizations. Please note that foreign jurisdictions differ in their privacy laws and some have privacy protection laws equivalent to or greater than those in the United States whereas others do not.
Infrascale is committed to protecting customer data and personal information and preventing unauthorized disclosure, use, modification, or access of or to customer data and personal information. In specific, Infrascale is committed to maintain reasonable and appropriate administrative, physical, and technical safeguards to:
Provide assurances of the integrity and confidentiality of customer data and personal information.
Protect customer data and personal information against any reasonably anticipated threats or hazards to the security or integrity of customer data or personal information, and unauthorized uses or disclosures of them, and
Maintain compliance with the legal framework of requirements for the privacy and security of customer data and personal information.
Accessing Customer Data and Making Changes.
Customer Data. Infrascale’s services provide functionality to access and update customer data uploaded by customers. Using our services, customers can view, update, append, and correct customer data uploaded to our services or their own public or private cloud solutions. Customers requiring assistance accessing and changing such customer data via the services can contact technical support for assistance by chatting with a support representative or completing a support ticket on our website at: https://www.infrascale.com/support/.
Personal Information or Account-Related Information. If you would like to access personal information customer data we may have to support your account, please contact us at firstname.lastname@example.org or by phone at one of the phone numbers at https://www.infrascale.com/support/.
Contact Information and Resolving Disputes.
If you would like to discuss this privacy statement or provide us with feedback, questions, or concerns about our privacy practices regarding customer data or personal information, please contact us at email@example.com. You may also contact us by writing to:Infrascale, Inc.
999 N. Sepulveda Blvd., Suite 100
El Segundo, CA 90245
United States of America
If you have a complaint about our privacy practices, you may submit a complaint to us at the above contact information. Our privacy team will look into your complaint and provide a response. You will need to provide sufficient information for us to evaluate your complaint and we may ask you to provide additional information as a condition of evaluating your complaint.
If you do not believe that your complaint or dispute has been resolved, you may contact the International Centre for Dispute Resolution (ICDR) of the American Arbitration Association at: http://go.adr.org/safeharbor. Infrascale has designated ICDR as its independent recourse mechanism for its participation in the US-EU and US-Swiss Safe Harbor Program. The ICDR will provide independent dispute resolution services to resolve complaints or disputes about our privacy practices. Procedures for contacting ICDR and filing a claim are linked to the website listed above.
This Agreement was last revised on December 3, 2015.