DATA PRIVACY TRANSPARENCY STATEMENT
PAIR NETWORKS, INC. D/B/A PAIR
Effective Date: May 25, 2018
Pair Networks, Inc. d/b/a pair Networks has prepared this data privacy transparency statement (this “Transparency Statement”) (collectively, “we”, “our” and/or “Pair”), to provide our customers, their employees, and any affected data subjects important information about the personal data we collect, receive, transfer, and process in the course of providing our services as a Web host and Website Distributor (our “Web Hosting Services”).
In this Transparency Statement, you will find information about the types of personal data we collect regarding our customers as the owner of a registered Pair user account through which you may host and distribute content through Pair’s Web Hosting Services (an “Account Owner”), (collectively, “you”, “your”), how and why we process such personal data, with whom we may share such information, as well as how we protect your information. We do not control our customers’, and their users’, Website Information (as defined below), and our responsibilities and liabilities with respect to such Website Information is strictly limited to our commitment to comply with our obligations as data processor in accordance with our customer’s instructions as data controllers with respect to such Website Information and our specific services as a website hosting services provider.
In this Transparency Statement, we also describe the processes by which you may contact us in order to exercise your rights, in accordance with applicable law, to: (1) access, correct, restrict, or delete your personal data; (2) object to the processing of certain aspects of your personal data; and (3) ask any questions you may have about our privacy practices. Please take note as well of those practices described in this Transparency Statement specifically stated to be necessary and/or integral, to the performance of our Web Hosting Services. Where specifically noted below, exercising your rights as described herein may affect our ability to continue performing Web Hosting Services as requested
This Transparency Statement may be updated and/or otherwise revised periodically to reflect changes in our data processing practices and/or policies. We will post notices of all such changes on our applicable websites and/or materials and the “Effective Date” noted above will indicate when this Transparency Statement was most recently revised. Except as may be otherwise required under applicable law, revisions to this Transparency Statement will be effective on the Effective Date noted without any other notice or approval by you. In certain jurisdiction, applicable law may require additional processes and procedures, in which case, revisions to this Transparency Statement will not be effective until we have met our obligations accordingly.
1. Data Controller; Data Processor
For purposes of the European Union General Data Protection Regulation (the “GDPR”), Pair Networks, Inc. d/b/a Pair is the data controller (the “Data Controller”) for the processing of all Personal Data, except for “Website Information”, as set forth herein. With respect to personal data included in Website Information, our customer, the website operator, is the “data controller” and we process Website Information solely as the data processor on behalf of such website operator.
You may contact us as follows:
Pair Networks, Inc.
2403 Sidney Street, Suite 210
Pittsburgh, Pennsylvania 15203
United States of America
2. Personal Data & Special Categories of Data
For the purpose of providing Web Hosting Services, we collect the types of personal information described below about you (as further detailed below, “Personal Data”).
- Personal Information – We collect personal contact information about Account Owner and, where relevant, alternate contacts for Technical and Billing contacts (as described below), including without limitation name, organizational affiliation (for Professional Accounts), VAT id, mailing address, phone numbers, and email addresses.
- Payment and Billing Information – We process payment information through a third-party service provider called a secure payment processor. Anytime you are asked to provide payment card information for payment to Pair, you are actually entering your payment card information directly to our payment processor’s systems. We enter into written contracts with our payment processors pursuant to which they are obligated to process your payment card information securely in accordance with the Payment Card Industry Data Security Standard (“PCI-DSS”), an information security standard for organizations that handle branded credit cards from major credit card brands. We do not collect, store or otherwise process your payment card information on our systems except for the limited, redacted information described below. As of the Effective Date first noted above, our secure payment processor is Stripe. You should review information about Stripe’s data handling policies and terms of service, available from their website (https://stripe.com/us/privacy).
- Account Information – We collect certain account information about our Account Owners and other users with whom we may interact, including without limitation: user name, password, domain, Web Hosting Services subscriptions under a given account, the email headers (including IP address) of messages that you choose to send to us, and history of correspondence between you and Pair.
3. How We Obtain Personal Data – We collect Personal Data from data subjects or from Account Owners through Pair websites, and other information you provide directly to us, including by email or in conversation with our staff.
4. Personal Data Processing and Data Retention – We use Personal Data that we collect hereunder as necessary to provide Web Hosting Services. Subject always to your rights as set forth in Section 9 below:
a. Pair Owner Accounts – In order for you to use Web Hosting Services, we require you to register an Owner Account through Pair websites. During the signup process, you will be prompted to set up a user name and password for account login purposes and personal contact information as follows: Name, Organization (for Professional Accounts), Physical Address, Phone Number and Email Address (“Account Information”). Your login information is necessary to protect your vital interests as it enables you to secure your own Owner Account and establish your identity with Pair for purposes of transactions in the course of using our Web Hosting Services. Your Account Information is necessary for the performance of Web Hosting Services as we use Account Information to contact you regarding your Owner Account, contact you regarding Web HostingServices, issue notices and alerts about the status of the Web Hosting Services, billing, invoices, collections, etc.
c. Service Notices – We send service-related notices, alerts and other messages to the email address(es) indicated in your Owner Account regarding account registration, account set up, billing and other service related communications. We use your Personal Data to send you such service-related messages as a necessary, and integral, part of our Web Hosting Services.
d. Support and Customer Service – When you contact us for technical support or customer service, we will process Personal Data that you provide at such time to associate you with the Web Hosting Services that is the subject of your request and the Owner Account that is associated with such Web Hosting Service. Such Personal Data includes email address, name, account numbers, and email headers (including IP address). You may contact us and provide Personal Data for such technical support and/or customer service by email, phone call, self-serve online support portals through websites operated by, or on behalf of, Pair. We use such Personal Data as necessary to respond to your request and/or provide the requested technical support and/or customer service, including without limitation communicating with you, internal communications, maintaining a history of correspondence, service tickets, outcomes, outstanding issues, etc. Our processing of Personal Data as described in this Section is also in furtherance of legitimate interests, including without limitation management reporting, quality assurance, reviewing historical support issues and requests for support or customer service, and to verify identity. We will process Personal Data in furtherance of this legitimate interest only when that is not overridden by your data protection rights under applicable law.
e. Helpdesk – We use a proprietary ticketing system developed in-house to manage customer requests and customer service communications and send customer support and customer service messages to the email address(es) indicated in your Owner Account.
f. System Security and Data Privacy Protection – We monitor information on user activity within our system in order to protect the security of our systems and the privacy of our customers, for example, as an investigatory tool in case of a dispute or an unauthorized hack. Such information includes information reported by your browser, Account Information when you login, IP addresses, User Agent, account activity and usage levels to better assist with service delivery and/or security. We process this data because it is necessary to protect the vital interests of our customers, audience, users and other visitors to our website. Additionally, we process this information to protect our legitimate interests of process improvement, system security and protecting our customers, audience, users and other visitors to our website in a manner that, given the limited nature of the data processed as described above, is not overridden by the interests or fundamental rights and freedoms of the data subjects.
g. Compliance with Legal Obligations – In addition to processing Personal Data for the purposes of providing Web Hosting Services, we process Personal Data collected hereunder and Website Information to comply with our own legal and regulatory obligations. For example, we may process personal information to comply with: applicable international sanctions, “know your customer”, anti-money laundering regulations, anti-bribery compliance requirements, record keeping requirements, required public filings, reporting requirements, court order, law enforcement order, and other legal and/or regulatory requirements.
h. Legitimate Interests – We may also use Personal Data collected hereunder in circumstances other than as expressly described above in connection with the services we provide; provided, however that any such additional processing may only occur when there is a legitimate interest to do so that is not overridden by your data protection rights as required by applicable law. The types of processing/uses contemplated hereunder may include, without limitation, for our own administrative and business needs (tracking time, billing, invoicing, collection), audits and self-assessments for compliance with applicable laws, regulations, court order, law enforcement order, and applicable workplace policies, and for information technology purposes including without limitation trouble shooting, business continuity, disaster recover, data backup and recovery.
i. Data Retention – We generally retain Personal Data for the periods specified applicable law, regulation, and/or court order, and in our document retention/filing polices, currently set at seven years. We may also retain Personal Data for longer periods where there is a reasonable basis for retaining such data, including without limitation in connection with the establishment, exercise or defense of legal claims. We retain Web Hosting account information for a period of six (6) months after account closure due to an automated suspension process for nonpayment but credit card information is not retained by our third-party processor after account closure.
5. Optional Data Processing. In addition to processing Personal Data in the ways set forth above for purposes related to the provision of Web Hosting Services, you may also choose to allow us to use certain Personal Data as detailed below. The types of data processing described in this Section 6 are not necessary or integral to the performance of Web Hosting Services and we will not use Personal Data for such optional purposes except as expressly set forth in this Section 5;
- Information Requested – If you request information about our company, our affiliates, or our respective products and services, you may elect to provide personal contact information such as your name, your email address, your phone number, your company affiliation, and/or your mailing address. We may use your information to respond to your request.
- Opt-In Subscription or Mailing Lists – From time to time we may offer you the option of signing up, or having us sign you up, for various subscription and/or mailing lists used to send communications from our company for purposes of keeping investors, customers, and other registered recipients updated with respect to investor relations information about our company, news and developments, our company’s products and services, and other communications about our company and our affiliates (“Updates”). In order to register you on such subscription and/or mailing lists, we will ask for your name and email address. If you provide your personal information specifically to subscribe to a particular Update (e.g., our Investor Relations Newsletter), we will use the personal information you provide specifically to send you the requested Updates. In other cases, we will specifically ask for your consent to use such information on an opt-in basis; provided, you acknowledge that where particular uses of opt-in information are necessary to our performance of related Domain Name Services, we may not be able to continue performing the affected Web Hosting Service if you exercise your right to refuse, or later withdraw, your consent.
6. Onward Transfers – Data We Share With Others. We will not sell, share, transfer, disclose, rent, use, or distribute Personal Data hereunder for purposes other than as set forth in this Transparency Statement, unless required by law or as expressly authorized by a data controller as described above.
- Updates – We send Updates to the email address(es) provided at the time you subscribed and/or otherwise opted-onto various subscription lists for Updates using an email service provider called MailChimp. MailChimp is registered under the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks as “The Rocket Science Group LLC d/b/a MailChimp”.
- Weebly (Consent) – With every web hosting account registered with us, Pair offers a website builder tool from a third-party called “Weebly” at no additional charge to Registrants. We do not transmit your personal information to Weebly. Instead, upon successful registration of a web hosting account with us, Pair shares the domain name for Customer Websites hosted under such web hosting account with Weebly, along with a unique, special purpose “@weeb.pairdomains.com” or “@weeb.mypair.com” email address that is not personally identifiable to any actual person by anyone other than Pair. Any email that Weebly would like to send to you is sent to this special purpose email address, directed to Pair’s email servers. This address only accepts email sent from Weebly (all other senders are rejected.) Whenever we receive mail sent to that address, we scrub it for spam and viruses and then forward it to the real email address that we have for you as reflected in Account Information. In this manner, Weebly never has access to your name or your real email address, but is able to communicate with you about their service. We ask for your express consent to forward Weebly messaging to you in the manner described above. You acknowledge that, without your consent, Weebly will have no way to communicate with you about your use of their website builder tool and thus you may not be able to continuing using their services. You should review information about Weebly’s data handling policies and terms of service, available from their website (https://weebly.com/privacy).
- ShopSite (Consent) – We offer online commerce through the third-party ecommerce platform ShopSite. If you choose to use ShopSite to power ecommerce functionality on your website, after you have chosen to purchase ShopSite’s services, we will forward your designated domain names and hosting account user name (or such other user name as you may designate) to ShopSite to help establish your ShopSite store administration account, and your login for such account.