PCN Privacy Policy, Effective July 12, 2020

Your privacy is important to PC Network Inc. (PCN, us, we, or our). This privacy statement explains our policies regarding the collection, use and disclosure of your personal information.

We will not use or share your information with anyone except as described in this Privacy Policy.

1.    Scope of this Privacy Policy.
This Privacy Policy applies to PCN Services, including: this website, the PCN DDI Portal, other applications and communications from or to the PCN-Inc.com domain, and PCN technology services, such as DNS, DHCP, and IP Address Management (DDI) which may involve the collection, processing, and transport of personal data (together, the Services). By using a PCN Service, you agree to the collection and use of information in accordance with this Privacy Policy.

Supplemental Privacy Notices: This Privacy Policy may be supplemented or amended by other privacy notices appearing on the Website or as part of a specific Service contract. Such privacy notices will explain how we handle information specific to where that privacy notice appears, and should be read together with this Privacy Policy.

Changes to this Privacy Policy: We may update this Privacy Policy to communicate changes in our data handling practices. When we make changes to this Privacy Policy, we will modify the Effective Date and post the new version at https://www.pcn-inc.com/terms-conditions-disclaimer/. Our changes will become effective immediately.

2.    Partner or Other Third-Party Privacy Policies
This Privacy Policy only applies to the use of information PCN collects from you through our Services. Our Services may be subcontracted to a third party from whom you are directly purchasing product and/or services (Partner). This Privacy Policy does not apply to information collected directly by our Partners or any other third party as we do not control these other privacy policies. However, PCN’s subcontracted Services may include PCN acting as a processor of your information for our Partner, in which case, this Privacy Policy would apply to PCN processed information.

If we utilize other companies as service providers, including our corporate affiliates and subsidiaries, we will not share your personal information with our service providers, unless it is required for the purposes of a legitimate business interest or to fulfill our Service obligations to you. These service providers may be contractually required to use any information we share with them only to perform services to us or on our behalf and to protect the confidentiality of your Data. We may also allow these companies to use anonymized information for their business purposes. We will not share your Personal Data with our affiliates, subsidiaries, or unrelated third parties to use for their own marketing purposes.

3.    How We Protect Your Information
PCN will implement and maintain appropriate technical and organizational measures to protect your Data and Personal Data. We have implemented physical, technical and administrative security practices and safeguards reasonably designed to protect your Data from unauthorized access and disclosure. When we collect or transmit sensitive information such as a financial account number, we use industry standard methods to protect that information as required by applicable laws. Although we use reasonable measures to protect your information, you are also responsible for taking reasonable steps to protect your information against unauthorized disclosure or misuse, for example, by protecting your password and logging off when finished using a shared computer or mobile device. PCNs security measures are detailed in PCN’s Security Policy. PCN will make that policy available to Customer, along with descriptions of the security controls in place for the Services and other information reasonably requested by Customer regarding PCN security practices and policies. In addition, those measures shall comply with the requirements set forth in ISO 27001.

4.    What information may be collected?
Personal Contact Information. If you request additional information or fill-in a contact form on our website or social media, you will provide us with personal contact information, such as name, company name, address, phone number, and email address. If you contact us directly via email, we may also collect information about you (or those of contacts that you choose to share with us) such as name, company name, address, phone number or email address. When you contact us for customer support, phone and ticketing systems will record and track personal contact information as well as data about the incident. Phone conversations or chat sessions with our representatives may be monitored and recorded.

Job Applicant Data. If you apply for a job with PCN, in addition to Personal Contact Information, we may also require you to submit additional personal information as well as a resume or curriculum vitae.

Billing Data. When executing a contract for purchasing the Services, PCN may also require you to provide corporate data, key contacts, credit references, financial qualification data, and billing information, such as billing name and address, banking information, and contact information for services recipients and billing and invoicing personnel.

Credentials. We collect passwords, password hints, and similar security information used for authentication and account access to systems in order for us to provide Services.

Device Data and Content. We may collect and/or process data about the devices we are managing for you, the content of files on those devices, and data from your communications when necessary to provide you with your contracted Services.

Website Metadata. As you navigate PCN’s website, we may also collect information through the use of commonly-used information-gathering tools, such as cookies and Web Site Navigational Information includes standard information from your Web browser (such as browser type and browser language), your Internet Protocol (“IP”) address, and the actions you take on the website (such as the pages viewed and the links clicked).

5.    How we Use or Share Data
All of the above information is referred to collectively as “Data;” some of it may qualify as “Personal Data” under the EU GPDR. PCN uses Data about to perform the Services requested. PCN does not ever sell or share Data with third parties except in compliance with this Policy.
Personal Contact Information. If you fill out a “Contact Me” Web form, PCN will use the information provided to contact you about your interest in the Services. This information will be used as part of delivering the Services, for project planning, execution, and when you contact us for customer support. We may use Personal Contact Information to contact you about past, current, or future business opportunities. These communications are not mass emails and are in line with the business communications and circumstances under which we originally received the information. You can opt out of communications from PCN at any time. Certain emails will have an opt out provision otherwise you can contact opt-out@pcn-inc.com.

Job Applicant Data. This data will be used to assess if you are a fit for any currently available positions and will be stored in a secure database for future reference if an appropriate position becomes available.

Billing Data. Billing data is used for invoicing and payment processes. We use payment data to complete transactions, as well as to detect and prevent fraud.

Credentials. Credentials are used for security purposes and to access systems in order to perform contracted Services.
Device Data and Content.

Device Data and Content. When we manage your technology, we may use the collected Data to create backup and restore files for disaster recovery or to collect key performance indicators to monitor the health of the server or to collect IP addresses in order to make a DDI change. We use Data to provide and improve the products and Services we offer and perform essential business operations. This includes operating the products, maintaining and improving the performance of the products and Services, developing new features, conducting research, and providing customer support. We use data to diagnose product problems, repair customers’ devices, and provide other customer care and support services.

Website Metadata. PCN may collect and use website metadata as follows:
Cookies. PCN uses cookies to make interactions with the PCN website easier and to enable certain functions, such as sign-in and authentication or to count the number of unique visitors to a web page. When you visit the website, PCN’s servers send a cookie to your computer or device. Standing alone, cookies do not personally identify you; they merely recognize your web browser. Most web browsers automatically accept cookies but provide controls that allow you to block or delete them. Instructions for blocking or deleting cookies in other browsers may be available in each browser’s privacy or help documentation. Please be aware that if you choose to block cookies, you may not be able to sign in or use certain features.

Log Files, IP Addresses, URLs and Other Data. As is true of most Web sites, we gather certain information automatically to analyze trends in the aggregate and administer our Web sites and Services. This information may include your Internet Protocol (IP) address (or the proxy server you use to access the World Wide Web), device and application identification numbers, your location, your browser type, your Internet service provider and/or mobile carrier, the pages and files you viewed, your searches, your operating system and system configuration information, and date/time stamps associated with your usage. Due to Internet communications standards, when you visit or use the website and Services, we automatically receive the URL of the website from which you came and the website to which you go when you leave our website. This information is used to analyze overall trends, to help us improve our Websites and Services, to track and aggregate non-personal information, and to provide the Websites and Services. For example, PCN uses IP addresses to monitor the regions from which Customers and Visitors navigate PCN’s Web sites. Salesforce also collects IP addresses from Customers when they log into the Services as part of PCN’s “Identity Confirmation” and “IP Range Restrictions” security features.

Unusual circumstances in which we may share Data:
In Connection with a Sale, Merger or related Event. If one of our corporate affiliates or a third party has acquired all or a part of our business, your Data will become owned by that company, unless otherwise provided for by the local legislation. In that event, the acquiring company’s use of your Personal Data will be subject to the governing Privacy Policy, any applicable supplemental privacy notices, and the privacy preferences you have expressed to the governing entity.

As required or permitted by applicable law. We may disclose Personal Data or Special Categories of Data about you when we believe disclosure is appropriate to comply with legal requirements, prevent fraud and crimes:
a.    to comply with the law or a regulatory requirement,
b.    to comply with governmental, administrative or judicial process, requirement or order (such as a court order),
c.    to cooperate with law enforcement or other governmental investigations or report any activities that may be in violation of legal or regulatory requirements,
d.    to prevent or investigate a possible crime (such as fraud or identity theft) or breaches (also suspected breaches) of security or of this Privacy Policy,
e.    to enforce a contract,
f.    to protect the legal rights, website or safety of PCN and our employees, Partners, third parties, the public in general or you.

6.    Where We Store and Process Personal Data (GDPR; International Transfer of Data)
PCN acts as a data controller in very limited situations—primarily when directly contacted by a data subject. Data collected by PCN may be stored and processed in your region, in the United States or in any other country where PCN or its affiliates, subsidiaries or service providers maintain facilities.

PCN is primarily a data processor or subprocesser performing specific Services as a subcontractor to Data Controllers. PCN currently processes data in Canada, the United Kingdom, the United States, and Vietnam. PCN Services are almost entirely remote. Typically, the Data is stored on systems in a customer’s or Data Controllers’s data center. PCN remotely accesses the systems to perform the processing activities required to fulfill the contracted Services. For example, monitoring and management of servers, migrating data from one server to another, server upgrades, troubleshooting incidents and outages, executing approved changes, etc.

By remotely accessing Data, PCN transfers personal data from the European Economic Area and Switzerland to other countries (primarily the United States and Canada), some of which have not been determined by the European Commission to have an adequate level of data protection. When we do, we use a variety of legal mechanisms, including contracts, to help ensure your rights and protections travel with your data. To learn more about the European Commission’s decisions on the adequacy of the protection of personal data in the countries where PCN processes personal data, please visit:
ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm

We take steps to ensure that the data we collect or process under this privacy statement is processed according to the provisions of this statement and the requirements of applicable law wherever the data is located.

7.    Your Choices about Your Data
If you would like to review, correct, restrict the processing thereof, object to direct marketing, or request erasure of your Personal Data or Special Categories of Data, please send us a request using the information in the “How to Contact Us” section of this Privacy Policy. For example, if there is any error in the Personal Data that you have submitted to us, please contact us and we will take appropriate measures to correct the error.

If you contact us we may ask you for additional information to verify your identity. We reserve the right to limit or deny your request if you have failed to provide sufficient information to verify your identity or to satisfy our legal and business requirements as noted in our data retention policy. When we delete your Personal Data or Special Categories of Data, it will be disposed of in a manner that prevents loss, theft, misuse, or unauthorised access in-line with our data retention policy.

You have the right to report to your local Supervisory Authority where you feel as though your rights under data protection legislation have not been appropriately considered. However, before doing so, please contact us directly as we are committed to working with you to help resolve any concerns about your privacy.

Where PCN is a processor or subprocessor under contract with a Data Controller, we will make available to Data Controller in a manner consistent with the functionality of the PCN Service and PCN’s role as a processor, the Personal Data of data subjects and the ability to fulfill data subject requests to exercise their rights under the GDPR. PCN shall comply with reasonable requests by the Data Controller to assist with Data Controller’s response to such a data subject request. If PCN receives a request from Data Controller’s data subject to exercise one or more of its rights under the GDPR in connection with a Service for which PCN is a data processor or subprocessor, PCN will redirect the data subject to make its request directly to Data Controller. Data Controller will be responsible for responding to any such request including, where necessary, by using the functionality of the Online Service. PCN shall comply with reasonable requests by Data Controller to assist with Data Controller’s response to such a data subject request.

8.    Data Retention Policy
PCN may retain your Data for as long as you continue to use our Services, and thereafter as permitted or required by applicable law or to fulfill legitimate business requirements.

9.    Marketing and Related-Communications
When you provide Personal Data, we may offer you a choice as to whether you would like to receive further marketing and related communications from us. These communications could be in the form of direct mail, email or telephone and will contain information to inform you of our products and services. You may opt-out of receiving these communications by e-mailing us at opt-out@pcn-inc.com, or by following any unsubscribe instructions in e-mail communications.

10.    Children’s Privacy
PCN’s website and Services are not directed at, nor targeted to, children. If you have not reached the age of majority, you may not use PCN’s website and Services unless necessary parental consent has been obtained. If you believe that we have received information from a person protected under child protection laws where necessary parental consent was not obtained, please notify us immediately, and we will take reasonable steps to securely remove that information.