Cogent and its subsidiaries and affiliates (“we”, “our”, “us”) are committed to protecting and respecting your privacy.
Effective January 1, 2020, the California Consumer Privacy Act of 2018 (as it may be amended, “CCPA”) provides new privacy rights to consumers who are residents of California, including rights to access and delete their own personal information upon receipt of a verifiable request. The CCPA also gives consumers the right to opt out of the sale of their personal information. For now, the CCPA does not apply to the personal information of a business’s employees or other members of their workforce, nor does it include personal information exchanged in a business-to-business communications or transactions, including provision of services.
This policy sets out the basis on which we will process any personal information or usage information we collect from you, or that you provide to us, in connection with your use of the different Cogent websites that link to this policy (the “Websites”) or with your use of our services.
Please read this policy carefully so that you understand your rights in relation to your personal information, and how we will collect, use and process your personal information.
What types of information do we collect and how we use it?
Information you give us. You may provide information by contacting us via our Websites, email, telephone or by creating an account in our customer portal, eCogent.
As it is in our legitimate interests to be responsive to you and to ensure the proper functioning of our products and organization, we will use your information to:
- communicate with you via email or telephone;
- administer and provide services and customer support to our customers; or
- enforce our Website terms and conditions.
Technical usage information. When you visit the Website, we collect the information sent to us by your computer, mobile phone, or other access device. This information includes:
- your IP address;
- device information including, but not limited to, identifier, name, and type of operating system;
- mobile network information; and
- standard web information, such as your browser type and the pages you access on our Website.
We collect this information in order to:
- personalize our Website to ensure content from the Website is presented in the most effective manner for you and your device;
- monitor and analyze trends, usage and activity in connection with our Website and services to improve the Website;
- administer the Website and for internal operations, in order to conduct troubleshooting, data analysis, testing, research, statistical and survey analysis;
- keep the Website safe and secure; or
- measure and understand the effectiveness of the content we serve to you and others.
We also use Google Analytics which is a web analytics tool that helps us understand how users engage with the Website. Like many services, Google Analytics uses first-party cookies to track user interactions as in our case, where they are used to collect information about how users use our site. This information is used to compile reports and to help us improve our Website. The reports disclose website trends without identifying individual visitors. You can opt out of Google Analytics without affecting how you visit our site – for more information on opting out of being tracked by Google Analytics across all websites you use, visit this Google page: https://tools.google.com/dlpage/gaoptout.
We ask that you not send us, and you not share, any sensitive Personal Information (e.g., government-issued or financial account numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, genetic, or biometric data, criminal background or trade union membership).
How do we share your personal data?
- Cogent-affiliated companies in the United States which store your personal data, to provide for disaster recovery, as well as for the performance of any contract we enter into with you; and
- IT Services providers that provide us with SaaS services, including Salesforce who we use to store our customer relationship management information.
Comply with Legal Requirements and Corporate Transactions. Cogent may disclose your Personal Information as we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence, for national security and/or law enforcement purposes; (d) to enforce our terms and conditions; and (e) to allow us to pursue available remedies or limit the damages that we may sustain. Additionally, in the event of a reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings), we may transfer the Personal Information we have collected to the relevant third party.
The security of your personal data
Unfortunately, the transmission of information via the internet or email is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your information transmitted through the Website or over email; any transmission is at your own risk. Once we have received your information, we will take appropriate technical and organizational measures to safeguard your personal data against loss, theft and unauthorized use, access or modification.
We will, from time to time, host links to and from the websites of our affiliates or third parties. If you follow a link to any of these websites, these websites will have their own privacy policies and we do not accept any responsibility or liability for these policies. Please check these policies before you submit any information to those websites.
Right to Know: You have the right to request that we disclose to you the following:
(1) The categories of personal information we have collected about you.
(2) The categories of sources from which the personal information is collected.
(3) The business or commercial purpose for collecting or selling personal information.
(4) The categories of third parties with whom we share personal information.
(5) The specific pieces of personal information we have collected about you.
We will comply upon receipt of a verifiable request from you.
Right to Deletion. You may request that we delete the personal information we hold about you by sending us a verifiable request. We have no obligation to comply with your request to delete your personal information if it is necessary for us to maintain your personal information in order to:
(1) Complete the transaction for which the personal information was collected, provide the service requested by you, or reasonably anticipated within the context of a business’s ongoing business relationship with you, or otherwise perform a contract between the business and you.
(2) Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity.
(3) Debug to identify and repair errors that impair existing intended functionality.
(4) Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law.
(5) Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code.
(6) Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the businesses’ deletion of the information is likely to render impossible or seriously impair the achievement of such research, if you have provided informed consent.
(7) To enable solely internal uses that are reasonably aligned with the expectations of the consumer based on the consumer’s relationship with the business.
(8) Comply with a legal obligation.
(9) Otherwise use the consumer’s personal information, internally, in a lawful manner that is compatible with the context in which the consumer provided the information.
Right to opt-out. You have the right, at any time, to direct a business that sells personal information about you to third parties not to sell your personal information. We do not sell your personal information, so this right does not apply to you.
Non-Discrimination. We will not discriminate against you because you exercised any of your rights stated herein, including, but not limited to, by:
(1) Denying services to you.
(2) Charging different prices for services, including through the use of discounts or other benefits or imposing penalties.
(3) Providing a different level or quality of services to you.
(4) Suggesting that you will receive a different price for services or a different level or quality of services.
Nothing prohibits us from charging you a different price or rate, or from providing a different level or quality of services to you, if that difference is reasonably related to the value provided to you by your information. We do not offer any financial incentives, including payments to you as compensation, for the collection of personal information, the sale of personal information, or the deletion of personal information.
We may update this policy from time to time. Any changes we will make to this policy in the future will be posted on this page. Please check back frequently to see any updates or changes to this policy.
Information Privacy Contact
Cogent Communications, Inc.
2450 N. St., NW
Washington, DC 20037
You can also review our general privacy practices and commitments at https://www.cogentco.com/en/privacy-policy.
Last updated: January 1, 2020