Privacy Policy

GENERAL INTRODUCTORY:

1-IX.EU is committed to respecting and protecting all personal data it processes. This 1-IX.EU Privacy Statement gives an overview of the practical translation of this commitment into 1-IX.EU’s operations. It explains how 1-IX.EU collects, uses, shares, holds and retains personal data as required in the normal course and scope of 1-IX.EU’s business. Personal data is considered any information relating to an identified or identifiable natural person as defined by applicable privacy law1.

The 1-IX.EU Privacy Statement not only describes why 1-IX.EU processes personal data and how, but also how these data can be accessed, changed and deleted by data subjects.

For any questions, suggestions or concerns about or related to this document, please contact us by email law@1-IX.EU . Physical correspondence can be directed to the 1-IX.EU post office WARSAW: ul. ADAM BRANICKI, No. 21, apt. U3, seats. WARSAW, code 02-972, POLAND, law@1-IX.EU.

 

Handling your personal data

The main reason that 1-IX.EU processes personal data is to support its role as an Internet Exchange Point (IXP). As an IXP, 1-IX.EU facilitates the interconnection of networks, so called Autonomous Systems, so they can exchange IP-traffic between each other. This is the 1-IX.EU IXP service.

Autonomous Systems who want to become 1-IX.EU customers enter into a contract, a Connection Agreement, for which 1-IX.EU needs to process personal data.

In addition to the establishing of the Connection Agreement, 1-IX.EU processes personal data to perform additional activities for the benefit of 1-IX.EU customers and to support the offering of the 1-IX.EU IXP service. We also process personal data of persons visiting our website.

 

Processing personal data to support the IXP functionality

Types of data collected from customers

In order to use the 1-IX.EU IXP service, Autonomous Systems become a customer of 1-IX.EU. The ordering of the 1-IX.EU IXP service requires the customer to fill in an online application form that amongst others specifies roles for a set of named individuals who can perform certain responsibilities on behalf of the customer when interacting with 1-IX.EU. This means that to provide customers with the IXP service, or to perform a function related to the IXP service, 1-IX.EU collects and processes data from and about these customers that include personal data relating to private individuals (i.e. managers and other employees).

The following types of data are included:

  • General customer contact details (such as the customer’s organization name, address and contact phone number), in addition to the name, position and email address of members of staff who formally contact or interact with 1-IX.EU on behalf of the customer; 
     
  • Customer billing details or other financial information; 
     
  • Records of each customer’s use of the 1-IX.EU IXP service and the customer’s communications with 1-IX.EU: this can be the customer’s order history with 1-IX.EU as well as email-correspondence between customer representatives and 1-IX.EU.

The collection of the included personal data is necessary for the performance of the Connection Agreement.

1-IX.EU does not publish the personal contact details provided by customers. Only the generic peering-contact email-address provided is mentioned on the connected networks list on the 1-IX.EU website so Autonomous Systems can reach out to each other to negotiate peering relations... If a customer decides to use a personal contact-email address for this, 1-IX.EU considers the customer to have given consent for this information to be published.

 

How these data, including personal data, is collected

Besides the use of the online application that customers use to order the 1-IX.EU IXP service (see 2.1.1), 1-IX.EU collects data, which might include personal data, when customers interact directly with 1-IX.EU. For example, 1-IX.EU collects information when representatives from (prospect) customers provide information to 1-IX.EU or send emails to 1-IX.EU, or when customer details are entered on the 1-IX.EU website.

1-IX.EU may receive and/or collect data, including personal data, from:

  • Anyone authorized to act on a customer’s behalf;
  • 1-IX.EU employees, agents, contractors and suppliers; 
     
  • Credit reporting bodies; 
     
  • Other telecommunication and information service providers, often other 1-IX.EU customers;
     
  • Public sources.

How 1-IX.EU uses these collected data

1-IX.EU uses data collected to the extent necessary to provide customers with the 1-IX.EU IXP service as well as related support. In doing so, 1-IX.EU may use these data, which might include personal data, for related purposes as required in the normal course and scope of 1-IX.EU’s business, such as:

  • Processing a customer’s application to become an 1-IX.EU customer: this is necessary for the performance of the Connection Agreement;
  • Additional orders from existing 1-IX.EU customers: this is necessary for the performance of the Connection Agreement; 
     
  • Carrying out checks for credit-worthiness of prospect customers: this is necessary for the purpose of the legitimate interests pursued by 1-IX.EU; 
     
  • Provisioning the IXP service to the customer: this is necessary for the performance of the Connection Agreement 
    ;
  • Dealing with customer enquiries and providing customers with customer support: this is necessary for the purpose of the legitimate interests pursued by 1-IX.EU;
     
  • Managing the service provided to the customer by 1-IX.EU, including account management, billing, processing payments and collecting debts: this is necessary for the performance of the Connection Agreement; 
     
  • Investigating complaints and carrying out dispute resolution: this is necessary for the purpose of the legitimate interests pursued by 1-IX.EU; 
     
     
  • Administering 1-IX.EU’s agreement with each customer: this is necessary for the performance of the Connection Agreement.

Other uses (processing) of personal data by 1-IX.EU besides for providing the IXP service and related support

1-IX.EU also processes personal data when sending mailings to customers, and to organise and host events and meetings. This is necessary for the purpose of the legitimate interests pursued by 1-IX.EU 

1-IX.EU may also publish lists of registered attendees on a website, with their consent, as part of its commitment to openness and transparency. The publishing of these lists is a common industry tool for attendees to prepare themselves for the meeting and set-up meetings with and contact other attendees of interest. These lists contain the names of the attendees and their organizations, but no contact details or other personal details. Opting out of having one’s name and organization published on the attendee-list is an option. If one’s name has been published on an 1-IX.EU website as part of a list of attendees of an event or meeting and one wish to be deleted from the list, please contact our Marketing team sales@1-ix.eu.

 

How 1-IX.EU shares data

1-IX.EU shares data with other organizations to the extent necessary for the delivery of the 1-IX.EU IXP service to customers, or when required by law.

1-IX.EU will only share customer information for marketing purposes (limited to mailings and events) after consent has been given. In particular, 1-IX.EU may disclose data, including personal data, to:

  • 1-IX.EU’s suppliers like colocation providers and resellers of the 1-IX.EU service so 1-IX.EU can supply the IXP service to the customer; 
     
  • 1-IX.EU’s out-sourced service providers who perform supporting functions and services on 1-IX.EU’s behalf, such as:
    - first line support services;
    - event services;
    - IT and cloud services;
    => in all these cases processing agreements are in place to see to it that the third parties, where 1-IX.EU is controller, comply with applicable data protection legislation;
     
  • Credit reporting bodies;
  • 1-IX.EU’s legal, accounting and financial advisers.

How long 1-IX.EU retains personal data

1-IX.EU will store personal data only as long as needed to satisfy the above purposes for which it was collected or as required by law.

1-IX.EU retains customer correspondence until 18 months after the Connection Agreement has been terminated. The Connection Agreement itself is retained for two years after termination. Unless longer retention is required by law.

Registration data for events organized by 1-IX.EU as well as public attendee lists are deleted six months after the event has taken place.

3. Protection and secrecy of personal data

1-IX.EU maintains a high level of physical security and protection for all its computer, storage and network facilities that are involved in the processing of personal data. 

Visitors to the 1-IX.EU website, use of Cookies

When the 1-IX  website https://1-IX.EU is visited, small files are recorded on the visitor’s computer (or any other device that is used to visit the website) through the visitor’s web browser. These files, called ‘cookies’, help enable website features and functionality while browsing the website.

The 1-IX.EU website uses cookies that:

  • Are strictly necessary for the provision of the services that are available through the website and facilitate the use of these services 
  • Improve the website experience by recording information about settings (e.g. your location)
  • Collect anonymous statistical information on the use of the website that helps 1-IX.EU improve the performance of the 1-IX.EU website (e.g. the number of visitors to each part of our websites and their origin)

For detailed information about the cookies used by 1-IX.EU, the purpose of these cookies and the period they remain active, please see the dedicated 1-IX.EU cookie policy. 

1-IX.EU will use the above information only to the extent required for 1-IX.EU’s legitimate interests, or where this is necessary to help provide requested 1-IX.EU IXP service to member or customer. 
 

1-IX.EU uses Google Analytics www.1-IX.EU . This tool helps us keep track of the use of the website: which pages are visited and how long do visitors stay there. This data helps us improve our website to offer visitors a better browsing experience. The cookies set by Google because of this do not contain or collect personal identifiable information.

During a visit to the 1-IX.EU website, other third parties may also set cookies on a visitor’s device. These cookies are set when a page is visited which has content embedded from third party sites, such as YouTube.

One can disable cookies, or specifically third party cookies, by adjusting the web browser settings. Please check the “help” menu of the browser for information about how to change the cookie preferences. However, if all cookies are disabled, one may not be able to use all supported website features.

Accessing and changing information

Data subjects have the right to ask 1-IX.EU to provide access to, rectify or delete any data relating to them or to restrict the processing of data relating to them. Furthermore, data subjects have the right to object against processing, and to request data in a standardized, machine-readable format (data portability).

In order to fulfil its obligations in this respect, 1-IX.EU may request data subjects to identify themselves.

Changes to this privacy statement

1-IX.EU may change this privacy statement from time to time, either because of internal or regulatory changes, or following feedback received. The latest version of the privacy statement is available here. We will proactively notify our customers and suppliers on substantive or material changes to this privacy statement.