California Privacy Policy

Last updated: January 1, 2023

Effective Date: January 1, 2023

This section contains disclosures required by the California Consumer Privacy Act of 2018 (as amended by the California Privacy Rights Act of 2020, hereinafter “CCPA”) and applies only to processing personal information of California residents that is subject to the CCPA.

Categories of Personal Information Disclosed and Categories of Third Parties to Whom it was Disclosed

For Zenlayer Console customers, we may have disclosed your identifiers (e.g. name, address, email, phone number) and commercial information (e.g. products or services purchased, purchase history) to third-party service providers (e.g. Salesforce, NetSuite, Google Analytics, PostHog) in order to generate bills, provide support to the customers, optimize customer experience, and understand product usage, etc.

Categories of Personal Information Shared and Categories of Third Parties to Whom it was Shared

For the purposes of this California Privacy Policy, “shared” or “sharing” means transfer of personal information to third parties for cross-context behavioral advertising. The following categories of personal information may have been shared with a third party for cross-context behavioral advertising:

• Personal identifiers, such as your name, phone number, address and email address;

• Internet or other electronic network activity information, such as your IP address, type of browser, version of operating system, device identifiers, and mobile advertising identifiers; and

• Information about you and your use of the Zenlayer Console.

Each of the categories of personal information listed above may be shared with the following categories of third parties for cross-context behavioral advertising:

• Advertising publishers that place advertisements for us, such as Google, LinkedIn and Meta;

• Third parties that provide statistical and analytic information regarding the effectiveness of our marketing.

Zenlayer never sells your personal information for money. Zenlayer allows third parties to place tracking technologies like cookies and pixels on our Sites, which allow those companies to receive information about your activity on our Sites that is associated with your browser or device. The companies may use that data to serve you more relevant ads on our Sites. Under the CCPA, this may constitute “sale” of your personal information.

Zenlayer does not collect or use your sensitive personal information. Zenlayer does not knowingly sell or share the personal information of consumers under 16 years of age, unless we receive affirmative authorization (opt-in) from either the minor who is between 13 and 16 years of age, or the parent or guardian of a minor less than 13 years of age.

Retention of Personal Information

Zenlayer retains your personal information only for as long as is reasonably necessary to fulfill the purpose for which it was collected. However, if necessary, we may retain your personal information for longer periods of time, until set retention periods and deadlines expire, for instance where we are required to do so in accordance with legal, tax and/or accounting requirements set by a legislature, regulator or other government authority.

Your California Privacy Rights

If you are a resident of the state of California, you are entitled to make certain requests regarding your personal information. Zenlayer will fulfill each of the below requests per the requirements of California law.

1. Request to Access. You can request access to the personal information we may have collected about you.

2. Request to Correct. You can request us to correct inaccurate personal information we may have about you.

3. Request to Delete. You can request that we delete your personal information. We will delete your personal information to the extent required by law.

4. Do Not Sell My Personal Information. You can request us to opt out of the sale of your personal information to a third party.

5. Do Not Share My Personal Information. You can request us to stop sharing your personal information for cross-context behavioral advertising.

You can use this online request Form or email Zenlayer at [e-mail] if you are interested in exercising any of the above rights.

We will not discriminate against you for exercising your rights. This generally means we will not deny you goods or services, charge different prices or rates, provide a different level of service or quality of goods, or suggest that you might receive a different price or level of quality for goods. Please note that deleting your personal information may impact your ability to use our Sites and online features, including closure of your online account.

Verifying Your Identity

Because we want to avoid taking action regarding your personal information at the direction of someone other than you, only you or an authorized agent permitted to act on your behalf may submit a request. The CCPA also requires that we verify the identity of each person who makes a request to access, correct, or delete.

To verify your identity, we will ask you to provide your first name, last name, email address, state, and zip code in the online webform or email request. We will seek to match any personal information you provide when submitting your request to any personal information we already maintain. In some cases, we may ask you to provide additional information and/or documentation.

If we can’t verify your identity, we will notify you, and your request to access, request, or delete your personal information may not be processed. Any requests may be denied if we have reason to believe they are fraudulent.

Contact Us

If you have any comments or questions regarding the California Privacy Policy or our personal information handling practices, please email [e-mail]. You can also write to us at the following address:

Zenlayer, Inc.

Attn: Legal Department

21680 Gateway Center Dr.

Suite 350

Diamond Bar, CA 91765