We respect your privacy and are committed to protecting your personal data. This Privacy Notice will inform you as to how we look after your personal data when you visit our website(s) (regardless of where you visit from) or use our services, products or otherwise provide personal data to us. This notice will also tell you about your privacy rights and how the law protects you.

Asavie (now known as Akamai), its subsidiaries and partner companies (“us”, “we” or “our”) is committed to protecting and respecting your privacy. The Privacy Notice, End User Licence Agreement and the documents referred to or linked in them set out the basis for which any data we collect from you or that you provide to us (“Data”) will be processed by us.

Please read this Privacy Notice carefully to understand our treatment and use of Data. For the purposes of the Data Protection Acts 2018, and any subsequent amendment (the “Acts”), the data processor is Akamai Technologies Ireland Limited, a private limited company and registered in Ireland (Registered Number 390724) and having its address at 100 Mount Street Lower, Grand Canal Dock, Dublin 2, D02 TY46, Ireland. Akamai is not the data controller for the purposes of the Acts. Should you require any information regarding how your data is controlled, you should consult the Data Controller Privacy Notice (typically this will be your employer) to understand how the Data Controller processes your data.

This Privacy Notice aims to give you information on how we receive and process your personal data to perform the requirements of the agreed contract(s).

Unless otherwise agreed, our website(s), products and services are not intended for children and we do not knowingly collect data relating to children. Children under the age of 13, or equivalent minimum age in the relevant jurisdiction, are not permitted to use the Site or Application except where such use is in the provision of services to educational institutions and, in those cases, use must be compliant with COPPA/GDPR requirements. If we learn that we have collected the personal information of a child under 13, or equivalent minimum age depending on jurisdiction, we will take steps to delete the information as soon as possible. Please contact us with any such information.

It is important that you read this Privacy Notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Privacy Notice supplements any other such notices and is not intended to override them.

The website(s), products and services may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party website(s), products or services and are not responsible for their privacy statements. When you leave our website(s), products, or services, we encourage you to read the privacy notice of the 3rd Party website(s), products, or service.

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you to provide the service, which we have grouped together as follows:

When accessing our product Administrative console, the configured administrator email addresses and any associated Name or Identifier is recorded. An optional email address and textual description can be configured for your devices. If provided, then Akamai services will collect and process this information. The email address is an option to invite a device to setup the service while the device description aids understanding of the reporting and alerting provided.

Contact Data includes billing addresses, email addresses as noted in section 3.1 and telephone numbers.

Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to contact us or access this website. For managed devices where the Application is used as the mobile device manager, then the Application may configure a password policy for the device, lock the device, initiate a remote wipe and collect the names of applications installed on the device. The application name data will only be collected if you enable the App Control feature in the Application management portal.

For devices using the Application the location of the device may be captured if location services are enabled. The MSISDN (Phone number) is collected in the case of registration via SMS, this information is ephemeral and is used only to link to the relevant account. Any relevant information will be collected only if allowed by the user, this will be in the form of a visual cue which the user must explicitly opt-in. These prompts are limited explicitly to location and VPN.

When devices use our service the Device number (MSISDN & IMEI), time and date the Device is accessing the network over mobile data or Wi-Fi, the amount of data sent and received, the location of access, websites accessed and the type of website accessed, website access attempts blocked and the type of website access attempt blocked due to policy enforcement actions are all recorded. These data points are all required to deliver the service offered and to perform the contract.

The Application makes use of cookies on the website(s) to support analysis and understanding of how people interact with the Application. We perform this analysis to help us improve the interface and effectiveness of the Application. Akamai uses cookies that are session-based and persistent-based. Session cookies exist only during one session. They disappear from your computer when you close your browser software or turn off your computer. Persistent cookies remain on your computer after you close your browser or turn off your computer. Please note that if you disable your Web browser’s ability to accept cookies, you will not be able to successfully use the Site. The data collection and reporting behind this analysis is currently provided by Google Analytics and Intercom. Further details on use of cookies may be found in our cookie statement here.

We use third-party analytics services to help understand your usage of our services. In particular, we provide a limited amount of your information (such as sign-up date and some personal information like your email address) to Intercom, Inc. (“Intercom”) and utilize Intercom to collect data for analytics purposes when you visit our website or use our product. As a data processor acting on our behalf, Intercom analyses your use of our website and/or product and tracks our relationship by way of cookies and similar technologies so that we can improve our service to you. For more information on Intercom's use of cookies, please visit https://www.intercom.com/terms-and-policies#cookie-policy. We may also use Intercom as a medium for communications, either through email, or through messages within our product(s). The Intercom Messenger Apps and Apps in Inbox products may also provide you with access to other third-party applications such as NativeForms. You should consult these third parties' privacy notices for further information on their use of your personal data. For more information on the privacy practices of Intercom, please visit here. Intercom’s services are governed by Intercom’s terms of use which can be found at here.

We may also collect, and use, Aggregated Data such as statistical or demographic data to improve our products and services. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity.
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For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Notice.
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We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
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If you fail to provide personal data where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you.

We use different methods to collect data from and about you including through:

You may give us your Identity, Contact and Financial Data filling in forms or by corresponding with us by post, phone, email, or otherwise. This includes personal data you provide when you interact with our website(s), products, or services.

As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.

When you use our service, we automatically collect the information outlined in section 3.

We may receive personal data about you, to be able to provide the services we offer, from various third parties as set out below:

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances where:

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw your consent to marketing at any time by contacting us at privacy@akamai.com or using the available unsubscribe features in the communication.

We may use your Data that we process to:

For customers using Akamai Self-Serve Analytics offerings, and to fulfil the contract as requested in these cases, Akamai must share the necessary data with Microsoft (Power BI) and/or Tableau. Only users authorised by the customer have access to the data presented in these 3rd Party Applications.

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at privacy@akamai.com. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

We may have to share your personal data with the parties set out below for the purposes set out in the table above.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

Our products are managed via management interfaces (either the Web UI or API) that are designed to be served to the Customer Administrator from their home region, being one of EU, US or APAC, using data sets stored in that region, with the exception of provisioning (Categorisation Rules for example) and billing information which is stored in the EU or APAC.
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Our products are delivered to end-users in their home region, being one of EU, US or APAC, using data sets stored in that region.

When undertaking any type of data transfers, we use contracts approved by the European Commission which give personal data the same protection it has in the European Union. We establish the adequacy of any non-EU region regarding that region’s Privacy Laws, ensuring they provide similar levels of protection to those offered by the GDPR (or similar regional Privacy Legislation) before any transfers are undertaken. Please contact your Data Controller (typically your employer) or contact us at privacy@akamai.com if you want further information on the mechanisms used to store or transfer your data in the provision of our services and products.

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorised way, altered, or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who must have such access to supply or maintain our services. All staff are trained in Data Security and Data Privacy and understand their responsibilities when processing customer data and will only process your personal data on your instructions, as needed by contract.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable supervisory authority or other regulator of a breach where we are legally required to do so.

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the type, amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

By law we must keep some information about our customers (including Contact, Identity, Financial and Transaction Data) after they cease being customers for tax and other legal purposes. These are outlined in our Data Retention Policies. We only ever keep such information to comply with local or regional legal requirements.

In some circumstances you can ask us to delete your data: see below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please read below to find out more about these rights.

To request access to your personal data or to exercise any of the rights set out above, please contact us please contact privacy@akamai.com.

For general queries regarding your rights, please contact your Data Controller (typically your employer) or contact us at privacy@akamai.com.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated.

Access Request: You can request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Data Correction: You can request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Data erasure: You can request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Objecting to Processing: You can object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have a compelling legitimate ground to process your information which overrides your rights and freedoms.

Restriction of Processing: You can request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request a Data Transfer to 3rd Party: You can request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw Consent: You can withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain offerings to you. We will advise you if this is the case at the time you withdraw your consent.

Legitimate Interest means our interest in conducting and managing our business to enable us to give you the best offering and the best and most secure experience; we make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests; we do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law); you can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us at privacy@akamai.com.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Internal Third Parties are other companies in Akamai based in the EEA that provide IT and system administration services and marketing services to Akamai.

External Third Parties are

the Revenue Commissioners, regulators and other authorities acting as processors or joint controllers based in Ireland who require reporting of processing activities in certain circumstances.

Note that if you are based outside of the EEA, then some of the parties described may also be outside the EEA.