GDPR and Privacy Shield Policy
Last Updated: November 20, 2018
Zscaler recognizes that the EU and Switzerland have established strict protections regarding the handling of Personal Data, including requirements to provide adequate protection for Personal Data transferred outside of the EU and/or Switzerland. To provide adequate protection for certain Personal Data relating to corporate customers, partners, vendors and employees that Zscaler receives in the U.S., Zscaler has elected to self-certify to the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks administered by the U.S. Department of Commerce ("Privacy Shield").
Zscaler complies with the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability. If there is any conflict between the terms in this Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.
For purposes of enforcing compliance with the Privacy Shield, Zscaler is subject to the investigatory and enforcement authority of the U.S. Federal Trade Commission. For more information about the Privacy Shield, see the U.S. Department of Commerce's Privacy Shield website located at https://www.privacyshield.gov. To review Zscaler's Privacy Shield certification, see the U.S. Department of Commerce's list of Privacy Shield certified companies located at https://www.privacyshield.gov/list.
This Policy also contains terms that reflect Zscaler’s commitment to comply with the General Data Protection Regulation (Regulation (EU) 2016/679) (the “GDPR”).
Personal Data Collection and Use
- User IDs obtained from the customer’s corporate directory and identifying the user, group and department within the customer’s organization;
- Transaction logs for all HTTP/HTTPS and non-HTTP/HTTPS transactions conducted by the customer;
- Public IP addresses in order to deduce the customer’s locations provisioned for use of the Products;
- Certificates and keys in order to allow the customer to selectively intercept SSL communications;
- Customer employee authentication information, including user IDs such as user email addresses and organization group and department information, in order to allow the customer to create granular access control policies and log security incidents;
- Billing and contact information (name, mailing address, phone number, email address, etc.) from partners and vendors;
- Other data provided by a customer, vendor, or partner to facilitate Zscaler’s provision of the Products or to allow Zscaler to receive services.
Zscaler also receives human resources data from its employees in the EU and/or Switzerland to manage various aspects of the employment relationship. Zscaler’s handling of this data is subject to internal corporate policies that are consistent with the Privacy Shield. Zscaler commits to cooperate with EU data protection authorities and the Swiss Federal Data Protection and Information Commissioner (FDPIC) and comply with the advice given by such authorities with regard to human resources data transferred from the EU and Switzerland in the context of the employment relationship.
We process Personal Data only for the purpose of providing services to our customers and for any other purpose authorized by the data subject or data controller. Zscaler will only process Personal Data in ways that are compatible with the purpose for which Zscaler collected the Personal Data, or for purposes that the individual or entity providing the Personal Data later authorizes. Before we use your Personal Data for a purpose that is materially different than the purpose for which it was collected or that you later authorized, we will provide you with the opportunity to opt out. Zscaler maintains reasonable procedures to help ensure that Personal Data is reliable for its intended use, accurate, complete, and current.
We do not collect any Personal Data that is considered sensitive personal information under the GDPR or Privacy Shield.
Data Transfers to Third Parties
Third-Party Agents or Service Providers
Disclosures for National Security or Law Enforcement
Under certain circumstances, we may be required to disclose your Personal Data in response to valid requests by public authorities, including to meet national security or law enforcement requirements.
Zscaler maintains reasonable and appropriate security measures to protect Personal Data from loss, misuse, unauthorized access, disclosure, alteration, or destruction in accordance with the GDPR and Privacy Shield.
Data Access and Portability Rights
You may have the right to access the Personal Data that we hold about you and to request that we correct, amend, or delete it if it is inaccurate or processed in violation of the GDPR or Privacy Shield. These access rights may not apply in some cases, including where providing access is unreasonably burdensome or expensive under the circumstances or where it would violate the rights of someone other than the individual requesting access. If you would like to request access to, correction, amendment, or deletion of your Personal Data, you can submit a written request using the contact information in the "Contact Us" section below. We may request specific information from you to confirm your identity. In limited circumstances we may charge a reasonable fee for access to your information.
You have the right to receive your Personal Data in a structured, commonly used and machine-readable format and the right to transmit your Personal Data to another data controller without hindrance from Zscaler.
Questions or Complaints
In compliance with the Privacy Shield Principles, Zscaler commits to resolve complaints about our collection or use of your Personal Data.
Zscaler has further committed to refer unresolved Privacy Shield complaints to the International Centre for Dispute Resolution, which is the international division of the American Arbitration Association (“ICDR/AAA”), located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact or visit the ICDR/AAA at http://go.adr.org/privacyshield.html for more information or to file a complaint. The services of the ICDR/AAA are provided at no cost to you.
You may have the option to select binding arbitration for the resolution of your complaint under certain circumstances, provided you have taken the following steps: (1) raised your complaint directly with Zscaler and provided us the opportunity to resolve the issue; (2) made use of the independent dispute resolution mechanism identified above; and (3) raised the issue through the relevant data protection authority and allowed the U.S. Department of Commerce an opportunity to resolve the complaint at no cost to you. For more information on binding arbitration, see U.S. Department of Commerce's Privacy Shield Framework: Annex I (Binding Arbitration) at http://ec.europa.eu/justice/data-protection/files/annexes_eu-us_privacy_shield_en.pdf.
If you have any questions about this Policy or would like to request access to your Personal Data, please contact us as follows:
Attn: Privacy Department
110 Rose Orchard Way
San Jose, CA 95134, USA
Email: [email protected]
Changes To This Policy
We reserve the right to amend this Policy from time to time consistent with the Privacy Shield's requirements and the GDPR.