Privacy Shield Policy
Zscaler recognizes that the EU has established strict protections regarding the handling of EU Personal Data, including requirements to provide adequate protection for EU Personal Data transferred outside of the EU. To provide adequate protection for certain EU 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. Privacy Shield Framework administered by the U.S. Department of Commerce ("Privacy Shield"). Zscaler adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability.
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.
Personal Data Collection and Use
Zscaler may receive the following categories of personal data from the EU:
- 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. Transaction logs are generated by Zscaler, not provided by the customer;
- Public IP addresses in order to deduce the customer’s locations provisioned for use of the Zscaler services;
- 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.
Zscaler also receives human resources data from its employees in the EU 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.
We process EU 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 EU Personal Data in ways that are compatible with the purpose for which Zscaler collected the EU Personal Data, or for purposes that the individual or entity providing the EU Personal Data later authorizes. Before we use your EU 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 EU Personal Data is reliable for its intended use, accurate, complete, and current.
We do not collect any EU Personal Data that is considered sensitive personal information under the Privacy Shield.
Data Transfers to Third Parties
Disclosures for National Security or Law Enforcement. Under certain circumstances, we may be required to disclose your EU 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 EU Personal Data from loss, misuse, unauthorized access, disclosure, alteration, or destruction in accordance with the Privacy Shield.
You may have the right to access the EU 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 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 EU Personal Data, you can submit a written request to the contact information provided below. We may request specific information from you to confirm your identity. In some circumstances we may charge a reasonable fee for access to your information.
Questions or Complaints
You can direct any questions or complaints about the use or disclosure of your EU Personal Data to us as noted below (Contact Us). We will investigate and attempt to resolve any complaints or disputes regarding the use or disclosure of your EU Personal Data within 45 days of receiving your complaint. For any unresolved complaints, we have agreed to cooperate with the International Centre for Dispute Resolution, which is the international division of the American Arbitration Association (“ICDR/AAA”). If you are unsatisfied with the resolution of your complaint, you may contact the ICDR/AAA at http://info.adr.org/safeharbor/
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 compliant 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 EU Personal Data, please contact us as follows:
Attn: Legal Department
110 Rose Orchard Way
San Jose, CA 95134, USA
Changes To This Policy
We reserve the right to amend this Policy from time to time consistent with the Privacy Shield's requirements.
Effective Date: September 1, 2016
Last modified: September 1, 2016