Privacy Statement

1. Introduction

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

The LL-IX Privacy Policy not only describes why LL-IX 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 or +40316302361. Physical correspondence can be directed to the LL-IX Office: Dr. Petre Herescu 12 str., ground floor, apt. 2 Bucharest, Sector 5, Romania.

2. Processing your personal data

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

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

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

2.1 Processing personal data to support the IXP functionality

2.1.1 Types of data collected from customers

In order to use the LL-IX IXP service, Autonomous Systems become a customer of LL-IX. The ordering of the LL-IX 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 LL-IX. This means that to provide customers with the IXP service, or to perform a function related to the IXP service, LL-IX 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:

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

LL-IX 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 LL-IX 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, LL-IX considers the customer to have given consent for this information to be published.

2.1.2 How these data, including personal data, is collected

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

LL-IX may receive and/or collect data, including personal data, from:

2.1.3 How LL-IX uses these collected data

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

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

LL-IX 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 LL-IX 

Use of LL-IX mailing lists

Lists include names and mail addresses of those subscribed, and messages sent include name, email address, date and the message content. Messages are archived, not publicly, and visible to others who are subscribed to the same list(s).

LL-IX uses mailing lists for:

2.3 How LL-IX shares data

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

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

2.4 How long LL-IX retains personal data

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

LL-IX retains customer correspondence until 18 months after the Connection Agreement has been terminated. The same applies to personal customer contact-details as retained in the LL-IX customer portal, i.e. after the Connection Agreement has terminated. The Connection Agreement itself is retained for two years after termination. Unless longer retention is required by law.

3. Protection and secrecy of personal data

LL-IX maintains strict procedures to authenticate people's identification and verify their right to authorise changes in the LL-IX customer-portal

Personal data held by LL-IX is not publicly available and authorised customer representatives can only see their own organisation’s details after logging in, including the registered contacts for their organisation.

LL-IX 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. 

4. Visitors to the LL-IX website, use of Cookies

When the LL-IX website 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 LL-IX website uses cookies that:

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

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

LL-IX uses Google Analytics for . 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 LL-IX 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.

5. Accessing and changing information

Data subjects have the right to ask LL-IX 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, LL-IX may request data subjects to identify themselves.

LL-IX customers have the possibility to access registered data via the LL-IX customer portal. Persons registered as being authorised can access and change personal contact details using the customer portal on behalf of their organisation. LL-IX will always help those who may have trouble modifying their own data.

Those subscribed to LL-IX mailing lists, can unsubscribe at any time or change preferences by accessing this web page. Contact us for requests or in case there are questions or concerns about the accuracy or appropriateness of any other personal data held by LL-IX. LL-IX will respond and seek to correct any problems as soon as possible.

6. Changes to this privacy statement

LL-IX 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.