Rowan Digital Infrastructure Privacy Policy
Your privacy is important to Rowan Digital Infrastructure and its affiliates (together, “Rowan”, “our”, “us”, or “we”). This privacy policy (the “Privacy Policy”) explains how we collect, use, disclose, and protect personal information.
This Privacy Policy applies to information we collect:
- From and about visitors of this website.
- In communications, including email, text, chat, and other electronic messages.
- From and about representatives of, or individuals in connection with, our actual or prospective vendors or business partners.
- Through other data collection points where we refer to this Privacy Policy.
This website is intended for business, investor, landowner, vendor, and general informational use related to our data center development. Please read this Privacy Policy carefully. By interacting with our website or other data collection points or providing us with your information, you acknowledge and, where applicable, agree to the collection, use, and sharing of your information as described in this Privacy Policy.
This Privacy Policy may change from time to time. Your continued use of the website after we make changes as described here is deemed to be acknowledgment and acceptance of those changes, so please check this Privacy Policy periodically for updates.
This Privacy Policy does not apply to any processing of personal information by or on behalf of Rowan that is covered by a more specific privacy policy.
- If you are a resident of California, you should also refer to our [California Privacy Policy].
- If you are located in the United Kingdom (the “UK”), the European Union (the “EU”), the European Economic Area (the “EEA”), or Switzerland, or the processing of your personal data would otherwise be subject to applicable laws and regulations relating to privacy, protection or processing of personal data in the EEA, EU, UK, or Switzerland, including the EU General Data Protection Regulation (2016/679) (“EU GDPR”), the UK’s equivalent to the EU GDPR (the “UK GDPR”) and the Swiss Federal Act on Data Protection (collectively, the “EEA-UK Data Protection Laws”), in addition to the details contained in this Privacy Policy, please also refer to our [EEA-UK Website Privacy Notice].
| Children’s and Minors’ Data |
Our website is not intended for, and we do not knowingly collect any personal information from, children under the age of 18. If we learn we have collected or received personal information from a child under 18 years old without verification of parental consent, we will delete that information.
The Personal Information We Collect
For the purposes described in this Privacy Policy, the types of personal information we collect or process include:
- Your basic information: such as your name, and prefix/title.
- Contact information: such as personal and work physical address, telephone number and/or email address.
- Information we obtain by automated means: such as device information, including your IP address, hardware identifiers, browser type and settings, and other device information.
- Information obtained through communications with us: such as information obtained through telephone calls (which may be recorded for compliance purposes), video communications and other verbal communications, and written correspondence.
- Technical information: such as information about your internet connection and usage details about your interactions with our services, such as clickstream information to, through, and from our services (including date and time), products that you view or search for, page response times, download errors, length of your visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), or methods used to browse away from a page.
- Other information: such as background information as made available by third parties or obtained through publicly available sources.
How We Obtain Your Personal Information
We may collect and maintain your personal information from the following sources:
- Information provided by you to us, including information we collect about you when you interact with our website.
- Automatic data collection technologies including through the use of cookies (a small text file placed on your hard drive), CAPTCHA or other similar technologies or tools. This information is used to improve website performance and for our business purposes, including to help provide you with a better experience when you browse the website. Where cookies or other tracking technologies are not necessary for us to provide the services you have requested or for the functioning of this website, we will ask you to consent to their use. You may opt-in to accept cookies automatically by changing the settings on your browser. If you opt-out of certain cookies, you may not be able to access certain parts of this website. You may wish to visit www.aboutcookies.org, which contains comprehensive information about types of cookies, how they are used and how you manage your cookie preferences.
- Information provided by third parties or as available from publicly available sources, such as information obtained from publicly available or accessible directories, databases, and agencies, including lists of individuals subject to sanctions or trade restrictions. If you represent one of our vendors, business partners or customers, we may also collect your personal information from the entity that you work for where this is necessary to receive products or services from, or otherwise conduct business with, such third party.
- We may process information in relation to companies that we are evaluating in connection with a corporate transaction (such as a merger, acquisition, or joint venture) or that are evaluating an investment in us. This information may include your personal data including name, title, email address, postal address, job title, telephone number, passport or other government-issued identification, and/or financial information, as appropriate.
How We Use the Personal Information We Collect
We will use the personal information we collect for one or more of the following purposes:
| Purpose | Legal Basis
(for the purposes of EEA-UK Data Protection Laws, if applicable) |
| To conduct business with you or to provide you with the services or information you have requested, including responding to your inquiries and requests and providing you with support. | Contractual necessity; and/or our legitimate interest in operating our business and providing data center services. |
| To communicate with potential customers, partners, vendors, landowners, investors, or other business contacts and to operate, schedule and facilitate meetings (in-person and online), and to administer participation in any of our events. | Our legitimate interest in operating our business and providing data center services; and/or consent. |
| To verify your identity (including to conduct anti-money laundering or KYC checks and to enable you to access our offices) or to evaluate a business partner or supplier. | Our legitimate interest in operating our business and providing data center services; contractual necessity; legal requirement; and/or consent. |
| To protect against, identify and prevent fraud, money-laundering, cyber-attacks, theft of our property, other threats to the safety, security and integrity of our website and other platforms or our business, and other malicious, or unlawful activity. | Legal requirement; and/or our legitimate interest in operating our business and our website. |
| To conduct conflicts checks. | Legal requirement. |
| To process and administer details associated with you, and to offer and improve our services. | Our legitimate interest in operating our business. |
| Complying with our legal obligations and corporate governance practices, which may require recording or monitoring telephone calls or other communications with you. | Legal requirement; our legitimate interest in operating our business. |
| Litigation management and conducting internal audits and investigations. | Legal requirement; and/or our legitimate interest in operating our business. |
| To keep a record of and manage your relationship with us. | Our legitimate interest in operating our business and providing services; and/or legal requirement. |
| To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding. | Our legitimate interest in operating our business; and/or legal requirement. |
| Corporate transaction and investment reporting. | Our legitimate interest in operating our business; and/or legal requirement. |
| To administer and ensure the performance of our business, this website (including our other platforms and IT systems), and to ensure compliance with our terms of use. | Our legitimate interest in operating our business. |
| To operate, maintain, and improve this website. | Our legitimate interest in operating our business and our website. |
| To make suggestions and recommendations to you (including to provide you with updates or other information) about our business and services that may be of interest to you, including in relation to services that are similar to those services we currently provide, or previously provided, to you. | Consent or our legitimate interest in operating our business where we have an existing relationship with you. |
| For statistical analysis and market research, such as to understand website traffic and performance. | Our legitimate interest in operating our business. |
| For any other purpose that has been notified in writing. | As identified in the relevant notice or where you have given consent to the processing of your personal information for the specific purpose. |
If we require your personal information due to a legal requirement or obligation or in order to perform a contract with you, failure to provide this information means that we may not be able to conduct business with you. In this case, we may have to cancel an existing business arrangement with you, but we will notify you if this is the case at the time.
Disclosure of Personal Information
Your personal information may be disclosed to and processed by our affiliates and agents and certain service providers as necessary to fulfill the purposes set out in this Privacy Policy, including professional advisors, consultants, data hosting providers and customer relationship manager software platform providers, as well as regulators, law enforcement and other government bodies.
We may also disclose personal information for the purposes described in this Privacy Policy and as required by law or regulation, or when we believe that disclosure is necessary to protect our rights and/or comply with a judicial proceeding, court order, request from a regulator, national security or any other legal or investigatory process involving us. Should we, or any of our affiliated entities, be the subject of a takeover, divestment, acquisition, joint venture, bankruptcy or similar proceeding, we may disclose your personal information to the new owner of the relevant business and their advisors.
We do not sell or transfer personal information to third parties for value.
The website may contain links to other websites which are not hosted, affiliated or operated by us. These websites may use automated means to collect information regarding your use of the websites. Your use of such websites is subject to the privacy policies or notices of the provider’s website.
International Visitors
Our website may be accessed by visitors from different countries. If you submit information through the website, your information may be processed in the United States or in other countries where we or our service providers operate.
Privacy laws in these countries may differ from those in your country of residence.
Security and Retention
The security of your personal information is important to us. We adopt and employ robust and appropriate security measures to protect any personal information you provide through the website from unauthorized access or use. You should be aware, however, that absolute security does not exist on the internet, and there is always the risk that unauthorized persons may access or use your information.
Although we make an effort to protect your personal information, we cannot guarantee the security of any information or data transmitted to or through the internet or our website; any transmission of information or data by you to or through the internet, including this website, is at your sole risk.
We will keep your personal information only for as long as is reasonably necessary.
Privacy Policy Changes
We reserve the right to amend this Privacy Policy from time to time and for any reason, in our sole discretion, without notice, by updating this Privacy Policy. Accordingly, users are strongly encouraged to review our Privacy Policy regularly. If we decide to change our Privacy Policy, we will post those changes so our users are always aware of what information we collect, how we use it and under what circumstances, if any, we disclose it. If at any point we decide to collect personal information or use any collected information in a manner different from that stated at the time it was collected, we will notify users by posting changes on this page. We will use information only in accordance with the Privacy Policy under which the information was collected. Your continued access or use of this website following the posting of changes to this Privacy Policy means that you acknowledge and accept such revisions, changes and/or amendments. If you object to any of the changes to this Privacy Policy, please stop accessing this website. Please check this page frequently and review any changes to this Privacy Policy carefully so you are aware of any changes, as they are binding on you.
Contact Us
If you have any questions or comments about this Privacy Policy, wish to access this Privacy Policy in an alternative format, submit requests, or wish to notify us of any errors or changes as to any personal information you provide us through this website (each, a “Communication”), you can email us at legal@rowan.digital.
We verify Communications by matching information provided in or in connection with your Communication to information contained in our records. Depending on the sensitivity of the Communication and the varying levels of risk in responding to such Communications (for example, the risk of responding to fraudulent or malicious communications), we may request further information, if applicable, in order to verify your Communication.
California Website Privacy Policy
Last Updated: July 2026
This California website privacy notice (the “California Privacy Policy”) supplements the [Privacy Policy] with respect to specific rights granted under the California Consumer Privacy Act of 2018 (as amended, the “CCPA”) to natural person California residents and provides information regarding how such California residents can exercise their rights under the CCPA. This supplement is only relevant to you if you are a resident of California as determined in accordance with the CCPA. Information required to be disclosed to California residents under the CCPA regarding the collection of their personal information that is not set forth in this California Privacy Policy is otherwise set forth in the [Privacy Policy].
What does this California Privacy Policy apply to?
This California Privacy Policy applies solely to your interactions with us through our website (as defined below) or as outlined in the Privacy Policy above.
What information do we collect about you?
The categories of website personal information we have collected from individuals over the last twelve (12) months include the following:
| Category | Examples | Collected |
|---|---|---|
| A. Identifiers | Name, contact details and address (including physical address, email address and Internet Protocol address), and other identification (including social security number, passport number and driver’s license or state identification card number). | YES |
| B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) | Telephone number, signature, bank account number, other financial information (including accounts and transactions with other institutions and anti-money laundering information). | YES |
| C. Protected classification characteristics under California or federal law | Date of birth, citizenship and birthplace. | NO |
| D. Commercial information | Records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | NO |
| E. Biometric information | Imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns and voice recordings or keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contains identifying information. | NO |
| F. Internet or other similar network activity | Use of our website (e.g., cookies, browsing history and/or search history), as well as information you provide to us when you correspond with us in relation to inquiries. | YES |
| G. Geolocation data | Physical location or movements. | NO |
| H. Sensory data | Audio, electronic, visual, thermal, olfactory, or similar information. | NO |
| I. Professional or employment-related information | Current or past job history or performance evaluations. | YES |
| J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)) | Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. | NO |
| K. Inferences drawn from other personal information | Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. | NO |
| L. Sensitive Personal Information (see further information on use of sensitive personal information below) | Social security, driver’s license, state identification card, or passport numbers; account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; precise geolocation; racial or ethnic origin; religious or philosophical beliefs; union membership; genetic data; the contents of a consumer’s mail, email, and text messages unless you are the intended recipient of the communication; biometric information for the purpose of uniquely identifying a consumer; and personal information collected and analyzed concerning a consumer’s health, sex life, or sexual orientation. | NO |
How do we use your personal information?
We collect personal information for the business or commercial purposes set forth in the “How We Use the Personal Information We Collect,” section of the Privacy Policy above. We retain the categories of personal information set forth above in the “What information do we collect about you?” section of this California Privacy Policy only as long as is reasonably necessary for those business or commercial purposes, except as may be required under applicable law, court order or government regulations.
To whom do we disclose your personal information?
We do not share for the purpose of cross-context behavioral advertising or sell (as such terms are defined in the CCPA) any of the personal information we collect about you to third parties.
Within the last twelve (12) months, we have disclosed personal information collected in connection with this website for a business or commercial purpose to the categories of third parties indicated in the chart below, and to affiliates and service providers, including administrators, lenders, banks, auditors, law firms, state and federal governmental agencies or pursuant to legal process, regulatory entities, self-regulatory organizations, consultants and third-party due diligence providers. We may also disclose your information to other parties as may be required by law or regulation, or in response to regulatory inquiries.
| Personal Information Category | Category of Third-Party Recipients |
|---|---|
| A. Identifiers | Administrators, lenders, banks, auditors, law firms, governmental agencies or pursuant to legal process, self-regulatory organizations and consultants. |
| B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) | Administrators, lenders, banks, auditors, law firms, governmental agencies or pursuant to legal process, self-regulatory organizations and consultants. |
| C. Protected classification characteristics under California or federal law | N/A |
| D. Commercial information | N/A |
| E. Biometric information | N/A |
| F. Internet or other similar network activity | Administrators, law firms, governmental agencies or pursuant to legal process and consultants. |
| G. Geolocation data | N/A |
| H. Sensory data | N/A |
| I. Professional or employment-related information | Administrators, law firms, governmental agencies or pursuant to legal process and consultants. |
| J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)) | Administrators, law firms, governmental agencies or pursuant to legal process and consultants. |
| K. Inferences drawn from other personal information | N/A |
| L. Sensitive Personal Information | Administrators, law firms, governmental agencies or pursuant to legal process and consultants. |
Some internet browsers have incorporated “Do Not Track” features. Most of these features, when turned on, send a signal or preference (the “DNT Signal”) to websites you visit indicating that you do not wish to be tracked. At this time, we do not currently respond to DNT Signals.
Your rights under the CCPA
Deletion Rights: You have the right to request that we delete any of your personal information that we retain, subject to certain statutory exceptions, including our compliance with U.S., state, local and non-U.S. laws, rules and regulations. We will notify you in writing if we cannot comply with a specific request and provide an explanation of the reasons.
Disclosure and Access Rights: You have the right to request that we disclose to you certain information regarding our collection and use of personal information specific to you over the last twelve (12) months. Such information includes:
- the categories of personal information we collected about you;
- the categories of sources from which the personal information is collected;
- our business or commercial purpose for collecting such personal information;
- the categories of third parties to whom we disclose the personal information;
- the specific pieces of personal information we have collected about you; and
- whether we disclosed your personal information to a third party, and, if yes, the categories of personal information that each recipient obtained.
Correction Right: You have the right to request that we correct any inaccuracies in the personal information that we retain, subject to certain statutory exceptions, including our compliance with U.S., state, local and non-U.S. laws, rules and regulations. We will notify you in writing if we cannot comply with a specific request and provide an explanation of the reasons.
No Discrimination: We will not discriminate against you for exercising your rights under the CCPA, including by denying service, suggesting that you will receive, or charging, different rates for services or suggesting that you will receive, or providing, a different level or quality of service to you.
How to Exercise Your Rights: To exercise any of your rights under the CCPA, or to access this notice in an alternative format, please submit a request on your behalf using any of the methods set forth in the Contact us section below.
Contact us
For any requests relating to the exercise of your rights under the CCPA, to access this notice in an alternative format, or questions regarding our processing of your personal information, please submit or have your authorized representative submit a request using any of the following methods:
Call using the following toll-free number: [ ]
Submit a request online using the following online form: [ ]
Email us at the following email address: legal@rowan.digital
We will contact you to confirm receipt of your request under the CCPA and request any additional information necessary to verify your request. We verify requests by matching information provided in connection with your request to information contained in our records. Depending on the sensitivity of the request and the varying levels of risk in responding to such requests (for example, the risk of responding to fraudulent or malicious requests), we may request further information, if applicable, in order to verify your request. You may designate an authorized agent to make a request under the CCPA on your behalf, provided that you provide a signed agreement verifying such authorized agent’s authority to make requests on your behalf, and we may verify such authorized person’s identity using the procedures above.
Please contact us at legal@rowan.digital with any questions about this California Privacy Policy.
EEA-UK WEBSITE PRIVACY NOTICE
This EEA-UK website privacy notice (the “EEA-UK Website Privacy Notice”) supplements the general Privacy Policy with respect to our use of personal data to the extent that EEA-UK Data Protection Laws (as defined in the general Privacy Policy) apply to our processing of your personal data.
Information required to be disclosed under the EEA-UK Website Privacy Notice regarding the collection of your personal data that is not set forth in this EEA-UK Website Privacy Notice is otherwise set forth in the general Privacy Policy above. To the extent there is any conflict in respect of any processing subject to EEA-UK Data Protection Laws between the general Privacy Policy and this EEA-UK Website Privacy Notice, this EEA-UK Website Privacy Notice shall apply. Please read this EEA-UK Website Privacy Notice carefully.
You do not need to take any action as a result of this EEA-UK Website Privacy Notice, but you may have certain rights as described below in the section headed “Your Rights”.
If you have any questions regarding our use of your personal data, or this EEA-UK Website Privacy Notice, please contact legal@rowan.digital.
The Controller
For the purposes of EEA-UK Data Protection Laws, Rowan and certain of its affiliates will be a controller of any personal data collected by us. In simple terms, this means that we: (i) “control” the personal data that we collect from you or that other sources provide, including making sure that it is kept secure; and (ii) make certain decisions on how to use and protect your personal data. You can contact the controller by emailing legal@rowan.digital.
Any Additional Personal Data We May Collect
As discussed in the “The Personal Information We Collect” section of the general Privacy Policy, the types of personal data we collect about you depends on the nature of your interaction with us.
We generally 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) or information about criminal convictions and offences, although there may be limited circumstances where we need to collect this type of personal data (e.g. as part of our legal obligations, in performance of a contract or as may be disclosed as part of a job application).
How We Obtain Your Personal Data
We collect and process your personal data from you and other third parties and/or publicly available sources listed in the “How We Obtain Your Personal Information” section of the general Privacy Policy above.
How We Use Your Personal Data and Lawful Basis
Further information about the legal bases under which we process your personal data is included in the section of the general Privacy Policy headed “How We Use the Personal Information We Collect.”
We may process your personal information on more than one legal basis depending on the specific purpose for which we are using your personal data. 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 we need to use your personal data for an unrelated purpose, we will notify you and explain the legal basis which allows us to do so.
No solely automated decision making, including profiling, is used when processing your personal data.
Disclosure and Transfers of Personal Data
Your personal data may be transferred to, or processed by, us, our affiliates or third parties located outside of the EEA or UK, including in the United States. To the extent your personal data is transferred outside of the EEA or UK, such transfers will be made in accordance with EEA-UK Data Protection Laws.
Security and Retention of Personal Data
Information about the security measures employed, and our data retention practices as it relates to personal data, is included in the section of the general Privacy Policy headed “Security and Retention.”
We will keep your personal data only for as long as is reasonably necessary for the purposes set out in this EEA-UK Website Privacy Notice, unless a longer retention period is required by law. We will not keep more information than we need for those purposes. For further information about how long we will keep your personal data, please contact legal@rowan.digital.
Your Rights
To the extent the EEA-UK Data Protection Laws apply to our processing of your personal data, you may have the following rights:
- Access: You have the right to ask for a copy of the personal data that we hold about you free of charge, however we may charge a ‘reasonable fee’, if we think that your request is excessive, to help us cover the costs of locating the information you have requested.
- Correction: You may notify us of changes to your personal data if the data we hold and process about you is inaccurate or if it needs to be updated.
- Deletion: If you think that we shouldn’t be holding or processing your personal data any more, you may request that we delete it. Please note that this may not always be possible due to legal obligations.
- Restrictions on use: You may request that we stop processing your personal data (other than storing it), if: (i) you contest the accuracy of it (until the accuracy is verified); (ii) you believe the processing is against the law; (iii) you believe that we no longer need your data for the purposes for which it was collected, but you still need your data to establish or defend a legal claim; or (iv) you object to the processing, and we are verifying whether our legitimate grounds to process your personal data, override your own rights.
- Object: You have the right to object to processing, including: (i) for direct marketing; (ii) for research or statistical purposes; or (iii) where processing is based on legitimate interests unless we reasonably demonstrate compelling legitimate grounds for the processing.
- Portability: If you wish to transfer your personal data that we hold and process about you on the legal ground of contractual necessity to another organisation (and certain conditions are satisfied), you may ask us to do so, and we will send it directly if we have the technical means.
- Withdrawal of consent: If you previously gave us your consent (by a clear affirmative action) to allow us to process your personal data for a particular purpose, but you no longer wish to consent to us doing so, you can contact us to let us know that you withdraw that consent. This will not impact on the legality of processing prior to such withdrawal of consent.
These rights are not absolute and in certain circumstances their exercise may not be possible, including when personal data must be maintained to comply with applicable laws.
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.
Contact Us
If you have any questions or concerns about this EEA-UK Website Privacy Notice, please contact us by emailing us at legal@rowan.digital.
Complaints
Should you wish to lodge a complaint with regards to how your personal data has been processed by us, you may do so with your local supervisory authority, including under:
- the UK GDPR and/or Data Protection Act 2018, please contact the UK Information Commissioner’s Office – https://ico.org.uk/global/contact-us; or
- the EU GDPR, please contact your local supervisory authority in the EU Member State of your habitual residence, place of work, or place of infringement, concern or complaint. A list of EU/EEA supervisory authorities and their contact details can be found at: https://edpb.europa.eu/about-edpb/about-edpb/members_en.
We would, however, appreciate the opportunity to address your concerns before you approach the relevant supervisory authority, so please contact us in the first instance.