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SOLARFLARE COMMUNICATIONS, INC. PRIVACY POLICY

 

This Privacy Policy is effective as of April 5, 2019.

This website located at http://www.solarflare.com (the “Site”) is owned and operated by Solarflare Communications, Inc.

1. Who We Are

Solarflare Communications Inc. designs, manufactures and sells software and hardware solutions for next-generation networks.

This privacy notice is issued on behalf of the Solarflare, also referred herein as “we”, “us” or “our” in respect of the processing of your personal data.

Solarflare is the Data Controller of this website and is responsible in terms of European Data Protection Regulations (GDPR) and other Data Protection Legislation.

We have appointed a data protection lead (DPL) responsible for overseeing questions in relation to this Privacy Notice. If you have any questions about this Privacy Notice, including any requests to exercise your legal rights, please contact us.

2. The Personal Data We Collect About You

Personal data means any data or information about an individual from which that person can be identified. It does not include data where your identity has been removed (anonymous data).

We may collect, use, store, and transfer different types of personal data about you, which we have grouped together as follows:

  • Contact details which includes your postal address, email address and telephone numbers.
  • Identity Data, which includes your first title, name, last (family / surname) name, nick name, gender, date of date, job title and organisation you work for.
  • Marketing and communications data, which includes your preferences in receiving marketing from us, and your communication preferences.
  • Profile Data includes your username and password, preferences, feedback and survey responses.
  • 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 access this website.
  • In respect of job candidates we will collect information relating to you as contained in your CV / Resume.
  • For employees we collect and hold personal information to satisfy employment legislation, financial information relevant to salary and tax obligations, training records and qualifications.
  • Usage Data includes information about how you use our website.

We may use the above personal data to form a view on what products and services we think you may want or need, or what may be of interest to you.

You may receive marketing communications from us if you have requested information from us or purchased services from us, or if you have provided us with your details when you entered a survey or registered for an event or a promotion, and where in each case, you have not opted out of receiving that marketing.

You can tell us not to contact you with marketing communications either at the point such information is collected or by following the unsubscribe instructions in any communication sent to you.

Please note that where you opt out of receiving marketing messages, this will not delete other personal data we hold about you.

We do not collect personal data about you other than the information that you voluntarily provide to us through this site to fulfil the purpose of your request such as to subscribe to a newsletter.

Please note that this website is not intended for children, and we do not knowingly collect data relating to children. If you are younger than 16 years of age, you may not register with or use this website. If you think that we may have unintentionally collected data relating to a child, please contact us to discuss.

We do not collect any Special Categories of Personal Data about you in relation to any products or services provided or offered via this website (this means 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 any information about criminal convictions and offences).

3. How We Collect Your Personal Data

Direct interactions. You may give us your Identity, contact, Marketing, and Communications Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

  • fill in a form on this website (such as the one on our ‘connect with us’ page);
  • create an account on our website (such as on our ‘career opportunities’ page);
  • subscribe to any publications (such as our ‘white papers’);
  • request marketing to be sent to you; or
  • when you give us some feedback.

Automated technologies or interactions. 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, server logs and other similar technologies.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. Please note that when you disable or refuse cookies, some parts of this site may become inaccessible or may not function properly. With respect to cookies and data analytics, which are captured when you visit our website, please refer to our cookie policy.

4. How We Use Your Personal Data

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

  • Where we need to perform the contract we are about to enter into or have entered into with you;
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;
  • Where we need to comply with a legal or regulatory obligation.

Generally we do not rely on ‘consent’ as a legal basis for processing your personal data. Where there is a need for Consent we will make this clear.

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

We may process your personal data on the basis of more than one lawful ground depending on the specific purpose for which we use your data:

Purpose/ActivityType of dataLawful basis for processing including basis of legitimate interest
To register you as a new customer, supplier, partner…(a) Identity
(b) Contact
Performance of a contract with you
To manage our relationship with you which may include:
(a) Notifying you about changes to our terms or Privacy Notice
(b) Asking you to leave a review or take a survey
(a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To enable you to complete a survey(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(a) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)(a) Identity
(b) Contact
(c) Technical
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation

To deliver relevant website content to you and measure or understand its effectiveness(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical
Necessary for our legitimate interests (to study how customers use our website and/or products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences(a) Technical
(b) Usage
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
Necessary for our legitimate interests (to develop our products/services and grow our business)
For recruitment and subsequent employment purposes(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
Necessary for our legitimate interests to satisfy our recruitment requirements and employment legislation / obligations.

Upon the receipt and acceptance of an offer of employment for salary, benefits and the performance of business functions and activities thereafter.

5. Disclosures of Your Personal Data

We may share your personal data with third parties for the purposes set out in section 4 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.

We may at our discretion and without prior notice to you, change the third parties who provide such services in support of our business operations.

6. International Transfers

We may conduct elements of our business operations globally.

We have implemented privacy practices for processing personal data protected under various data protection laws relevant to the jurisdictions and type of personal data impacted.

Where necessary for legitimate business purposes we only transfer data between our international offices where there is a legitimate business justification to do so, with applicable data privacy legislation, including standards and conditions related to information security.

For EU citizens data transfers between our business entities or to third parties will involve transferring your data outside the EEA. We take all reasonable and appropriate precautions to ensure at least one of the following safeguards is implemented where these transfers take place:

7. Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

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

Collection of information by third party sites

Like many other commercial websites, our site contains links to other sites whose information collection practices may be different than ours. You should consult the other sites’ privacy policies, as we do not have any control over any information that may be submitted to, or collected by such third parties.

Although we employ security measures to prevent unauthorized access to information we collect online, we cannot guarantee the privacy of personal data you transmit over the web, or that may be collected in transit by third parties, including any consultants that provide services to us.

8. How Long We Retain Your Personal Data

We will only retain your personal data for as long as necessary to fulfill 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 our legal, regulatory and contractual obligations, the nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process personal data and whether we can achieve those purposes through other means.

9. Your Legal Rights

Under certain circumstances and depending on your location you have rights under applicable data protection laws in relation to your personal data.

If you are an EU Citizen, you are entitled to:

  • Request access to your personal data;
  • Request correction of your personal data;
  • Request erasure of your personal data;
  • Object to processing of your personal data;
  • Request restriction of processing your personal data;
  • Request transfer of your personal data;
  • Withdraw your consent.

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 will notify you directly if these circumstances arise.

To process a legitimate request we may need to request specific information from you to help us verify 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 an unauthorized person. We may also contact you to seek further information in relation to your request to assist in our response.

We try to respond to all legitimate requests within one month, in accordance with legislation. Occasionally, we may require more time particularly if your request is complex or you have made a number of requests. In this case, we will notify you without undue delay and keep you updated on the progress being made.

To exercise any of the rights set out above, please use the contact details below.

If you believe we have not responded to or resolved your request satisfactorily you should notify us immediately in order that we can address your concerns. If subsequently you are still dissatisfied, and you are an EU citizen, you have the right to formulate a complaint to the Supervisory Authority, in the Member State of your habitual residence, place of work or place of the alleged infringement. The following link will help to identify your local Supervisory Authority https://edpb.europa.eu/about-edpb/board/members_en.

10. Contact Us

If you have any questions about our company, the Site or this Privacy Policy, please contact us by clicking on the Contact Us link on the Site or by writing to the following address:  Solarflare Communications, Inc., 7505 Irvine Center Drive, Suite 100, Irvine, California 92618, USA.  We encourage visitors to the Site to contact us with questions and comments.  Email addresses and other information of persons using the Contact Us feature may be collected in order to facilitate our responses to such inquiries.

11. Revisions to This Privacy Notice

We may periodically update this Notice to comply with privacy regulations, describe new website features, products or services we offer and how it may affect our use of information about you.

This Privacy Notice was last updated April 5, 2019.

Copyright ©Solarflare Communications Inc. 2019.  All rights reserved.