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PRIVACY AND COOKIES POLICY

This Privacy and Cookies Policy (“Policy”) applies to the websites operated by
Extreme Networks, Inc. (“we” or “us” or “our”), accessible via our global and
regional websites and any mobile applications or other online and/or mobile
applications or websites operated by us that are related to us (collectively,
the “Website”).This Policy (together with our Terms of Sale and any other
documents referred to in this Policy or those documents) sets out how we may or
will use any personal information that you provide through our Website. Please
read it carefully before you proceed.



By visiting our Website, and/or using the services offered on or through our
Website, you acknowledge you have read and understood the terms of this Policy
(as amended from time to time).

 1. INFORMATION WE MAY COLLECT FROM YOU

1.1 We may collect and process the following data about you:

1.1.1 Information that you provide by filling in forms on our Website. This may
include, but is not limited to, information provided at the time of registering
to use our Website, subscribing to our service, signing up for our newsletter,
registering for a seminar, using a chat function, or requesting further
services. Such information may include, for example, your name, home and/or
business address, email address, telephone number, demographic information such
as age, and/or other information that may identify you as an individual. We may
also ask you for information when you enter a competition or promotion sponsored
by us, sign-up for email newsletters, and when you report a problem with our
Website. You can choose not to provide us with some of this information, but
doing so may affect your ability to use our Website and our services.

1.1.2 If you contact us, we may keep a record of that correspondence.

1.1.3 We may also ask you to complete surveys that we use for research purposes,
although you do not have to respond to them.

1.1.4 Subject to your expressed marketing preferences, to send you marketing
information about goods and services that may be of interest to you by post,
telephone, email or other means. You have the right to “opt in” and “opt out” of
certain uses of your personal information for these purposes.

1.1.5 Details of your visits to our Websites and the resources that you access,
including, but not limited to, traffic data, location data, weblogs and other
communication data, whether this is required for our own purposes or otherwise.

1.1.6 Information regarding your interaction with emails we send you, including
whether or not you open the email.

1.1.7 Information we may receive about you if you use any of the other websites
we operate or the other services we provide. We work closely with third parties
(including, for example, business partners, sub-contractors in technical,
payment and delivery services, advertising networks, analytics providers, and
search information providers) and we will notify you when we receive information
about you from them and the purposes for which we intend to use that
information.

 2. HOW WE USE YOUR INFORMATION

2.1 We use information provided by you and/or held about you (including your
personal information) in the following ways:

2.1.1    To ensure that content from our Website is presented in the most
effective manner for you and for your computer.

2.1.2    For any specific purpose for which it was provided or volunteered.

2.1.3    To perform analysis and research in relation to transactions, including
analyzing our users’ demographics, interests, browsing and viewing preferences.

 * To manage our business needs, such as monitoring, analyzing, modifying and
   improving the services’ and Website’s functionality and performance;
 * To determine which features and functionality of the services users like best
   to help us operate, enhance and improve the services;

The legal basis for these purposes will typically be that the processing is
necessary for our legitimate interests, including to ensure our products and
services are properly provided, to promote our products and services, and to
provide you with information on our products and services.

2.1.6    To carry out our obligations arising from any contracts or transactions
entered or contemplated to be entered into between you and us, or to provide you
with the Website and any services requested by you.

2.1.7    To notify you about changes to our service.

2.1.8    To assist you in finding a reseller channel Partner so that you can
order product and services for your company;

2.1.9    To fulfill orders and provide you with products and services you have
requested and/or paid for;

 * To enforce your legal rights under an agreement; and
 * To provide you with an estimate for our products or services.

The legal basis for these purposes will typically be that the processing is
necessary to fulfil a contract that we have in place with you.

2.1.12  To develop, market, sell or provide products and services.

2.1.13  To provide you with educational materials, webinars and training that
you request.

2.1.14  To send you information about our or our Partners’ products or services.
 Sometimes, where you have shown interest in a particular product, our Partners
may contact you directly.

2.1.15  To send you notices (for example, in the form of e-mails, SMS, mailings,
and the like), and otherwise correspond with you, about products, services,
companies, and events, sponsored by us and others, that we think might interest
you, where you have consented to be contacted for such purposes.

 * To grow our business.
 * To get to know our potential and existing clients, consumers, and users.
 * To identify relevant content shared with potential and current users.
 * The legal basis for these purposes will typically be that we have your
   consent to our use of your personal information or that processing is
   necessary for our legitimate interests, including to ensure our products and
   services are properly provided, to promote our products and services, and to
   provide you with information on our products and services. To prevent fraud
   and abuse on and unauthorized access to the services and Websites.
 * To meet reporting requirements (e.g. filing tax forms).
 * To retain documents and information related to a legal action.

2.1.22  To enforce any agreements we have with you.

2.1.23  To report data breaches or unauthorized access to the services.

The legal basis for these purposes will typically be to comply with our
regulatory and legal obligations or to enforce our legal rights.

 3. WHERE WE STORE YOUR INFORMATION

3.1 The data that we collect from you may be transferred to, stored at, or
processed from a location outside the jurisdiction in which you reside. This
means it may be transferred to countries that do not offer the same level of
legal protection as exists in your country of residence. Whenever we transfer
your information outside of your country of residence, we will take steps to
ensure that adequate safeguards are in place to make sure it is treated securely
and in accordance with this Policy. You may contact us for a copy of the
safeguards that we have put in place.

 4. SERVICE PROVIDERS

4.1 We may use third-party partners, carefully selected by us, to help operate
our Website and deliver our products and services, and may share your
information with our service providers that provide products or services for or
through this Website or for our business (such as website or database hosting
companies, address list hosting companies, e-mail service providers, research,
analytics and customer experience and survey companies, distribution companies
and resellers, fulfilment companies, marketing and promotional companies, and
other similar service providers that use such information on our behalf).

4.2 We may disclose statistics regarding user behavior to third parties in the
form of aggregate data, such as overall patterns or demographic reports that do
not describe or identify any individual user.

 5. PARTNER MARKETING

5.1 If you have indicated an interest in our products or services (including by
clicking on an email or download, or visiting our Website), including on behalf
of your company, we may provide your contact information and information about
your company to one of our resale channel partners or provider of managed
services (a “Partner”) so that they can provide information regarding those
services to your company. If you become a customer of a Partner, the Partner may
use your information in accordance with its policies. For questions about how
that Partner may use your information, please contact that company.

5.2 Our Partners participate with us in marketing programs to offer to
prospective and existing customers product trials, event invitations and
marketing content and other offerings. Our Partners may do so independently or
using our systems or platforms, or based on customer data and information we may
provide.  Where a Partner refers you to our marketing program, you may be asked
to enter personal or company information on in-take forms or “click-through”
webpages.  We may capture this information and share it with the Partner, so
that we and the Partner may communicate further with you, as appropriate, and to
assess your engagement with and the results of the marketing programs. We will
retain and only use this personal information for these marketing and assessment
purposes.

 6. DISCLOSURE OF YOUR INFORMATION

6.1 We may disclose your personal information to any member of the Extreme
Networks group, which means Extreme Networks, Inc. and our direct and indirect
subsidiaries.

6.2 We may also use your personal information to maintain our internal record
keeping and/or share it with our affiliates for internal marketing or other
purposes.

6.3 We may disclose your personal information to third parties:

6.3.1 To our Partners, to allow them to provide information to you regarding
products or services you may be interested in.

6.3.1 In the event that we sell or buy any business or assets, in which case we
may disclose your personal information to the prospective seller or buyer of
such business or assets.

6.3.2 If Extreme, or substantially all of our assets, are acquired by a third
party, in which case personal information we hold about our customers will be
one of the transferred assets.

6.3.3 If we are under a duty to disclose or share your personal information in
order to comply with any legal obligation, or in order to enforce or apply our
agreements; or to protect the rights, property, or safety of Extreme, our
customers, or others. This includes exchanging information with other companies
and organizations for the purposes of fraud protection and credit risk
reduction.

6.3.4 We may disclose user information to government authorities, and to other
third parties, when compelled to do so by government authorities or otherwise as
required or permitted by law, including but not limited to in response to court
orders and subpoenas. We also may disclose user information when we have reason
to believe that someone is causing injury to or interference with our rights or
property, other users of our Website, or anyone else that could be harmed by
such activities. Additionally, we cooperate with law enforcement inquiries and
other third parties when in good faith, we believe that we are lawfully
authorized or required to do so, or that doing so is reasonably necessary or
appropriate to comply with the law or with legal process or authorities, respond
to any claims, or to protect the rights, property or safety of the Website or
the products, users, our employees or the public, including without limitation
disclosures intended to protect Extreme or users from fraudulent, abusive,
inappropriate or unlawful use of the Website or our products or services or to
enforce laws, intellectual property rights, and other rights.

 7. RETENTION

7.1 Your personal information will be retained for as long as is reasonably
necessary for the purposes listed above or as required by applicable local law.
Please contact us for further details of applicable retention periods.

7.2 We may keep an anonymized form of your personal information, which will no
longer refer to you, for statistical purposes without time limits, to the extent
that we have a legitimate and lawful interest in doing so.

 8. IP ADDRESSES AND COOKIES

8.1 We may collect information about your computer, mobile phone, personal
electronic device, and all other similar electronic or mobile devices, including
where available your IP address, operating system and browser type, for system
administration and to report aggregate information to our advertisers. This is
statistical data about our users’ browsing actions and patterns, and does not
show personal details that identify you.

8.2 For the same reason, we may obtain information about your general internet
usage by using a cookie file that is stored on the hard drive of your computer.
Cookies are small pieces of information (e.g., cookies, web beacons, pixels,
gifs tags or other similar technologies) sent by a web server to a web browser
that allow the web server to recognize the web browser. This operates as a piece
of data stored on your browser or device, or may identify, compile, aggregate
and/or collect information through other means. They help us to improve our
Website and to deliver a better and more personalized service. They enable us:

8.2.1 To estimate our audience size and usage pattern.

8.2.2 To store information about your preferences, and so allow us to customize
our Website according to your individual interests.

8.2.3 To speed up your searches.

8.2.4 To recognize you when you return to our Website.

8.3 You can control how your browser handles cookies received from our Website.
You can choose to refuse all cookies, or to be prompted before a cookie is saved
to your hard drive, or to only accept cookies from certain selected websites
that you designate. Information on deleting or controlling cookies is available
at www.AboutCookies.org. By refusing to accept cookies from us, you may not be
able to use some of the features and functionality available on our Website.

 9. ADVERTISING AND ONLINE TRACKING

9.1 We may allow third-party companies to serve ads and collect certain
information when you visit the Website. These companies may use certain
information (e.g., click stream information, web browser type, time and date,
subject of advertisements clicked or scrolled over) during your visits to the
Website in order to provide advertisements about goods and services likely to be
of interest to you. These companies typically use a cookie or third-party clear
gif/web beacon to collect this information. Our systems do not recognize browser
“Do Not Track” signals, but several of our service providers who utilize these
cookies or web beacons on our Website enable you to opt out of targeted
advertising practices. To learn more about these advertising practices or to opt
out of this type of advertising, you can visit www.networkadvertising.org or
www.aboutads.info/choices.

 10. CHILDREN’S PRIVACY

10.1 Protecting the privacy of young children is especially important. Our
services are not directed to children under the age of 13, and we do not
knowingly collect Personal Information on our own behalf from children under the
age of 13 without obtaining parental consent. If you are under 13 years of age,
then please do not use or access our services. If we learn that Personal
Information has been collected by us on our Website or through our products from
persons under 13 years of age and without verifiable parental consent, then we
will take the appropriate steps to delete this information. If you are a parent
or guardian and discover that your child under 13 years of age has obtained an
account on the service, then you may alert us at
privacyinquiries@extremenetworks.com and request that we delete that child’s
Personal Information from our systems.

 11. YOUR RIGHTS

11.1 You may have the right to request access to, and rectification or erasure
of, the personal information Extreme holds about you. You may also have the
right to object to or restrict certain types of processing of your personal
information and can request to receive a machine-readable copy of the personal
information you have provided to Extreme.

11.2 Extreme will assess any request to exercise one of these rights on a case
by case basis. There may be circumstances in which we are not legally required
to comply with your request because of relevant legal exemptions provided for in
data protection legislation.

11.3 Please note that by continuing to use our services or the Website, and by
providing any personal information to us offline or via the Website or email
addresses provided on the Website, you are consenting to our use of your
personal information as set out in this Privacy and Cookies Policy. Please do
not provide us any personal information if you do not want that information to
be used by us in this manner.

 12. YOUR CALIFORNIA PRIVACY RIGHTS

12.1 Under the California Consumer Privacy Act of 2018 (“CCPA”), California
Consumers have certain privacy rights. This section is intended to provide
further information and notification pursuant to the CCPA. Capitalized terms
that are not defined in this Privacy Policy are used in accordance with their
definitions under CCPA. California Consumers who wish to request information
about our compliance with the CCPA or who have questions more generally about
this Privacy Policy and our privacy commitments should contact us at
privacyinquiries@extremenetworks.com.

12.2 Categories of Personal Information We Collect:

Category Definition Collected? A.    Identifiers A real name, alias, postal
address, unique personal identifier, online identifier, Internet Protocol
address, email address, account name, Social Security number, driver’s license
number, passport number, or other similar identifiers. YES B.    Personal
information categories listed in the California Customer Records statute (Cal.
Civ. Code § 1798.80(e)). A name, signature, Social Security number, physical
characteristics or description, address, telephone number, passport number,
driver’s license or state identification card number, insurance policy number,
education, employment, employment history, bank account number, credit card
number, debit card number, or any other financial information, medical
information, or health insurance information. Some personal information included
in this category may overlap with other categories. YES C.    Protected
classification characteristics under California or US federal law. Race, color,
ancestry, national origin, religion, creed, age (40 and above), disability
(mental and physical), sex, gender (including pregnancy, childbirth,
breastfeeding or related medical conditions), sexual orientation, gender
identity, gender expression, medical condition, genetic information, marital
status, military and veteran status NO D.    Commercial information. Records of
personal property, products or services purchased, obtained, or considered, or
other purchasing or consuming histories or tendencies. YES E.     Biometric
information. Physiological, biological, or behavioral characteristics
identifying an individual’s DNA that can be used, singly or in combination with
each other or with other identifying data, to establish individual identity. 
Examples include imagery of the iris, fingerprint, face, hand, palm, vein
patterns, voice recordings, keystroke patterns or rhythms, gait patterns or
rhythms, and sleep, health, or exercise data NO F.     Internet or other similar
network activity. Browsing history, search history, information on a consumer’s
interaction with an internet website, application, or advertisement. YES G.   
Geolocation data. Location data generated by a consumer device capable of
connecting to the Internet that directly identifies the precise physical
location of the identified individual at particular times and that is compiled
and retained. 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. NO 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

12.3 We obtain the Personal Information in categories A, B, D, and F from the
following categories of sources:

12.3.1     Directly from you; for example, when you enter your name and contact
information on a form on our website.

12.3.2     From third-parties that perform services on our website; for example,
when you interact with a chat agent on our website and provide your name and
contact information.

12.3.3     Indirectly from you; for example, we may collect records about your
interactions with our website, email, or transactions you conduct with us.

12.3.4     From our Partners; for example, we may receive your contact
information or information about transactions you are considering from our
Partners.

12.4 We may use the Personal Information in categories A, B, D, and F that we
collect as described in clause 2 above.

12.5 We do not sell your Personal Information to third parties.  However, we may
disclose Personal Information in categories A, B, D, and F as described in
clauses 5 and 6 above.

12.6 Under the CCPA, you have the following rights:

12.6.1  You may request once every 12 months that we disclose to you information
about our collection and use of your Personal Information.

 * You may request, subject to certain exemptions, that we delete the Personal
   Information we have collected about you.
 * You may request information about your Personal Information that we have
   disclosed in the previous 12 months.
 * We will not discriminate against you if you exercise any of your rights under
   CCPA.

12.7 Direct requests to exercise your rights under CCPA to
privacyinquires@extremenetworks.com or 1-800-245-1621.  Only you or your agent
registered with the California Secretary of State’s office may make a verifiable
request related to your Personal Information.  You may make a request on behalf
of your minor child.

12.7.1 We will attempt to verify your request, generally by asking you to
provide evidence that matches the Personal Information we have maintained.  The
exact method of verification will depend on the type of request made and the
type of Personal Information maintained.

12.7.2 After we receive your request to exercise your rights under CCPA, we will
take reasonable steps to verify that your request is a valid request from you. 
We will try to respond within 45 days, and will inform you in writing if we need
an extension of time up to 90 additional days.  Any disclosure of information
will cover the previous 12-month period.  If we cannot comply with your
requests, we will inform you of the reason why.

12.7.3 If a verifiable consumer request is excessive, repetitive, or manifestly
unfounded, we may charge a reasonable fee to process the request.  If we
determine that a fee is applicable, we will explain our reasons for charging a
fee, and provide you with an estimate before completing your request.

 13. CHANGES TO THIS POLICY

13.1 This Policy may be amended by us at any time. Please check this page
periodically to inform yourself of any changes. It was last amended in December
2019.

 14. HOW TO CONTACT US

14.1 If you have any questions, need further information about our privacy
practices, or would like to let us know that your details require updating,
please contact us at privacyinquiries@extremenetworks.com.

14.2 You may also have the right to complain to a data protection authority if
you think we have processed your personal information in a manner that is
unlawful or breaches your rights. If you have such concerns, we request that you
initially contact us (at the email address provided above) so that we can
investigate, and hopefully resolve, your concerns.

 

LAST UPDATED: January 1, 2020

QMS00996

 

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