Xirrus, Inc. and its subsidiaries and affiliates (“Xirrus,” “we,” or “us”) are committed to protecting your privacy. We have prepared this Privacy Policy to describe to you our practices regarding the Personal Data we collect about you. “Personal Data” means any data relating to an identified or identifiable individual, including, for example, your name, address, telephone number and e-mail address.

This Privacy Policy is made part of the Xirrus Terms of Use at www.xirrus.com/terms-of-use. Capitalized terms not defined in this Privacy Policy will have the meanings set forth in the Terms of Use.

  1. How We May Collect or Receive Your Personal Data

Site users’ data: We collect Personal Data from you when you visit www.xirrus.com (the “Site”), send us information or communications, and/or when you submit content to our Site.

Business data: We collect Personal Data about contact persons at our customers, vendors and other partners in the context of our business relationships.

End-users’ data: We process end-users’ Personal Data that are transmitted and uploaded via our infrastructure and services. We process end-users’ Personal Data as a data processor on behalf of and under the instructions of our customers. We require our customers to comply with applicable law governing the collection, use and other processing of end-users’ Personal Data. We have also informed our customers that they may be responsible for providing appropriate notice to end-users whose Personal Data are collected and processed by Xirrus, Inc. in the U.S.

  1. The Types of Personal Data We May Collect

Site users’ data: We receive and store any information you enter on our Site or otherwise provide to us.

We may collect Personal Data from you, such as your user name, password, first and last name, company name, mailing address, e-mail address, and phone number, when you create a customer support or partner account on the Site. If you download certain items from the Site, we collect your name, e-mail address, and any URL you provide. If you provide us feedback or contact us via e-mail or an online form, we may collect your name and e-mail address, as well as any other content included in the e-mail or that you submit to us, in order to send you a reply.

We use a web marketing automation suite to gather information about Site users (such as IP address, operating system, web browser, and pages visited) when they complete an online form, for example; for registration to events, contact/request forms or for subscription to our e-mail communications.

Our servers (which may be hosted by a third party service provider) collect information from you when you visit or use the Site, such as browser type and version, operating system, platform, Internet Protocol (IP) address (a number that is automatically assigned to your computer when you use the Internet, which may vary from session to session), domain name, and a date/time stamp for your visit. If you create an account, we may link your IP address with your account and collect information about your activities on our Site.

We may use cookies, Flash cookies, and navigational data like Uniform Resource Locators (URLs) on the Site to gather information about your online activities, such as the date and time of your visit, the information for which you searched and which you viewed, and the sites you visited before and after visiting the Site. We may also use a cookie or Flash cookie to save your settings and to provide customizable and personalized services (such as to hold your account information). A “cookie” is a small data file placed on your hard drive when you visit certain websites. A “Flash cookie” is a small data file placed on your hard drive when you visit certain websites that use Adobe Flash. You may disable cookies by adjusting the preferences settings of your browser. Consult the “Help” feature of your browser for specific instructions. To adjust Flash cookie settings, access your Flash management tools from Adobe’s web site http://www.adobe.com/products/ directly.

We use Google Analytics to collect and process analytical data about Site users. Google Analytics tracks your interaction with the Site and stores information about IP address, operating system, web browser, and pages visited. Also collected is information about demographics of the Site users, the device used, and where the visit originated.  Google provides certain privacy options and choices in this regard, which are described here.

If you choose to disable cookies or Flash cookies, some areas of our Site may not work properly. Our advertisers and partners may also use their own cookies. We do not control use of these cookies used by advertisers and partners and expressly disclaim responsibility for information collected through them.

We may use software tools such as Flash or JavaScript to collect page interaction information such as clicks, drags, and hover-overs, response times, errors, and length of visits to certain pages.

We may use clear gifs (otherwise known as web bugs or web beacons) to gather information about your visit to the Site, such as what you click on and pages and information you viewed. Additionally, be aware that advertisers and partners may also use their own clear gifs and we do not control use of these by advertisers and partners and expressly disclaim responsibility for information collected through them. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are placed on a user’s hard drive, clear gifs are embedded invisibly on web pages.

Business data: We may collect the name, address, e-mail address, phone number, company name, job title, position and job responsibilities of contact persons in the context of our business relationship with customers, vendors and other partners.

End-users’ data: We may collect and process the following types of Personal Data when you use our products and services: name, contact details, job title, position, job responsibilities, address, email address, IP and MAC address, User ID and password, location of the device, and data we collect from you social media account when you use a social media sign-in (i.e., your date of birth, age, gender and marital status).

Public Areas of the Site: We display your name and public profile information (collectively, your “Public Profile”) when you post content to or use forums, blogs, and other community features of the Site (collectively, “Public Areas”). Your Public Profile is available on the Public Areas to other users, and they will be able to identify your activities on the Public Areas that are associated with your Public Profile. If you post content to or use Public Areas or send emails or other messages to other users of the Public Areas, you should be aware that any Personal Data you provide can be read, collected or used by other users of the Public Areas. We are not responsible for the Personal Data you choose to submit in the Public Areas or send to other users. We may allow you to log into forums or blogs using a third party service. Your account with that service is provided by a third party, not us, and is subject to that third party’s terms and conditions and privacy policy.

  1. How We Use Your Personal Data

Site users’ data: We may use the Personal Data you submit to us on our Site to provide you the services you request, aid us in serving you better, and to respond to your requests.

We may also use the Personal Data we obtain about you on our Site to:

  • Facilitate the creation of and secure your Account on our network;
  • Identify you as a user in our system;
  • Provide the services and customer support you request;
  • Improve the quality of experience and provide you a personalized experience when you use the Site;
  • Send you administrative e-mail notifications, such as security or support and maintenance advisories (the e-mails we send may contain code that enables our database to track your usage of the e-mail, such as whether the e-mail was opened and/or what links (if any) were clicked);
  • Respond to your inquiries related to employment opportunities or other requests; and
  • Contact you, including by e-mail, postal mail, or telephone, to market our products and services and also third party products and services we believe may be of interest to you.

Also, we may record the IP address of a visitor to our Site and look up the host name or domain name associated with that IP address.

Business data: We may use the Personal Data we obtain about you in the context of our business relationship to:

  • Manage our existing and prospective relationships with customers, vendors and other partners;
  • Communicate with existing and prospective customers, vendors and other partners (for example, about the products and services we offer or intend to offer);
  • Perform accounting, auditing, billing, and collection activities; and
  • Comply with applicable legal requirements, industry standards, and our policies.

End-users’ data: We use the Personal Data we obtain about end-users to provide them with our products and services.

In addition, we may use Personal Data of end-users, Site users, customers, vendors and other partners to investigate and help prevent potentially unlawful activity or activity that threatens the network or otherwise violates the customer agreement for that service.

  1. Disclosure of Your Data

 Except as described below, we do not share, sell or rent your Personal Data with third parties:

We may share your Personal Data with third party service providers under contract to perform functions on our behalf. Examples include sending postal mail or e-mail, storing data, conducting data analytics to improve our products and services, performing quality assurance, providing technical support, providing marketing assistance, verifying identity, and providing customer service. These third parties may have access to your Personal Data only as needed to perform their functions. These service providers are not permitted to use the personal data for their own purposes.

When we record the IP address of a visitor to our Site and look up the host name or domain name associated with that IP address, we may pass that host name or domain name to third party partners for use in marketing products and services to the organization or entity associated with that host name or domain name.

We may also share your Personal Data with entities within the Xirrus Group to whom it is reasonably necessary or desirable for us to disclose your Personal Data, and with our resellers and distributors.

Information assets, including your Personal Data, may be disclosed or otherwise transferred to an acquirer, successor, or assignee of our company as part of any merger, acquisition, debt financing, sale of assets, or similar transaction, or in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets. Should such a transaction occur, we will use reasonable efforts to direct that company to use your Personal Data in a manner that is consistent with this Privacy Policy

We may disclose your Personal Data if we have a good faith belief that disclosure is necessary to: (1) comply with the law or with legal process served on us, including lawful requests for disclosures by U.S. and other authorities, including to meet national security or law enforcement requirements; (2) protect and defend the rights or property of us or our users; (3) act in an emergency to protect someone’s safety; or (4) investigate any violation or potential violation of the law, this Privacy Policy, the Agreement, or any other agreements between you and Xirrus.

  1. International Data Transfers

To offer our services, we may transfer your Personal Data to recipients in countries other than the country in which the data were originally collected, including the United Sates, where we are headquartered. The laws in those countries may not offer the same level of data protection as the country in which the data initially were provided. When we transfer your Personal Data to recipients in other countries, we will protect the data as described in this Privacy Policy.

Xirrus, Inc. is certified under the EU – U.S. Privacy Shield framework. The Privacy Shield certification can be found at https://www.privacyshield.gov/list.  To view our Privacy Shield Privacy Policy, please click here.

Xirrus, Inc. is also certified under the Swiss – U.S. Safe Harbor framework. The Safe Harbor certification is available here.

In addition, where applicable, we will comply with legal instruments providing adequate safeguards for the transfer of Personal Data to countries outside the European Economic Area or Switzerland, such as the European Commission’s standard contractual clauses.

  1. Choices and Rights Regarding Your Personal Data

We offer you choices regarding the collection, use, and sharing of your Personal Data. We may periodically send you free newsletters and emails about new services, products, or other noteworthy news. Where required under applicable law, we will only send you promotional communications with your consent. When you receive newsletters or promotional communications from us, you may indicate a preference to stop receiving further communications from us and you will have the opportunity to “opt-out” by following the unsubscribe instructions provided in the email you receive, by changing your account settings, or by contacting us at unsubscribe@xirrus.com. Should you opt-out of receiving future mailings, we may share your email address with third parties to ensure that you do not receive further communications from third parties. Despite your indicated email preferences, we may send you notices of any updates to this Privacy Policy, the Terms of Use, or other terms for the Site.

Subject to applicable law, you may have the right to request access to and receive information about the Personal Data we maintain about you, update and correct inaccuracies in your Personal Data, and have the information blocked or deleted, as appropriate. You also may have the right to object to our processing and disclosure of your Personal Data and withdraw your consent to our processing and disclosure of Personal Data at any time.  Please note that you may not be able to benefit from all features of the Site or our services if you request the deletion of your Personal Data, object or withdraw your consent to the processing your Personal Data. To exercise these rights, you should contact us at privacy@xirrus.com.

We do not track our Site visitors over time and across third party websites to provide targeted advertising except as otherwise described in this Privacy Policy, and we do not specifically respond to “Do Not Track” (“DNT”) signals.

  1. Security

We use physical, managerial, and technical security measures that are designed to protect your Personal Data against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure or access, or any other unlawful form of processing. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, while Xirrus uses reasonable efforts to protect your Personal Data, Xirrus cannot guarantee its absolute security.

  1. Changes to our Privacy Policy

We may make periodic changes to this Privacy Policy, which we will post to this page. We will indicate in this Privacy Policy the date of the latest revision. All changes will be effective from that date. In the event that any modifications to this Privacy Policy materially alter your rights or obligations hereunder, we will make reasonable efforts to notify you of the change and, where required by applicable law or as we otherwise deem appropriate, to obtain your consent.  For example, we may generate a pop-up or similar notification when you access the Site for the first time after such material changes are made.  Your continued use of the Site or our services after the revised Privacy Policy has become effective indicates that you have read, understood and agreed to the then-current version of this Privacy Policy.

  1. Contacting Xirrus

We can be reached by e-mail at privacy@xirrus.com or by mail at:

Xirrus Inc., 2101 Corporate Center Drive, Thousand Oaks, CA 91320

Attn: Data Security Department

Xirrus UK Ltd. is the entity responsible for Personal Data collected from Site users and contact persons at customers, vendors and other partners in the EEA and Switzerland. You can reach Xirrus UK Ltd. at privacy@xirrus.com or at 11th Floor Whitefriars, Lewins Mead, Bristol, Avon BS1 2NT.