Privacy & Cookies Statement

Effective Date: February 2022

Purpose

This Privacy & Cookies Statement ("Privacy Statement") describes how CommScope, Inc. of North Carolina, located at 3642 E US Highway 70, Claremont, North Carolina 28610, USA and its affiliates and subsidiaries (collectively, "Company" or "CommScope") collect, use, share, and otherwise process individually identifiable data about visitors to this Site (defined below), contact persons of our customers, prospects, distributors, sales representatives, vendors, investors, suppliers, and individual end-users of CommScope products or services ("Personal Data"). To obtain information about the local CommScope entity in your jurisdiction, please contact us as detailed below.

Scope

This Privacy Statement applies to Personal Data that we collect through our public website, mobile applications, or through any CommScope products or services that link to this Privacy Statement (collectively, the "Sites"), including Ruckus-branded products or services, as well as offline through contact forms or other communications with CommScope personnel.

This Site contains links and references to other websites administered by unaffiliated third parties. This Privacy Statement does not apply to such third-party websites. When you click a link to visit a third-party website, you will be subject to that website's privacy practices. We encourage you to familiarize yourself with the privacy and security practices of the linked third-party websites before providing any Personal Data on that website.

Personal Data about our employees, contractors, and other CommScope temporary workers are addressed through internal company policies and procedures, and are outside the scope of this Privacy Statement.

For the privacy statement applicable to recruiting activities and job candidates, please see CommScope's Recruiting Data Protection Notice.

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Summary of Key Points

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1. Collection of Personal Data

We collect the following categories of Personal Data:

Basic Data: Name, title, company, job responsibilities, phone number, mailing address, email address, contact details, and recordings in certain limited circumstances, where you have provided consent.

Registration Data: Newsletter requests, subscriptions, downloads, and username/passwords.

Device Data: Computer Internet Protocol (IP) address, unique device identifier (UDID), cookies and other data linked to a device, and data about usage of our Site and communications (Usage Data). Note, however, we do not consider Device Data to be Personal Data except where we link it to you as an individual or where applicable law requires.

Marketing Data: Computer Internet Protocol (IP) address, unique device identifier (e.g., MAC address), cookies and other data linked to a device, and data about usage of our Site and communications (Usage Data).

Credit Card Data:  Includes credit card number and other payment information collected to order products or services from us.

For Ruckus products and services, in addition to the above-mentioned categories of Personal Data, the following categories of Personal Data are also collected:

End-Client Data: Includes information collected from end clients connected to wired or wireless networks, such as MAC address, IP address, username, device OS type, mobile applications used and amount of data uploaded or downloaded, among others.

Network Data: Includes network name, network type, captive portal options, and telemetry information, among others. Note, however, we do not consider Network Data to be Personal Data except where we link it to you as an individual or where applicable law requires.

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2. Use of Personal Data

We use the above categories of Personal Data for the following purposes:

 

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3. Sharing of Personal Data

We share Personal Data with the following categories of recipients:

Affiliates: We share Personal Data within the CommScope group of companies as necessary for the purposes we described above.

Business Partners. We share Personal Data with certain trusted business partners for Ruckus products and services, including but not limited to value-added resellers (VARs), where we have customer consent to do so.

Service providers: We share Personal Data with service providers to enable such parties to perform functions on our behalf and under our instructions in order to carry out the purposes identified above, such as marketing, identity management, and web hosting. We require service providers to provide reasonable security for Personal Data and to use and process such Personal Data on our behalf only at our instruction.

Auditors and advisors: We share Personal Data with auditors for the performance of audit functions and advisors for the provision of legal and other advice.

Business reorganization: We share Personal Data with any corporate purchaser or prospect to the extent permitted by law as part of any merger, acquisition, sale of company assets, or transition of service to another provider, as well as in the event of insolvency, bankruptcy, or receivership in which Personal Data would be transferred as an asset of CommScope.

Mandatory disclosures and legal rights: We share Personal Data in order to comply with any subpoena, court order or other legal process, or other governmental request. We also share Personal Data to establish or protect our legal rights, property, or safety, or the rights, property, or safety of others, or to defend against legal claims.

If you have questions about the parties with which we share Personal Data, please contact us as specified below.

 

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4. Marketing Choices

You have control regarding our use of your Personal Data for directing marketing. IIf you no longer wish to receive any marketing communications, remain on a mailing list to which you previously subscribed, or receive any other marketing communication, you can choose to not receive such communications at any time. Please follow the unsubscribe link in the relevant communication, customize your communications in our Preference Center, or contact us as detailed below.

 

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5. Cookies

We use and allow certain trusted partners to use cookies, web beacons, and similar tracking technologies (collectively, "cookies") on our Site.

What are cookies?

When you visit any website, it may store or retrieve information on your browser, mostly in the form of cookies. Cookies are small amounts of data that are stored on your browser, device, communication, or the page you are viewing. This information might be about you, your preferences or your device and is mostly used to make the site work as you expect it to. The information does not usually directly identify you, but it can give you a more personalized web experience. Some cookies are deleted once you close your browser, while other cookies are retained even after you close your browser so that you can be recognized when you return to a website. More information about cookies and how they work is available at Cookiepedia.

How do we use cookies?

We use cookies to provide the Site, products, and services, gather information about your usage patterns when you navigate this Site in order to enhance your personalized experience, and to understand usage patterns to improve our Site, products, and services. We also allow certain trusted partners to place cookies on our Site in order to collect information about your online activities on our Site over time and across different websites you visit. This information is used to provide advertising tailored to your interests on websites you visit, also known as interest-based advertising, and to analyze the effectiveness of such advertising.

Cookies on our Site are generally divided into the following categories:

Strictly Necessary Cookies: These cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the site will not then work. These cookies do not store any personally identifiable information.

Analytical/Performance Cookies: These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site. They help us to know which pages are the most and least popular and see how visitors move around the site. All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies we will not know when you have visited our site and will not be able to monitor its performance. We use Google Analytics, and you can see below for how to exercise choice regarding such cookies by visiting https://tools.google.com/dlpage/gaoptout.

Functional Cookies: These cookies enable the website to provide enhanced functionality and personalization. They may be set by us or by third party providers whose services we have added to our pages. If you do not allow these cookies then some or all of these services may not function properly. These cookies qualify as persistent cookies, because they remain on your device for us to use during a next visit to our Site. You can delete these cookies via your browser settings.

Targeting Cookies: These cookies may be set through our site by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant adverts on other sites. They do not store directly personal information, but are based on uniquely identifying your browser and internet device. If you do not allow these cookies, you will experience less targeted advertising. You can delete these cookies via your browser settings. To learn more about certain cookies used for interest based advertising by third parties, including through cross-device tracking, and to exercise certain choices regarding such cookies, please visit the Digital Advertising Alliance, Network Advertising Initiative, Digital Advertising Alliance-Canada, European Interactive Digital Advertising Alliance or your device settings.

What are your options if you do not want cookies on your computer?

You are free to decide which of the above-described categories of cookies you would like to permit on your browser by visiting . Please note that depending on the settings you choose, the full functionality of our website may no longer be available. Additionally, you can review your Internet browser settings, typically under the sections "Help" or "Internet Options," to exercise browser-based choices you may have for certain cookies. If you disable or delete certain cookies in your Internet browser settings, you might not be able to access or use important functions or features of this Site, and you may be required to re-enter your log-in details.

 

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6. Data Subject Rights

Where required by applicable law (such as GDPR or LGPD), you may have the right to obtain confirmation that we maintain certain Personal Data relating to you and the corresponding processing activities, to verify its content, origin, and accuracy, as well as the right to access, review, port, delete or anonymize , or to block or withdraw consent to the processing of certain Personal Data (without affecting the lawfulness of processing based on consent before its withdrawal), by contacting us through the Act On Your Personal Data feature. You may also have the right to request information about third parties with whom we have shared your Personal Data, as well as the right to request review of decisions based solely on automated data processing. In particular, you have the right to object to our use of Personal Data for direct marketing and in certain other situations at any time. Contact us below for more details. Please note that we need to retain certain Personal Data as required or permitted by applicable law.

Act On Your Personal Data >

California consumers please see Section 9.

 

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7. Data Security

We maintain technical and organizational measures to protect Personal Data from loss, misuse, alteration, or unintentional destruction. However, no security measure can guarantee against compromise. You also have an important role in protecting your Personal Data. You should not share your username and password with anyone, and you should not re-use passwords across more than one website. If you have any reason to believe that your username or password has been compromised, please contact us as detailed below.

 

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8. Cross-Border Data Transfers

We transfer Personal Data to various jurisdictions as necessary for the purposes described above, including to jurisdictions that may not provide the same level of data protection as your home country. We provide appropriate protections for cross-border transfers as required by law for international data transfers. With respect to transfers originating from the European Economic Area ("EEA"), we implement standard contractual clauses approved by the European Commission, and other appropriate solutions to address cross-border transfers as required by applicable law. Where required by such laws, you may request a copy of the suitable mechanisms we have in place by contacting us as detailed below.

 

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9. Notice to California Consumers

If you reside in the United States in the state of California, we are required by California law to provide you with additional information about how we use and disclose your information, and you may have additional rights with regard to how we use your information. We have included this California-specific information below.

CA Personal Information. Consistent with the "Collection of Personal Data" section above, we collect certain categories and specific pieces of information about individuals that are considered "Personal Information" in California ("CA Personal Information"). Specifically, we may collect the following types of CA Personal Information:

• Identifiers: name, address, telephone number, email address, age, date of birth, username and password for our websites, IP address;
• Commercial information: products or services purchased, obtained or considered, other purchasing or consuming histories or tendencies, payment information, transaction history;
• Professional or employment-related information;
• Internet or other electronic network activity information: computer and connection information, statistics on page views, traffic to and from the websites, ad data and other standard weblog information; and
• Geolocation information: physical location information through the use of our website, services and/or products.

Sources. We collect certain categories of CA Personal Information from you and other third parties as described in the "Collection of Personal Data" section above. The categories of third parties from whom we collect CA Personal Information include the following:

• Third-party partners (e.g., distributors, certified installers);
• Third party applications (including blogs, chat rooms, or support centers);
• Advertising networks; and
• Other companies or organizations, such as market research firms or data aggregators.

Purposes. We collect the CA Personal Information for the business and commercial purposes described in the "Use of Personal Data" section above. We also share and/or disclose your CA Personal Information as follows:

• Sharing your CA Personal Information for business purposes: As described above in the "Sharing of Personal Data" section, we may share the following categories of your CA Personal Information with third party partners, public or government authorities and future business partners for our business purposes:
• Identifiers,
• Commercial Information,
• Professional or employment-related information
• Internet or other electronic network activity information
• Geolocation information.

As described above, examples of business purposes include product and service fulfillment, internal operations, prevention of fraud and other harm, and legal compliance.

• Sharing your CA Personal Information for other purposes: We may share the following categories of your CA Personal Information with third party partners in a manner that constitutes a "sale" under California law:
• Identifiers,
• Commercial Information,
• Professional or employment-related information
• Internet or other electronic network activity information

This information may be shared for the following purposes: marketing, analytics, product or service performance measurements.

We do not knowingly share the CA Personal Information of individuals under 16 years of age, in a manner that constitutes a "sale" under California law.

California Consumer Rights. Subject to certain exceptions, as a California resident, you have the right to: (i) request access to your CA Personal Information; (ii) request deletion of your CA Personal Information; (iii) request information about the CA Personal Information about you that we have disclosed and/or "sold" (as such term is defined under California law) to third parties within the past 12 months; and (iv) opt-out of the "sale" of your CA Personal Information, as detailed above.

• Do Not Sell My Information. To opt-out of the "sale" of your CA Personal Information as described in this section, click here.
• Exercising other California consumer rights. Should you wish to request the exercise of your other rights as detailed above with regard to your CA Personal Information, we will not discriminate against you by offering you different pricing or products, or by providing you with a different level or quality of products, based solely upon this request. Please see the CCPA Details/Do Not Sell My Information page. You also have the option of designating an authorized agent to exercise your rights on your behalf. For authorized agents submitting requests on behalf of California residents, please contact us as described below, with any evidence you have that you have been authorized by a California consumer to submit a request on their behalf.

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10. Other Issues

(i) What is the legal basis of processing?

Some jurisdictions require an explanation of the legal basis for the collection and processing of Personal Data. We have several different legal grounds on which we collect and process Personal Data, including, without limitation: (a) as necessary to perform a transaction (such as in order to provide the products and services you requested); (b) as necessary to comply with a legal obligation (such as when we use Personal Data for record keeping to substantiate tax liability); (c) consent (where you have provided consent as appropriate under applicable law, such as for direct marketing or certain cookies); and (d) necessary for legitimate interests (such as when we act to maintain our business generally, including maintaining the safety and security of the Site). With respect to legitimate interests, given that we are a B2B company, we typically collect and process limited Personal Data about customer contacts and other individuals acting in their business capacities, as part of our overall effort to reduce the privacy impact on individuals.

(ii) What are the consequences of not providing Personal Data?

You are not required to provide all Personal Data identified in this Privacy Statement to use our Site or to interact with us offline, but certain functionality will not be available if you do not provide certain Personal Data. If you do not provide certain Personal Data, we may not be able to respond to your request, perform a transaction with you, or provide you with marketing that we believe you would find valuable.

(iii) Do we engage in automated decision-making without human intervention?

We do not use automated decision-making without human intervention, including profiling, in a way that produces legal effects concerning you or otherwise significantly affects you.

(iv) Does the Site honor do not track ("DNT") signals sent via browsers?

Given the divergent practices of organizations that offer browsers and the lack of a standard in the marketplace, we do not respond to DNT signals at this time.

(v) How long do we retain Personal Data?

We typically retain Personal Data related to marketing activities for as long as you accept marketing communications from us, and upon request we will securely delete such data in accordance with applicable law. For Personal Data that we collect and process for other purposes described above, we typically retain such Personal Data for no longer than for the period necessary to fulfill the purposes outlined in this Privacy Statement and as otherwise needed to address tax, corporate, compliance, litigation, and other legal rights and obligations.

(vi) How will we handle any changes to this Privacy Statement?

We may update this Privacy Statement from time to time as our services and privacy practices change, or as required by law. The effective date of our Privacy Statement is posted above, and we encourage you to visit our Site periodically to stay informed about our privacy practices. We will post the updated version of the Privacy Statement on our Site, and ask for your consent to the changes if legally required.

 

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11. Contact Us

If you have questions or comments regarding this Privacy Statement or our privacy practices, or if you wish to contact the local person in charge for data protection in your jurisdiction, please contact us at:

CommScope, Attn: Legal Department
3642 E US Highway 70, Claremont, North Carolina 28610
Email: privacycontact@commscope.com

CommScope's Data Protection Officer for Germany can be contacted at:

datenschutz süud GmbH
Wörthstraße 15
97082 Würzburg, Germany

You may also have the right to lodge a complaint with the relevant data protection supervisory authority.