Alcatel-Lucent Global Privacy and Data Protection Policy

This Policy applies to all business activities of Alcatel-Lucent S.A., Alcatel- Lucent International and all of their subsidiaries, collectively “Alcatel-Lucent”, and to all Alcatel-Lucent web sites that are operated by or on behalf of Alcatel-Lucent and/or link to this Global Privacy and Data Protection Policy.

This Policy does not apply to consumer activities as Alcatel-Lucent does not have direct business relations with consumers.

Our Commitment To Privacy And Protection Of Your Personal Data

Alcatel-Lucent respects your right to privacy and is committed to protecting your personal data.

In order to conduct a successful business in an increasingly global and digital economy, the processing of personal data, which includes, but is not limited to, collecting, using, storing, retaining, accessing and/or disclosing, by Alcatel-Lucent is often necessary.

Alcatel-Lucent recognizes in addition the legal rights and expectations of its customers, suppliers, partners and other third parties submitting personal data to Alcatel-Lucent or conducting business with or on behalf of Alcatel-Lucent, and of its employees and other personnel, (hereafter collectively referred to as “individuals” or “data subjects” or “you”) as they relate to the privacy and protection of the individual’s personal data.

It is our goal to balance the benefits of processing personal data with your right, as an individual, to control the use of your personal data. Meeting this commitment is a primary management objective and the individual and collective responsibility of all Alcatel-Lucent entities and employees as well as third parties conducting business with or on behalf of Alcatel-Lucent.

What Is Personal Data?

Personal data means any information alone or combined with other data which may be used to identify an individual. This includes, but is not limited to, an individual’s first and last name, e-mail address, mailing and/or residential address, telephone number, title, birth date, gender, occupation, customer contact information, IP-address and/or other personal information that may be required in order for us to provide a service to you and/or to conduct business with you.

Contacting Us

We value your opinion and feedback.

Please email us any questions or comments about our Global Privacy and Data Protection Policy, or write us at:

Alcatel-Lucent Chief Data Privacy Officer
148/152 Route de la Reine, 92100 Boulogne-Billancourt - France


Alcatel-Lucent’s 9 Principles For Privacy & Data Protection

The visual to the right represents Alcatel-Lucent’s 9 principles for Privacy & Data Protection organized in 4 domains:

Learn more by clicking on the name of the privacy principle on the visual to the right, or the name of the domain below.

Copyright © 2011 Alcatel-Lucent. All rights reserved

MANAGEMENT

AT A GLANCE

1. Roles And Responsibilities Assigned

Assigning the management and accountability

2. Monitoring & Enforcement

Monitoring and enforcing compliance with Policies and laws.

1. Management & Accountability

Roles And Responsibilities Assigned

Alcatel-Lucent assigns and supports the management and accountability of its Global Privacy and Data Protection Policy and associated procedures.

Alcatel-Lucent maintains a Privacy & Data Protection governance structure under which the Chief Privacy Officer, the Privacy & Data Protection Program Owner and other functions and bodies as may be required or useful, have assigned responsibilities for defining, documenting, promoting and communicating the Alcatel-Lucent Global Privacy and Data Protection Policy and programs, and for developing and implementing processes and procedures to ensure global compliance with those policies and procedures as well as applicable privacy and data protection laws.

(See “Our Commitment to Privacy and Protection of Your Personal Data” at the top)

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2. Monitoring & Enforcement

Compliance With Laws

Alcatel-Lucent will comply with all mandatory applicable laws around the world that are designed to protect your right to privacy and lawful processing of your personal data.

Alcatel-Lucent maintains processes and procedures for periodically assessing and verifying compliance with these requirements.

US Subsidiary - Safe Harbor Principles

For personal data of individuals that Alcatel-Lucent USA Inc., the US subsidiary of Alcatel-Lucent, receives from countries covered by the European Directive 95/46/EC or from Switzerland, Alcatel-Lucent USA Inc. is committed to handling such personal data in accordance with the Safe Harbor Principles.

Alcatel-Lucent USA Inc. adheres to the U.S.-EU Safe Harbor Framework and to the U.S.-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland. Alcatel-Lucent USA Inc. has certified that it complies with the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement.

To learn more about the Safe Harbor program, and to view Alcatel-Lucent USA Inc.’s certification, please visit http://www.export.gov/safeharbor/

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RIGHT OF INDIVIDUALS

AT A GLANCE

3. Transparency

Informing individuals about the processing of their Personal Data.

4. Consent

Informing individuals of the available choices they may have relating to the processing of their data.

5. Data Subject Access

Providing individuals access to their personal data for review and updates.

3. Transparency

Notice To Individuals

Alcatel-Lucent provides required notices through different means (emails, system privacy notices, etc.) to individuals relating to the processing of their personal data by Alcatel-Lucent.

Required Notices include information like the purpose(s), the personal data, individuals’ rights and choices, and the recipients, if any, for which such individuals’ personal data are being processed.

Web Sites Covered By This Policy

The Alcatel-Lucent Global Privacy and Data Protection Policy applies also to all web sites and domains of Alcatel-Lucent.

Links To External Web Sites

Alcatel-Lucent web sites may provide external links. Alcatel-Lucent does not control those unaffiliated third-party web sites and their privacy policies and practices as they relate to the use and protection of your personal data.

Compliance With Anti-Corruption

Alcatel-Lucent maintains an Anti-Corruption Third Party Risk Management program and therefore processes personal information including, but not limited to, names of third party employees, majority shareholders, directors and management, either submitted online by third party representatives about their companies, or submitted by Alcatel-Lucent employees based on publicly available information.

The Anti-Corruption Third Party Risk Management process is to fulfill legal requirements under applicable anti-corruption laws and treaties, including but not limited to the U.S. Foreign Corrupt Practices Act, the U.K. Bribery Act, and the OECD anti-bribery treaty.

The Third Party Register automates and captures the business and compliance due diligence information on third parties to review and approve or reject all types of third parties for engagement with Alcatel-Lucent.

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4. Consent

Collecting Your Personal Data

Except where legally required, your provision of personal data is strictly voluntary. Alcatel-Lucent informs individuals of the available choices they may have relating to the processing of their personal data and, when required, obtains the related consent.

Wherever appropriate, individuals will be informed of their available options in providing such personal data (e.g., “opt-in” or “opt-out”). In addition, Alcatel-Lucent will seek to obtain, where required, the implicit or explicit consent of such individuals with respect to the collection, use, retention and disclosure of their personal data.

When you visit certain Alcatel-Lucent web pages, you may need to be registered and create a password in order to log in.

If you have indicated that you wish Alcatel-Lucent to remember your login identification and/or password this information will be used to complete the customization functions on our web sites. In some circumstances, we may request you to provide personal data. Your response to such a request is strictly voluntary.

Unless you request your personal data to be deleted or revoke your consent, it may be retained by Alcatel Lucent, pursuant to applicable laws, to:

  1. verify compliance with the agreement;
  2. track software and documents you download;
  3. track page visits and usage of other applications available on the Alcatel-Lucent web sites.

We also may receive your personal data from our business partners and suppliers. We intend to use such personal data for the purposes described in the paragraph above.

Use Of Cookies

A cookie is a piece of information, usually a small text file that is generated by a web server and saved on your device. Most of the Alcatel-Lucent web sites employ cookies, primarily to improve your user experience. You can change the settings of your browser to refuse cookies or choose to be warned when receiving a cookie in order to be given a choice to accept or reject a cookie.

To learn more, please read our Cookie Policy by clicking here.

Social Plug-Ins

Alcatel-Lucent web sites may provide social plug-ins as part of social media.

Alcatel-Lucent web sites may provide social plug-ins from numerous social networking web sites (such as Facebook.com, Google+, LinkedIn, etc). These plug-ins are identified with their respective usual logos and/or suffixes.

If you visit an Alcatel-Lucent web page that contains such plug-ins, they are initially disabled until you click the provided plug-in button to enable it. By enabling a particular plug-in, you declare your consent to establish a connection and the transmission of data to the related social network web site.

Revoking Consent

At any time, you can revoke your consent to the collection, processing, and use of your personal data for the future.

Upon revocation of your consent or request for deletion of your personal data, the related personal data will be deleted, unless:

  • there is a legal justification for continued use and processing of personal data, or
  • the revocation or request concerns data which is necessary for billing and accounting purposes, or
  • the retention of the personal data is mandatory due to other legal reasons,
  • the availability of the personal data is necessary for the performance of the purpose.

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5. Data Subject Access

Accessing Your Personal Data

Individuals have the right to request access, review, deletion and blocking of their personal data, and to make or request updates where applicable.

(See also “Data Quality”).

This can be done either by logging onto the web site with your user name and password, or by contacting us and by clarifying your request. To protect your privacy and secure your personal data, we will also take reasonable steps to verify your identity before granting you such an access.

In addition, Alcatel-Lucent has local processes and procedures in place to handle complaints and disputes relating to the collection, use, retention and disclosure of personal data.

To manage the latest industry news you receive from Alcatel-Lucent, you can access the Profile and Subscription Center by clicking here.

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INFORMATION CONTROLS

AT A GLANCE

6. Data Protection

Implementing security means to protect personal data.

7. Data Quality

Making reasonable efforts to ensure the accuracy of personal data.

6. Data Protection

Securing Your Information

Alcatel-Lucent secures personal data from unauthorized access, alteration, use and disclosure.

Industry standard information security safeguards are used to appropriately protect both physical and electronic personal data, in any format or media, against unauthorized access, alteration, use and disclosure.

We have put appropriate physical, electronic and managerial procedures and controls in place to:

  1. prevent unauthorized access and disclosure of your personal data,
  2. maintain personal data accuracy,
  3. ensure correct use of information, and
  4. safeguard and secure your personal data.

Our commitment is to protect your personal data no matter where it is collected, transported, processed or retained.

If you believe there has been or may have been a security breach at or by Alcatel-Lucent involving your personal data, please immediately contact Alcatel-Lucent at the address provided in the section “Contact Us”.

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7. Data Quality

Integrity Of Your Information

Alcatel-Lucent wants to ensure that the quality of your personal data collected, used, retained and disclosed remains accurate. If your personal data need changes, you can and are encouraged to review and update it.

Individuals have the right to review their personal data and make or request updates, data deletion or blocking where applicable. This can be done either by logging onto the web site, or by contacting us and describing the requested change.

To protect your privacy and secure your personal data, we will also take reasonable steps to verify your identity before applying necessary changes.

See also “Accessing Your Personal Data”.

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INFORMATION LIFECYCLE

AT A GLANCE

8. Proportionality

Collecting and using personal data only for the specific purpose and as long as legally allowed.

9. Disclosure

Disclosing personal data only for a legitimate purpose or where required by law.

8. Proportionality

Collection and Use of Your Personal Data

Only necessary personal data will be collected and used for Alcatel-Lucent’s legitimate business in line with the purposes for which it is collected.

Main Alcatel-Lucent business purposes include:

  1. responding to your requests for products, documentation and/or services;
  2. processing your order or invoice;
  3. conducting a commercial transaction;
  4. corresponding with you and/or your company;
  5. enabling your subscription or event registration;
  6. handling your job application;
  7. sending you direct marketing information;
  8. performing market research;
  9. advertising our offering and conducting surveys;
  10. conducting compliance due diligence assessments;
  11. executing employment contract;
  12. promoting site registration;
  13. delivering, improving and/or personalizing online services.

Retention Of Your Personal Data

Personal data may be retained only as long as necessary to fulfill the permitted purpose(s) and in compliance with the retention period(s) permitted by the applicable country laws and as may be defined in the Alcatel-Lucent Information and Records Management Policy.

Supporting Children’s Privacy

Alcatel-Lucent respects children’s privacy.

Alcatel-Lucent web sites do not target, and are not intended to attract, children. Alcatel-Lucent does not knowingly collect personal data from children or send requests to children for personal data. The definition of "child" or "children" should take into account applicable laws (like the US Children's Online Privacy Protection Act (COPPA)) as well as national and regional cultural customs.

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9. Disclosure

Disclosure Of Your Personal Data To Third Parties

If you provide us your personal data, we may transfer that personal data to Third Parties so that such Third Parties may provide services like operations required to transact business with you, or to alert you about new products or services.

If you provide us your personal data, we may transfer that personal data within Alcatel-Lucent or to Alcatel-Lucent affiliated third parties or business partners. Your personal data may be transferred within your country and/or across borders from your country of residence or jurisdiction to Alcatel-Lucent entities, affiliated third parties and/or business partners in other countries around the world so that such Alcatel-Lucent entities, affiliated third parties and/or business partners may provide services and other operations required to transact business with you. Such personal data may include, but is not limited to, account or contact information, credit card information and ordering/invoicing information.

In addition, Alcatel-Lucent may share some of your personal data with other Alcatel-Lucent business partners who may desire to alert you to new products and services, and only in cases where we believe your business interests will be served. Alcatel-Lucent will share your personal data with its business partners only if you have provided us with your explicit or implicit consent to do so.

Alcatel-Lucent works with certain companies that deliver Alcatel-Lucent advertising and undertake surveys on behalf of Alcatel-Lucent. These companies may collect information to help us determine which products, services and offerings are of most interest to our current and future customers. Unless you have given your consent, implicitly or explicitly, the information collected is not identifiable at an individual level. However, it may be identifiable at a company level, with or without your consent, or aggregated at an anonymous level to provide us with general statistics and trends.

In the event that Alcatel-Lucent sells a part or parts of its business, the personal data that we have collected could be transferred to the acquiring company unless you instruct Alcatel-Lucent not to do so in writing.

Alcatel-Lucent requires a commitment by third parties receiving personal data to adhere to all applicable requirements of this Alcatel-Lucent Global Privacy and Data Protection Policy and related procedures, as well as the data privacy and protection law(s) of the applicable countries.

Alcatel-Lucent reserves the right to share your personal data to respond to information requests by duly authorized governmental authorities and subject to applicable laws.

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Complying With And Maintaining Our Global Privacy and Data Protection Policy

Alcatel-Lucent primarily utilizes the self-assessment approach to assure our continuing compliance with our Global Privacy and Data Protection Policy. Alcatel-Lucent verifies that the Policy is adequate and in line with applicable laws, comprehensive for the information intended to be covered, prominently displayed and completely implemented.

Alcatel-Lucent reserves the right to make changes to this Policy from time to time without providing a notice to you. We recommend that you re-visit this Alcatel-Lucent Global Privacy and Data Protection Policy page occasionally to learn of any new privacy practices or changes to our Policy. Your continued use of the Alcatel-Lucent web sites indicates your acknowledgement and/or acceptance of any changes to this Alcatel-Lucent Global Privacy and Data Protection Policy.

This Alcatel-Lucent Global Privacy and Data Protection Policy was last updated in November 2014. Main changes are as follows:

  • introduction of and alignment with our 9 privacy principles;
  • extension of its application scope to non web activities;
  • reference to the new cookie policy;
  • new structuring and layout to enhance readability.