Alcatel-Lucent Global Privacy and Data Protection Web Site Policy Statement

Our Commitment to Privacy and Protection of Your Personal Data

Alcatel-Lucent International, a wholly owned subsidiary of Alcatel-Lucent, and all Alcatel-Lucent legal entities (collectively “Alcatel-Lucent”) recognize that our employees, and the individuals who represent companies with whom we conduct business, value their privacy. However, in order to conduct a global business in this increasingly electronic economy, the collection of the personal data of individuals is often necessary. We respect your right to privacy and are committed to protecting your personal data. It is our goal to balance the benefits of e-commerce with your right, as an individual, to prevent the misuse of your personal data.

What Is Personal Data

Personal data means any information that, when used alone or combined with other data, 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 addresses, telephone number, title, birth date, gender, occupation, customer contact information and/or other personal information that may be required in order for us to provide a service you request, or may have requested, at our web sites.

Compliance With Laws

Alcatel-Lucent strives to comply with all applicable and known laws around the world that are designed to protect your right to privacy and prevent misuse of your personal data. Although legal requirements may vary from country to country, we intend to adhere to the principles set forth in this Global Privacy and Data Protection Web Site Policy Statement even if we transfer your personal data from your country of residence to countries that may not provide the same privacy rights or require the same level of protection for your personal data. Our commitment is to protect your personal data no matter where it is collected, transported, processed or retained.

US Subsidiary - Safe Harbor Privacy Statement

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

Web Sites Covered by Our Privacy Statement

This Alcatel-Lucent Global Privacy and Data Protection Web Site Policy Statement applies to all web sites and domains of Alcatel-Lucent (www.alcatel-lucent.com). Alcatel-Lucent web sites may provide links to unaffiliated third-party web sites for your convenience and information; however, Alcatel-Lucent does not control those unaffiliated third-party web sites or (except where Alcatel-Lucent is providing your personal data to a third party with whom Alcatel-Lucent has contracted for services) their privacy policies or practices as they relate to the use and protection of your personal data. You may visit those third-party links at your sole discretion and should read their privacy policies and statements before providing them your personal data.

Collecting Your Personal Data

You will be able to browse our web sites anonymously unless you have previously indicated that you wish Alcatel-Lucent to remember your login identification and/or password. In some circumstances, we may request you to provide personal data. Your response to such a request is strictly voluntary. Alcatel-Lucent uses this personal data to customize your experience on our web sites. We also may use your personal data for other business purposes, such as alerting you to products and services that can assist you in your business, promoting site registration, order processing and online customer service.

When you visit certain Alcatel-Lucent web pages, you may need to be registered and create a password in order to log in. The use of those web pages, and the downloadable information on such web pages, may be governed by a written agreement between you, or your employer, and Alcatel-Lucent. Unless you request your personal data to be deleted, it may be retained by Alcatel Lucent, pursuant to applicable laws, to: (i) verify compliance with the agreement, (ii) track software and documents you download; or (iii) 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 only if it has been collected in accordance with acceptable privacy practices consistent with the Alcatel-Lucent Global Privacy and Data Protection Policies as well as applicable laws.

In general, you can visit our web sites without divulging any personal data. However, there are areas of our web sites that require us to collect personal data to complete the customization functions for which they are designed that may not be available to those individuals who elect not to provide the personal data requested. You are always welcome to visit the public portion of the Alcatel-Lucent web sites without revealing any personal data.

Use of Your Personal Data

When we collect your personal data from you, we will inform you at the time as to the reason we are requesting such personal data. The personal data will be used only for Alcatel-Lucent business purposes such as: (i) responding to your requests for products, documentation and/or services; (ii) processing your order or invoice; (iii) conducting a commercial transaction; (iv) corresponding with you and/or your company; (v) enabling your subscription or event registration; (vi) handling a job application; (vii) sending direct marketing information; and/or (viii) performing market research. We will also use your personal data to personalize the content you review and to better understand how you use the web sites in order to improve the services Alcatel-Lucent provides as well as the web site information.

Upon your acceptance of the Terms of Use, which this Alcatel-Lucent Global Privacy and Data Protection Web Site Policy Statement is a part, such an acceptance will include your permission to us to collect and use your personal data. However, you have the right to request Alcatel-Lucent not to contact you for the purposes of sending you newsletters, customer surveys, direct marketing materials and/or market research information. You can exercise this right by clicking on the appropriate option or checkbox at the point where the personal data is collected or by editing your personal data we have collected.

In specific cases, Alcatel-Lucent may request your direct consent to use your personal data by providing an “opt-in” and/or “opt-out” checkbox in information fields before your personal data can be used for any additional purposes to that for which your consent has been or is given.

Disclosure of Your Personal Data to Third Parties

If you elect to provide us with personal data, we may transfer that personal data within the Alcatel-Lucent entities 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 information, credit card information and ordering/invoicing information.

In addition, Alcatel-Lucent may share your personal data (with the exception of account, credit card, and ordering information) with other Alcatel-Lucent business partners who may desire to alert you to new products and services to improve your competitive edge, 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 consent to do so. If you do not want to receive marketing materials from any of our business partners, please do not provide contact information via the Internet, or let them know directly that you wish to be removed from their contact list.

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 reserves the right to share your personal data to respond to information requests by duly authorized governmental authorities and subject to applicable laws. In exceptionally rare circumstances, where national, state or company security is at issue (such as with the World Trade Center terrorist act in September 2001), Alcatel-Lucent reserves the right to share our entire database of employees, visitors, vendors and customers with the appropriate governmental authorities duly authorized by applicable laws.

Collecting Your Domain Information

Alcatel-Lucent also collects domain information as a part of our analysis of the use of our web sites. This data enables us to become more familiar with the individuals who visit our web sites and pages, how often they visit, and what parts of the web sites they visit most often. Alcatel-Lucent uses this information to improve our web-based offerings. This information is collected automatically and requires no action on your part.

Collecting Your Information through Cookies

Some pages on our web sites use “cookies,” which are small files that are placed on your hard drive by the web site for identification purposes. These files are used for site registration and customization for the next time you visit us. It identifies you to a web site when you revisit to load your preferences and track the pages you visit. If your browser is set up to automatically accept cookies, your browser will add this text in a small file to your hard drive. Most web browsers allow you to modify the way cookies are handled. You can refuse cookies or choose to be warned when receiving a cookie in order to be given a choice to accept or reject a cookie. By not accepting cookies, you may have to manually input user IDs and passwords to access certain information on this web site, and some pages may not fully function. Please note that the only personal data held in a cookie is personal data you have provided to Alcatel-Lucent online.

Securing Your Information

We have put in place appropriate physical, electronic and managerial procedures to (i) prevent unauthorized access to your personal data, (ii) maintain personal data accuracy, (iii) ensure correct use of information, and (iv) safeguard and secure your personal data we collect online.

Please take note of the following to ensure the security of your personal data and other confidential information you may provide online:

  • You should be aware that when you disclose personal data or other confidential information in discussion forums, blogs or chat rooms, such personal data or other confidential information is accessible to and collectable by others who are present or who may have access to the forum, blog or chat room.
  • Alcatel-Lucent advises you to protect yourself against unauthorized access to your computer and disclosure of your Alcatel-Lucent password.
  • If you believe that your password has been compromised, you should immediately change your password.

If you believe there has been a security breach at Alcatel-Lucent involving your personal data, please contact Alcatel-Lucent at the address provided below.

Supporting Children’s Privacy

Alcatel-Lucent web sites do not target, and are not intended to attract, children under the age of 13. Alcatel-Lucent does not knowingly collect personal data from children under the age of 13 or send requests to children for personal data.

Accessing and Correcting Your Personal Data

Alcatel-Lucent wants to ensure that any personal data you provide remains accurate. If you have changes to your personal data, you can review and update your personal data after logging onto the web site with your user name and password. You can correct errors in your personal data by sending us a request and pointing out the error. To protect your privacy and secure your personal data, we will also take reasonable steps to verify your identity before granting access or making the corrections.

Contacting Us

We value your opinions and feedback. Please email us any questions or comments about our Global Privacy and Data Protection Web Site Policy Statement, or write us at:

Alcatel-Lucent
Chief Privacy and Data Protection Counsel - Law
Room 6E236
600 – 700 Mountain Avenue
Murray Hill, New Jersey 07974

Complying with and Changing Our Global Privacy and Data Protection Web Site Policy Statement

The Alcatel-Lucent Global Privacy and Data Protection Web Site Policy Statement was last updated on 31 May 2011. Alcatel-Lucent utilizes the self-assessment approach to assure our continuing compliance with our Global Privacy and Data Protection Web Site Policy Statement. From time to time, Alcatel-Lucent verifies that the policy statement is accurate and in line with applicable laws, comprehensive for the information intended to be covered, prominently displayed, completely implemented, and in conformity with the U.S. Commerce Department’s Safe Harbor Principles.

Alcatel-Lucent reserves the right to make changes to this policy statement from time to time without notice to you. We recommend that all visitors and users of this web site re-visit the Alcatel-Lucent Global Privacy and Data Protection Web Site Policy Statement 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 the Alcatel-Lucent Global Privacy and Data Protection Web Site Policy Statement.