Ruckus Cloud Privacy Policy

Last revised July 23, 2016

This privacy policy (“Policy”) describes how Ruckus Wireless, Inc. (“Ruckus”) collects, uses and discloses personal information of its customers and potential customers (“Customers”) and their representatives in relation to the Ruckus Cloud service (referred to as the “Service”).

This Policy addresses processing by Ruckus where Ruckus is the controller of any personal information it collects and holds about an individual. This Policy does not describe how Ruckus processes personal information as a data processor for and on behalf of its Customers when they use the Service. Such information is separately included within the Privacy Annex to the Ruckus Cloud Hosted Service Terms and Conditions, agreed to between Ruckus and its Customers at the point of sale.

By enquiring about or using the Service, Customers consent to the processing (e.g. collection, use, and/or disclosure) of information in accordance with this Policy.

Please note: If you are a user of the Service as an employee of, or as an agent or contractor for the benefit of a Customer, or in any other way are an end-user of the Service which we provide to Customer, then it is the that Customer’s own privacy policy (where appropriate) which applies to the processing of your personal information and not this Policy.

What is Personal Information?

“Personal information” means information from which an individual can be identified, such as an individual’s name, phone number, postal address, email address and log-in information. Personal information also includes other information when it is associated with or linked to personal information that identifies an individual.

Personal information does not include “anonymous” or “aggregate” information. Anonymous information is information that is not associated with or linked to personal information and that does not enable identification of an individual, nor can it be re-constituted in order to be able to identify an individual. Aggregate information is anonymous information about a group or category of products, services or users. Ruckus may use and disclose such anonymous or aggregate information for various purposes (such as analysis of statistical trends) at its sole discretion without notice or liability to a Customer.

Information Collected by Ruckus

Information Provided by the Customer

Ruckus collects personal information and other information that the Customer expressly provides in a variety of ways in connection with registering for and using the Service. These include the following:

  • Account Registration: Ruckus collects personal information that the Customer provides to Ruckus when registering for a support or Service account, or when updating such account information. Examples of this type of information include name, company, email address, telephone number, username, password and postal address. Ruckus may indicate that some personal information is required for registration, while some is optional.

 

  • Logging In: When a Customer logs into the Service with its registered account login credentials. In addition, certain networks using the Service may require the Customer to establish or use log-in credentials. Ruckus may collect information such as email address and user or administrator-created usernames and passwords, in order to support this log-on functionality and otherwise to provide the Service.

 

  • Installation and Configuration: Ruckus also collects certain information that the Customer provides when it installs Ruckus hardware devices and configures its local area networks. Examples of this type of information include the serial numbers of the Customer’s access points (APs) and controllers and network name.

Information Automatically Collected by the Service

In addition, Ruckus collects certain information automatically as part of the operation of the Service. This information includes data like the following:

  • Log Files. When a Customer uses or accesses the Service, Ruckus’ server logs automatically capture information such as the Internet Protocol (IP) address, access time, browser type, operating system, device type (e.g., a personal computer or a mobile device) and unique device identifiers for handheld or mobile devices the Customer may be using. Additional information may also be captured such as the actions a Customer takes on the Service, and the content, features and activities that the Customer accesses and engages with on the Service.

 

  • Authentication. The Service automatically collects the serial number and MAC address of the Customer’s APs in connection with verifying and authenticating the registration of such APs.

 

  • Network Usage Information. In addition, the Service automatically collects information from terminal devices connected to networks configured and managed using the Service, as well as performance and other information regarding such networks. Examples of this type of information include information about the Customer’s APs and controllers (e.g., serial number, software version, MAC address, IP address, model number and geolocation information), information regarding the Customer’s networks (e.g., network name), information regarding connected devices including operating system, device type, device location information (e.g., Global Positioning System (GPS) data and/or location coordinates) and network traffic information (e.g., hostname, protocols, port numbers, IP addresses and MAC addresses). The Service uses this information to make network traffic data available to the Customer (and any third party administrators to whom the Customer expressly delegates access) through the online “dashboard” interface, which allows the Customer and such administrators to control network traffic.

Ruckus uses this information to administer, operate, maintain and improve the Service. If Ruckus links or associates any automatically collected information with personal information, Ruckus treats such automatically generated information as personal information under this Policy. Otherwise, Ruckus uses and disclose automatically collected information in anonymous or aggregate form.

End User and Device Data Collected by the Service for the Customer

The Service collects and processes, on a Customer’s behalf, personal information of end users or other individuals with whom Ruckus has no direct relationship. For example, Customer uses Ruckus hardware products and services (including the Service) to provide internet access to end users and to collect and analyze information regarding use of the Customer’s private, guest or public networks by the devices that connect to the internet via such networks. This includes information about those devices, such as MAC address, device type, operating system and, if the Customer is using Ruckus’s location-based service, device location in real time. The Customer is responsible under applicable data privacy laws for the collection of such information and its use by Ruckus on the Customer’s behalf (as the Customer’s data processor or equivalent), and the Customer’s own privacy policy (not this Policy) governs the collection, use and sharing of such information. Any such individual end user who seeks to access, modify or delete data should contact Customer directly.

Use of Personal Information

Ruckus uses personal information about Customer’s and their representatives to administer, operate, maintain, enhance and improve the Service and other Ruckus solutions, to enable use of certain features of the Service, to provide information to the Customer and otherwise respond to the Customer’s requests, to identify or troubleshoot issues and provide technical support, to prevent fraudulent use of the Service, to prevent or take action against activities that are or may be in violation of the Service terms of service or any applicable law, other administrative purposes and internal record keeping, and for any other purposes that Ruckus may disclose to the Customer. Ruckus may also use personal information to contact a Customer regarding Ruckus products and services that it believes the Customer may find of interest. Customers may opt-out from receiving future marketing communications from Ruckus as described below under “Direct Marketing and Customer Preferences.”

Disclosure of Personal Information

Ruckus may disclose personal information about a Customer (or its representatives) to third parties in the following circumstances:

  • Consent. Ruckus may disclose a Customer’s personal information to third parties with Customer’s consent. For example, a third party administrator to whom the Customer expressly delegates access to its Service account will have access to the Customer’s information as collected by the Service.

 

  • Service Providers and Partners. Ruckus may disclose personal information to third-party service providers (such as data storage and processing facilities) and business partners that help operate, deliver and market the Service. Ruckus limits the personal information provided to these third parties to that which is reasonably necessary for them to perform services on Ruckus’s behalf and they may only use personal information to provide Ruckus with these services, except as detailed in the “Third Party Services” section below.

 

  • Business Transfers. If Ruckus is involved in a merger, acquisition, asset sale, debt financing or similar transaction, Ruckus may disclose and otherwise transfer personal information to an acquirer, successor, or assignee as part of its business assets. Also, if any insolvency, bankruptcy or other reorganization proceeding is brought by or against Ruckus, personal information may be considered one of Ruckus’ assets and may be sold, disclosed or transferred to third parties.

 

  • Affiliated Companies. In connection with providing the Service, Ruckus may disclose personal information to its subsidiaries and other corporate affiliates that follow privacy practices at least as protective as those described in this Policy.

 

  • Legal Obligations and Protecting Ruckus’s Interests. Ruckus may share personal information with third parties if it has a good faith belief that it is required to do so by applicable law, legal process or demand of a governmental authority. In addition, Ruckus may disclose personal information if it has a good faith belief that such disclosure is necessary to protect its property or other legal rights (including enforcing its agreements), or the rights or property of others, or otherwise to help protect the safety or security of the Service or other users of the Service.

Except as described in this Policy, Ruckus will not disclose the personal information collected about a Customer or its representatives through the Service to third parties without the Customer’s consent.

Location of Personal Information

Ruckus is a global organization, and the Service is primarily hosted in the United States although it may also be hosted in other countries. Further, Ruckus’s service providers process data in the United States and other countries. As a result, personal information may be transferred, stored and processed by Ruckus, its affiliates and its service providers outside of the Customer’s own region. For example, if a Customer chooses to use the Service from outside the United States, the Customer may be transferring its personal information outside of its region and into the United States for storage and processing. In addition, Ruckus may transfer the Customer’s data from the United States to other countries or regions in connection with storage and processing of data, fulfilling the Customer’s requests, and operating the Service. By providing personal information to Ruckus through use of the Service, the Customer agrees to such transfer, storage and processing.

 

The Customer should be aware that each region can have its own privacy and data security laws, some of which may be less stringent as compared to those of the Customer’s own region. If a Customer is located within the European Economic Area (“EEA”), for example, the Customer should note that European data protection law permits the export of personal information to other countries subject to the provision of adequate levels of protection for the processing of such personal Information.

Direct Marketing and Customer Preferences

If a Customer receives marketing e-mails from Ruckus, that Customer may unsubscribe at any time by following the instructions contained within the e-mail. The Customer may also opt-out from receiving marketing emails from Ruckus, and any other promotional communications that Ruckus may send to the Customer from time to time, by sending a request by email to Ruckus at [email protected] or by writing to Ruckus at the address below.

The Customer should be aware that if the Customer opts-out of receiving marketing communications from Ruckus, it may take up to ten business days to process such opt-out request, and the Customer may receive marketing communications from Ruckus during that period. Additionally, even after opting-out from receiving marketing communications from Ruckus, the Customer may continue to receive administrative messages from Ruckus regarding the Service as part of its operation of the Service.

Access, Modify or Delete Personal Information   

The Customer can access and modify certain personal information it provides to Ruckus by accessing and updating its account settings. If the Customer wishes to access, modify or delete any other personal information Ruckus holds about the Customer (or its representatives), it may contact Ruckus via email at [email protected], and Ruckus will respond within 30 days or any longer period as permitted by applicable law.

Ruckus will retain the personal information it collects or accesses under this Policy, or processes on the Customer’s behalf, for so long as reasonably necessary to provide the Service or as necessary to comply with its legal obligations, resolve disputes and enforce its agreements, or otherwise where Ruckus reasonably believes it has a legitimate reason to do so. Ruckus reserves the right to delete personal information that is no longer necessary to provide the Service.

The Customer should note that where Ruckus modifies or deletes personal information in or from its active databases, copies of such information may persist in backup files.

Third Party Services

The Service may enable the Customer to access or otherwise use third party products and services. In addition, the Customer may choose to authorize a third party (such as a third party application provider) to access the data collected by the Service. Such third parties may have their own privacy policies that govern their collection, use and disclosure of personal information.   Because Ruckus does not control the privacy practices of these third parties, Ruckus is not responsible for (and this Policy does not cover) the processing of the Customer’s personal information by these third parties. Accordingly, the Customer should be sure to read their privacy policies and provide copies of the same to any of its affected representatives or end-users of the Service.

For example, the Service uses the Google Maps API as a source of maps, geographic data, and geo-location information for the purposes of providing location-based information regarding terminal devices connected to networks managed by the Service and for providing related reporting and analysis. Google may collect information, including personal information, from those who view content provided through the Google Maps API, and Google handles such information in accordance with Google’s own privacy policy.

Security

The security of the Customer’s personal information is important to Ruckus. While Ruckus cannot guarantee absolute security of the Customer’s personal information, it uses firewalls and employs certain other security techniques designed to protect personal information from loss, misuse, alteration and unauthorized access. For example, when a Customer enters confidential information (such as login passwords), the Service encrypts the transmission of that information using secure socket layer technology (SSL).

Cookies

The Service may use “cookies” for the performance of certain aspects of the Service. Cookies are small data files stored on devices by a website or online portal. Cookies help Ruckus monitor and improve the functionality and usage of the Service and the Customer’s experience (and the experience of end users) while using the Service. For example, the Service uses cookies to keep track of and maintain a continuous service session.

The cookies used by the Service may fall into the following categories:

  • Cookies which are “strictly necessary” for functionality of the website platforms on which the Service These cookies are essential in order to enable movement around the relevant website and use of its features; and
  • Functionality” cookies which allow the Service to remember choices the Customer makes and the Customer’s preferences, for example where the Customer registers or logs-in using a particular username.
  • Performance/Analytical” cookies which collect information about how the Customer navigates the Service; for example, which pages are accessed most frequently. They identify how the Customer interacts with the Service, any errors that occur, which pages are not used often, which pages take a long time to load, which pages the Customer tends to visit and in what order. These cookies do not collect any information which could identify the Customer and are only used to help Ruckus improve how the Service works and understand what interests the Customer.

The following table summarizes the first party cookies used as part of the Service (at present third party cookies are not used as part of the Service):

Cookie name/type

Expiration period

Purpose

Category of cookie

Session ID

Session

Tracks and maintains a continuous user session

Strictly necessary

Google Analytics

Persistent (stored for up to 2 years)

Tracks user behavior

Performance/Analytical

 

To delete or block cookies from the Service, the Customer should use browser settings. For more general information about cookies, including the difference between session and persistent cookies, Customer should visit www.allaboutcookies.org.

Children

The Service is not intended for children under the age of 13 and Ruckus does not knowingly collect personal information from those children.

Changes to this Policy

Ruckus may update this Policy from time to time. Ruckus will post the updated Policy on this page and update the “last revised” date above. If Ruckus changes this Policy in a manner that materially alters the Customer’s rights or obligations, it will use reasonable efforts to notify the Customer of the change. For example, Ruckus may send a message to the Customer’s email address (or that of its representative), if it has one on file, or generate a pop-up or similar notification when the Customer accesses the Service after Ruckus makes such material changes. Ruckus encourages the Customer to review this Policy periodically to stay informed about how it collects, uses, and discloses personal information. The Customer’s continued use of the Service after the revised Policy has become effective indicates that the Customer has agreed to the current version of this Policy.

Contacting Ruckus

Ruckus welcomes comments or questions regarding this Policy. Please feel free to email Ruckus at [email protected] or write to Ruckus at:

Ruckus Wireless, Inc.
350 West Java Dr.
Sunnyvale, CA 94089
Attention: Privacy Policy

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