Data Privacy Declaration

1. General information
2. What kind of data is collected and how is it used?
3. Which cookies are used?
4. Social media plugins
5. Newsletters
6. Is other personal data collected and processed?
7. Will my data be transferred to third parties, e. g. authorities?
8. How long will my data be stored?
9. Do I have a right to information and rectification of my stored data? What other rights do I have with regard to my stored data?
10. Can I withdraw my consent to the use of my data?
11. Who is my contact person if I have questions about data protection?
12. How long is this data privacy declaration valid?

1. General information

Thank you for your interest in the website(s) of (Bristlecone, San Jose, 10 Almaden Blvd, Suit 600, San Jose, CA 95113 and Kulashekar Raghavan(CFO, Bristlecone) hereinafter referred to as “Bristlecone”. We take data protection and privacy issues very seriously and comply with the applicable national and European data protection regulations. Therefore, we would like to inform you with this declaration about data protection measures and which data we may store and how we use this data.

2. What kind of data is collected and how is it used?

2.1 Data collection by this website

Whenever a user accesses the website, the user’s internet browser automatically transfers the following data to Bristlecone’s web server for technical reasons:

  • IP address of the requesting computer
  • date and time of access
  • name and URL of the retrieved file
  • transferred data volume
  • access status (file transferred, file not found etc.)
  • identification data of the browser and operating system used
  • name of the provider of user’s internet access
  • website from which access is made

This data is collected, processed and used for the purpose of enabling the use of the website (connection setup), system security and technical administration of the network infrastructure. A comparison with other databases or a transfer to third parties, also in excerpts, does not take place. The legal basis for processing is Art. 6 para. 1 b GDPR.

The data collected as part of the voluntary entries under “Contacts & Service” will be used and processed exclusively for the purpose of processing the enquiry and to carry out the services you may have requested

2. Use of Google Analytics

This website uses Google Analytics, a web analytics service provided by Google Inc. (“Google”). Google Analytics uses “cookies”, which are text files placed on your computer, to help the website analyze how users use the site. The information generated by the cookie about your use of this website is usually transferred to a Google server in the USA and stored there. However, if you activate the IP anonymization on this website, your IP address will be shortened previously by Google within Member States of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases the full IP address is transferred to a Google server in the USA and shortened there. On behalf of the operator of this website, Google will use this information to evaluate your use of the website, to compile reports on website activity and to provide the website operator with further services related to website and internet use. The IP address transmitted by your browser within the scope of Google Analytics will not be aggregated with other Google data. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website. You can also prevent Google from collecting the data generated by the cookie and relating to your use of the website (including your IP address) and from processing this data by downloading and installing the browser plug-in available under the following link
https://tools.google.com/dlpage/gaoptout?hl=de. You can prevent Google Analytics from collecting data by clicking on the following link. An opt-out cookie is set that prevents future collection of your data when you visit this website: https://tools.google.com/dlpage/gaoptout?hl=en

For more information on terms of use and privacy, please visit https://www.google.com/analytics/terms/de.html or https://www.google.de/intl/de/policies/. Please note that on the website Google Analytics has been extended by the code “anonymizeIp” in order to guarantee an anonymous registration of IP addresses (so-called IP masking).

The legal basis for processing is Art. 6 para. 1 f GDPR, whereby Bristlecone’s authorization arises from the fact that, on the one hand, Bristlecone has an interest in evaluating the website data for purposes of website optimization and, on the other hand, a concerned person can reasonably foresee at the time when the personal data is collected and in view of the circumstances under which it is carried out (in particular the above-mentioned measures) that it will possibly be processed for this purpose.

3. Which cookies are used?

Cookies and their usage:

We use cookies on our website. Like most other web servers, cookies are small text files that a website can send to your browser and store it on your hard drive so that we can recognize you in your future visit to our website. This is in order to provide you with better user experience.

Session cookie – Session cookies remain only as long as a browsing session is active. It aids user inconvenience during browsing. These cookies allow websites to link the actions of a user during a browser session and expire at the end of the browsing session.

Persistent cookie – Persistent cookies are stored on a user’s device even after the end of a browsing session. It helps in recalling the preferences or actions of the user. They are used to retain the visitor’s preferences such as language and regional preference(s) at the end of each browsing session. We may use services of third-party analytics provider to analyze cookies to carry out a behavioral analysis in order to provide targeted and relevant content to visitors.

Cookies are accepted by default. You may change the settings of your browser to delete existing cookies or prevent future cookies from being automatically accepted. However, if you disable cookies, certain parts and functions of our website may not be available.

If you do not want to take advantage of our cookies, you can find out in the help function of your browser how to set your browser to prevent it from accepting new cookies or deleting existing cookies. There you will also learn how to block your browser for all new cookies or which settings you have to make in order to receive a notification of new cookies.

Cookies are used on this website.

By using our website, you agree to have cookies placed in your device. At Bristlecone, we strongly believe in being transparent and open in our proceedings related to collection and usage of data. This policy spells out a detailed description of our cookies, their types and related policies.

What are cookies?

Cookies are fragments of data that Bristlecone places on your web browser during navigation to enable seamless access to our all our web pages. Cookies enable us to identify your device, secure your access and prevent threats & breaches. Cookies also enable us to share relevant ads to you. By using cookies, we help remember your preferences and are able to serve you enhanced user experience every single time.

What types of cookies does Bristlecone use?

Cookies are of two types: session cookies and persistent cookies. A session cookie is one that gets automatically deleted once you close the browser. A persistent cookie, after you sign in, stays stored in your browser and will be read by Bristlecone when you return to our site or partner sites. Persistent cookies are present in your browser till they reach their defined expiration date.

How can cookies help me?

Cookies help us to recognize you when you visit the Bristlecone site. Cookies remember your preferences, choices and behaviors. Cookies position us to help you provide a personalized and a more customized experience that’s in line with your settings. Cookies also make your interactions with Bristlecone better, quicker, seamless and secure.

The legal basis for processing is Art. 6 para. 1 f GDPR, whereby Bristlecone’s authorization arises from the fact that, on the one hand, Bristlecone has an interest in evaluating the website data for purposes of website optimization and, on the other hand, a concerned person can reasonably foresee at the time when the personal data is collected and in view of the circumstances under which it is
carried out (in particular the above-mentioned measures) that it will possibly be processed for this purpose.

4. Social media plugins

We use social media plugins from various social networks (e. g. Facebook). With the help of these plugins you can share content or recommend products. The plugins are deactivated by default and therefore do not send data to other websites. By clicking on the button “Activate Social Media” you can activate all plugins (so-called 2-click solution). The plugins can of course be deactivated again
with one click.

If these plugins are activated, your browser establishes a direct connection with the servers of the respective social media network as soon as you access the operator’s website. The content of the respective plugin is transmitted directly from the social media network to your browser and embedded into the website.

By embedding the plugins, the social media network receives the information that you have visited the respective page of the operator. If you are logged in to the social media network, it can allocate the visit to your account. When you interact with the plugins, the corresponding information is transferred directly from your browser to the social media network and stored there.

For the purpose and scope of data collection and the further processing and use of the data by social media networks, as well as your rights and options for the protection of your privacy, please refer to the data protection notices of the respective networks.

If you do not want social media networks to collect information about you through the operator’s website, you must log out or disable the social media plugins before you visit our website.

Even if you are not logged in to social media networks, websites with active social media plugins can still send data to these networks. With an active plugin, a cookie with an identifier is placed each time the website is accessed. Since your browser sends this cookie every time you connect to a network server without being asked, the network could basically use it to create a profile of the websites visited by the user associated with the ID. And it would then also be possible to assign this
identifier to a person again at a later time – for example when logging on later to the social network.

The operator uses the following plugins:

  • Facebook (provided by Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304 USA) You can view Facebook’s privacy policy here
  • Google+ My Business (provided by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043 USA) You can view Google’s privacy policy here: German / English
  • Twitter (provided by Twitter Inc., 795 Folsom St., Suite 600, San Francisco, CA 94107, USA) You van view Twitter’s privacy policy here
  • Instagram (provided by Instagram Inc., 1601 Willow Road, Menlo Park, CA, 94025, USA) You can view Instagram’s privacy policy here

5. Newsletters

5.1 Which data are collected and for what purpose are they processed?

If you register for a newsletter, we use your e-mail address to send you the respective newsletter, in which we inform you regularly about interesting products and services of Bristlecone. The legal basis is your consent in accordance with Art 6 Para. 1 lit. a GDPR. In order to ensure your proper registration for the newsletter, i.e. to prevent unauthorized registrations on behalf of third parties, we will send you a confirmation e-mail after your initial newsletter registration using the double opt-in procedure, in which we ask you to confirm your registration. In connection with your newsletter registration we also store your registration data (e.g. e-mail address, date and time of registration/confirmation of the opt in) so that we can trace and prove the registration at a later time. The legal basis for this storage is a legitimate interest, Art 6 para. 1 lit f, Art 7 para. 1 GDPR. The legitimate interest is based on the obligation to provide proof of consent.

5.2 How long do we store your data?

We store your email address to send you the newsletter until you unsubscribe or until we stop sending you the newsletter. After unsubscribing from the newsletter, your registration data will be stored for up to 4 years, limited to the purpose of securing evidence.

5.3 How can I cancel my newsletter subscription?

You can revoke your consent to receive newsletters from Bristlecone at any time in the future by clicking on the unsubscribe link at the end of a newsletter received.

6. Is other personal data collected and processed?

We collect and process your personal data only if you request certain services and we need your data for this purpose or if you have voluntarily given us your express consent. The legal basis for processing is Art. 6 Para. 1 b GDPR and Art. 6 Para. 1 a GDPR.

You can do this, for example, by completing a registration form or sending us an email, ordering products or services, submitting inquiries to us, requesting materials or registering. Unless otherwise required by law, we will only use your personal data for the purposes for which you have given your consent. For special services such as newsletters, sweepstakes, etc. the respective special data protection provisions apply.

7. Will my data be transferred to third parties, e. g. authorities?

At Bristlecone, those bodies within Bristlecone receive your data that are required to fulfill our contractual and legal obligations. Some data must be disclosed under strict contractual and legal requirements:

  • Due to legal obligation:

    In certain cases, we are required by law to transfer data to a requesting public authority.
    Personal data will only be transferred to state institutions and public authorities within the framework of mandatory national legal provisions or if disclosure is necessary in the event of attacks on the network infrastructure for legal or criminal prosecution. The legal basis for processing is Art. 6 Para. 1 c GDPR.

  • To external service providers for data processing:
    When service providers get access to our customers’ personal data, this usually takes place in the course of so-called order processing of personal data. This is expressly provided for by law. In this case, Bristlecone remains responsible for the protection of your data – in addition, the processor may also be responsible. The service provider works strictly in accordance with our instructions, which we ensure by means of strict contractual regulations, technical and organizational measures and supplementary controls. Bristlecone works with service suppliers as processors. These are Bristlecone
    Group companies and service providers for IT services (e. g. for technical administrative tasks and for usage analysis), telecommunications, consulting and advisory services as well as sales and marketing.
    The data protection regulations for instruction-bound order processing of personal data are complied with.
  • To Bristlecone Group companies:
    Bristlecone may transfer your personal data to Bristlecone Group companies in order to carry out a business relationship with you or for the purposes of legitimate interests.
    If data are transferred abroad, they are based within the EU or the EEA or in a country which, according to the decision of the EU Commission, has an appropriate level of data protection. In the case of data transfers to Bristlecone Group companies domiciled in other countries, Bristlecone ensures by way of guarantees that the data-importing Bristlecone Group Bristlecone has been obligated to an appropriate level of data protection.

Beyond this, we do not transfer data to third parties unless you have given your express consent, the transfer is obviously necessary for the provision of an offer or service requested by you or this is provided for by law. We also do not intend to transfer your data beyond this to a third country or international organization.

8. How long will my data be stored?

We store data for as long as it is legally necessary or necessary for the provision of
the service requested by you, or as long as it has been agreed upon in a declaration
of consent.

9. Do I have a right to information and rectification of my stored data? What other rights do I have with regard to my stored data?

You may at any time and free of charge request information about the scope, origin and recipients of the stored data as well as the purpose of the storage; in addition, you have the right to rectification, erasure or restriction of the processing of your data in accordance with data protection regulations, a right to object to the processing as well as a right to data portability. Please note that there is a right of appeal to a supervisory authority.

10. Can I withdraw my consent to the use of my data?

You have the right to withdraw your consent to the use of your data at any time. Just send an email to [marketing@bcone.com] or send a letter to the following address:

(Bristlecone, San Jose, 10 Almaden Blvd, Suit 600, San Jose, CA 95113)

The data processing performed on the basis of your consent is legal until the time of withdrawal.

11. Who is my contact person if I have questions about data protection?

If you have any questions or comments, please feel free to contact Bristlecone at any time:

Roman Ferencak,
VP, EMEA,
roman.ferencak@bcone.com

Tanja Campbell,
Consultant,
tanja.campbell@bcone.com

Devyani Abhyankar,
Director HR for US and EMEA,
devyani.abhyankar@bcone.com

Rama Krishnamurthy,
Sr. Manager Global Marketing
rama.krishnamurthy@bcone.com

12. How long is this data privacy declaration valid?

This data privacy declaration is up-to-date and dates from May 25, 2018. We reserve the right to amend the data privacy declaration at any time with effect for the future, in particular to adapt it to a further development of the website or the implementation of new technologies.

 

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