Cisco Privacy Statement

ARCHIVED 2022-09-03, DATE APPROXIMATE · VERSION 20220903_rev01 · COMPARED WITH 20160413_rev01

Full text changes — 20160413_rev01 to 20220903_rev01

COLOUR MARKS THE SEVERITY OF A FLAGGED CLAUSE · + AND − MARK ADDED AND REMOVED

1This privacy policy ("Policy") describes how OpenDNS, Inc. collects and uses the personal information you provide on the website [https://www.opendns.com](https://www.opendns.com/) and [https://www.umbrella.com/](https://www.umbrella.com/) ("Websites") which are owned and operated by OpenDNS, Incorporated ("OpenDNS", "we", "us", "our"), and all associated OpenDNS and Umbrella services ("Services") provided by OpenDNS through these Websites.
1Cisco Systems, Inc. and its subsidiaries (collectively "Cisco") are committed to protecting your privacy and providing you with a positive experience on our websites and while using our products and services ("Solutions").
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3#### Contact Information
3This Privacy Statement applies to Cisco websites and Solutions that link to or reference this Privacy Statement and describes how we handle Personal Information and the choices available to you regarding collection, use, access, and how to update and correct your Personal Information. Additional information on our Personal Information practices with respect to Cisco Offers may be provided in [privacy data sheets and maps](https://trustportal.cisco.com/c/r/ctp/trust-portal.html), offer descriptions, or other notices provided prior to or at the time of data collection. Certain Cisco websites and Solutions may have their own privacy documentation describing how we handle Personal Information for those websites or Solutions specifically. To the extent a specific notice for a website or Solution differs from this Privacy Statement, the specific notice will take precedent. If there is a difference in translated, non-English versions of this Privacy Statement, the U.S.-English version will take precedent.
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5OpenDNS has been awarded TRUSTe's Privacy Seal signifying that this Policy has been reviewed by TRUSTe for compliance with TRUSTe's [program requirements](http://www.truste.com/privacy-program-requirements/) including transparency, accountability and choice regarding the collection and use of your personal information. The TRUSTe program covers only information that is collected through the Websites, [https://www.opendns.com](https://www.opendns.com/) and [http://www.umbrella.com](http://www.umbrella.com/). TRUSTe's mission, as an independent third-party, is to accelerate online trust among consumers and organizations globally through its leading privacy trustmark and innovative trust solutions. If you have questions or complaints regarding our Policy or practices, please contact us at [opendns-privacy@cisco.com](mailto:opendns-privacy@cisco.com) or write to us at Privacy Matters, OpenDNS, Inc., 135 Bluxome Street, San Francisco, CA 94107. If you are not satisfied with our response you can contact [TRUSTe here](http://watchdog.truste.com/pvr.php).
5## What is Personal Information
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7OpenDNS participates in the EU and Swiss Safe Harbor Privacy Framework as set forth by the United States Department of Commerce. As part of our participation in the safe harbor, we have agreed to TRUSTe dispute resolution for disputes relating to our compliance with the Safe Harbor Privacy Framework.
7"Personal Information" is any information that can reasonably be used to identify an individual and may include name, address, email address, phone number, login information (such as account number, password), social media account information, or payment card number.
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9Please click [here](http://www.truste.com/about-TRUSTe/contact-us/) for fax and postal mail information. TRUSTe's Dispute Resolution process is only available in English.
9The types of Personal Information that we may process depends on the business context and the purposes for which it was collected. It may include:
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11#### EU Safe Harbor Statement
11- Contact, subscription, registration, online identifiers, social media and discussion forum or communications details;
12- Communications (such as audio, video, text) content;
13- Online behavior and product usage information;
14- Financial Information (such as bank account details or credit card information);
15- Details of an individual's business and other interests and opinions (such as where information is held in a Customer Relationship Management database); and
16- Information about the user of our products and services, including System Information such as device identifiers, and telemetry (such as IP or MAC address) when such data is linked or tied to a specific person's device.
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13The United States Department of Commerce and the European Commission have agreed on a set of data protection principles and frequently asked questions to enable U.S. companies to satisfy the requirement under European Union law that adequate protection be provided to Personal Information transferred from the European Economic Area to the United States (the "U.S.-EU Safe Harbor"). OpenDNS complies with the U.S.-E.U. Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use and retention of personal data from the European Union member countries. OpenDNS 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 OpenDNS's certification, please visit [http://www.export.gov/safeharbor/](http://www.export.gov/safeharbor/).
18If we link other data with your Personal Information, we will treat that linked data as Personal Information.
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15#### Information You Provide Us
20## Collection & use of your Personal Information
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17If you email us through any of the contact us links on our Website, if you submit a request for information through our Website or if you submit a support ticket through our Website we may ask you for Personal Information including but not limited to your name and email address in order to respond to your questions, comments and requests. If you choose to correspond with us via email, we may retain the content of your email messages, your email address and our correspondence with you. If you register for an account, we will also collect Personal Information such as your name, email address, billing address and credit card information.
22We may collect data, including Personal Information, about you as you use our websites and Solutions and interact with us. We also acquire Personal Information from trusted third-party sources and engage third parties to collect Personal Information on our behalf.
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19#### Service Usage Information
24We may use your Personal Information for the purposes of operating and helping to ensure the security of our business, delivering, improving, and customizing our websites and Solutions, sending notices, marketing and other communications, and for other legitimate purposes permitted by applicable law.
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21When you use our Services, OpenDNS stores certain DNS, IP address and related information about you to improve the quality of our Service, to provide you with Services and for internal business and analysis purposes. For example, OpenDNS runs a Domain Name System (DNS) service. DNS translates a domain name (e.g., http://www.example.com) into the corresponding numerical address (e.g., 192.0.34.166) that allows your system to access the domain over the network.
26We collect Personal Information for a variety of business reasons, such as:
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23#### Tracking Technologies
28- Order processing, including billing and payment;
29- Customer relationship management and administration;
30- Creating and managing user accounts;
31- Provisioning websites and Solutions and enabling the use of certain features;
32- Analyzing, personalizing, improving accuracy, and enhancing user experience, communications, and interactions;
33- Sending communications to you, including for marketing or customer satisfaction purposes, either directly from Cisco or from our partners;
34- Managing communications preferences. You can modify your communication preferences at any time. See [Your choices and selecting your communication preferences below.]()
35- Contract performance, Solution delivery, and customer service;
36- Managing a job application;
37- Administering online education, testing, and certifications;
38- Facilitating conferences, webinars, and other events; and
39- Protecting Cisco, our users, Solutions, and others.
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25Technologies such as: cookies, beacons, tags and scripts are used by OpenDNS and our partners, affiliates, or analytics or service providers (including Optimizely, Google Analytics, Mixpanel, Crazy Egg, New Relic, Inspectlet, Bizo, Google Adwords, Doubleclick, Rubicon, Olark, Bizible, Salesforce, Marketo, Reachforce, Facebook, Google+, Twitter, Disqus, Scorecard Research, ShareThis and Customer.io). These technologies are used in analyzing trends, administering the site, tracking users' movements around the site and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis.
41If you choose to provide Cisco with a third party's Personal Information (such as name, email, and phone number), you represent that you have the third party's permission to do so. Examples include forwarding reference or marketing material to a friend or sending job referrals. Third parties may unsubscribe from any future communication following the link provided in the initial message or by submitting a [Privacy Request](https://privacyrequest.cisco.com/).
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27We may use "cookies" on or in conjunction with our Websites to help OpenDNS identify and track visitors, their usage of our Websites, and their website access preferences. A cookie is a string of information that a website stores on a visitor's computer, and that the visitor's browser provides to the website each time the visitor returns. If you do not wish to have cookies placed on your computer you should set your browser to refuse cookies before using the Websites, with the drawback that certain features of the Websites may not function properly without the aid of cookies. We do not link the information we store in cookies to any Personal Information you submit while on our Websites.
43In some instances, Cisco and the third parties we engage may automatically collect data through cookies, web logs, web beacons, and other similar applications. Please read the [Use of cookies and similar technologies]() section below for more information.
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29As is true of most web sites, we gather certain information automatically and store it in log files. This information may include Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. We do not link this automatically collected data to other information we collect about you.
45## Your privacy rights
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31We partner with a third party to either display advertising on our Websites or to manage our advertising on other sites. Our third party partner may use technologies such as cookies to gather information about your activities on this site and other sites in order to provide you advertising based upon your browsing activities and interests. If you wish to not have this information used for the purpose of serving you interest-based ads, you may opt-out by clicking [here](http://preferences-mgr.truste.com/) (or if located in the European Union click [here](http://www.youronlinechoices.eu/)). Please note this does not opt you out of being served ads. You will continue to receive generic ads.
47We need your help to keep your Personal Information accurate and up to date. We provide options to access, correct, suppress, or delete your Personal Information:
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33We use Local Storage Objects (LSOs) such as HTML5 to store content information and preferences. Third parties with whom we partner to provide certain features on our site or to display advertising based upon your Web browsing activity use LSOs such as HTML 5 to collect and store information. Various browsers may offer their own management tools for removing HTML5 LSOs.
49- You can view or edit your Cisco.com Personal Information and preferences online by using the [Cisco Profile Management Tool](https://www.cisco.com/c/en/us/about/account.html).
50- When Cisco is acting as a **"data controller,"** you can exercise your rights of access and request corrections, suppression, or deactivations under applicable data protection laws directly with that Cisco entity as described in the specific Solution documentation or by submitting a request through the [Privacy Request form](https://privacyrequest.cisco.com/).
51- When Cisco is acting as a **"data processor,"** and you wish to exercise your rights of access and request corrections, suppression, or deactivations, Cisco will direct you to the data controller under the applicable data protection laws.
52- If you need additional assistance, or help with accessing, correcting, suppressing, or deleting your Personal Information, please feel free to [contact us](https://privacyrequest.cisco.com/) directly. We will respond to your request within 30 days. If we are unable to honor your request or need more time, we will provide you with an explanation.
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35#### Chat Rooms, Discussion Forums, Bulletin Boards
54## Your choices and selecting your communication preferences
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37If you participate in one of our chat rooms, discussion forums, or post messages to a Website bulletin board, you should be aware that the information disclosed and shared will be broadly available to other persons, both inside of and/or outside of OpenDNS, who have access to that chat room, forum or bulletin board. Please be careful and responsible whenever you're online by not posting any more Personal Information than you want revealed. In addition, if you post Personal Information online that is accessible to the public, you may receive unsolicited messages from other parties in return. Please also note that a participant's expressed opinion is his or her own and should not be considered to reflect the opinion of OpenDNS. To request removal of your personal information from our blog or community forum, contact us at [opendns-contact@cisco.com](mailto:opendns-contact@cisco.com). In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.
56We give you the option to receive a variety of information related to our business, programs, website, and Solutions. You can manage your communication preferences at any time through the following methods:
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39Our blog is also managed by a third party application that may require you to register to post a comment. We do not have access or control of the information posted to the blog. You will need to contact or login into the third party application if you want the personal information that was posted to the comments section removed. To learn how the third party application uses your information, please review their privacy policy.
58- By following the instructions included in each promotional email from us to unsubscribe from that mailing.
59- By completing and submitting this [form](https://privacyrequest.cisco.com/) or by contacting us via mail at: Cisco Systems, Inc., Privacy Office, 170 West Tasman Dr., San Jose, CA 95134, USA. Please be sure to include your name, email address, the communication received, method of delivery (such as post, email, phone call, text), and any additional information about the material you no longer wish to receive.
60- For short message services ("SMS Services"), reply "STOP," "END," or "QUIT" to the SMS text message you have received.
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41#### Use and Disclosure of Personal Information
62These choices do not apply to service notifications or other required communications that are considered part of certain programs, websites, and Solutions, which you may receive periodically unless you cancel or stop use in accordance with its terms and conditions. With your permission, we may also share your Personal Information with Cisco business partners or vendors, so they may send you information about websites, programs, products, or services that may be of interest to you. To opt-out of Cisco sharing with third parties for their marketing purposes, please submit a [Privacy Request](https://privacyrequest.cisco.com/).
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43OpenDNS does not share, rent, trade or sell your Personal Information with third parties, except as described in this Policy. If you do provide us with Personal Information, we will only use it for the purposes described where it is collected or to deliver the Services you requested, and we will not sell, license, transmit or disclose this information outside of OpenDNS unless (1) you expressly authorize us to do so, (2) it is necessary to allow our trusted service providers or agents (such as address list hosting companies, advertising and analytic companies, billing service providers, email service providers, search providers, security providers, live chat software providers and other similar service providers) to provide products or services for us or you, (3) it is disclosed to entities that perform marketing services on our behalf or to other entities with whom we have joint marketing agreements, these service providers are authorized to use your Personal Information only as necessary to provide these services to us. (4) it is necessary in connection with a sale of all or substantially all of the assets of OpenDNS or the merger of OpenDNS into another entity or any consolidation, share exchange, combination, reorganization, or like transaction in which OpenDNS is not the survivor; you will be notified via email and/or a prominent notice on our Web site of any change in ownership or uses of your Personal Information, as well as any choices you may have regarding your Personal Information or (5) otherwise as we are required or permitted by law. Also, we reserve the right to fully use and disclose any information that is not Personal Information (such as statistics, most frequented domains, phishing attempts blocked by our Services).
64By using our websites, Solutions, or otherwise engaging or providing Personal Information to us, you agree that we may communicate with you regarding security, privacy and administrative issues relating to your use. For example, if we learn of a security system's breach, we may attempt to notify you by posting a notice on our websites, sending an email, or otherwise contacting you.
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45If you send us a request, inquiry, feedback or other comments (for example via a support email or via one of our feedback mechanisms), we reserve the right to edit and republish it in our Knowledge Base, which is displayed on our Websites, in order to help us clarify or respond to your request or to help us support other users with similar issues.
66## Sharing your Personal Information
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47We post customer testimonials on our Websites which may contain Personal Information. We do obtain the customer's consent via email prior to posting the testimonial to post their name along with their testimonial. If you wish to request that your testimonial be removed you may contact us at [opendns-contact@cisco.com](mailto:opendns-contact@cisco.com).
68We may share your Personal Information with third parties for the purposes of operating our business, delivering, analyzing, improving, securing, and customizing our websites and Solutions, sending marketing and other communications related to our business, and for other legitimate purposes permitted by applicable law(s) or otherwise with your consent.
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49#### Updating, Correcting or Deleting Personal Information and OpenDNS Accounts
70We may share Personal Information in the following ways:
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51You may correct, update, or delete your Personal Information by accessing it through the edit account information page or by emailing our Customer Support at [opendns-contact@cisco.com](mailto:opendns-contact@cisco.com). If emailing Customer Support, please allow us 3 business days in order to satisfy your request.
72- Within Cisco and any of our worldwide subsidiaries for the purposes of data processing, such as marketing, business operations, compliance, security, website or Solution functionality, or storage.
73- With business partners, service vendors, authorized third-party agents, or contractors to provide a requested website, Solution, service, or transaction. Examples include processing of orders and credit card transactions, hosting websites, hosting seminar registration, assisting with sales-related efforts or post-sales support, and providing customer support.
74- With Cisco business partners or vendors, so that they may share information with you about their products or services. To opt-out of Cisco sharing with third parties for their marketing purposes, please submit a [Privacy Request](https://privacyrequest.cisco.com/).
75- In connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or to another company.
76- In response to a request for information by a competent authority or third party if we believe disclosure is in accordance with, or is otherwise required by, any applicable law, regulation, or legal process.
77- With law enforcement officials, government authorities, or other third parties as necessary to comply with legal process or meet national security requirements; protect the rights, property, or safety of Cisco, our business partners, you, or others; or as otherwise required by applicable law.
78- In aggregated, anonymized, and/or de-identified form that cannot reasonably be used to identify you.
79- If we otherwise notify you and you consent to the sharing.
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53We will retain your information for as long as your account is active or as needed to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
81## Security of your Personal Information
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55#### Opt-Out
83We take reasonable and appropriate steps to protect the Personal Information entrusted to us and treat it securely in accordance with this Privacy Statement. Cisco implements physical, technical, and organizational safeguards designed to protect your Personal Information from accidental or unlawful destruction, loss, alteration, and unauthorized disclosure or access. We also contractually require that our suppliers protect such information from accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access.
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57In connection with promotions or other projects, we may ask you specifically whether you have objections with respect to a certain kind of data use or sharing. If you opt-out under such circumstances, we will respect your decision. To opt out of receiving commercial communications from OpenDNS, please click on the "opt-out" or "unsubscribe" link in the communication or please contact us at [opendns-contact@cisco.com](mailto:opendns-contact@cisco.com). Your e-mail address will be removed from our marketing list. Please allow us a reasonable period of time, not to exceed 10 days, in order to satisfy your request, as some promotions may already be in process.
85## Retention and disposal of Personal Information
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59#### Third-Party Websites
87We will retain your Personal Information as needed to fulfill the purposes for which it was collected. We will retain and use your Personal Information as necessary to comply with our business requirements, legal obligations, resolve disputes, protect our assets, and enforce our rights and agreements.
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61For your convenience, we may provide links to other websites and web pages that we do not control. This Policy does not apply to the practices of third parties that OpenDNS does not own or control, or to individuals that OpenDNS does not employ or manage. The privacy and security practices of websites linked to or from OpenDNS websites are not covered by this Privacy Policy, and OpenDNS is not responsible for the privacy or security practices or the content of such websites.
89We will not retain Personal Information in identifiable form when the purpose(s) for which the Personal Information was collected have been achieved and there is no legal or business need to retain such Personal Information. Thereafter, the data will either be destroyed, deleted, anonymized, and/or removed from our systems.
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63#### Privacy of Minors
91## Use of cookies and similar technologies
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65OpenDNS recognizes the privacy interests of children and we encourage parents and guardians to take an active role in their children's online activities and interests. Our Websites and Services are not intended for children. We do not knowingly collect Personal Information from anyone under the age of 13.
93Like many websites and web-based Solutions, Cisco uses automatic data collection tools, such as cookies, embedded web links, and web beacons. These tools collect certain standard information that your browser sends to us (such as Internet Protocol (IP) address, MAC address, clickstream behavior, and telemetry).
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67#### Data Security
95These tools help make your visit to our website and Solutions easier, more efficient, and personalized. We also use the information to improve our website and Solutions and provide greater service and value, to better understand your potential interest in our Solutions, and to provide you with more relevant ads and other content.
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69We restrict access to Personal Information collected about you at our Websites to our employees, our affiliates' employees, those who are otherwise specified in this Policy, or others who need to know that information to provide the Services to you or in the course of conducting our business operations or activities. When you enter sensitive information (such as a credit card number) on our order forms, we encrypt the transmission of that information using secure socket layer technology (SSL). While no website can guarantee security, we maintain appropriate physical, electronic, and procedural safeguards to protect your Personal Information collected via the website. We protect our databases with various physical, technical and procedural measures and we restrict access to your information by unauthorized persons. We also advise all OpenDNS employees about their responsibility to protect customer data and we provide them with appropriate guidelines for adhering to our company's business ethics standards and confidentiality policies. Inside OpenDNS, data is stored in password-controlled servers with limited access. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security. If you have any questions about security on our Website, you can contact us at [opendns-contact@cisco.com](mailto:opendns-contact@cisco.com).
97We partner with third parties to display advertising on our website and to manage our advertising on other sites. Our third-party partners may use cookies or similar technologies to provide you with advertising based on your browsing activities and interests. You may opt out of this advertising; however, generic, non-personalized ads will continue to be displayed.
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71#### Visiting our Website from Outside of the United States
99For more information, or if you would like to opt out of interest-based advertising, see [How Cisco Uses Automatic Data Collection Tools](https://www.cisco.com/c/en/us/about/legal/automatic-data-collection-cookies.html).
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73If you are visiting our Websites from outside of the United States or otherwise contacting us from outside of the United States, please be aware that your Personal Information may be transferred to, stored or processed in the United States, where many of our servers are located and our central database is operated. The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country, but please be assured that we take steps to protect your privacy. By using our Services, you understand that your information may be transferred to our facilities and those third parties with whom we share it as described in this Policy.
101To update your cookie preferences, visit the [Cisco Cookie Consent Manager]().
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75#### Social Media Features and Widgets
103## Linked websites
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77Our Web Site includes Social Media Features, such as the Facebook Like button and Widgets, such as the Share this button or interactive mini-programs that run on our site. These Features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the Feature to function properly. Social media Features are either hosted by a third party or hosted directly on our Site. Your interactions with these Features are governed by the privacy policy of the company providing it.
105We may provide links to other third-party websites and services that are outside Cisco's control and governed by the respective third-party's privacy policy, not by this Privacy Statement. We encourage you to review the privacy statements posted on the websites you visit and in the applications you use.
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79#### Privacy Policy Changes
107## Forums and chat rooms
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81We reserve the right to modify this Policy at any time, so please review it frequently. If we make material changes to this Policy we will post those changes to this privacy policy on the home page and other places we deem appropriate, prior to the change becoming effective so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. This Policy is not intended to and does not create any contractual or other legal right in or on behalf of any party.
109If you participate in a discussion forum, local communities, or chat room on a Cisco website, you should be aware that the information you provide there (such as your public profile and comments) will be made broadly available to others and could be used to contact you, send you unsolicited messages, or for purposes neither Cisco nor you have control over. Also, please recognize that individual forums and chat rooms may have additional rules and conditions. Cisco is not responsible for the Personal Information or any other information you choose to submit in these forums. To request removal of your Personal Information from our blog or community forum, please submit a [Privacy Request](https://privacyrequest.cisco.com/). In some cases, we may not be able to remove all Personal Information and comments. In such cases, we will provide you with a response and explanation.
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83#### General Terms and Conditions of Use
111## Children's privacy
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85The terms of this Policy are incorporated into our general terms of use. Please review our terms of use at [https://www.opendns.com/terms-of-service/](https://www.opendns.com/terms-of-service/)
113Cisco encourages parents and guardians to take an active role in their children's online activities. Cisco does not knowingly collect Personal Information from children without appropriate parental or guardian consent. If you believe that we may have collected Personal Information from someone under the applicable age of consent in your country without proper consent, please let us know using the methods described in the [Questions, comments, and how to contact us]() section and we will take appropriate measures to investigate and address the issue promptly.
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87#### Effective Date of This Privacy Policy
115## International transfer, processing and storage of Personal Information
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89This Privacy Policy was first effective as of July 22, 2007.
90This Privacy Policy was last updated on February 10, 2015.
117As Cisco is a global organization, Personal Information may be transferred to Cisco in the United States of America, to any Cisco subsidiary worldwide, or to third parties and business partners as described above that are located in various jurisdictions around the world. Similarly, Personal Information may be accessed from countries where Cisco or its subsidiaries have operations.
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119By using our websites and Solutions or providing any Personal Information to us, where applicable law permits, you acknowledge and accept the transfer, processing, and storage of such information outside of your country of residence where data protection standards may be different.
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121- **APEC Privacy Certification**
122 Cisco's global privacy program, described in this Privacy Statement, complies with the Asia Pacific Economic Cooperation (APEC) Cross-Border Privacy Rules System (CBPRs) and Privacy Recognition for Processors (PRP). The APEC CBPR system and PRP provides a framework for organizations to ensure protection of Personal Information transferred among participating APEC economies. More information about the APEC Privacy Framework, CBPRs, and PRP can be found on the [CBPR site](http://cbprs.org/). Our certification applies to our business processes across our global operations that process and transfer Personal Information to/from our affiliates around the world. To view our certifications, please see the [APEC CBPR System Directory](http://cbprs.org/compliance-directory/cbpr-system/) and the [APEC PRP Directory](http://cbprs.org/compliance-directory/prp/).
123 For more information on the scope of our participation, or to [submit a privacy inquiry through BBB National Programs](https://bbbprograms.org/programs/all-programs/GlobalPrivacyDivision/gpd-complaints-portal), our Accountability Agent, please click on the official seal below:
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125- **EU Binding Corporate Rules - Controller**
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127 Cisco's global privacy program and policies have been approved by the Dutch, Polish, Spanish, and other relevant European privacy regulators as providing additional safeguards for the protection of privacy, fundamental rights, and freedoms of individuals for transfers of Personal Information protected under European law. Cisco's Binding Corporate Rules -- Controller (BCR-C) -- provide that international transfers made by Cisco as a controller worldwide of European Personal Information benefit from additional safeguards.
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129 A copy of our BCR-C can be found in our [Global Privacy Policy](https://www.cisco.com/c/en/us/about/trust-center/global-privacy-policy.html). More information about BCRs can be found on the [European Commission site](http://ec.europa.eu/justice/data-protection/international-transfers/binding-corporate-rules/index_en.htm).
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131- **EU, UK and Swiss-US Privacy Shields**
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133 Cisco Systems Inc. and its US-based subsidiaries: Acano LLC, AppDynamics LLC, Broadsoft, Inc., Cisco OpenDNS LLC, Cisco Systems Capital Corporation, Cisco WebEx LLC, CliQr Technologies LLC, CloudLock LLC, Duo Security LLC, Jasper International Services LLC, Jasper Technologies LLC, Kenna Security, Inc., Meraki LLC, Rizio, Inc. (dba Voicea), Scientific-Atlanta LLC, and ThousandEyes LLC (collectively "Cisco-US") complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of Personal Information transferred from the European Union, the United Kingdom, and Switzerland to the United States in reliance on Privacy Shield.
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135 Cisco-US has certified that it adheres to the Privacy Shield Principles with respect to such data. If there is any conflict between the policies in this privacy statement and data subject rights under the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit the [Privacy Shield site](https://www.privacyshield.gov/) ([https://www.privacyshield.gov](https://www.privacyshield.gov/)).
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137 Although the Privacy Shield has been invalidated as a transfer mechanism, Cisco-US is committed to protecting all Personal Information received from European Union (EU) member countries, the UK, and Switzerland (see above [Collection and use of your Personal Information]() for examples of the Personal Information Cisco processes when you use our websites and Solutions and interact with us), in accordance with the Frameworks' applicable Principles and to ensuring Personal Information collected from individuals in the EU is accessible to them as part of their individual rights when Cisco is the Controller of the Personal Information. (See [Your privacy rights]().)
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139 Cisco-US is responsible for the processing of Personal Information it receives and subsequently transfers to a third party acting as an agent on its behalf. Cisco-US complies with the Privacy Shield Principles for all onward transfers of Personal Information from the EU, the UK, and Switzerland (for examples of such transfers, see [Sharing your Personal Information]() above) including the onward transfer liability provisions. In certain situations, Cisco-US may be required to disclose Personal Information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
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141 Cisco-US is subject to the regulatory enforcement powers of the US Federal Trade Commission.
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143 To learn more about these Privacy Shield Frameworks, visit the [U.S. Department of Commerce's Privacy Shield site](https://www.privacyshield.gov/Program-Overview).
144
145## Automated decision-making
146
147Our processing of Personal Information includes both automated and manual methods of processing. Our automated methods are often used to assist our manual methods. When automated methods are used to assist in decision-making, we may manually review some of the insights produced by the automated methods against the underlying data from which the insights were made. This manual review may be conducted by Cisco employees or trusted third-party business partners who are working on Cisco's behalf.
148
149In the event that decisions are made solely based on automated methods of processing and produce legal effect or significantly affect an individual, we will provide the impacted individual the opportunity to question the decision or request manual review.
150
151## Complaint resolution
152
153In compliance with the Privacy Shield Principles, Cisco-U.S. commits to resolve complaints about your privacy and our collection or use of your Personal Information transferred to the United States. European Union, United Kingdom, and Swiss individuals with Privacy Shield inquiries or complaints should first contact Cisco-US via the [Privacy Request Form](https://privacyrequest.cisco.com/).
154
155Cisco-U.S. has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, BBB EU Privacy Shield. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit the [BBB EU Privacy Shield consumer complaint system](https://bbbprograms.org/privacy-shield-complaints/) ([http://bbbprograms.org/privacy-shield-complaints](http://bbbprograms.org/privacy-shield-complaints)) for more information and to file a complaint. This service is provided free of charge to you.
156
157If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See [Privacy Shield Annex 1 at the Privacy Shield site](https://www.privacyshield.gov/article).
158
159Alternatively, you can contact the data protection supervisory authority in your jurisdiction for assistance. (Note, Cisco's main establishment in the EU is in the Netherlands. As such, our EU lead authority is the [Dutch Autoritiet Persoonsgegevens](https://autoriteitpersoonsgegevens.nl/en).)
160
161## Your California privacy rights
162
163### **California Consumer Privacy Act (CCPA) / California Privacy Rights Act (CPRA)**
164
165For business purposes in the last twelve months, Cisco may have collected, used, and shared Personal Information about you as described in this privacy statement. Each category of data that may be used by Cisco or shared with third parties is categorically outlined in this Privacy Statement.
166
167California consumers have a right to: (1) request access, correction, and deletion of their Personal Information, (2) opt out of the sale of their Personal Information, and (3) not be discriminated against for exercising one of their California privacy rights.
168
169All individuals have the right to request access to and deletion of the information Cisco holds about them either online via the Cisco [Privacy Request Form](https://privacyrequest.cisco.com/) or by mail to Cisco Systems, Inc., Privacy Office, 170 West Tasman Dr., San Jose, CA 95134, USA.
170
171In addition, California residents may also submit a request by calling direct 408-906-2726 or toll free 833-774-2726 (833-PRI-CSCO).
172
173Cisco does not sell the Personal Information of California consumers.
174
175Cisco does not discriminate against individuals for exercising their privacy rights.
176
177View the [Cisco CCPA Metrics Report](https://www.cisco.com/c/en/us/about/legal/2020-ccpa-metrics-report.html).
178
179### **California Shine the Light**
180
181Residents of the State of California, under California Civil Code § 1798.83, have the right to request from companies conducting business in California a list of all third parties to which the company has disclosed Personal Information during the preceding year for direct marketing purposes. Alternatively, the law provides that if the company has a privacy policy that gives either an opt-out or opt-in choice for use of your Personal Information by third parties (such as advertisers) for marketing purposes, the company may instead provide you with information on how to exercise your disclosure choice options.
182
183Cisco has a comprehensive Privacy Statement and provides you with details on how you may either opt-out or opt-in to the use of your Personal Information by third parties for direct marketing purposes. Therefore, we are not required to maintain nor disclose a list of the third parties that received your Personal Information for marketing purposes during the preceding year.
184
185## Updates to this Cisco Privacy Statement
186
187We may update this Privacy Statement from time to time. If we modify our Privacy Statement, we will post the revised version here with an updated revision date. If we make material changes to our Privacy Statement, we may also notify you by other means, such as by posting a notice on our websites or sending you a notification. By continuing to use our website after such revisions are in effect, you accept and agree to the revisions and to abide by them.
188
189**The Cisco Privacy Statement was revised and effective as of July 1, 2022.**
190
191We value your opinion. Should you have questions or comments related to this Privacy Statement, please submit a [Privacy Request](https://privacyrequest.cisco.com/) or send mail to:
192
193### **Chief Privacy Officer**
194
195Cisco Systems, Inc.
196170 West Tasman Dr.
197San Jose, CA 95134 USA
198
199### **Americas Privacy Officer**
200
201Cisco Systems, Inc.
202170 West Tasman Dr.
203San Jose, CA 95134 USA
204
205### **Europe, Middle East, Africa, and Russia (EMEAR) Privacy Officer**
206
207Cisco Systems International BV
208Haarlerbergweg 13-19,
2091101 CH Amsterdam-Zuidoost, Netherlands
210
211### **Asia, Pacific, Japan and China (APJC) Privacy Officer**
212
213Cisco Systems (USA) Pte Ltd
21480 Pasir Panjang Road
215Bldg 80, Lvl 25, Mapletree Biz City
216Singapore, Singapore 117372, Singapore