Where We Operate and Applicable Law
Aten is an international enterprise comprised of multiple affiliated entities with offices and showroom locations in numerous jurisdictions. The laws of the jurisdictions where we operate may have specific application to the personal information that we receive regarding you if you reside in those areas. The following links will provide you with the contact and location details applicable to the jurisdictions wherein we have established a physical presence: https://www.aten.com/global/en/contact-us/office-locations/ (for office locations) and https://www.aten.com/global/en/contact-us/visit-showroom/ (for showroom locations).
Personal Information Defined
Collection of Personal Information through Our Websites
By accessing and communicating with us through our websites, you consent to our collection and use of your personal information as described in the table and information below. If you do NOT agree with our collection and use of your personal information as described below, please do not visit our website or communicate with us through our website, in each instance as applicable.
The Information that We Collect and How We Use and Share the Information
The information that we collect regarding you and the purposes for which we use and share the information depend substantially on the nature of the relationship that we have with you and how you interact with us. The following table provides details regarding our collection, use and sharing of personal information:
|The Information We Collect about You||Our Use of the Information||Our Sharing of the Information|
|Passive User of Our Website||Using analytics services, we collect information regarding your visit(s) to our website, such as browser type and version, operating system and network, location and time zone setting, browsing preferences, and duration of visit to particular pages of our website. The information is aggregated and not tied to a particular user. In some instances, such as when you download our product related software, we may also receive cookie and device information such as IP address or device identifier that may enable us to identify a particular system or user.||We use analytics data to assist persons in accessing our website, to collect information that will help us to improve the quality of our visitors’ browsing experience, for our own analysis of how visitors use our website, and to improve the functionality and user-friendliness of our website.||We share this information only with our staff and vendors who assist us with analytics evaluation of our website. More details regarding our use of Google Analytics is provided below.|
|Active User of Our Website||In addition to the above analytics information, we collect information about you when you communicate with us using any one or more of a number of forms on our website including “Contact Us,” “Inquiries,” “Book a Showroom Tour,” “Product Registration,” “Online DMR Partner Recruiting Program,” “Subscribe to Our Newsletter” and other comparable form, or you may transmit an email to us when invited to do so at various locations on our website. Should you so communicate with us, we may, for example, keep a record of your name, entity that you represent, country, phone, fax, email, job title, nature of business, product interests and preferences, industry, event and subscription registration, downloads, username/passwords, and any other information you voluntarily provide to us.||We use this information for login authentication and to enable customers and prospective customers and other parties interested in our products and services to communicate with us so that we can respond with requested information and/or assistance as determined appropriate, and to send you marketing messages, customer newsletters, and invitations to relevant events.||This information is shared amongst our staff who need the information to provide responses to inquiries and to facilitate the provision of our products and services as necessary, and may be provided to or secured from vendors that will process your personal information on our behalf and under our written instructions to carry out their services during the course of our business, such as IT service providers, shipping vendors, financial institutions, customer relationship management databases and other cloud-based solutions, third party companies providing us with business analytics and statistics to assist with our marketing campaigns, and third party venues in which we may host events and seminars (we endeavor to ensure when we contract with such vendors that they only process your personal information under our instructions and maintain the security and confidentiality of your personal information by implementing appropriate technical and organizational measures for such processing).|
|Customer or representative of Our Customer or Prospective Customer||We collect or receive, principally from you, (a) identification information, such as name, gender, title, job title, or address, (b) contact information, including your phone number(s), your email address and social media account or handle where appropriate, and information regarding the company for which you are serving as a representative, if applicable, (c) financial information, such as payment source information and invoicing details, (d) information regarding the products or services that you purchase from us or about which you inquire, and (e) information regarding our relationship with you and the performance of any contract that we may have with you.||We use this information to communicate with our customers and prospective customers as necessary to respond to inquiries regarding and otherwise provide our products and services, conduct our business, perform our contracts, ship our products, maintain our relationship with you, and send you marketing messages, customer newsletters, and invitations to relevant events.|
|Representative of Our Vendor or Supplier or Prospective Vendor or Supplier||We collect or receive, principally from you, (a) identification information, such as name, gender, title, job title, or address, (b) contact information, including your phone number(s), your email address and social media account or handle where appropriate, and information regarding the company for which you are serving as a representative, if applicable, (c) financial information, such as payment source or destination information, (d) information regarding the products or services that we may purchase from you or about which we inquire, and (e) information regarding our relationship with you and the performance of any contract that we may have with you.||We use this information to communicate with our vendors and suppliers as well as our prospective vendors and suppliers as necessary to present and respond to inquiries regarding and otherwise secure and receive your products and services, conduct our business, perform our contracts, and maintain our relationship with you.||This information is shared amongst our staff who need the information to make inquiries and to facilitate the securing of your products and services as necessary, and may be provided to vendors that will process your personal information on our behalf and under our written instructions to carry out their services during the course of our business, such as IT service providers, shipping vendors, financial institutions, vendor relationship management databases and other cloud-based solutions (we endeavor to ensure when we contract with such vendors that they only process your personal information under our instructions and maintain the security and confidentiality of your personal information by implementing appropriate technical and organizational measures for such processing).|
|Individual Vendor or Supplier||We collect or receive, principally from you, (a) identification information, such as name, gender, title, job title, or address, (b) contact information, including your phone number(s), your email address and social media account or handle where appropriate, and information regarding the company for which you are serving as a representative, if applicable, (c) financial information, such as payment source or destination information, and (d) tax ID information.||We use this information to communicate with our vendors and suppliers and prospective vendors and suppliers as necessary to present and respond to inquiries regarding and otherwise secure and receive your products and services, conduct our business, perform our contracts, and maintain our relationship with you, and to fulfill legal obligations imposed on us.|
|Job Applicant||When you apply for a position with us, you may provide us with your full name, email, education and qualification details, skills, compensation expectations, any disabilities that require accommodation, your entitlement to work in the country wherein you seek to be employed, resume, CV, home address, home telephone number, mobile telephone number, reference information, and other details set out in your application. Recruiters, references, former employers, and background screening agencies may also provide us with comparable information or confirmation of such information about you. Background screening agencies may provide us with information regarding your criminal history or other significant background information, as applicable. We may be required under applicable law to obtain information that you voluntarily provide regarding your race/ethnicity and gender.||We use this information to comply with employment law requirements, to conduct background checks, and otherwise to assess the qualifications of candidates for employment with our company.||This information is shared with (a) our HR Department, (b) government agencies that may require the information, (c) internal staff who are assessing the candidate for purposes of employment with our company, (d) recruiting and background screening agencies with whom we contract to assess candidate qualifications and background, (e) former employers and references as necessary to confirm information about you, and (f) possibly with other vendors that will process your personal information on our behalf and under our written instructions to carry out their services during the course of our business, such as IT service providers and certain cloud-based solutions (we endeavor to ensure when we contract with such vendors that they only process your personal information under our instructions and maintain the security and confidentiality of your personal information by implementing appropriate technical and organizational measures for such processing).|
|Employee||We collect or receive, principally from you, but also on occasion from your supervisor and your colleagues, as applicable, in addition to the job applicant information noted above, passport details or other immigration related information, social security number, driver’s license information, bank account details, marital status, photograph, emergency contact information, benefit plan enrollment information, dependent information, employment tax related information, payroll related information, employment program participation information, records of time taken for various leaves, training records, performance appraisals, disciplinary and grievance records, information regarding your use of our computer network and phone and timekeeping systems, and information regarding your job performance and your activities as an employee.||We use this information to comply with employment law and occupational safety requirements, to engage with you as an employee of the company, to process your payroll and payroll related taxes, to enable you to enroll in employee benefit plans sponsored by the company, to respond to inquiries from your lenders, and to manage your performance as an employee.||The data is transmitted as necessary to (a) appropriate government agencies that require reports of such information, (b) our payroll processing vendor to enable processing of payroll and payroll taxes, (c) our benefits vendors to enable them to process benefits for you, (d) recruiting and background screening agencies with whom we contract to assess candidate qualifications and background, (e) companies requesting such information as a consequence of your applying for loans, (f) former employers and references as necessary to confirm information about you, and (g) possibly with other vendors that will process your personal information on our behalf and under our written instructions to carry out their services during the course of our business, such as IT service providers and certain cloud-based solutions (we endeavor to ensure when we contract with such vendors that they only process your personal information under our instructions and maintain the security and confidentiality of your personal information by implementing appropriate technical and organizational measures for such processing).|
|Individual Shareholder (or Representative thereof) or Director||We collect or receive, principally from you, (a) identification information, such as name, gender, title, job title, or address, (b) contact information, including your phone number(s), your address, your email address, (c) information regarding businesses with which you may be affiliated, (d) financial information, such as payment source or destination information, (e) information regarding your voting and other actions taken in connection with your role(s), and possibly, (f) tax ID information.||We use this information to communicate with our shareholders and directors as necessary to provide information and respond to inquiries regarding meetings and actions, stock transactions, the state of the company and its operations, maintain our relationship with you, and to fulfill legal obligations imposed on us.||This information is shared amongst our staff who need the information to communicate with you and share information with you, as necessary, and may be provided to vendors that will process your personal information on our behalf and under our written instructions to carry out their services during the course of our business, such as law firms, auditors, IT service providers, financial institutions, vendor relationship management databases and other cloud-based solutions (we endeavor to ensure when we contract with such vendors that they only process your personal information under our instructions and maintain the security and confidentiality of your personal information by implementing appropriate technical and organizational measures for such processing).|
We may consolidate the information as detailed above with information that we receive or obtain from other sources, such as from our staff or personnel, customers, professional advisers, partners, and agents of Aten, third parties with whom we interact, regulators and authorities, and publicly available sources.
Under GDPR, “sensitive personal information” includes data consisting of racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data, data concerning health or data concerning a natural person's sex life or sexual orientation. We do not actively seek sensitive personal information; however, we may collect (a) racial or ethnic origin information that you as an employee voluntarily provide to us in order for us to comply with applicable employment laws; (b) fingerprint data as a means for employees to use the company’s timekeeping system and potentially, in the future, for employees to access our offices or centers within our offices; and (c) health information in connection with the securing and provision of health and related benefits programs for our employees.
In addition to the specific uses noted above, we also note that we may use information that we receive in all categories, as necessary (a) for our legitimate interests to prevent illegal activities, including fraud, and to keep our website and IT systems and processes safe, (b) to debug and audit our systems and data, (c) to comply with legal or regulatory inquiries/requests, (d) for quality assurance purposes, and (e) to comply with corporate governance requirements.
In this regard, we note that we may be required to share information that we receive in the following situations generally:
- with law enforcement, regulatory, or government agencies requesting personal information in connection with any inquiry, subpoena, court order, or other legal or regulatory procedures, with which we would need to comply;
- to establish or protect our legal rights, property, or safety, or the rights, property, or safety of others;
- to defend against legal claims;
The Systems We Use to Collect and Process the Information
We collect information directly from you, as detailed above, and we also gather information about you as we conduct our business such as through our websites and other systems, including, for example, our:
- email system
- instant messaging systems
- mobile and office phone systems, including voicemail and related software and also the records relating to such use
- intranet and Internet systems
- computer network
- other relevant systems and other hardware and software owned, used or provided by or on behalf of us.
We are not responsible for the data policies or procedures or content of any linked websites. We recommend that you check the privacy and security policies of each website you visit.
We Offer Marketing Choices
We may send you direct marketing messages including by way of email alerts and postal services provided that we have a lawful ground to do so. If you no longer wish to receive our email alerts, to be part of a mailing list, or to receive any marketing communications, you can opt-out of such communications at any time by clicking on the unsubscribe link in the relevant communication or contacting us at marketing@Aten.com.
Third Party Marketing and Advertising Organizations
We may also use targeted advertising cookies, such as Google Ads, to deliver tailored advertising on our Sites and other websites that you may visit. You can learn more about how to control advertising cookies by visiting the Network Advertising Initiative’s Consumer Opt-Out link, the DAA’s Consumer Opt-Out link for browsers, or the DAA’s opt-out link for mobile devices. Please note that electing to opt-out will not stop advertising from appearing in your browser or applications and may make the ads you see less relevant to your interests.
Special Rights & Disclosures Regarding Personal Information
1. Residents of the EU
If you are in the European Economic Area (the “EEA”), you have the following rights under the GDPR:
- Access - to request a copy of the personal information that we are processing about you;
- Rectification - to require the correction of any mistake in the personal information, whether incomplete or inaccurate, that we have regarding you;
- Erasure - to require the erasure of personal information concerning you in certain situations, such as where we no longer need it or if you withdraw your consent (where applicable);
- Portability - to receive the personal information concerning you that you have provided to us, in a structured, commonly used, and machine-readable format and have the right to transmit that data to a third party in certain situations;
- Objection - to (i) object at any time to the processing of your personal information for direct marketing purposes and (ii) object to our processing of your personal information where the legal ground of such processing is necessary for legitimate interests pursued by us or by a third party, in which case we will comply with your request unless we can demonstrate compelling legitimate grounds for the processing;
- Restriction - to request that we restrict our processing of your personal information in certain circumstances, such as when you contest the accuracy of that personal information, we no longer need the information. or if our processing is unlawful;
- Withdrawal of consent – to withdraw your consent to our processing of your information if we have relied on your consent (or explicit consent) as our legal basis for processing your personal information (“Explicit consent” being required if we have relied on consent as the condition to lawfully process “special categories of personal data,” as defined in the GDPR);
- Notification of data breach – to receive notice in certain instances of data breaches that involve your personal information; and
- Complaint - to lodge a complaint with the local data protection authority, such as the Information Commissioner's Office (“ICO”) in the UK, if you believe that we have not complied with applicable data protection laws, including the GDPR (please follow this link for a list of local data protection authorities in the EEA countries: https://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080).
Please note that some of these rights may be limited where we have an overriding interest or legal obligation to continue to process the personal information or where data may be exempt from disclosure due to reasons of legal professional privilege or professional secrecy obligations.
If you are in the EEA and would like to exercise any of those rights, please:
- Email our Data Protection Officer at DPO@aten.com;
- Provide enough information to identify yourself (e.g., name, email address, etc.);
- Provide proof of your identity and address (a copy of your driver’s license or passport and a recent utility or credit card bill); and
- Provide the information to which your request relates.
2. Residents of Certain U.S. States
Several jurisdictions within the United States grant state residents certain rights and disclosures. We provide the following information to further help you understand your potential privacy rights.Categories of Personal Information Collected.
Categories of Personal Information Collected.We collect the following categories of information:
- Identifiers, such as name, postal address, online identifier, Internet Protocol address, email address, account name, social security number, driver's license number, passport number, or other similar identifiers.
- Categories of personal information described in Section 1798.80(e) of the California Civil Code, such as name, address, telephone number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, passport number, or driver's license or state identification card number.
- Characteristics of protected classifications under federal law, such as gender or national origin - or under California law, such as marital status or age (if job applicants choose to provide this information).
- Commercial information, such as products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
- Internet or other electronic network activity information, such as browsing history, search history, and information regarding a consumer's interaction with an Internet Web site, application, or advertisement.
- Geolocation data.
- Visual information, such as photographs.
- Professional or employment-related information (if job applicants choose to provide this information).
- Inferences drawn from the above categories of information.
The categories of sensitive information include:
- Account log-in, financial account, debit card, or credit card number, in combination with any required security or access code, password, or credentials allowing access to the account.
Rights. Various jurisdictions throughout the United States provide residents with rights over their data. Depending on your state of residence, you may have the following rights:
Request for Information or Deletion. Residents of certain U.S. states have the right to know whether we process your personal information and, in some instances, to request that we disclose to you the categories listed below for the preceding 12 months. We have the right to request verification of your identity for all requests for information. In responding to this right, we shall provide to you:
- The categories of personal information we collect about you.
- The categories of sources from which your personal information is collected.
- The business or commercial purpose(s) for collecting, selling, sharing, or disclosing your personal information, and the categories of personal information disclosed for such purpose(s).
- The categories of third parties with whom we share your personal information.
- The categories of personal information we have sold, if any, about you and the categories of third parties to whom your personal information was sold, by category or categories of personal information for each third party to whom the personal information was sold.
- The specific pieces of personal information we have collected about you.
In addition, you may have the right to request we delete your personal information.
Request for Correction. Residents of certain U.S. states have the right to request the correction or rectification of inaccurate information in the resident’s personal information.
Request for Portable Data. Residents of certain U.S. states have the right to receive, in certain circumstances, a portable format of their personal information that allows the data to be transmitted to another entity.
Do Not Sell or Share My Personal Information. Residents of certain U.S. states have the right to opt out of the sale or sharing of the consumer’s personal information. We do not sell your personal information. However, we may use your personal information to provide personalized or targeted advertising. In such circumstances, you may have the right to direct us not to share your personal information for such purposes. If you wish to opt out of this sharing of your personal information for personalized or targeted advertising, please visit this webpage: Do Not Sell or Share My Personal Information.
Limiting the Use of Sensitive Personal Information. Residents of California have the right to direct us to use or disclose sensitive personal information only for providing goods or services, or as otherwise minimally permitted under applicable law. However, we do not use or disclose sensitive personal information for any purpose other than providing our goods and services to you, or as otherwise minimally permitted under applicable law.
Third Party Marketing. California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your personal information to third parties for the third parties’ direct marketing purposes.
Automated Processing & Profiling. Residents of certain U.S. states have the right to opt out of the processing of personal information for purposes of profiling in furtherance of decisions that produce legal or similarly significant effects concerning a consumer.
Right to Equal Service & Price. You have the right to receive equal service and price, even if you exercise a privacy right.
Verification Process for Exercising Rights. To protect your privacy, we verify privacy rights requests to ensure that only you (or your authorized agent) can exercise rights pertaining to your personal information. As part of our verification process, we may request you to submit additional information.
If you are an authorized agent wishing to exercise rights on behalf of a state resident, please contact us and provide us with a copy of the consumer's written authorization designating you as their agent. We may need to verify your identity and place of residence before completing your rights request.
Appeal Process. If we do not decide to act in response to your request to exercise a right, we will provide a timely response detailing the reasons for not taking the action and, depending on your jurisdiction, any rights that you may have to appeal our decision.
If you wish to exercise these rights, you must submit a request by emailing our Data Protection Officer at DPO@aten.com; alternatively, you can contact the Data Protection Officer in Taiwan at 886-2-8692-6789 or his designated representative in the United States at 949-428-1111, ext. 1114 [or toll free at 1-888-999-ATEN (2836), ext. 1114.
3. Minors and Children
We do not seek to collect or maintain information on our website from those we know are under 18, and no part of our website is structured to attract anyone under 16. If you are the parent or legal guardian of a child under 16 who uses our website, then please contact our Data Protection Officer at DPO@aten.com to have that child’s information deleted. “OnGuard Online,” maintained by the Federal Trade Commission of the United States of America, provides a resource that may help parents and legal guardians in monitoring and limiting their children’s access to certain types of material on the Internet.
4. Residents of Taiwan
If you are a Taiwan resident, you have the following rights under the Personal Data Protection Act:
- Inquiry or review your personal information (fees may be charged);
- Request a copy of your personal information (fees may be charged);
- Request to supplement or correct your personal information;
- Request to cease collecting, processing or using your personal information; and
- Request to erase your personal information.
Please note that if you request us to cease collecting, processing or using or request us to erase your personal information, the use of this website or our provision of products and services or our securing of products and services from you, in each instance as applicable, may not be possible. We shall not be responsible for any of your losses arising therefrom.
Our Security Measures to Safeguard the Information
We endeavor to take all reasonable steps to protect your personal information but cannot guarantee the security of any data you disclose online. Please note that email is not a secure medium and should not be used to send confidential or sensitive information. By providing information online, you accept the inherent security risks of providing information over the Internet and will not hold us responsible for any breach of security, unless it is due to our negligence or willful default.
When We Transfer Information Internationally
While our offices in Belgium, Romania, and Poland are in the EEA, not all of our offices are in countries that have the same data protection laws as the United Kingdom and the EEA. When we transfer personal information from within the EEA to countries located outside the EEA or the United Kingdom that have not received an adequacy decision from the European Commission, including within Aten affiliated entities and offices and with our service providers, we have implemented adequate safeguards to appropriately protect such transfer of personal information, including through data transfer agreements incorporating the European Commission's standard contractual clauses or as permitted under applicable data protection laws. These safeguards are designed to protect your privacy rights and provide you with remedies in the unlikely event that your personal information is misused. You may ask for further information on the safeguards that we have put in place to safeguard the transfer of your personal information to countries outside of the EEA by contacting our Data Protection Officer at DPO@aten.com.
A cookie is a small file of letters and numbers that is sent by our web server to your computer or mobile device when you access our website. Our website uses persistent cookies, which enable our web server to recognize your device and browsing preferences each time you visit our website. For more information on cookies, visit www.allaboutcookies.org.
Cookies can be disabled by changing the settings on your browser, though some parts of the website may not function well if you choose to do so.
Our website uses Google Analytics, a web analytics service provided by Google, Inc. ("Google"), currently headquartered at 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Google Analytics employs cookies that are stored to your computer in order to facilitate an analysis of your use of the site. The information generated by these cookies, such as time, place and frequency of your visits to our site, including your IP address, is transmitted by Google to Google’s location in the US and stored there.
In using Google Analytics our website employs the extension “anonymizeIp”. In doing so, Google abbreviates and thereby anonymizes your IP address before transferring it from EU/EEA member states. Google uses this information to analyze your use of our site, to compile reports for us on internet activity and to provide other services relating to our website.
You can prevent the data generated by cookies about your use of the website (incl. your IP address) from being passed to Google, and the processing of these data by Google, by downloading and installing the browser plugin available at the following link: tools.google.com/dlpage/gaoptout.
- Cookie settings in Chrome
- Cookie settings in Firefox
- Cookie settings in Microsoft Edge
- Cookie settings in Safari web and iOS
“Do Not Track” Browser Settings
Some browsers provide you with a way to signal that you do not want your browsing activity to be tracked. We may not currently respond to all Do Not Track (“DNT”) or similar signals, as we are awaiting consensus from the Internet policy and legal community on the meaning of DNT and the best way to respond to these signals.
California and certain other U.S. state residents may opt out of tracking technologies by broadcasting an Opt-Out Preference Signal, such as the Global Privacy Control (GPC) (on the browsers and/or browser extensions that support such a signal). To download and use a browser supporting the GPC browser signal, click here: https://globalprivacycontrol.org/orgs. If you choose to use the GPC signal, you will need to turn it on for each supported browser or browser extension you use. Your request to opt-out of sale/sharing will be linked to your browser identifier only and not linked to any account information because the connection between your browser and the account is not known to us.
How We Retain the Information
You can also fill out the form in Support Center (https://eservice.aten.com/eServiceCx/Common/FAQ/askQuestion.do), and we will process your request as soon as possible.
Notification of Changes
Last updated: Jun 2023