Supplemental EEA+ Privacy Notice

Last updated November 1, 2022

We, A10 Networks, Inc., address this Supplemental EEA+ Website Privacy Notice to individuals located in the European Economic Area (EEA), United Kingdom (UK) and Switzerland only. If you visit or otherwise use any website we operate that includes a link to this notice, this Supplemental EEA+ Website Privacy Notice supplements our Website Privacy Statement. If you represent a customer, vendor or other entity that does business with us, this this Supplemental EEA+ Website Privacy Notice supplements our Business Contacts Privacy Statement.

1. What laws apply?

If you are located in the EEA, the EU General Data Protection Regulation applies to the processing of your personal data. If you are located in the UK, the UK General Data Protection Regulation applies to the processing of your personal data. References to the “GDPR” are references to the General Data Protection Regulation as it applies in the country where you are located. If you are located in Switzerland, the provisions of the Swiss Federal Data Protection Act (the “FDPA”) apply to you, and references to the GDPR below shall be interpreted analogously for the purposes of applying the FDPA.

2. Who is the data controller?

A10 Networks, Inc., 2300 Orchard Parkway, San Jose, California 95131. Our UK GDPR representative is A10 Networks Limited, Asmec Centres, Merlin House, Brunel Road, Theale, Berkshire, RG7 4AB, UK (dataprivacy@a10networks.com), and our EU GDPR representative is our general counsel.

3. What lawful bases of processing do we rely on?

We rely on the following legal bases to process your personal data, as appropriate:

  • Necessary for us to perform a contract with you or take steps at your request prior to entering into a contract per Article 6(1)(b) GDPR (“Contract Performance Legal Basis”);
  • Necessary for us to comply with an applicable legal obligation per Article 6(1)(c) GDPR (“Legal Obligations Legal Basis”);
  • Necessary for us to realize a legitimate interest based on an assessment of that interest and your privacy and other fundamental interests per Article 6(1)(f) GDPR (“Legitimate Interest Legal Basis”); or
  • According to your consent per Article 6(1)(a) GDPR (“Consent Legal Basis”). In these cases, you can withdraw your consent at any time with future effect.

The following table outlines the legal basis and, where applicable, the legitimate interests pursued with respect to each purpose for which we process personal data.

Purposes of Use or DisclosureLegal Basis and Legitimate Interest
Responding to your inquiry or considering your requestLegitimate Interest Legal Basis—namely, to provide you and our other users with a good experience.
Evaluating your job applicationConsent with respect to collecting personal data you submit to us in your job application.

Legitimate Interest Legal Basis with respect to evaluating your job application—namely, to determine whether it is in our interests to extend an offer to you.

Filling your orders, making orders, and maintaining, securing, customizing and improving our site and servicesIf we are contractually obligated to perform the processing based on the terms of a contract, Contract Performance Legal Basis.

Otherwise, we process your personal data on the Legitimate Interest Legal Basis—namely, to improve our services and communications so that we can continue to provide high quality offerings to you and others.

To send and tailor our promotional communications to youConsent Legal Basis if we have obtained your consent to market to you.

In all other cases, Legitimate Interest Legal Basis, if you have not objected to our marketing and for the purpose of increasing use of our products and services.

To exercise our legal rights, defend and advance our legal interests, comply with applicable laws such as data protection laws, and protect against fraudulent, harmful and illegal activityIf we are legally obligated to perform the processing (such as to disclose personal information to a law enforcement authority with authorization under criminal law), Legal Obligations Legal Basis.

If we are contractually obligated to perform the processing, Contract Performance Legal Basis.

In all other cases, Legitimate Interest Legal Basis—namely, to exercise our legal rights, defend and advance our legal interests, and protect against fraudulent, harmful and illegal activity.

or partial sale or transfer of our business or assetsLegitimate Interest Legal Basis—namely, to engage in a transaction that our management team considers to be advantageous to our business interests.

But we will seek your consent if we wish to use your purpose for any new purpose incompatible with those set forth in this Privacy Notice, and if you provide such consent, the Consent Legal Basis applies.

4. Where is your personal data processed and on what basis do we transfer personal data across borders?

As of the date of this notice we rely on service providers in locations including the United States, India, Germany, Japan, the United Kingdom and Taiwan. We take measures to ensure that service providers in the United States provide an adequate level of data protection by entering into appropriate data transfer agreements based on Standard Contractual Clauses and performing data protection assessments of data transfer arrangements as appropriate. Data transfer agreements are accessible upon request by contacting us at the details shown further above.

5. Do you have to provide personal data?

You are not legally required to provide us with your personal data, but if you do not provide us with personal data that we reasonably need to provide our website, process your orders or evaluate your job application, you may not be able to fully use our site, make orders or be considered for a job posting. If you do not allow us to collect information through cookies and similar technology, some parts of our website may not work properly or be as tailored to you as they could otherwise be, but they will still generally be usable. We will inform you of personal data that we reasonably need to fulfil the purposes in our privacy notices, such as by marking certain fields as mandatory on online forms requesting personal data from you.

6. Your Rights

In the EEA, Switzerland and the UK you have the following rights, subject to the conditions under the GDPR and/or local data protection law:

(a) To object, on grounds relating to your particular situation, to the processing of your personal data by us. This includes the right to object to our processing of your personal data for direct marketing and the right to object to our processing of our personal data where we are performing a task in the public interest or pursuing our legitimate interests or those of a third party. If we process your personal data based on our legitimate interests or those of a third party, or in the public interest, you can object to this processing, and we will cease processing your personal data, unless the processing is based on compelling legitimate grounds or is needed for legal reasons. Where we use your personal data for direct marketing for our own products and services, you can always object and opt out of future marketing messages using the unsubscribe link in such communications.

(b) To obtain from us confirmation as to whether your personal data is being processed, and, where that is the case, to request access to details about how we process your personal data and copies of the personal data.

(c) To obtain from us the rectification of inaccurate personal data concerning you.

(d) To ask us to erase your personal data to the extent it is not required for legally required purposes.

(e) To request restriction of processing of your personal data, in which case, it would be marked and processed by us only for certain purposes.

(f) To receive your personal data which you have provided to us in a structured, commonly used and machine-readable format and you have the right to transmit the personal data to another entity without hindrance from us.

(g) To lodge a complaint with a supervisory authority (only for EEA and UK).

(h) In some jurisdictions such as France and Portugal, you also have the right to provide us with guidelines as to the processing of your personal data after your death.

You may view a list of supervisory authorities in the EEA, UK and Switzerland and their respective contact information here:

JurisdictionData protection authority’s website
EEAhttps://edpb.europa.eu/about-edpb/board/members_en
United Kingdomhttps://ico.org.uk/global/contact-us/
Switzerlandhttps://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact.html

 

To exercise your rights under applicable privacy law, to raise a privacy concern, or to make a data-related request, please submit your request at the email address below. Any requests to exercise your privacy rights or make a data-related request must be in writing and include your name and address and any other information that may identify you. For certain requests, you must also provide information that we reasonably request from you so that we can verify your identity.

A10 Networks, Inc.

e-mail at dataprivacy@a10networks.com