Introduction

We are Anuta Networks Holdings, a company incorporated under the laws of Ireland, and the following affiliates (collectively, throughout this Policy, “we”):

• Anuta Networks International, LLC, a Delaware limited liability company
• Anuta Networks Pvt. Ltd

We respect your privacy and are committed to protecting it through our compliance with this Policy.  This Policy describes the types of information we may collect from you or that you may provide when you visit the website www.anutanetworks.com (our “Website”) and our practices for collecting, using, maintaining, protecting and disclosing that information.

This Policy applies to any information we collect on the Website, including any information in any emails, posts, texts and other electronic messages between you and the Website.  This Policy does not apply to any information that we collect by any other means.

Acceptance

Please read this Policy carefully to understand our policies and practices regarding your information and how we will treat it.  If you do not agree with our policies and practices, you can choose not to use our Website.  By accessing or using our Website, you agree to this Policy.  This Policy may change from time to time.  Your continued use of the Website after we make changes is deemed to be acceptance of those changes, so please check the Policy periodically for updates.

Legal Basis for Processing

We have the legal right to use your Personal Information (as defined below) in the ways described in this Policy based on your consent, or on the need to use the Personal Information to provide you with products or services that you request, or for the legitimate purposes of furthering our existing relationship with you.  Accordingly, you have a contractual rather than a statutory obligation to provide such information.  If you do not provide such information, you may be unable to use our Website and we may be unable to provide any products or services you request.

Information We Collect About You and How We Collect It

Via our Website, we collect only the following pieces and categories of information by which you may be personally identified:

• Your first and last name;
• Your company’s name;
• Your contact information, such as e-mail address, mailing or business address and telephone;
• The country where you are located;
• IP Address, Mobile Device ID and similar persistent identifiers related to the mobile device or computer you use to access the Website; and
• Any other personal information you choose to submit to us through our Website’s fillable web-forms.

All of this information is cumulatively referred to in this Policy as “Personal Information.”  Other than with respect to your IP Address, Mobile Device ID and similar persistent identifiers (which are collected and processed automatically when you visit our Website, as described below), we only collect Personal Information via our Website when you provide it directly to us, such as by submitting fillable web-forms, requesting further services or reporting a problem with our Website.  We retain records and copies of your correspondence (including email addresses) if you choose to contact us through the Website.

 How We Use Your Personal Information

We use information that we collect about you or that you provide to us, including any Personal Information, to present our Website and its contents to you, to provide you with information, products or services that you request from us, and to fulfill any other purpose for which you provide the information.

We may use your Personal Information to contact you and provide you with promotional information about our own products and services or for delivering e-mail newsletters and similar content that may be of interest to you.  If you do not want us to use your information in this way, please see the section below titled “Choices About How We Use and Disclose Your Information” for information about how to opt out of these communications.

We may also use your Personal Information to notify you about changes to our Website or any products or services we offer or provide through it and to carry out our obligations and enforce our rights arising from any contracts entered into between us and you (and/or your company), including for billing and collection.  We may also use the information that you provide in any other way that we describe when you provide the information and for any other purpose with your consent.

We also use your information as described in the sections below titled “Information Collected Through Automatic Data Collection Technologies,” “Use of Google Analytics,” “Tracking and ‘DO NOT TRACK,’” and “Use and Disclosure of Pseudonymized, Aggregated or De-Identified Data.”

Information Collected Through Automatic Data Collection Technologies

As you navigate through and interact with our Website, we may automatically collect certain traffic data and usage information.  This may include information about your equipment, your IP Address, Mobile Device ID and similar persistent identifiers, and your browsing actions and patterns when you visit our Website, including the referring and exit pages.  The technologies that we use for this automatic data collection may include cookies that are stored on your computer, small embedded electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs) and other types of embedded code on the Website that permit us to count users and obtain other related Website statistics (for example, recording the popularity of certain Website content and verifying system and server integrity).

We use this information to estimate our audience size and usage patterns and to help us manage our content and improve your use of the Website.

Third parties also may use these technologies to collect information about your online activities over time and across several websites (including our Website) or other online services for purposes of serving interest-based advertising (online behavioral advertising).  See the section below titled “Tracking and ‘DO NOT TRACK’” for information on how you can opt out of behavioral tracking on our Website and how we respond to web browser signals and other mechanisms that enable consumers to exercise choice about behavioral tracking.

Use of Google Analytics

We use Google Analytics to track and analyze certain traffic and usage statistics regarding our customers’ use of our Website, such as number of visitors to our Website, how visitors are navigating to our Website, visitors’ general geographic region information, how long our visitors are visiting our Website, and information about the equipment our visitors are using to access the Website, such as browser version and operating system.  Google Analytics may use a Google Analytics cookie and may collect your IP Address or Mobile Device ID as part of this service (but neither we nor Google Analytics otherwise collects or processes any of your Personal Information in connection with our use of the Google Analytics services).  We use this traffic and usage information to gauge, internally, the effectiveness of our advertising efforts and to make improvements to the Website and our marketing and promotional efforts.

In addition, we use the following Google Analytics Advertising Features:

• Remarketing
• Google Display Network Impression Reporting
• Google Analytics Demographics and Interest Reporting
• Google Ads (an integrated service with Google Analytics)

By enabling these features, Google collects certain additional traffic and usage data using a Google Advertising cookie and other identifiers not tied to your Personal Information.  This information includes demographic information about our Website visitors and general information about our visitors’ interests, but does not identify our visitors individually.  In fact, we are prohibited by Google policy from using this information to try to identify individual users or for merging non-personally-identifiable information obtained from Google with personally-identifiable information we otherwise have about you without obtaining your separate consent.  We use the information collected from our use of the Google Analytics Advertising Features to segment our audience and better target our ad campaigns (for example, to target visitors from the Southeast United States with certain ads in Google search results that have previously shown a high degree of success in this demographic ).

For more information, please review the following:

• Information about Google’s use of Google Analytics cookies and Google Advertising cookies: https://policies.google.com/technologies/types
• How Google uses information from sites or apps that use Google’s services: https://policies.google.com/technologies/partner-sites

You can opt-out of our use of certain Google Analytics features by updating the Ad Settings in your browser (http://www.google.com/settings/ads) or mobile device (https://support.google.com/ads/answer/1660762#mob), by visiting the Network Advertising Initiative’s (NAI’s) Consumer Opt-Out page at https://web.archive.org/web/20240707144504/https://optout.networkadvertising.org/, or by visiting Google’s currently available opt-outs over the web at https://tools.google.com/dlpage/gaoptout/.

Tracking and “DO NOT TRACK”

Tracking involves the use of cookies, web beacons or other embedded code or tracking technologies to collect, analyze and store information on a user’s behavior over time on multiple sites, including information on the sites visited, products viewed, products purchased and other online interactions.  Tracking information can be used to enable companies to make interest-based (behavioral) advertising available to users on multiple sites that they visit.

We do not currently collect Personal Information about your online activities over time and across third-party sites for tracking purposes.  However, other parties, including third-party advertisers, ad networks, ad servers, Internet providers and mobile device providers may use cookies, web beacons or other embedded code or tracking technologies to collect, analyze and store information about your online activities over time and across third-party sites when you use our Website for the purposes of serving you interest-based advertising (online behavioral advertising) on other websites.  We do not control these third parties’ tracking technologies or how they may be used.  If you have any questions about an advertisement, you should contact the responsible advertiser directly.

In addition, you may choose to click on one of our advertisements on a social media platform and thereby be directed to our Website.  Please note: when you click on one of our advertisements directing you to our Website from a social media platform, the social media platform may use a tracking cookie or other automatic information collection technology to track, analyze and store information about your preferences and your online activities across third-party websites over time, and they may use this information to serve interest-based advertising to you or for other purposes. The information collected by such tracking cookies or other automatic information collection technologies is controlled by third-party privacy policies.  We encourage you to review the relevant social media platform’s privacy policy for more information.

You may opt-out of certain interest-based advertising activities by visiting the Network Advertising Initiative’s (NAI’s) Consumer Opt-Out page at https://web.archive.org/web/20240707144504/https://optout.networkadvertising.org/.

Our Website does not and will not respond to any “DO NOT TRACK” signals sent by your browser, mobile device or otherwise.  If your browser or mobile device sends a “DO NOT TRACK” signal to our Website, our Website will not treat you differently than other visitors to our Website whose equipment does not send such signals.

Disclosure of Your Information

We may disclose Personal Information to our subsidiaries and affiliates and to any contractors, service providers and other third parties who need to know such information to provide services that we request to support our permitted uses of Personal Information.  For example, we may disclose certain of your Personal Information in connection with our use of Google Analytics (see the section above titled “Use of Google Analytics”) and we may use a third party cloud-hosting service provider (such as Amazon Web Services) to store certain of your Personal Information securely.

We may disclose your Personal Information to a buyer or other successor to our business in the event of a sale of equity or assets, reorganization, merger or a similar corporate transaction and any due diligence review with respect to any such proposed transaction.

We may also disclose your Personal Information to comply with any court order, law or legal process, including to meet national security and law enforcement requirements and to respond to any government or regulatory request or audit and to enforce or apply any contracts you or your company have entered into with us, or if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of our customers or others.

We may also disclose your Personal Information for any other purpose disclosed when the information is provided and for any other purpose with your consent.

Use and Disclosure of Pseudonymized, Aggregated or De-Identified Data

We may pseudonymize some of your Personal Information so that it can no longer be attributed to you without the use of other separately maintained information, or we may convert or combine some Personal Information of users into de-identified or aggregated data that does not disclose any of the Personal Information of any individual user.  We may use and disclose to third parties any such pseudonymized, de-identified or aggregated data (including traffic and usage data that does not identify you personally) for any lawful purpose.

Choices About How We Use and Disclose Your Information

You have certain choices regarding the Personal Information you provide to us.  You can set your browser to refuse all or some browser cookies.  If you disable or refuse cookies, some parts of the Website may then be inaccessible or not function properly.

If you do not wish to have your Personal Information used by us to contact you with promotional or informational content or messages, you may send us an email stating your request to info@anutanetworks.com or you can opt-out by simply clicking on the “Unsubscribe” or “Updating your e-mail preferences,” link in the most recent e-mail you received from us and follow the prompts that appear.

Users Outside of the United States

Our Website is hosted in the United States and our services are provided from the United States.  It is possible that certain information will be stored on servers in multiple other countries on the “cloud” or other similar distributed hosting platforms.  If you are a resident of any country other than the United States, please note that by providing your Personal Information to us, you are consenting to the transfer of your Personal Information to the United States and other jurisdictions as indicated above, and to our use and disclosure of your Personal Information in accordance with this Policy.

If you are a resident of the European Union, please note that the EU has determined that the laws of the United States do not provide adequate protection for your Personal Information.  Accordingly, we are transferring your Personal Information from the EU to the United States based on your consent, or our need to use your Personal Information to provide products or services that you request, and subject to the following additional protections:

• If we intend to disclose your Personal Information to any third party that will carry out processing on our behalf, we will enter into a contract with that third party that provides that your Personal Information may be processed only for limited and specified purposes consistent with the consent that you have provided to us, and that the third party must provide the same level of protection for your Personal Information that we are obligated to provide under this Policy while it is processing your Personal Information.
• If we are processing your Personal Information based on your consent, you may withdraw that consent at any time.
• You may restrict our use of your Personal Information, by sending us an email stating your request to info@anutanetworks.com, if you have contested the accuracy of that information, or if the processing is unlawful or you need the information to establish, exercise or defend a legal claim. We will then store your Personal Information and process it only with your consent, or to establish, exercise or defend a legal claim or to protect the rights of others.  The restriction with respect to information claimed to be inaccurate would end if we verify the accuracy of that contested information.
• Some of the information that you provide to us may be sensitive information related to your racial or ethnic identity, political opinions, religious or philosophical beliefs, trade union membership, health (including genetic and biometric data), sex life or sexual orientation (“Sensitive Information”). We will not use or disclose any of your Sensitive Information without your express consent, subject to certain limited exceptions.  Should we wish to make any use or disclosure of your Sensitive Information, we will notify you by e-mail and request that you authorize such use or disclosure by responding to the e-mail with your express consent.
• We do not create profiles to analyze or predict your performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or movements, and we do not make any decision about you that would have legal consequences or similarly significant affects for you based solely on automated decision-making, including the use of profiles. We do not process your Personal Information using automated decision-making or similar automated means (such as by processing the information using proprietary algorithms).
• Upon our receipt of your request by email at info@anutanetworks.com and our verification of your identity, we will advise you whether or not we are processing Personal Information concerning you and, if so, we will provide you with a copy of your Personal Information being processed and certain information about the nature and purposes of the processing. You may correct any such Personal Information that is inaccurate or incomplete.
• Upon your request, we will erase any of your Personal Information that is no longer needed for the purpose for which it was collected, or that is being used for direct marketing purposes, or if our use is based on your consent and you withdraw that consent.
• You have the right to obtain a copy of your provided Personal Information, together with certain additional Personal Information that we have generated as a result of your use of our Website, in a structured and commonly used and machine-readable format, and to transfer such Personal Information to another service provider. Upon your request, we will transfer that Personal Information directly to another service provider if it is feasible for us to do so.
• If we are using your Personal Information on the basis of your consent, and we change our Policy to permit any use or disclosure of your Personal Information that is materially different than the uses for which it was originally collected or subsequently authorized by you, we will obtain your consent before we make such further uses of your Personal Information.

If you have a complaint about our compliance with this Policy, you may contact us using one of the methods described below in the section titled “Contact Information.”  If you are not satisfied with our response, you will have the right to lodge a complaint with the Supervisory authority in your country of residence in the EU.

Your California Privacy Rights

If you are a California resident, you may obtain certain information regarding our disclosure of your Personal Information to third parties for their direct marketing purposes.  To make such a request, please send an email to info@anutanetworks.com.  Please note, however, that we do not currently disclose your Personal Information to third parties for their direct marketing purposes.

Accessing and Correcting Your Information

You can send us an email at info@anutanetworks.com to request access to any Personal Information that you have provided to us, or to correct or delete that Personal Information.  We will evaluate such requests on a case-by-case basis.  We may not accommodate a request to access Personal Information if we cannot reasonably verify the identity of the person making the request or that the request is otherwise valid.  We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

Children Under the Age of 16

Our Website is not intended for children under 16 years of age, and no one under age 16 may provide any information to our Website.  We do not knowingly collect personal information from children under age 16.  If you are under 16 years of age, do not use or provide any information on our Website, use any of the interactive features of our Website, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or username you may use.  If we learn we have collected or received personal information from a child under 16 years of age without verification of parental consent, we will delete that information.  If you believe we might have any information from or about a child under age 16, please contact us at info@anutanetworks.com.

Data Security

We have implemented measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration, and disclosure.  All information that you provide to us is stored on our servers behind firewalls, and certain Personal Information will be encrypted using secure socket layer (SSL) technology.

Unfortunately, the transmission of information over the Internet is not completely secure.  Although we have implemented security measures that we think are adequate, we cannot guarantee the security of your Personal Information transmitted to our Website.  Any transmission of Personal Information is at your own risk. We are not responsible for the circumvention of any privacy settings or security measures contained on the Website.

Changes to Our Privacy Policy

We post any changes we make to our Policy on this page.  If we make material changes to how we treat our users’ Personal Information, we will notify you through a notice on the Website home page.  The date the Policy was last revised is identified at the top of the page.  You are responsible for ensuring we have an up-to-date, active and deliverable email address for you, and for periodically visiting our Website and this Policy to check for any changes.

Contact Information

To ask questions or comment about this Policy or our privacy practices, contact us:

Via e-mail at info@anutanetworks.com

Via telephone at +1 408.458.7955
Via postal mail at 1525 McCarthy Blvd., #1020, Milpitas, CA 95035