What is Personal Data?

"Personal Data" is any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier, like your name or email address. In certain jurisdictions, Personal Data may also include information that identifies, relates to, or could reasonably linked to a household or legal entity.

Personal Data may include, but is not limited to name, address, email address, phone number, login information (such as account number, password), social media account information, IP address, or payment card number. It may also include information about your preferences and behavior, as well as inferences drawn about you.

Who is the Controller of my Personal Data?

The Ciena Group, as the controller of your personal data, assumes the responsibility for the processing of your personal data. We determine the methods and means by which we collect your data, the purposes for which it is collected, and the duration for which it is retained. We ensure that your personal data is handled in accordance with applicable data protection regulations and industry best practices.

To provide you with a comprehensive overview, we have compiled a list of various Ciena entities that are part of the Ciena Group. These entities operate under the umbrella of the Ciena Group and collectively contribute to the management and processing of your personal data. You can find a list of our various Ciena entities below under ‘List of Ciena Entities and Registered office address’ section.

What Information does Ciena collect?

Personal Data

The specific Personal Data that we collect depends on the nature of our relationship and interactions with you. However, Ciena will only collect Personal Data that is necessary for Ciena’s business activities and functions or as otherwise permitted under applicable law, including with your consent.

Ciena may collect the following types of Personal Data:

• Contact information, including identifiers: Information used to communicate with you, such as first and last name, title, company name, email address, telephone number, and postal address.
• If you are a customer or a supplier:
• Account and commercial information: Information that Ciena maintains in association with the customer or supplier account, such as your name, title, company name, employee ID, work email address, work telephone number, work address, account number, username/user ID, password, payment information including bank account information, purchase records, government or tax identifiers, information about your use or provision of the product or service, your preferred language and other preferences, credit and billing status and support inquiries; and
• Information about your communications with us: Correspondence you send to us by mail, email, or via any chat functions on the website, electronic messaging systems, call recordings if you call customer service and to the extent permitted by law.
• If you visit our website:
• Internet or other similar network activity: Information collected when you visit a website, such as IP address, browsing history, information on your interaction with the website, browser type and language, operating system, location, date and time;
• Location information: Information about your physical location, such as if you provide your postal address or based on your IP address if you visit a website; and
• Inferences: Information drawn from the data collected above, such as what topics you may be interested in based on the areas of the website you visit.
• We also store login credentials if you choose to create an account on  MyCiena portal.
• If you are a job applicant:
• Contact information, including identifiers: Information used to communicate with you, such as first and last name, email address, telephone number, gender and postal address; and
• Login credentials when you create a job applicant portal with us
• Professional or employment-related information: Information contained in your job inquiries or applications, such as resume, cover letter, date of birth, education, professional history and contact details.
• In certain jurisdictions, where permitted and in accordance with applicable laws, we collect – either ourselves or through third party service providers - details of professional registrations, sanctions with professional bodies, financial checks and/or criminal convictions, as well as pre-employment drug screening

You are not required to provide Personal Data to Ciena. Please keep in mind that if you choose not to provide your Personal Data to Ciena, we may not be able to provide you with our products or services or some of their features, or to respond to queries you may have as detailed in “How does Ciena use my Personal Data” section below.

Sensitive Personal Data           

Sensitive Personal Data, which may be called special categories of data in certain jurisdictions, includes political opinions, your religious or philosophical beliefs, racial or ethnic origin, trade union membership, health, or medical information, genetic or biometric data, or other data treated as sensitive under applicable law. Ciena generally does not collect, sell, or share Sensitive Personal Data without consent. If Ciena reasonably needs to collect any Sensitive Personal Data from you, Ciena will obtain your consent for the collection of such Sensitive Personal Data as may be required under applicable law. If you are a job applicant, please do not provide any sensitive Personal Data unless asked to do so.

Please note that in Australia, professional or trade association membership is a category of sensitive information.

Children’s Online Privacy

Ciena’s products and services are not directed to children and Ciena does not knowingly collect, sell, or share Personal Information from children under the age of 16. If you are a parent or guardian of a minor under the age of 16 and believe that he or she has disclosed Personal Information to us, please contact us as described below under "How to Contact Us." Ciena will take steps to delete their Personal Information.

How does Ciena collect my Personal Data?

From You
We can collect your Personal Data directly from you, including but not limited to when you:

• browse our website(s);
• use our Community or Customer Portal or otherwise interact with us as a customer or on behalf of a customer;
• use our Recruitment Portal or otherwise apply for employment with us;
• subscribe to our alerts or publications (including newsletters and mailing lists);
• attend our webinars;
• request information from us about products and services;
• contact us, such as with a question or complaint;
• visit us at various industry events; or
• when you otherwise choose to provide your Personal Data to us.

From Other Sources

• Ciena may also obtain Personal Data about you from other sources including third-party marketing or advertising services or other publicly accessible sources on the internet.
• If you are a potential employee, we may obtain Personal Data about you from other sources, including recruiters, employment research firms, identity verification services, the references you provide to us, websites, and other publicly accessible sources on the Internet. We may also collect Personal Data you submit to us through third-party websites. In certain jurisdictions, where permitted and in accordance with applicable laws, we collect – either ourselves or through third party service providers - details of professional registrations, sanctions with professional bodies, financial checks and/or criminal convictions, as well as pre-employment drug screening.

Automatically Collected Information
When you visit our website, we store data that your browser automatically transmits to us in log files, such as your IP-address, domain name and page from which you entered our website, browser type and browser version, pages requested, and date/timestamp of requests.

In addition, our website uses “cookies,” which are small text files placed on your device by web page servers. We use cookies on our website that store limited information about your settings and usage behavior on the website, such as which pages you visit on our website and how much time you spend on each page, to recognize repeat visitors and help personalize your online experience. When required under applicable law, we will only collect this data with your prior express consent.

For what purposes does Ciena process my Personal Data?

Ciena may process your Personal Data for the following purposes:

Processing Activity	Legal Basis for Processing
Provision of our website, products, and services, including providing the services you request, maintaining your account, billing, technical support, and professional services.	This processing is necessary for the performance of a contract with you or to take steps at your request before entering into a contract. This is a primary processing purpose.
Utilization of products and services purchased, including communication about product/service delivery and managing supplier accounts.	This processing is necessary for the performance of a contract with you or to take steps at your request before entering into a contract. This is a primary processing purpose.
Recruitment and hiring, including assessing applications, considering future positions, and carrying out HR functions per applicable law.	Necessary for the performance of a contract or to take steps at your request before entering into one. Necessary for compliance with a legal obligation. Legitimate interest in recruitment and hiring. Prior consent obtained in jurisdictions that require it. This is a primary processing purpose.
Communications and marketing, including outreach for products, services, surveys, and advertisements.	Legitimate interest in communication. Prior consent obtained where required. This is a primary processing purpose.
Improvement of website, products, or services, including market analytics, quality assurance, and development.	Legitimate interest in improving services. Prior consent obtained where required. This is a primary processing purpose.
Management and protection of business operations, including fraud prevention, security monitoring, and system protection.	Necessary for compliance with a legal obligation. Legitimate interest in business protection. This is a primary processing purpose.
Compliance with law, including safeguarding and documenting legal obligations.	Necessary for compliance with a legal obligation. This is a primary processing purpose.
Legal proceedings, including establishing, exercising, or defending legal claims or responding to regulators.	Necessary for compliance with a legal obligation. Legitimate interest in defending rights. This is a primary processing purpose.

When we process your Personal Data for our legitimate business interests, we put in place safeguards to protect your privacy and to ensure that our legitimate interests are not overridden by your interests or fundamental rights and freedoms.

Where the processing of your Personal Data is based on your consent, you may withdraw your consent at any time by contacting us using the details at the end of this notice.

Does Ciena disclose my Personal Data to third parties?

Ciena does not sell your Personal Data for monetary compensation. We may disclose Personal Data to third parties as described below.

We disclose information within Ciena
We disclose information within Ciena for the purposes described in this notice, including providing you with the latest information about our products and services and offering you our latest promotions.

We disclose information to vendors and partners for the purposes described in this notice
We disclose information to authorized vendors and partners to the extent that they assist Ciena in the provision of our website(s) or services offered on our website(s) or otherwise. For example, we may disclose Personal Data to service providers in the field of IT application hosting, marketing service providers, recruiting professionals, and human resources vendors for the purposes set out above.

We may disclose your information in other specific situations
In addition to the circumstances described above, your Personal Data may be disclosed to third parties in certain circumstances, such as:

• To comply with the law
• When required by the court
• To protect you, others, or us
• When needed by outside auditors, law enforcement, or regulators
• In connection with a merger, acquisition, or sale of all or a portion of our assets or business
• In aggregated, anonymized, and/or de-identified form that cannot reasonably be used to identify you
• With your consent

We will obtain your consent for any of the disclosures described above if required by applicable law.

How does Ciena protect my Personal Data?

To prevent unauthorized access to and misuse of your Personal Data (including accidental loss, disclosure, alteration, or destruction), maintain data accuracy, and ensure the correct use of information, we have put in place reasonable and appropriate technical, organizational, administrative, physical, and procedural security measures to safeguard and secure the information that we collect from you as described in this Privacy Notice.

International Data Transfers

Ciena is a global organization, with legal entities, business processes, and technical systems that operate across borders. Ciena may transfer your Personal Data to other Ciena group companies or authorized vendors and partners in the United States, European Union, and elsewhere.

The recipients of your Personal Data may be located in jurisdictions that may not have the same level of protection with respect to your Personal Data as considered adequate in the jurisdiction from which you initially provided the information. We have put in place appropriate safeguards (such as technical, organizational, and security measures and standard contractual clauses approved by local authorities) in accordance with applicable legal requirements to ensure that your Personal Data is adequately protected in accordance with applicable law. We will obtain your consent to such transfers if required by law.

In relation to intra-group transfers, all members of the Ciena group that process Personal Data are party to the Ciena Intra Group Data Sharing Agreement, which regulates how Personal Data is shared and used with the group and (where necessary) includes international transfer mechanisms (such as approved EU standard contractual clauses).

For further information about the recipients of your Personal Data and the safeguards implemented by us, including how to obtain a copy of them, please contact us using the contact details in the "How to Contact Us" section.

How long does Ciena retain my Personal Data?

We retain Personal Data for as long as necessary for the purposes described above (for example, to provide you with a service you have requested or to comply with applicable retention obligations, such as legal, tax, or accounting requirements).

When the processing of your Personal Data is no longer necessary for the above-mentioned purposes, we will either delete, destroy, or anonymize it. Where your Personal Data is stored in backup archives, your Personal Data will be deleted or destroyed in accordance with our general deletion routines (and be securely stored so that it is isolated from any further processing until deletion, destruction, or anonymization has been completed). We will not attempt to re-identify Personal Data that has been anonymized.

Use of Cookies and Similar Technologies

At Ciena, we use the following classifications of cookies:

Type of Cookies	Purpose of Use	Legal Basis for Processing
Essential Cookies	Essential cookies enable you to navigate the website and to use its services and features. Without these necessary cookies, the website will not perform without errors, and we may not be able to provide the website or certain services or features. Essential cookies further allow us to maintain the safety and security of our website.	To the extent these cookies can be attributed to you, the processing of your Personal Data will be based on our legitimate interests in providing effective, error-free, and secure functionalities, features, and services on our website, including management of your cookie choices. This is a primary processing purpose.
Functional Cookies	Functional cookies are optional. They collect information about your choices and preferences, allowing us to remember language or other local settings and customize the website accordingly. These cookies also track your use of the website to help us improve its performance, analyze website traffic, and evaluate advertising effectiveness.	We will only place functional cookies, and process any related data, if you accept these cookies and provide your consent for the related processing of your Personal Data. This is a secondary processing purpose.
Advertising Cookies	Advertising cookies are optional. They are set to display targeted promotions or advertisements based on your interests on the website or to manage our advertising. These cookies collect information about your activities on our website and other websites to provide you with targeted advertising.	We will only place advertising cookies, and process any related data, if you accept these cookies and provide your consent to the related processing of your Personal Data. This is a secondary processing purpose.

You have the ability to accept or decline non-essential cookies via the settings in our Cookie Tool. You can also withdraw your consent and disable non-essential types of cookies at any time via our Cookie Tool. You may also be able to modify your browser settings to decline non-essential cookies. See the "How can I change my preferences regarding the processing of my Personal Data and/or the use of cookies?" section for more information. If you choose to decline non-essential cookies, you may not be able to fully experience the interactive features of our website or receive some of our services.

How can I change my preferences regarding the processing of my Personal Data and/or the use of cookies?

If you wish to unsubscribe or discontinue receiving communications from us (including newsletters and other materials) please use the unsubscribe facility/preference center link provided here.

To manage your cookie preferences, such as to accept or refuse certain types of cookies and to provide or withdraw your related consent to the processing of your Personal Data, you can use the options and tools made available to you by your web browser.

• Your Web Browser: You can configure your browser so that it always rejects certain types of cookies or asks you each time whether you want to accept them or not. Your browser documentation includes instructions explaining how to enable, disable or delete cookies at the browser level (usually located within the “Help”, “Tools” or “Edit” facility).

If you manage cookies at the individual browser level, please remember that Essential cookies will remain and cannot be turned off. Please also understand that choosing to reject Functional cookies may reduce the performance and functionality of our website.

External Links

Ciena may provide links to external websites for your convenience. The links and information those websites contain are not monitored by us, and those websites are subject to their own privacy policies. We are not responsible for the content, accuracy, or practices of those websites, nor do we endorse those websites or content provided thereon.

What rights do I have under data protection laws?

Depending on where you are located and applicable law, you have the right:

• to obtain information about how we process your Personal Data and to obtain a copy of your Personal Data (right of access);
• to have any inaccurate Personal Data corrected and, taking into account the purposes of the processing, have incomplete Personal Data completed (right of rectification); 
• to have your Personal Data deleted, if one of the grounds for deletion applies (this is also known as the right to erasure; "right to be forgotten"; or right to cancellation depending on jurisdiction);
• to request the restriction of processing of your Personal Data if the legal requirements are met (right to restriction of processing or right to limit use and disclosure of Personal Data to primary processing purposes);
• if the legal requirements are met, to receive Personal Data which you have provided to us in a structured, commonly used, and machine-readable format and to transmit such Personal Data to another controller without restriction by us or, where technically feasible, to have such data transmitted directly by us to another controller (right to data portability);
• if applicable, not to be subject to a decision based solely on automated processing which produces legal effects concerning you or significantly affects you in a similar way, if the legal requirements are not met (Ciena does not engage in such automated decision making);
• to object, in accordance with the statutory provisions, to the processing of your data, which is necessary for the purposes of our legitimate interests, on grounds relating to your particular situation (right to object);
• to object to the processing of your Personal Data by us for direct marketing purposes, if applicable; and
• if we are processing your Personal Data on the basis of your consent, to withdraw your consent at any time. The withdrawal of your consent does not affect the lawfulness of the processing of your Personal Data prior to your withdrawal of consent.
• You may have the right to contact your local data protection authority. If you would like more information. For more information on how to contact your local data protection authority, please email us at privacy@ciena.com or contact us through the “How to Contact Us” details below.

How can I exercise my rights?

You can exercise your rights by contacting us 1) filling out and submitting this form or 2) contact us through the “How to Contact Us” details below.

We will verify and respond to your request consistent with applicable law. We may need to request additional Personal Information from you in order to verify your identity and protect against fraudulent requests.

If you make a request to delete, we may ask you to confirm your request before we delete your Personal Information.

Authorized agents may also submit requests using the contact information above.

Additional Information Regarding the EEA

If you are in the European Economic Area (“EEA”), you also have the right to lodge a complaint with the competent data protection supervisory authority, in the Member State of your habitual residence, place of work, or of an alleged infringement of the GDPR, and you may also have this right in other countries.

Additional Information Regarding California

If you are a California resident, please refer to the “Additional Information Regarding California” supplement for information on the requests you may make under the California Consumer Privacy Act (CCPA).

How do I learn about changes to this Notice?

We periodically review this Privacy Notice and may make changes to it. When changes are made, we will post the current version to this website with a new effective date listed below. By using this website, you signify your agreement with the terms of this Privacy Notice. We will inform you of material changes to this Privacy Notice as required by applicable law.

If we decide to process your Personal Data for purposes in a way that is materially different from what we stated in our Privacy Notice at the time we collected that information from you, we will inform you and, where required under applicable law, give you a choice about the intended processing by appropriate means, which may include giving you an opportunity to opt-out.

List of Ciena Entities and Registered office address

As part of our ongoing commitment to legal transparency and corporate governance, we provide the official details of our legal entities and their registered office locations. List of Ciena Entities and Registered office address can be found here.

How to Contact Us

If you have any questions about this Privacy Notice, or the related processing of your Personal Data or to exercise your rights, please e-mail or mail the appropriate contact below:

You can contact Ciena at:
Ciena Corporation
ATTN: Senior Corporate Counsel, Information Security and Privacy
7035 Ridge Road
Hanover, Maryland 21076
United States
Phone Number: +1 800-898-1987
E-mail: privacy@ciena.com

For Marketing Inquiries:
Ciena Corporation
ATTN: Director of Digital Marketing
7035 Ridge Road
Hanover, Maryland 21076
United States
E-mail: privacy@ciena.com

REGION SPECIFIC DATA PROTECTION OFFICERS

For queries from data subjects in Germany:
Thomas Schmitz
Data Protection Officer
Ciena Limited
6th Floor, Main Airport Center
Unterschweinstiege 10
D-60549 Frankfurt am Main
Deutschland
E-mail: tschmitz@ciena.com

For queries from data subjects in Brazil:
Leonardo Albuquerque
Data Protection Officer
Ciena Communications
Edifício Morumbi Golden Tower,
Vila São Francisco, Zip Code 04711-130 in the City of São Paulo,
State of São Paulo
E-mail: lalbuque@ciena.com