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HEWLETT PACKARD ENTERPRISE PRIVACY STATEMENT
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This Privacy Statement is effective as of December 21, 2022.
Hewlett Packard Enterprise Company and its subsidiaries (HPE or We) respect your
privacy. This Privacy Statement informs you about our privacy practices
including details of the personal data we collect, use, disclose and transfer as
well as choices you can make and rights you can exercise in relation to your
personal data. This Privacy Statement is available from a link on the footer of
every HPE web page.
HPE respects and takes into account the major privacy principles and frameworks
around the world, including, but not limited to, the OECD Guidelines on the
Protection of Privacy and Transborder Flows, the EU General Data Protection
Regulation 2016/679 (GDPR), and the APEC Privacy Framework. HPE’s privacy
practices described in this Privacy Statement also comply with the APEC Cross
Border Privacy Rules (CBPR) System.
This Privacy Statement applies to all HPE-owned websites, domains, services,
applications, and products, and those of our subsidiaries, except that a privacy
policy or statement specific to a particular HPE program, product or service may
supersede or be supplemented by this Privacy Statement.
* 1. HOW WE USE PERSONAL DATA
We collect personal data only if required to provide our products or
services, fulfil our legitimate business purposes and/or comply with
applicable laws and regulations. Depending on your relationship with HPE we
collect and process your personal data as follows:
* HPE products and services: contact details, login credentials and
interactions with our digital assets and content, for the following main
purposes: account creation and management; entering into and performing
agreements with you or your organization; providing support and tools to
activate licenses and request support; managing and fulfilling orders;
deploying and delivering products and services; conducting quality
controls; managing returns of defective media; operating and providing
access to customer portals, hosted management services and mobile
applications; consulting; notifications of contract expiry and renewal
options; developing and improving our products and services and ensuring
compliance with regulatory requirements.
* HPE Financial Services: contact details, driving license, passport,
identity card details, records of good standing and other information as
may be relevant (e.g., information from publicly available resources) for
the following main purposes: providing lease, loan, and other financial
services; conducting anti-money laundering and other regulatory checks;
initiating credit approval process and facilitating the purchase and
resale of equipment.
* Sales and marketing: contact details, identification information,
information required to purchase our products and services online,
profile, role and preferences, login credentials, digital activity
information and other information as may be relevant (e.g. information
from publicly available sources) for the following main purposes: sales
and marketing; advertising; creating and delivering targeted adverts and
offers; conducting marketing campaigns; managing contacts and preferences;
generating leads and opportunities; managing lead generation activities;
sales engagement activities; organizing and managing events, webinars,
virtual meetings; and engaging in social media interactions.
* Online Data Collection Tools: digital activity information for the
following main purposes: enabling efficient use of our websites, mobile
applications, products, and services; collecting statistics to optimize
the functionality of our websites, mobile applications, products and
services; improving user experience and delivering content tailored to
their interests; and improving marketing and advertising campaigns.
* Online forums and surveys: contact details, login credentials, comments,
and feedback for the following main purposes: engaging with partners and
suppliers in online forums; conducting customer satisfaction and
engagement surveys.
* Partner and supplier programs: contact details for the following main
purposes: managing relations with partners and suppliers; engaging and
delivering products and services to customers in which case we may receive
personal data directly from you or from our partners.
* Training and education: contact details for the main purpose of conducting
trainings and managing education programs for customers, partners, and
suppliers.
* Due diligence screening: contact details and other information as may be
relevant (e.g., information from publicly available sources) for the
following main purposes: conducting anticorruption due diligence on third
parties and conducting required investigations, in compliance with
applicable laws.
* Brand-protection programs: contact details, login credentials and other
relevant information (e.g. information from publicly available sources)
for the main purpose of conducting investigations into HPE product-related
fraud, compliance, grey marketing, theft and/or counterfeit.
* Security and authentication: contact details, identification information
and CCTV footage for the following main purposes: ensuring safety and
security of HPE staff and premises; login credentials, protecting HPE’s
network and other digital assets; providing access to restricted areas and
information assets and protecting personal data from unauthorized
access.
* Whistleblowing: contact details and information about alleged misconducts
for the main purpose of detecting, preventing, and investigating
misconduct by HPE staff, customers, partners, and suppliers.
* Enquiries and complaints: contact details and information included in
enquires and complaints for the main purpose of addressing and resolving
enquiries and complaints.
* Recruitment: contact details for the purpose of sending job alert
subscriptions managed by HPE or our recruitment partners; contact details
and information made publicly available on professional social networks
such as LinkedIn for the purpose of identifying and contacting potential
job candidates. For information regarding personal data processed in
connection with a job application or job offer, please refer to our
Recruitment Notice.
* Student virtual work experience programs through the Forage platform (for
students 18 and older): profile information (e.g., contact details,
photo) education (e.g., school, degree, stage of degree), work preferences
(e.g., location, type of work, skills), country and inferences.
* Mergers and acquisitions: contact details and information included in
enquires and pulse surveys for the following main purposes: addressing
queries and shaping and refining the on-boarding and integration
experience.
Non-HPE web sites and social media features. HPE sites or services may
provide links to third-party applications, products, services or websites for
your convenience or information. We may also provide social media features
that enable you to share information with your social networks and to
interact with HPE on various social media sites. HPE does not control third
party sites, or their privacy practices and we do not endorse or make any
representations about third party sites. The personal data you choose to
provide to or that is collected or shared by these third parties is not
covered by this Privacy Statement. We encourage you to review the privacy
policy of any site you interact with before allowing the collection and use
of your personal data.
* 2. HOW WE SHARE PERSONAL DATA
HPE does not sell, rent, or lease personal data to others except as described
in this Privacy Statement. We may share and/or disclose your personal data as
follows:
Disclosure within the HPE group of companies. HPE has its headquarters in the
United States of America and operates worldwide. HPE may disclose your
personal data as necessary within the HPE group of companies in connection
with how we use your personal data.
Disclosure to third parties. HPE retains suppliers and service providers to
manage or support its business operations, provide professional services,
deliver products, services, and customer solutions and to assist HPE with
marketing and sales communication initiatives. Those third parties may
receive and process your personal data under appropriate instructions, as
necessary to support and facilitate how we use your personal data. Suppliers
and service providers are required by contract to keep confidential and
secure the information they process on behalf of HPE and may not use it for
any purpose other than to carry out the services they are performing for
HPE.
Where HPE engages with partners, resellers and/or distributors as part of its
business operations, HPE may disclose your personal data to them in order to
facilitate sales and delivery of its products and services. Partners,
resellers and/or distributors are required by contract to keep confidential
and secure the information received from HPE and may use it only for the said
purposes, unless otherwise authorized by you or applicable laws and
regulations.
Except as described in this Privacy Statement, HPE will not share your
personal data with third parties without your permission, unless to: (i)
respond to duly authorized information requests of police and governmental
authorities; (ii) comply with law, regulation, subpoena, or court order;
(iii) enforce/protect the rights and properties of HPE or its subsidiaries;
or (iv) protect the rights or personal safety of HPE, our employees, and
third parties on or using HPE property when allowed and in each case in
accordance with applicable law.
Circumstances may arise where, whether for strategic or other business
reasons, HPE decides to sell, buy, merge, or otherwise reorganize businesses
in some countries. Such a transaction may involve the disclosure of personal
data to prospective or actual purchasers, or the receipt of it from sellers.
It is HPE’s practice to seek appropriate contractual protection for personal
data in these types of transactions.
* 3. HOW WE TRANSFER PERSONAL DATA INTERNATIONALLY
HPE may transfer your personal data as necessary within the HPE group of
companies and to other third parties. The recipients may be located in
countries which do not provide the same level of data protection as the
country in which you are located. HPE will take steps to ensure personal data
we transfer is adequately protected as required by applicable data protection
laws. Where required by local law, we will request your consent to transfer
your personal data.
Transfers within HPE group of companies. HPE has an intra-company agreement
on the transfer and processing of personal data within the HPE group of
companies. This agreement also forms the basis of HPE’s Binding Corporate
Rules for Controller which have been approved by the Data Protection
Regulators in Europe and some other countries. The BCRs allow HPE to ensure
that personal data transferred internationally within the HPE group is
adequately protected in accordance with applicable data protection laws. If
you would like to learn more about our BCRs and the countries that have
approved them, please click here.
HPE’s privacy practices described in this Privacy Statement comply with the
APEC Cross Border Privacy Rules (CBPR) System, including transparency,
accountability, and choice regarding the collection and use of personal data.
The CBPR system provides a framework for organizations to ensure protection
of personal data transferred among participating APEC economies. More
information about the CBPR framework can be found here. The CBPR
certification does not cover information that may be collected through
downloadable software on third party platforms. If you have an unresolved
privacy or data use concern related to HPE’s APEC Certification that we have
not addressed satisfactory, please contact our U.S. based third party dispute
resolution here.
Transfers to third parties. With respect to transfers to third parties
located in countries which do not provide an adequate level of data
protection, HPE will take appropriate safeguards such as signing EU Standard
Contractual Clauses, or other model clauses approved by a data protection
authority, with the recipient, relying on approved codes of conduct or
certification mechanisms adopted by the recipient or binding and enforceable
commitments of the recipient. If you would like to receive more information
about the appropriate safeguards and/or receive a copy of the relevant
mechanism for your review, please contact the HPE Privacy Office.
* 4. HOW TO MANAGE COMMUNICATIONS AND PREFERENCES
HPE may provide you with information that complements our products and
services and/or communications about our new products, services and offers.
If you or your organization purchased our products or services, you may
receive alerts, software updates or responses to support requests that are
part of our products and services. If you choose to receive HPE
communications, you may also choose to subscribe to receive specific
newsletters and publications. In some cases, you may also choose whether to
receive the information and communication by email, telephone, or post.
Manage communication choices. You can change your choices and preferences
relating to HPE communications by:
* Accessing online - Get connected with updates from HPE, indicating or
changing your preferences and providing your email address;
* Accessing HPE Passport, a single-login service that lets you register with
HPE enabled websites using a single user identifier and password of your
choice. HPE Passport allows you to set your privacy preferences for email
and telephone contact from HPE.
Unsubscribe from communications. In the event you no longer wish to receive
HPE communications, you can unsubscribe from such communications by:
* Following opt-out or unsubscribe link and/or instructions included in each
email subscription communication;
* Accessing the Communication preference center, selecting “Unsubscribe” and
providing your email address;
* Indicating to the caller that you do not wish receive calls from HPE
anymore.
In the event your opt-out or unsubscribe request has not been resolved in a
timely manner, please contact the HPE Privacy Office with details of your
name, contact information, and description of the communications you no
longer wish to receive from HPE.
Please note that these options do not apply to communications relating to the
administration of orders, contracts, support, product safety warnings, or
other administrative and transactional notices, where the primary purpose of
these communications is not promotional in nature.
* 5. AUTOMATIC DATA COLLECTION TOOLS
How HPE uses Automatic Data Collection Tools. HPE web sites and applications
use cookies, web beacons, device identifiers, IP addresses, and other similar
technologies (collectively, Automatic Data Collection Tools), to provide and
secure HPE web sites and applications, remember log-in details, collect
statistics to optimize functionality, collect information on user activity in
response to email communications and related to white papers, documents and
other assets made available through our web sites and applications, and more
generally to improve your user experience and deliver content tailored to
your interests. Some of these Automatic Data Collection Tools are strictly
necessary to provide HPE web sites and applications, while others are used to
understand, tailor and improve HPE web sites and applications.
HPE also allows third-party advertising companies to use Automatic Data
Collection Tools on our web sites and applications in order to understand how
you interact with our web sites and applications, to optimize our
advertisements and marketing and to serve advertisements specific to your
interests on other web sites and applications you may visit or use. HPE may
use retargeting and behavioral advertising technologies, a set of practices
collectively referred to as “Interest Based Advertising” to tailor those
advertisements to your perceived interests based on information collected
through Automatic Data Collection Tools.
Automatic Data Collection Tools may also be used when you share information
using a social media sharing button on our websites. The social network will
record that you have done this and may use this information to send you
targeted advertisements. The types of Automatic Data Collection Tools used by
these companies and how they use the information is governed by their privacy
policies.
When you enter your contact details on a web form on an hpe.com site, in
order to subscribe to a service, download a white paper or request
information about HPE’s products and services, your contact details may be
stored in a cookie on your device. This information is then accessed on
subsequent visits to hpe.com sites, allowing us to track and record the sites
you have visited and the links you have clicked, in order to better
personalize your on-line experience, and future HPE communications.
If you choose to receive marketing emails or newsletters from HPE, we may
track whether you’ve opened those messages and whether you’ve clicked on
links contained within those messages, through the use of web beacons and
personalized URLs embedded in these communications. This allows HPE to better
personalize future communications and limit these communications to subjects
that are of interest to you.
Choices Regarding Automatic Data Collection & Online Tracking. While HPE web
sites at this time do not recognize automated browser signals regarding
tracking mechanisms, such as "do not track" instructions, you can generally
express your privacy preferences regarding the use of most Automatic Data
Collection Tools through your web browser or device settings. You can set
your browser in most instances to notify you before you receive certain
Automatic Data Collection Tools, giving you the chance to decide whether to
accept them or not. You can also generally set your browser or device to turn
off certain Automatic Data Collection Tools. If you are accessing our web
sites or applications in countries of the European Union (EU), or countries
where the EU regulations apply, you are given the choice to accept or refuse
our use of non-essential cookies (as described in the section titled ‘How HPE
uses Automatic Data Collection Tools’ above) through a ‘cookie preference’
banner that appears on our web pages. The banner stops being displayed when
you have made your choice, but it can be brought back on display by selecting
the ‘Cookies’ link on the footer of every HPE web page. California residents
may have additional choices as described in the Specific Information for
California Residents page.
Since these Automatic Data Collection Tools allow you to take advantage of
some of our web sites' and applications’ features, we recommend that you
leave them turned on. If you block, turn off or otherwise reject certain
Automatic Data Collection Tools, some web pages or user experiences may not
display properly or you will not be able, for instance, to add items to your
shopping cart, proceed to checkout, or use any web site services that require
you to sign in.
HPE participates in the Digital Advertising Alliance (DAA and DAAC)
self-regulatory program for digital online advertising (see
http://www.aboutads.info/ or http://youradchoices.com/ in the US and
http://youradchoices.ca/ in Canada). HPE advertisements that are targeted to
you will be identified with the Ad Choices icon . If you do not want this
information to be used for serving you targeted advertisements on web sites
you may visit, you can click here to opt-out. For applications, please update
your device settings. This will allow you to access and update your
preferences. Please note that this does not opt you out of being served
non-targeted advertising.
Some of our websites use Google Analytics cookies. Information collected by
Google Analytics cookies will be transmitted to and stored by Google on
servers in the United States of America in accordance with its privacy
practices. To see an overview of privacy at Google and how this applies to
Google Analytics, visit https://www.google.com/policies/privacy/. You may opt
out of tracking by Google Analytics by visiting
https://tools.google.com/dlpage/gaoptout.
In the USA and Canada, we participate in the Adobe Marketing Cloud Device
Co-op. This helps us understand how you use our websites and apps across all
the devices you use and deliver tailored promotions based on your interests
to those devices. You can learn more about how Adobe does this, and how to
opt-out, at https://www.adobe.com/privacy/opt-out.html .
* 6. HOW WE KEEP PERSONAL DATA SECURE
HPE takes seriously the trust you place in us to protect your personal data.
In order to protect your personal data from loss, or unauthorized use, access
or disclosure, HPE utilizes reasonable and appropriate physical, technical,
and administrative procedures to safeguard the information we collect and
process. All systems used to support HPE’s business are governed by HPE’s
corporate Cyber Security policies, which are built upon industry standards
and best practices like the International Organization for Standardization
(ISO) 27001 family of standards and National Institute of Standards and
Technology (NIST) standards.
When collecting or transferring sensitive information we use a variety of
additional security technologies and procedures to help protect your personal
data from unauthorized access, use, or disclosure. The personal data you
provide us is stored on computer systems locked in controlled facilities
which have limited access. Access to your information is restricted to HPE
employees or authorized third parties who need to know that information in
order to process it for us, and who are subject to strict confidentiality
obligations. When we transmit sensitive information over the internet, we
protect it through the use of encryption, such as the Transport Layer
Security (TLS), Internet Protocol Security (IPSec), or Secure Socket Layer
(SSL).
* 7. HOW LONG WE KEEP PERSONAL DATA
Typically, we keep personal data for the length of any contractual
relationship and, to the extent permitted by applicable laws, after the end
of that relationship for as long as necessary to perform purposes set out in
this Privacy Statement, to protect HPE from legal claims and administer our
business. When we no longer need to use personal data, we will delete it from
our systems and records or take steps to anonymize the data unless we need to
keep it longer to comply with a legal or regulatory obligation. If you would
like to receive more information about our data retention policies, please
contact the HPE Privacy Office.
* 8. HOW TO EXERCISE YOUR RIGHTS AND ADDITIONAL INFORMATION
Our privacy practices are aligned with the requirements of Europe’s General
Data Protection Regulation (GDPR) and the applicable data protection laws of
other countries in which we operate. We respect the rights individuals have
in relation to their personal data under these laws. Depending on what data
protection laws you are subject to, this additional information may be
relevant and applicable to you.
Data controllers. Companies from the HPE group of companies may act as data
controllers in relation to your personal data for the processing of personal
data described in this Privacy Statement. You can find the up-to-date list of
the HPE group of companies by clicking here. If you would like to receive
more information about which HPE entity acts as data controller for your
personal data, please contact the HPE Privacy Office.
Chief Privacy Officer. HPE has appointed a Chief Privacy Officer (CPO),
Margaret Gloeckle, who also acts as the local Data Protection Officer in many
countries we operate in. We also have local Data Protection Officers in
certain countries, such as Germany and Poland. You can contact the CPO/DPO
by completing the form available here or in writing to:
Hewlett Packard Enterprise
Office of Legal & Administrative Affairs – ATTENTION PRIVACY OFFICE
1701 E Mossy Oaks Rd
Spring, TX 77389
Legal basis to process personal data. We process your personal data on the
following legal bases:
* Legitimate Interest. We may process your personal data as required to
pursue our legitimate business interests (provided this is not overridden
by interests or rights of relevant individuals). In particular, to manage,
develop and improve our products and services; support our customers and
sales operations; protect our staff and assets; communicate information
that supplements our products and services and ensure compliance with laws
and regulations.
* Performance of an agreement. We may process your personal data to enter
into or fulfil agreements with your or your organizations, including to
deliver and manage our products and services and allow our customers to
use our products, services and supporting tools.
* Legal obligation. We may process your personal data to comply with
applicable laws and regulations, establish or exercise our legal rights.
For example, in connection with legal claims, compliance, regulatory and
investigative purposes.
* Consent. We may process your personal data where you have provided your
consent. In particular, where we cannot rely on an alternative legal basis
or we are required by law to ask for your consent in the context of some
of our sales and marketing activities, online data collection tools, or
surveys. At any time, you have a right to withdraw your consent by
changing your communication choices, unsubscribing from HPE communications
or contacting the HPE Privacy Office.
Your rights in relation to your personal data. Depending on what data
protection laws you are subject to, you may have the right to:
* Request confirmation of the processing of your data, access or obtain
copies of personal data HPE processes about you;
* Rectify your personal data, if inaccurate or incomplete;
* Delete or anonymize your personal data, unless an exception applies. For
instance, we may need to keep your personal data to comply with legal
obligation;
* Restrict the processing of your personal data, in certain circumstances.
For instance, if you contest accuracy of your personal data you may
request that we restrict processing of your personal data for the time
enabling us to verify the accuracy of your personal data;
* Request to limit certain uses and disclosures of your sensitive personal
information;
* Opt-out of the sharing of your personal data for purposes of behavioral
advertising;
* Data portability, in certain circumstances. For instance, in the EU you
may request us to transmit some of your personal data to another
organization if the processing is based on your consent or a contract;
* Object to processing of your personal data, in certain circumstances. For
instance, in the EU you may object to direct marketing including use of
your personal data for profiling for direct marketing or where we process
your personal data because we have legitimate interest in doing so.
* Obtain information about the entities with which HPE has shared your
personal data;
* Withdraw consent to the processing of your personal data.
California residents may opt-out from the “sale” of personal information,
i.e. our use of optional Automatic Data Collection Tools, by visiting the “Do
Not Sell My Personal Information” page.
These rights may be limited in some situations such as where HPE can
demonstrate that HPE has a legal requirement or legitimate interest to
process your personal data or can legitimately apply an exemption to the
exercise of a right under applicable law.
To view and update the personal data you provided directly to HPE, you can
return to the web page where you originally submitted your data and follow
the instructions on that web page, using HPE Passport where enabled.
Otherwise, please contact us by completing the form available here or by
writing to the CPO at the address indicated in the Chief Privacy Officer
section above. To protect your privacy and security, we will take reasonable
steps to verify your identity before processing your request. Complaint with
a supervisory authority. If you consider that the processing of your personal
data infringes applicable data protection laws, you may have a right to lodge
a complaint with a supervisory authority in the country where you live, or
work, or where you consider that data protection rules have been breached.
Your rights under HPE Binding Corporate Rules. You may have additional rights
under our BCRs in Europe and other countries that have approved our BCRs. For
example, as a third party beneficiary, where you believe your personal data
has been transferred by an EU HPE company to an HPE company located outside
the EU and processed by that company in breach of the BCR, you may have a
right to:
* Lodge a complaint with the HPE company which transferred your personal
data outside the EU ;
* Lodge a complaint with a supervisory authority located in the same country
as the HPE company which transferred your data outside the EU;
* Bring a court action against the HPE company which transferred your
personal data outside the EU.
If HPE processes your personal data on behalf of an HPE customer, then we
will, in the first instance, refer your complaint to our customer to handle.
For further information, please visit the HPE BCR web page available here.
* 9. HOW TO CONTACT US
If you have any questions about our Privacy Statement, any concerns or
complaint regarding our collection and use of your personal data or wish to
report a possible breach of your privacy, please contact the HPE Privacy
Office by email or write to our worldwide corporate headquarters address
below.
We will treat your requests and complaints confidentially. Our representative
will contact you within a reasonable time after receipt of your complaint to
address your concerns and outline options regarding how they may be resolved.
We will aim to ensure that your complaint is resolved in timely and
appropriate manner.
World Wide Corporate Headquarters
Hewlett Packard Enterprise
Office of Legal & Administrative Affairs
ATTENTION -PRIVACY OFFICE
1701 E Mossy Oaks
Rd
Spring, TX
77389
United States
* 10. CHANGES TO THIS PRIVACY STATEMENT
If we modify this Privacy Statement, we will publish a revised version with
an updated revision date. The privacy link on the footer of every HPE web
page will then point to that new version.
* 11. LOCAL LANGUAGE VERSIONS OF THIS PRIVACY STATEMENT AND COUNTRY SUPPLEMENTS
Please click here to access translations of this Privacy Statement and any
country specific supplements.
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