Effective Date: March 29, 2016

Blue Coat Systems, Inc. ("Blue Coat" or "we") recognizes that the European Community has established a data protection regime pursuant to Directive 95/46/EC, which applies to the European Economic Area ("EEA") and that Switzerland ("CH") has also established a data protection regime which applies to CH that restricts companies in the EEA/CH from transferring personal data about individuals in the EEA/CH to the United States.  Blue Coat adheres to the Safe Harbor Privacy Principles published by US Department of Commerce ("Safe Harbor Principles") with respect to personal data about individuals in the EEA/CH that we receive from our subsidiaries, customers and other business partners or through our home page at www.bluecoat.com (“EEA/CH Data”).  More information on the Safe Harbor Principles and Blue Coat's scope of participation is available at http://export.gov/safeharbor/.

Scope of this Notice

This Notice does not apply to employees of Blue Coat or our subsidiaries; this Notice addresses other data subjects residing in the EEA and CH (collectively, "EEA/CH Persons") whose data we may receive from one of our subsidiaries, customers, suppliers or other business partners in the EEA/CH. We have issued a separate Safe Harbor Notice for Blue Coat Employees in the EEA/CH.

Categories of EEA Data

We receive EEA/CH Data related to individual independent contractors, and employees and individual representatives of Blue Coat’s corporate customers, prospective corporate customers, resellers, suppliers and other corporate business partners as well as individual website visitors, K9 product users and prospects. Such EEA/CH Data includes, without limitation, names, addresses, work phone numbers, work email addresses, and any other personal data that are provided to Blue Coat in order to manage our business and business relationships.

We also provide data processing services to affiliated and unaffiliated entities.  We process information that such entities instruct us to process, on their behalf and subject to their direction. When we receive EEA/CH Data from another company in the EEA/CH for processing, the categories of data sent and the purposes of processing depend on such other company (the data controller) and on the relationship the data controller has with the relevant data subjects.


We collect and use EEA/CH Data for purposes of providing products and services to our customers and prospective customers, communicating with corporate business partners about business matters, processing EEA/CH Data on behalf of corporate customers, providing information on our services, and conducting related tasks for legitimate business purposes. With respect to marketing, EEA/CH Persons may opt-out of receiving marketing communications from Blue Coat by following opt-out instructions that are contained in each marketing email. We will offer EEA/CH Persons the opportunity to choose whether we may use EEA/CH Data for a purpose that is incompatible with the purpose for which the data was originally collected or subsequently authorized by the individual.  EEA/CH Persons may contact us regarding our use of EEA/CH data.


We share EEA/CH Data with our subsidiaries, affiliates and contractors, who process EEA/CH Data on behalf of Blue Coat (and/or its subsidiaries). We also provide information to our channel partners, such as distributors and resellers, to fulfill product and information requests, and to provide customers and prospective customers with information about Blue Coat and its products and services. We also share EEA/CH Data with other third parties for the purposes for which we receive the EEA/CH Data (e.g., performance of contractual obligations and rights), and we may also disclose EEA/CH Data where we are legally required to disclose (e.g., under statutes, contracts or otherwise) or where the disclosure is permitted by law or the Safe Harbor Principles and we have a legitimate business interest in such disclosure. EEA/CH Persons may opt out of disclosures to entities other than agents unless the disclosure is required by law, but such an opt-out request may make it difficult or impossible for us to provide requested services.

Access and Review

If you are an EEA/CH Person about whom we hold EEA/CH Data, you may request access to, and the opportunity to update, correct or delete, such EEA/CH Data. To submit such requests or raise any other questions, please contact the business that provided your EEA/CH Data to us. You can also contact our Safe Harbor Contact. We reserve the right to take appropriate steps to authenticate an applicant's identity, to charge an adequate fee before providing access and to deny requests, except as required by the Safe Harbor Principles.