General EEA Safe Harbor Notice
Effective September 24, 2008
Scope of Safe Harbor Certification
Dolby Laboratories, Inc. (hereinafter “Dolby” 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 restricts companies in the EEA in transferring personal data about individuals in the EEA to the United States, unless there is “adequate protection” for such personal data when it is received in the United States. Dolby also recognizes that Switzerland has established a similar regime through the Swiss Federal Act on Data Protection (“FADP”). To create such “adequate protection” and to overcome the restriction on international data transfers established by the Directive and FADP, Dolby complies with the U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland received by Dolby from subsidiaries, customers, suppliers and other businesses in the EEA and Switzerland. Dolby has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement (“Safe Harbor Principles”). For ease of reference throughout this Notice, the term “EEA” shall include Switzerland. Dolby’s Safe Harbor Certification does not extend to data that Dolby receives directly through www.dolby.com or other websites (information on Dolby’s practices regarding data received through websites is contained in the Website Privacy Statement). More information on the Safe Harbor Principles and Dolby’s scope of participation is available at http://www.export.gov/safeharbor/.
Scope of this Notice
Dolby has issued a separate Safe Harbor Notice for Employees in the EEA and this Notice does not apply to employees of Dolby; this Notice addresses other data subjects residing in the EEA (“EEA Persons”) whose data Dolby may receive from one of its subsidiaries, customers, suppliers or other businesses in the EEA, e.g., customers’ procurement managers, suppliers’ sales representatives, individual independent contractors, etc.
Categories of EEA Data
Dolby sells entertainment products and technologies largely to businesses and rarely directly to consumers. Thus, Dolby mainly receives information related to business entities from the EEA. Dolby does also receive contact information related to individual representatives of businesses with whom Dolby is dealing, including, without limitation, names, addresses, work phone numbers and work email addresses (collectively “EEA Data”). Some EEA Data covered by this Notice is provided to Dolby by another company in the EEA (e.g., a supplier to Dolby), and therefore the categories of data provided and the purposes of collecting such data often depend on such other company, with whom the EEA Persons typically have a closer employment, business or other relationship (and which therefore, can provide additional information on the data shared with us).
Dolby collects and uses EEA Data for purposes of communicating with past, current and prospective customers about business matters, transmitting marketing emails and performing other marketing activities, and conducting related tasks for legitimate business purposes.
Dolby shares EEA Data with affiliates and contractors, which process EEA Data on behalf of Dolby. Dolby also shares EEA Data with other third parties for the purposes for which Dolby receives the EEA Data (e.g., performance of contractual obligations) and as required or permitted by law.
With respect to marketing emails, EEA Persons may opt-out of receiving further email marketing communications from Dolby by sending an email to [unsubscribe at dolby dot com], or by following opt-out instructions that are contained in marketing emails. EEA Persons may also send an email to this address to ask to opt-out of disclosures to third parties, but such a limitation on data sharing may make it difficult or impossible for Dolby to provide the requested services. Notwithstanding other statements in this General EEA Safe Harbor Notice, Dolby may disclose EEA Data where it is legally required to disclose (e.g., under statutes, contracts or otherwise) or the disclosure is permitted by law and Dolby has a legitimate business interest in such disclosure.
Access and Review
EEA Persons whose EEA Data Dolby holds may request access to, and the opportunity to update, correct or delete some or all of the EEA Data that Dolby holds about them. To submit such requests or raise any other questions, please contact the Dolby Safe Harbor Contact as described below. Dolby reserves the right to take appropriate steps to authenticate an applicant’s identity, charge an adequate fee before providing access and deny requests, except as required by the Safe Harbor Principles.
Safe Harbor Contact
If you have questions, please contact the Dolby Safe Harbor Privacy Contact at [privacy (at) dolby (dot) com].
If you have a comment or concern that cannot be resolved with Dolby directly, you may contact the competent local data protection authority in your EEA Member State.