Safecore’s Privacy Policy

YOUR PRIVACY IS IMPORTANT TO SAFECORE.

This Policy Adopted By: Safecore, and partners which are part of the Safecore service system, and other entities which directly or indirectly are controlled by Safecore (each, an Affiliate, with Safecore and its Affiliates being collectively referred to as Safecore).

This Privacy Policy provides you information about what type of information is gathered and tracked by Safecore, how the information is used, and with whom the information is shared. This policy applies to information obtain on our website as well as any personal information which is hosted or archived through any of our service offerings.

Introduction

Safecore is in the business of managing applications and infrastructure to host or archive information for our global clients who are in many different industries. Safecore is committed to respecting your privacy, and we have created this privacy policy (the “Privacy Policy”) to give you a clear understanding of how our Web Site operates, and how personally identifiable information is handled. We have a clear Privacy Policy: we collect no personally identifiable information through this web site unless you voluntarily supply it. We define personally identifiable information as information that can uniquely identify an individual person.

By using our Web Site, you consent to the collection and use of information as set forth in this Privacy Policy.

The information we collect.

Safecore collects two types of information about users of this Web site; "Personal Information" (including, but not limited to, your name, address, telephone number and e-mail address) and non-personally identifiable and anonymous "Aggregate Information" (such as information about how many users log onto our Web site). Unless you provide it to us voluntarily or the information is collected via cookies in the manner described in this policy, Safecore does not collect Personal Information in connection with your use of this Web site.

Please read this policy carefully to learn how you can verify the accuracy of any Personal Information we have concerning you and how you can request that Safecore delete or update your Personal Information.

In order to accommodate your information request, we ask you to submit your name, title, company affiliation (if any), mailing address, telephone number and e-mail address.

How we use the information we collect.

We will use the information you submit (a) to answer your specific inquiry; (b) at your option, to send you additional materials relating to Safecore and services that may be of interest to you; (c) in the administration of the Web site; and (d) as otherwise described in this policy.

Safecore may, from time to time, share your Personal Information with marketing consultants, in which case, the consultants shall be prohibited from using your Personal Information except with respect to assisting Safecore in the sale of its services and products, and the consultants shall also be required to comply with the terms of this policy.

How we use cookies and other technologies.

General - When you visit this site, information about your browser type, operating system, IP address, and the domain name from which you access this site (e.g., google.com) is collected. In addition, we may collect information about your browsing behavior, such as the number of times you have visited the site, the date you visited the site, and the amount of time you spent viewing the site. In addition, Safecore may track your response to Safecore's advertisements, e-mails and site content, determine your ability to receive HTML-based e-mail messages, learn how many users open an e-mail and allow our service providers to compile aggregated statistics about an e-mail campaign for Safecore. This information is used solely for our internal purposes in managing the site and improving its functionality, as well as to assist us in better targeting interactive advertising, thereby enhancing customer support and site usability. The collection of such information is subject to the terms set forth in this policy.

The information we disclose.

Subject to applicable law, we disclose and share your personal information:

• Among Safecore and its Affiliates;
• To unaffiliated third parties that are under contract to perform services for or on behalf of Safecore (Service Providers), and are required to uphold and maintain policies with respect to privacy and the treatment of your Personal Information;
• To a third party in connection with a proposed or actual sale, merger, or transfer of all or a portion of a business or division; and
• To other persons as permitted or required by applicable law or regulation.

Any access to such information will be limited to the purpose for which such information was provided to us or our Service Providers. Safecore, its Affiliates and Service Providers may be located throughout the world. Accordingly, your Personal Information may be sent to countries which have a different level of privacy protection than the United States of America (USA) or your country of residence. For instance, if you inquire about services Safecore provides in France and in Brazil, Safecore will forward your inquiry to the Safecore location in such countries. Safecore will, at your request, provide you with details of companies and countries to which your information has been sent.

Links and third-party websites.

This policy applies only to Safecore’s Web site. This site includes links to both our Affiliated Web sites and to non-affiliated Web sites, including access to content, products and services of such Affiliated and non-affiliated sites. Although some of the entities controlling these sites are under contract with Safecore, we urge you to familiarize yourself with the individual privacy and other terms for each linked Web site prior to submitting your personally identifiable information.

How to opt out or request changes.

You are entitled to request that Safecore:

• provide you with a copy of your Personal Information that it holds;
• cease processing your Personal Information, in whole or in part, as you direct us, for the purposes of direct marketing;
• correct any errors in that Personal Information; and
• update that Personal Information as required.

If you would like to receive a copy of the Personal Information we have about you as submitted to us via this Web site, or if you wish to opt out of receiving marketing related communications from us, please send a request to Operations@safecore.com. If this information is incorrect or incomplete, please let us know by sending a request to Operations@safecore.com, and we will make every reasonable effort to correct or update it promptly (unless we require further information from you in order to fulfill your request). You may also ask us to remove your name and other Personal Information from our databases. In each of the foregoing cases, we will make all reasonable efforts to honor your request promptly, subject to legal and other permissible considerations.

Notification of changes.

Safecore may, in its sole discretion, update this policy at any time and from time to time, by posting the amended policy on this Web site. If we make material changes to this policy that affect our treatment of your Personal Information, we will provide you with e-mail or postal mail notice and a choice to opt in under the terms of the revised policy. After the changes take effect, all newly collected Personal Information will be subject to the terms of the revised policy and all previously collected Personal Information will be handled in accordance with your response to our opt-in notice (in accordance with the revised policy if you opt in and in accordance with the previous policy if you do not opt in). If no material changes have been made to this policy that affect our treatment of your Personal Information, the amended policy shall be effective upon posting, and your access to or use of the site following an update shall be deemed consent to the revised policy. If you have asked to receive marketing and other materials, and you regularly receive electronic communications from us, amendments to this policy may be sent to you via e-mail. We urge you to refer back to this page regularly and especially prior to providing any Personal Information via this Web site. This policy may not be otherwise amended without the written consent of Safecore. This policy was last updated on June 1, 2007.

How we protect and store your information.

Safecore takes seriously the security of the information it collects. Safecore has therefore implemented technology and security policies and procedures intended to reduce the risk of accidental destruction or loss, or the unauthorized disclosure or access to such information appropriate to the nature of the data concerned. In addition, Safecore has certified its compliance with the Safe Harbor framework designed to satisfy the "adequacy" requirement under the European Directive on Data Protection.

Personal Information collected via this Web site is stored on servers in the USA, and these servers are subject to Safecore's IT security policies and procedures. If you are located in another jurisdiction, you should be aware that your Personal Information once collected will be transferred to our servers, and the USA currently does not have uniform data protection laws.

Children.

Safecore is concerned about the safety of children when they use the internet, and will never knowingly collect Personal Information from minors (children under 13 years of age, or any other age defined under applicable law) [without prior verifiable parental consent]. If we become aware that a minor is attempting to or has submitted Personal Information via this Web site, we will notify the user that we may not accept his or her Personal Information. We will then remove any such Personal Information from our records.

Safecore's Business Ethics Program.

Disclosures made pursuant to Safecore's Business Ethics Program are covered by Safecore's Code of Ethics and Business Conduct in lieu of this privacy policy.

Questions regarding this policy.

If you have questions concerning this Policy, please contact our Director of Privacy at 781-272-1140, or via e-mail at privacy@safecore.com or by writing to Director of Privacy, Safecore, One Van de Graaff Drive, Burlington, MA 01803 U.S.A.

Safecore commits to the following:

• Safecore only collects information that is needed. Safecore collects information that will enable it to administer customer accounts, to provide marketing information about Safecore's services and products, to provide  articles that may be useful to customers, to obtain information that may be helpful to Safecore in administering and enhancing its Web site, and to fulfill any regulatory or legal requirement. We keep our customers informed as to what information we are collecting and how that information will be used.
• From our employees  Safecore collects information that will enable it to manage employee benefits and related benefit plan administration, for human resources management purposes and staff training and for immigration purposes, as well as to fulfill any regulatory or legal requirement.
• Customers must "opt in" prior to Safecore using Customer information online. You have the option of determining whether to supply Safecore with information that it may use for purposes of sending you information, whether it is sent through online marketing efforts, by telephone, by fax or by mail. At any time, you may "opt out", and Safecore will use its best efforts to promptly cease processing the Personal Information you previously supplied. In connection with the offline activities of Safecore, the Customer may simply notify Safecore in writing that it wishes to cease receiving additional information from Safecore ("opt out"), and Safecore will use its best efforts to promptly honor any such request.  
• Safecore uses security procedures and safeguards that it considers appropriate for the level of Personal Information our customers or employees are providing to Safecore. Safecore's goal is to prevent unauthorized access, maintain data accuracy, ensure the appropriate use of information and use professional industry standards to protect against the loss, misuse or alteration of information under Safecore's control in connection with its information management services.
• Release of Information. In addition to using customer or employee information to fulfill requests received from its respective customers or employees, Safecore discloses information provided to it when required to do so by law or by a regulatory agency. In addition, Safecore may share, as appropriate, with its Affiliates, with unaffiliated third parties that are under contract to perform services for or on behalf of Safecore (Service Providers) (who are required to uphold and maintain policies with respect to privacy and the treatment of your Person Information) and/or to a third party in connection with a proposed or actual sale, merger or transfer of all or a portion of a business or division.
  

If you have any questions about our privacy policy, please contact our Director of Privacy at 781-272-1140 or via e-mail privacy@safecore.com  or in writing to Director of Privacy, Safecore,  One Van de Graaff Drive, Burlington, MA 01803 USA.