Privacy
Policy

Thank you for visiting SPLASHTOP Inc.’s (“Splashtop”) Internet web site located at the URL: http://www.mirroring360.com (the “Site”).  At Splashtop, we know that you care how information about you is collected, used, or shared.  This Privacy Policy explains what information of yours may be collected by Splashtop through its family of products such as when you use Mirroring360™ and/or related services (each a “Product” or the “Products”) and through the Site, and how the information will be used.  We will not use your information in any way except as described in this Privacy Policy.

Acceptance of the Privacy Policy
This Privacy Policy is incorporated into and is subject to the Splashtop Terms of Use, which are available at http://www.mirroring360.com/terms.  By visiting and using the Site or Products, you agree to abide by the terms and conditions of this Privacy Policy, and you consent to the collection, use and disclosure of your personal information and other non-personally identifying information by Splashtop in accordance with the terms and conditions of this Privacy Policy.  If you do not agree to the terms and conditions of this Privacy Policy or the Terms of Use, please do not provide us with any information and do not use the Site or the Products.

Privacy Policy Updates
Due to the Internet’s rapidly evolving nature, we may need to update this Privacy Policy from time to time.  If so, we will post the updated Privacy Policy on our Site located at http://www.mirroring360.com/privacy so such notice is visible when users log-on for the first time after the changes are posted.  We may also send registered users of the Site email notifications notifying such users of any changes to the Privacy Policy.  If any change is unacceptable to you, you shall cease using the Site and the Products.  If you do not cease using the Site and the Products, you will be deemed to have accepted the changes.

Aggregate Information
We may track the total number of visitors to our Site, the number of visitors to each page of our Site, the number of External Web Site (defined below) pages you have visited, technical information about your computer, system and browser software and IP addresses.  The aggregate information extracted from this data will be maintained, used and disclosed in aggregate form only and will not contain personally identifiable information.  We may use such aggregate information to analyze trends, improve the Products we provide to our users, administer the Site and gather broad demographic information for aggregate use.

Information We Collect
Through the Site:
You can generally visit our Site without revealing any personally identifiable information about yourself.  However, in certain instances, you may be given the option to fill out a service registration, complete a survey or other form which could contain personally identifiable information, such as user identification name, an email address, and/or any other information that you voluntarily transmit with your communication to us.

Whenever you visit a Splashtop web page, your browser may send certain information to our server, which we record.  This information may include the URL of the referring web page, your browser and OS type, etc.

Through the Products:
Each Splashtop-based software product or service contains an activation time stamp, which is transparently collected by our server the first time you use the Product.  You will be assigned a unique user ID number.  In addition, as part of acceptance to use the Product, you are authorizing Splashtop to collect information about your use of the Product, including, without limitation, the number of times you use the Product or various applications included with the Product, the duration of use, how many times and the type of technical problems that occur during use of the Product and technical information about your computer and system software and the Product version you are using.  We do this for purposes such as analyzing how the Product is used, diagnosing service or to address technical problems, and improving Product quality and features.

Information Use
We may use your personally identifiable information you submit to the Site or Products, such as your email address, to register you to download our software and/or use our Products, contact you to deliver certain services or information you have requested, verify your authority to enter our Site, improve the content and general administration of the Site, services and Products, and provide you with notices regarding goods, services and/or Products that you have purchased or may wish to purchase in the future.

Choice to Opt-In
We will not share your personally identifiable information in any way except as described in this Privacy Policy unless you specifically elect to make such information available to third parties by selecting to “opt-in” in various places on the Site or in the Products.  For example, prior to making your personally identifiable information available to third parties for their direct marketing purposes, we will give you the opportunity to “opt in” to receive such third party communications.  This means we will require your affirmative action to indicate your consent before we provide your personally identifiable information to third parties for their direct marketing purposes.

Disclosure
We may share non-personally identifiable information (such as anonymous usage data, referring/exit pages and URLs, platform types, number of clicks, etc.) with interested third parties to help them understand the usage patterns for certain Product services.  Moreover, we may share your personally identifiable information and/or aggregate information with a parent, subsidiary or affiliate entity in our corporate family or with our agents such as service providers or agencies that provide data security and maintenance services to us.  We may also disclose your personally identifiable information and/or aggregate information to third parties if it is necessary to fulfill your product or service order.  For example, we may provide your personally identifiable information, such as your email address, to a third party service provider or vendor who sends information on our behalf that you have opted to receive about our products and services; similarly, we may share personally identifiable information such as your credit card number to a payments processing company in order to receive payments or to services agencies who provide browser services related to Splashtop’s Products.  Additionally, in the case where you “opt in” to make your personally identifiable information available to other third parties, we may provide that information to partner entities or other third parties.  We may also disclose your personally identifiable information (a) if we are required to do so by law, regulation or other government authority or otherwise in cooperation with an investigation of a governmental authority, (b) to enforce the Splashtop Terms of Use agreement or to protect our rights or (c) to protect the safety of users of our Site, services and our Products.  We will not sell your personally identifiable information to any company or organization without your permission, except we may transfer your personally identifiable information and/or aggregate information to a successor entity upon a merger, consolidation or other corporate reorganization in which Splashtop participates or to a purchaser of all or substantially all of Splashtop’s assets to which the Site or the Products relate.

Children’s Privacy
We recognize the privacy interests of children and we encourage parents and guardians to take an active role in their children’s online activities and interests.  The Site is not intended for children under the age of 13.  We do not target its services or the Site to children under 13.  We do not knowingly collect personally identifiable information from children under the age of 13. 

Links to Third Party Sites
The Site may provide links to other Web sites or resources over which we do not have control (“External Web Sites”).  Such links do not constitute an endorsement by Splashtop of those External Web Sites.  You acknowledge that we are providing these links to you only as a convenience, and further agree that we are not responsible for the content of such External Web Sites.  Your use of External Web Sites is subject to the terms of use and privacy policies located on the linked to External Web Sites.

Security
We may employ procedural and technological measures, consistent with industry practice, to protect your personally identifiable information.  Such measures are reasonably designed to help protect your personally identifiable information from loss, unauthorized access, disclosure, alteration or destruction.  We may use firewalls, password protection, encryption, secure socket layer and take other physical security measures and place internal restrictions on who within Splashtop may access your data to help prevent unauthorized access to your personally identifiable information.

Correction/Deletion/Updating Personally Identifiable Information
We will provide you with the ability to modify or delete the personally identifiable information you have submitted through the Products or through the Site.  However, we may retain a copy of your subscription records for audit purposes.

If you have any questions regarding this Privacy Policy please contact us:

By e-mail: privacy@splashtop.com

By mail: 1054 South De Anza Boulevard, Suite 200
San Jose, California 95129

By phone: 408-861-1088

Personal information collected on the Site or within the Products may be stored and processed in the United States or any other country in which Splashtop or its affiliates, subsidiaries or service providers maintain facilities.  By using the Site and/or Products you agree to this Privacy Policy and you acknowledge this Privacy Policy may not offer an equivalent level of protection of that required in the European Union or certain other countries.

This Privacy Policy was last updated: June 4, 2014