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PRIVACY POLICY

  1. Introduction

This Privacy Policy (“Policy”) details Splashtop Inc.’s (“Splashtop”) commitment to protecting the privacy of individuals who visit our Websites and who register to use the products and Service(s) (as defined below) which we market for subscription (“Subscriber”). For the purposes of this Policy, the term, “Websites”, shall refer collectively to www.splashtop.com as well as the other websites that the Splashtop operates and that link to this Policy.

At Splashtop, we know that you care how information about you is collected, used, or shared. This Policy explains what information of yours may be collected by Splashtop through its family of products and/or related services (each a “Service” or the “Services”) and through the Websites, and how the information will be used. We will not use your information in any way except as described in this Policy.

  1. Scope of This Policy

In this Policy, personal information means information relating to an identified or identifiable natural person. An identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, or location data. The use of information collected through our Service shall be limited to the purpose of providing the Services for which the Subscribers has engaged.

Our Websites may contain links to other websites and the information practices and the content of such other websites are governed by the privacy statements of such other websites. We encourage you to review the privacy statements of any such other websites to understand their information practices.

We have no direct relationship with individuals whose personal information we process in connection with our Subscriber’s use of our Services. If you are an individual who interacts with a Subscriber while using our Services (such as a customer of one of our Subscribers who are, for example, a Managed Service Provider or an IT support technician) and would either like to amend your contact information or no longer wish to be contacted by one of our Subscribers that use our Services, please contact the Subscriber that you interact with directly.

  1. Acceptance of the Privacy Policy

This Policy is incorporated into and is subject to the Splashtop Terms of Service for use of our Services, which are available at https://www.splashtop.com/terms/splashtop, and Splashtop Terms of Use for use of our Websites, which are available at https://www.splashtop.com/terms. By visiting and using the Websites or Services, you agree to abide by the terms and conditions of this 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 Policy. If you do not agree to the terms and conditions of this Privacy Policy or the Terms of Service, please do not provide us with any information and do not use the Websites or the Services.

  1. Privacy Policy Updates

Due to the Internet’s rapidly evolving nature, we may need to update this Policy from time to time. If so, we will post the updated Privacy Policy on our Websites located at https://www.splashtop.com/privacy. We may also send registered users of the Websites email notifications notifying such users of any changes to the Policy. If any change is unacceptable to you, you shall cease using the Websites and the Services. If you do not cease using the Websites and the Services, you will be deemed to have accepted the changes.

  1. Information We Collect From You on our Websites

You can generally visit our Websites 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, OS type, as well as the information set forth below:

Cookies and Other Tracking Technologies:

We and our authorized partners may use cookies and other information gathering technologies to provide us with personal information, information about devices and networks you utilize to access our Websites, and other information regarding your interactions with our Websites. For detailed information about the use of cookies in the Websites, please read and review our Cookie Policy which can be found at https://www.splashtop.com/cookie-policy.

We partner with third parties to manage our advertising on other sites. Our third party partners may also use technologies such as cookies to gather information about your activities on our Websites and other sites in order to suggest advertisements based upon your browsing activities and interests. If you wish to not have this information used for the purpose of serving you interest-based ads, you may opt-out by clicking http://preferences-mgr.truste.com (or if located in the European Union you may opt-in the use of cookies, by clicking http://www.youronlinechoices.eu/).

We may use web beacons, tags and scripts on our Websites or in email we send to you. These assist us in delivering cookies, counting visits to our Websites, understanding usage and campaign effectiveness and determining whether an email has been opened and acted upon. We may receive reports based on the use of these technologies from our third-party service providers on an individual and aggregated basis.

We may use Local Storage Objects (“LSOs”) such as HTML5 to store content information and preferences. Various browsers may offer their own management tools for removing HTML5 LSOs. Third parties with whom we partner to provide certain features on our Websites or to display advertising based upon your Web browsing activity use LSOs such as HTML5 and Flash to collect and store information. For further information on how to manage Flash LSOs please visit http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html.

 

Logs:

As is true with most websites and services delivered over the Internet, we gather certain information and store it in log files when you interact with our Websites and Services. This information includes internet protocol (IP) addresses as well as browser type, internet service provider, URLs of referring/exit pages, operating system, date/time stamp, information you search for, locale and language preferences, identification numbers associated with your devices, your mobile carrier, and system configuration information. Occasionally, we connect personal information to information gathered in our log files as necessary to improve our Websites and Services. In such a case, we would treat the combined information in accordance with this Policy.

 

Analytics:

We collect analytics information when you use the Websites to help us improve them. We may also share anonymous data about your actions on our Websites with third-party service providers of analytics services.

We also use mobile analytics software to allow us to better understand the functionality of our mobile application on your device. This software may record information such as how often you use the mobile application, the events that occur within the mobile application, aggregated usage, performance data, and where the mobile application was downloaded from. We do not link the information we store within the analytics software to any personally identifiable information you submit within the mobile application.

  1. Information We Collect from Subscribers through our Services

Account and Registration Information:

We ask for and may collect personal information about you such as your name, address, phone number, email address, and credit card information, as well as certain related information like your company name and website name, when you register for an account to access or utilize one or more of our Services (an “Account”). We also ask for and collect personal information such as an email address and a name or alias from any individual that you authorize to log into and utilize our Services in connection with Your Account.

If you sign-up for a free trial Account, you are not required to enter your credit card information unless and until you decide to continue with a paid subscription to our Services. A third-party intermediary is used to manage credit card processing. This intermediary is not permitted to store, retain, or use your billing information for any purpose except for credit card processing on our behalf.

We refer to any information described above as “Account Information” for the purposes of this Policy. By voluntarily providing us with Account Information, you represent that you are the owner of such personal data or otherwise have the requisite consent to provide it to us.

Other Submissions:

We ask for and may collect personal information from you when you submit web forms on our Websites or as you use interactive features of the Websites, including, participation in surveys, contests, promotions, sweepstakes, programs (including reseller, referral, beta, and early access program applications), requesting customer support, or otherwise communicating with us.

Attendee Information:

We ask for and may collect personal information such as your name, address, phone number and email address when you register for or attend a sponsored event or other events at which any member of the Splashtop team participates.

Desktop software and Mobile Application:

When you download, or install, and use our Services, we collect following information: (a) Device information including device names, the type of device you use, its IP address and MAC address, and operating system version and (b) Session information including session start time, end time, speed of access to Splashtop servers in different regions, our desktop software or mobile application crash dumps, or error logs.

  1. Information We Collect from Other Sources

Social Media Widgets:

The Websites may include social media features, such as the Facebook Like button, and widgets, such as the Share This button or interactive mini-programs that run on our Websites. These features may collect your Internet protocol address, which page you are visiting on the Websites, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on the Websites. Your interactions with these features are governed by the privacy statement of the companies that provide them.

Information From Third Party Services:

We may also obtain other information, including personal information, from third parties. For example, we may have access to device information from a third party RMM (remote monitoring and management) service who integrates with our Services. Any access that we may have to such information from a third party RMM service is in accordance with the authorization procedures determined by that service. You should check your privacy settings on these third party services to understand and change the information sent to us through these services.

  1. Information Use

General Uses:

We may use the information we collect about you (including personal information, to the extent applicable) for a variety of purposes, including to (a) provide, operate, maintain, improve, and promote the Services; (b) enable you to access and use the Services; (c) process and complete transactions, and send you related information, including purchase confirmations and invoices; (d) send transactional messages, including responses to your comments, questions, and requests; provide customer service and support; and send you technical notices, updates, security alerts, and support and administrative messages; (e) send promotional communications, such as providing you with information about products and services, features, surveys, newsletters, offers, promotions, contests, and events; and provide other news or information about us and our partners. You can opt-out of receiving marketing communications from us by contacting us at privacy@splashtop.com or following the unsubscribe instructions included in our marketing communications; (f) process and deliver contest or sweepstakes entries and rewards; (g) monitor and analyze trends, usage, and activities in connection with the Websites and Services and for marketing or advertising purposes; (h) investigate and prevent fraudulent transactions, unauthorized access to the Services, and other illegal activities; (i) personalize the Websites and Services, including by providing features or advertisements that match your interests and preferences; and (j) for other purposes for which we obtain your consent.

Legal Basis for Processing:

We normally collect personal information from you only where: (a) we have your consent to do so, (b) where we need the personal information to perform a contract with you (e.g. to deliver the the Services you have requested), or (c) where the processing is in our or a third party’s legitimate interests (and not overridden by your data protection interests or fundamental rights and freedoms). In some cases, we may also have a legal obligation to collect personal information from you, or may otherwise need the personal information to protect your vital interests or those of another person.

Where we rely on your consent to process the personal information, you have the right to withdraw or decline your consent at any time. Please note that this does not affect the lawfulness of the processing based on consent before its withdrawal. If you have any questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us at privacy@splashtop.com.

  1. Choice to Opt-In

We will not share your personally identifiable information in any way except as described in this Policy unless you specifically “opt-in” to allow us to do so. We do not currently share your personally identifiable information with third parties for their direct marketing purposes. If we were to do so in the future, we would require your affirmative action to indicate your consent before we would provide your personally identifiable information to any third parties for their direct marketing purposes.

  1. Sharing Of Information Collected

Third-Party Service Providers:

We share information, including personal information, with our third-party service providers that we use to provide hosting for and maintenance of our Websites, application development, backup, storage, payment processing, email notification service, analytics and other services for us. These third-party service providers may have access to or process your personal information for the purpose of providing these services for us. We do not permit our third-party service providers to use the personal information that we share with them for their marketing purposes or for any other purpose than in connection with the services they provide to us.

Compliance with Laws and Law Enforcement Requests; Protection of Our Rights:

In certain situations, we may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We may disclose personal information to respond to subpoenas, court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims. We may also share such information if we believe it is necessary in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our Terms of Service, available at http://www.splashtop.com/terms/splashtop, or as otherwise required by law.

Testimonials:

From time to time, we may post testimonials on the Websites that may contain personal information. We obtain your consent to post your name along with your testimonial. If you wish to update or delete your testimonial, you can contact us at privacy@splashtop.com.

Splashtop Sharing:

We may share information, including personal information, with any member of the Splashtop team. Moreover, we may share your personally identifiable information and/or aggregate information with a parent, subsidiary or affiliate entity in our corporate family. 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 Websites or the Services relate.

With Your Consent:

We may also share personal information with third parties when we have your consent to do so.

  1. Communications Preferences

We offer those who provide personal contact information a means to choose how we use the information provided. You may manage your receipt of marketing and non- transactional communications by clicking on the “unsubscribe” link located on the bottom of our marketing emails or you may send a request to privacy@splashtop.com.

  1. How Long We Retain Your Personal Information

We will retain your personal information for as long as is needed to fulfill the purposes outlined in this Policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

For personal information that we process on behalf of our Subscribers, we will retain such personal information in accordance with the terms of our agreement with them, subject to applicable law.

  1. Your Privacy Rights

Upon request we will provide you with information about whether we hold, or process on behalf of a third party, any of your personal information. To request this information please contact us at privacy@splashtop.com. Subscribers to our Services may update or change their Account Information by editing their profile or organization record or by contacting support@splashtop.com for more detailed instructions. To make a request to have personal information maintained by us returned to you or removed, please email privacy@splashtop.com. Requests to access, change, or remove your information will be handled within thirty (30) days.

An individual who seeks access to, or who seeks to correct or, amend inaccuracies in, or delete personal information stored or processed by us on behalf of a Subscriber should direct his/her query to the Subscriber (the data controller). Upon receipt of a request from one of our Subscribers for us to remove the data, we will respond to their request within thirty (30) days. We will retain personal information that we store and process on behalf of our Subscribers for as long as needed to provide the Services to our Subscribers. We will retain and use this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

The security of your personal information is important to us. We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once it is received. If you have any questions about the security of your personal information, you can contact us at support@splashtop.com.

If you are a Subscriber or otherwise provide us with personal information in connection with your use of our Websites or Services, we will delete this information upon your request, provided that, notwithstanding such request, this information may be retained for as long as you maintain an Account for our Services, or as needed to provide you with our Services, comply with our legal obligations, resolve disputes and enforce our agreements.

Additional Rights for EEA:

If you are from certain territories (such as the European Economic Area or “EEA”), you may have the right to exercise additional rights available to you under applicable laws, including:

Right of erasure: In certain circumstances, you may have a broader right to erasure of personal information that we hold about you – for example, if it is no longer necessary in relation to the purposes for which it was originally collected. Please note, however, that we may need to retain certain information for record keeping purposes, to complete transactions or to comply with our legal obligations.

Right to object to processing: You may have the right to request that Splashtop stop processing your personal information and/or to stop sending you marketing communications.

Right to restrict processing: You may have the right to request that we restrict processing of your personal information in certain circumstances (for example, where you believe that the personal information we hold about you is inaccurate or unlawfully held).

Right to data portability: In certain circumstances, you may have the right to be provided with your personal information in a structured, machine readable and commonly used format and to request that we transfer the personal information to another data controller without hindrance.

If you would like to exercise such rights, please contact us at the contact details in Section 18 below. We will consider your request in accordance with applicable laws. To protect your privacy and security, we may take steps to verify your identity before complying with the request.

  1. International Transfer Of Information Collected

Splashtop is a U.S.-based, global company. To facilitate our global operations, as well as to provide you with the Services you subscribed, we may transfer and access such personal information from around the world, including from other countries in which Splashtop has operations for the purposes described in this Policy. We may also transfer your personal information to our third party processors, who may be located in a different country to you. Such countries may have laws which are different, and potentially not as protective, as the laws of your own country. Splashtop has signed Data Processing Agreement (“DPA”) with our third party processors as contractual safeguard to ensure equivalent obligations as those required from Splashtop are satisfied.

If you are visiting our Websites from the EEA or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your personal information to the United States and other jurisdictions in which we operate. By providing your personal information, you consent to any transfer and processing in accordance with this Policy.

 

  1. 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 Websites is not intended for children under the age of 13. We do not target its services or the Websites to children under 13. We do not knowingly collect personally identifiable information from children under the age of 13.

  1. Links to Third Party Sites

The Websites may provide links to other websites 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 at such External Web Sites.

  1. 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.

  1. 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 Services or through the Websites. However, we may retain your Account Information for audit, legal or archival purposes.

If you have any questions regarding this 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 Websites or within the Services 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 Websites and/or Services you agree to this Policy and you acknowledge this Policy may not offer an equivalent level of protection of that required in the European Union or certain other countries.

This Policy was last updated: May 23, 2018