Privacy

Effective as of December 9, 2016

Intertrust Technologies Corporation and its affiliated companies (“Intertrust”) provides this Privacy Policy in order to describe our practices regarding the information we collect through www.intertrust.com (the “Site”). By using and visiting the Site, you agree to the information collection and use practices described in this Privacy Policy.  This Privacy Policy applies only to the Site. Your use of the Site is also governed by our Terms of Service.

THE SITE IS INTENDED FOR USERS AGE THIRTEEN (13) AND OLDER. By using the Site, you acknowledge that you are at least 13 years old. Note that the Site is not intended for children and the Site does not knowingly collect personal information from children. If we discover that we have inadvertently collected personal information from anyone younger than the age of 13, we will delete that information.

1. What Information We Collect

Information That You Provide

We may collect “Personal Information” (information that can be used to identify or contact you as a specific individual, such as your name or email address) and other information about you, such as demographic information (your age, gender, ZIP code or similar information), business information (including your job title, employer, and business contact information), and certain information about your interests and preferences. We will also collect payment information (typically, credit card account information) if you choose to purchase products or services through the Site.  Any information combined with Personal Information will be treated as Personal Information.

Community Forums & User Content

The Site may provide you the opportunity to participate and post content publicly in forums, through interactive features and through other communication functionality (“Community Forums“).  You may choose, through such features or otherwise, to submit or post questions, comments, suggestions or other content, (collectively, “User Content“).  Please note that certain information, such as your name, may be publicly displayed on the Site along with your User Content.

Note that anything you post to a Community Forum is public others will have access to your User Content and may use it or share it with third parties. If you choose to voluntarily disclose Personal Information, that information will be considered public information and the protections of this Privacy Policy will not apply.

Information Third Parties Provide About You

We may receive information about you from third parties. For example, we may supplement the information we collect with outside records in order to provide you with information, services or products you have requested, to tailor content, to offer you opportunities to purchase products or services that we believe may be of interest to you, and for other purposes. We may combine the information we receive from those other sources with information we collect through the Site. In those cases, we will apply this Privacy Policy to the combined information.

Information We Collect Automatically When You Access and Use the Site

As described below, we and our third-party service providers automatically or passively collect certain information regarding your use of our Site (“Usage Information”). Usage Information may include the browser and operating system you are using, the URL or advertisement that referred you to our Site, any search terms you entered into a search engine that led you to our Site, the areas within our Site that you visited, and the time of day you visited our Site, among other information. Usage Information also includes the IP address or other unique identifier (“Device Identifier”) for any computer, mobile phone, or other device used to access our Site. A Device Identifier is a number that is automatically assigned to your device, and our servers identify your device by its Device Identifier. Some mobile service providers may also provide us with information regarding the physical location of the device you used to access our Website. Usage Information is generally non-identifying, but if we associate it with you as a specific and identifiable person, we will treat it as Personal Information.

Usage Information is collected via tracking technologies, including:

Cookies

A cookie is a small text file that is stored in your browser when you visit the Site or otherwise access our online content. Cookies may be stored on your device for different periods of time depending on how they are used. “Session cookies” store information that is only relevant for your current activity and expire when you close your browser. “Persistent cookies” remain after you close your browser and may be accessed through your browser on subsequent visits. We use both session ID cookies and persistent cookies when you visit our Site. We use session cookies to make it easier for you to navigate our Site. Persistent cookies enable us to track and target the interests of our users to enhance their experience on our Site. Certain web browsers and certain browser add-ons, such as Adobe Flash, may provide additional data storage mechanisms that are used in a manner similar to cookies, and some of the content included on our Site may make use of this type of storage. For example, a Flash cookie is a data file placed on a device via the Adobe Flash plugin that may be built into or downloaded by you to your device. Cookies and Flash Cookies may be used for a variety of purposes, such as to identify your device when you revisit our Site, to recall your authentication information, or to store information related to your navigation throughout our Site, or to enable certain features on our Site.

You may refuse to accept cookies, or remove cookies, by editing the privacy and security settings of your browser. For specific instructions on how to change privacy and security settings, consult the “Help” menu within your browser. Additionally, you can disable or delete similar data used by browser add-ons, such as Adobe Flash cookies, by changing the add-on’s settings or visiting the Website of its manufacturer. (For more information about Flash and the privacy choices Adobe offers, visit http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager.html.) If you choose to disable cookies or to adjust your Flash privacy settings on your device, some features of the Site may not function properly.

We use a third-party analytics service called Google Analytics that uses cookies to help us better understand user behavior on the Site.  For more information about how Google Analytics collects and processes data, visit www.google.com/policies/privacy/partners/ (“How Google uses data when you use our partners’ sites or apps”).

Web Beacons

Small graphic images or other web programming code called web beacons (also known as “1×1 GIFs” or “clear GIFs”) may be included in our web pages and email messages. Web beacons may be invisible to you, but any electronic image or other web programming code inserted into a web page or email can act as a web beacon. Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to the Site, to monitor how users navigate the Site, and to count how many emails that were sent were actually opened.

Embedded Scripts

An embedded script is programming code that is designed to collect information about your interactions with the Site, such as the links you click on. The code is temporarily downloaded onto your device from our web server or that of a third-party service provider, is active only while you are connected to the Site, and is deactivated or deleted thereafter.

In addition, we may use a variety of other technologies that collect similar information for security and fraud detection purposes.

2. How We Use Information We Collect

We may use information collected through our Site, including your Personal Information and Usage Information, to: (a) enable you to use our Site, and to provide related user service, including responding to your questions, complaints, or comments; (b) fulfill transactions and process orders and payments; (c) administer and develop our business relationship with you and the company for which you work; (d) provide you with information, products, or services that you have requested or agreed to receive or that we otherwise believe will interest you, including information and special offers from us and our third-party business partners; (e) tailor content, recommendations and offers we display to you, both on the Site and elsewhere online, (f) improve our Site, products, and services, and for other internal business purposes; (g) process information you provide via our Site, including verifying that your email address is active and valid; (h) contact you with administrative communications and, in our discretion, changes to our Privacy Policy, Terms & Conditions, or any of our other policies, (i) assess your employment application for a position with Intertrust (or an entity related to Intertrust) and prepare related governmental and internal statistics reports, and (j) for purposes as disclosed at the time you provide your information, with your consent, and as further described in this Privacy Policy.

3. How We Share Information with Third Parties

Intertrust may share non-personally identifiable information, such as Usage Information and aggregated user statistics, with third parties in our discretion. Intertrust will not provide any of your personal information to third parties for their marketing purposes unless we first provide you with the opportunity to opt-in or opt-out of such sharing. We may share the information we have collected about you, including Personal Information, as disclosed at the time you provide your information, with your consent, as described in this Privacy Policy, and in the following circumstances:

Third Parties Providing Services on Our Behalf We may use third-party service providers to perform services on behalf of the Site, and we may provide these service providers with access to information so that they can carry out the services they are performing for you or for Intertrust. Some of these service providers may collect information on the Site directly from you on our behalf; in such cases, these service providers are not permitted to use your Personal Information for their own use. Administrative and Legal Reasons We may transfer and disclose information, including Personal Information, to third parties in order to comply with a legal obligation; when we believe that the law requires it; at the request of governmental authorities conducting an investigation; to verify or enforce our Terms & Conditions or other applicable policies; to respond to an emergency; or otherwise to protect the rights, property, safety, or security of Intertrust, users of the Site, or others. Business Transfers & Transitions Intertrust may share your information, including Personal Information, with its subsidiaries and affiliates, primarily for business and operational purposes. In the event Intertrust goes through a business transition, such as a merger, acquisition by another company, or sale of all or a portion of its assets, including, without limitation, during the course of any due diligence process, your Personal Information will likely be among the assets transferred. By providing your Personal Information, you agree that we may transfer such information to the acquiring entity without your further consent. You will be notified via email and/or a notice posted on our Site of any such change in ownership or control of your personal information.

4. Analytics Providers, Ad Servers, and Similar Third Parties

We work with network advertisers, ad agencies, analytics service providers and other vendors to provide us with information regarding traffic on our Site (including pages viewed and the actions taken when visiting our Site), to serve our advertisements on other websites, within mobile apps, and elsewhere online, and to provide us with information regarding the use of our Site and the effectiveness of our advertisements. For example, if you view or click on an advertisement for Intertrust or one of our products, our service provider(s) may be able to tell us the advertisement that you clicked on and where you were viewing the advertisement. Our service providers may set and access their own tracking technologies on your device (including cookies and web beacons) and may otherwise collect or have access to information about you and your visits to and activity on the Site, as well as on other websites or online services. Some of these third parties may collect personal information from you over time when you visit the Site or other websites and services.  Cookies and web beacons, including those set by third-party network advertisers, may be used to, among other things, target advertisements to you, prevent you from seeing the same advertisements too many times, and conduct research regarding the usefulness of certain advertisements to you. We may share Usage Information about visitors with third-party advertising companies, analytics providers, and other vendors for similar purposes. We use a variety of service providers to perform advertising services. Some of these companies are members of the Network Advertising Initiative (“NAI”) or the Digital Advertising Alliance (“DAA”) Self-Regulatory Program for Online Behavioral Advertising. You may want to visit http://www.networkadvertising.org/managing/opt_out.asp, which provides information regarding targeted advertising and the “opt-out” procedures of NAI members. You may also want to visit http://www.aboutads.info/choices/, which provides information regarding targeted advertising and offers an “opt-out” by participating companies in the DAA Self-Regulatory Program. Please note opting out through these mechanisms does not opt you out of being served advertising. You will continue to receive generic ads while online.

5. Security

Intertrust takes commercially reasonable steps to help protect and secure the information it collects and stores about its users. However, please remember that no data storage or data transmission is guaranteed to be 100% secure. Thus, while we strive to protect your Personal Information, Intertrust cannot ensure or warrant the security of any information you transmit to us. You use our Site and provide us with your information at your own risk.  We may store information that we collect through our Site indefinitely except as otherwise required by law.

6. Links to other websites

The Site may contain links to third-party websites, such as our pages available through third party social media platforms. Intertrust takes no responsibility for the content, operation or privacy practices of such websites. This Privacy Policy does not apply to third-party websites, and you should check the policies of any linked website before offering information to the sponsor of the website. Intertrust provides these links to you only as a convenience, and the inclusion of any link to such websites does not imply endorsement by Intertrust of those sites.

7. Consent to transfer

We operate the Site from the United States. If you are located outside of the United States, please be aware that information we collect will be transferred to and processed in the United States. By visiting the Site, or providing us with any information, you fully understand and unambiguously consent to this transfer, processing and storage of your information in the United States, a jurisdiction in which the privacy laws may not be as comprehensive as those in the country where you reside and/or are a citizen.

8. Employment applications

If you apply for a job through the Site, Intertrust or its service provider may ask you to provide self-identifying information (such as veteran status, gender, and ethnicity) in conjunction with laws and regulations enforced by the Equal Employment Opportunity Commission (“EEOC”) and other federal, state, and local regulatory agencies. Providing such self-identifying information is voluntary, but if you do provide such information, Intertrust or its service provider may submit that information to the appropriate government or regulatory agencies to fulfill reporting requirements and use that information to defend against employment related complaints.

9. Changes to this Privacy Policy

We may revise this Privacy Policy from time to time at our sole discretion. If we do so, we will post the updated policy on our Site, and in our discretion, will provide notice to you via the contact information we have on file.

10. Contact Us

If you have questions or comments about our use of your information or about this Privacy Policy, please contact us by email at legal@intertrust.com or write to: Intertrust Technologies Corporation, Attn: Legal Department, 920 Stewart Drive, Suite 100, Sunnyvale, CA 94085.

11. California Residents – Your California Privacy Rights

Pursuant to California Civil Code Section 1798.83, residents of the State of California have the right to request from companies conducting business in California certain information relating to third parties to which the company has disclosed certain categories of personal information during the preceding year for the third parties’ direct marketing purposes. Alternatively, the law provides that a company may comply, as Intertrust does, by disclosing in its privacy policy that it provides consumers choice (opt-out or opt-in) regarding sharing personal information with third parties for those third parties’ direct marketing purposes, and information on how to exercise that choice.  As stated above in this Privacy Policy, Intertrust provides you choice prior to sharing your personal information with third parties for their direct marketing purposes. If you do not opt-in or if you choose to opt-out at the time Intertrust offers that choice, Intertrust does not share your information with that identified third party for its direct marketing purposes.

If you are a California resident and you have questions about our practices with respect to sharing information with third parties for their direct marketing purposes and your ability to exercise choice, please email your request to legal@intertrust.com or write to: Intertrust Technologies Corporation, Attn: Legal Department, 920 Stewart Drive, Suite 100, Sunnyvale, CA 94085.  You must put the statement “Your California Privacy Rights” in the subject field of your email or include it in your writing if you choose to write to us at the designated mailing address. You must include your name, street address, city, state, and ZIP code. We are not responsible for notices that are not labeled or sent properly, or do not have complete information.  Please note that we are only required to respond to one (1) such request each calendar year.