Intertrust Privacy Policy

Effective as of January 1, 2022

Intertrust Technologies Corporation and its affiliated companies (“Intertrust”) provide this Privacy Policy in order to describe our practices regarding the information we collect, use, and share when you interact with our websites, products, and email communications (the “Services”). Intertrust offers a wide range of products and services related to computer security, digital rights management, online advertising, data aggregation and distribution, and data analytics. Please read the product-specific details in this Policy, which provide additional information about some of our products.

By using the Services, you consent to the collection and use of information as described in this Privacy Policy. Your use of the Services is also governed by our Terms of Service.

1. When This Privacy Policy Applies

This Policy applies to our websites, products, emails we send, as well as the information we collect when you interact with us through social media or other websites and online services. It does not apply to non-Intertrust websites and mobile applications that may link to the Services or be linked to or from the Services; please review the privacy policies on those websites and applications directly to understand their privacy practices.

We may make changes to this Policy from time to time. We will post any changes, and such changes will become effective when they are posted. Your continued use of our Services following the posting of any changes will mean you accept those changes.

2. What Information We Collect

In this Policy, “personal information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household.

Categories of Personal Information We Collect

Personal Identifiers: name, phone number, address, email address, and other contact information; username and other account information; demographic information.

Content you submit: User Content, as described below.

Commercial Information: payment information (e.g., credit card number)

Internet or Other Electronic Network Activity Information: device identifiers such as IP address and user agent; the assigned unique IDs in cookies (as described below); information about how you arrived at and navigated through our Services.

Geolocation Data: precise location (e.g., GPS) or imprecise location (e.g., location derived from IP address).

Professional or employment-related information:

Education information:

Inferences drawn to create a profile about a consumer reflecting the consumer’s preferences or characteristics: We may analyze your preferences based on the information we collect from any source.

Information That You Provide

When you become or express interest in becoming a client of Intertrust, we ask you to provide certain information to allow us to communicate with you and provide customized products and services. This information typically includes your name or email address, 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 our websites.

The Services may also 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, indications of interest in the content or other content, (collectively, “User Content”). When you create User Content in a Community Forum, that content is displayed publicly. Your name, along with any information you have disclosed in your profile, will be accessible by other users of the forum as well as the general public.

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.

Information We Collect Automatically

When you interact with the Services, as either a client, direct visitor to our website, or indirect user through a product employed by a third-party application, certain information about your use of our Services is automatically collected. This information includes, as applicable, the IP address or other unique identifier for any computer, mobile phone, or other device used to access our Services, the browser and operating system you are using, the URL or advertisement that referred you to our Services, any search terms you entered into a search engine that led you to our Services, the areas within our Services that you visited, and the time of day you visited our Services, among other information.

Our Use of Cookies

Much of this information is collected through cookies, web beacons, and other tracking technologies, as well as through your web browser or device (e.g., IP address, MAC address, browser version, etc.). The tracking technologies employed when you use our Services may be first-party or third-party. We use cookies for the following purposes:

• Strictly necessary cookies: These cookies are necessary for the website to function. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the site will not then work.
• Performance cookies: These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site. They help us to know which pages are the most and least popular and see how visitors move around the site. If you do not allow these cookies we will not know when you have visited our site, and will not be able to monitor its performance.
• Functional cookies: These cookies enable the website to provide enhanced functionality and personalization. They may be set by us or by third party providers whose services we have added to our pages. If you do not allow these cookies then some or all of these services may not function properly.
• Targeting cookies: These cookies may be set through our site by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant adverts on other sites. They do not store directly personal information, but are based on uniquely identifying your browser and internet device. If you do not allow these cookies, you will experience less targeted advertising.

You can see in our Cookie Notice a detailed list of the cookies we use on our website.

You can make changes to which categories of cookies we use (with the exception of strictly necessary cookies) in our privacy preference center. However, blocking some types of cookies may impact your experience of the site.

Change cookie settings in the privacy preference center

As an alternative mechanism to control cookies you may also edit the privacy and security settings of your browser where you can refuse to accept cookies, or remove cookies. However, our privacy preference center uses a cookie to remember the choices you have made. Consequently if you delete all your cookies we won’t be able to remember your cookie preferences and you will have to update them with us again.

We use Google Analytics, a web analytics service provided by Google, Inc., on our Services. Google Analytics uses cookies or other tracking technologies to help us analyze how users interact with and use the Services, compile reports on the Services’ activity, and provide other services related to our Services’ activity and usage. The technologies used by Google may collect information such as your IP address, time of visit, whether you are a return visitor, and any referring website. The Services do not use Google Analytics to gather information that personally identifies you. The information generated by Google Analytics will be transmitted to and stored by Google and will be subject to Google’s privacy policies. To learn more about Google’s partner services and to learn how to opt out of tracking of analytics by Google, click here.

3. How We Use Information We Collect

We may use information collected through our Services, including the categories of personal information listed above, to:

1. Communicate with you, including to respond to your inquiries and fulfill your requests;
2. Administer and develop our business relationship with you and the company for which you work;
3. Provide you with more relevant content in email bulletins to which you may be subscribed;
4. Provide, maintain, personalize, optimize, and improve the Services, including research and analytics regarding use of the Services, or to remember you when you leave and return to the Services;
5. Provide and improve our products and services;
6. Provide services on behalf of our clients who employ specific products, as described in Section 10;
7. Detect, investigate, and prevent activities that may violate our policies or be fraudulent or illegal.

We may combine information together from our records. We may share de-identified information and/or our analyses derived from such information at our discretion.

4. How We Share Information with Third Parties

We may share information, including personal information, with the following categories of recipients.

Merged or Acquiring Entity: We may transfer to another entity or its affiliates or service providers some or all information about you in connection with, or during negotiations of, any merger, acquisition, sale of assets or any line of business, change in ownership control, or financing transaction. We cannot promise that an acquiring party or the merged entity will have the same privacy practices or treat your information the same as described in this Privacy Policy.

Service Providers: We may share the information collected via our Services with companies who work on our behalf to help us provide and support the Services and our products and services, such as:

• Billing and collection providers, such as payment processors and organizations that assist us in assessing your credit and payment status.
• Auditing and accounting firms.
• Professional services consultants, such as firms that assist with providing legal services, or supplying project-based resources and assistance.
• Advertising, marketing, and analytics services, including entities that analyze the information we collect from or about you to communicate with and advertise to you.
• Security vendors, such as entities that assist with security incident verification and response, service notifications, and fraud prevention.
• IT vendors, such as entities that assist with website design, hosting, and maintenance, data and software storage, and network operation.

There are limited circumstances in which the service provider collects data directly from you when their privacy policies may also apply.

Third Parties: We may disclose information to third parties:

• Advertising, Marketing, and Analytics Partners: We partner with companies that assist us with marketing our Services, including by “remarketing” to you on other websites, apps, or social media platforms. These companies may collect information from you automatically via cookies or other tracking technologies when you use our Services.

Authorities and Legally Authorized Recipients: We may transfer and disclose information about you 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 Services, or others.

Subsidiaries and Affiliates: Intertrust may share your information about you 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 information will likely be among the assets transferred.

5. Your Rights

The law gives you rights related to your personal information. To make a request to exercise your rights, please use the contact information below. Individuals from different countries or jurisdictions may have different rights. We reserve the ability to limit our response to your request to exercise your rights based on the law that is applicable to you.

Rights:

• Withdraw consent: If we have collected personal information with your consent, you have the right to withdraw that consent at any time.
• Access/Right to Know: You have the right to request access to personal information we collected about you and information regarding the source of that personal information, the purposes for which we collect it, and the third parties and service providers with whom we share it.
• Correction: You have the right to request that we correct the personal information we hold about you if it is inaccurate or incomplete.
• Deletion: You have the right to request that we erase data we have collected from you. Please note that we may have a reason to deny your deletion request or delete data in a more limited way than you anticipated, e.g., because of a legal obligation to retain it.
• Portability: You have the right, in certain circumstances, to request that we provide your personal information to you in a format that can be transferred to another entity.
• Restrict Processing: You have the right, in certain circumstances, to request that we limit our processing of your personal information if you are contesting the accuracy of your personal information; asserting that our processing is unlawful; asserting that we need to keep the information for reasons related to the establishment, exercise, or defense of legal claims, or you object to our processing.
• Object: You have the right to object to our processing if we are processing your personal information based on legitimate interests, using your personal information for direct marketing (including profiling), or processing your personal information for purposes of scientific or historical research and statistics.
• Automated Decisionmaking: You have the right, in certain circumstances, not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects on you.
• Sale of personal information: California residents have the right to request that a business stops “selling” your personal information. A “sale” of personal information is defined broadly: “selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by the business to another business or a third party for monetary or other valuable consideration.”

California Residents’ Privacy Rights:

• California “Shine the Light”/Third Party Marketing: Residents of the State of California have the right to request information regarding third parties to whom a company has disclosed certain categories of personal information during the preceding year for the third parties’ direct marketing purposes. If you are a California resident and would like to make such a request, please send an email to privacy@intertrust.com or write to: Intertrust Technologies Corporation, Attn: Legal Department, 400 N. McCarthy Boulevard, Suite 220, Milpitas, California 95035. You must put the statement “Your California Privacy Rights” in the subject field of your email or include it in your writing and include name, street address, city, state, and ZIP code.
• California Consumer Privacy Act (“CCPA”):
  • Categories of personal information we disclose: We may disclose any of the categories of personal information listed above and use them for the above-listed purposes or for other business or operational purposes compatible with the context in which the personal information was collected. Our disclosures of personal information include disclosures to our “service providers,” which are companies that we engage for business purposes to conduct activities on our behalf. The categories of service providers with whom we share information and the services they provide are described above.
  • “Sale” of personal information: Intertrust does not “sell” your personal information.

Individuals Located in the European Economic Area, the United Kingdom, and Switzerland: If you are a resident of the EEA or Switzerland, the following information applies.

• Purposes of processing and legal basis for processing: As explained above, we process personal information in various ways depending upon your use of our Services. We process personal information on the following legal bases: (1) with your consent; (2) as necessary to perform our agreement to provide Services; and (3) as necessary for our legitimate interests in providing the Services where those interests do not override your fundamental rights and freedoms related to data privacy.
• Right to lodge a complaint: Users that reside in the EEA or Switzerland have the right to lodge a complaint about our data collection and processing actions with the supervisory authority concerned. Contact details for data protection authorities are available here.
• Transfers: Personal information we collect may be transferred to, and stored and processed in, the United States or any other country in which we or our affiliates or subcontractors maintain facilities. We ensure that transfers of personal information to a third country or an international organization are subject to appropriate safeguards as described in Article 46 of the GDPR.

Special Information for Nevada Residents: Residents of the State of Nevada have the right to opt out of the sale of certain pieces of their information to other companies who will sell or license their information to others. At this time, we do not engage in such sales. If you are a Nevada resident and would like more information about our data sharing practices, please use the contact information provided below.

6. Your Options to Control Your Personal Information

Verification Procedures: We must verify your identity for everyone’s protection, so we may require you to provide us with verification information prior to accessing any records containing personal information about you. We do this by:

• Asking you to provide personal identifiers we can match against information we may have collected from you previously and confirm your request using the email or telephone account stated in the request; or
• Having you submit your request through your account page, which will automatically verify your identity and will result in faster processing of your request.

If you are a California resident, you may authorize another individual or a business registered with the California Secretary of State, called an authorized agent, to make requests on your behalf. We will require the authorized agent and you to each verify your identities.

We will use the information you provide for verification only for the purpose of verification. We may have a reason under the law why we do not have to respond to your request, or respond to it in a more limited way than you anticipated. If we do, we will explain that to you in our response.

Marketing and Other Communications: If at any time you would like to unsubscribe from receiving future emails, you can click the unsubscribe link at the bottom of any email communication, or contact us using the contact information below and we will promptly remove you from all marketing correspondence.

Interest-Based Advertising; Cookie Management; and Do Not Track: Interest-based advertising is the collection of information across different websites and/or different devices for the purpose of tailoring advertising based on preferences or interests known or inferred from the information collected.
Intertrust does not serve advertising on its website, but we partner with third parties to use the information you make available to us when you interact with our Services to provide you with advertising that is more relevant to you after you leave our Services. You may limit such third parties’ information collection by using our cookie management control panel. You can learn more about ad serving companies and the options available to limit their collection and use of your information by visiting the websites for the Network Advertising Initiative, the Digital Advertising Alliance, and the European Interactive Digital Advertising Initiative. Similarly, you can learn about your options to opt-out of mobile app tracking by certain advertising networks through your device settings and by resetting the advertiser ID on your Apple or Android device.

Please note that opting-out of advertising networks services does not mean that you will not receive advertising while using our Services or on other websites, nor will it prevent the receipt of interest-based advertising from third parties that do not participate in these programs. It will, however, exclude you from interest-based advertising conducted through participating networks, as provided by their policies and choice mechanisms. If you delete your cookies, you may also delete your opt-out preferences.

Your browser or device may include “Do Not Track” functionality. At this time, Intertrust does not respond to browser “Do Not Track” signals.

7. Security

Intertrust protects and secures 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 services and provide us with your information at your own risk.

8. International Transfers

If you use our Services outside of the United States, you understand that we may collect, process, and store your personal information in the United States and other countries. The laws in the U.S. regarding personal information may be different from the laws of your state or country. Any such transfers will comply with safeguards as required by relevant law.

9. 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 privacy@intertrust.com or write to: