Effective Date: January 31, 2012

Please read the following to learn more about our Privacy Policy. By visiting Accellion’s web site, submitting information to Accellion or using any of our products or services, you acknowledge that you accept the practices and policies outlined in this Privacy Policy.
 
Accellion complies with the U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland (the “Safe Harbor Frameworks”). Accellion has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view Accellion’s certification, please visit http://www.export.gov/safeharbor/
 
What Personal Information Does Accellion Collect?
 
The information we gather from customers enables us to provide, personalize and improve our services for users of the services. We do not collect, access or disclose any information, including Personal Information, that may be included in content or files you store or send using Accellion services except at your request, in response to legal process, or where required to do by applicable law, but we do collect the following types of information from our customers.
 
Personal Information You Provide to Us
 
We may receive and store any information you enter on our web site or provide to us in any other way. The types of Personal Information collected include your full name, address, company, email address and telephone number, and if you order products from us through our website, any financial and commercial information you provide for that purpose. The Personal Information you provide may be used for such purposes as responding to your requests for certain products and services, customizing the content you see, and communicating with you about specials, sales offers, and new products. We may also compare our customer list to lists received from other companies, in an effort to avoid sending unnecessary messages to our customers. 
 
Anonymous Information Collected Automatically
 
We may receive and store certain types of information whenever you interact with our web site or services. For example, Accellion may choose to automatically receive and record information on our server logs from your browser including your IP address, Accellion cookie information, and the page you requested. We may receive a confirmation when you open an email from Accellion if your computer supports this type of program.
Generally, our service may automatically collect usage information, such as the numbers and frequency of visitors to our site and its components. Accellion generally only uses this data in aggregate form, that is, as a statistical measure, and not in a manner that would identify you personally. However, if you have registered with Accellion using our site and your browser accepts cookies, Accellion may automatically collect individualized information regarding your visits to Accellion’s site (“Individual Site Usage Information”) to provide you with a more personalized customer experience. As part of this use of information, we may provide aggregate information to our partners about how our customers, collectively, use our site. If you do not wish to have your Individual Usage Information collected, please see the “What About Cookies” section below for further information.
 
What About Cookies?
 
Cookies are alphanumeric identifiers that we may transfer to your computer’s hard drive through your browser to enable our systems to recognize your browser and tell us how and when pages in our site are visited and by how many people. Accellion cookies do not collect Personal Information; however, we may combine the general information collected through cookies with other Personal Information in connection with our collection of Individual Site Usage Information (as described above). If you do not wish to have your Individual Site Usage Information collected, most browsers have an option for turning off the cookie feature, which will prevent your browser from accepting new cookies, as well as (depending on the sophistication of your browser software) allowing you to decide on acceptance of each new cookie in a variety of ways. Please be aware that disabling cookies may reduce your ability to access certain portions of the Accellion website, and that by disabling cookies, you are agreeing not to access those portions of the Accellion website. In addition, we may also record the pages you visit on the website through the use of pixel tags (also called “clear gifs” or “beacons”).
 
Will Accellion Share Any of the Personal Information it Receives?
 
We neither rent nor sell your Personal Information to anyone. We share your Personal Information only with your consent or to business partners and affiliates as described below:
 
Agents: We may employ other companies and people to perform tasks on our behalf and need to share your information with them to provide products or services to you. Unless we tell you differently, Accellion’s agents do not have any right to use Personal Information we share with them beyond what is necessary to assist us. You hereby consent to our sharing of Personal Information for the above purposes.
 
Business Transfers: In some cases, we may choose to buy or sell business assets. In these types of transactions, customer information is typically one of the business assets that is transferred. Moreover, if Accellion, or substantially all of its assets, were acquired, customer information would be one of the assets that is transferred or acquired by a third party. You acknowledge that such transfers may occur, and that any acquirer of Accellion may continue to use your Personal Information as set forth in this policy.
 
Protection of Accellion and Others: We may release Personal Information when we believe in good faith that release is necessary to comply with any law; enforce or apply our terms of use and other agreements; or protect the rights, property, or safety of Accellion, our employees, our customers, or others. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction.
 
Security
 
Accellion takes appropriate steps to ensure data privacy and security including through various hardware and software methodologies. However, due to the open communication nature of the Internet, we cannot guarantee that communications between you and the Accellion website, and the Accellion website and you, will be free from unauthorized access by third parties. Users of the Accellion website do so at their own risk with respect to such communications. 
 
Dispute Resolution
 
If you have any complaints regarding our compliance with the Safe Harbor Frameworks, you must first contact us atmarketing@accellion.com. Accellion will investigate and attempt to resolve complaints and disputes regarding use and disclosure of Personal Information.  For complaints that cannot be resolved between Accellion and the complainant, Accellion will cooperate with JAMS pursuant to the JAMS International Mediation Rules.
 
Beta Programs
 
We sometimes release beta versions of our website and related services, which are further refined before the release of the final version. Because the website and services are still in a test phase, we may not always catch an unintended privacy issue, despite our efforts to do so. As such, we welcome user feedback on any privacy concerns you may have. In light of the above and because of the complex and constantly changing nature of the internet and related technology, Accellion does not guarantee error-free performance under this Privacy Policy. To the extent permissible under law, Accellion and third parties providing services to you in connection with the Accellion website, shall not be liable for any incidental, consequential or punitive damages relating to this Privacy Policy.
 
Children
 
Accellion requests that children under the age of 18 not use the Accellion website nor submit any personal information to the Accellion website. Accellion does not knowingly collect personal information from children under the age of 13. Since information regarding children under the age of 13 is not collected, Accellion does not knowingly use or distribute personal information regarding children under the age of 13. If Accellion obtains actual knowledge that it has collected personal information about a child under the age of 13, that information will be immediately deleted from our database.
 
Changes to this Privacy Policy
 
Accellion may amend this Privacy Policy from time to time. Use of information we collect now is subject to the Privacy Policy in effect at the time such information is collected. If we make changes in the way we use Personal Information, we will notify you by posting an amendment to the Privacy Policy on the website. Such modifications will become effective on the day they are posted. Accellion encourages you to frequently review this Privacy Policy for any modifications.
 
Email Communications & Opt-Out
 
If you wish to: (i) remove your personally identifiable information from our system in order to stop receiving information from us, (ii) update your Personal Information, or (iii) have any questions about this privacy statement, the practices of this site, or your dealings with this website, please send us a detailed message (with sufficient information for us to identify your Personal Information) at marketing@accellion.com. We will make every effort to resolve your concerns.  If you’ve registered with Accellion online and request that all of your Personal Information be expunged, you acknowledge that Accellion may terminate your account without any Accellion service without liability to you.