DeviceVM, Inc. Privacy Policy

Thank you for visiting DeviceVM, Inc.'s ("DeviceVM") Internet web site ("Site") located at the URL: http://www.splashtop.com ("Site").  This Privacy Policy details certain policies implemented throughout our company governing DeviceVM's use of personally identifiable information about users of our Site and users of our services and/or products ("Product" or "Products").

Privacy Policy Updates

Due to the Internet's rapidly evolving nature, DeviceVM may need to update this Privacy Policy from time to time. If so, DeviceVM will post its updated Privacy Policy on our Site located at http://www.splashtop.com/privacy/01.html 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 this Site and the Products. If you do not cease using this Site and the Products, you will be deemed to have accepted the change.

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 services and Products we provide to our users, administer the Site and gather broad demographic information for aggregate use.

Information Collection

Through the Site:
You can generally visit our Site without revealing any personally identifiable information about yourself. However, in certain sections of this Site, we may require you to complete a registration form. In the registration process, we will collect personally identifiable information such as your password, user identification name, and email address and any other information that you voluntarily transmit with your communication to us.

Through the Products:
Each Product contains a unique application number. The first time you use a Product, this unique application number and an activation time stamp is transparently collected by DeviceVM's servers. In addition, as part of the installation process when you first use the Product, you will have the option of helping DeviceVM improve the Product by authorizing DeviceVM 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. The information collected from your use of the Product will be correlated to your unique application number. You may decline to provide such information when you install the Product. You may also "opt-in" to or "opt-out" of providing such information about your use of the Product after the installation process through the Products configuration tools. Additionally, when you use our Products, you will also have the option of submitting personally identifiable information during the installation process such as your name, email address, geographic location, gender and age group, which helps us personalize the services we provide to you and improve the Products. Submitting such personally identifiable information to DeviceVM is voluntary and all information fields are optional, and we will only use such information as described in this Privacy Policy. DeviceVM may also provide you with the ability to submit your personally identifiable information after the installation process through the Products configuration tools.

Information Use

DeviceVM uses the unique application number associated with the Product you are using to deliver updates to you and to track how many copies of the Product are being used. In addition, if you have agreed to allow DeviceVM to collect information about your use of the Product, DeviceVM may use such usage statistics and technical information about your computer and system software and information about the Product version you use to deliver updates to you and improve the Products. DeviceVM may use the personally identifiable information that you submit during the installation process and/or through the Products configuration tools in an aggregate manner for DeviceVM's marketing purposes. We may also use your personally identifiable information you submit to the Site 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, provide you with notices regarding goods, services and/or Products that you have purchased or may wish to purchase in the future, contact you with regard to your "opt-in" choices (as set forth below) and for targeted advertising. We may combine personally identifiable information with non-personally identifiable information to enable us to attribute usage of the services and/or Products to a particular computer or network for internal business purposes only. DeviceVM will not share such correlated information with third parties without your permission.

Choice to Opt-In

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 provide your personally identifiable information and/or the aggregate information to parent, subsidiary or affiliate entities within DeviceVM's corporate family, partner entities that are not within DeviceVM's corporate family, vendors and service agencies that we may engage to assist us in providing our Products and services to you and marketing, advertising or research firms that we may engage to assist in creating and delivering our targeted advertising. For example, we may provide your personally identifiable information to a credit card processing company to process your payment or to services agencies who provide browser services related to DeviceVM's Products. We will also disclose your personally identifiable information (a) only 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 DeviceVM 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 except we may transfer your personally identifiable information to a successor entity upon a merger, consolidation or other corporate reorganization in which DeviceVM participates or to a purchaser of all or substantially all of DeviceVMs assets to which this Site relates.

Children's Privacy

DeviceVM recognizes the privacy interests of children and we encourage parents and guardians to take an active role in their children's online activities and interests. This Site is not intended for children under the age of 13. DeviceVM does not target its services or this Site to children under 13. DeviceVM does not knowingly collect personally identifiable information from children under the age of 13.

Cookies

We may use small text files called cookies to improve overall Site experience. A cookie is a piece of data stored on the user's hard drive containing information about the user. Cookies generally do not permit us to personally identify you.

Aggregate Information

The Site may track the total number of visitors to our Site, the number of visitors to each page of our Site, browser type, IP addresses, External Web Sites (defined below) linked to, and we may analyze this data for trends and statistics in the aggregate, but such information will be maintained, used and disclosed in aggregate form only and it will not contain personally identifiable information. We may use such aggregate information to analyze trends, administer the Site and gather broad demographic information for aggregate use.

Disclosure

We may provide your personally identifiable information and the aggregate information to parent, subsidiary or affiliate entities within DeviceVM's corporate family, partner entities that are not within DeviceVM's corporate family, vendors and service agencies that we may engage to assist us in providing our products and services to you and marketing, advertising or research firms. For example, we may provide your personally identifiable information to a credit card processing company to process your payment. We will disclose your personally identifiable information if we reasonably believe we are required to do so by law, regulation or other government authority. We may transfer your personally identifiable information to a successor entity upon a merger, consolidation or other corporate reorganization in which DeviceVM participates or to a purchaser of all or substantially all of DeviceVM's assets to which this Site relates.

Choice to Opt-In

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.

Links to Third Party Sites

The Site may provide links to other Web sites or resources over which DeviceVM does not have control ("External Web Sites"). Such links do not constitute an endorsement by DeviceVM of those External Web Sites. You acknowledge that DeviceVM is providing these links to you only as a convenience, and further agree that DeviceVM is 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. Such measures are reasonably designed to help protect your personally identifiable information from loss, unauthorized access, disclosure, alteration or destruction. DeviceVM may use firewalls, password protection, encryption, secure socket layer and take other physical security measures and place internal restrictions on who within DeviceVM may access your data to help prevent unauthorized access to your personally identifiable information.

Correction/Deletion/Updating Personally Identifiable Information

Personally Identifiable Information Collected Through the Products:
DeviceVM may also provide you with the ability to modify and delete the personally identifiable information you have submitted through the Product via the Products configuration tools.

Personally Identifiable Information Collected Through the Site:
DeviceVM provides you with the ability to review, correct and delete your contact information that you have provided to us through the Site and information regarding your previous activity on the Site, including purchase, download and payment activity; provided, however, that DeviceVM will retain a copy in its files of all personally identifiable information, even if removed, in order to resolve disputes or enforce its terms of use. If you wish to review, correct or request the deletion of the foregoing information, you may access your account and review, correct and delete your personally identifiable information or 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


If you have any questions regarding this Privacy Policy please contact us via email at: privacy@splashtop.com. 



Our computer systems are currently based in the United States, so your personal data will be processed by us in the U.S. where data protection and privacy regulations may not offer the same level of protection as in other parts of the world, such as the European Union.  If you create a user account with the Site as a visitor from outside the United States, by using the Site you agree to this Privacy Policy and you consent to the transfer of all such information to the United States, which may not offer an equivalent level of protection of that required in the European Union or certain other countries, and to the processing of that information as described in this Privacy Policy.



This Privacy Policy was last updated: November 11, 2007. 



This Privacy Policy is effective as of: October 10, 2007