Privacy Policy

DATED 2023-05-30 · VERSION 20230601_rev01 · COMPARED WITH 20230326_rev01 · ARCHIVE SNAPSHOT

Full text changes — 20230326_rev01 to 20230601_rev01

COLOUR MARKS THE SEVERITY OF A FLAGGED CLAUSE · + AND − MARK ADDED AND REMOVED

+This privacy policy applies to customers in Global service region (using [my.splashtop.com](https://my.splashtop.com/)). The [EU Privacy Policy](https://splashtop.com/legal/privacy-policy-eu) applies to customers using our EU service region (using [my.splashtop.eu](https://my.splashtop.eu/)). You can [find your service region by following the steps here](https://support-splashtopbusiness.splashtop.com/hc/articles/360043945732-How-to-find-the-service-region-info-).
+This is a global Privacy Policy. Certain sections may only apply to you if you are located in certain parts of the world such as the EU, or California.
+#### **1\. Introduction**
+**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.
+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 Services (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 any other websites operated by Splashtop and/or its affiliates that contain a 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.
+At Splashtop, we aim to be transparent about how your personal information is collected, used, and/or shared. The purpose of this Policy is to inform you of the types of personal information we may collect from you and how that information will be used. Splashtop collects certain personal information through its Websites as well as its family of products and/or related services (each a "Service" or the "Services"). Except as expressly set forth in this Policy, Splashtop will not use your information in any other manner or for any other purpose.
+#### **2\. Scope of This Policy**
+If your data is governed by EU data protection law, the Controller responsible for the processing of your personal data is Splashtop B.V., having its registered office in (1019 GM) Amsterdam, the Netherlands, at Piet Heinkade 135.
+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.
+If you have any questions or wishes in connection with your personal data or with our privacy practices, you may contact us at [privacy@splashtop.com](mailto:privacy@splashtop.com).
+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.
+**2\. Scope of This Policy**
+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.
+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 Services shall be limited to the purpose of providing the Services for which the Subscriber has engaged.
+#### **3\. Acceptance of the Privacy Policy**
+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 are not responsible for the privacy practices of such other websites and we encourage you to review the privacy statements of any such other websites to understand their information practices.
+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/legal/terms-of-service](https://splashtop.com/legal/terms-of-service), and Splashtop Terms of Use for use of our Websites, which are available at [https://www.splashtop.com/legal/website-terms](https://splashtop.com/legal/website-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.
+In certain cases, we may process your personal information as a Processor or Service Provider on behalf of our client Subscribers. 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.
+#### **4\. Privacy Policy Updates**
+**3\. 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/legal/privacy-policy](https://splashtop.com/legal/privacy-policy). 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.
+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/legal/privacy-policy](https://splashtop.com/legal/privacy-policy). We may also send registered users of the Websites email notifications notifying such users of any changes to the Policy.
+#### **5\. Information We Collect From You on our Websites**
+**4\. What 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.
+When visiting our Websites, 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:
+In addition, 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/legal/cookie-policy](https://splashtop.com/legal/cookie-policy).
+We and our authorized partners may place cookies and other information gathering technologies on your browser. These technologies provide us with personal information, including 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/legal/cookie-policy](https://splashtop.com/legal/cookie-policy). If you are in the EU or UK, cookies will be placed only after you have agreed to their being placed. You may opt-out or block cookies at any time.
+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 [https://preferences-mgr.truste.com](https://preferences-mgr.truste.com/) (or if located in the European Union you may opt-in the use of cookies, by clicking [https://www.youronlinechoices.eu/](https://www.youronlinechoices.eu/)).
+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 [https://preferences-mgr.truste.com](https://preferences-mgr.truste.com/) .(or if located in the European Union you may opt-in the use of cookies, by clicking ).
+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 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. If you are located in the European Union or the UK, we will only use such technologies if you have consented to their use.
+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 to collect and store information.
+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 to collect and store information. For further information on how to manage Flash LSOs please visit [https://www.macromedia.com/support/documentation/en/flashplayer/help/settings\_manager07.html](https://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.
+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. Splashtop requires this information in order for the Website and Services to work as optimally as possible (for example, to display content correctly and to keep the Website and Services secure), the processing of these personal data is therefore necessary for the purposes of the legitimate interests pursued by Splashtop and are stored for 1 year.
 **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.
+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. The processing of personal data is necessary for the purposes of the legitimate interests pursued by Splashtop, in order to improve services and will not be retained for longer than 2 years.
+#### **6\. Information We Collect from Subscribers through our Services**
+**5\. What Information We Collect From You if you apply for a job with us**
+**Account and Registration Information:**
+If you apply for a position at Splashtop, you will provide your personal data such as your first and last name, full address, email address, phone number and your CV and other attachments to your application. Splashtop uses this information to review your application and respond to your application. The processing of these personal data is necessary to enter into a contract to which you are a party and for the purposes of the legitimate interests pursued by Splashtop, namely recruitment. Splashtop retains your personal data for 4 weeks after rejection or, with your consent, for a period of 2 years.
+**6\. 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.
+We refer to any information described above as "Account Information" for the purposes of this Policy. The processing of your Account Information in this context is necessary for the performance of a contract to which you are a party in connection with the use of our Service. You cannot register for an Account and make use of our services without providing us with these personal details. Except for Financial Records such as your name, billing and shipping address, invoice records, and/or agreements between you and Splashtop ("Financial Records"), your Account Information is stored for as long as you have an Account and will be deleted by contacting privacy@splashtop.com. Splashtop has a legal obligation to retain Financial Records for a period of 7 years from the date of the invoice transaction.
 **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.
+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. The processing of personal information is necessary for the purposes of the legitimate interests pursued by Splashtop, in order to interact with you. Your personal data is stored for a period of one month after responding to your message, resolving your issue or the end of the survey, contest, promotion, sweepstake or program.
+**Newsletters:**
+If you have signed up for Splashtop's newsletters, we will send you information on the development of our Services. If, at any moment, you do not wish to receive emails of Splashtop anymore, you can unsubscribe by using the opt-out option that is provided in every email that we send you. You may also unsubscribe by sending an email to [privacy@splashtop.com](mailto:privacy@splashtop.com). To subscribe, you have to provide us with your email address. We process this personal information on the basis of your consent, which you may withdraw at any point through unsubscribing. We retain your e-mail address and the data that show that you have signed up for the newsletter for as long as you are subscribed to the newsletter and no longer than 1 year after you unsubscribe.
 **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.
+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. The processing of your personal data is therefore necessary for the performance of a contract to which you are a party. You cannot register for an event without providing us with these personal details. Your personal information is deleted in accordance with Newsletters section of this policy.
 **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.
+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. Splashtop requires this information in order for the Services to work as optimally as possible (for example, to display content correctly and to keep the Services secure), the processing of these personal data is therefore necessary to perform our contract with you and can be transferred to customer or deleted by contacting [privacy@splashtop.com](mailto:privacy@splashtop.com).
+#### **7\. Information We Collect from Other Sources**
+**7\. 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.
+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. If your personal information is governed by EU or UK data protection laws, Splashtop will only allow such data processing if you have consented to cookies (see section 4 above).
 **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.
+#### **8\. Information Use**
+**8\. How we use your personal Information**
 **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](mailto: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.
+We 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](mailto: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:**
+**9\. 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.
+We collect your personal information only where one or more of the following apply: (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 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](mailto:privacy@splashtop.com).
+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 wish to withdraw your consent or 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](mailto:privacy@splashtop.com).
+#### **9\. Choice to Opt-In**
+**10\. Sharing of Information Collected**
+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.
+#### **10\. 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 [https://www.splashtop.com/legal/terms-of-service](https://splashtop.com/legal/terms-of-service), or as otherwise required by law.
+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 [https://www.splashtop.com/terms/splashtop](https://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](mailto:privacy@splashtop.com).
+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](mailto: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.
+#### **11\. Communications Preferences**
+**11\. How Long We Retain Your Personal Information**
+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](mailto:privacy@splashtop.com).
+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 completed automatically after a period of 2 years.
+#### **12\. 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.
+#### **13\. Your Privacy Rights**
+**12\. 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](mailto: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](mailto: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](mailto:privacy@splashtop.com). Requests to access, change, or remove your information will be handled within thirty (30) days.
+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](mailto: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](mailto: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](mailto: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](mailto: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:**
+**Additional Rights for EEA and UK:**
 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 Access: You have the right to obtain information about what personal information process about you.
+Right to rectification: You have the right to request the rectification of inaccurate personal information concerning you.
 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.
+Right to withdraw consent: Where the processing of your personal information is based on your consent, you have the right to withdraw your consent at any time. In such case, we will stop processing your data immediately.
+If you would like to exercise such rights, please contact us at [privacy@splashtop.com](mailto:privacy@splashtop.com) . 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. These rights may not be exercisable where they conflict with the rights of Splashtop, Splashtop staff and clients, or others, including but not limited to certain proprietary rights, rights to fair proceedings, confidentiality rights, conflicting privacy rights.
+We will respond to your request without undue delay and under usual circumstances within 1 month of receipt of your request; however, our response time may be extended by 2 additional months where necessary, taking into account the complexity of the matter and the volume of pending requests. If an extension to our typical response time is necessary, we will notify you within 1 month of receipt of your initial request, together with the reason(s) for the delay.
+If we determine that no action will be taken regarding your request, we will inform you without delay and at the latest within 1 month of receipt of your request along with the reason(s) for our refusal to take action. In such case, you will have the right to lodge a complaint with the appropriate supervisory authority and to seek a judicial remedy.
+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).
 **Additional Rights for State of California:**
+The California Consumer Privacy Act ("the CCPA") took effect January 1st, 2020. We are committed to protecting your privacy and complying with the CCPA. If you are a California consumer, the CCPA provides you with specific rights regarding your Personal Information:
 Categories of Personal Information Collected: In the preceding 12 months, we have collected the categories of personal information listed below. Note that not all categories of information are collected from all people.
+- Identifiers, such as name, email addresses, Internet Protocol address, account name, or other similar identifiers
+- Identifiers, such as name, email addresses, Internet Protocol address, account name, or other similar contact information identifiers
+- Categories of personal information described in the California Customer Records statute (California Civil Code Section 1798.80), including telephone number, postal address, payment information and, for employment candidates, education and employment history
+- Categories of personal information described in the California Customer Records statute (California Civil Code Section 1798.80), including name telephone number, postal address, payment information and, for employment candidates, education and employment history
 - Commercial information, including product usage data, records of products or services purchased or considered, or purchasing habits
+- Internet and other similar network activity, such as browsing history on our web sites or information regarding interaction with our web sites, emails or products
+- Internet and other similar network activity, such as browsing history on our web sites or information regarding interaction with our web sites, emails or products, inferences - including information about your interests, preferences and favorite brands and products
+- Customer records, billing address, credit or debit card information,
 - Geolocation data
+- Professional or employment-related information from employment candidates
+- Professional or employment-related information from consumers and employment candidates including job title and business contact information
+Your Rights: Under the California Consumer Privacy Act of 2018 ("the CCPA"), California consumers have the right to request access to the specific pieces of personal information we have collected about them in the last 12 months. You may also request additional details about our information practices, including the categories of personal information we have collected about you, the categories of sources of such collection, the business or commercial purpose for collecting personal information, the categories of third parties with whom we share your personal information, the categories of personal information we have disclosed about you in the preceding 12 months. If you are a California consumer, you also have the right to request deletion of your personal information (subject to certain exceptions), to opt out of sales of personal information, and to receive equal service and price and not be discriminated against if you choose to exercise your rights under the CCPA. California consumers may make a rights request by sending a request via the email and postal mail contact options at the bottom of this privacy policy. Your request must include sufficient information that allows us to reasonably verify you are the person about whom we collected personal information, which may include your email address, name and Splashtop account email address (which is required only if you already have an account with us).
+Your Rights: Under the CCPA, California consumers have the following rights: Right to request access to the specific pieces of personal information we have collected about them within the last 12 months. You may also request additional details about our information practices, including the categories of personal information we have collected about you, the categories of sources of such collection, the business or commercial purpose for collecting personal information, the categories of third parties with whom we share your personal information, the categories of personal information we have disclosed about you in the preceding 12 months; Right to request rectification of and deletion of your personal information (subject to certain exceptions);
+Sale of Personal Information: **We do not sell any of your personal data to third parties**. If in the future we anticipate selling your personal information to any party, we will provide you with the opt-out and opt-in rights required by the CCPA.
+Right to object to processing;
+Further disclosures: For further disclosures regarding your personal information, as required by the CCPA, please refer to the remainder of this privacy policy. You can find information about the business and commercial purposes for which we collect your personal information, the sources from which we collect personal data, and information about the categories of third parties to whom we disclose your personal information to, as well as information regarding which categories of personal information are being disclosed.
+Right to data portability;
+#### **14\. International Transfer Of Information Collected**
+You may opt out of the selling of your personal information and behavioral profiling including automated decision making.
+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 choose to exercise your rights under the CCPA, Splashtop will not discriminate against you and you will continue to receive the same access to and pricing for the Services as any person who has chosen not to exercise their rights under the CCPA.
+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.
+California consumers may make reasonable rights requests free of charge by sending a request via the email and postal mail contact options at the bottom of this privacy policy. Your request must include sufficient information that allows us to reasonably verify you are the person about whom we collected personal information, which may include your email address, name and Splashtop account email address (which is required only if you already have an account with us). Within 45 days of receiving a viable request, Splashtop shall complete the requirements of the request and submit all relevant documentation needed to confirm completion to the requestor. If reasonably necessary to complete a request, an extension of 45 days will be added after providing the requestor notice of extension.
+#### **15\. Children's Privacy**
+Sale and Sharing of Personal Information: **We do not sell any of your personal data to third parties in the ordinary sense of the term 'sell'**. We do, however, share your personal information for the purposes outlined in this privacy policy with our approved processors. We also use website analytics services that may process personal information that may constitute a 'sale' under CCPA. You may opt out of that at any time by blocking cookies on our website. Please refer to our subprocessor list for more information.
+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.
+Further disclosures: For further disclosures regarding your personal information, as required by the CCPA, please refer to the remainder of this privacy policy. You can find information about the business and commercial purposes for which we collect your personal information, the sources from which we collect personal data, and information about the categories of third parties to whom we disclose your personal information to, as well as information regarding which categories of personal information are being disclosed.
+#### **16\. Links to Third Party Sites**
+**13\. International Transfer Of Information Collected**
+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.
+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. Some of our service providers are located outside the European Economic Area (EEA), including the United States, Taiwan and China. To comply with EU data protection laws around international data transfer, service providers outside the EEA are only allowed to process your personal data in accordance with a contract entered into between Splashtop and the service provider, incorporating the European Commission's Standard Contractual Clauses, which ensure that adequate data protection arrangements are in place (Article 46.1(c) GDPR), or if another safeguard for international transfer detailed in GDPR Chapter V applies. For more information on where and how the relevant document may be accessed or obtained, please contact us.
+#### **17\. Security**
+**14\. Children's Privacy**
+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.
+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 are 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. If you become aware that we are processing the personal information of children under the age of 13, please contact us and we will delete such data as soon as possible.
+#### **18\. Correction/Deletion/Updating Personally Identifiable Information**
+**15\. Links to Third Party Sites**
+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.
+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 for convenience only. 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.
+If you have any questions regarding this Policy please contact us:
+**16\. Security**
+**By e-mail**:
+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. We employ procedural and technological measures, consistent with industry practices 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 use firewalls, password protection, encryption, secure socket layer and take other physical security measures and place internal restrictions on whom within Splashtop may access your data to help prevent unauthorized access to your personally identifiable information. You may find additional details about our technical and organizational measures here: [https://www.splashtop.com/security/practices/technical-and-organizational-measures](https://splashtop.com/security/practices/technical-and-organizational-measures).
+[privacy@splashtop.com](mailto:privacy@splashtop.com)
+If you have any questions regarding this Policy please contact us:
+**By mail**:
+**By e-mail**: privacy@splashtop.com
+North Wolfe Road,
+**By mail**: 10050 North Wolfe Road, Suite SW2-S260,
+Suite SW2-S260,
 Cupertino, CA 95014
+**By phone**:
+**By phone**: 408-861-1088
+-861-1088
+This Policy was last updated: May 30, 2023
+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: April 20, 2021
+_This agreement may be translated into different languages. In case of any conflicts or inconsistencies between the English version or any translation hereof, the English version shall prevail and govern._
+_This policy may be translated into different languages. In case of any conflicts or inconsistencies between the English version or any translation hereof, the English version shall prevail and govern._