IOCOM PRIVACY STATEMENT

February 2009
inSORS Reference: PS — 09-02

Generally

This Privacy Policy describes how inSORS Integrated Communications, Inc, doing business as IOCOM, uses and safeguards information that you provide to it. By subscribing to IOCOM Services or by otherwise accepting a license under, or using, IOCOM Software, you agree to this Privacy Policy. If you do not want your information used in the manner described in this Privacy Policy, do not use any IOCOM Software or Services.

As used in this Privacy Policy, “IOCOM Services” means any products or services supplied to you by IOCOM that provide collaboration or other communication functionality, and "IOCOM Software" means any computer programs to which IOCOM grants you access. An IOCOM Affiliate is any corporation or other entity that, now or in the future: directly or indirectly controls, is controlled by, or is under common control with, IOCOM or that has entered into a distribution agreement with IOCOM and agreed to comply with the terms of this Privacy Policy. “Control” means the direct or indirect ownership of more than 50% of the outstanding voting stock or rights of a corporation or other entity.

IOCOM takes your privacy seriously. IOCOM is committed to complying with all applicable laws and regulations and to cooperating with all governmental authorities.

User Information and Its Use

IOCOM or an IOCOM Affiliate may gather and process information about you, including, for example, the following “User Information”:

Identification Data (e.g., name; address; telephone number; email address)
Profile Data (e.g., age; sex; country or area of residence)
Usage Data (e.g., the starting times and durations of your IOCOM collaboration sessions; who participated in your sessions)
Banking and Payment Information (e.g., credit card account numbers; payment history)
Order History (e.g., information regarding subscriptions, licenses and products that you obtain from IOCOM)
Referrals (e.g., information regarding other persons that you elect to send to IOCOM)
Survey Results (e.g., answers voluntarily given to Survey Questions)

IOCOM or an IOCOM Affiliate may collect and process User Information regarding you, to the extent allowed by all relevant laws and regulations, in order to further the following “Purposes”:

Provide communication services and support to IOCOM's current and prospective customers
Take, process and deliver orders for subscriptions to IOCOM Services or otherwise to license IOCOM Software
Verify your identity
Improve IOCOM Software and Services
Protect IOCOM's legitimate business interests, including, in particular, to enforce any IOCOM Subscription Agreement or IOCOM Software License Agreement (or any other contract between you and IOCOM) and protect IOCOM against fraud and other improper actions
Resolve disputes
Plan and implement IOCOM marketing and promotional operations, including, for example, obtain feedback regarding IOCOM Software and Services and provide information to you and others about present or future IOCOM Software and Services.

Except as provided otherwise in this Policy, User Information will only be accessed by authorized employees of IOCOM, an IOCOM Affiliate or a third-party banking organization or other provider of payment services, in order to further the Purposes identified above. IOCOM, IOCOM Affiliates and the providers of IOCOM payment services will all take appropriate organizational and technical measures to protect User Information and comply with all relevant laws and regulations.

Certain User Information may be combined into Aggregated, Anonymous Data that does not identify you, or any other individual, personally. IOCOM may share Aggregated, Anonymous Data with third parties in order to further the Purposes identified above. Such third parties will not have access to any User Information that specifically identifies you or any other individual. Such third parties will take appropriate organizational and technical measures to protect the Aggregated, Anonymous Data and comply with all relevant laws and regulations.

IOCOM or an IOCOM Affiliate may contact you (via email, telephone, postal mail or otherwise): to advise you of information regarding IOCOM Software and Services (including faults, service issues, and IOCOM Software updates) and to ask you Survey Questions (which may request, for example, that you provide information regarding yourself and your experience with IOCOM Software and Services). You are under no obligation to provide information in response to Survey Questions. You may make an election not to be so contacted simply by sending an email to no-information@IOCOM.com, advising IOCOM that you prefer not to receive the information or Survey Questions. To the extent that you make such an election and you are receiving a complementary, trial, or other reduced-fee license to use IOCOM Software or Services, IOCOM has the right immediately to terminate both your license and your ability to use any IOCOM Software or Services, without any liability to you as a result of the termination.

Transfer of User Information to Third Parties

Except as provided elsewhere in this Privacy Policy, IOCOM will not sell, rent, or otherwise transfer User Information to any third party without your explicit permission, unless one or both of the following conditions are met:

IOCOM is obliged to do so under applicable laws or regulations (or is requested or ordered to do so by a competent governmental authority). In the event that a competent governmental authority requests or orders IOCOM to retain or provide User Information, IOCOM will provide all reasonable assistance required to fulfill its legal obligations.
IOCOM has in good faith belief that such action is necessary to investigate or protect against harmful or unauthorized activities involving others or others' property (including IOCOM and your use of IOCOM Software and Services).

Storage and Processing of User Information

IOCOM will retain User Information to further the Purposes identified above, but will not retain it any longer than permitted under the relevant laws and regulations. IOCOM does not represent that User Information will necessarily be maintained for any length of time. If your IOCOM Subscription or other license to use IOCOM Software or Services is terminated, IOCOM will continue to safeguard your User Information as described in this Privacy Policy.

User Information may be stored and processed in any country in which IOCOM or IOCOM Affiliates maintain a facility, including outside of the European Union (“EU”). IOCOM reserves the right to transfer User Information outside of your country and outside of the EU. By using IOCOM Software or Services, you consent to the transfer of User Information outside of the EU.

IOCOM retains the right to treat User Information as a business asset in the event that IOCOM, or substantially all of its assets, are acquired by a third party. Such an acquisition may occur, for example, through the operation of an acquisition, merger or other corporate restructuring. In such a case, User Information may be deemed a business asset by both IOCOM and the third party acquirer, and User Information may be acquired and used by the third party as a “business asset.

IOCOM software may be stored on your computer. IOCOM may also store cookies on your computer to help IOCOM Software recognize you and your preferences. IOCOM's cookies may contain User Information, enabling IOCOM to obtain information about your use of IOCOM Software and Services.

While using IOCOM Software and Services, you may choose to release personal information to third parties. IOCOM urges you to exercise caution before doing so, particularly since IOCOM collaboration sessions could be recorded by meeting participants, with or without your knowledge. For example, a participant in an IOCOM collaboration session may have the ability to record and store the content of an IOCOM collaboration session using third-party software or equipment. A participant in an IOCOM collaboration session may also be able to record and store the content of an IOCOM collaboration session using IOCOM Software and Services. To the extent that IOCOM Software and Services are used to effect the recording of a collaboration session, a dot followed by the term, REC (i.e., “·REC”), will appear in red on the screen of each endpoint device participating in the session. If you see such a notice and do not want images and sound from your endpoint so recorded and stored, do not to participate in the collaboration session.

Further, IOCOM Software and Services necessarily utilize the Internet. The Internet is an open system, and IOCOM cannot and does not warrant that third parties cannot or will not intercept information transmitted via the Internet.

Access to and Correction of User Information

Provided that IOCOM can, with reasonable business effort, verify your identity, you have the right (a) to access your User Information maintained by IOCOM and correct any such User Information that is incorrect in a material way and (b) to have IOCOM remove certain of your User Information from IOCOM databases. To the extent that you desire IOCOM to delete any User Information regarding yourself from IOCOM databases, IOCOM has the right immediately to terminate both your license and your ability to use any IOCOM Software or Services, without any liability to you as a result of the termination.

If you would like to (a) view or correct your User Information, (b) remove your personally identifiable identifiable information from the database(s) of IOCOM and IOCOM Affiliates (to the extent not required, e.g., for billing purposes), or (c) follow up on an unresolved privacy issue, please contact IOCOM either by sending an email to consumerhotline@IOCOM.com or by sending a letter to
Consumer Affairs Officer
inSORS Integrated Communications, Inc.
111 West Jackson Boulevard
Chicago, IL 60604.

Modification of This Privacy Policy

IOCOM reserves the right to modify this Privacy Policy. IOCOM will inform you of any such modification by publishing a modified Privacy Policy at http://www.iocom.com/privacy. The modified Privacy Policy will become effective thirty days after such publication. Your use of the IOCOM Software or Services thirty days after such publication (or earlier, upon your express acceptance of the modified Privacy Policy within the thirty-day period) constitutes an acceptance of the modified Privacy Policy.

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