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Privacy Policy

General Information
PowerFile respects the privacy of our customers, business partners, employees, job applicants, and other visitors to our websites who may choose to provide personal information. We recognize the need for appropriate protections and management of personal information that you provide to us. This Privacy Statement will assist you to understand what types of information we may collect, how that information may be used, and with whom the information may be shared.

Scope
This Privacy Statement applies to PowerFile Corporation.

Information we may process about clients of our customers is dealt with separately. For details of this please see the section entitled "Personal information of our customer's clients" below.

What Personal Information Does PowerFile Process?
Personal Information is information that identifies or can identify a specific individual. PowerFile may collect information about individuals such as their name, address, telephone number or e-mail address. PowerFile may collect certain personal information from customers, business partners, employees and candidates for employment. PowerFile does not collect personal information when you visit PowerFile's web sites unless you choose to provide it to PowerFile.

Customers and Business Partners — On PowerFile web sites you can register products, request information, subscribe to marketing or support materials, register to a secure extranet site to obtain access to product information, support, services, and training. PowerFile will collect personal information from you for these purposes. The types of information you provide to PowerFile on these pages may include name, address, phone number, e-mail address, user IDs and passwords, and contact preferences.

Employees and Applicants — PowerFile also collects personal information from its employees and applicants (human resources data) in connection with its recruiting and hiring activities and administration of its human resources programs and functions.

How Does PowerFile Use Customer and Business Partner Personal Information?
PowerFile will use personal information to provide customers and business partners with information and services and to help us better understand your needs and interests. Specifically, we use your information to help you complete a transaction or order, to communicate with you, to deliver products/services to you, to bill you for products/services you purchased, and to provide ongoing service and support. Occasionally we may use your information to contact you to complete surveys that we use for marketing and quality assurance purposes. Personal information collected online may be combined with information you provide to PowerFile through other sources such as trade shows or seminars. We may also use it to contact you by electronic or other means such as telephone or mail, to tell you about products and services of PowerFile or its subsidiaries and divisions, or, if we think this may interest you, or other parties.

PowerFile may share the personal information that you have submitted to PowerFile with third parties in responding to your requests for products or services or product evaluations. Also, we may on occasion share information to allow selected partners to send you special offers in blind mailings. If your information is sourced from within the EU, you will be given the opportunity to opt out of having your personal information used and/or shared for marketing purposes, or we will obtain your prior agreement to this as applicable under relevant laws. However, if you request information on any of our products/services, PowerFile may provide your information to third party distributors and resellers who may subsequently contact you directly regarding such products/services. In these instances, you will not have the opportunity to opt out of having your information shared with these third party distributors and resellers, as the transfer of data is necessary to provide the products or services you requested.

Some of PowerFile's websites make on-line newsgroups, chat forums and blogs available to our users. Any information that is disclosed in these forums becomes public information and you should exercise caution when deciding to disclose your personal information. PowerFile may, from time to time, send e-mail (in accordance with applicable laws) regarding our products and services to users who have posted to our newsgroups. Each participant's opinion expressed in a newsgroup is his or her own and should not be considered as reflecting the opinion of PowerFile. By posting in our newsgroups you expressly consent to these uses of your information.

Should we undergo any sort of corporate reorganization in the future, we may need to provide your information to the resulting entity. We may also provide it to law enforcement agencies if they request it or if we feel this is necessary to protect our business, employers, suppliers or customers. We will only do this once we are satisfied it is appropriate to do so.

How Does PowerFile Use Employee, Contractor and Job Applicant Personal Information?
PowerFile uses personal information of its employees, contractors, and job applicants for a variety of human resources and similar functions, including job applications and hiring programs, compensation and benefit programs, performance appraisals, training, business travel, expense and tuition reimbursement, identification cards, access to PowerFile facilities and computer networks, employee profiles, internal employee directories, human resources recordkeeping, compliance with legal requirements and other employment related purposes.

Unless permitted by relevant laws, or you have agreed to this, PowerFile does not use your personal information for a purpose other than as provided in this Privacy Statement or for the stated purpose identified at the time such information is collected, received or stored. Where appropriate under applicable laws, you will be given a more detailed explanation of these data uses at the relevant time.

Personal information given to PowerFile may be transferred within PowerFile or to its appointed business partners or service providers across state and country borders for efficient data consolidation, storage and simplified information management in accordance with applicable law.
We will place appropriate restrictions on the recipients and require them to adequately protect the information according to relevant laws.

With Whom Does PowerFile Share Personal Information?
PowerFile contracts with third party service providers and suppliers to deliver complete products, services and customer solutions. PowerFile may share personal information with its service providers and suppliers for the sole purpose and only to the extent needed to support the customers' business needs. Service providers and suppliers are required to keep confidential and secure the personal information received from PowerFile and may not use it for any purpose other than as originally intended.

Human resources data may be shared with third party vendors for the exclusive purpose of enabling the vendor to provide service or support to PowerFile in connection with these human resources programs and functions. Personal data concerning PowerFile employees is not shared with third parties for non-employment related purposes, unless disclosure of such information is reasonably necessary to comply with any applicable law, legal process, or enforceable governmental inquiry.

Third party vendors, service providers and suppliers receiving personal information are expected to apply the same level of privacy protection as contained in this Privacy Statement. However, unless otherwise dictated by law or agreement, PowerFile is not responsible for any improper use by such parties.

Unless permitted by relevant laws, or you have agreed to this, PowerFile will not share personal information you provided to PowerFile with any other third parties without your permission, or sell, trade or lease your personal information to others, except as provided in this Privacy Statement.

Choice and Consent
PowerFile does not require that customers, business partners or non-employee visitors to PowerFile websites provide PowerFile with personal information. The decision to provide personal information is voluntary. If you do not wish to provide the personal information requested, however, you may not be able to proceed with the activity or receive the benefit for which the personal information is being requested. To exercise any opt out rights under applicable laws, please notify PowerFile of your desire to do so at mkt@powerfile.com or PowerFile, Inc. 1165 Triton Drive, Foster City, CA, USA, 94404. It may take a reasonable period of time to process your request.

PowerFile employees and applicants for employment are required to provide PowerFile with personal information as a condition of employment, or applying for employment, with PowerFile. This information is used by PowerFile and may be shared with third party vendors in connection with PowerFile's administration of its human resources programs and functions consistent with the terms of this Privacy Statement and applicable law.

Sensitive Information
Sensitive information is defined as personal information specifying medical or health conditions, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, or information specifying the sex life of the individual.

Except as provided below, PowerFile does not request or receive sensitive information from visitors to our web sites. PowerFile may receive sensitive information such as medical or health conditions, or race and ethnic data regarding its employees or their dependents in connection with the administration of its health and welfare benefit plans, or as part of government mandated recordkeeping requirements where required by law. Such information will not be shared with third parties except as permitted by applicable law or as required in connection with the administration of human resources programs. In addition, sensitive information that has not been made public by an affected employee will not be used for a purpose other than its original purpose without the employee's approval unless allowed under applicable law. Where appropriate under applicable laws, you will be given a more detailed explanation of sensitive information uses at the relevant time.

Access to and Accuracy of Personal Information
PowerFile strives to keep your personal information accurate. We have implemented technology, management processes and policies to maintain data integrity. PowerFile will take reasonable steps to ensure that the data is complete, accurate and reliable for its intended use. We will provide you with access to your information when reasonable, or in accordance with relevant laws, including making reasonable effort to provide you with online access and the opportunity to change your information. To protect your privacy and security, we will also take reasonable steps to verify your identity before granting access or making changes to your data. Requests to delete personal data are subject to any applicable legal and ethical reporting or document retention obligations. A request to access, delete or correct your personal information may be made to mkt@powerfile.com or PowerFile, 1165 Triton Drive, Foster City, CA, USA 94404.

Security of Personal Information
PowerFile is committed to taking reasonable efforts to secure the personal data you choose to provide us. To protect the privacy of any personal information you may have provided, PowerFile employs industry-standard controls including physical and logical access controls, Internet firewalls, intrusion detection, anti-virus protection, and network monitoring, and, where appropriate, Secure Socket Layer (SSL) or similarly encrypted browsers. In addition, access to sensitive information as defined in this Privacy Statement is limited to those individuals and agents having a need to know.

Other Information/Logging and Cookies
PowerFile collects and/or logs Internet Protocol addresses, Internet domain names, the web browser and operating system used to access the PowerFile web site, the files visited, the time spent in each file, and the time and date of each visit.

PowerFile also uses cookies on some of its web sites. Cookies are identifiers that can be sent from a web site via your browser to be placed on your computers hard drive. Thereafter when you visit a web site, a message is sent back to the web server by the browser accessing the web site. You may elect not to accept cookies by changing the designated settings on your web browser. However, not utilizing cookies may prevent you from using certain functions and features of web sites. The information collected from the use of cookies is used and analyzed to improve PowerFile's web sites, such as by gaining a better understanding of your interests and requirements regarding our website.

You can set your browser to notify you when you are sent a cookie, giving you the chance to decide whether or not to accept it. The information we collect and analyze is used to improve our service to you and personalize your web-browsing experience.

Links to Non-PowerFile Websites and Third Parties
The PowerFile websites may provide links to third-party websites for your convenience and information. If you access those links, you will leave the PowerFile web site. PowerFile does not control those sites or their privacy practices, which may differ from PowerFile's. We do not endorse or make any representations about third party websites. The personal data you choose to give to unrelated third parties is not covered by the PowerFile Privacy Statement. We encourage you to review the privacy policy of any company before submitting your personal information.

Verification
PowerFile will engage in periodic self-assessment to verify that it continues to be in compliance with this Privacy Statement.

Contact Information
If you have any questions or comments regarding this Privacy Statement or believe that the privacy of your personal information has not been respected, you may make a written submission to the attention of PowerFile's Marketing Department, at mkt@powerfile.com or 1165 Triton Drive, Foster City, CA, USA, 94404.

Dispute Resolution
If an employee living in an E.U. member country has a complaint regarding the transfer of human resources data to the U.S., PowerFile agrees to cooperate with the appropriate European data protection authority for handling such complaints. PowerFile agrees to handle all other disputes involving the transfer of personal data from the EU to the U.S. in accordance with the JAMS dispute resolution procedures applicable to international disputes, which are available for review at http://www.jamsadr.com.

Except as provided above, dispute resolution for all other individuals shall be in accordance with applicable law.

Personal Information of Our Customers' Clients
When we provide services to our customers, in some instances we process personal information about their clients ("Client Information") on their behalf. In these situations it is our customers rather than we who decide the reasons for which the Client Information will be processed. For details of how the Client Information will be used and protected, and details of how to access or correct the information, please refer to the privacy policy of the PowerFile customer to whom you submitted your personal information. Relevant laws may oblige customers to require that we comply with the same security rules that they are subject to under such laws.

Changes to This Statement
PowerFile will review and update this Statement periodically, and will note the date of its most recent revision below.

Revised: September 2008


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