Safe Harbor Privacy Statement

Effective: May 3, 2011

This Statement describes how Irdeto Silicon Valley, Inc. located at www.irdeto.com and its affiliated companies collects, uses, and discloses certain personally identifiable information that it receives in the United States from the European Union and Switzerland ("EU and Swiss Personal Data"). In particular, Irdeto Silicon Valley, Inc. recognizes that the European Union and Switzerland have established strict protections regarding the handling of EU and Swiss Personal Data, and Irdeto Silicon Valley therefore has elected to adhere to the US-EU and US-Swiss Safe Harbor Privacy Principles (the "Safe Harbor") with respect to such EU and Swiss Personal Data that it receives in the United States.

Irdeto Silicon Valley, Inc. complies with the U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland. Irdeto Silicon Valley, Inc. has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view Irdeto Silicon Valley, Inc.'s certification, please visit www.export.gov/safeharbor/.

Irdeto Silicon Valley, Inc. is the global leader providing the media and entertainment industry with the most comprehensive Irdeto Silicon Valley, Inc. commercial search and discovery services for analyzing the impact of digital media online, providing the best anti-piracy measures and enabling effective marketing decisions through insightful business intelligence.

Categories of Individual Data Subjects

In general, Irdeto Silicon Valley, Inc. may obtain EU Personal Data in the United States about several different types of individuals, including potential intellectual property right infringers or sharers of content. Irdeto Silicon Valley, Inc. practices with respect these types of individual data subjects are described below:

Intellectual Property Right Infringers or Sharers of Content

Irdeto Silicon Valley may use EU Personal Data for business purposes in providing the following services to our business clients ("Clients"):

1. Peer-to-Peer Tracking & Enforcement
2. Web Video Tracking & Enforcement
3. Cyberlocker Tracking & Enforcement
4. Live Streaming Tracking & Enforcement
5. First Alert & Crisis Enforcement Services
6. Business Intelligence & Monetization Services

In providing the above listed services, Irdeto Silicon Valley, Inc. may obtain various types of EU Personal Data about potential intellectual property right infringers or sharers of content: information generally broadcasted by a peer-to-peer client without modification, user IP address, serve IP address, timestamp of detection, peer-to-peer client name and version, aliased username or ID (if provided), filename, file size, protocol hash of file, proportion of the file in possession, URL of potentially infringing content, file description (if provided), view count (if provided), and other URLs posted by user (if provided).

Irdeto Silicon Valley, Inc. may use these types of EU Personal Data for business purposes, including delivering or providing products or services; to establish or maintain client and business relationships; to provide access to Internet-based and e-commerce activities; to perform accounting functions; and to conduct other activities as necessary or appropriate in connection with the servicing and development of the business relationship.

In the case of intellectual property right infringers, a notice of such infringement with information evidencing the infringement may be sent to an appropriate online service provider based upon the user IP address.

If your personally identifiable information changes, you may correct, update or delete inaccuracies within your information by contacting us at This e-mail address is being protected from spambots. You need JavaScript enabled to view it. we will respond to your request to access within 30 days.

Clients

Irdeto Silicon Valley, Inc. provides a wide variety of services and solutions to its business clients ("Clients") that facilitate services including intellectual property right infringement trackin and online service provider notifications of intellectual property right abuse individuals ("Data Subjects"). In some instances, Irdeto Silicon Valley, Inc. may obtain access to EU Personal Data about such Data Subjects in the course of providing the services and solutions. In other specific instances, Irdeto Silicon Valley, Inc. may also obtain access to data about our Clients' end users in the course of providing support services to the Clients ("End Users"). Such data may include the data listed above, and other information, depending on the particular Client and application at issue.

Wherever we obtain access to EU Personal Data about Data Subjects or End Users, we are acting as a mere data processor on behalf of our Clients, and we therefore conduct such activities strictly in accordance with their instructions and pursuant to our contractual arrangements with them. If you are an End User with an existing relationship with one of our Clients, you should refer to the Client's website to understand the privacy practices that apply to EU Personal Data that we may maintain about you. If you would like to access and review your EU Personal Data, you should contact us with any such requests. We will cooperate as appropriate with requests from our Clients to assist with such responses.

Other Necessary Disclosures

Irdeto Silicon Valley, Inc. does not share, sell, rent or trade personal information with third parties other than as disclosed within this privacy policy. Irdeto Silicon Valley, Inc. may disclose EU Personal Data to business partners and subcontractors as necessary in connection with the performance of requested services or solutions, or as otherwise appropriate in connection with a legitimate business need. Irdeto Silicon Valley, Inc. may also disclose EU Personal Data as necessary in connection with the sale or transfer of all or part of the business. In these situations, Irdeto Silicon Valley, Inc. will require the recipient of the data to protect the data in accordance with the relevant principles in the Safe Harbor, or otherwise take steps to ensure that the EU Personal Data is appropriately protected. Irdeto Silicon Valley may also disclose EU Personal Data where required or permitted by law, or where Irdeto Silicon Valley, Inc. believes that such disclosures are appropriate in connection with a law enforcement request.

Irdeto Silicon Valley, Inc. reserves the right to disclose personally identifiable information as required by law and when we believe that disclosure is necessary to protect our rights and/or to comply with a judicial proceeding, court order, or legal process served on our web site.

Email Communications

We send out infringement notices when copyrighted materials have been illegally downloaded from and/or uploaded to the internet. The information in the notice will provide you with details of why you received the notice. These notices are not promotional in nature and you may not opt-out from receiving them.

Cookies

A cookie is a small text file that is stored on a user’s computer for record-keeping purposes. We use cookies on this site. We do not link the information we store in cookies to any personally identifiable information.

We use session ID cookies. We use session cookies to make it easier for you to navigate our site and so that we may track number of page views per user. A session ID cookie expires when you close your browser.

Data Security and Integrity

Irdeto Silicon Valley, Inc. has hosting centers within the United States that store and process EU Personal Data in various locations in the United States. Irdeto Silicon Valley, Inc. takes reasonable precautions to protect EU Personal Data in these centers and in other locations in the United States from loss, misuse and unauthorized access, disclosure, alteration, and destruction. BayTSP also makes reasonable efforts to keep EU Personal Data reliable for its intended use, accurate, current, and complete.

Changes to this Privacy Policy

If we decide to change our privacy practices, we will post those changes to this privacy policy, the home page, and other places we deem appropriate so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it.

We reserve the right to modify this privacy policy at any time, so please review it frequently. If we change how we use your personally identifiable information, we will notify you here, by email, or by means of notice on our home page.

Questions

If you have any questions about this Safe Harbor Privacy Statement, or if you would like to request access to EU Personal Data that we may maintain about you, please contact us as follows:

Irdeto Silicon Valley, Inc.
ATTN: Privacy Department
3255-3 Scott Blvd., Suite 101
Santa Clara, CA 95054  USA

Irdeto Silicon Valley, Inc. has been awarded TRUSTe's Privacy Seal signifying that this privacy policy and practices have been reviewed by TRUSTe for compliance with TRUSTe's program requirements including transparency, accountability and choice regarding the collection and use of your personal information. The TRUSTe program does not cover information that may be collected through downloadable software. TRUSTe's mission, as an independent third party, is to accelerate online trust among consumers and organizations globally through its leading privacy trustmark and innovative trust solutions. If you have questions or complaints regarding our privacy policy or practices, please contact us at This e-mail address is being protected from spambots. You need JavaScript enabled to view it. . If you are not satisfied with our response you can contact TRUSTe.

Irdeto Silicon Valley, Inc. complies with the EU Safe Harbor and Swiss Harbor framework as set forth by the Department of Commerce regarding the collection, use, and retention of data from the European Union and Switzerland. As part of our participation in the safe harbor, we have agreed to TRUSTe dispute resolution for disputes relating to our compliance with the Safe Harbor and Swiss Privacy Framework. If you have any complaints regarding our compliance with the Safe Harbor you should first contact us at This e-mail address is being protected from spambots. You need JavaScript enabled to view it. .

If contacting us does not resolve your complaint, you may raise your complaint with TRUSTe by internet at http://watchdog.truste.com/pvr.php?page=complaint, fax at +1 415 520 3420, or mail at Watchdog Complaints, TRUSTe, 55 2nd Street, 2nd Floor, San Francisco, CA, USA 94105. If you are faxing or mailing TRUSTe to lodge a complaint, you must include the following information: the name of company, the alleged privacy violation, your contact information, and whether you would like the particulars of your complaint shared with the company. For information about TRUSTe or the operation of TRUSTe's dispute resolution process, see http://watchdog.truste.com/pvr.php?page=complaint or request this information from TRUSTe at any of the addresses listed above. The TRUSTe dispute resolution process shall be conducted in English.