Privacy Statement

(Effective as of Oct 2012)

Introduction

Brightidea, Inc. ("Brightidea") is committed to protecting the privacy of your personal information while using our Web site and our hosted application service and related support services. Brightidea has therefore established this Privacy Policy to assist you to understand how Brightidea collects and uses personally identifiable information. By using our Web site or our hosted application service or related support services, you are agreeing to the collection and use of personal information in the manner described in this Privacy Policy.

Safe Harbor Certification

Your personal information may be transferred abroad (including outside the EU and Switzerland for our users in the EU or Switzerland) in connection with our providing our hosted application service and related support services.

Brightidea is self-certified to the United States/European Union and United States/Switzerland Safe Harbor Programs and is thus committed to complying with the U.S.-EU and U.S.-Swiss Safe Harbor principles with respect to all personal data received from the EU and Switzerland (see http://www.export.gov/safeharbor/eg_main_018236.asp).

Brightidea agrees to cooperate with the EU Data Protection Authorities and the Swiss Federal Data Protection and Information Commissioner, and to participate in the dispute resolution program provided by the European Data Protection Authorities Panel.

In compliance with the US-EU and US-Swiss Safe Harbor Principles, Brightidea commits to resolve complaints about your privacy and our collection or use of your personal information. European Union or Swiss citizens with inquiries or complaints regarding this privacy policy should first contact Brightidea at support@Brightidea.com.

Brightidea has further committed to refer unresolved privacy complaints under the US-EU and US-Swiss Safe Harbor Principles to an independent dispute resolution mechanism, the BBB EU SAFE HARBOR, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed by Brightidea, please visit the BBB EU SAFE HARBOR web site at www.bbb.org/us/safe-harbor-complaints for more information and to file a complaint.

If you have a complaint concerning Brightidea' Safe Harbor compliance, please contact support@Brightidea.com.

Web Site Data Collection Overview

Our server software gathers in log files, general demographic information from all users of our Web site and for users of our hosted application service and related support services. For each visitor to the Brightidea Web site, our Web server automatically recognizes the visitor's domain name, browser type, operating system, referring domains, entry page, exit page, and average time on the Web site. This information is used for internal purposes only, to help us improve our Web site and better understand our visitors' needs.

We may use the services of marketing companies to help us collect and/or log Internet Protocol addresses, Internet domain names, the web browser and operating system used to access the Brightidea Web site, the files visited, the time spent in each file, and the time and date of each visit. We use Web beacons and cookies. Cookies are identifiers that can be sent from a Web site via your browser to be placed on your computer's 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 our Web site. The information collected from the use of cookies is used and analyzed to improve our Web site. We use cookies to personalize the experience of our visitors, provide support to customers, record visitor preferences, provide personalized and specialized content, record session information, track visitor clickstream behavior throughout the Web site, and customize site content based on your browser type, operating system, and preferences. By gathering such information to supplement our records, we learn things like what pages are most attractive to our visitors, which of our products most interest our customers, and what kinds of offers our customers like to see. Although we or our marketing companies log the information coming from our site on our behalf, we control how that data may and may not be used. If you do not want to help us learn how to improve our site, products, offers and marketing strategy, you can opt-out of this Web site analysis tool by disabling your cookies. If you disable your cookies, you may still use our Web site; however, you may not be able to access certain areas within it.

If you choose to receive company or product information, you will need to complete our online request forms. The online forms provide site visitors with an opportunity to request free product downloads and demos, view Brightidea white papers, register for free Brightidea online seminars as they may be offered, and enroll for various services. These forms require your name, company name, e-mail address, company address, phone number as well as other information to help us determine and respond to your needs related to the products and/or services requested. All information provided by the visitor is voluntary. We use this information to send updates about our company and our products and to contact you if requested or necessary. We also use the demographic information you provide on these forms in connection with studies and reports regarding our Web site, such as Web site usage patterns, in order to better understand the needs of visitors to our Web site. We will not, however, associate any personally identifiable information which you provide with the information in these studies and reports.

We use Web beacons alone or in conjunction with cookies to compile information about your usage of our Web site and interaction with emails from Brightidea.Web beacons are clear electronic images that can recognize certain types of information on your computer, such as cookies, when you viewed a particular Web site tied to the Web beacon and a description of a website tied to the Web beacon. We only use Web beacons to operate and improve our Web site and emails communications.

We may occasionally run contests or other special promotions on our Web site in which we ask persons who choose to participate for contact information (like an e-mail address) or demographic information (like a zip code, industry or country). We may use the data we collect from you in these contests and promotions to send you promotional material about our company or our partners. Your contact information collected from these contests and promotions may be used to administer the contest and notify winners and contact you when necessary.

E-mail Addresses

We do not collect e-mail addresses without the site visitor voluntarily providing us with this information (typically via our online information request form, whitepaper request form, and other Web site forms and surveys). We will periodically use your e-mail information for service, sales, support, and marketing purposes. From time to time, we may share your e-mail address with our partner organizations and companies for service, sales, support, and marketing purposes. If you do not wish to receive marketing e-mail from us or our partners in the future, you may opt out as described below.

Customer Data

Customers or end users may use our hosted services to host certain data about their personnel. We do not use or disclose such data except as provided in our subscription agreements with our customers, or as may be required by law , or if we believe that use or disclosure is necessary to protect our rights and/or to comply with a judicial proceeding, court order or legal process. Customers are responsible for maintaining the security and confidentiality of their usernames and passwords.

Data Security

We use a variety of security measures and employ appropriate physical, administrative and technical safeguards to protect against the loss or unauthorized use, alteration or disclosure of, or unauthorized access to, the personal information under our control. We have licensed the industry-standard Secure Sockets Layer (SSL) technology, which permits encryption of potentially sensitive information such as your name and address. This will make your information unusable in the event of unauthorized third-party interception. We store this information in a secure environment at one or more of our service providers.

Brightidea personnel with access to this information have been trained and advised of the importance of maintaining the security and confidentiality of such information and of using it only for the purposes described in this Privacy Policy.

Other than as expressly described in this Privacy Policy, we will not share personally identifiable information with anyone outside of Brightidea without your prior permission unless we believe in good faith that such release is reasonably necessary to (i) comply with applicable law, (ii) enforce the terms of any of our user agreements, or (iii) protect the rights, property or safety of Brightidea, our visitors, or others.

Upon request submitted to support@Brightidea.com, Brightidea will provide Web site visitors at no cost with access to their personal information that we have on record and the ability to complete, update or remove such information. The Brightidea Web site may provide links to third-party Web sites for your convenience and information. If you access those links, you will leave the Brightidea Web site. Brightidea does not control these third-party sites or their privacy practices, which may differ from Brightidea'. We do not endorse or make any representations about third party Web sites. The personal data you choose to give to unrelated third parties is not covered by this Privacy Policy.

In the event your personal information is acquired, or is reasonably believed to have been acquired, by an unauthorized person, and applicable law requires notification to you by Brightidea, Brightidea will notify you of such breach promptly by email, fax, or U.S. mail, as permitted by law and consistent with the reasonable investigatory needs of law enforcement and/or Brightidea.

Notificationof Privacy Policy Changes

Brightidea may amend this Privacy Policy from time to time. If Brightidea decides to make material changes in the way we use your personal information, we will post the changes on this page so that you always will know what information we collect, how it is used, and when and how it will be disclosed. Your use of the Brightidea Web site following notice of such change will be deemed acceptance of the revised Privacy Policy, which may include application of the new policy to information provided prior to the date of such change.

Choice/Opt-Outand Updating Information

If you receive marketing or similar e-mail messages from us and wish to opt out of receiving such messages, you may simply follow the opt-out procedure specified in such e-mail. In addition, if you have registered on our site, you may opt out of receiving any future marketing or similar messages by unsubscribing. You may also contact us by regular mail addressed to: Brightidea, Inc., Attn: Support, 434 Brannan Street, San Francisco, CA 94104 - USA.

Contacting Us

If you have any questions about this Privacy Policy or this Web site, please contact us directly at: support@Brightidea.com

Written inquiries may be addressed to: Brightidea, Inc., Attn: Support, 101 Montgomery Street, Suite 2500, San Francisco, CA 94104 - USA.

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