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Privacy

EMC Corporation Privacy Statement

Updated: November 2010

General Information

EMC Corporation and its subsidiaries respect the privacy of our customers, business partners, 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 data collected by EMC through the majority of its web sites. It does not apply to sites of EMC subsidiaries that do not display or link to this statement or have their own privacy statements.

Information we may process about clients of our customers is dealt with separately in the section entitled “Personal Information of our Customer’s Clients” below.

Safe Harbor Compliance

EMC has certified its participation, and compliance with, the U.S. Department of Commerce Safe Harbor framework regarding the transfer of personal information from European Union member countries to the United States. The principles of Safe Harbor compliance are notice, choice, onward transfer, security, data integrity, access and enforcement. Additional information about the Safe Harbor principles and certification process can be found at www.export.gov/safeharbor.

EMC is also a member of the TRUSTe Privacy Program. TRUSTe is an independent organization whose mission is to build user’s trust and confidence in the Internet by promoting the use of fair information practices. To demonstrate our commitment to your privacy, we have agreed to disclose our information practices and have our Internet privacy practices reviewed for compliance by TRUSTe.

What Personal Information does EMC Collect?

On EMC web sites you can order products or services, register products, request information, subscribe to marketing or support materials, download software, enter a contest, apply for a job, respond to promotional campaigns, or register to a secure extranet site to obtain access to product information, support, services and training. EMC will collect personal information from you for these purposes. Personal information for purposes of this Privacy Statement is information that identifies or can identify a specific individual. EMC may collect information about individuals such as their name, address, telephone number or email address, user IDs and passwords, billing and transaction information, credit card or other financial information, and contact preferences. Personal information collected online may be supplemented with information you provide to EMC through other EMC services, as well as other sources such as trade shows or seminars, as well as other data appending methods.

EMC does not collect personal information when you visit EMC’s web sites unless you choose to provide it to EMC.

How does EMC use Personal Information?

EMC 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 welcome you, to help you complete a transaction or order, to deliver products or services to you, to bill you for products or 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 or to send promotional mailings to inform you of other products or services available. We may also use information submitted as part of a job application or inquiry to contact you as part of the recruiting and hiring process.

Some of EMC’s websites provide on-line newsgroups, chat forums and blogs for our users. Any information that you disclose in these forums becomes public information, which could be read, collected or used by other users to send you unsolicited messages. You should exercise caution when deciding to disclose your personal information. Some EMC websites also provide for “Live Chat” wherein EMC personnel can monitor the user’s areas of interest in the web site and engage in instant messaging with the user to provide additional information or answer any questions. By posting in our newsgroups and using “Live Chat” you expressly consent to these uses of your information. We are not responsible for the personally identifiable information you choose to submit in these forums. For testimonials, we provide a choice as to whether a user posts his or her personal information along with the testimonial.

In accordance with applicable law, personal information collected on EMC websites may be transferred, stored and processed in the United States or any other country in which EMC or its affiliates, subsidiaries or service providers maintain facilities, even if the level of data privacy required is less than that required by the European Union or under Safe Harbor. By entering your personal data, you consent to worldwide processing of your personal information.

In addition, we may use aggregate demographic information to improve our websites, but that information is not personally identifiable.

With whom does EMC Share Personal Information?

EMC contracts with third party service providers and suppliers (including distributors and resellers) to deliver certain products, services and customer solutions. Examples of such services provided on our behalf are the delivery of mailings, hosting websites, processing transactions, and planning events. EMC may share personal information with its service providers and suppliers to the extent needed to deliver the service or respond to requests for information on products or services or otherwise support the customers’ business needs. In these instances, you will not have the opportunity to opt out of having your information shared with these third party providers and suppliers, and they may contact you directly regarding such products or services.

Third party service providers and suppliers receiving personal information are expected to apply the same level of privacy protection as contained in this Privacy Statement. They are required to keep confidential and secure the personal information received from EMC and may not use it for any purpose other than as originally intended. However, unless otherwise dictated by law or agreement, EMC is not responsible for any improper use by such parties.

We may also disclose personal information and the content of communications in order to: (a) comply with the law or respond to lawful requests or legal process; or (b) act in good faith to protect the rights or property of our business, employees, suppliers or customers.

Some EMC services may be co-branded and offered in conjunction with another company. If you register for or use such services, both EMC and the other company may receive information collected in conjunction with the co-branded services.

Unless permitted by relevant laws, or you have provided consent, EMC will not share, sell, trade or lease your personal information to others, except as provided in this Privacy Statement.

Choice and Access

EMC does not require that customers, business partners or non-employee visitors to EMC websites provide EMC with personal information. The decision to provide personal information is voluntary. If you do not 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.

You can always unsubscribe or choose not to receive promotional information from us by following the specific instructions in the email you receive or by notifying us via the appropriate method below depending on which site is at issue. It may take a reasonable period of time to process your request, no longer than 30 days for direct mail and telephone promotions and 10 business days for e-mail promotions. In countries where required by law, EMC will offer you the opportunity to opt in before promotional materials are sent to you. This will not apply to the receipt of mandatory service communications that are considered part of certain EMC services, which you may receive periodically unless you cancel the service.

EMC strives to keep your personal information accurate. We have implemented technology, management processes and policies to maintain data integrity. 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 take steps to verify your identity before granting access or making changes to your data. Requests to delete personal information are subject to any applicable legal and ethical reporting or document retention obligations. To access and/or correct information, you can do so online or notify us via the appropriate method below depending on which site is at issue.

For EMC.com and Powerlink: emarketing@emc.com or EMC, Attn: Marketing Department, 176 South Street, Hopkinton, MA, USA, 01748-9103.

For RSA.com: webmaster@rsa.com or RSA Security Inc., Attn: Legal Department, 174 Middlesex Turnpike, Bedford, MA 01730.

For Iomega.com: for e-newsletters, special offers, “My Support” accounts, and software updates, you may update your personal information and opt-in preferences by logging into your “My Support” profile at https://iomega-na-en.custhelp.com/cgi-bin/iomega_na_en.cfg/php/enduser/myprofile.php or Iomega, Attn: eMarketing Department, 4059 South 1900 West, Roy, UT 84067; if you have created an account at Iomega’s Online Store, you may update your personal information by logging into your account at the Online Store at https://go.iomega.com/login/.

Security of Personal Information

EMC 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, EMC employs industry-standard physical and logical access controls that change in response to the changing regulatory and threat environments including Internet firewalls, intrusion detection, anti-virus protection, and network monitoring, and, where appropriate, Secure Socket Layer (SSL) or similarly encrypted browsers. If a password is used to help protect your accounts and personal information, it is your responsibility to keep your password confidential.

Display of Advertising

As is true of most web sites, EMC collects and/or logs Internet Protocol addresses, Internet domain names, the web browser and operating system used to access the EMC web site, the files visited, the time spent in each file, and the time and date of each visit. EMC collects these through the use of log files and web beacons.

EMC 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 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 web sites. The information collected from the use of cookies is used and analyzed to improve EMC’s web sites, such as by gaining a better understanding of your interests and requirements regarding our website. Cookies are linked to your personal information, such as your email address or password. 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.

For EMC.com, we use the services of a third party vendor to help us measure the effectiveness of our advertising and how visitors use the site. To do this, we use Web beacons and cookies provided by this vendor on this site. The type of information we collect includes the pages visited, navigation patterns, etc. This information helps us learn things such as what product information is of most interest to our customers, and what kinds of offers our customers like to see. These third party tracking devices only collect data in the aggregate. Although the vendor logs the information coming from our site on our behalf, EMC controls how that data may and may not be used. If you do not want to assist EMC in improving our site, products, offers, and marketing strategy, you can opt-out of this website analysis tool by clicking here http://ecn-analytics-nssl.emc.com/optout.html.

Websites of EMC subsidiaries or divisions may use similar tracking tools for similar internal business purposes only. These websites may not offer this opt-out functionality.

EMC.com utilizes framing techniques to make it appear that the user is still on the site when the user is actually on a third party Web site. Widgets support functions that require that you disclose certain personally identifiable information given the user’s choice of participation.

If you choose to use our referral service to tell a friend about a page on EMC.com, we will ask you for your friend’s name and email address. We will automatically send your friend a one-time email inviting him or her to visit the site. EMC does not store this information.

Links to Non-EMC Web Sites and Third Parties

The EMC web sites may provide links to third-party web sites for your convenience and information. If you access those links, you will leave the EMC web site. EMC does not control those sites or their privacy practices, which may differ from EMC’s. 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 the EMC Privacy Statement. We encourage you to review the privacy policy of any company before submitting your personal information.

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 EMC 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.

Enforcement of this Privacy Statement

If you have questions regarding our compliance with this Privacy Statement you should first contact us by making a written submission to EMC’s Office of the General Counsel, at general_counsel@emc.com or 176 South Street, Hopkinton, MA, USA, 01748. If your inquiry is not satisfactorily addressed, you should contact TRUSTe at http://www.truste.org/consumers/watchdog_complaint.php, or by fax 415-520-3420, or mail at Watchdog Complaints, TRUSTe, 55 2nd Street, 2nd Floor, San Francisco, CA, USA 94105. TRUSTe will serve as a liaison with us to resolve your concerns.

Changes to this Statement

EMC will review and update this Statement periodically, and will note the date of its most recent revision above. If we make material changes to this Statement, we will notify you either by prominently posting a notice of such changes prior to implementing the changes or by directly sending you a notification. Should we undergo any sort of corporate reorganization in the future, you agree that we may provide your information to the resulting entity in which case we will follow these Change procedures. We encourage you to review this Privacy Statement frequently to be informed of how EMC is protecting your information.