PRIVACY

This Privacy Policy is effective as of: April, 2006

This Privacy Policy was last updated: August 30, 2011

Table of Contents

• Scope of this Privacy Policy
• Dispute Resolution
• Safe Harbor
• Changes to this Privacy Policy
• What information does Soonr Collect?
• How does Soonr use Cookies?
• How does the Soonr Software's integration with third-party software affect User Privacy?
• How does Soonr use my information?
• Will Soonr transfer any of my information across International borders?
• When can my information be disclosed to third parties?
• What are my access and opt-out rights?
• What is your policy for Children?
• What is your security policy?
• How do I update my personally identifiable information?
• How do I contact Soonr?

Soonr is a software company that enables secure online backup and synchronization services over any data network. Soonr end users can store, access, download, search, forward, print and share files instantly. They can also setup teams for collaboration purposes.

We at Soonr recognize the importance of your privacy and the protection of your information. This privacy policy is intended to inform you about the personally identifiable information we collect via the Soonr software ("Soonr Software") and through the services provided by Soonr that are enabled by the Soonr Software ("Soonr Services"). We refer to those who have downloaded and use the Soonr Software as users ("Users"). This privacy policy also explains our privacy practices on our corporate website located at www.Soonr.com ("Website").

[Soonr is a licensee 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.. Because Soonr wants to demonstrate its commitment to your privacy, it has agreed to disclose its information practices and have its privacy practices reviewed for compliance by TRUSTe.

If you have questions or concerns regarding this Privacy Policy, you should first contact privacy@Soonr.com. If you do not receive acknowledgement of your inquiry or your inquiry has not been satisfactorily addressed, you should contact TRUSTe at http://watchdog.truste.com/pvr.php?page=complaint&url= TRUSTe will then serve as a liaison with us to resolve your concerns.

Soonr. participates in the EU Safe Harbor Privacy Framework as set forth by the United States Department of Commerce. 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 Privacy Framework. If you have any complaints regarding our compliance with the Safe Harbor you should first contact us (as provided above). If contacting us does not resolve your complaint, you may raise your complaint with TRUSTe by Internet at http://www.truste.com/consumers/watchdog_complaint.php, fax at 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, seehttp://www.truste.com/consumers/watchdog_complaint.php or request this information from TRUSTe at any of the addresses listed above.

The TRUSTe dispute resolution process shall be conducted in English.

Soonr follows the Safe Harbor Principles published by the United States Department of Commerce (the “Principles”) with respect to the transfer of personal data from the European Union to the United States of America. This Privacy Policy details certain policies implemented throughout Soonr implementing the Principles and governing Soonr's use of personally identifiable information provided to Soonr via this Sites and through our Services. If there is any conflict between the policies in this Privacy Policy and the Principles, the Principles will govern.]

We may update this privacy policy as we continue to offer you more Soonr Services, including services integrating the Soonr Software with software owned by third-party companies with whom we will choose to partner. If so, Soonr will post our updated privacy policy on our Website along with notice that the privacy policy has been changed so you are aware of what personally identifiable information we may collect and how we may use this information. Soonr may also send Users of the Website e-mail notifications notifying such Users of any changes to the privacy policy. We encourage you to review this privacy policy frequently, particularly each time you register for new Soonr Services via the Soonr Software. Your continued use of this Website and/or continued provision of personally identifiable information to us will be subject to the terms of the then-current privacy policy.

In general, Soonr collects your personally identifiable information only when you provide it to us; for example, when you register for a Soonr account, or when you email it to us. We try to make it clear to you when you are providing personally identifiable information to us (e.g., by creating a web form for you to fill out.) Similarly, we try to make it clear when the information you are providing is required by making an indication on the web form.

* When you register for a Soonr account and use the Soonr Software. In order to use the Soonr Software, you must download the software and register for an account during the software setup process. As part of the registration process, we ask you to provide personally identifiable information such as your full name, your email address, and your mobile number. We also require you to setup a User ID and password, which may be considered personally identifiable information. We also ask (but do not require you) to provide us with other information such as, your mobile phone number and your country of residence. Some of this information may be considered personally identifiable information. Please note that if you choose NOT to provide your mobile phone number, you may not be able to enjoy all of the functionality of the Soonr Software. This functionality is primarily for the notification of events using text messsaging.

* When you invite others to try the Soonr Software. When a User elects to invite other teams or individuals to join Soonr, we ask the User to provide the team or individual's name and their email address. Soonr will automatically send the team or individual a one-time email inviting the team or individual to subscribe to Soonr which includes a temporary user ID and password. Soonr does not store the message sent, but we do keep track of who sent the message and to which email address it was sent to. To request the removal of this information from our database,[you or] the team or individual may contact us by sending a message to privacy@Soonr.com

* When you visit the Soonr Website or Contact Us. We may collect personally identifiable information from you when you visit the Website. For example, if you send us an email asking a question, we will collect your personally identifiable information that you elect to include in your correspondence to us and your email address. We will keep whatever information you provide for as long as it reasonably takes to answer your question.

The Soonr Software collects additional information from Users, including: their IP address, browser, and operating system and version. It also collects some information on how Users use the Soonr Software, including information about which files Users choose to share with other Users, and which of the files those Users have accessed and when. The Soonr Software also collects the make and model number (e.g., Nokia 6250) of your mobile phone when Users login from their phone in order to optimize their experience with the Soonr Software. We also collect additional non-personally information from you when you visit the Website, including your IP Address, browser type, domain name, time/date, referring URL, landing page, and pages viewed. None of this additional information can be used to identify Users personally and it will be collected, used and disclosed only in aggregate non-personally identifiable form.

Soonr uses cookies in connection with the Soonr Software and the Website. A cookie is a small bit of data, which includes an anonymous unique identifier that is sent to your computer's browser from a website's computers and stored on your computer's hard drive. We use cookies in conjunction with the Soonr Software in order to identify your computer and your cell phone when you log in. We also use cookies to enhance your experience as you visit the Website. Cookies generally do not permit us to personally identify you.

If you delete or disable your cookies, you will significantly impair the functionality of the Soonr Software, and may not be able to use all the features of the Website.

* Accessing, Sharing, Storing and Uploading User Files. Users may use the Soonr Software to access, upload, or store almost any type of file on our servers. They may also share those files with other Soonr Users. Users have a choice regarding which files and folders they upload to our servers and which (if any) other Users they provide access to those files and folders. Please be careful when sharing files that contain personally identifiable and/or sensitive information.

* Soonr Backup and Synchronization. If a User marks a folder for storage in Soonr's storage server, the file is uploaded to the Soonr server. This allows the file to be accessed or synchronized by the User (or by others to whom the User has shared the file) even if the User's computer is offline or turned off. Files are encrypted during transfer (upload and download) between Soonr and the User's computer. To allow search of this stored content by the User, the file needs to be indexed while in an unencrypted format. The files are stored encrypted on Soonr's servers.

Soonr uses the information we collect from you to provide you with the Soonr Services which you have requested, to enable the functionality of the Soonr Software, to contact you about your account, to help you resolve any technical matters when you seek technical assistance and to improve the Soonr Software and Soonr Services. If you are a User, we will use your email address to contact you about the Soonr Software and Soonr Services, about product upgrades, updates, and new products and services. We may use web beacons to determine whether you have opened the emails that we send to you. A "web beacon" is an electronic image, also known as a clear GIF or a single-pixel (1x1), which can recognize certain types of information on an individual's computer such as an individual's cookie number, the time and date of a page view, and/or a description of the page where the web beacon is placed.

You may access the Soonr Services, including any files stored on your computer, from any location from which you can connect to the Soonr Services via your mobile phone and other internet connected device.

If you are a User located in the United States of America, your personally identifiable information will be stored on servers located in the United States of America. With respect to Users outside of the United States of America, we may, but do not guarantee, that we will store your personally identifiable information on servers located in the country in which the User is located or if there are no servers in that country, then in the country that Soonr reasonably selects. We may add new servers in different geographic locations from time to time.

Soonr may use third parties to process personally identifiable information about you to assist us in providing the Soonr Services and Soonr Software to you. If we do, we will require that they comply with this Privacy & Security Policy and any other appropriate privacy and security measures. Soonr may also disclose personally identifiable information about you to third parties when we have a good faith belief that it is necessary to do so: in response to legal process, to protect and defend Soonr's rights or property, to prevent fraud or in cases of imminent danger or to enforce the Soonr End User License Agreement.

Soonr does not sell or rent your personally identifiable information to other parties, but we may transfer your personally identifiable information to a successor entity upon a merger, consolidation or other corporate reorganization in which Soonr participates or to a purchaser or acquirer of all or substantially all of Soonr's assets to which this Website relates.

You may uninstall and delete the Soonr Software from your computer at any time. If you are a User, as part of the Soonr End User License Agreement, we require that you initially accept emails from us. However, you may take your name off the list for these emails and/or choose which types of emails you'd prefer to receive at any time by following the 'unsubscribe' directions at the bottom of every email. We will always correct your account information when you notify us. If you cancel your use of the Soonr Software or any product or service, we will delete all information except those records necessary for our legitimate business purposes.

Soonr recognizes the privacy interests of children and we encourage parents and guardians to take an active role in their children's online activities and interests. Neither the Soonr Software, the Soonr Services nor the Website are intended for children under the age of 13. Soonr does not target the Soonr Software, the Soonr Services or the Website to children under 13. Soonr does not knowingly collect personally identifiable information from children under the age of 13.

The security of your information is important to us. We may use certain technological measures consistent with industry standards to protect the information submitted to us, both during transmission and once we have received it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security.

Sharing access to your files may create additional risks to privacy and to the confidentiality of the information within your files. We provide certain safeguards from our end, for example, the ability for you to view who has accessed the files you've decided to share. But some of the responsibility to prevent unauthorized access remains with you. You can find more information about how the shared access works by clicking on the "How it Works" link. If you authorize others to share access to your files, you are agreeing that you recognize those risks. Moreover, while most mobile phones support SSL or other forms of secure data transmission, some mobile phones -particularly older mobile phones - do not. Users who access the Soonr Service via older mobile phones should take note of this. We strongly encourage all Users to check the operating instructions or similar documentation for their mobile phone PRIOR to using the Soonr Service.

Upon request and within 30 days, Soonr will grant individuals reasonable access to personal information that it holds about them. Soonr provides you with the ability to review and update the registration information that you provide to us by accessing and modifying this information in your account, except where the burden or expense to Soonr of providing access would be disproportionate to the risks to your privacy or where the legitimate rights of persons other than you would be violated.

If you have questions, please contact us at any time by email at privacy@Soonr.com or in writing at:

Global Office
Soonr USA
307 Orchard City Dr, Suite 206
Campbell, CA 95008
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