Flash Networks Ltd. and its subsidiaries (“Flash Networks”) are concerned about privacy issues and wants you to be familiar with how we collect, use and disclose information. This Privacy Policy describes our practices in connection with information that we collect through the website owned and controlled by us from which you are accessing this Privacy Policy (the “Site”) as well as certain information we collect from offline sources, as explained in more detail below. By providing Personal Information to us, you agree to the terms and conditions of this Privacy Policy.

If you apply for a job through the Site, our use of the Personal Information you provide through our Career pages are governed by a separate privacy policy, not this Privacy Policy.

Personal Information

Personal Information We May Collect

Personal Information” is information that identifies you as an individual, such as (but not limited to):

• Name

• Postal address (including billing and shipping addresses)

• Telephone number

• Email address

• Organization and job title or function

• Login ID, PIN or other Password for access to certain content on the Site

We may merge Personal Information collected through the Site with Personal Information that we collect about you offline, such as business contact information that we receive in connection with sales presentations, your e-mails to us or your purchases from us, information gathered when you attend a trade show, seminar or other business event, or information provided by your employer if your company enrolls you in a training event. All such merged Personal Information will be treated in accordance with this Privacy Policy.

How We Use Personal Information

We may use Personal Information:

• To respond to your inquiries and fulfill your requests, such as to send you e-mail alerts, white papers or information about our company, products and services.

• To send you important information regarding the Site, changes to our terms, conditions, and policies and/or other administrative information.

• To allow you to register for or take advantage of various opportunities, such as participating in forums, blogs or other interactive features;

• To send you marketing communications that we believe may be of interest to you.

• To allow you provide feedback in a customer satisfaction survey or for market research purposes.

• To personalize your experience on the Site by presenting products and offers tailored to you.

• To administer and develop our business relationship with you and the organization you represent, if you represent one of our customers, business partners or prospective customers or partners.

• For our business purposes, such as data analysis, providing services requested by you, audits, developing new products, enhancing our website, improving our services, identifying usage trends and determining the effectiveness of our promotional campaigns.

• As we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

How Personal Information is Disclosed

Your Personal Information may be disclosed:

• To our affiliates for the purposes described in this Privacy Policy. Flash Networks Ltd. is the party responsible for the management of the jointly-used Personal Information.

• To our third party service providers who provide services such as website hosting, data analysis, payment processing, order fulfillment, infrastructure provision, IT services, customer service, email delivery services, credit card processing, auditing services and other similar services to enable them to provide services.

• To identify you to anyone to whom you send messages through the Site.

• By you, onmessage boards, chat, profile pages and blogs and other services to which you are able to post information and materials. Please note that any information you post or disclose through these services will become public information, and may be available to visitors to the Site and to the general public. We urge you to be very careful when deciding to disclose your Personal Information, or any other information, on the Site.

• To a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings).

• As we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

Other Information

Other Information We Collect

Other Information” is any information that does not reveal your specific identity or does not directly relate to an individual, such as:

• Browser information

• Information collected through cookies, pixel tags and other technologies

• Demographic information and other information provided by you

• Aggregated information

How We Collect Other Information

We and our third party service providers may collect Other Information in a variety of ways, including:

• Through your browser: Certain information is collected by most browsers, such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system version and Internet browser type and version. We use this information to ensure that our Site functions properly.

• Usage data: We may use statistical data, analytics, trends and usage information derived from your use of services (“usage data”) through pixel tags and other similar technologies. Usage data includes, for example, aggregated quantitative information about active users, activity, topics, and groups. Some ways we use the usage data include operating, improving and personalizing the services and our offerings.

• IP Address: Your “IP Address” is a number that is automatically assigned to the computer that you are using by your Internet Service Provider (ISP). An IP Address is identified and logged automatically in our server log files whenever a user visits the Site, along with the time of the visit and the page(s) that were visited. Collecting IP Addresses is standard practice on the Internet and is done automatically by many web sites. We use IP Addresses for purposes such as calculating Site usage levels, helping diagnose server problems, and administering the Site.

• From you: Information such as your location, as well as other information, such as your preferred means of communication or areas of interest, is collected when you voluntarily provide this information. Unless combined with Personal Information, this information does not personally identify you or any other user of the Site.

• By aggregating information: Aggregated Personal Information does not personally identify you or any other user of the Site, (for example, we may aggregated Personal Information to calculate the percentage of our users who have a particular telephone area code).

How We Use and Disclose Other Information

Please note that we may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. If we are required to treat Other Information as Personal Information under applicable law, then, in addition to the uses listed in the “How We Collect Other Information” section above, we may use and disclose Other Information for all the purposes for which we use and disclose Personal Information.

In some instances, we may combine Other Information with Personal Information (such as combining your name with your geographical location). If we combine any Other Information with Personal Information, the combined information will be treated by us as Personal Information as long as it is combined.

Third Party Sites

This Privacy Policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including any third party operating any site to which this Site contains a link. The inclusion of a link on the Site does not imply endorsement of the linked site by us or by our affiliates.

Security

We use reasonable organizational, technical and administrative measures to protect Personal Information under our control. Unfortunately, no data transmission over the Internet or data storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us in accordance with the “Contacting Us” section below.

Choices and Access

Your choices regarding our use and disclosure of your Personal Information

We give you many choices regarding our use and disclosure of your Personal Information for marketing purposes. You may opt-out from:

• Receiving electronic communications from us: If you no longer want to receive marketing-related emails from us on a going-forward basis, you may opt-out of receiving these marketing-related emails by following the instructions contained in the email.

• Our sharing of your Personal Information with affiliates for their marketing purposes: If you would prefer that we do not share your Personal Information on a going-forward basis with our affiliates for their marketing purposes, you may opt-out of this sharing by contacting us at compliance@flashnetworks.com

• Our sharing of your Personal Information with unaffiliated third parties for their marketing purposes: If you would prefer that we do not share your Personal Information on a going-forward basis with unaffiliated third parties for their marketing purposes, you may opt-out of this sharing by contacting us at compliance@flashnetworks.com

We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt-out as described above, we will not be able to remove your Personal Information from the databases of our affiliates or unaffiliated third parties with which we have already shared your Personal Information (i.e., to which we have already provided your Personal Information as of the date that we implement your opt-out request). Please also note that if you do opt-out of receiving marketing-related messages from us, we may still send you important administrative messages, and you cannot opt-out from receiving administrative messages.

How you can access, change or suppress your Personal Information

If you would like to review, correct, update, suppress, delete or otherwise limit our use of your Personal Information that has been previously provided to us, you may contact us at compliance@flashnetworks.com or at the addresses listed below in “Contacting Us”.

In your request, please make clear what information you would like to have changed, whether you would like to have your Personal Information suppressed from our database or otherwise let us know what limitations you would like to put on our use of your Personal Information. We will try to comply with your request as soon as reasonably practicable.

Retention Period

We will retain your Personal Information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or allowed by law.

Use of site by Minors

The Site is not directed to individuals under the age of fifteen (15), and we request that these individuals do not provide Personal Information through the Site

Cross-Border Transfer

Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using our Site you consent to the transfer of information to countries outside of your country of residence, including the United States, which may have different data protection rules than in your country.

Sensitive Information

We ask that you not send us, and you not disclose, any sensitive Personal Information (e.g., information related to racial or ethnic origin, political opinions, religion or other beliefs, health, criminal background or trade union membership) on or through the Site or otherwise to us.

Updates to this Privacy Policy

We may change this Privacy Policy. Please take a look at the “Last Updated” legend at the top of this page to see when this Privacy Policy was last revised. Any changes to this Privacy Policy will become effective when we post the revised Privacy Policy on the Site. Your use of the Site following these changes means that you accept the revised Privacy Policy.

Contacting Us

If you have any questions about this Privacy Policy, please contact us by email at compliance@flashnetworks.com, or please write to the following address:

Flash Networks LTD.

7 Sapir Road, POB 12624

Herzilya 46733

ISRAEL


Please note that email communications are not always secure; so please do not include sensitive information in your emails to us.

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