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Safe Harbor Privacy Policy

2Wire, Inc. d/b/a Pace Americas

Introduction

2Wire, Inc. d/b/a Pace Americas (“Pace Americas”) abides by the Safe Harbor Principles developed by the US Department of Commerce and the European Commission. In connection with the provision of services to corporate customers in the European Union (the “EU”), Pace Americas collects and maintains certain personal information about its customers’ customers (“End Users”) and End Users’ equipment. Pace Americas receives this information as a data processor, and all such information is owned and controlled by Pace Americas’ corporate customers and is subject to their instructions.

This privacy policy is focused on personal information received by Pace Americas that is covered by the Safe Harbor Agreement; for our general privacy policy please see http://www.pace.com/universal/privacy-policy/.

EU Safe Harbor Privacy Policy

The European Commission’s Directive on Data Protection went into effect in October of 1998 regarding the transfer of personal data to non-European Union countries. However, a streamlined means for U.S. organizations to comply with the Directive, was adopted in cooperation with the U.S. Department of Commerce and the European Commission. Together they developed a "Safe Harbor" framework where both can share the goal of enhancing privacy protection for their citizens.

To learn more about the Safe Harbor program, and view the 2Wire, Inc. d/b/a Pace Americas’ certification, please visit http://www.export.gov/safeharbor/

Notice

As an agent processing personal information under the direction of its customers, Pace Americas has no direct relationship with the individuals whose personal data it processes. Pace Americas works with its customers to help them provide notice of data processing to individuals, including information concerning (1) the purposes for which personal information is collected and used; (2) a contact person to whom enquiries or complaints may be directed; (3) the types of third parties to whom personal information is disclosed; and (4) the choices and means that individuals are offered for limiting use and disclosure of personal information.

Choice

As an agent processing personal information under the direction of its customers, Pace Americas has no direct relationship with the individuals whose personal data it processes. Pace Americas works with its customers to help them inform individuals about the possibility of such disclosures and provide individuals with the choice of opting-out of them. Pace Americas works with its customers to ensure that it only processes personal information for purposes that are compatible with those for which it was originally collected or subsequently authorized by the individual End User. Pace Americas does not collect sensitive personal information, as defined in the Principles.

Onward Transfers

Personal information may be transferred to third-party data processors to process personal data in accordance with the purpose for which it was collected or as subsequently authorized by the individual End User. Please be aware that in certain circumstances, personal information may be subject to disclosure pursuant to judicial or other government subpoenas, warrants, or orders.

Data Security

Pace Americas offers a high level of data security to protect personal information from loss, misuse and unauthorized access, disclosure, alteration and destruction. As an agent processing personal information under the direction of its customers, Pace Americas has concluded a contract with its customers specifying the conditions under which personal information received from the EU are processed and kept secure. Pace Americas has appropriate contractual language in place with third party data processors providing that they must apply the Principles to the processing of personal data received from Pace Americas.

Data Integrity

Pace Americas only processes personal data that are relevant to the services it provides, and only for purposes compatible with those for which the data were collected. As an agent processing personal information under the direction of its customers, Pace Americas works with its customers so that they can provide a way for individuals to correct their data if necessary.

Access

As a data processor, Pace Americas has no direct relationship with the individuals whose personal data it processes. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct his query to the applicable client of Pace Americas (the data controller) which has transferred such data to Pace Americas for processing. The client will then provide access to the individual as determined under the applicable local data protection law.

Enforcement

Pace Americas uses a self-assessment approach to assure compliance with this privacy and periodically verifies that this policy is accurate, comprehensive for the information intended to be covered, prominently displayed, completely implemented and accessible and in conformity with the Principles. We encourage interested persons to raise any concerns using the information provided and we will work with our customers to investigate and attempt to resolve any complaints and disputes regarding use and disclosure of personal information. If a complaint or a dispute cannot be resolved through our internal process, we agree to dispute resolution through the applicable EU data protection authority as a third party resolution provider.

Amendments

This privacy policy may be amended from time to time consistent with the requirements of Safe Harbor. We will post any revised policy on this website.

Contact Information

Questions, comments or complaints concerning this Safe Harbor Privacy Policy or Pace Americas’ data collection and processing practices can be mailed or emailed to:

2Wire, Inc. d/b/a Pace Americas
Legal Department
1764 Automation Parkway
San Jose,
CA 95138