Welcome to Prime Networks. Prime Networks values the privacy of its users. Prime Networks’ primary business is distribution of content, media, and applications for our customers and as such it may from time to time acquire personally identifiable information of employees of businesses considering or using our services.

Prime Networks offers data services to customers that may involve helping publishers and advertisers across our customer base gather non-personally identifiable information about their end users. Prime Networks may also offer services that could involve the collection, use or disclosure of personally identifiable information unless otherwise directed by our business customers.

Prime Networks is committed to abiding by its contractual obligations and by all local, domestic, and international laws governing the protection of personal data. This Privacy Statement sets forth company privacy policy regarding our handling of data. By using Prime Networks’ services, you agree to let Prime Networks collect and use information according to the terms in this policy. Our privacy policy may change from time to time and changes will be posted on this page.

Please note that you should consult the privacy policies of each site you visit and if you link to a third party site from Prime Networks, any information you provide to that site and any use of that information by the third party are not under the control of Prime Networks and therefore are not subject to this Privacy Statement.

I. DISTRIBUTING CONTENT, STREAMING MEDIA, DELIVERING APPLICATIONS FOR OUR BUSINESS CUSTOMERS.

1. Prime Networks functions as an intermediary service provider to Internet businesses.

   Prime Networks’ business customers receive access to our networks. Prime Networks then transmits the content these customers have chosen to move through Prime Networks’ installation of servers. In providing these services, Prime Networks facilitates and enhances communications whose content is chosen by others. Prime Networks does not initiate these transmissions, does not select the persons receiving the transmission, and does not select or substantively modify the content of the information contained in the transmission.

2. Prime Networks may automatically store data to transmit it efficiently. The data may be stored briefly or for a longer period of time, as determined by the technical requirements Prime Networks develops through working with our business customers.

   Temporary storage processes retain information only so long as is reasonably necessary to transmit the data. Intermediate storage processes retain information only so long as is reasonably necessary for continued transmission, to maintain the security of the network and the data, to permit the company to monitor and improve our performance, for related administrative purposes, or as required by our business customers. In some cases, data may be stored by Prime Networks for an extended period.

3. Prime Networks’ processing of data is determined by our business customers.

   When processing data on behalf of business customers as an intermediary service provider, Prime Networks does not collect, use, or disclose personally identifiable consumer information, except as directed by Prime Networks’ business customers. Prime Networks complies with any conditions on access to information requested by Prime Networks’ business customers, and maintains as confidential the proprietary business information of Prime Networks’ business customers, as is set forth in our contracts with them.

4. Prime Networks removes data that is no longer needed, data that it has reason to believe is being used to facilitate activity illegal in that jurisdiction, data which should legally be disabled or data that it has reason to believe will result in legal or regulatory action against Prime Networks.

   Prime Networks routinely removes data from its system after the data is no longer needed, but may store information for a variety of administrative and systems purposes for extended periods. Prime Networks will act expeditiously to remove or to disable access to information it has stored upon obtaining actual knowledge that the information at the initial source of the transmission has been removed from the network and removal is now sought, or that access to it has been disabled, or that a court or an administrative authority has ordered such removal or disablement. Should Prime Networks become aware of facts or circumstances that make it apparent that our network is being used to facilitate illegal activity, upon obtaining such knowledge, Prime Networks will act expeditiously to remove or disable access to the information.

5. Prime Networks is primarily a business-to-business company that respects obligations to consumers to protect their privacy.

   In serving our business customers, we respect the privacy and security of their consumer customers and other end users. Prime Networks may report non-personally identifiable information to its business customers about the quantity of and delivery location of information. Such information may include historical information to run customized analyses, focusing on such data as “IP” addresses, identifying usage patterns associated with addresses owned by internet service providers, or geographic concentrations of internet usage. In processing such aggregate data, Prime Networks does not collect, use or disclose personally identifiable information unless directed by its business customers to do so.

6. As a global company, Prime Networks acknowledges the importance of international standards to protect personal privacy.

   As an intermediary service provider, Prime Networks does not on its own behalf collect, use, or disclose such personally identifiable consumer or end-user information as names, addresses, and e-mails. Prime Networks expects any of our business customers who do collect, use or disclosure such information and who use Prime Networks to process that information to adhere to fair information privacy standards, including the following principles:

   Notice and Communication. We expect our business customers to communicate explicitly with consumers and other end-users about data collection and use and to identify the purpose for which personally identifiable information is collected and the extent to which it may be shared, by prominently posting clear, human-readable privacy policies on their business to consumer web sites.

   Choice, Consent and Control. We expect our business customers to limit their requests for information from consumers to the information necessary for fulfilling the level of service desired by the user. We expect them to obtain informed consent prior to the collection and use of personally identifiable information and to provide users information about their ability to review and when appropriate to correct personally identifiable information. Among the rewards of such an approach are reduced user frustration, increased trust, and the facilitation of consumer relationships through anonymous, customized, or personalized relationships, as appropriate, between our business customers and their consumer customers.

   Fairness and Integrity. We expect our business customers to treat users and their personally identifiable information with fairness and integrity. We expect our business customers accurately to represent their information practices in a clear and unambiguous manner, to use information only for the purpose stated and retain the information only so long as is necessary, to ensure that information is accurate, complete and up-to-date, and to provide the means to insure accountability and provide recourse.

7. Prime Networks maintains the security of data on our system to protect against possible loss, misuse or alteration.

   Prime Networks’ systems make use of a variety of mechanisms to protect personally identifiable information processed through our systems and stored by our business customers regarding their users against loss, misuse or alteration. These include administrative, physical and technical precautions to help protect the confidentiality, security and integrity of personally identifiable information stored on our system. Prime Networks uses appropriate trusted protocols for the secure transmission of data.

8. Prime Networks will act to protect your privacy if it learns your data is being abused.

   Prime Networks is committed to abiding by all applicable laws. Since in our capacity as an intermediary service provider we do not collect such key personal identifiers as name, address, and e-mail from consumers, we rely on business customers who may collect such data to abide by their commitments to their consumer customers. Should our business customers fail to meet those commitments, we want to know about it. If you believe any business using Prime Networks services may have failed to live up to the legal commitments they have made to protect your privacy, please tell us at support@primenets.net. We will act expeditiously to bring your complaint to our business customer, and to remove or to disable access to any identifiable personal information regarding a data subject we may have stored upon obtaining actual knowledge of the fact that the information may have been obtained in violation of a privacy law or agreement.

9. Prime Networks will act to protect propriety information if it learns proprietary data is being abused.

   As is set forth in our contractual agreements with our business customers, Prime Networks respects the confidentiality of proprietary information. If you believe that Prime Networks or anyone using Prime Networks’ services may have failed to live up to any legal commitments they have made to protect proprietary information, please notify us and we will undertake a review of the issues you have raised in an effort to reach a prompt and proper resolution. We will act expeditiously to remove or to disable access to any proprietary information whose confidentiality could be at risk upon obtaining actual knowledge of the fact that the access could violate a contractual obligation or any relevant law governing the uses of such information.

II.PERSONALLY IDENTIFIABLE INFORMATION OF EMPLOYEES OF BUSINESS CUSTOMERS.

1. Prime Networks may collect, store and use personally identifiable information of employees of our business customers to enable us to provide products, services and information to existing or potential business customers.

   In order to provide products and services to our business customers, Prime Networks has constant communications with the employees of these business customers in the scope of their employment. From time to time, Prime Networks may collect, store and use personally identifiable information regarding these employees in connection with business communications. This information may include names, company names, addresses, telephone numbers, facsimile numbers, and e-mail addresses. In addition, Prime Networks may ask employees of business customers for web site addresses, product interests, and credit-related information with respect to product purchases and other information.

2. Prime Networks may acquire personally identifiable information concerning employees of other companies through authority, permission, or consent.

   Prime Networks may acquire personally identifiable information regarding the employees of potential or existing business customers from a variety of sources. Such information may come from public sources and records, such as telephone, Internet, or business directories, or public maps and records. Other personally identifiable information may be provided to Prime Networks by the employees themselves, or by their employer or its agents.

3. Personally identifiable information collected from employees of businesses may be acquired, stored, processed, and used by Prime Networks from time to time for marketing purposes.

   Prime Networks may use personally identifiable information regarding employees of businesses for business communication and marketing purposes. We do not currently but may in the future provide such information to our vendors, suppliers and business partners to provide an employee of a business with a product or service requested by the employee or the employee’s business or to improve the operation and maintenance of our business services. We expect anyone to whom we disclose personally identifiable information of an employee of a business, not to use or disclose the employee’s personally identifiable information for other purposes, although we cannot guarantee how other vendors, suppliers, or business partners will actually use such information.

III. PRIME NETWORKS ENHANCED DATA AND CONSUMER PRIVACY

Some of Prime Networks’ services help publishers and advertisers across our customer base gather non-personally identifiable information about and gain better insight into their consumer end users.

Information We May Collect About Consumers

The information that Prime Networks finds useful to provide enhanced data services does not require the identification of individual people. As a result, Prime Networks does not collect, store, or use personally identifiable information such as names, addresses, e-mails, phone numbers or social security numbers from the consumer end users of our business customers on our own behalf. Prime Networks also does not integrate the information we collect with names, addresses, e-mails, or other data in a way that would allow us to identify any individual person.

Among the ways Prime Networks provides insight to our customers is by gathering statistical and user preference data about consumers through the use of cookies and other similar mechanisms. The information we may collect includes clickstream information, URLs, usage data regarding pages viewed, date and time, browser type, domain type, geographic location information, and other non-personally identifiable information. We may also use cookies and other similar mechanisms to collect, store, and use information about your computer system and associate this information with other non-personally identifiable information. Prime Networks retains the non-personally identifiable information we collect for no more than twelve months.

Using Data to Provide Better Insight

Prime Networks may use the information we collect to support and complete current on-line interactions between our business customers and their consumer end users, to facilitate Web site and system administration, and for research and development. Prime Networks may also distribute the information we collect on our own behalf to other Prime Networks companies, our agents, and our business customers, so long as they agree not to integrate such information with names, addresses, e-mails or other data in a way that would allow them to identify an individual person.

On occasion, Prime Networks acts as a service provider providing back-end services to a specific business customer and collects information from that customer’s websites. In those instances, the use of the data is governed by that business customer’s privacy policy.

How to Contact Us

As specified above, in providing managed services and creating Prime Networks enhanced data, Prime Networks seeks to maintain the anonymity of individuals whose data may be collected, used, or disclosed by Prime Networks. Prime Networks wants to know if you believe your personally identifiable information has been improperly used, and is prepared to respond appropriately. Should you have reason to believe Prime Networks or our business customers have failed to protect your personally identifiable data properly, we want to know about it. Please contact us at support@primenets.net. We will act expeditiously to remove or to disable access to any identifiable personal information regarding an individual we may have stored upon obtaining actual knowledge of the fact that the information may have been obtained in violation of a privacy law or agreement.

Consumer Choice

Prime Networks believes in giving consumers choice. To enable this choice, we provide consumers with the ability to opt out of allowing Prime Networks to collect non-personally identifiable information to enable our business customers to customize their Web sites through targeted advertising.

IV. PERSONALLY IDENTIFIABLE INFORMATION ON INDIVIDUAL CONSUMERS.

1. Except as required by law or recognized public policy, Prime Networks will not knowingly collect, store or use sensitive personal data, except with the individual’s permission.

   As specified above, in distributing content, streaming media, and delivering applications for our business customers, Prime Networks generally has no direct relationship with consumers and does not collect personally identifiable data on them. Prime Networks and our subsidiaries will not knowingly collect, use or disclose sensitive personal data, except with the individual’s permission, or under one of the principles specified in applicable U.S. and international privacy laws, discussed below. Sensitive personal data includes personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, health or sexual activity.

2. Prime Networks recognizes standard domestic and international legal and public policy exceptions to non-disclosure.

   Important exceptions to the general rule of non-disclosure without permission have been codified internationally in such privacy laws as the 1995 EU Privacy Directive, Title V of the U.S. Financial Services Modernization Act in 1999, and Canada’s Personal Information Protection Act (C-6). In general, information processors such as Prime Networks may collect, maintain and use personally identifiable information that could be considered sensitive or controversial with the consent of the subject of the personally identifiable information, or when the processing is necessary for the performance of a task carried out in the public interest, such as processing or publication of material from public record sources or the public media. In addition, Prime Networks recognizes other standard legal and public policy exceptions to non-disclosure set forth in these and other relevant statutes. Prime Networks may therefore collect, use and disclose personally identifiable information necessary for the establishment, exercise or defense of legal claims, as required by law, or where the collection, use and disclosure is necessary for the purposes of preventive medicine, medical diagnosis, the provision of care or treatment or the management of health-care services. As provided by applicable U.S. federal law, Prime Networks may also disclose personally identifiable information without the consent of the individual to protect the confidentiality or security of the firm’s records pertaining to the customer, the service or product, or the transaction, to protect against or prevent actual or potential fraud, for institutional risk control, to resolve customer disputes or injuries, and for various other purposes provided by law.

3. Prime Networks will provide consumers meaningful notice and choice before collecting personally identifiable information on them.

   While today most of the data that streams through or is maintained by Prime Networks is selected by Prime Networks’ business customers, Prime Networks may offer services directly to consumer customers. In such cases, Prime Networks is committed to providing consumers meaningful notice and choice before collecting personally identifiable information on them from non-public sources. If we sell all or part of our business or make a sale or transfer of assets or are otherwise involved in a merger or business transaction, we may transfer your personally identifiable information to a third party as part of that transaction as long as the acquirer agrees to comply with this privacy policy or has in place a substantially similar privacy policy. Prime Networks will provide anyone who becomes a consumer customer of Prime Networks with the ability to opt out of the provision of personally identifiable information for any purpose other than the service authorized by the consumer.

4. Prime Networks will use our best efforts to stop the processing of any disputed personally identifiable information upon notification by an individual that there may be a problem.

   If you believe Prime Networks may be processing or maintaining sensitive or personally identifiable information pertaining to you without your consent, or in violation of applicable domestic or international laws, please let us know at support@primenets.net. We will act expeditiously to disable access to any sensitive or personally identifiable information about you we may have obtained, while we work to investigate your complaint and to resolve the problem.

5. Prime Networks will respect regulations and other applicable laws governing the handling of personally identifiable information in connection with the purchase, sale, or transfer of the assets of a business.

   Recent federal bankruptcy litigation and FTC actions have highlighted new questions regarding the handling of personally identifiable information in connection with the resolution of a company’s assets involving the liquidation of those assets. These questions may also have implications for the purchase, sale or transfer of personally identifiable information in connection with other forms of corporate restructuring. Prime Networks is committed to respecting FTC regulations and any other applicable state and federal laws regarding the purchase, sale or transfer of personally identifiable information in connection with any form of purchase, sale or transfer of the assets of a business.

6. Prime Networks does not currently knowingly collect, use and disclose personally identifiable data on children under the age of 13. Prime Networks will comply with the Children’s Online Privacy Protection Act of 1998 if Prime Networks were to offer services to children under the age of 13.

   In general, any data on children that might be processed or stored by Prime Networks would be processed without modification through Prime Networks’ role as an intermediary services provider for other businesses. In the event that Prime Networks were to collect, use or disclose personally identifiable data on children on its own behalf and not as an intermediary services provider, Prime Networks will comply with the Children’s Online Privacy Protection Act of 1998 (“COPPA”) at that time, including but not limited to by obtaining verifiable parental consent, offering choice regarding disclosures to third parties, and providing parental access to information.