BeInSync™ Privacy Policy Supplement

The Phoenix Technologies Ltd. Privacy Policy (the “Policy”) describes our practices in connection with Personally Identifiable Information (PII) that we collect through our Sites and Services, including our BeInSync service. In addition, this BeInSync Privacy Policy Supplement describes our collection and use of additional types of information through the BeInSync service.

Information Collected
User Files: The BeInSync service allows users to upload their personal data files (“User Files”) for purposes of remote access, sharing, remote backup services, and other functions. We treat these User Files as PII, in that they are associated with a particular individual. However, we also provide special protections for these User Files, as described below.Usage Data: When you use BeInSync, Phoenix and its service providers may collect information about your usage of BeInSync (“Usage Data”), including:

• the amount of storage used;
• the number and size of files stored;
• the status of your account (e.g., whether you are using a free trial or have become a subscriber, when you installed the client software and registered, etc.);
• login, connection history and IP addresses;
• information on the users you have authorized for the “share” function of the service;
• names of the computers you have installed the BeInSync client software on (i.e., nicknames you have given to these computers); and
• support history (i.e., content of support emails and chat).

How Does Phoenix Use the Information Collected?
User Files: User Files are uploaded directly to and stored on third-party service provider servers and may be subject to the third-party service provider’s policies as well as Phoenix’s policies. We only use the User Files to fulfill services requested by BeInSync subscribers. We do not access or otherwise use information contained within User Files. We do reserve our ability to access and disclose User Files as required by subpoena or court order, or in other circumstances covered in Section 4.f of the Policy (“Law enforcement; emergencies; compliance”) or Section 4.e of the Policy (“Assignment”).

Usage Data: If any Usage Data is maintained in personally-identifiable form, it will be treated as PII under the Policy. For example, it may be used for the purposes set forth in Section 3(a) of the Policy and disclosed in the circumstances set forth in Section 4 of the Policy.

When Usage Data is maintained as Non-Personally Identifiable Information, such as in aggregate form, it may be used and shared for any purpose.