SKYPE PRIVACY POLICY

Your privacy is important to Skype. Therefore, Skype is committed to respecting your privacy and the confidentiality of your personal data, traffic data and communications content.

Skype Software S.à r.l and /or Skype Communications S.à r.l., both incorporated under the laws of Luxembourg, having their registered office at 22/24 Boulevard Royal, L-2449 Luxembourg, collect and process your personal information under this Privacy Policy. Skype Inc., a California company, whose business address is at 2145 Hamilton Avenue, San Jose, CA 95125, USA, collects and processes personal information about members of Skype Manager™ in the United States.

This Privacy Policy is designed to assist you in understanding how Skype uses and safeguards the information you provide in using Skype's peer-to-peer VoIP software, Skype's websites and/or Skype's products.

CONTENTS

1. WHAT IS SKYPE AND WHAT PRODUCTS DOES IT OFFER?

Skype Software S.à r.l. offers the Skype software, Skype Inc. offers Skype Manager and Skype products purchased through Skype Manager to customers in the United States, and Skype Communications S.à r.l. offers other Skype products.

2. WHAT INFORMATION DOES SKYPE USE?

Skype may gather and use information about you, including (but not limited to) information in the following categories:

(a) Identification data (e.g. name, address, telephone number, mobile number, email address);

(b) Profile information (e.g. age, sex, country of residence and any information that you choose to make available to others as part of your Skype user profile);

(d) Banking and payment information (credit card information, account number);

(e) Survey results;

(f) information about your usage of and interaction with the Skype software, our products and websites including computer and connection information, device capability, bandwidth, statistics on page views, and traffic to and from our websites;

(g) Products or services ordered and delivered;

(h) the URL of videos that you have selected to appear in your mood message;

(i) Skype test calls made to ECHO123 (which are recorded and played back to the user and deleted thereafter);

(j) List of your contacts;

(k) Your user profile;

(l) Your username and password for other email accounts where you have provided this to us and requested us to search for your friends on Skype (Please note that Skype does not retain this information or use it for any other purpose);

(m) Correspondence between you and Skype;

(n) Traffic data (data processed for the purpose of the conveyance of communications or the billing thereof, including, but not limited to, the duration of the call, the number calling and the number called); and

(o) content of chat communications (please see section 13).

3. HOW DOES SKYPE USE THIS INFORMATION AND FOR WHAT PURPOSE?

Our primary purpose in collecting information is to provide you with a safe, smooth, efficient, and customized experience. Skype collects and uses, or has third party service providers acting on Skype’s behalf collecting and using, personal data relating to you, as permitted or necessary to:

• provide communication products, in particular to convey the communications you make by means of the Skype software and/or the Skype products;

• take, process or deliver orders made via our websites, invoice you or notify you of the status of your order;

• provide other services for you (as described when we collect the information);

• provide you with customer support and troubleshoot problems;

• compare information for accuracy;

• inform you about service updates and faults;

• request feedback or participation in on-line surveys;

• resolve disputes;

• verify your identity;

• customize, measure, and improve the Skype software, our products and websites;

• to improve our search functionality and help you find contacts more easily;

• organise and carry out Skype’s marketing or promotional operations/offers, contests, games and similar events; and

• protect your and Skype’s interests, including in particular to enforce our Terms of Service and fight against fraud, (together, the Purposes).

4. OUR DISCLOSURE OF YOUR PERSONAL INFORMATION

Except as provided below, Skype shall not sell, rent, trade or otherwise transfer any personal and/or traffic data or communications content to any third party without your explicit permission, unless it is obliged to do so under applicable laws or by order of the competent authorities.

Skype may disclose personal information to respond to legal requirements, to protect Skype’s interests, to enforce our policies or to protect anyone's rights, property, or safety.

In order to provide you with Skype products you have requested, Skype may sometimes, if necessary, share your personal and traffic data with Skype’s group companies, carriers, partner service providers and/or agents, for example the PSTN-VoIP gateway provider, Wifi access services providers, distributors of Skype software and/or Skype products, and/or the third party banking organizations or other providers of payment, email delivery, analytical services, customer support, or hosting services. Skype will always require these third parties to take appropriate organizational and technical measures to protect your personal data and traffic data and to observe the relevant legislation.

Some Skype products may be co-branded and offered together with or via a partner company. If you register for or use such products, you consent to both Skype and the partner company’s use of personal data collected in connection with the co-branded product. Skype may offer its products in connection with other websites or services or may team with other online services to give you the combined results of both products/services or additional services and benefits. To determine whether you would benefit from the combined offer, if you have provided your consent, Skype may match your email address, and email addresses of your contacts against email addresses you have provided to the third party website/service provider.

If you are a member of the Business Control Panel, detailed information about the activity on your Skype account including traffic data and details of your purchases and downloads may be accessed by the Administrator of the Business Control Panel if you have agreed to such access. You can withdraw your agreement at any time by changing the settings on your account page on www.skype.com. If you provide personal data including your name and job title to be included on the Business Control Panel directory, you acknowledge that such data may be viewed by other members of that Business Control Panel.

If you leave a voicemail for another Skype user, your voicemail message may be transferred to a third party service provider (where the Skype contact you are trying to reach has signed up to receive voicemails by text message), and will be converted to text. The conversion process may in exceptional cases, require access by analysts. By using the voicemail product, you consent to the processing of your voicemail message by Skype and its service provider.

Skype, Skype's local partner, or the operator or company facilitating your communication may provide personal data, communications content and/or traffic data to an appropriate judicial, law enforcement or government authority lawfully requesting such information. Skype will provide all reasonable assistance and information to fulfil this request and you hereby consent to such disclosure

Your information may be stored and processed in any country in which Skype and its group companies maintain facilities, including outside of the EU. In this regard, or for purposes of sharing or disclosing data in accordance with this article 4, Skype reserves the right to transfer information outside of your country. By using Skype software, Skype's websites or Skype products you consent to any such transfer of information outside of your country. As Skype continues to develop its business, Skype might sell or buy subsidiaries or business units. In such transactions as well as in the event Skype or substantially all of its assets are acquired by a third party, personal information of Skype users will generally be one of the transferred business assets. We reserve the right to include your personal information, collected as an asset, in any such transfer to a third party.

5. WHAT ARE COOKIES AND GIFS HOW DOES SKYPE USE THEM?

Cookies are pieces of information that the browser of the Skype software client or your internet browser may store on your computer's hard drive. Cookies enable Skype to: recognize you or your preferences, gain information about the use of its websites, and help us to improve our products and websites. This information may be analyzed by third parties on our behalf.

The Help option on the toolbar of most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Skype software browser cookies can be disabled by: accessing the File menu from your Skype software client toolbar, choosing the Privacy option and unchecking the ‘Allow Skype Browser Cookies’ box.

Please bear in mind that some personalized services may not be available if you choose to disable cookies.

Clear Gifs

Skype web pages may include clear gifs. Clear gifs (also known as web-beacons) are tiny graphics with a unique identifier, which are used to count your visits to the page (but which do not retain any personally identifiable information). In addition, Skype uses clear gifs in our HTML-based emails to let us know which emails have been opened and acted upon. This allows us to gauge the effectiveness of certain communications and the effectiveness of our marketing campaigns.

Third Party Advertising

Skype’s advertisements appearing on third party websites are delivered to you by our carefully selected ad-serving partners (“Ad-Serving Partners”). Skype and our Ad-Serving Partners may use non-personally identifiable information about your relationship with Skype’s websites in order to provide Skype advertisements likely to be of greater interest to you and to help us measure and improve the performance of our advertising campaigns. Skype and our Ad-Serving Partners typically use a cookie or web-beacon to collect this information.

You may choose to opt-out of the use of your information in Skype's advertising efforts by clicking on the following link: http://media.skype.com/optout.html.

If you choose to opt-out, Skype's advertisements will still be delivered to you but no information about your relationship with Skype's websites will be available for this purpose.

6. YOUR USER PROFILE

Your user profile is the information provided by you at registration which is displayed in your Skype profile in the Skype software client, in the Skype search directory and on your personal details page in your account on www.skype.com. It may include your Skype user name, full name, address, telephone and mobile numbers, gender, date of birth, country, language, “about me” page URL, and any other information that you decide to make available. You can access your user profile from the “Skype” menu in the Skype software client or from your account on www.skype.com in order to view, correct or complete information, remove non-mandatory information; and to see the privacy settings associated with your profile information.

7. LINKED WEBSITES AND THIRD PARTY APPLICATIONS

Skype websites may contain links that will let you leave Skype's website and access another website. Linked websites are not under the control of Skype and it is possible that these websites have a different privacy policy. The Privacy Policy applies solely to personal information that is acquired on the websites or through your use of the Skype software, Skype products and/or your relationship with Skype, so Skype urges you to be careful when you enter any personal information online. Skype accepts no responsibility or liability for these other websites.

If you use any extras, plug-ins or third party applications together with the Skype software (“Applications”), the provider of such Applications may obtain access to certain personal information about you. Skype does not and cannot control how the provider of Applications may use any personal information connected in connection with such Applications. Please ensure that you review any privacy policies or other terms applicable to the use of such Application before installation.

8. HOW DOES SKYPE PROTECT YOUR PERSONAL INFORMATION?

Skype shall take appropriate organizational and technical measures to protect the personal data and traffic data provided to it or collected by it with due observance of the applicable obligations and exceptions under the relevant legislation. Your personal and traffic data can only be accessed by authorized employees or consultants of Skype or the concerned Skype group entities that need to have access to this data in order to be able to fulfil their given duties.

9. PERSONAL DATA OF FRIENDS

You may be interested in inviting your friends to join Skype. In the event you wish to use Skype's referral service, you will be directed to a webpage and will have the possibility of adding one or more email addresses in an online form. The information entered in this form, will only be used for the purposes of automatically generating an email message to these potential Skype users. By entering your friend’s email address you are confirming that your friend has consented to the supply of their details. Skype may identify you as the person who has made the referral in the email sent to your friend.

10. CONTACTING YOU

Skype may from time to time ask you to provide information on your experiences which will be used to measure and improve quality. You are at no time under any obligation to provide any of such data. Any and all information which is voluntarily submitted in feedback forms on the website or any survey that you accept to take part in is used for the purposes of reviewing this feedback and improving the Skype software, Skype products and websites.

Skype may contact you to send you messages about faults and service issues. Further, Skype reserves the right to use email, the Skype software or SMS to notify you of any eventual claims related to your use of Skype software, the Skype websites and/or Skype products, including without limitation claims of violation of third party rights.

Skype may send you alerts by email or SMS to notify you when someone has tried to contact you. Skype may also use email, SMS or the Skype software to keep you up to date with news about the Skype software and Skype products that you have purchased and/or to inform you about other Skype products or other Skype related information. You can opt-out of the receipt of alerts and/or promotional emails or SMS by clicking the ‘unsubscribe’ link on the email that you receive or by signing into your account page on www.skype.com.

If you have registered for or use co-branded Skype products, the emails or SMS that you receive may be from our partner company, acting on Skype’s behalf.

11. CAN THIS PRIVACY POLICY BE MODIFIED?

Skype reserves the right to modify the provisions of this Privacy Policy if deemed necessary. We will inform you of these changes by publishing the revised Privacy Policy at skype.com/go/privacy. The revised Privacy Policy shall become effective within thirty (30) days of such publishing, unless you expressly accept the revised Policy earlier. You agree that the express acceptance by you, or your continued use of the Skype software or Skype products after the notice period of thirty (30) days, shall constitute your acceptance of the Privacy Policy.

12. WHAT RIGHTS DO YOU HAVE AND HOW CAN YOU CONTACT SKYPE?

You have the right to access and, where relevant, to amend your personal information. Some of your information may be viewed or edited online by signing into your account page on www.skype.com. We will respond to requests to view, correct, complete or remove your personal information within a reasonable period of time and upon verification of your identity. Please address any questions to our customer support team.

Skype will use all reasonable endeavours to accommodate requests to delete personal information unless it is required to be retained by law or for lawful business purposes. However, please note that due to the technical nature of the peer to peer network, it can sometimes take up to two weeks before your Skype ID disappears completely from the peer to peer network. Your details may still appear in the search directory during this time.

13. HOW LONG IS YOUR PERSONAL DATA KEPT BY SKYPE?

Skype will retain your information for as long as is necessary to: (1) fulfil any of the Purposes (as defined in article 3 of this Privacy Policy) or (2) comply with applicable legislation, regulatory requests and relevant orders from competent courts.

Retention of Instant Messages.

Your chat communications content may be stored by Skype (a) to convey and synchronise your messages and (b) to enable you to retrieve your chat history where possible. Chat history messages will be stored for a maximum of 30 days. Skype will at all times take appropriate technical and security measures to protect your information. By using this product, you consent to the storage of your chat communications as described above.