EMC Corporation Privacy Statement

General information

EMC respects the privacy of our customers, business partners, employees and job applicants, and other visitors to our websites who may choose to provide personal information. We recognize the need for appropriate protections and management of personal information that you provide to us. This Privacy Statement will assist you to understand what types of information we may collect, how that information may be used, and with whom the information may be shared.

Scope

This Privacy Statement applies to EMC Corporation (including its divisions and wholly-owned subsidiaries) worldwide.

Information we may process about clients of our customers is dealt with separately. For details of this please see the section entitled "Personal information of our customer's clients" below.

Safe harbor compliance

EMC has certified its participation, and compliance with, the U.S. Department of Commerce Safe Harbor framework regarding the transfer of personal information from European Union member countries to the United States. The principles of Safe Harbor compliance are notice, choice, onward transfer, security, data integrity, access, and enforcement. Additional information about the Safe Harbor principles and certification process can be found at www.export.gov/safeharbor.

What personal information does EMC process?

Personal Information is information that identifies or can identify a specific individual. EMC may collect information about individuals such as their name, address, telephone number or e-mail address. EMC may collect certain personal information from customers, business partners, employees and candidates for employment. EMC does not collect personal information when you visit EMC's web sites unless you choose to provide it to EMC.

• Customers and Business Partners — On EMC web sites you can order products or services, register products, request information, subscribe to marketing or support materials, register to a secure extranet site to obtain access to product information, support, services, and training. EMC will collect personal information from you for these purposes. The types of information you provide to EMC on these pages may include name, address, phone number, e-mail address, user IDs and passwords, billing and transaction information, credit card or other financial information, and contact preferences.
• Employees and Applicants — EMC also collects personal information from its employees and applicants (human resources data) in connection with its recruiting and hiring activities and administration of its human resources programs and functions. Current EMC employees can go on-line to access their individual employee profiles, job-related data, compensation and benefit information, to make benefit elections and transactions and to make changes to their personal information.

How does EMC use customer and business partner personal information?

EMC will use personal information to provide customers and business partners with information and services and to help us better understand your needs and interests. Specifically, we use your information to help you complete a transaction or order, to communicate with you, to deliver products/services to you, to bill you for products/services you purchased, and to provide ongoing service and support. Occasionally we may use your information to contact you to complete surveys that we use for marketing and quality assurance purposes. Personal information collected online may be combined with information you provide to EMC through other sources such as trade shows or seminars. We may also use it to contact you by electronic or other means such as telephone or mail, to tell you about products and services of EMC or its subsidiaries and divisions, or, if we think this may interest you, of other parties.

EMC may share the personal information that you have submitted to EMC with third parties in responding to your requests for products or services or product evaluations. Also, we may on occasion share information to allow selected partners to send you special offers in blind mailings. If your information is sourced from within the EU, you will be given the opportunity to opt out of having your personal information used and/or shared for marketing purposes, or we will obtain your prior agreement to this as applicable under relevant laws. However, if you request information on any of our products/services, EMC may provide your information to third party distributors and resellers who may subsequently contact you directly regarding such products/services. In these instances, you will not have the opportunity to opt out of having your information shared with these third party distributors and resellers, as the transfer of data is necessary to provide the products or services you requested.

Some of EMC's websites make on-line newsgroups, chat forums and blogs available to our users. Any information that is disclosed in these forums becomes public information and you should exercise caution when deciding to disclose your personal information. EMC may, from time to time, send e-mail (in accordance with applicable laws) regarding our products and services to users who have posted to our newsgroups. Each participant's opinion expressed in a newsgroup is his or her own and should not be considered as reflecting the opinion of EMC. Some EMC websites also provide for "Live Chat" wherein EMC personnel can monitor the user's areas of interest in the web site and engage in instant messaging with the user to provide additional information or answer any questions. By posting in our newsgroups and using "Live Chat" you expressly consent to these uses of your information.

Should we undergo any sort of corporate reorganization in the future, we may need to provide your information to the resulting entity. We may also provide it to law enforcement agencies if they request it or if we feel this is necessary to protect our business, employers, suppliers or customers. We will only do this once we are satisfied it is appropriate to do so.

How does EMC use employee, contractor and job applicant personal information?

EMC uses personal information of its employees, contractors, and job applicants for a variety of human resources and similar functions, including job applications and hiring programs, compensation and benefit programs, performance appraisals, training, business travel, expense and tuition reimbursement, identification cards, access to EMC facilities and computer networks, employee profiles, internal employee directories, human resources recordkeeping, compliance with legal requirements and other employment related purposes.

Unless permitted by relevant laws, or you have agreed to this, EMC does not use your personal information for a purpose other than as provided in this Privacy Statement or for the stated purpose identified at the time such information is collected, received or stored. Where appropriate under applicable laws, you will be given a more detailed explanation of these data uses at the relevant time.

Personal information given to EMC may be transferred within EMC or to its appointed business partners or service providers across state and country borders for efficient data consolidation, storage and simplified information management in accordance with applicable law. We will place appropriate restrictions on the recipients and require them to adequately protect the information according to relevant laws.

With whom does EMC share personal information?

EMC contracts with third party service providers and suppliers to deliver complete products, services and customer solutions. EMC may share personal information with its service providers and suppliers for the sole purpose and only to the extent needed to support the customers' business needs. Service providers and suppliers are required to keep confidential and secure the personal information received from EMC and may not use it for any purpose other than as originally intended.

Human resources data may be shared with third party vendors for the exclusive purpose of enabling the vendor to provide service or support to EMC in connection with these human resources programs and functions. Personal data concerning EMC employees is not shared with third parties for non-employment related purposes, unless disclosure of such information is reasonably necessary to comply with any applicable law, legal process, or enforceable governmental inquiry.

Third party vendors, service providers and suppliers receiving personal information are expected to apply the same level of privacy protection as contained in this Privacy Statement. However, unless otherwise dictated by law or agreement, EMC is not responsible for any improper use by such parties.

Unless permitted by relevant laws, or you have agreed to this, EMC will not share personal information you provided to EMC with any other third parties without your permission, or sell, trade or lease your personal information to others, except as provided in this Privacy Statement.

Choice and consent

EMC does not require that customers, business partners or non-employee visitors to EMC websites provide EMC with personal information. The decision to provide personal information is voluntary. If you do not wish to provide the personal information requested, however, you may not be able to proceed with the activity or receive the benefit for which the personal information is being requested. To exercise any opt out rights under applicable laws, please notify EMC of your desire to do so at emarketing@emc.com or EMC, 176 South Street, Hopkinton, MA, USA, 01748-9103. It may take a reasonable period of time to process your request.

EMC employees and applicants for employment are required to provide EMC with personal information as a condition of employment, or applying for employment, with EMC. This information is used by EMC and may be shared with third party vendors in connection with EMC's administration of its human resources programs and functions consistent with the terms of this Privacy Statement and applicable law.

Sensitive information

Sensitive information is defined as personal information specifying medical or health conditions, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, or information specifying the sex life of the individual.

Except as provided below, EMC does not request or receive sensitive information from visitors to our web sites. EMC may receive sensitive information such as medical or health conditions, or race and ethnic data regarding its employees or their dependents in connection with the administration of its health and welfare benefit plans, or as part of government mandated recordkeeping requirements where required by law. Such information will not be shared with third parties except as permitted by applicable law or as required in connection with the administration of human resources programs. In addition, sensitive information that has not been made public by an affected employee will not be used for a purpose other than its original purpose without the employee's approval unless allowed under applicable law. Where appropriate under applicable laws, you will be given a more detailed explanation of sensitive information uses at the relevant time.

Access to and accuracy of personal information

EMC strives to keep your personal information accurate. We have implemented technology, management processes and policies to maintain data integrity. EMC will take reasonable steps to ensure that the data is complete, accurate and reliable for its intended use. We will provide you with access to your information when reasonable, or in accordance with relevant laws, including making reasonable effort to provide you with online access and the opportunity to change your information. To protect your privacy and security, we will also take reasonable steps to verify your identity before granting access or making changes to your data. Requests to delete personal data are subject to any applicable legal and ethical reporting or document retention obligations. A request to access, delete or correct your personal information may be made to emarketing@emc.com or EMC, 176 South Street, Hopkinton, MA, USA 01748-1903.

Security of personal information

EMC is committed to taking reasonable efforts to secure the personal data you choose to provide us. To protect the privacy of any personal information you may have provided, EMC employs industry-standard controls including physical and logical access controls, Internet firewalls, intrusion detection, anti-virus protection, and network monitoring, and, where appropriate, Secure Socket Layer (SSL) or similarly encrypted browsers. In addition, access to sensitive information as defined in this Privacy Statement is limited to those individuals and agents having a need to know.

Other information/logging and cookies

EMC collects and/or logs Internet Protocol addresses, Internet domain names, the web browser and operating system used to access the EMC web site, the files visited, the time spent in each file, and the time and date of each visit.

EMC also uses cookies on some of its web sites. Cookies are identifiers that can be sent from a web site via your browser to be placed on your computers hard drive. Thereafter when you visit a web site, a message is sent back to the web server by the browser accessing the web site. You may elect not to accept cookies by changing the designated settings on your web browser. However, not utilizing cookies may prevent you from using certain functions and features of web sites. The information collected from the use of cookies is used and analyzed to improve EMC's web sites, such as by gaining a better understanding of your interests and requirements regarding our website.

You can set your browser to notify you when you are sent a cookie, giving you the chance to decide whether or not to accept it. The information we collect and analyze is used to improve our service to you and personalize your web-browsing experience.

EMC uses the services of a third party vendor to help us measure the effectiveness of our advertising and how visitors use EMC.com. To do this, we may use web beacons and cookies provided by this vendor on this site. The type of information we collect includes the pages visited, navigation patterns, etc. This information helps us learn things such as what product information is of most interest to our customers, and what kinds of offers our customers like to see. Although the vendor logs the information coming from our site on our behalf, EMC controls how that data may and may not be used. If you do not want to assist EMC in improving our site, products, offers and marketing strategy, you can "opt-out" of this web-site analysis tool by clicking here: https://documents.hitbox.com/optout.html.

Websites of EMC subsidiaries or divisions may use similar tracking tools for similar internal business purposes only. These websites may not offer this opt-out functionality.

Links to non-EMC websites and third parties

The EMC websites may provide links to third-party websites for your convenience and information. If you access those links, you will leave the EMC web site. EMC does not control those sites or their privacy practices, which may differ from EMC's. We do not endorse or make any representations about third party websites. The personal data you choose to give to unrelated third parties is not covered by the EMC Privacy Statement. We encourage you to review the privacy policy of any company before submitting your personal information.

Verification

EMC will engage in periodic self-assessment to verify that it continues to be in compliance with this Privacy Statement.

Contact information

If you have any questions or comments regarding this Privacy Statement or believe that the privacy of your personal information has not been respected, you may make a written submission to the attention of EMC's Office of the General Counsel, at general_counsel@emc.com or 176 South Street, Hopkinton, MA, USA, 01748.

Dispute resolution

If an employee living in an E.U. member country has a complaint regarding the transfer of human resources data to the U.S., EMC agrees to cooperate with the appropriate European data protection authority for handling such complaints. EMC agrees to handle all other disputes involving the transfer of personal data from the EU to the U.S. in accordance with the JAMS dispute resolution procedures applicable to international disputes, which are available for review at http://www.jamsadr.com.

Except as provided above, dispute resolution for all other individuals shall be in accordance with applicable law.

Personal information of our customers' clients

When we provide services to our customers, in some instances we process personal information about their clients ("Client Information") on their behalf. In these situations it is our customers rather than we who decide the reasons for which the Client Information will be processed. For details of how the Client Information will be used and protected, and details of how to access or correct the information, please refer to the privacy policy of the EMC customer to whom you submitted your personal information. Relevant laws may oblige customers to require that we comply with the same security rules that they are subject to under such laws.

Changes to this statement

EMC will review and update this Statement periodically, and will note the date of its most recent revision below.

Revised: October 2007