This privacy policy applies to www.synacor.com, www.synacor.net and www.zimbra.com, owned and
operated by Synacor, Inc. (‘Synacor’), and Synacor’s privacy practices in
connection with: the Client Websites (defined below), third party sites on
which Synacor provides advertising services, and mobile applications owned and/or
operated by Synacor or its clients. The use of information collected through
our service shall be limited to the purpose of providing the service for which
the Client has engaged Synacor.

Synacor works to ensure that the personal information
of its end users, including its clients’ end users, will be kept safe and
confidential. The following is Synacor’s Privacy Policy:

TRUSTe Privacy Certification

Introduction

Synacor is a global technology company providing
Internet solutions to enable its clients, media companies and advertisers to
build close relationships with consumers on the Internet. We provide and manage
web portals, email and other services (‘Services’) to and for our clients
(which include ISPs, computer electronics manufacturers, charities, and other
companies) on their websites and mobile applications (‘Client Websites’).
Synacor also provides advertising on its Client Websites, its Mobile App
(defined below), and to third parties for their websites.

Synacor considers the privacy and security of the
information of its users and its client’s end users to be very important. The
following privacy policy explains how Synacor collects and uses information
obtained (a) in connection with its Client Websites, (b) when you visit the www.synacor.com, www.synacor.net  and www.zimbra.com websites (‘Synacor Websites’ and, together with the
Client Websites, the ‘Websites’), (c) when Synacor provides advertising on
third party web sites, and (d) on a mobile application owned and/or operated by
Synacor or its clients (‘Mobile App’). It also describes the choices available
to you regarding our use of your personal information and how you can access
and update this information.

Synacor (and its subsidiary companies, NTV Internet
Holdings, LLC; Zimbra Technology India Private Limited; Synacor Europe Limited;
Zimbra Software, LLC; Synacor China, Ltd.; Synacor Canada, Inc.; and Sync
Holdings, LLC; Zimbra Japan G.K. and Zimbra Singapore Pte Ltd.) participates in
and has certified its compliance with the EU-U.S. Privacy Shield Framework and
the Swiss-U.S. Privacy Shield Framework.  Synacor is committed to
subjecting all personal data received from European Union (EU) member countries
and Switzerland, in reliance on the Privacy Shield Framework, to the
Framework’s applicable Principles.  To learn more about the Privacy Shield
Framework, visit the U.S. Department of Commerce’s Privacy Shield List at https://www.privacyshield.gov/list.

Synacor is responsible for the processing of personal
data it receives, under the Privacy Shield Framework, and subsequently
transfers to a third party acting as an agent on its behalf.  Synacor
complies with the Privacy Shield Principles for all onward transfers of
personal data from the EU and Switzerland, including the onward transfer
liability provisions.

With respect to personal data received or transferred
pursuant to the Privacy Shield Framework, Synacor is subject to the regulatory
enforcement powers of the U.S. Federal Trade Commission.  In certain
situations, Synacor may be required to disclose personal data in response to
lawful requests by public authorities, including to meet national security or
law enforcement requirements.

If you have an unresolved privacy or data use concern
that we have not addressed satisfactorily, please contact our U.S.-based third
party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.

Under certain conditions, more fully described on the
Privacy Shield website at https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint, you may invoke binding arbitration when other
dispute resolution procedures have been exhausted.

Information Collection and Use on
the Client Websites

Information Collected and How We Use It

We collect information (which may include login,
password, or other personal information) via the Client Websites when you
choose to provide it to us and/or from our Clients. In addition, you or our
Client may provide demographic information (such as zip code or age), or other
information as part of registration, sign-in, completing surveys, or otherwise.
You can choose not to provide certain information, but then you may not be able
to take advantage of many of the special features of the Client Websites.
Please note that we do not control the data, we only act as a data processor of
this data on behalf of our Clients. As a data processor, we will not share,
sell, rent, or trade with third parties for their marketing purposes any PII
collected by us, unless you direct us to do so.

When you download and use our Services through our
Mobile App, we automatically collect information on the type of device you use,
operating system version, and the device identifier. We do not ask for, access
or track any location based information from your mobile device at any time
while downloading or using our Mobile App or Services.

We send you push notifications from time-to-time in
order to update you about any events or promotions that we may be running. If
you no longer wish to receive these types of communications, you may turn them
off at the device level. To ensure you receive proper notifications, we will
need to collect certain information about your device such as operating system
and user identification information.

Synacor may work with third party service providers to
augment some of the information you provide on the Websites. For example, if you
have provided your email address via the Client Websites, we may work with a
third party data company to determine your age and zip code, and add that
information to our database to create more tailored advertising, content and
products.

Synacor uses the information provided to us in order
to improve the quality of the Websites, provide you with customized content
according to your preferences, and provide anonymous aggregate reporting for
internal and external clients, including disclosing some aggregate information
and user statistics to current and prospective clients, advertisers, and
content partners in order to describe our services.

Synacor may also use e-mail addresses and other
information to respond to users who communicate with us for support purposes or
otherwise. If you choose to correspond with Synacor through e-mail, Synacor may
retain the content of the correspondences, the e-mail addresses and its
responses. You may sign-up to receive marketing emails or other communications
from us.  If you would like to discontinue receiving this information, you
may update your email preferences by using the ‘Unsubscribe’ link found in
emails we send to you.

Information Collected Automatically

As is true of most web sites, we gather certain
information automatically and store it in log files. This information may
include internet protocol (IP) addresses, browser type, domain type, internet
service provider (ISP), referring/exit pages, operating system, date/time
stamp, and/or clickstream data.

We may combine this automatically collected log
information with other information we collect about you. We do this to improve
services we offer you, and to enhance our marketing, analytics, and site
functionality. IP addresses also are used to provide us an audit trail in the
case of any attempted illegal or unauthorized use of the Websites or Mobile
App.

We use mobile analytics software to allow us to better
understand the functionality of our Mobile App on your device. This software
may record information such as how often you use the application, the events
that occur within the application, aggregated usage, performance data, and
where the application was downloaded from. We do not link the information we
store within the analytics software to any personally identifiable information
you submit within the Mobile App.

Cookies and Web Beacons

Technologies such as cookies, beacons, tags, scripts
and other similar technologies are used by Synacor and/or our advertising
partners, affiliates, analytics and service providers. These technologies are
used in analyzing trends, advertising auditing and reporting, content
personalization, administering the sites, tracking users’ movements around the
site, and gathering demographic information about the user base as a whole. We may
receive reports based on the use of these technologies by these companies on an
individual as well as aggregated basis.

We also use cookies to remember users’ settings (e.g.
content preferences and, with user permission, passwords), and for authentication
purposes. Users can control the use of cookies at the individual browser level.
If you reject cookies, you may still use our site, but your ability to use some
features or areas of our site may be limited.

To manage Flash LSOs please click here:

http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html

Advertising

We partner with third parties to display and manage
advertising on the Websites and Mobile App and to display and manage our
advertising on other sites. Our third party partners may use technologies such
as cookies to gather information about your activities on those properties in
order to provide you advertising based upon your browsing activities and
interests. If you wish to not have this information used for the purpose of
serving you interest-based ads, you may opt-out by clicking http://www.networkadvertising.org or http://preferences-mgr.truste.com [or if located in the European Union click here]. Please note
this does not opt you out of being served ads. You will continue to receive
generic ads.

Controlling the use of your information

Sharing of Information by Synacor.

Synacor will not share, sell, rent or trade PII
collected on the Client Websites or from our Clients with third parties for
promotional purposes. We will not share your PII with any individuals or
non-affiliate companies except in the following circumstances:

Protection of Synacor and others: We reserve the right
to disclose information as required by law such as to comply with a subpoena,
bankruptcy proceedings, or similar legal process when we believe that
disclosure is necessary to protect our rights and/or comply with a judicial
proceeding, court order, or legal process served upon us.

Business Transfers: Synacor may transfer any
information in our possession to any successor to all or substantially all of
its business or assets that concern the Services.

Aggregation: Synacor may share aggregated usage and
demographic information collected via the Client Websites, third party web
sites, the Mobile App, and Services. However, no PII will be included in these
aggregations.

Affiliated Business We Do Not Control: We are
affiliated with a variety of businesses that jointly provide products or
services with Synacor. When an affiliated business is associated with your
transaction, we may share information that is related to such transactions with
that affiliated business that is necessary to provide products and services to
us. We only permit the use of any PII by these affiliated businesses solely as
necessary for such businesses to provide the requested products and services to
us and for no other reason.

Sharing Your Own Information with Others.

If you choose to post comments to blogs, forums, or
other editorial sections of the Websites or the Mobile App, any information you
submit there can be read, collected, or used by other users of such website.
Therefore, when using blogs, forums, other editorial sections of the Websites
or the Mobile App, or otherwise posting information online, we urge you to
think carefully about including any information (name, address, passwords,
medical information, or otherwise) that might be used to identify you or your
family members. We are not responsible for the information you choose to submit
through these features.

If a password is used to help protect your accounts
and information, it is your responsibility to keep your password confidential.
Do not share this information with anyone. If you are sharing a computer with
anyone you should always log out before leaving a site or service to protect
access to your information from subsequent users.

Information Relating to Children

Neither the Websites, the Mobile App, nor the Services
are designed for those 13 years of age and younger. Synacor does not knowingly
collect PII from anyone under the age of 13. If the company is made aware that
it has received PII from someone under 13, it will use reasonable efforts to
remove that information from its records. Children under the age of 13 should
not post in any of the blogs, forums, or other editorial sections of Websites
or the Mobile App.

Updating/Accessing/Amending/Correcting Personally Identifiable
Information

Synacor acknowledges that you have the right to access
your personal information.  If you are a user of the Client Websites or
the Mobile App, the information provided through those properties is owned and
controlled by Synacor’s clients. Please check the privacy policy on the Client
Website or Mobile App for instructions on how to modify your personal
information with the owner of that information. If requested to remove data we
will respond within a reasonable timeframe.

If you are a user of Synacor’s Website and would like
us to update, correct, delete, or deactivate any personal information that you
have provided to us on such website, please send your request to us at privacypolicy@synacor.com and we will process your request within a reasonable period of time
after receipt, not to exceed thirty (30) days. Upon request Synacor will
provide you with information about whether we hold any of your personal
information.

Synacor collects information under the direction of
its Clients, and has no direct relationship with the individuals whose personal
data it processes. If you are a customer of one of our Clients and would no
longer like to be contacted by one of our Clients that use our service, please
contact the Client that you interact with directly. We may transfer personal
information to companies that help us provide our service. Transfers to
subsequent third parties are covered by the service agreements with our
Clients.

Data Retention

We will retain your information and the personal
information we process on behalf of our Clients for as long as your account is
active or as needed to provide you services. If you wish to cancel your account
or request that we no longer use your information to provide you services
contact us at privacypolicy@synacor.com. We will retain and use your information as necessary
to comply with our legal obligations, resolve disputes, and enforce our
agreements.

Social Media (Features) and Widgets

The Websites and Mobile App may include Social Media
Features, such as the Facebook Like button and Widgets, such as the Share this
button or interactive mini-programs that run on the Websites and Mobile App.
These features may collect your IP address, which page you are visiting on the
sites, and may set a cookie to enable the feature to function properly. Social
Media Features and Widgets are either hosted by a third party or hosted
directly on the Websites or the Mobile App. Your interactions with these
features are governed by the privacy policy of the company providing it.

Security Procedures

Synacor has implemented a variety of security measures
to protect PII received by Synacor, including containing all PII behind its
secured server network and limiting its accessibility to a limited number of
authorized persons who have special access rights to such systems. We follow
generally accepted industry standards to protect the PII submitted to us, both
during transmission and once we receive it. No method of transmission over the
Internet, or method of electronic storage, is 100% secure, however. Therefore,
while we strive to use commercially acceptable means to protect your PII, we
cannot guarantee its absolute security.

Additional Information

The Websites and the Mobile App may contain links to
other sites. Synacor is not responsible for the privacy practices, the content
or the products and services offered by such websites. Because we cannot
control the activities of third parties, we cannot accept responsibility for
any use of your PII by such third parties, and we cannot guarantee that they
will adhere to the same privacy practices as Synacor. We encourage you to
review the privacy statements of any other service provider from whom you
request services. If you visit a third party website that is linked to the
Websites or the Mobile App you should read that site’s privacy statement before
providing any PII.

Changes to this Policy

We reserve the right to modify this privacy statement
at any time, so please review it frequently. If we make material changes to
this policy, we will notify you by means of a notice on this website prior to
the change becoming effective.

This Privacy Policy was last updated on May 3, 2017.

Questions about this privacy statement, the practices
or dealing with the Websites or Mobile App should be directed to:

Synacor, Inc.

Privacy Policy Administrator

40 La Riviere Drive, Suite 300

Buffalo, NY 14202

privacypolicy@synacor.com

In addition to the policies above, the following items
refer specifically to www.synacor.com.

We collect PII on www.synacor.com when you apply for a
job. If you apply for a job, we will collect through our job application
service provider, information including your name, email, address, phone number
and resume. We use a third party service provider to manage our job postings
and resume submission. This third party is prohibited from using your PII for
promotional purposes.

We utilize framing techniques on some pages of our
website to make it appear that the user is still on the website when the user
is actually on a third party website. Please be aware that you are providing
your personal information to these third parties and not to the Websites.

We post customer testimonials/comments/reviews on our
website which may contain PII. We do obtain the customer’s consent via email
prior to posting the testimonial to post their name along with their
testimonial. If you want your testimonial, comments or reviews removed please
contact us at privacypolicy@synacor.com.

You will not receive any communications from the
Synacor.com website unless you contact us for a specific request or submit a
job application. See above how to modify your PII submitted.

In addition to the policies above, the following items
refer specifically to www.zimbra.com

We may share your information with third parties who
provide services on our behalf to help with our business activities such as
processing payments. These companies are authorized to use your personal
information only as necessary to provide these services to us.