Xdrive LLC, a wholly owned subsidiary of AOL LLC, (hereinafter collectively referred to as "Xdrive") is a licensee of the TRUSTe Privacy Program. TRUSTe is an independent, non-profit organization whose mission is to enable individuals and organizations to establish trusting relationships based on respect for personal identity and information by promoting the use of fair information practices. This privacy statement covers the site www.xdrive.com. Because we are committed to protecting our users' privacy, Xdrive has agreed to disclose its information practices and have its privacy practices reviewed for compliance by TRUSTe.

If you have questions or concerns regarding this statement, please contact Xdrive by e-mail at xdriveprivacy@aol.com. If you do not receive an acknowledgment of your inquiry or if we do not satisfactorily address your inquiry, you may contact TRUSTe through the TRUSTe Watchdog Dispute Resolution Process. TRUSTe will serve as a liaison with us to resolve your concerns.The TRUSTe program covers only information that is collected through this Web site, and does not cover information that may be collected through software downloaded from the site.

What is Xdrive and why is my information needed?

Xdrive is a Web based service providing online storage space and related services that customers can use to store, share, access, and protect important files. This policy explains the personal information we collect in connection with your use of the Xdrive,service and how we use it. If you access Xdrive with your User ID or screen name from your AOL membership or as a user of the AOL Network, the AOL Member Privacy <http://about.aol.com/aolnetwork/mem_policy> or AOL Network Privacy Policy <http://about.aol.com/aolnetwork/aol_pp> will continue to apply to AOL's collection and use of your personal information, except as described below.

What personal information does Xdrive collect from me?

Xdrive collects personal information when you register, including your screen name, first name, and last name. (If you registered for Xdrive before 9/10/2006, we also collected a password, and valid user ID or screen name.) If you upgrade to or register for a paid account, Xdrive will ask for your payment information in order to provide you uninterrupted service. Once registered, you are part of the Xdrive community, a customer account is created, and you can take full advantage of Xdrive's services.

After you register, we may ask you for additional personal information from time to time, such as when you respond to a survey or request for information about your preferences, enter a contest or promotion sponsored by Xdrive, and when you report a problem with the service or with your account. If you contact Xdrive we keep a record of that interaction, including any email you send. A link is included to this Privacy Policy wherever Xdrive collects personal information.

What are cookies and how does Xdrive use them?

In order to provide a personalized service, Xdrive uses cookies to store some information about your account. A cookie is a small amount of data that is sent to your browser from a web server that is stored on your computer's hard drive. Xdrive uses both session ID cookies and persistent cookies. Generally, we use cookies:

• To establish an authenticated session with the service when you login to your Xdrive account using our web interface. When you use Xdrive's web interface to access your account, logging in will require that you accept a session ID cookie. When you close your web browser, the session ID cookie will terminate.


• To remember some of your basic account preferences in order to deliver a better, more personalized service. A persistent cookie may be set when you register, "Sign In," or use the Xdrive web interface to record certain application settings and other preferences.

You have choices with respect to cookies. By modifying your browser preferences, you have the choice to accept all cookies, to be notified when a cookie is set, or to reject all cookies. If you choose to reject all cookies, you will be unable to access your Xdrive account via the web interface.

Xdrive may also record your IP address for system administration, monitoring, and fraud prevention purposes.

This privacy statement covers the use of cookies by Xdrive only and does not cover the use of cookies or web beacons by any advertisers on the site or any other business partners. Some of our business partners (e.g., advertisers) use cookies on our site. We have no access to or control over these cookies.

Advertising Networks

We and our advertisers may from time to time use advertising network providers to help present advertisements on Xdrive. These advertising networks use cookies, web beacons, or similar technologies on your computer in order to provide targeted advertisements about goods and services that may be of interest to you while visiting other Web sites. We may share certain information about you as a user that is not personally identified to you (such as user age and zip code) with certain advertising network providers in order to help them deliver more relevant advertisements through their ad networks. The use of cookies, web beacons, or similar technologies by ad network providers is subject to their own privacy policies. If you are a registered member of AOL or a registered user of the AOL Network, please review the AOL Member Privacy Policy <http://about.aol.com/aolnetwork/mem_policy > and the AOL Network Privacy Policy located at <http://about.aol.com/aolnetwork/aol_pp> for more information about ad network providers and the choices you have about these technologies as users of the AOL services. If you are not an AOL member or a registered user of the AOL Network, we encourage you to return to this section periodically for updated information about advertising networks and the choices that you have about these technologies.

How does Xdrive use my information?

Xdrive uses the personal information we collect or receive about you to operate and improve the service, as well as to communicate with you and respond to your inquiries.

Xdrive will use your e-mail address to send you e-mails that are generated when you perform certain functions within the service. The types of e-mails that are sent include, but are not limited to, welcome e-mails, share e-mails, and cancellation e-mails.

Xdrive does research on customer demographics and behavior based on the information you provide and how you use the service. We gather information about how you use the service using log files, tracking pixels, and database history tables. We do this to better understand and serve our customers. This research is compiled and analyzed on an aggregated and de-identified basis.

With whom does Xdrive share my information?

Xdrive will not disclose any of your Xdrive personal information except when we have your permission; in response to legal process or under the circumstances described below. Xdrive does not sell or give access to our customer e-mail list or other customer profile information to third parties. The following describes some of the ways that your information may be disclosed.

• Data in the Aggregate: Xdrive may disclose aggregated statistics (for example, 45% of our users are female) in order to describe our services to prospective partners, advertisers, and other third parties, and for other lawful purposes.


• Service Providers: When you sign up for an Xdrive premium paid service, we will pass relevant information to a third party payment processing company. Sensitive payment information (for example, credit card account number) is encrypted for added security during these transmissions. We prohibit these companies from retaining, sharing, storing or using this personally identifiable information for any other purpose.
  Xdrive is a wholly owned subsidiary of AOL LLC, which also performs certain operational functions on behalf of Xdrive. For example, AOL LLC processes several types of e-mail for Xdrive, including but not limited to welcome, cancellation and share e-mails. To facilitate these operations, Xdrive provides AOL LLC with your e-mail address information. AOL LLC also provides billing services for Xdrive, and Xdrive will provide AOL LLC with your billing information to assist with the processing of Xdrive billing transactions.
  For AOL Network users or AOL Members using Xdrive, certain AOL offerings may require interactivity with Xdrive services, and your Xdrive personal information may be shared with AOL in connection with such offerings.
• Third Party Retail Distributors: If you register for Xdrive through one of our third party retail distributors, Xdrive may disclose your email address to that specific third party retail distributor.
• Xdrive Files: We do not use the data, information or files that you submit, upload, post, or download on or through Xdrive ("Xdrive Files"). If, however, you disclose your Xdrive Files on public areas of the service, or make such Xdrive Files available to others, such as by sharing, you understand and agree that other online users will have access to any information you provide.
• Special Circumstances: Your Xdrive account information or your Xdrive Files may be accessed and disclosed in response to legal process (for example, a court order, search warrant, or subpoena); in other circumstances in which Xdrive believes the Xdrive service is being used in the commission of a crime; when we have a good faith belief that there is an emergency that poses a threat to the safety of you or another person; or when necessary either to protect the rights or property of Xdrive, or for us to render the service you have requested.

What is Xdrive's policy on allowing me to update, correct, or delete my personal information?

You can edit your Xdrive account information at any time by accessing your account using our web interface. Your profile information can be modified by accessing the "My Profile" page once you are logged in. Information associated with your screen name, if applicable, must be modified within the Screen Name Service (SNS).

What security precautions are in place to protect the loss, misuse, or alteration of my information?

When you register for an Xdrive account, the signup page may ask you for sensitive information (such as your credit card number). We use industry-standard SSL encryption to help protect the registration information you provide.
Your Xdrive account information and Xdrive customer profile are password-protected to help ensure that you, and only you, have access to this personal information. You may edit your Xdrive account information by logging into our web interface using your Xdrive username and password.

We require that you do not divulge your password to anyone. Xdrive will never ask you for your password in an unsolicited phone call or e-mail. Also remember to sign out of your Xdrive account and close your browser window when you finish your work to help ensure that others cannot access your personal information or files if you share a computer with someone or use a computer in a public place like a library or Internet cafe.

As a global company, Xdrive has international sites and users all over the world. When you give Xdrive personal information, that information may be sent electronically to servers outside of the country where you originally entered the information, such as to the United States or other countries. In addition, that information may be used, stored and processed outside of the country where you entered it.

Unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, Xdrive cannot ensure or warrant the security of any information you transmit to us or while using the service, and you do so at your own risk. We have implemented technical, administrative, and physical safeguards designed to help protect personal information stored in our systems.

How Xdrive uses contact information that you might provide when "Sending a File" or "Sharing a Folder"?

When you use Xdrive to "Send a File" or "Share a Folder" with someone, you normally enter the intended recipient's e-mail address into the system so that a message can be sent informing him or her of the share. We do not sell or make those e-mail addresses available to any 3rd parties.

When you use Xdrive's "Send a File" feature, you can elect to have the system send a notification message on your behalf by entering the e-mail address(es) of the person(s) with whom you want to share the file. If you prefer, you can instead generate a web link to the file, which can be sent as part of your own message. Send a File notification messages sent by Xdrive are one-time only messages with the sole intent of notifying the recipient of the shared file.

Using Xdrive's "Share a Folder" feature requires that the person with whom you are sharing have an Xdrive account to access the folder. If the person with whom you are sharing does not already have an Xdrive account, a free sharing account will be created for that person when you share the folder. Xdrive will automatically send an e-mail inviting the person to activate their free account so they can access the folder you have shared. To activate, the sharing account holder will need to register for the service and will need to provide standard information to do so.

What else should I know about my privacy?

Please keep in mind that whenever you voluntarily disclose personal information online - for example on message boards, through e-mail, or in chat areas - that information can be collected and used by others. Xdrive does not control and is not responsible for how others use that information.

This web site contains links to other sites. Please be aware that Xdrive is not responsible for the privacy or other practices of other sites. We encourage our users to be aware when they leave our site and to read the privacy statements of each and every web site that collects personally identifiable information. This privacy statement applies solely to information collected by this web site.

Ultimately, you are responsible for maintaining the secrecy of your passwords and/or any account information. Please be careful and responsible online.

Additional Information

Questions regarding this statement should be directed to xdriveprivacy@aol.com or to Xdrive LLC, 331 N. Maple Drive, Beverly Hills, CA 90210.

Other Resources

• Electronic Frontier Foundation - a civil liberties organization working to protect your rights online.
• Electronic Privacy Information Center - established to focus public attention on emerging civil liberties issues relating to the National Information Infrastructure.
• Privacy Issues Page - from the Center for Democracy and Technology (CDT).
• The EPIC Cookies Page - definitions, links, and news.
• How to Protect Your Privacy - information from the Federal Trade Commission

Updated on: 03/05/07