Privacy and Security Statement

Effective Date: January 1, 2011

ADARA Networks, Inc. (“Adara”) is committed to protecting the personal information of persons who visit and use http://www.adaranetworks.com and all other publicly accessible web sites owned or operated by or on behalf of Adara (collectively, the “Site”). Adara is committed to adhering to the U.S. Safe Harbor Privacy Principles of Notice, Choice, Onward Transfer, Security, Data Integrity, Access and Enforcement. This privacy statement applies to all information collected by the Site or submitted for use in connection with the Site.

AGREEMENT

Your access and use of the Site indicates your acknowledgment of the terms of this privacy and security statement, as posted each time you access the Site. Please review this privacy and security statement periodically for changes.

The Personal Information Adara Collects

On the Site, persons and entities may voluntarily make requests for information and publications on products, services, the trade, trade-related science and technology, or apply and register for certain memberships, programs, accounts, as made available by Adara from time to time. In order for Adara to process any such requests or applications, you may have to provide certain personal information such as your name, date of birth, email address, postal address, telephone number, username, password, credentials, or other information that permits Adara to contact you. By voluntarily providing personal information to Adara, you consent to the collection and use of the information by Adara and its designated agents (service providers) for the related activity and for the other uses set forth herein.

How Adara Uses Personal Information

Adara uses personal information to carry out the purpose for which the information was provided with your consent.

Adara does not share personal information with third parties except under limited circumstances:

(a) with your consent, to carry out the purpose for which the information was provided, including the use of designated agents (service providers) for the processing of information based on our instructions and in compliance with this policy and other appropriate security and confidentiality measures;

(b) to the extent necessary to meet any applicable law, regulation, legal process or enforceable government interest, including but not limited to, national security, public interest, or law enforcement requirements;

(c) to the extent necessary to protect against harm or damage to persons, property or rights of Adara, its users or other members of the public as required or permitted by law; and

(d) to the extent necessary to enforce the terms of use of our Site and/or to detect or prevent fraud and otherwise to protect the security or integrity of the Site.

To the extent Adara is compelled to disclose personal information, it will use commercially reasonable efforts to notify all affected persons, unless doing so will violate the law or court order. Adara encourages all of its business partners to adopt and adhere to standards of protection consistent with this policy.

Promotions and Offers. Adara may also use personal information to provide updates and information on Adara products and services, sales and advertising materials, catalogs, newsletters, and special offers.

Electronic Mail Advertisements: Adara will not use personal information to send electronic mail advertisements except to those recipients with whom Adara has an existing business or personal relationship or who have expressly consented to the receipt of such advertisements.

Business Transfers. In the future, Adara may be sold or acquired along with its assets, or other business transactions may occur in which personal information of customers is transferred along with other assets of the Company. By providing personal information, you consent to the disclosure and transfer for this purpose. Adara will use commercially reasonable efforts to require before disclosure that any prospective successors and assigns have appropriate physical, electronic, and managerial procedures to safeguard and secure personal information.

Sensitive Information – “Opt-In” Consent to Giving Information

Adara will require your “opt-in” consent for the collection of sensitive information (i.e. personal information specifying medical or health conditions, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership or information specifying your sex life, if relevant).

You Can “Opt-Out” From Receiving Information

You may withdraw your consent (“opt-out”) from receiving any informational or promotional materials by simply contacting Adara at IT@adaranetworks.com and requesting that no further information, materials or offers be sent to a specific postal address and/or email address. Adara will honor and process all such requests within a commercially reasonable amount of time after receiving the request.

YOU CAN UPDATE YOUR PERSONAL INFORMATION

You may update or delete your personal information from the Site by contacting Adara at IT@adaranetworks.com. Adara will use commercially reasonable efforts to honor and process all such requests within a commercially reasonable amount of time after receipt of the request.

PLEASE BE AWARE THAT IT MAY NOT BE TECHNOLOGICALLY FEASIBLE TO REMOVE EACH AND EVERY RECORD OF THE INFORMATION THAT YOU HAVE PROVIDED TO ADARA IN ELECTRONIC FORM. Due to the nature of storage of electronic records, a copy of your personal information may exist in a backup system that is in non-erasable form or that is difficult or impossible to locate. Notwithstanding, Adara will take commercially reasonable steps to delete all personal information in active and readily accessible and searchable media after receiving a request to delete personal information.

The Non-Personal Information That is Collected – Use of “Cookies” and “Web Beacons”

Adara may collect anonymous, non-personally identifiable information from your visit to the Site (“Aggregate Data”), such as: your computer IP address, the type of software browser you are using to visit the Site, the type of operating system your computer is using, the domain name of your Internet Service Provider, data about the number of times you have visited the Site, the web pages visited and the emails and newsletters that we may send you. Adara may use Aggregate Data to monitor how many people are using the Site, opening emails, and for what purposes. In addition, Adara may use Aggregate Data to determine the popularity of certain content and to customize information and services to you and other visitors to the Site.

Adara may place a small piece of software on your computer called a “Cookie” or embed a small graphic image file in an email or on a web page called a “Web Beacon” that sends the anonymous, non-personal Aggregate Data to us or a third party sponsor. Your browser software used to visit the Site can be set to reject all Cookies. However, certain features of the Site may not function properly if you reject Cookies. Adara will not link non-personal Aggregate Data with personal information.

Adara’s Commitment to Security; Your Responsibilities for Security; Limitation of Liability

Adara’s Commitment to Security
To protect personal information from loss, misuse and unauthorized access, disclosure, alteration and destruction, Adara and its service providers utilize generally accepted industry standard physical, electronic and managerial procedures to safeguard and secure the personal identifying information that Adara collects online. Subject to the terms and conditions hereof, such information is not made available to any person or entity outside of Adara, its staff and designated agents (service providers).

Personal information will generally be stored in Adara databases or databases maintained by Adara service providers on servers located in the United States or other country where Adara or its service providers may have an office. By providing personal information through this site, you acknowledge and consent to the transfer, processing and storage of personal information across national boundaries.

Personal Identification Information (Login Names and Passwords). You must take precautions to prevent unauthorized access and use of your personal identification information, including but not limited to, login names and passwords. For example, you should not disclose to anyone for any purpose personal passwords or other personal identification information used to access and/or conduct transactions on the Site. You are solely responsible for all results (claims, liabilities and damages of any kind) arising from or related to your disclosure of your personal identification information to another person or entity, whether the disclosure was intentional or not.

No Unauthorized Use of Another’s Personal Identification Information. You agree not to use anyone else’s personal identification information without proper authorization. If we learn that you are using someone else’s personal identification to access and use the Site, Adara reserves the right to terminate your access privileges, in addition to any and all other rights and remedies we may have or be entitled to.

DUE TO THE NATURE OF ELECTRONIC COMMUNICATIONS AND STORAGE, YOU ACKNOWLEDGE AND AGREE THAT THESE SECURITY MEASURES MAY NOT PREVENT ALL LOSS, MISUSE, THEFT OR ALTERATION OF INFORMATION COLLECTED FROM THE SITE AND THAT THE EXCLUSIONS OF WARRANTIES AND LIMITATIONS OF LIABILITY PROVISIONS OF ADARA’S TERMS OF USE OF THE SITE (INCORPORATED BY THIS REFERENCE AS THOUGH FULLY SET FORTH HEREIN) APPLY TO THE LOSS, MISUSE, THEFT OR ALTERATION OF INFORMATION AND DATA, TO THE MAXIMUM EXTENT PERMITTED BY LAW.

Links to Third Party Sites

This privacy and security statement only applies to information collected by Adara. This privacy and security statement does not apply to the practices of persons or entities that Adara does not own, control, or manage. The Site may contain links to third party websites. Any information you provide to, or that is collected by, third-party sites may be subject to the privacy policies of those sites, if any. Adara encourages you to read such privacy policies of any third party sites you visit. It is the sole responsibility of such third parties to adhere to any applicable restrictions on the disclosure of your personally identifying information, and Adara, its affiliates, and each of their respective directors, officers, employees, agents and representatives shall not be liable for wrongful use or disclosure of your personally-identifying information by any third party.

Adara’s Commitment to Children’s Privacy

This site is not designed or intended to attract children under the age of 13. Adara does not collect information from any person that it actually knows to be under the age of 13.

Enforcement

Adara periodically reviews its process and procedures for compliance with this policy, If Adara receives a formal written complaint regarding the use or transfer of personal information, Adara will contact the complaining party regarding the concerns raised in the complaint. To the extent Adara cannot resolve the concerns directly with the complaining party, Adara will cooperate with appropriate regulatory and local authorities to resolve the complaint regarding the use or transfer of personal information and data.

Modifications

Adara reserves the right to change this privacy and security statement at any time. Adara will post all changes of this privacy statement on adaranet.com and/or e-mail you notification of such changes. You should periodically review adaranet.com and this privacy statement for changes.

HOW TO CONTACT ADARA FOR ANY REASON

You may contact Adara regarding questions or comments about this privacy statement or for any reason at IT@adaranetworks.com.

Privacy and Security Statement