Policy Overview

The purpose of this Privacy Policy is to describe the practices employed by Tangoe, Inc. with respect to the acquisition, receipt, use, and protection of the information we receive from and on behalf of our customers, prospects, and partners. We are committed to follow the guidelines set forth by the US Department of Commerce' Safe Harbor framework and as a result Tangoe provides an environment to securely process private information received from the European Union member countries and Switzerland from which we process private information.

Tangoe, Inc. complies with the U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland. Tangoe, Inc. has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view Tangoe's certification, please visit http://www.export.gov/safeharbor/

Information Collected and Intended Use

Tangoe, Inc. is the leading provider of Telecommunications Expenses Management services for corporate customers. Tangoe does not provide its service to the individual or consumer markets. In the performance of this service, the information we receive from our customers may contain one or more of the following data elements which is considered personal information related to the employees of our customers: Employee Id, Name, Title, Location, Corporate E-Mail Address, Department/Cost Center, Phone Numbers, and Corporate Address. Additionally, we receive Telecommunication Invoices including Call Detail Records associated with devices, services, and networks for which Tangoe Corporate customers are either primarily or secondarily liable.

This information is used for the sole purpose of matching charges and telecommunications inventory of Tangoe's corporate customer enabling the responsible employee's to manage the acquisition, tracking, use, and disposal of these corporate assets.

Further, upon explicit opt-in and only with the consent of the particular employee, Tangoe accepts Employee Shipping Address, Credit Card and Date of Birth information. This information is stored for the sole purpose of requesting, approving, ordering, testing, and shipping wireless devices (I.e.: Cellular Telephone, Pagers, Calling Cards, Personal Digital Assistants, etc.), accessories and service to the employee upon approval from the employee's designated manager(s). This information is forwarded to the telecommunication carrier, designated carrier representative or accessory vendor selected by the employee for purposes of procurement, fulfillment and provisioning of the requested device, service, and/or accessory. Upon being notified by the telecommunications carrier or accessory vendor the order has completed, this information is purged from Tangoe's records.

In addition, parties visiting our website (www.Tangoe.com) can visit the Site without

providing personal information; however, computers connected to the internet contain information such as IP Address (Internet Protocol Address) and Domain Name which may identify the computer and network attempting to access our web site. This information is captured and stored for tracking and monitoring purposes.

The above notwithstanding Personal Information captured and contained in the Tangoe databases and servers is not sold, licensed, or distributed to any third parties except authorized employees, partners, vendors, and suppliers for the purposes of managing corporate telecom expenses on behalf of our corporate customers.

Data Protection

Tangoe, Inc. employs reasonable and generally accepted measures to protect customer information from loss, misuse, unauthorized access, disclosure, alteration and destruction of information which includes compliance with confidentiality and non-disclosure provisions in agreements between Tangoe, Inc. and its customers, partners, suppliers, and employees.

Tangoe Inc.'s managed and hosted solutions maintain customer information on secure servers located in secure data centers. Personal information stored in secure databases requires unique login ID's and passwords in order to access the information and is only used for the intent described in this policy. Customer login ID's and passwords are provided to customers in order to allow access to the information pertaining to the specific customer for whom it is intended. Further, customer sensitive data is stored encrypted using 128-bit strong encryption keys. All access to customer data whether it is customer or internally accessed is controlled and monitored by Tangoe's professional, full time, IT staff.

All servers are located in secure Tangoe managed networks, protected by one or more firewalls restricting access to the individuals for which access is specifically intended. Extensive monitoring and security tools are utilized to ensure application, data, and network integrity.

Enforcement

Tangoe, Inc. conducts periodic internal and external audits to ensure that Customer Data is maintained in a manner consistent with this Policy and the principles of the Safe Harbor framework. In addition, Tangoe, Inc. conducts annual SAS70 Type II audits from an independent auditor to ensure IT and Operational security controls and policies are in place and enforced. Any employee, vendor, or supplier found to have violated this Policy will be disciplined, up to and including termination of employment or termination of service contract. Tangoe will further correct any deficiencies identified by internal and external audits to ensure continued compliance with this Policy.

Privacy Complaints by European Union and Swiss Citizens:

In compliance with the Safe Harbor Principles, Tangoe commits to resolve complaints about your privacy and our collection or use of your personal information. European Union and Swiss citizens with inquiries or complaints regarding this privacy policy should first contact Tangoe at:

Tangoe, Inc.
35 Executive Blvd,
Orange CT 06477 USA
ATTN: Chief Privacy Officer
OfficeOfPrivacy@Tangoe.com

For suspected violations please include a description of the violation, date or timeframe in which the suspected violation occurred and your contact information. Tangoe takes any report of Privacy violation very seriously and will investigate each report to the fullest extent possible.

Tangoe has further committed to refer unresolved privacy complaints under the Safe Harbor Principles to an independent dispute resolution mechanism, the BBB Safe Harbor, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint or if your complaint is not satisfactorily addressed by Tangoe, you may contact:

Council of Better Business Bureaus, Inc.
BBB Safe Harbor
4200 Wilson Boulevard, Suite 800
Arlington, VA 22203
Phone: 703-276-0100
Web: www. us.bbb.org
Email: eusafeharbor@council.bbb.org

Tangoe reserves the right to change this policy at any time and will post the Privacy Policy at http://www.tangoe.com/Forms/privacy-policy.html

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