Oracle Services Privacy Policy

As a global corporation with operations in over 80 countries, Oracle has developed global information practices designed to assure that the information Oracle has about its customers ("customer information") and the data that we may access or host in order to provide services ("services data") is appropriately protected.

In order to perform services in a timely and cost-effective manner, Oracle may transfer services data to an Oracle office, service engineer or consultant in another country. All Oracle employees and offices worldwide that access services data are required to comply with our global data protection requirements.

Oracle's privacy practices, including its practices for services data, are self-certified to the Safe Harbor Program agreed to by the US Department of Commerce and European Commission. For more information about the Safe Harbor, please go to http://www.export.gov/safeharbor/. In addition, Oracle is a licensee of the TRUSTe Privacy Program, and Oracle's general privacy policy is certified by TRUSTe.

Customer Information is information that we may collect from your use of the Oracle.com Web sites and your interactions with us off-line. We deal with customer information according to the terms of our general privacy policy.

Services Data is data that resides on Oracle, customer or third-party systems to which Oracle is provided access to perform services (including On Demand environments as well as test, development and production environments that may be accessed to perform Oracle consulting and support services). Oracle treats services data according to the terms of this policy, and treats services data as confidential in accordance with the terms of your order for services.

To illustrate the difference between customer information and services data, when a customer contracts with Oracle for On Demand services, the customer provides information about itself, including its name, address, billing information, and some employee contact information. Oracle's Web sites may also collect some information about the customer and some employees as part of that interaction. All of that information is customer information, and is treated according to Oracle's general privacy policy.

In contrast, having contracted with Oracle for On Demand or other services, the customer then provides Oracle with access to its production, development or test environment, which may include personal information about its employees, customers, partners or suppliers (collectively "end users").

Below are the conditions under which Oracle may access, collect and/or use services data.

To Provide Services. Services data may be accessed and used to fulfill the requirements specified in your order for support, consulting, On Demand or other services.

To Maintain and Upgrade a System. Technical staff may require periodic access to services data to monitor system performance, test systems and develop and implement upgrades to systems. Any temporary copies of services data created as a necessary part of this process are only maintained for time periods relevant to those purposes.

To Address Performance and Fix Issues. On occasion, Oracle may develop new versions, patches, updates, and other fixes to its programs and services (such as security patches addressing newly discovered vulnerabilities). In accordance with the terms of your order for services and/or with notice to you, we may access and/or use a copy of your test, development or production environment, including services data, to test such new versions, patches, updates and fixes and validate that they work in your environment(s).

As a Result of Legal Requirements. Oracle may be required to provide personally identifiable information to comply with legally mandated reporting, disclosure or other legal process requirements.

Oracle may transfer and access services data globally as required for the purposes specified above. If Oracle hires subcontractors to assist in providing services, their access to services data will be consistent with the terms of your order for services and this services privacy policy.

Oracle does not use services data except as stated above or in your order. Oracle may process services data, but does not control your information collection or use practices for services data. If you provide any services data to Oracle, you are responsible for providing any notices and/or obtaining any consents necessary for Oracle to access and use services data as specified in this policy and your order.

Oracle's access to services data is based on job role/responsibility. Services data residing in Oracle hosted systems is controlled via an access control list (ACL) mechanism, as well as the use of an account management framework. You control access to services data by your end users; end users should direct any requests related to their personal information to you.

Oracle is committed to the security of your services data, and has in place physical, administrative and technical measures designed to prevent unauthorized access to that information. Oracle security policies cover the management of security for both its internal operations as well as the services. These policies, which are aligned with the ISO/IEC 17799:2005 and ISO/IEC 27001:2005 standards, govern all areas of security applicable to services and apply to all Oracle employees. Oracle's Support, Consulting and On Demand lines of business have developed detailed statements of security practices that apply to many of their service offerings, which are available for review at your request.

Oracle's security policies and procedures are reviewed by the Oracle Security Oversight Committee (OSOC) and Oracle Global Information Security (GIS). The OSOC coordinates implementation of security wide programs, including security policies and data privacy standards. GIS is responsible for security oversight, compliance and enforcement, and for conducting information security assessments and leading the development of information security policy and strategy.

Oracle is also committed to reducing risks of human error, theft, fraud, and misuse of Oracle facilities. Oracle's efforts include making personnel aware of security policies and training employees to implement security policies. Oracle employees are required to maintain the confidentiality of services data. Employees' obligations include written confidentiality agreements and compliance with company policies concerning protection of confidential information.

Oracle promptly evaluates and responds to incidents that create suspicions of unauthorized handling of services data. Oracle GIS and Legal are informed of such incidents and, depending on the nature of the activity, defines escalation paths and response teams to address the incidents. If Oracle determines that your services data has been misappropriated (including by an Oracle employee), Oracle will promptly report such misappropriation to you.

Oracle has appointed a Chief Privacy Officer. If you believe your services data has been used in a way that is not consistent with this policy, or if you have further questions related to this policy, please contact the Chief Privacy Officer by email at privacy_ww@oracle.com. Written inquiries may be addressed to Chief Privacy Officer, Oracle Government Affairs, 1015 15th St. Ste 200, Washington DC 20005, United States of America.

Last Updated: January 6, 2009