IMMERSION CORPORATION PRIVACY POLICY

Last updated February 6, 2018

This Privacy Policy is made available to you in order to make you aware of how Immersion Corporation (“Immersion”) collects, uses, and shares information collected via your visit to the Immersion.com, go.Immersion.com, touchsensecloud.com, or immersiontouch.cn website (collectively, the “Sites”), and other information collected via use of Immersion products (“Products”) (together with the Sites, the “Services”).  By using the Services, you are consenting to the information collection, use, and sharing practices described in this Privacy Policy.

1. Personal Information. “Personal Information” is information that identifies you as an individual or relates to an identifiable individual, such as your name, telephone number, mailing address, or email address.  We may need to collect and process these types of Personal Information in order to provide the requested Services to you, or because we are legally required to do so. If you do not provide the information that we request, we may not be able to provide you with the requested Services.

2. Collection of Personal Information. We and our service providers may collect Personal Information in a variety of ways, including:

• Through the Services: We may collect Personal Information through the Services, e.g., when you sign up for a newsletter, download software, receive Immersion haptic effects on your mobile device, or make a purchase.

• From Other Sources: We may receive your Personal Information from other sources, such as public databases, joint marketing partners, social media platforms (including from people with whom you are friends or otherwise connected) and from other third parties.

If you provide us with any Personal Information relating to other people, you are representing that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.

3. Use of Personal Information. Immersion uses Personal Information for its legitimate business interests, including the following:

• To respond to your inquiries and fulfill your requests, complete your transactions, and provide you with related customer service;

• To verify compliance with your agreements with us, log software licenses granted, track software downloaded from the Site, and track use of other Products;

• To send administrative information to you, such as changes to our terms, conditions and policies, as well as marketing communications that we believe may be of interest;

• For our business purposes, such as data analysis, audits, fraud monitoring and prevention, developing new products, enhancing, improving or modifying our Services, identifying usage trends, determining the effectiveness of our promotional campaigns, and operating and expanding our business activities.

4. Disclosure of Personal Information. Immersion may disclose Personal Information to its affiliated entities for the purposes described in this Privacy Policy. Immersion Corporation is the party responsible for the management of the jointly-used Personal Information. In addition, we may disclose Personal Information to third-party service providers that provide services on our behalf, such as website hosting, data analysis, payment processing, order fulfillment, information technology and related infrastructure provision, customer service, email delivery, auditing and other services.

5. Additional Uses and Disclosures of Personal Information. Immersion may use and disclose Personal Information as allowed or required by applicable law, including uses and disclosures that are necessary or advisable to: (a) protect the rights, safety, security or property of users of our Services, the public, or Immersion or others; and (b) conform to legal or regulatory requirements. In addition, Immersion may use, disclose or transfer your information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings).

6. Product Analytic Data. Immersion may collect certain data when you use a Product (“Product Analytic Data”), including a Product incorporated into a third-party application, product or service (a “Third Party App”). Product Analytic Data may include your IP address, your country and language, information about your device (such as brand, model, operating system and component types), the Product used (such as name, version and settings of the Product), the Third-Party App running the Product, usage of the Product (such as which Product content was played, how much of the Product content was played, whether that Product content was downloaded/streamed or resided in the device, and whether the Product functionality was muted or at what volume it played), and the date and time that such information was gathered.  Immersion also may assign a number to identify your device, derived from one or more unique device identifiers.  This identification number is different from any built-in identification number for your device (such as your International Mobile Equipment Identity (“IMEI”)) and does not reveal to Immersion any such built-in identification number.

7. Other Information. “Other Information” is any information that does not reveal your specific identity or does not directly relate to an identifiable individual, such as demographic information and other information provided by or collected from you that does not reveal your specific identity, and information that has been aggregated in a manner that it no longer reveals your specific identity.  If we are required to treat Other Information as Personal Information under applicable law, we may use and disclose it for the purposes for which we use and disclose Personal Information as detailed in this Privacy Policy.  Otherwise, we may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. If we combine Other Information with Personal Information, we will treat the combined information as Personal Information as long as it is combined.

8. Other Information Collected Through the Site. We and our service providers may collect Other Information through our Site in a variety of ways, including:

• Through your browser or device. Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system name and version, device manufacturer and model, language, and Internet browser type and version. We use this information to ensure that the Site functions properly.

• Using cookies. Cookies are pieces of information stored directly on the computer that you are using. Cookies allow us to collect information such as browser type, referring website address, time spent on the Site, pages visited, language preferences, and other anonymous traffic data.  We and our service providers use the information for security purposes, to facilitate navigation, to authenticate users and control access to restricted areas of the Site, to display information more effectively, and to personalize your experience. We also gather statistical information about use of the Site in order to continually improve its design and functionality, understand how it is used and assist us with resolving questions about the Site. We do not currently respond to browser do-not-track signals. If you do not want information collected through the use of cookies, most browsers allow you to automatically decline cookies or be given the choice of declining or accepting a particular cookie (or cookies) from a particular website. You may also wish to refer to http://www.allaboutcookies.org/manage-cookies/index.html.  If, however, you do not accept cookies, you may experience some inconvenience in your use of the Site.

• Using pixel tags and other similar technologies. Pixel tags (also known as web beacons and clear GIFs) may be used to, among other things, track the actions of users of the Site (including email recipients), measure the success of our marketing campaigns and compile statistics about usage of the Site and response rates.

• Website analytics. We use Google Analytics, which uses cookies and similar technologies to collect and analyze information about use of the Site and report on activities and trends. This service may also collect information regarding the use of other websites, apps and online resources.  You can learn about Google’s practices by going to https://www.google.com/policies/privacy/partners/, and exercise Google’s opt out by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.

• IP Address. Your Internet Protocol (“IP”) address is automatically assigned to your computer by your Internet Service Provider. An IP address may be identified and logged automatically in our server log files whenever a user accesses the Site, along with the time of the visit and the page(s) that were visited.  Collecting IP addresses is standard practice and is done automatically by many websites, applications and other services.  We use IP addresses for purposes such as calculating usage levels, diagnosing server problems and administering the Site.  We may also derive your approximate location from your IP address.

9. Third-Party Services.  This Privacy Policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including any third party operating any website or service to which the Services link or any Third-Party App.  The inclusion of a link on the Services does not imply endorsement of the linked site or service by us or by our affiliates.

10. Security of Your Personal Information. Immersion is committed to taking reasonable steps to protect the Personal Information that you provide to us. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contacting Us” section below.

11. Reviewing and Correcting Your Personal Information.  If you would like to request to review, correct, update, suppress, restrict or delete Personal Information that you have previously provided to us, or if you would like to request to receive an electronic copy of your Personal Information for purposes of transmitting it to another company (to the extent this right to data portability is provided to you by applicable law), you may send a request to us by using the contact details in the “Contacting Us” section below.  We will respond to your request consistent with applicable law.

• In your request, please make clear what Personal Information you would like to have changed, whether you would like to have your Personal Information suppressed from our database or otherwise let us know what limitations you would like to put on our use of your Personal Information. For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request.  We will try to comply with your request as soon as reasonably practicable.

• Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion (e.g., when you download our software, you may not be able to change or delete the Personal Information provided until after you cease using such software). There may also be residual information that will remain within our databases and other records, which will not be removed.

12. Marketing Communications. If you no longer want to receive marketing-related emails from us on a going-forward basis, you may opt-out by using the unsubscribe link contained in each such email.  We will try to comply with your request(s) as soon as reasonably practicable.  Please note that if you opt-out of receiving marketing-related emails from us, we may still send you important administrative messages, from which you cannot opt-out.

13. Retention Period. We will retain your Personal Information for as long as needed or permitted in light of the purpose(s) for which it was obtained.  The criteria used to determine our retention periods include: (i) the length of time we have an ongoing relationship with you; (ii) the length of time we provide the Services to you; (iii) whether there is a legal obligation to which we are subject; or (iv) whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).

14. Jurisdictional Issues and Cross-Border Transfers.  Because Immersion Corporation operates globally, we make information we gather available to our worldwide business units.  Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, including the United States, which may have data protection rules that are different from those of your country.  If you use our Services from the European Economic Area (“EEA”), for example, the personal data we collect may be transferred outside the EEA for use by Immersion Corporation and its affiliates for any of the purposes described above.

15. Sensitive Information. We ask that you not send us, and you not disclose, any sensitive Personal Information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background) on or through the Site or otherwise to us.

16. Updates to this Privacy Policy. We may change this Privacy Policy.  The “LAST UPDATED” legend at the top of this Privacy Policy indicates when this Privacy Policy was last revised.  Any changes will become effective when we post the revised Privacy Policy on the Services.  Your use of the Services following these changes means that you accept the revised Privacy Policy.

17. Contacting Us. Immersion Corporation, located at 50 Rio Robles, San Jose, California 95134, is the company responsible for collection, use and disclosure of your Personal Information under this Privacy Policy.  If you have any questions about this Privacy Policy, please contact us at privacy@immersion.com, or Immersion Corporation, c/o Legal Department, 50 Rio Robles, San Jose, California 95134.  Because email communications are not always secure, please do not include credit card or other sensitive information in your emails to us.

18. Additional Information for Individuals in the EEA. If you are located in the EEA, you may also:

• contact us at Immersion Software Ireland Limited, 3rd Floor, Ulysses House, Foley Street, Dublin 1, Republic of Ireland with any questions about this Privacy Policy, and

• lodge a complaint with a supervisory authority competent for your country or region.

Tell us what you think.  Immersion welcomes your comments on our Privacy Policy.

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