PRIVACY POLICY

Last Updated: October 25, 2010

1. Introduction

This policy applies to the ModusLink Global Solutions, Inc. (ModusLink Global Solutions) website accessible through ModusLink Global Solutions’ home page located at www.moduslink.com. This policy does not apply to the websites of any subsidiary or affiliate company of ModusLink Global Solutions or any other company that is associated with ModusLink Global Solutions. Those websites, like any other website, may have their own privacy policies and ModusLink Global Solutions encourages you to review the privacy policies of any of those sites that you visit.

ModusLink Global Solutions, Inc. has been awarded TRUSTe's Privacy Seal signifying that this privacy policy and practices have been reviewed by TRUSTe for compliance with TRUSTe's program requirementsincluding transparency, accountability and choice regarding the collection and use of your personal information. The TRUSTe program does not cover information that may be collected through downloadable software. TRUSTe's mission, as an independent third party, is to accelerate online trust among consumers and organizations globally through its leading privacy trustmark and innovative trust solutions. If you have questions or complaints regarding our privacy policy or practices, please contact us at info@moduslink.com. If you are not satisfied with our response you can contact TRUSTe hereor mail at Watchdog Complaints, TRUSTe, 55 2nd Street, 2nd Floor, San Francisco, CA, USA 94105. If you are faxing or mailing TRUSTe to lodge a complaint, you must include the following information: the name of company, the alleged privacy violation, your contact information, and whether you would like the particulars of your complaint shared with the company. The TRUSTe dispute resolution process shall be conducted in English.

Moduslink Global Solutions, Inc. participates in the EU Safe Harbor Privacy Framework as set forth by the United States Department of Commerce.

We (ModusLink Global Solutions) understand the importance of providing you with information concerning the collection and use of data collected from you during your visit to our website. Our privacy policy is set forth below. This policy may be updated from time to time and we encourage you to check this page periodically for any updates.

Definitions.Some helpful definitions of terms used in this privacy policy are:

Personal Information is information that can be used to uniquely identify you personally. Examples of Personal Information include your name, mailing address, telephone number, email address and credit card number.

Anonymous Information is information that can not be used to uniquely identify you personally. Examples of Anonymous Information include your IP address, the type of browser software you use when visiting our site, the date and time you visit our site and what pages you viewed when visiting our site.

2. Collection and Use of Anonymous Information

You can visit our website without telling us who you are or revealing any Personal Information to us. During your visit, we may collect certain Anonymous Information. For example, we may track the number of visitors to our website by logging Internet Protocol (IP) addresses. We may keep track of what pages are visited on our website so we can monitor the performance and usage of our website. Also, we may pay attention to what visitors do and do not use on our website in order to assess the effectiveness of our website and modify our content or design appropriately. Anonymous Information may be used individually or aggregated with other Anonymous Information. We may use Anonymous Information for our own benefit and we may share Anonymous Information with other companies.

3. Collection and Use of Personal Information

We collect Personal Information about you only when you elect to provide such information to us, such as when you register to receive products or services, request additional information from us, enter a contest or promotion, or submit an email to us. The information collected might include your name, company name, e-mail address, mailing address, phone numbers, etc. Any Personal Information collected will be used solely for the purpose(s) for which it was collected (for example, to send you additional information about our products or services that you requested) unless you indicate otherwise. The Personal Information you provide to us may be shared with other companies with which we have relationships in order to complete your request or provide you with the products or services which you have requested. We may also enlist a third party to collect, store, process and manage on our behalf any Personal Information you elect provide to us. When we use other companies to perform services on our behalf, we will require that such companies protect your Personal Information consistent with this policy and not for their own promotional purposes.

In addition, from time to time, we may offer you the opportunity to receive information, products or services directly from a third party. If you elect to receive such items, we may share with such third party any of your Personal Information that was collected when you elected to receive such items.

4. Choice/Opt-out

If you no longer wish for us to collect your Personal Information or to receive communications from us, you may contact us using the instructions in the Access/Contact section below indicating your wishes or follow the unsubscribe instructions included in each promotional email.

5. Sharing of Your Personal Information

Except as disclosed in this privacy policy, ModusLink Global Solutions does not share your personal information with any outside parties. We may share your personal information with service providers who perform services on our behalf. For example, we may hire other companies to handle the processing of payments, to provide data storage, to host our website, to assist in direct marketing, to conduct audits, etc. Those companies will be permitted to obtain only the Personal Information they need to provide the service. They are required to maintain the confidentiality of the information and are prohibited from using it for any other purpose. This will include sharing your information with the companies whose products you order through our website. You should familiarize yourself with the privacy policy of any such company.

Information about our customers, including Personal Information, may be disclosed as part of any merger, acquisition, or sale of the company and/or its assets, as well as in the unlikely event of insolvency, bankruptcy, or receivership. We will notify you of such an occurrence as described in the "Changes to This Privacy Policy" section below.

We reserve the right to disclose Personal Information if required to do so by law or in the good faith belief that such action is necessary to (a) conform to the edicts of the law or comply with legal process served on ModusLink Global Solutions or this site; (b) protect and defend the rights or property of ModusLink Global Solutions and our family of Web sites; or (c) act in urgent circumstances to protect the personal safety of ModusLink Global Solutions’ employees or agents, users of our services, or members of the public. Personal Information collected on this site may be stored and processed in the United States, Europe and Asia, and by using the Site, you consent to any such transfer of information outside of your country.

6. Use of Cookies and Other Technologies

A cookie is a small amount of data that is sent to your browser software from a web server and is typically stored by your browser on your computer's hard drive.

We may insert cookies on your computer and access those cookies. These cookies may be used to help you navigate through our website, to provide you with customized and personalized features, and to assist us in collecting Anonymous Information concerning usage of our web site.

Additionally, we may allow other companies to present advertisements on some pages on our web site, and we may allow those companies to set and access their own cookies and web beacons on your computer in connection with such advertising. Those other companies' use of their cookies is subject to their own privacy policies, not ours.

7. Security

ModusLink Global Solutions is concerned with the security of the data we have collected and has in place reasonable measures to prevent unauthorized access to that information. These measures include policies, procedures and technical elements relating to data access controls. Such measures are reasonably designed to help protect your Personal Information from loss, unauthorized access, disclosure, alteration or destruction. ModusLink Global Solutions may use encryption, secure socket layer, firewalls, physical lock and key, internal restrictions, password protection and other security measures to help prevent unauthorized access to your Personal Information. In addition, ModusLink Global Solutions uses standard security protocols and mechanisms to exchange the transmission of sensitive data.

In the event that your personal data is acquired, or is reasonably believed to have been acquired, by an unauthorized person and applicable law requires notification, ModusLink Global Solutions will notify you of the breach. Notice will be given promptly, consistent with the legitimate needs of law enforcement and any measures necessary for ModusLink Global Solutions or law enforcement to determine the scope of the breach and to assure or restore the integrity of the data system. ModusLink Global Solutions may delay notification if ModusLink Global Solutions or a law enforcement agency determines that the notification will impede a criminal investigation, unless and until ModusLink Global Solutions or the agency determines that notification will not compromise the investigation.

8. Children

ModusLink Global Solutions recognizes the privacy interests of children and we encourage parents and guardians to take an active role in their children's online activities and interests. We do not intend to solicit or collect personal information from anyone under the age of 13. If you are under 13, you should not use or enter information on this site, including without limitation any interactive areas of the site.

9. Links

If you click on a link to a third-party site, including on an advertisement, you will leave our website and go to the site you selected. Because we cannot control the activities of third parties, we cannot accept responsibility for any use of your personally identifiable information by such third parties, and we cannot guarantee that they will adhere to the same privacy practices as ModusLink Global Solutions. We encourage you to review the privacy statements of any other service provider from whom you request services. If you visit a third party website that is linked to our website, you should read that site’s privacy statement before providing any personally identifiable information.

10. Changes to This Privacy Policy

We reserve the right to change the terms of this privacy policy at any time. When we make changes, we will revise the "last updated" date at the top of the policy. If there are material changes to this policy or in how ModusLink Global Solutions will use your Personal Information, we will notify you by prominently posting a notice of such changes here. We will then notify you via a prominent notice on our home page. We encourage you to review this policy whenever you visit our site.

11. Access /Contact

If you have questions or concerns about this privacy policy, the practices of our website or would like access to your Personal Information in order to correct, update, or delete this information please contact us at:

ModusLink Global Solutions, Inc.
1601 Trapelo Road
Suite 170
Waltham, MA  02451
Tel: 781.663.5000
Fax: 781.663.5095
Attn: Legal Department
email: info@moduslink.com
Requests for access will be responded to within 30 days of the request.