PRIVACY POLICY (THE “POLICY”)
Last Revised March 5, 2008

This Policy applies to Saba Software, Inc., and its affiliated entities throughout the world (collectively referred to as “Saba,” “we,” or “us.”). A list of our affiliated entities is available at http://www.saba.com/company/locations. Saba is committed to protecting your personal information. For that reason, Saba created this Policy which explains what personal information Saba collects about you, the purposes for which it uses and shares this information and how we safeguard that information. If you do not agree to the privacy practices described in the Policy, please do not use “http://www.saba.com/” or related sites (collectively, the “Site”).

What this Policy Applies To
The personal information covered by this Policy (“Personal Information”) includes, but is not limited to, personal information that is collected online at the Site and personal information that Saba receives from its clients pertaining to contractors, customers and related parties of the clients ((a) and (b) collectively referred to as "Users").
For individuals who are located in the European Union (the “EU”), you should be aware that Saba abides by the Safe Harbor framework agreed to by the US Department of Commerce and the EU with respect to Personal Information it receives from the EU. For additional information regarding the Safe Harbor program, see the US Dept. of Commerce web site at http://www.export.gov/safeharbor/. Because we comply with Safe Harbor principles, our transfers of such Personal Information from EU countries to the US meet the adequacy requirements of the EU Data Protection Directive.

Collection of Personal Information
Saba collects Personal Information such as names, addresses, telephone numbers, email addresses and birthdates. For example, if you submit a webinar registration to us online, we will collect your e-mail address. If you use Saba’s software through one of our clients, you may be asked to input information into an individual profile. This profile may include your name, learning course registrations, Centra sessions attended, employment information and/or other information. Users may also be asked to select a password. We also collect Users' names, companies, industries, postal addresses, email addresses and/or phone numbers when they register to receive certain information from us and/or our Site. Personal Information collected by Saba may be stored in the US or any other country in which Saba or its agents maintain facilities.

On occasion, we have access to sensitive Personal Information of Users provided to us by clients located in the EU. This sensitive Personal Information may include racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, financial records, health information, sexual orientation and/or alleged commission of an offense. Saba will not disclose such sensitive Personal Information to a non-agent third party or use it for a purpose other than the purpose for which it was originally collected or subsequently authorized, unless the individual explicitly consents or a legal exception applies.

Use of Personal Information
Saba uses Personal Information to:
• Confirm and fill orders for products and services;
• Assist clients with compliance and learning obligations and virtual meeting sessions;
• Perform professional services;
• Administer accounts and provide support;
• Maintain databases and subscription lists;
• Process job applications;
• Update databases;
• Alert Users to product upgrades, special offers, updated information and other new products and services;
• Deliver services, such as newsletters, events, training and software requested by Users;
• Create and publish content relevant to Users;
• Provide Users with access to limited-entry areas of our Site as appropriate;
• Otherwise conduct its business operations; and
• Contact Users as necessary for the above purposes.

We will not use Personal Information for any other purpose incompatible with the purposes listed above, unless it is required or authorized by you, is in your own vital interest or is necessary to comply with a legal obligation. Your Personal Information may be shared with Saba business affiliates in a manner consistent with the Policy.
With respect to Personal Information provided by clients, Saba uses such Personal Information solely for the purposes of performing tasks on behalf of, and under the instruction of, our clients.

Use of Personal Information by Third Parties
Personal Information may be shared with third party agents who provide products and/or services to Saba, such as web site hosting, information technology consulting, web site management, marketing, promotion, data analysis, audit, legal, administrative, back-up and security. Saba works to ensure that such third parties use the Personal Information only for the purposes for which we engage them and under similar privacy protection to what we maintain.

In the event there is a change in Saba's corporate structure, including, without limitation, merger, consolidation, sale, liquidation or transfer of substantial assets, Saba may, in its sole and absolute discretion, transfer, sell or assign information collected, including, without limitation, aggregated information and Personal Information, to one or more affiliated or unaffiliated third parties.

Saba may also disclose Personal Information in order to: (1) comply with applicable laws; (2) respond to governmental inquiries or requests; (3) comply with valid legal processes; (4) protect the rights, privacy, safety or property of Saba, Site visitors, clients or the public; (5) enforce our Site terms of service; and (6) permit us to pursue available remedies or limit the damages that we may sustain.

Direct Marketing
We ask Site Users to choose whether to receive promotional email updates about products and services offered by Saba. We may also ask Site Users to choose whether to allow Saba to share their Personal Information with third parties for marketing purposes. We will honor the choices made. If you subsequently decide that you no longer wish to receive promotional emails from Saba, or if you no longer wish to allow Saba to share your Personal Information on a going-forward basis for marketing purposes with third parties, you may opt-out of receiving such emails or from such sharing as described below in the Access and Correction section. When you opt-out as described above, you must clearly state which of the following choices you are opting-out of:

Receiving promotional email updates from Saba;
Allowing Saba to share your personal information with third-parties for their marketing purposes.

We will endeavor to comply with your request as soon as reasonably practicable. Please note that if you opt-out as described above, we will not be able to remove your Personal Information from the databases of third parties with which we have already shared your Personal Information (i.e., to which we have already provided your Personal Information as of the date that we implement your opt-out request). If you wish to cease receiving marketing-related emails from such third parties, please contact such third parties directly or utilize any opt-out mechanisms set forth in their respective privacy policies or marketing-related emails.

Use of “Cookies” and Other Tracking Technologies
When you use the Site, we, or third parties authorized by us, may collect certain technical and routing information about your computer to facilitate your use of the Site and its services. For example, we may log environmental variables, such as browser type, operating system, CPU speed, and the Internet Protocol address of your computer. We use these environmental variables to facilitate and track your use of the Site and its services. Saba may also use such environmental variables to measure traffic patterns on the Site and, in certain cases, to bring opportunities of potential interest to your intention.

While it is possible that some data may be traceable to an individual, any such linked information will be treated in accordance with this Policy as long as it is so linked.
Saba uses "cookies" or similar technologies to store login and general information on visitors' computers. A cookie is a small amount of information that a web site transfers to a computer's hard drive. We use cookies to simplify visitors' access and to tailor our services to visitors' needs and interests. In some cases, we offer visitors the choice of having an ID or password stored in a cookie so that visitors do not need to re-enter it when they return to the Site. No other site can read a cookie set by Saba, and we cannot read a cookie that another web site wrote to a visitor's computer. Most Internet browsers are set to accept cookies. Users can reset browsers to refuse cookies and still use our Site, although access may be slower and less convenient.
We also may collect data by using "pixel tags," "web beacons," "clear GIFs" or similar means (collectively, " tags") that allow us to know when you visit our Site. Through tags, we do not have access to personal information about you, but we obtain aggregate data (i.e., the IP address and the domain name, the areas of the Site you visit, your operating system, your browser version and the URL you came from) which can be used to enhance your online experience.

External Links
The Site may include links to other web sites not controlled by Saba. Please note that we are not responsible for the collection, use, maintenance, sharing, or disclosure of data and/or information by such third parties. Once you leave our Site (you can usually tell where you are by checking the URL in the location bar on your browser), use of any information you provide is governed by the privacy policy of the operator of the site you are visiting. That policy may differ from ours. We encourage you to read the privacy policies of web sites that you visit before submitting personal information. If you can't find the privacy policy of any of these web sites via a link from the web site's homepage, you should contact the web site directly for more information.

Security and Confidentiality
Saba takes appropriate and commercially reasonable technical and organizational measures to protect Personal Information against unauthorized access, accidental loss or damage and unauthorized destruction. Saba employees who handle confidential, proprietary or personal information are required to treat it confidentially and are not permitted to use it for purposes unrelated to Saba's business or disclose it to unauthorized third parties.

For online financial transactions, we use technology to protect the personally identifiable information that you transmit to us via our Site. Unfortunately, however, no security system or system of transmitting data over the Internet can be guaranteed to be entirely secure. If you have reason to believe that your interaction with us is no longer secure, please notify us of the problem by contacting us at privacy1@saba.com.

Data Retention
We will not keep Personal Information longer than as necessary for the fulfillment of the purposes outlined herein. We seek to avoid the retention of unnecessary or duplicative information.

Data Integrity
Saba takes reasonable steps to ensure that the Personal Information it maintains is reliable for, and relevant to, its intended use. We also endeavor to ensure that such Information is accurate, complete and current.

Access and Correction
Where required by applicable law, Saba provides Users with the right to access and correct their Personal Information that Saba controls. For information about how to exercise these rights, or to unsubscribe from our newsletters or from our sharing information with third parties for their marketing purposes, please contact Saba Customer Service by clicking here.

Policy Updates
We may update this Policy from time to time. When we do so, changes in our Policy will be effective immediately upon posting the revised Policy to the Site. If you are a regular visitor to this Site, we recommend that you check this Policy on a regular basis. By continuing to use the Site after a revised Policy has been posted, you will be deemed to have agreed to Policy changes. If you do not agree with the terms of this Policy, please do not continue using this Site.

Changes to this Policy will be posted on the Site "http://www.saba.com/privacy.htm". You should visit the Site periodically to review the most recent Policy.

Contact Information
Questions regarding this Policy should be directed to Saba at legal@saba.com or by contacting us at:

Saba Software, Inc.
Attn: Legal Dept.
2400 Bridge Parkway
Redwood Shores, CA 94065
USA