more on This is "pretty good" privacy?

[Dave Farber <dave () farber net>]

------ Forwarded Message
From: "Matthew T. Blackmon" <segoy () firesermon com>
Date: Sun, 23 Feb 2003 15:31:00 -0500
To: dave () farber net
Subject: RE: [IP] This is "pretty good" privacy?

Dave-

I think this is a bit of a red herring.

<begin quote>
YOU HEREBY EXPRESSLY CONSENT TO PGP CO.'S PROCESSING OF YOUR PERSONAL DATA
(WHICH MAY BE COLLECTED BY PGP CO. OR ITS DISTRIBUTORS) ACCORDING TO PGP
CO.'S CURRENT PRIVACY POLICY WHICH IS INCORPORATED INTO THIS AGREEMENT BY
REFERENCE (SEE HTTP://WWW.PGP.COM).
<end quote>

The PGP Privacy statement <http://www.pgp.com/privacy.php> mentions the
specific conditions of private information collection and disclosure:

<from http://www.pgp.com/privacy.php>
Disclosure of User Information

PGP will not sell, rent, or lease your personal information to third
parties. We will not share your personal information with business partners
or any other third party company except as described below:

Agents:  We employ other companies and people to perform tasks on our behalf
and may need to share your information with them to provide products or
services to you. Examples include providing customer service, processing
credit card payments, fulfilling orders, and providing marketing assistance.
Unless we tell you differently, PGP's agents do not have any right to use
your information we share with them beyond what is necessary to assist us.
You hereby consent to our sharing of your information for the above
purposes.

Business Transfers:  In some cases, we may choose to buy or sell assets. In
these types of transactions, customer information is typically one of the
business assets that is transferred. Moreover, if PGP or substantially all
of its assets were acquired, or in the unlikely event that PGP goes out of
business or enters bankruptcy, customer information would be one of the
assets that is transferred or acquired by a third party. You acknowledge
that such transfers may occur, and that any acquirer of PGP may continue to
use your information as set forth in this policy.

Promotional Offers:  We may send promotional offers to you. However, you
will be provided the opportunity to opt-out of receiving such promotional
offers.

Protection of PGP and others:  We may release your information when we
believe in good faith that release is necessary to comply with law; enforce
or apply our conditions of use and other agreements; or protect the rights,
property, or safety of PGP, our employees, our users, or others. This
includes exchanging information with other companies and organizations for
fraud protection and credit risk reduction (as described above) and to
comply with export laws.

With your Consent:  Except as set forth above, you will be notified when
your information may be shared with third parties, and will be able to
prevent the sharing of this information.

Your Choices relating to your Personal Information

As stated previously, you can always opt not to disclose personal
information to us, even though it may be needed to make a purchase or take
advantage of certain PGP features. You may request an update or deletion of
your PGP account by sending an email to customersupport () pgp com.
</from>

This all looks kosher to my eyes.  The mentions of the Business Transfers,
however, is an interesting addition to their privacy policy.  Despite being
absent from many companies policies, this is something that has been upheld
when challenged and not specifically mentioned.  I am willing, however, to
listen to evidence to the contrary.

Regards,
M




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