This Notice explains how IndustryVault LLC (“IndustryVault”, “we”, “our” or “us”) collect, store, use, disclose and otherwise process information about you in the course of our business, including through the IndustryVault Solutions, the IndustryVault Platform, and the IndustryVault Sites (“Sites”) that link to this Notice (collectively, the “Services”) and through other means such as our and our partner’s events, sales and marketing activities. It also sets out more information about your privacy rights.

This Privacy Notice is referenced in and made a part of the IndustryVault Terms of Service, as well as any Master Services Agreement with IndustryVault (the “Agreement”), and any capitalized terms used but not defined herein shall have the meaning set forth in the Agreement or Documentation, as applicable. In the event of any conflict between the terms of the Agreement and this Privacy Notice, this Privacy Notice shall govern.

In simple terms, the IndustryVault approach to Privacy is the following.

• We don’t sell your information - We share information outside of IndustryVault only as permitted by law for our everyday business purposes.
• Your information is confidential - Our employees and the companies we contract with are obligated to hold your information in the strictest confidence.
• We protect your information - We have rigorous security procedures and virus/malware software in place.

The following sections provide details regarding our approach.

About Our Services

We provide the Services to our Clients under an agreement with them and solely for their benefit and the benefit of their personnel and other personnel authorized by them as users of the Services ("Authorized Users"). Because the Services are provided through software-as-a-service hosted in the cloud, Authorized Users may access and use the Services from anywhere, subject to IndustryVault’s Agreements with our Clients and any applicable laws.

This Notice does not apply to the content that our Clients and their Authorized Users upload and store in the Services ("Client Content"). In those circumstances:

(a) IndustryVault is processing Client Content on behalf of a Client and that Client is responsible for the collection and use of your data; and

(b) that Client’s privacy notice will apply to the Client’s collection and use of such Client Content.

In such circumstances, you should refer to their privacy notice and direct any queries to them. The Client’s Agreement with IndustryVault governs our use of and processing of Client Content in these circumstances.

Information You Provide

The personal information we collect when you use the Sites, and the reasons why you are asked to provide it, will be made clear to you at the point we ask you to provide your personal information. We will let you know prior to collection whether the provision of personal information we are collecting is compulsory or may be provided on a voluntary basis.

When using the Sites, we may collect your name, email, postal address, phone number and other information you provide via the Sites when, for example, you submit inquiries, request more information about our services, complete surveys or download IndustryVault collateral, provide feedback about our services or register for sales events or marketing activities. When you register to use our Services, we may collect your personal information (like name and contact details).

Information We Automatically Collect

When using the Sites, we automatically collect certain information when you visit or use the Sites. This information may reveal your identity and may include information about the specific computer or device you are using, such as your computer’s operating system and Internet Protocol (IP) address.

We also automatically collect and store information about your activities on our Sites, such as information about how you came to and used our Sites, event information (like access times and browser type and language), and data collected through cookies and other similar technologies that uniquely identify your browser, computer and/or other device. We may share information about your computer or other device with our third-party service providers for information and network security, including fraud detection.

When using the Services, we automatically collect certain data relating to the performance and configuration of our Service and our Clients' and Authorized Users' consumption, use of, and interaction with the Services (collectively, “Service Data"). While Service Data usually does not involve personal information, it may include such data in the following instances:

• Technical information, or data obtained from APIs, software or systems hosting the products and services and devices accessing these products and services, log files generated during such use;
• Data and metadata about an Authorized Users, such as user ID, email, IP address, other data about the user’s computer or other device, browser and connecting software (e.g., OS and software versions); and
• Data and metadata about an Authorized Users' activities and behavior within our Service, such as click-patterns and feature utilization.

Service Data is used by IndustryVault for (a) providing, supporting and operating our products and services, (b) network and information security and (c) to analyze, develop and improve our products and services.

Use of Information We Collect

We use personal information collected via the Sites, our Service and through other means (e.g., in person) for purposes described in this Notice, including using your information to:

• Operate, audit and improve our Sites, products and services;
• Provide Client service and support;
• Provide and to facilitate the delivery of products and services you request;
• Send you related information, including confirmations, invoices, technical notices, updates, security alerts, training and support and administrative messages;
• Maintain your account;
• Enhance security, monitor and verify identity or service access, combat fraud, spam, malware or other network and/or information security risks;
• Detect bugs, report errors and perform activities to maintain the quality or safety of our services;
• Conduct research and development;
• Understand you and your preferences to enhance and personalize your experience and enjoyment when using our Sites, products and services;
• Develop and send you marketing, sales and promotional communications (where this is in accordance with your marketing preferences);
• Communicate with you about one of our events or our partner events, including webinars and demos;
• Respond to your comments or questions or provide information requested by you;
• Link or combine it with other personal information we get from third parties, to help understand your needs, provide you with better service and to prevent fraud;
• Process and deliver contest entries and rewards;
• Maintain legal and regulatory compliance;
• Short-term, transient use, such as customizing content that we or our service providers display on the Services; and
• Process your information for other legitimate business purposes, such as Client surveys, data analysis, audits, collecting and assessing feedback, identifying usage trends, determining the effectiveness of our marketing campaigns and to evaluate and improve our products, services, marketing and Client relationships.

We store and process personal information in the United States only.

Sharing of Personal Information

We do not share your personal information with third parties other than as follows:

• When you instruct us to do so;
• With your consent, for example, when you agree to our sharing your information with other third parties for their own marketing purposes subject to their separate privacy policies;
• With third party vendors, consultants and other service providers who work for us and need access to your information to do that work. Examples include vendors and service providers who provide assistance with marketing, billing, processing credit card payments, data analysis, fraud prevention, network and information security, technical support and Client service;
• With third party business partners, such as distributors, and/or referral partners, who are involved in providing services to our prospects and/or Clients, to fulfill product and information requests and to provide Clients and prospective Clients with information about IndustryVault and its products and services. From time to time, we may engage in joint sales or product promotions with select business partners. If you purchase or specifically express an interest in a jointly-offered product, promotion or service, we may share relevant personal information with those partner(s). Where you have given your consent to do so, these business partners may send you marketing communications about their own products and services. Please be aware that we do not control our business partners' use of such information. Our partners are responsible for managing their own use of the personal information collected in these circumstances. We recommend you review the privacy notices of the relevant partner to find out more about their handling of your personal information.
• Where it has been de-identified, including through aggregation or anonymization;
• To comply with laws or to respond to lawful requests and legal process, to protect our rights and property and that of our agents, Clients, members and others including to enforce our agreements, policies and terms of use or in an emergency to protect the personal safety of any person;
• In order to protect any individual’s vital interests, but only where we believe it necessary in order to protect the vital interests of any person; and
• In connection with or during negotiation of any business transfer, merger, financing, acquisition, or dissolution transaction or proceeding involving sale, transfer, divestiture or disclosure of all or a portion of our business or assets to another company.

Security of Your Personal Information

We take all reasonable and appropriate steps to protect your personal information in an effort to prevent loss, misuse, and unauthorized access, disclosure, alteration and destruction. We use appropriate technical and organizational measures to protect your personal information which may include: physical access controls, encryption, internet firewalls, intrusion detection and network monitoring depending on the nature of the information and the scope of processing. IndustryVault staff who may have access to your information are required to keep that information confidential.

Your Information Choices and Changes

You may opt out of receiving promotional emails from us by following the instructions in those emails. If you opt out, we may still send you non-promotional emails, such as emails about your accounts or our ongoing business relations. You may also send requests about your contact preferences and changes to your information by emailing [email protected]. If you are looking to exercise your consumer rights under the California Consumer Privacy Act (CCPA), please use the CCPA Consumer Rights Request Form found in the “California Users Only: Your Privacy Rights” section below.

Data Retention and Deletion

We retain personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to comply with applicable legal, tax or accounting requirements, to enforce our agreements or comply with our legal obligations). When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing, until deletion is possible. When processing Client Content on behalf of our Clients, we will retain Client Content for as long as our Client instructs us to and/or as required by applicable law.

Changes to this Notice

We may change this Privacy Notice from time to time. If we make any changes to this Notice, we will change the Last Updated date above. If such changes are material in nature, we will provide you with additional notice (such as adding a statement to the main website page or sending you an email notification).

How to Contact Us

If you have any questions about this Notice or other privacy-related issues, please contact us at [email protected] or IndustryVault LLC, 100 Pine Street, Suite 1250, San Francisco, CA 94111.

California Users Only: Your Privacy Rights

The California Consumer Privacy Act of 2018 ("CCPA"), effective as of January 1, 2020, requires businesses that collect personal information of California residents to make certain disclosures regarding how they collect, use and disclose such information.

This section addresses those requirements. For a description of all of our data collection, use and disclosure practices, please read this Privacy Notice in its entirety.

Personal Information Collection and Sharing

IndustryVault does not sell personal information as we understand sale to be defined by the CCPA and its implementing regulations. The categories of personal information we collect about you and the third parties with whom we share that personal information for a business purpose are as follows:

Sources of Personal Information

The sources from which we collect personal information are described in the following sections above:

• Information You Provide
• Information We Automatically Collect
• Information We Receive From Third Parties

Purposes for Collecting Personal Information

We collect personal information identified in the lists above to communicate with you, for marketing and promotional purposes, to provide and improve our services and other purposes set forth in the Use of Information We Collect section above.

California Consumer Rights

California law gives California residents the right to make the following requests with regard to certain information we collect about them, at no charge, two times every 12 months:

• The right to request a copy of personal information we collected or disclosed for a business purpose in the past 12 months;
• The right to request deletion of personal information we collected, subject to certain exemptions (for example, where the information is used by us to detect security incidents, debugging or to comply with a legal obligation); and
• The right to request that we disclose personal information we collect, use and disclose.

You can submit a copy, deletion or right-to-know request online by contacting us at 415-813-2000 or emailing [email protected]. IndustryVault will verify that the information you submit [(which includes first name, last name, email address, company, and country/state)] matches our records before we fulfill the request. You may use an authorized agent to submit a consumer rights request on your behalf using the methods above; however, IndustryVault will require the authorized agent to provide signed permission to submit the request on your behalf and may still contact you to confirm your identity and that this request was submitted with your permission. IndustryVault does not discriminate against you for exercising your rights or offer you financial incentives related to the use of your personal information.