PRIVACY POLICY

EDGEWATER NETWORKS PRIVACY POLICY

EFFECTIVE DATE: December 10, 2017

1. INTRODUCTION. EDGEWATER NETWORKS, Inc. (“us,” “we,” or “Company”) is committed to respecting the privacy rights of its customers, visitors, and other users of the Edgewater Networks Website and services therein (collectively the “Website”). We created this Privacy Policy (“Privacy Policy”) to give you confidence as you use the Website, and to demonstrate our commitment to fair information practices and the protection of privacy. This Privacy Policy is only applicable to the Website, and not to any other websites or applications that you may be able to access from the Website, each of which may have data collection, storage, and use practices and policies that differ materially from this Privacy Policy.

2. INFORMATION COLLECTION PRACTICES

2.1. TYPES OF INFORMATION COLLECTED

(a) TRAFFIC DATA COLLECTED. We automatically track and collect the following categories of information when you use our Website: (1) IP addresses; (2) domain servers; (3) types of computers accessing the Website; and (4) types of devices used to access the Website (collectively “Traffic Data”). Traffic Data is anonymous information that does not personally identify you but is helpful for marketing purposes or for improving your experience on the Website. We may also use “cookies” to customize content specific to your interests, to ensure that you do not see the same advertisement repeatedly, and to store your password so you do not have to re-enter it each time you visit the Website.

(b) PERSONAL DATA COLLECTED. In order for you to access certain premium, services and to purchase products that we offer via the Website, we require you to provide us with certain information that personally identifies you (“Personal Information”). Personal Information includes the following categories of information: (1) Contact Data (such as your name, telephone number, mailing and delivery addresses, photograph, and e-mail address. Also included in Contact Data is your customers’ data including names, telephone numbers, mailing addresses, photographs, and email addresses); (2) Financial Data (such as your selling and purchasing histories, and credit card number and bank account information); (3) Demographic Data (such as your zip code, age, and income) and (4) Location Data (such as tracking data, location data, and GPS data). If you communicate with us by e-mail, post messages to any of our chat groups, bulletin boards, or forums, or otherwise complete online forms, surveys, or entries, any information provided in such communication may be collected as Personal Information. By using the Website, you verify that you have proper authorization from your customers and applicable third parties to provide their Personal Information, Financial Information, and all other data to Company.

(c) CHILDREN AND MINORS. Children and minors are expressly prohibited from using or accessing the Website. Further, entering any information into or by way of the Website is expressly prohibited. We do not knowingly collect any personal information from children under the age of 13. Should information from children under the age of 13 (further collectively referred as “Children’s Content”) be communicated to us in any way, we require you at all times to comply with the Children’s Online Privacy Protection Act of 1998 (“COPPA”), as amended from time to time. We require you to use the tools available in the Website to designate users that are under 13 or who have otherwise opted-out of personal information collection. Should you choose not to designate such users, we will assume that such users are not under the age of 13. We will not actively monitor your compliance with COPPA, therefore, we disclaim liability for your failure to properly designate users through the Website and your failure to honor your obligations set forth herein.

2.2. USES OF INFORMATION COLLECTED

(a) COMPANY USE OF INFORMATION. We use Personal Data for operational use of the Website, match making within the Website, analytics, to send your customer’s information about Company or our products and services, or promotional material from some of our partners, or to contact you when necessary. We use your Financial Data to verify your qualifications for certain products or services and to bill you for products and services. We use Demographic Data to customize and tailor experiences on the Website, displaying content that we think users and customers might be interested in and according to your preferences.

(b) SHARING OF PERSONAL INFORMATION. We share certain categories of information we collect from you in the ways described in this Privacy Policy. We share Demographic Data with advertisers and other third parties only on an aggregate (i.e., non-personally-identifiable) basis. We share Contact Data with other companies who may want to send you information about their products or services, unless you have specifically requested that we not share Contact Data with such companies. We also share Contact Data and Financial Data with our business partners who assist us by performing core services (such as hosting, billing, fulfillment, or data storage and security) related to our operation of the Website. Those business partners have all agreed to uphold the same standards of security and confidentiality that we have promised to you in this Privacy Policy, and they will only use your Contact Data, Travel Data and other Personal Information to carry out their specific business obligations to Company. If you do not want us to share your Contact Data with any third parties, please email us at legal@edgewaternetworks.com

(c) USER CHOICE REGARDING COLLECTION, USE, AND DISTRIBUTION OF PERSONAL INFORMATION. We will not use your personal data for advertising purposes unless you have freely given your explicit and prior consent via the Website. However, after your consent has been given, we may use personal data as described in this Policy. You may, however, object to such use at the time of collection and each time a message is sent. If you do not wish to receive information and promotional material from us or from some of our partners, you may select the appropriate “opt-out” option each time we ask you for Personal Information.

3. CONFIDENTIALITY AND SECURITY OF PERSONAL INFORMATION. Except as otherwise provided in this Privacy Policy, we will keep your Personal Information private and will not share it with third parties, unless such disclosure is necessary to: (a) comply with a court order or other legal process; (b) protect our rights or property; or (c) enforce our Terms of Service. Your Personal Information is stored on secure servers that are not accessible by third parties. We provide you with the capability to transmit your Personal Information via secured and encrypted channels if you use a similarly equipped web browser.

3.1. USER ABILITY TO ACCESS, UPDATE, AND CORRECT PERSONAL INFORMATION. We maintain a procedure in order to help you confirm that your Personal Information remains correct and up-to-date. We reserve the right (but do not undertake the obligation) to conduct a review, at any time, to validate your data and account information, to ensure that your participation in the Website does not breach these Terms and/or any applicable law. You authorize us and our agents to make any inquiries of you and for us to use and disclose to any third party we consider necessary to validate this information. To facilitate the foregoing validation, you agree to provide sufficient information or documentation as we, in our discretion, may request. If you do not provide such information within thirty (30) days of our request, your responses are incomplete or otherwise insufficient, or we cannot verify the information applicable to your account, then we may terminate your account. At any time, you may visit your personal profile. Through your personal profile you may: (a) review and update your Personal Information that we have already collected; (b) choose whether or not you wish us to send you information about our company, or promotional material from some of our partners; and/or (c) choose whether or not you wish for us to share your Personal Information with third parties.

3.2. LOST OR STOLEN INFORMATION. You must promptly notify us if your credit card, user name, identification, or password is lost, stolen, or used without permission. In such an event, we will remove that credit card number, user name, or password from your account and update our records accordingly.

3.3. PUBLIC INFORMATION. The Website contains links to other applications and other websites. We are not responsible for the privacy practices or the content of such applications or websites. We also make chat rooms, forums, message boards, and news groups available to you. Please understand that any information that is disclosed in these areas becomes public information. We have no control over its use and you should exercise caution when deciding to disclose your Personal Information.

4. UPDATES AND CHANGES TO PRIVACY POLICY. We reserve the right, at any time and without notice, to add to, change, update, or modify this Privacy Policy, simply by posting such change, update, or modification on the Website and without any other notice to you. Any such change, update, or modification will be effective immediately upon posting on the Website.

5. YOUR PRIVACY RIGHTS.

(a) CALIFORNIA PRIVACY. Under California’s “Shine the Light” law, California residents who provide personal information in obtaining products or services for personal, family, or household use are entitled to request and obtain from us, once each calendar year, information about the customer information we shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of customer information and the names and addresses of those businesses with which we shared customer information for the immediately preceding calendar year.

To obtain this information, please send an e-mail with “Request for California Privacy Information” in the subject line and in the body of your message. We will provide in response the requested information to you at your e-mail address.

Please be aware that not all information sharing is covered by the “Shine the Light” requirements and only required information will be included in our response.

(b) PERSONAL DATA REQUESTS. We will make available to you the personal data about you in our custody or control that we have collected, used or disclosed upon your written request, to the extent required and/or permitted by law. To request access to personal information that we hold about you, we require that you submit your request in writing. When we receive an access request from an individual, we will attempt to fulfill the requested information within 30 days, including requests regarding the personal data we have in our possession or control about the individual, what it is being used for, and to whom it has been disclosed, if applicable. In certain situations, however, we may not be able to give individuals access to all or some of their personal data. If we deny an individual's request for access to their personal data, we will advise the individual of the reason for the refusal.

(c) REQUESTS TO BE FORGOTTEN. We will entertain requests to delete your personal data upon your written request, to the extent required and/or permitted by law. To request to delete information that we hold about you, we require that you submit your request in writing. Your right to be forgotten is upheld so far as this is practically achievable and so far as this does not neglect the rights of other users. We obviously cannot guarantee that data that you have shared with other users or published to the public has not been copied, particularly if it has been shared publicly. We also cannot guarantee the deletion of data that has been cached locally by individual devices that have previously been connected to our online services or such devices which have not been connected to our online services but where the data was originally input and stored by another user.

6. SECURITY. The security of your personal data is very important to us. We have put in place reasonable physical, electronic, and administrative procedures to safeguard the information we collect. Access to your personal data is granted only to those employees who require it in order to perform their duties. We cannot guarantee, however, that all communications between us or information stored on our servers will be free from unauthorized access by third parties such as hackers, or other criminals. Your use of our services demonstrates your assumption of this risk.

7. CHANGES TO THIS POLICY. We reserve the right, at our discretion, to modify our privacy practices and update and make changes to this privacy policy at any time. For this reason, we encourage you to refer to this privacy policy on an ongoing basis. This privacy policy is current as of the "last revised” date which appears at the top of this page. We will treat personal data in a manner consistent with the privacy policy under which it was collected, unless we have your consent to treat it differently. By using the Website following any privacy policy change, you freely and specifically give us your consent to collect, use, transfer and disclose your personal data in the manner specified in such then-current privacy policy.

 

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