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PRIVACY POLICY




MICROSTRATEGY PRIVACY POLICY

Effective May 3, 2021

We at MicroStrategy (hereinafter “we”, “us” and “our” for the purposes of this
Privacy Policy) know you care about your privacy, and so do we. We have
developed this Privacy Policy to describe the types of Personal Information we
may collect, how we may use and share that information, our lawful basis for
processing it,  what rights you have  in relation to your Personal Information
and how we protect it. Please read this Privacy Policy carefully to understand
how we will treat your Personal Information in connection with our applications,
products/services, and/or websites (the “MicroStrategy Offerings”). We are not
in the business of selling Personal Information about you to advertisers or
spammers.

This Privacy Policy applies to processing undertaken where we are the
organization which determines why and how your Personal Information is processed
and is otherwise required under applicable law to provide notice of any
processing undertaken.

“Personal Information” is any information that relates to you, and which, alone
or in combination with other information, could reasonably be used to identify
you. It does not include data where the identity has been removed (anonymous
data).

We may make changes to this Privacy Policy from time to time, so please review
it frequently. We will indicate at the top of the policy when it was most
recently updated and, if the changes are significant, we will provide more
prominent notice.


OUR SERVICES 

In addition to, and included in, the MicroStrategy Offerings, MicroStrategy
provides security and identity product offerings (which includes the Badge and
Communicator applications), branded together as Identity (“Identity”) as part of
a service that is hosted by MicroStrategy or a third-party service provider on
behalf of MicroStrategy (a “Cloud Implementation”).  

If you are using Identity as part of a service other than a Cloud Implementation
(e.g., one that is hosted on-premises by your employer), then: (i) MicroStrategy
is not collecting, using or sharing any Personal Information about you; and (ii)
the organization that makes the service available to you (or, if applicable, the
third party that hosts the services on behalf of such organization) (the
“Implementing Organization”) may collect, use or share Personal Information
about you, and details about the Personal Information they collect maybe found
in their own privacy policy. 

If you are using Identity as part of an implementation of the MicroStrategy
Offerings other than a Cloud Implementation, please contact the Implementing
Organization to obtain information regarding what Personal Information they are
collecting and how they are using or sharing that information. 

If you are using Identity as part of a Cloud Implementation (not hosted on
premises by an employer/ third party) this Privacy Policy applies to the
Personal Information MicroStrategy collects about you in connection with and for
support, training, our own business purposes (such as  for finance and billing),
marketing, recordings and record keeping. 

We may collect or receive Personal Information about you in various ways,
depending on which of our applications and websites you use and how you interact
with us, please see below for more information.


HOW WE COLLECT INFORMATION

Information you provide to us 

You may choose to submit Personal Information and other information to us by
purchasing or interacting with the MicroStrategy Offerings. Examples of this
include, when you create and manage a user account via our website, join or
connect with a network, request technical support services, request information
or support from us, communicate with us by email, telephone, or online chat,
upload information through the MicroStrategy Offerings, subscribe to newsletters
or other subscription services, register for training, educational programs,
webinars or conferences, purchase products and services, submit job
applications, request marketing to be sent to you, visit one of our sites, or
participate in surveys.

For certain of the MicroStrategy Offerings or when you visit one of our sites,
we may ask you to provide information including:

 * Basic personal details (e.g., your name, title, and gender);
 * Contact details (e.g., your corporate email address, postal address,
   including country and state,  and phone number);
 * Professional details (e.g., your job title, your company or organization name
   and any professional organization memberships);
 * Usernames or URLs;
 * Payment details (e.g., credit card information, bank account, etc.)
 * Your photo (in connection with MicroStrategy World, events where you are a
   speaker or where you upload your photo in connection with Badge)and
 * Any other Personal Information you choose to provide us (e.g., in
   communications with technical support services, marketing teams, or during
   the provision of products/services).

Some of the information is necessary for us to provide particular MicroStrategy
Offerings, or for security clearance, and our ability to deliver the
MicroStrategy Offerings or allow access to our site(s) may be affected by your
not providing certain information. 

Information that we collect 

When you access or use MicroStrategy Offerings, we may also collect certain
information about your device and your use of the MicroStrategy Offerings. Such
information may include:

 * information, including version information, about the web browser or
   application you are using;
 * products/services you purchased, with related pricing;
 * if you are using a mobile device, the model of the device and its operating
   system;
 * crash data;
 * a unique identifier we assign to you;
 * your IP address;
 * information about your usage of the MicroStrategy Offerings, including what
   functions or pages you use, the frequency of your use, links that you click
   on, and how often you log in; 
 * cookies (please see our Cookies Policy here); and 
 * video images and audio recording where you have interacted with us on Zoom.

For certain of the MicroStrategy Offerings, including MicroStrategy web or
mobile applications, we do not collect any Personal Information about you. 
Please refer to specific application privacy practices posted on the relevant
application webstores for a list of personal information each application may
collect.

Biometric Information

When using the Identity mobile application, you may be asked to allow access to
the fingerprint scanner and/or camera on your device. This access is requested
so that a fingerprint or facial profile may be collected to validate your
credentialing information when logging into that device. This information, which
may be considered biometric data (the “Biometric Information”) is not
transmitted to us and we do not receive or retain it. We only maintain records
of when your credentialing information has been validated by Identity.

The Biometric Information may be provided to individuals such as Identity
Network administrators, User Mobile Users, and other users of the Identity
Networks you choose to participate in, as a means of confirming credentialing
information. Where this occurs, the Biometric Information is subject to those
third-parties own privacy policies, terms and conditions and other policies. We
encourage you to read those third-party policies and agreements before
participating in such credentialing activities.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you
when websites set or access cookies. If you disable or refuse cookies, please
note that some parts of this website may become inaccessible or not function
properly. For more information about the cookies we use, please see our Cookies
Policy.

Information We Collect From Other Sources 

We may also collect these categories of information from sources other than
directly from you. In particular, we collect this information from publicly
available sources (such as your employer's website or professional social
networks such as LinkedIn), and may obtain Personal Information from third party
data. Other users of the MicroStrategy Offerings may provide information about
you when they submit content through the MicroStrategy Offerings. For example,
you may be mentioned in a technical support case opened by someone else.
Similarly, an administrator may provide your Personal Information such as when
they designate you as the billing or technical contact on your company's
account. We may also receive information from analytics providers.  

Please note that we may also have access to information about you that our
customers may upload to our cloud services.

Location Information

To provide certain of the MicroStrategy Offerings, we may request your
permission to access location information from your device. Some functions of
the MicroStrategy Offerings may not work if you choose not to allow access to
this location information. If you initially consent to sharing your location
information through one of our applications or websites, you can subsequently
stop the collection of this information by changing the settings of your device
or by uninstalling the applications. Where you have not enabled location
services for the applications or websites, we may derive general usage
information (such as time zone)  from your use of the applications or websites,
including from your Bluetooth signal (where this is switched on when using
Identity.

Video/ Audio 

To provide certain of the MicroStrategy Offerings we employ the use of video
conferencing services, which include the likes of companies such as Zoom, to
interact with you and answer your queries or provide technical support.
MicroStrategy may record this meeting and process some or all recorded data
(including personal data) for provision of services, quality control, training
purposes and to improve our services.  Depending on your jurisdiction, we mainly
rely on legitimate interest as our legal basis for processing.

 

This recording shall include video images and audio. Please note that when the
recording sign is on (e.g. in Zoom (the red button)), the call is being
recorded. In some instances, if it is required by applicable data protection
law, we will obtain your explicit consent, which we will obtain at the point of
collecting the data from you and which may be refused or revoked at any time. 

Please see the Zoom Privacy Policy for more information on how Zoom works and
processes Personal Information.


OUR LAWFUL BASES FOR PROCESSING 

We will only process your Personal Information if we have a lawful basis for
doing so. Lawful bases for processing include, depending on the applicable law,
consent, contractual necessity, and our “legitimate interests” or the legitimate
interest of others, as further described below. 

Consent 

Depending on your jurisdiction, some activities may require your consent, for
example where we collect your personal data at events for our direct marketing
communications so that we can provide further information and marketing to you.
If applicable law requires your consent to process data in a certain way, then
we will obtain it before carrying out that activity. When we process Personal
Information based on your consent, it will be expressly indicated to you at the
point and time of collection. 

Where consent is not required, we will process your Personal Information because
either it is necessary for our legitimate interests, is necessary to enable us
to perform the contract or provide our services to you, or it is necessary for
us to comply with our legal obligations.

Necessary to comply with a Legal/ Regulatory Obligation 

From time to time, we may also need to process Personal Information to comply
with a legal or regulatory obligation. We rely on this lawful basis when
processing any data subject rights requests in accordance with applicable data
protection laws and for activities relating to the prevention, detection and
investigation of any crime. We also rely on it to comply with our financial
reporting obligations and compliance with subpoenas or similar court orders.

Vital Interests/ tasks carried out in public interest 

We may also need to process Personal Information if it is necessary to protect
the vital interests of you or other data subjects, or if it is necessary for a
task carried out in the public interest. 

Necessary to fulfill a contract 

Other activities are carried out to fulfill a contract or agreement (for
example, to comply with contractual obligations we have to you, including when
we provide MicroStrategy Offerings to you in accordance with the applicable
terms and conditions, or when we process payments and purchases you make). If a
contract or account is in place, then we will process your Personal Information
on the basis that it is necessary to perform our contractual commitments to
you. 

Legitimate Interests

In addition to the uses set out above, we may also process the Personal
Information we collect for our legitimate business interests when that is an
available legal basis under applicable law.  “Legitimate Interests” means the
interests of our company in conducting and managing our business to enable us to
give you the best service and products and the most secure experience. For
example, we have an interest in making sure our marketing is relevant for you,
so we may process your information to send you marketing that is tailored to
your interests.  Our legitimate interests can also apply to processing that is
in your interests as well. For example, we may process your information to
ensure our websites and systems are secure. Specifically, we may also process
the Personal Information we collect on the basis of the following legitimate
business interests: 

 * where the processing enables us to enhance, modify, personalize or otherwise
   improve our services and communications for the benefit of our customers; 
 * to enhance the security of our network and information systems; 
 * to better understand how people interact with our websites; 
 * to review and update the information we hold on you, to ensure it is accurate
   and up to date; 
 * to assess your purchasing history and build a business profile on you (in
   your professional/business role); 
 * for analysis and research in connection with product offerings and
   development; 
 * promoting our products and services; and 
 * for direct marketing purposes (where this is permitted) and to determine the
   effectiveness of promotional campaigns and advertising. 

When we process your personal information for our legitimate interests, we
consider 3 questions: is there a legitimate interest behind the use of your
Personal Information? Is our use necessary for that purpose and do your rights
override our legitimate interest? We always keep your rights in high regard and
we take steps to ensure your Personal Information is not used in ways other than
those you would expect.  We will not use your Personal Information for
activities where our interests are overridden by the impact on you (unless we
have your consent or are otherwise required or permitted to by applicable data
protection law). 

Where legitimate interest, or one of the other legal basis referred to above,
isn’t available under applicable data protection law for the processing
described under that subheading , then we will apply another alternative legal
basis to enable us to carry out that data processing, or adjust the processing
undertaken accordingly.

If you have any concerns about us using your Personal Information as outlined
above, you have the right to object using the contact details contained in this
Privacy Policy.

FOR CALIFORNIA RESIDENTS

The personal Information about you that we collect includes information within
the below categories of data. These categories also represent the categories of
Personal Information that we have collected over the past 12 months. Note that
the categories listed below are defined by California state law. Inclusion of a
category in the list below indicates only that, depending on the services and
products we provide you, we may collect some information within that category.
It does not necessarily mean that we collect all information listed in a
particular category for all of our customers. 

With the exception of recording of sales calls (and biometric information, which
we do not collect or receive a copy of), we disclose the below categories of
information with our affiliates and service providers. 

We do not sell your Personal Information.

Category Source Purpose of Processing Identifiers such as a real name, alias,
postal address, unique personal identifier, online identifier Internet Protocol
address, email address, account name, social security number, driver’s license
number, passport number, or other similar identifiers.

From you or our service providers.

A subset of this data is processed in connection with a number of our
operational functions, including to provide products/services to you,
bill/invoice you; manage any accounts, respond to your inquiries, validate your
identity and provide technical support via Zoom calls.

It is also used for marketing purposes, as well as to detect and prevent fraud
and other unauthorized activity and enforce our terms of use.

It may also be used to comply with applicable legal requirements, relevant
industry standards and our policies.

Information that identifies, relates to, describes, or is capable of being
associated with, a particular individual, including, but not limited to, your
name, signature, social security number, physical characteristics or
description, address, telephone number, passport number, driver's license or
state identification card number, insurance policy number, education,
employment, employment history, bank account number, credit card number, debit
card number, or any other financial information, medical information, or health
insurance information. From you or our service providers.

A subset of this data is processed in connection with a number of our
operational functions, including to provide products/services to you,
bill/invoice you; manage any accounts, respond to your inquiries, validate your
identity and provide technical support via Zoom calls.

It is also used for marketing purposes, as well as to detect and prevent fraud
and other unauthorized activity and enforce our terms of use.

It may also be used to comply with applicable legal requirements, relevant
industry standards and our policies.

Characteristics of classes protected under federal or California law, including:
familial status, disability, sex, national origin, religion, color, race, sexual
orientation, gender identity and gender expression, marital status, veteran
status, medical condition, ancestry, source of income, age, or genetic
information. From you or our service providers. This information may be
necessary to accommodate any accessibility needs you may have if you come into
our facilities. Commercial information, including records of personal property,
products or services purchased, obtained, or considered, or other purchasing or
consuming histories or tendencies. From you or our service providers. A subset
of this data is processed in connection with a number of our operational
functions, including to manage your account and validate your identity. It may
also be used for marketing purposes, including offering you products that may
interest you. Internet or other electronic network activity information,
including, but not limited to, browsing history, search history, and information
regarding a consumer’s interaction with an Internet Web site, application, or
advertisement. Via automated means

This data is processed in order to optimize performance of our websites and to
offer your products and services.

It is also processed to detect security incidents, protect against malicious,
deceptive, fraudulent or illegal activity, and for data analytics.

Audio, electronic, visual, thermal, olfactory, or similar information. From you
or our service providers. This data is processed in connection with a number of
our operational functions, including recording sales calls and other calls. 
Biometric Information We do not collect this information  Please see section
above on biometric information. Professional or employment-related information.
From you or our service providers.

A subset of this data is processed in connection with a number of our
operational functions, including to manage your account. It may also be used for
marketing purposes, including offering you products that may interest you.

A subset of this data is necessary to open and manage an application for
employment as well.


HOW WE USE THE INFORMATION WE COLLECT

We may use the information we collect from you to:

 * provide products/services to you;
 * bill/invoice you;
 * complete corporate transactions
 * manage any accounts that you may have with us;
 * validate your identity;
 * send personalized marketing messages via email, post and telephone to you.
   Where required by applicable law, we will send these messages with your
   consent, and you have the right to opt out of receiving marketing by
   contacting us;
 * serve relevant advertising on our site and third-party sites related to our
   products and services which are personalized to your interests;
 * provide you with notice of product releases, special events, trainings,
   promotions or other matters relevant to you;
 * respond to your inquiries;
 * improve the services you receive from us;
 * solicit your feedback;
 * prevent you from having to re-enter Personal Information about you on future
   visits to our websites or subsequent use of our applications;
 * facilitate your access to third-party services and resources;
 * keep track of your activities;
 * process your payments and purchases;
 * operate, evaluate and improve our business (including developing new products
   and services; enhancing and improving our services; managing our
   communications; analyzing our products; performing data analytics; and
   performing accounting, auditing and other internal functions);
 * provide technical support/ answer your questions via Zoom calls; 
 * detect and prevent fraud and other unauthorized activity and enforce our
   terms of use; and
 * comply with applicable legal requirements, relevant industry standards and
   our policies.

We will only use your Personal Information for the purposes for which we
collected it, unless we reasonably consider that we need to use it for another
reason and that reason is compatible with the original purpose.

Our Marketing Activities 

Where you have submitted your details on the MicroStrategy Website or at an
event, webinar, via Zoom, or otherwise provided them to us so that we can
provide you with further information about our products and services, we will
only use the Personal Information you provide us for those purposes and,
depending on your jurisdiction, in line with the consent we have obtained from
you at the time. 

We will communicate with you using the contact information provided (i.e. if you
provide us your telephone number, we will call you, if you provide us your
e-mail address, we will e-mail you), unless you have indicated a preferred
method of contact, in which case we will follow that method of communication.
Where we e-mail you with information about our products and services, we will
provide you with a clear way to opt-out of receiving any further communications.

Please note, marketing communications are not the same as “information only”, or
“service” or “transaction” communications where consents are not usually
required for us to communicate with you about the services you have inquired
about or have signed up to obtain through the MicroStrategy Website, using
contact details you have provided for this purpose. 

Where you no longer wish to receive emails that are marketing communications,
you can unsubscribe at any point by contacting us using the contact details in
the email sent to you or by using the contact details contained in this Privacy
Policy. You can also opt out of receiving marketing communications from us by
logging into our website and unchecking relevant boxes to adjust your marketing
preferences in our preference center. 

Please note, we are not responsible for any direct marketing sent to you by any
third party in respect of which you have given your consent. In such instances,
you should refer to the privacy policy of that third party. If you wish to
unsubscribe you will need to contact them directly. 

Data Enrichment & Profiling 

We sometimes utilize third party business databases such as ZoomInfo to keep our
contact database up to date and accurate. We compare the data we hold about you
as a business contact with data held by Zoominfo, and we update where necessary,
for example by adding your new business address. This is known as ‘data
enrichment’. Please note that we do not share or contribute any of your
information to ZoomInfo. For more information on ZoomInfo please see their
Privacy Policy.

We use your information to build a business profile about you, in your
professional/business capacity, for example by noting your purchase history,
type of contract and product use/ feedback, and responses to our communications.
We use this information in order to better assess your business needs and to
understand what products within the MicroStrategy Offerings might be suitable
for you in future, such as relevant upgrades. We may use such information to
determine which marketing communications to send to you, and depending on your
jurisdiction, where you have opted in to receive these. 


WITH WHOM WE MAY SHARE INFORMATION

We disclose information about you: 

 * to our third-party service providers, such as IT systems, network and back-up
   and storage;
 * to other MicroStrategy group companies; 
 * resellers;
 * system integrators;
 * co-sellers;
 * referral partners;
 * technology partners;
 * professional advisors, such as lawyers, accountants, auditors and/or
   consultants; or
 * government agencies, such as law enforcement authorities, or regulators.

We also reserve the right to transfer any information we have about you in
connection with any sale or transfer of all or a portion of our business or
assets, including in the event of a reorganization, dissolution or liquidation.

In addition, if you are using Identity, we may share certain of your information
with the administrator of an Identity Network that you are a member of, with
other users of the Identity application, or with third party services with which
your Identity Badge is integrated.


TRANSFERS OF PERSONAL INFORMATION ABROAD 

We take appropriate steps to protect your Personal Information regardless of
where it is stored, taking into consideration the requirements of the data
protection laws which we consider are applicable to how we process your Personal
Information. These include entering into contracts with third parties. An
example of this could arise if our processing of your Personal Information is
protected under United Kingdom or European Union data protection laws.  If that
Personal Information will be transferred by us or on our instructions to a
country outside the United Kingdom or European Economic Area and doing so would
otherwise be restricted under prevailing data protection law applicable to us,
because your Personal Information would not be protected to an equivalent data
protection law standard, we will put in place an approved mechanism for
providing appropriate safeguards to protect it. This includes approved
mechanisms such as standard contractual clauses. 

There may also be some instances in which we rely upon one or more permitted
exceptions under the relevant data protection law from taking this step for
particular situations.  For example, where we have asked for your explicit
consent to do, or to perform a contract with you, or take steps prior to doing
so, to conclude or perform a contract with another party concluded in your
interest, for important reasons of public interest, or where it is done in the
context of legal claims.

MicroStrategy, and its affiliated entities MicroStrategy Services Corporation
and Usher Incorporated, also comply with the EU-U.S. Privacy Shield Framework
and Swiss-US Privacy Shield Frameworks as set forth by the U.S. Department of
Commerce regarding the collection, use, and retention of personal information
transferred from the European Union and Switzerland to the United States.
MicroStrategy has certified to the Department of Commerce that it adheres to the
Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer,
Security, Data Integrity and Purpose Limitation, Access, and Recourse,
Enforcement and Liability. If there is any conflict between the terms in this
privacy policy and the Privacy Shield Principles, the Privacy Shield Principles
shall govern. To learn more about the Privacy Shield program, and to view our
certification, please visit https://www.privacyshield.gov/list/

The Federal Trade Commission has jurisdiction over MicroStrategy’s compliance
with the Privacy Shield. 

In compliance with the Privacy Shield Principles, MicroStrategy commits to
resolve complaints about our collection or use of your personal information.
European Union and Swiss individuals with inquiries or complaints regarding our
Privacy Shield policy should first contact MicroStrategy at
privacy@microstrategy.com

MicroStrategy has further committed to refer unresolved Privacy Shield
complaints to JAMS, an alternative dispute resolution provider located in the
United States. If you do not receive timely acknowledgment of your complaint
from us, or if we have not resolved your complaint, please contact or visit
https://www.jamsadr.com/eu-us-privacy-shield for more information or to file a
complaint. The services of JAMS are provided at no cost to you.

For more information on the arbitration process, please review Section C of the
Privacy Shield Annex I at:
https://www.privacyshield.gov/article?id=ANNEX-I-introduction.


HOW WE PROTECT PERSONAL INFORMATION

We maintain appropriate administrative, technical and physical safeguards
designed to protect the Personal Information you provide against accidental,
unlawful or unauthorized destruction, loss, alteration, access, disclosure or
use. We have put in place procedures to deal with any suspected breach of
Personal Information and will notify you and any applicable regulator of a
breach where we are legally required to do so.


HOW LONG WE KEEP PERSONAL INFORMATION

We also ensure that, in compliance with applicable law, we do not retain
Personal Information longer than necessary. We will keep Personal Information
about you for as long as we have a relationship with you, for example as long as
you wish to keep receiving marketing messages from us, or as long as you are a
customer (and for a reasonable period thereafter). When determining how long to
retain Personal Information after we no longer have a relationship with you, we
take into account how long our customers usually want to continue hearing from
us, our legal obligations and the expectations of regulators, as well as the
length of time information is needed for internal audit purposes and to exercise
or defend our legal rights.

We also consider the amount, nature and sensitivity of the Personal Information,
the potential risk of harm from unauthorized use or disclosure of your Personal
Information, the purposes for which we process your Personal Information and
whether we can achieve those purposes through other means, and the applicable
legal, regulatory, tax, accounting or other requirements.

This includes the following:

 * Retention in case of queries -  We may retain your Personal Information for a
   reasonable period in case of follow up queries from you.
 * Retention in case of claims - We may retain your Personal Information for the
   period in which you might legally bring claims against us (this means we will
   retain it in line with relevant limitation periods, which are applicable to
   your jurisdiction, for example 7 years from the end of the contract, for
   information relating to contracts with us if based in the UK) if and to the
   extent this is relevant.
 * Retention in accordance with legal and regulatory requirements - We will
   consider whether we need to retain your Personal Information after the period
   of retention in the case of queries or claims because of a legal or
   regulatory requirement. 
 * Retention permitted under applicable law - We will continue to retain
   Personal Information where necessary to provide our services to you and the
   retention of such Personal Information is necessary for the purposes of
   pursuing our legitimate interests or where it is necessary for public
   interest purposes.

We review our retention periods for Personal Information on a regular basis, and
all data is retained in compliance with applicable data protection law. We will
only  permanently retain certain basic Personal Information, for limited
purposes. This is in relation to retaining basic contact details, to keep a
record that you were a customer, in case you return in future, or where you have
asked us not to contact you again. 


LINKS TO OTHER WEBSITES

The MicroStrategy Offerings may contain links to websites maintained by third
parties, whose information and privacy practices differ from ours, including,
for example, websites that process online payments. We are not responsible or
liable for the content of any such websites, any use of such websites or the
information or privacy practices employed by the providers of such websites. We
encourage you to read the privacy statements of all third-party websites before
using such websites or submitting any Personal Information or any other
information on or through such websites.


NOT FOR USE BY CHILDREN

The Services and MicroStrategy Offerings are not directed to, and we do not
knowingly contact or collect Personal Information from, individuals under the
age of eighteen. If you are under the age of eighteen, these Services and
Offerings are not intended for you and you should not provide us with any
Personal Information.


YOUR RIGHTS 

Depending on your jurisdiction, you may be entitled to certain rights, which can
include:

 * Where our use of your Personal Information requires consent, you may withdraw
   this consent at any time;
 * You may request access to your Personal Information we hold about you and
   obtain information about how we process it. Depending on the applicable
   privacy laws (e.g. California law), you may be entitled to request the
   categories and specific pieces of Personal Information that we have collected
   about you, the categories of sources from which the Personal Information was
   collected, the purposes of collecting the Personal Information, the
   categories of third parties we have shared the Personal Information with, and
   the categories of Personal Information that have been shared with third
   parties for a business purpose;
 * You may update, correct or amend the Personal Information we hold about you
   if it is wrong;
 * You may ask us to change, restrict or stop the way in which we communicate
   with you or process Personal Information about you;
 * You may ask us to delete your Personal Information;
 * You have rights in relation to automated decision making, including profiling
   which has a legal effect, or which causes a significant effect;
 * You may ask us to move, copy or transfer your Personal Information; 
 * You may object to our processing of your Personal Information; and
 * You may opt out of the sale of  Personal Information—however, for purposes of
   California law, we do not sell your Personal Information to third parties,
   nor do we intend to, as those terms are defined by California privacy law. 
   We also have not done so for the last 12 months. In addition, we have
   contracts with our service providers to prohibit any sale of the personal
   information we provide them; but if you have any concerns that our third
   parties might be selling your information, please contact us.

If you would like to exercise any of your rights or if you have any questions
about this notice or would like to make a complaint please send an email to
privacy@microstrategy.com that details your request and includes your exact
name, physical address and email address. You may also submit a request to
access or delete your information via our webform.

Please note that, where required by law (such as in California), we may need to
verify your identity when you request to exercise your privacy rights.  To do
so, we may ask you to confirm information we already have on file or provide
such other proof as we need in order to determine and confirm your identity
before responding to your request.  Also, under California law (and as may be
expected in other jurisdictions as well), if you would like to authorize someone
to make a request on your behalf, you must provide the agent with written,
signed permission to submit privacy right requests on your behalf, or provide a
letter from your attorney. The agent or attorney must provide this authorization
at the time of request.  Note that we may require you to verify your identity
with us directly before we provide any requested information to your approved
agent.

We will not discriminate against you in any way for exercising your rights.
You have the right to make a complaint at any time to your local data protection
regulator. If you are based in the European Economic Area, you can access a list
of these here. If you are based in the UK you can access contact details for the
ICO here. We would, however, appreciate the chance to deal with your concerns
before you approach your regulator or ICO so please contact us in the first
instance.

How to Contact Us

If you have any comments or inquiries about this Privacy Policy, if you would
like to update information we have about you or to exercise your rights, you may
contact us by submitting a Data Privacy Inquiry, sending an email to
privacy@microstrategy.com or by sending regular mail to the following address:

Attn: Office of the General Counsel
MicroStrategy Incorporated
1850 Towers Crescent Plaza
Tysons Corner, Virginia 22182

If you are located in the E.U., you may also write to us at:

MicroStrategy Limited
Building 10, Chiswick Park
566 Chiswick High Road
Chiswick, London, W4 5XS
Attn: Legal Department

We are committed to working with you to obtain a fair resolution of any
complaint or concern about privacy. If, however, you believe that we have not
been able to assist with your complaint or concern, you have the right to make a
complaint to the data protection authority in the country in which you live via
their website.

Changes to this Policy

We may change this Policy from time to time by updating this page in order to
reflect changes in the law and/or our privacy practices.  We will update the
date at the top of the Privacy Policy accordingly. We encourage you to check
this Policy for changes when you revisit the MicroStrategy website.

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