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PRIVACY POLICY




Insight is concerned about privacy issues and wants you to be familiar with how
we collect, use and disclose information. This Privacy Policy describes our
practices in connection with information that we collect through activities that
link to this Privacy Policy including websites and through your interactive
business with Insight. By providing information to us, you agree to the terms
and conditions of this Privacy Policy. You can find out details of all of
Insight’s affiliates by visiting our website here. When we refer to ‘we’ or
‘Insight’ in this policy we are referring to Insight Enterprises, Inc. and its
affiliates. You can find out more about Insight’s commitment to the GDPR here.


INFORMATION WE MAY COLLECT

Categories of data subjects from whom we may collect data:

 * employees and former employees including volunteers, agents, individual
   contractors, temporary or casual workers;
 * applicants who have applied for employment;
 * relatives, guardians or associates of employees, former employees or
   applicants;
 * contractors, agents, consultants and suppliers both past and present and
   their individual employees or representative;
 * customers and former customers and their employees or representatives, which
   may include clients of our customers and former customers;
 * individuals and representatives of organizations who have registered with
   Insight to obtain information on products and/or services offered; and
 * individuals and representatives of organizations who have visited the
   website.

Information may include:

 * browser and device information;
 * server log file information;
 * information collected through cookies and other technologies;
 * demographic information and other information provided by you;
 * financial details;
 * complaints or grievances;
 * contact details, being corporate contact details where appropriate, including
   email, postal address, telephone and facsimile numbers;
 * purchasing habits and customers;
 * customer preferences;

In addition, with respect to employees, former employees and applicants the
additional categories of data may include:

 * Personal details
 * Family, lifestyle and social circumstances
 * Employment details
 * Financial details
 * Complaints or grievances
 * Email and postal addresses
 * Telephone and facsimile numbers
 * Limited sensitive data such as racial or ethnic origin, physical or mental
   health or condition, religious observance, issues notified under
   whistleblower policies, criminal records and disciplinary records, collected
   in the ordinary course of the employment relationship.


HOW WE MAY COLLECT THE INFORMATION

We may collect information in a variety of ways, including:

 * From you directly.
 * Through this site: Insight may collect information through the website when
   you visit.
 * Through business interaction: We may collect information through your or your
   employer’s business interaction with our employees or offices.
 * From other sources: We may receive information from other sources, such as
   public databases; joint marketing partners; social media platforms; or other
   third parties.


HOW WE MAY USE INFORMATION

 * Data storage and administration;
 * Data security;
 * Customer and user administration, including the processing of orders,
   enquires and client reporting;
 * Employee administration;
 * Advertising, marketing and public relations activities;
 * Maintenance of accounts and records;
 * Analysis of trends and statistical data;
 * Crime prevention and prosecution of offenders; and
 * Maintenance, development and testing of our website and systems which may
   include trouble shooting and tailoring specific client and partner
   experiences.

Insight will always request your consent to send you marketing communications -
as per the Information Disclosure section below you may opt-out of this whenever
you wish.

Our legal basis for collecting and using the personal data described above and
in this Privacy Policy will depend on the personal data concerned and the
specific context in which we collect it.

However, we will normally collect personal data from you only (i) where we have
your consent to do so, (ii) where we need the personal data to perform a
contract with you, or (iii) where the processing is in our legitimate interests
and not overridden by your rights.

If we ask you to provide personal information to comply with a legal requirement
or to perform a contract with you, we will make this clear at the relevant time
and advise you whether the provision of your personal information is mandatory
or not (as well as of the possible consequences if you do not provide your
personal data).

We will process your information for the purposes of operating our website and
communicating with you as necessary to provide our services to you and in our
legitimate commercial interests, for instance, when responding to your queries,
undertaking marketing activities, improving our website and services or for the
purposes of detecting or preventing illegal activities.

If you have questions about or need further information concerning the legal
basis on which we collect and use your personal information, please contact us
using the contact details provided below.


COOKIES

Please read this section carefully as it contains important information on how
we use cookies on our websites. This policy should be read together with this
entire Privacy Policy (of which this cookies section is a part).

Insight, its service providers or other third parties may set cookies for your
web browser when you visit our website, use our products or visit a website
where Insight provides ads, content or analytics.

This section on Cookies only relates to your use of Insight’s websites. On our
websites we may link to other websites owned and operated by certain trusted
third parties to make additional products and services available to you. These
other third-party websites may also use cookies or similar technologies in
accordance with their own separate policies. For privacy information relating to
these other third-party websites, please consult their policies as appropriate.

Use of cookies by Insight

Cookies are small text files that are placed on your computer by websites that
you visit. They are widely used in order to make websites work, or work more
efficiently, as well as to provide information to the owners of the site.
Cookies may be used to store items such as identifiers and user preferences. A
website may set a cookie to the browser used if the browser’s preferences allow
it.

Generally, we use cookies in order to improve the user experience of this
website in particular with customized content, tell us which parts of the
websites the users have visited, keep track of your preferences while you are
using Insight services, provide enhanced services, remember the location and
language settings for individual users, provide general internal and customer
analytics, and support security measures.For example, we may monitor how many
times you visit the website, which pages you go to, traffic data, location data
and the originating domain name of your internet service provider. This
information helps us to recognise our visitors and to understand and provide
what is most relevant to our visitors. Some of this data will be aggregated or
statistical, which means that we will not be able to identify you individually.

For further information on our use of cookies, including a detailed list of your
information which we and others may collect through cookies, please see our
Privacy Preference Centre. There you can also change your cookie preferences by
opting in or opting out of specific categories of cookies.

Types of cookies

The cookies we place on your device fall into the following categories:

Strictly necessary cookies—these cookies are essential for you to be able to
navigate our website and use its features. Without these cookies, the services
you have asked for could not be provided. They are usually only set in response
to actions made by you which amount to a request for services, such as setting
your privacy preferences, logging in or filling in forms. You can set your
browser to block or alert you about these cookies, but some parts of the site
will not then work.

Performance cookies—These cookies allow us to count visits and traffic sources,
so we can measure and improve the performance of our site. They help us know
which pages are the most and least popular and see how visitors move around the
site. All information these cookies collect is aggregated and therefore
anonymous. If you do not allow these cookies, we will not know when you have
visited our site.

Functionality cookies—these cookies enable the website to provide enhanced
functionality and personalisation. They may be set by us or by third-party
providers whose services we have added to our pages. If you do not allow these
cookies then some or all of these services may not function properly.

Targeting cookies— These cookies may be set through our site by our advertising
partners. They may be used by those companies to build a profile of your
interests and show you relevant adverts on other sites. They do not store
directly personal information, but are based on uniquely identifying your
browser and internet device. If you do not allow these cookies, you will
experience less targeted advertising.

Consent to use cookies and changing settings

We will ask for your permission (consent) to place cookies or other similar
technologies on your device, except where they are essential for us to provide
you with a service that you have requested (e.g. to enable you to put items in
your shopping basket and use our check-out process).

You can withdraw any consent to the use of cookies or manage any other cookie
preferences by using our Privacy Preference Centre (accessible via ‘Cookie
settings’ in the bottom right corner of our website). You can then make your
choices using the sliders and buttons.

How to change your global cookie settings locally on your own device:

Cookie settings can be changed in the settings of most web browsers.

You may refuse to accept cookies by modifying the settings on your browser, for
example:

 * For Internet Explorer™:
   http://windows.microsoft.com/fr-fr/internet-explorer/delete-manage-cookies
 * For Safari™: https://support.apple.com/en-gb/HT201265
 * For Chrome™: https://support.google.com/chrome/answer/95647?hl=en-GB&hlrm=en
 * For Firefox™:
   http://support.mozilla.org/fr/kb/Activer%20et%20d%C3%A9sactiver%20les%20cookies
 * For Opera™: http://help.opera.com/Windows/10.20/en/cookies.html
 * To opt out of being tracked by Google Analytics across all websites, visit
   http://tools.google.com/dlpage/gaoptout.

Please note, if you choose to block cookies via the browser, you may not be able
to access certain parts or functions of this website.


SURVEYS

The information you provide for surveys will be used to support your
relationship with Insight. Insight may use online surveys to ask
visitors/customers for contact information (like their email address). We use
contact data from our surveys to send the survey taker information about our
company and promotional material on behalf of our partners. We may combine
survey information with other data we hold about you.


CONTESTS/GIVEAWAYS

The information you provide during contests and giveaways will be used to
support your customer relationship with Insight. Insight may ask for contact
information (like your email address). We use contact data from these events to
send users information about our company and promotional material from some of
our partners. The contact information is also used to contact the visitor when
necessary. We may combine this information with other data we hold about you.


CAREERS

When you apply to work with us, we may use contact data from your application to
contact you and to schedule a personal interview. As a global business, we may
transfer your personal information outside of your home country, to Insight’s
affiliates, and to our third-party service partners. Personal information about
unsuccessful candidates will be held after the recruitment exercise has been
completed and may be reconsidered should an appropriate position become
available. Insight will follow the applicable law as to erasure of such personal
information. We may retain pseudonymized (de-personalized) statistical
information about applicants to help inform our recruitment activities. Once a
person has taken up employment with us, we will compile a file relating to their
employment. At that stage, we will give more details about how we process and
hold employee data.

Insight may use third-party service partners and a third-party recruitment tool
(“Tool”) which leverages artificial intelligence and machine learning
technologies to process application data. The Tool will make an automated
decision on the suitability of your application based on predefined criteria,
helping us filter candidates for careers at Insight; for example, when applying
for a technical cloud-based role, the tool will look for experience, job titles,
tenure, and skills which match our requirements. Candidates have the option to
utilise a “Get Matched” function within the Tool, in which case you will be
prompted to upload additional documents to the website, such as your CV,
certificates and/or a cover letter. An automated algorithm compares the
documents you provide with current vacancies at Insight. This enables us to
provide you with further career opportunities tailored to your candidate
profile. Insight’s recruitment team will review the scores and profiles produced
by the Tool when considering applications. Our third-party service partners may
also retain pseudonymized (de-personalized) information about candidates to
assist with the development of their services, which may include further machine
learning to improve their artificial intelligence models. If you do not want
your personal data to be used for machine learning, you can submit your
application by email.

Insight will not ask you to provide any sensitive personal information at the
point of application. If you include any sensitive personal information within
your application, we will process it as described above and in accordance with
applicable laws.

You can exercise your data protection rights at any time. If you wish to update
your employment, job history, and applicant data processed by Insight or
withdraw your consent for participation in future recruitment, you may contact
us as outlined in the Choice/Opt-Out/Rights section of this policy.


INFORMATION DISCLOSURE

Insight will not give or sell any information regarding you or your order and
the products you purchase to any outside organization for its use in marketing
or solicitation without your consent, save for the limited circumstances
outlined in this policy. Your information may be shared with group companies,
agents, contractors or vendors of Insight who provide data processing services
to us or who otherwise process personal data for the purpose of performing
services for you or Insight or for the purpose notified to you when we collected
your personal data. Insight may release personal data (including personally
identifiable information) when required to by law if we have a good-faith belief
that such action is necessary to comply with a current judicial proceeding, in
response to a lawful request by public authorities, a court order or legal
process served on Insight.

Insight may also share your personal data with a potential or actual buyer (and
its agents and advisers) in connection with any proposed or actual purchase,
merger or acquisition of any part of our business, provided that we inform the
buyer it must use your personal data only for the purposes disclosed in this
Privacy Policy, as well as any other person with your consent to the disclosure.

We may also disclose your information if we sell or buy any business or assets,
in which case we may disclose your personal data to the prospective seller or
buyer of the business or assets. If Insight or substantially all of its assets
are acquired by a third party, personal data held may be one of the transferred
assets. Any third party who acquires assets from us may acquire all or part of
our business. They may not be in the same line of business as we are. Similarly,
your personal information may be passed on to a successor in interest in the
event of a reconstruction, liquidation or administration.


SECURITY

While Insight uses all reasonable efforts to safeguard your personal data, no
security program is impenetrable, and criminals have been adept at circumventing
widely adopted security safeguards. Accordingly you acknowledge that the use of
the internet is not entirely secure and that you provide personal information to
Insight at your own risk. Insight cannot therefore guarantee the security or
integrity of any personal data that are transferred from you or via the
internet. Any user or third party accessing Insight’s website or services is
responsible for its own use of the website and the services. Insight is not
responsible for any third party’s actions or its security controls with respect
to information that third parties may collect or process via the website,
services or otherwise.

Insight uses what we consider to be reasonable and appropriate organizational,
technical and administrative measures to protect information under our control.
This site has security measures in place to protect the loss, misuse and
alteration of the information under our control. All account information you use
or supply on Insight's website when ordering or tracking products is held on a
system which is designed to be secure. We use reputable advanced encryption
technology which the aim to protect you from unauthorized use of information
supplied on our website. In addition, we may use your IP address to help
diagnose problems with our server, and to administer our website. Your IP
address is used to help identify you and your shopping cart and to gather broad
demographic information.


SOCIAL MEDIA FEATURES

This website includes social media features, including Facebook “Like” button
and Twitter “Follow” button. These features may collect your IP address, which
page you are visiting on this website, and may set a cookie to enable the
feature to function properly. Social media features are either hosted by a third
party or hosted directly on this website. Your interactions with these features
are governed by the privacy policy of the company providing it.

Where we have given you (or where you have chosen) a password which enables you
to access certain parts of our site or our online ordering facility, you are
responsible for keeping this password confidential. We ask you not to share a
password with anyone. Please make sure this password is unique and that you do
not use this password for any other purpose. If you use another account (such as
a social media account) to log on to a secure part of the Insight website, then
please make sure that you keep that password secure as well. If you think that
any of your passwords have been compromised, please notify us so that we can
look after the security of your details on our website.


LINKS TO THIRD-PARTY WEBSITES AND SERVICES

This website may contain links to third-party sites. If you click on those links
this will take you outside Insight’s service. We cannot control and are not
responsible for the privacy practices of those third-party sites. We encourage
users to be aware when they leave this website, and to read the privacy
statements of each website they visit. This Privacy Policy applies only to this
Website.


RETENTION OF PERSONAL DATA

We retain personal data we collect from you where we have an ongoing legitimate
business need to do so (for example, to provide you with a service you have
requested or to comply with applicable legal, tax or accounting requirements).

When we have no ongoing legitimate business need to process your personal data,
we will either delete or anonymise 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 data and isolate it from any further
processing until deletion is possible.




CHOICE/OPT-OUT/RIGHTS

You have the following data protection rights:

 * you have the right to opt-out of receiving marketing communications from us.
   You can exercise this right by clicking on "unsubscribe" by clicking on the
   “unsubscribe” or “opt-out” link in the marketing e-mails we send you. To
   opt-out of other forms of marketing (such as postal marketing or
   telemarketing), then please contact us using the contact details provided
   below. You may also modify your preferences in respect of such communications
   here.
 * you may also have the following rights (although all of these rights are
   subject to some conditions and exceptions):
   * to access, correct, and request deletion of your personal data;
   * to object to processing of your personal data, ask us to restrict said
     processing, and/or request portability of your personal data;
   * to erasure of your personal data.
 * if we have collected and process your personal data with your consent, then
   you can withdraw your consent at any time. Withdrawing your consent will not
   affect the lawfulness of any processing we conducted prior to your
   withdrawal, nor will it affect processing of your personal data conducted in
   reliance on lawful processing grounds other than consent;
 * you have the right to complain to a data protection authority about our
   collection and use of your personal data. For more information, please
   contact your local data protection authority.

You must be able to provide your name and email address or other information
sufficient to allow us to identify you. We respond to all requests we receive
from individuals wishing to exercise their data protection rights in accordance
with applicable data protection laws.

If you would like to exercise your rights please get in touch with the relevant
Insight affiliate. The contact details of each Insight affiliate are detailed on
our website at here.

Postal mail should be addressed for the attention of:

 * The Global Compliance Officer for North America and APAC regions; or
 * The DPO (Legal Department) for EMEA countries.

Email should be sent to:

 * Compliance@Insight.com for North America and APAC regions; and
 * DPO@Insight.com for EMEA countries.


INSIGHT’S COMPLIANCE WITH THE DATA PRIVACY FRAMEWORK

Insight complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the
UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework
(Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. Insight has
certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data
Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the
processing of personal data received from the European Union and the United
Kingdom in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF.
Insight has certified to the U.S. Department of Commerce that it adheres to the
Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with
regard to the processing of personal data received from Switzerland in reliance
on the Swiss-U.S. DPF. If there is any conflict between the terms in this
privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF
Principles, the Principles shall govern. To learn more about the Data Privacy
Framework (DPF) program, and to view our certification, please visit
https://www.dataprivacyframework.gov/.

The controlled U.S. subsidiaries of Insight, as identified in our
self-certification submission, also adhere to the DPF Principles. Find below the
list of Insight U.S. entities or subsidiaries adhering to the DPF Principles:

 * Insight Enterprises, Inc.
 * Insight North America, Inc.
 * Insight Direct USA, Inc.

If you have a question or complaint related to participation by Insight in the
DPF, we encourage you to contact us at compliance@insight.com or
DPO@insight.com. For any complaints related to the DPF that Insight cannot
resolve directly, we have chosen to co-operate with the relevant EU Data
Protection Authority, or a panel established by the European data protection
authorities, for resolving disputes with EU individuals, the UK Information
Commissioner’s Office (ICO), for resolving disputes with UK individuals, and the
Swiss Federal Data Protection and Information Commissioner (FDPIC) for resolving
disputes with Swiss individuals. Please contact us if you’d like us to direct
you to your data protection authority contacts.

In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and
the Swiss-U.S. DPF, Insight commits to refer unresolved complaints concerning
our handling of personal data received in reliance on the EU-U.S. DPF and the UK
Extension to the EU-U.S. DPF and the Swiss-U.S. DPF to JAMS, an alternative
dispute resolution provider based in the United States or the EU Data Protection
Authorities in your jurisdiction. If you do not receive timely acknowledgment of
your DPF Principles-related complaint from us, or if we have not addressed your
DPF Principles-related complaint to your satisfaction, please visit
https://www.jamsadr.com/dpf-dispute-resolution for more information or to file a
complaint.  The services of JAMS and the EU Data Protection Authorities are
provided at no cost to you.

As further explained in the DPF Principles, binding arbitration is also
available to address residual complaints not resolved by other means.


EU and UK individuals and Swiss individuals with inquiries or complaints
regarding our handling of personal data received in reliance on the EU-U.S. DPF
and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF should first
contact Insight at: compliance@insight.com or DPO@insight.com. Insight will
endeavour to respond within 30 days. In the unlikely event that we fail to
respond within 30 days, or if our response does not address your concern,
Insight will undertake to refer the concern to our Global Compliance Officer who
will investigate the matter and communicate with you within 14 days.

As outlined in the Choice/Opt-Out/Rights section of this policy, you have the
right to access, correct, request deletion of, and object to the processing of
your personal data, in addition to other data protection rights you may have
under applicable data protection legislation. For further information about the
choices and means we offer you for limiting the use and disclosure of your
personal data, please see Choice/Opt-Out/Rights. You can contact us as follows:

 * Compliance@Insight.com for North America and APAC regions; and
 * DPO@Insight.com for EMEA countries.

Insight is a global business. As a result, the personal data that we may collect
from you may be transferred to, processed, and stored at, any of our locations
which may be inside or outside the European Economic Area, the United Kingdom or
Switzerland. Insight may also share or otherwise make available your personal
data to our affiliates and sub-processors. Insight maintains a list of its
appointed sub-processors at:
https://www.insight.com/en_US/help/terms-and-policies/sub-processors.html. This
webpage provides clarification about the types and identities of any third
parties that Insight may share your personal data with, and the purposes for
which Insight has engaged these third parties. If you would like to receive
notifications of changes to Insights sub-processors, please subscribe on the
webpage noted above. When we transfer personal data received under the DPF to a
third party, we remain liable to you for the acts and omissions of these third
parties under the DPF as if they were the acts and omissions of Insight under
the DPF.

Insight is subject to the investigatory and enforcement powers of the Federal
Trade Commission (FTC). We may be required to disclose personal data that we
handle under the DPF in response to lawful requests by public authorities,
including to meet national security or law enforcement requirements.


UPDATES TO THIS PRIVACY POLICY

We may change this Privacy Policy as our business continues to evolve. When we
update our Privacy Policy, we will take appropriate measures to inform you in
case of significant modifications, consistent with the significance of the
changes we make. Please take a look at the “Last Updated” legend at the bottom
of this page to see when this Privacy Policy was last revised.

Supplement for California Residents

Last Updated September 2023




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