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PRIVACY POLICY

This Policy was last updated on January 5, 2021.


INTRODUCTION

Logility, Inc. and Demand Management, Inc., New Generation Computing, Inc., and
The Proven Method, Inc., each a subsidiary or affiliate (also referred to herein
as “we,” “us,” and “our”), are committed to protecting the privacy and security
of the personal information we collect, use, share, and otherwise process as
part of our business. We also believe in transparency, and we are committed to
informing you about how we treat your personal information. This Privacy Policy
(the “Policy”) will provide you with a comprehensive description of our
practices regarding the collection, use, disclosure, and sale of personal
information when we are acting as a data controller and of the rights you have
regarding your personal information. You may obtain an accessible version of
this Policy by contacting us via the methods identified in the Contact Us
section at the end of this Policy.

PLEASE READ THIS POLICY CAREFULLY TO UNDERSTAND HOW WE TREAT YOUR PERSONAL
INFORMATION AND WHAT CHOICES AND RIGHTS YOU HAVE IN THIS REGARD. IF YOU DO NOT
AGREE WITH THE TERMS AND CONDITIONS OF THIS POLICY, YOU SHOULD NOT ACCESS OR USE
THE SITE OR ENGAGE IN COMMUNICATIONS WITH US CONCERNING OUR PRODUCTS OR
SERVICES.


WHO IS RESPONSIBLE FOR YOUR PERSONAL INFORMATION?

If you are a user in the European Union (the “EU”) or the European Economic Area
(the “EEA”), for purposes of the EU General Data Protection Regulation, 2016/679
(the “GDPR”), or in the United Kingdom (the “UK”), for purposes of the UK GDPR
and/or the Data Protection Act 2018 (“UK Regulations”) (the GDPR and the UK
Regulations for purposes of this Policy will be referred to as “EU/UK
Regulations,” but each will apply only where relevant and applicable), we act as
a data controller with respect to the personal information collected by us when
you: (1) visit a website that displays or links to this Policy (the “Site”); (2)
interact with us on our social media pages; and (3) communicate with us,
including via emails and phone calls. For users in California, we act as a
“business” under the California Consumer Privacy Act (the “CCPA”) with respect
to this information. In these roles, we are responsible for implementing the
applicable data protection principles and for safeguarding the personal
information.

We also process personal information as a “processor” under the EU/UK
Regulations or a “service provider” under the CCPA on behalf of our customers.
Questions regarding our customers’ practices should be directed to those
customers. When we are acting as a data processor or a service provider, we
collect and process personal information in accordance with the instructions
provided by our customers.


WHAT PERSONAL INFORMATION DO WE COLLECT?

As a data controller, we collect and process the following personal information
for the purposes set forth below. In addition to the information that we collect
from you directly, we may also receive information about you from other sources,
including third parties, business partners, our affiliates, or
publicly-available sources.  Please do not provide another person’s personal
information to us.


CATEGORY

Contact Information


TYPES OF DATA AND PURPOSE

When you visit the Site, register for events or programs with us, or request our
products or services, we may ask you for your name, address, telephone number,
email address, or other contact details in order to respond to your request or
inquiry.

Business Information

When you seek products or services from us in the course of contractual or
customer relationships between you, your organization, and us, we collect
business contact information and other personal information in order to provide
you with the services or products you have requested.

User Account Information

In order to access and use certain features of the Site, you must first complete
a registration. When you create an account or register with us, we collect (a)
your organization’s name, type (e.g. for-profit, non-profit, governmental), and
address; (b) the name, title, e-mail address and telephone number of the
individual who is the contact for your organization; (c) other demographic
information (location, time zone); and (d) your organization’s industry and
revenue. This information is necessary to enable us to provide you the account
you have requested and to maintain the account and your profile. We also track
the services you have purchased from us. You may update your account information
by contacting us at datamanagement@logility.com.

Cookies and Similar Technologies

When you visit the Site, we collect cookies and use similar technologies to
enhance your experience, gather general visitor information, and track visits to
the Site, all in order to provide you with a more personal and interactive
experience on the Site, to improve our marketing efforts, and for usage
analytics purposes (e.g. page response times, download errors, length of visit,
webpages visited, etc.).

Please see our Cookie Policy, available
here https://www.logility.com/cookie-policy/, for more information. If you
choose to disable cookies and similar technologies, some areas and features of
the Site may not work properly.

Automated Information

When you visit the Site, we automatically collect information from your browser
or your mobile device, which includes the date and time of your visit, your
Internet Protocol (IP) address or unique device identifier, domain server, your
browser type, access time, cookies, and data about which pages you visit in
order to allow us to operate and provide the Site and our services. This
information is used to understand how you interact with the Site and to provide
you with advertising and a more personalized experience. To learn more about our
collection of technical data, please see our Cookie Policy.

Feedback / Support / Inquiries

If you provide us with feedback or contact us for support or to ask us
questions, we will collect your name, address, telephone number, email address,
and other information needed to respond to your feedback, or request for
support, or to answer your question.

Your Communications

When you communicate with us, we may retain your communications in order to
process and respond to them, as well as to improve our services. We may use your
email address to communicate with you about our products and services. If at any
time you would like to unsubscribe from receiving future emails, you may
unsubscribe using the link at the bottom of each email.

Location Information

When you use the Site, we may collect information about your location and use of
the Site, including your interaction with advertising and analytics services on
the Site, in order to (a) serve you the content and functionality you request,
and (b) maintain the privacy and security of the Site and services. Location
information collected may include your Internet Protocol (IP) address and unique
device identifier.

Email Interconnectivity

If you receive email communications from us, we may use certain tools to capture
data related to if/when you open our message and if/when you click on any links
or banners it contains. Other information collected through this email tracking
feature includes: your email address, the date and time of your “click” on the
email, a message number, the name of the list from which the message was sent, a
tracking URL number, and a destination page. We use this information to enhance
our marketing efforts. We do not sell or distribute this information to third
parties.

Mailing List

When you sign up for one of our mailing lists, we collect your contact
information, including your email address.

Third Party Information

In addition to the information that we collect from you directly, we may also
receive information about you from other sources, including third parties,
business partners, our affiliates, or publicly-available sources.

Financial and Payment Information

If you choose to purchase products or services from us through this Site,
including training, we collect your first and last names, company name, country,
street address, city, state, zip code, telephone number, and email address. You
also will be asked to provide your bank account number, bank routing
information, and other data necessary to process payments, including credit card
numbers, security codes, expiration dates, and other related billing
information; this information is passed directly to our payment processors and
is not accessed by us. By submitting your payment card information, you
expressly consent to the sharing of your information with third-party payment
processers and other third-party services (including but not limited to vendors
who provide fraud detection services to us and other third parties). Please note
that credit card numbers and account information are not stored on our servers.

Contact Us

If you choose to contact us via the Contact Us form on the Site, we will collect
your first and last names, job title, company, physical address, telephone
number, email address, and the information that you choose to include in your
message to us so that we can receive and respond to you request if needed. We
may request that you provide additional user information relevant to the support
requested. This information helps us direct your request and respond more
quickly to your needs.

If you wish to contact us regarding training via the form on the Site, we will
collect your first and last names; email address; telephone number, and the
information that you choose to include in your message and subject line to us so
that we can receive and respond to you request if needed.

Download Resources

If you wish to download a whitepaper or other resources from the Site, we will
collect your first and last names and email address in order to provide you with
the information you have requested.


HOW DO WE PROCESS AND USE PERSONAL INFORMATION?

We collect and use the types of personal information listed above in an effort
to operate our business, to improve your experience on the Site, to provide
services to you, and to communicate with you about the information you have
requested. We may also use personal information to help target specific offers
to you and to help us develop and improve the Site and our products and
services. Additionally, we may use your personal information in the following
ways:

 * To provide you with the products and services you have requested and to
   manage our relationship with you, including administering your account,
   processing payments, accounting, auditing, billing and collection, and taking
   other steps necessary to the performance of our business relationship with
   you;
 * To improve the Site’s content and functionality;
 * To personalize your experience (your information helps us to better respond
   to your individual needs);
 * To improve customer service (your information helps us to more effectively
   respond to your customer service requests and support needs) and our products
   and services;
 * To respond to visitor, subscriber, and customer inquiries;
 * To determine user interests, needs, and preferences;
 * To provide notice of changes to the Site or the services and products we
   offer or provide;
 * To deliver products and services to you and to honor our Terms of Use;
 * To comply with your instructions;
 * To conduct research and analysis;
 * To develop new products and services;
 * To manage and maintain the security of the Site and our services;
 * To market our services and products to you or to send you information about
   us, including our affiliates, or our products or services, or to contact you
   when necessary. Where legally required to do so, we will only provide you
   with marketing-related information after you have opted in to receive those
   communications, and we will provide you with the opportunity to opt-out of
   such communications at any time. We do not sell or distribute this
   information to third parties or use it for any other purpose;
 * To send periodic emails, including information and updates pertaining to your
   account;
 * Pursuant to your consent;
 * In any other way we may describe when you provide the information; and
 * For any other purpose to which you have consented or for which we have a
   legal basis under law.

We do not use your personal information for making any automated decisions
affecting or creating profiles other than as described above.

Other Processing Activities

We may process any of personal information identified in this Policy when
necessary for:

 * The establishment, exercise, or defense of legal claims, whether in court,
   administrative, or other proceedings. (The legal basis for such processing is
   our legitimate interest in the protection and assertion of our legal rights,
   your legal rights, and the legal rights of others.)
 * Obtaining or maintaining insurance coverage, managing risks, or obtaining
   professional advice (The legal basis for this processing is our legitimate
   interest in the proper protection of our business.)
 * Purposes that are consistent with, related to and/or ancillary to the
   purposes and uses described in this Policy for which your personal
   information was provided to us.

We may process your personal information in connection with any of the purposes
and uses set out in this Policy on one or more of the following legal grounds:

 * Because it is necessary to perform the services you have requested or to
   comply with your instructions or other contractual obligations between you
   and us;
 * To comply with our legal obligations as well as to keep records of our
   compliance processes;
 * Because our legitimate interests, or those of a third-party recipient of your
   personal information, make the processing necessary, provided those interests
   are not overridden by your interests or fundamental rights and freedoms;
 * Because it is necessary to protect your vital interests;
 * Because it is necessary in the public interest; or
 * Because you have expressly given us your consent to process your personal
   information in a particular manner.

We do not use your personal information for making any automated decisions
affecting or creating profiles other than as described above.

Under the CCPA, we may use and disclose any of the personal information that we
collect in order to:

 * Comply with federal, state, or local laws;
 * Comply with a civil, criminal, or regulatory inquiry, investigation,
   subpoena, or summons by federal, state, or local authorities;
 * Cooperate with law enforcement agencies concerning conduct or activity that
   we, a service provider, or a third party reasonably and in good faith believe
   may violate federal, state, or local law;
 * Exercise or defend legal claims; and
 * Collect, use, retain, sell, or disclose consumer information that is
   de-identified or in the aggregate consumer information.

Is entry of personal information required?

Some pages on the Site may give you the option of providing certain of your
personal information. You may choose not to provide us with any personal
information, and you may still access and use much of the Site. However, you
will not be able to access any portions of the Site that require your personal
information.


SHARING AND DISCLOSING YOUR PERSONAL INFORMATION

When we are acting as a data controller and where the EU/UK Regulations do not
apply, we may share your information in the following contexts. If we are acting
as a data processor, disclosures in the following contexts will be limited in
accordance with the instructions from the data controller.


CATEGORY

Acquisitions and Similar Transactions


DISCLOSURE CONTEXTS

We may disclose your personal information in the event of a merger, divestiture,
restructuring, reorganization, dissolution, or other sale or transfer of some or
all of our company assets, whether as a going concern or as part of bankruptcy,
liquidation, or similar proceeding, in which personal information held by us
about the Site’s users is among the assets transferred.

Disclosures With Your Consent

We may ask if you would like us to share your personal information with other
unaffiliated third parties who are not described elsewhere in this Policy. We
will only disclose your personal information in this context with your consent.

Disclosures Without Your Consent

We may disclose your personal information in response to subpoenas, warrants,
court orders or other legal processes, or to comply with relevant laws. We may
also share your personal information in order to establish or exercise our legal
rights, to defend against a legal claim, and to investigate, prevent, or take
action regarding possible illegal activities, suspected fraud, safety of person
or property, or a violation of our Terms of Use.

Service Providers

We may share your personal information with our service providers that need
access to your information to provide operational or other support services on
our behalf. Among other things, service providers may help us to administer the
Site; support our provision of services/products requested by you; provide
technical support; send marketing, promotions and communications to you about
our services/products; provide payment processing; and assist with other
legitimate purposes permitted by law.

Aggregated Data

We may disclose aggregated information about our users, and information that
does not identify any specific individual, such as groupings of demographic data
and customer preferences, for new product and marketing development.


HOW LONG DO WE STORE AND USE YOUR PERSONAL INFORMATION?

We will retain and use your personal information for as long as is necessary to
fulfill the purposes for which it was collected, to comply with our business
requirements and legal obligations, to resolve disputes, to protect our assets,
to provide our services, and to enforce our agreements. When applicable, we
store your personal data in accordance with the instructions from our data
controller clients.

We take reasonable steps to delete the personal information we collect when (1)
we have a legal obligation to do so; (2) we no longer have a purpose for
retaining your personal information; (3) your registration to use the Site
lapses; (4) you opt-out of receiving further communications from us; or (5) you
ask us to delete your information, unless we determine that doing so would
violate our existing, legitimate legal, regulatory, dispute resolution,
contractual, or similar obligations. We may decide to delete your personal
information if we believe it is incomplete, inaccurate, or that our continued
storage of your personal information is contrary to our legal obligations or
business objectives.

To the extent permitted by law, we may retain and use anonymous and aggregated
information for performance reporting, benchmarking, and analytic purposes and
for product and service improvement. When we delete personal information, it
will be removed from our active servers and databases as well as the Site, but
it may remain in our archives when it is not practical or possible to delete it.


HOW DO WE PROTECT YOUR PERSONAL INFORMATION?

We have put security measures in place to protect the personal information that
you share with us from being accidentally lost, used, altered, or disclosed or
accessed in an unauthorized manner. We review our security procedures
periodically to consider appropriate new technology and methods.

We use secure servers. We do not collect, store or save your financial
information on the Site or in our servers. While our security measures seek to
protect your personal information in our possession, no security system is
perfect, and no data transmission over the Internet can be guaranteed to be
completely secure. As a result, while we strive to protect your personal
information, we cannot guarantee or warrant the security of any information you
transmit to or from our Site, and you do so at your own risk. We cannot promise
that your personal information will remain absolutely secure in all
circumstances.

The safety and security of your personal information also depends on you. When
you use a password for access to restricted parts of the Site, you are
responsible for keeping the password confidential. Do not share your password
with anyone.

We also use reasonable security measures when transmitting personal information
to consumers in response to requests under the California Consumer Privacy Act.
We have implemented reasonable security measures to detect fraudulent
identity-verification activity and to prevent the unauthorized access to or
deletion of personal information.

If a data breach compromises your personal information, we will notify you and
any applicable regulator when we are required to do so by applicable law.


RIGHTS AND CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION

Please use the Contact Us details at the end of this Policy to exercise your
rights and choices under this Policy. If you would like to manage, change,
limit, or delete your personal information or if you no longer want to receive
any email, postal mail, or telephone contact from us in the future, such
requests may be submitted via the Contact Us details. If you are exercising a
right that is the responsibility of our customers, we will direct you to contact
the customer who is responsible for responding to your request.

Email Opt-Out. If you no longer wish to receive communications from us via
email, you may opt-out by clicking the “unsubscribe” link available at the
bottom of our email communications or by contacting us
at datamanagement@logility.com and providing your name and email address so that
we may identify you in the opt-out process. Once we receive your instruction, we
will promptly take corrective action.

Cookies. As discussed in our Cookie Policy, available
here https://www.logility.com/cookie-policy/, you can set your browser to refuse
all or some browser cookies, or to alert you when cookies are being sent. If you
disable or refuse cookies, please note that some parts of the Site may be
inaccessible or not function properly.

No Disclosure of Your Information for Third-Party Advertising. We do not share
your personal information with unaffiliated third parties for promotional
purposes.

Online Tracking. We do not currently recognize browser settings or signals of
tracking preferences, which may include Do Not Track instructions. Do Not Track
is a web browser setting that seeks to disable the tracking of individual users’
browsing activities. We adhere to the standards set out in this Policy and do
not currently respond to Do Not Track signals on the Site or on third-party
websites or online services where we may collect information.

Accuracy and Updating Your Personal Information. Our goal is to keep your
personal information accurate, current, and complete. If any of the personal
information you have provided to us changes, please let us know via the Contact
Us details provided at the end of this Policy. You may directly edit your
account details if you have a user account for training purposes. For instance,
if your email address changes, you may wish to let us know so that we can
communicate with you. If you become aware of inaccurate personal information
about you, you may want to update your information. We are not responsible for
any losses arising from any inaccurate, inauthentic, deficient or incomplete
personal data that you provide to us.

Preferences. If you wish to change your communication preferences or ask that we
restrict how we use your personal information, please contact us using the
information in the Contact Us section of this Policy. You may follow opt-out
links on marketing communications sent to you.

Complaints. If you believe that your rights relating to your personal
information have been violated, you may lodge a complaint with us by contacting
us using the information provided in the Contact Us section of this Policy.


CALIFORNIA RESIDENTS

CALIFORNIA CONSUMER PRIVACY ACT (“CCPA”)

The CCPA gives consumers the right to request that we (1) disclose what personal
information we collect, use, disclose, and sell, and (2) delete certain personal
information that we have collected or maintain. You may submit these requests to
us as described in the Contact Us section of this Policy.

However, by way of example, these rights do not apply where we collect or sell a
consumer’s personal information if: (1) we collected that information while the
consumer was outside of California; (2) no part of a sale of the consumer’s
personal information occurred in California; and (3) no personal information
collected while the consumer was in California is sold. In addition,
de-identified information is not subject to these rights. Furthermore, if your
information is collected in the context of a business relationship with us, it
may not currently be covered by the CCPA.

If a request is submitted in a manner that is not one of the designated methods
for submission, or if the request is deficient in some manner unrelated to our
verification process, we will either (1) treat the request as if it had been
submitted in accordance with the designated manner, or (2) provide you with
specific directions on how to submit the request or remedy any deficiencies with
the request, as applicable.

Request to Know. You have the right to request: (1) the specific pieces of
personal information we have collected about you; (2) the categories of personal
information we have collected about you; (3) the categories of sources from
which the personal information is collected; (4) the categories of personal
information about you that we have sold and the categories of third parties to
whom the personal information was sold; (5) the categories of personal
information about you that we disclosed for a business purpose and the
categories of third parties to whom the personal information was disclosed for a
business purpose; (6) the business or commercial purpose for collecting,
disclosing, or selling personal information; and (7) the categories of third
parties with whom we share personal information. Our response will cover the
12-month period preceding our receipt of a verifiable request.

Request to Delete. You have a right to request the erasure/deletion of certain
personal information collected or maintained by us. We will delete your personal
information from our records and direct any service providers (as defined under
applicable law) to delete your personal information from their records.

Excessive Requests. If requests from a consumer are manifestly unfounded or
excessive, in particular because of their repetitive character, we may either
(1) charge a reasonable fee, or (2) refuse to act on the request and notify the
consumer of the reason for refusing the request. If we charge a fee, the amount
will be based upon the administrative costs of providing the information or
communication or taking the action requested.

Non-Discrimination. You have the right not to receive discriminatory treatment
by us due to your exercise of the rights provided by the CCPA. We do not offer
financial incentives and price or service differences, and we do not
discriminate against consumers for exercising their rights under the CCPA.

No Sales of Personal Information. Under the CCPA, you have the right to direct
us to stop selling your personal information to third parties and to refrain
from doing so in the future. For purposes of the CCPA, we do not sell personal
information as defined under applicable law, and we have not sold personal
information during the past 12 months.

Verification Process. We are required by law to verify the identities of those
who submit requests. To determine whether the individual making the request is
the consumer about whom we have collected information, we will verify your
identity by matching the identifying information provided by you in the request
to the personal information that we already maintain about you. If we cannot
verify the identity of the person making a request, we may deny it in whole or
in part. We will inform you if we cannot verify your identity.

Authorized Agents. Authorized agents may submit requests via the methods
identified in this Policy. If you use an authorized agent to submit a request,
we may require you to: (1) provide the authorized agent with signed permission
to do so; (2) verify your identity directly with us; and (3) directly confirm
with us that you provided the authorized agent permission to submit the request.
However, we will not require these actions if you have provided the authorized
agent with power of attorney pursuant to the California Probate Code. We may
deny a request from an agent that does not submit proof that they have been
authorized by the consumer to act on their behalf.

CALIFORNIA SHINE THE LIGHT

Under California Civil Code Section 1798.83, California residents who provide
personal information in obtaining products or services for personal, family, or
household use may be entitled to request and obtain from us once a calendar year
information about the information we shared, if any, with other businesses for
direct marketing uses. At present, we do not share your personal information
with third parties for those third parties’ direct marketing purposes. Please be
aware that not all information sharing is covered by the “Shine the Light”
requirements and only information on covered sharing, if any, will be included
in our response. As part of the California Online Privacy Protection Act, all
users of our Site may make any changes to their information at any time by
contacting us at datamanagement@logility.com.


NEVADA RESIDENTS

You may submit a verified request to us at datamanagement@logility.com to
request that we not make any sale (as defined under Nevada law) of any covered
information (as defined under Nevada law) that we have collected or will collect
about you. We will respond to any such request as required by Nevada law.


EU/EEA/UK RESIDENTS

If you are located in the EU, EEA or UK, you may have the following rights under
the relevant EU/UK Regulations. All requests should be sent to the address noted
in the Contact Us section of this Policy, and we will fulfill requests to the
extent required by applicable law.

Right of Access. To the extent required by law, you have the right to receive
confirmation as to whether or not personal data concerning you are being
processed, and, where that is the case, access to the personal data and the
following information: the purposes of the processing; the categories of
personal data concerned; and the recipients or categories of recipient to whom
the personal data have been or will be disclosed. We will provide a copy of your
personal information in compliance with applicable law.

Right of Rectification. Our goal is to keep your personal information accurate,
current, and complete. Please contact us if you believe your information is not
accurate or if it changes.

Right to Erasure. In some cases, you have a legal right to request that we
delete your personal information when (1) it is no longer necessary for the
purposes for which it was collected; (2) consent has been withdrawn in certain
instances; (3) you have objected to the processing in certain instances; (4) the
personal information has been unlawfully processed; (5) the personal data must
be erased for compliance with a legal obligation; and (6) the personal data were
collected in relation to the offer of information society services. However, the
right is not absolute. When we delete personal information, it will be removed
from our active servers and databases as well as the Site, but it may remain in
our archives when it is not practical or possible to delete it. We may also
retain your personal information as needed to comply with our legal obligations,
resolve disputes, or enforce any agreements.

Right to Restrict Processing. You have the right to restrict the processing of
your personal data when (1) the accuracy of the personal data is contested, for
a period enabling us to verify the accuracy of the personal data; (2) the
processing is unlawful and you oppose erasure and request a restriction instead;
(3) we no longer need the personal data but you require us to keep it for the
establishment, exercise or defense of legal claims; or (4) you have objected to
us processing the personal information, pending resolution of the objection.

Right to Object. In certain circumstances, you have the right to object to the
processing of your personal information where the processing is necessary for
performance of a task carried out in the public interest, for our legitimate
interests, or for the legitimate interests of others. You also have the right to
object where personal data are processed for direct marketing purposes or for
scientific or historical research purposes or statistical purposes.

Right to Withdraw Consent. If you have provided your consent to the collection,
processing, and transfer of your personal information, you may have the right to
fully or partially withdraw your consent. Once we have received notice that you
have withdrawn your consent, in whole or in part, we will no longer process your
information for the purposes to which you originally consented and have since
withdrawn unless there are compelling legitimate grounds for further processing
that override your interests, rights and freedoms or for the establishment,
exercise or defense of legal claims. Withdrawal of consent to receive marketing
communications will not affect the processing of personal information for the
provision of our services.

Right to Complain. If you believe we have not processed your personal
information in accordance with applicable provisions of the EU/UK Regulations,
we encourage you to contact us at datamanagement@logility.com. You also have the
right to make a complaint to the relevant Supervisory Authority or seek a remedy
through the courts. A list of Supervisory Authorities in the EU is available
at: https://edpb.europa.eu/about-edpb/board/members_en. UK users may contact the
Information Commissioner’s Office at https://ico.org.uk/make-a-complaint/. If
you need further assistance regarding your rights, please contact us using the
contact information provided below and we will consider your request in
accordance with applicable law.


INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION

We are located and established in the United States and, therefore, your
personal information may be transferred to, stored, or processed in the United
States. While the data protection, privacy and other laws of the United States
might not be as comprehensive as those in your country, we take necessary and
appropriate steps to protect the privacy and security of your personal
information. By using the Site or requesting services from us, you understand
and consent to the collection, storage, processing, and transfer of your
information to our facilities in the United States and those third parties with
whom we share it as described in this Policy.

When storing, hosting, or otherwise processing information (including personal
data) for residents of the EU/EEA/UK, we may send such data outside of these
regions. When we transfer information to the United States or other countries,
we do so for the purposes set forth in this Policy and in accordance with
applicable law. We rely on recognized legal bases to lawfully conduct
cross-border/international transfers of personal information outside of the EU,
EEA or UK, such as your express informed consent to do so, when transfer is
necessary for us to deliver services pursuant to an agreement between us and
you, or when the transfer is subject to safeguards that assure the protection of
your personal information, such as the European Commission’s approved standard
contractual clauses.


CHILDREN’S ONLINE PRIVACY PROTECTION ACT

The Children’s Online Privacy Protection Act (“COPPA”), as well as other data
privacy regulations, restrict the collection, use, or disclosure of personal
information from and about children on the Internet. Our Site and services are
not directed to children aged 18 or younger, nor is information knowingly
collected from children under the age of 18. No one under the age of 18 may
access, browse, or use the Site or provide any information to or on the Site. If
you are under 18, please do not use or provide any information on the Site
(including, for example, your name, telephone number, email address, or
username). If we learn that we have collected or received personal information
from a child under the age of 18 without a parent’s or legal guardian’s consent,
we will take steps to stop collecting that information and delete it. If you
believe we might have any information from or about a child under the age of 18,
please contact us using the contact information provided below.

For more information about COPPA, please visit the Federal Trade Commission’s
website
at: https://www.ftc.gov/enforcement/rules/rulemaking-regulatory-reform-proceedings/childrens-online-privacy-protection-rule.


THIRD-PARTY SITES

This Policy is applicable only to the Site, and it does not apply to any
third-party websites.

The Site may contain links to, and media and other content from, third-party
websites. These links are to external websites and third parties with which we
may have no relationship. Because of the dynamic media capabilities of the Site,
it may not be clear to you which links are to the Site and which are to
external, third-party websites. If you click on an embedded third-party link,
you will be redirected away from the Site to the external third-party website.
You can check the URL to confirm that you have left this Site.

We cannot and do not (1) guarantee the adequacy of the privacy and security
practices employed by or the content and media provided by any third parties or
their websites; (2) control third parties’ independent collection or use or your
personal information; or (3) endorse any third-party information, products,
services or websites that may be reached through embedded links on this Site.

Any personal information provided by you or automatically collected from you by
a third party will be governed by that party’s privacy policy and terms of use.
If you are unsure whether a website is controlled, affiliated, or managed by us,
you should review the privacy policy and practices applicable to each linked
website.


UPDATES AND CHANGES TO THIS POLICY

We reserve the right, at any time, to add to, change, update, or modify this
Policy to reflect any changes to the way in which we treat your personal
information or in response to changes in law. Should this Policy change, we will
post all changes we make to this Policy on this page. If we make material
changes to how we treat your personal information, we will also notify you
through a notice on the home page of the Site for a reasonable period of time.
Any such changes, updates, or modifications shall be effective immediately upon
posting on the Site. The date on which this policy was last modified is
identified at the beginning of this Policy.

You are expected to, and you acknowledge and agree that it is your
responsibility to, carefully review this Policy prior to using the Site, and
from time to time, so that you are aware of any changes. Your
continued use of the Site after the “Last Updated” date will constitute your
acceptance of and agreement to such changes and to our collection and sharing of
your personal information according to the terms of the then-current Policy. If
you do not agree with this Policy and our practices, do not access, view, or use
any part of the Site.


CONTACT US

For more information, or if you have any questions or concerns regarding this
Policy, wish to exercise your rights, or wish to lodge a complaint with us, you
may contact us using the information below, and we will do our best to assist
you. Please note, if your communication is sensitive, you may wish to contact us
by postal mail or telephone.

In Writing: 470 East Paces Ferry Road, Atlanta, GA 30305

By Telephone: 1-800-762-5207

EMEA: +44 (0) 121 629 7866

Asia Pacific: +61 (0) 2 9911 4029

South America: +55 (11) 3568-2442

By Email: datamanagement@logility.com

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