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 2. Privacy & Cookie Notice


PRIVACY & COOKIE NOTICE




INTRODUCTION

Wolters Kluwer (“we” or “us”) wants to inform you about the ways we process your
personal information. In this Privacy & Cookie Notice we explain what personal
information we collect, use and disclose.

Personal information means any data relating to an individual who can be
identified, directly or indirectly, based on that information. This may include
information such as names, contact details, (online) identification data, online
identifiers or other characteristics specific to that individual.

This Privacy & Cookie Notice applies when you visit our websites, solutions and
other services, including events, that refer or display a link to this notice
(“Services”). This Privacy & Cookie Notice may be supplemented or replaced by
additional privacy statements or terms provided to you.

 * WHO WE ARE
   
   Wolters Kluwer is a global organisation consisting of many companies
   worldwide. Any personal information provided to or collected by Wolter Kluwer
   via our corporate web pages is controlled by Wolters Kluwer N.V., P.O. Box
   1030, 2400 BA, Alphen aan den Rijn, The Netherlands and/or one of its
   affiliates or subsidiaries. Our corporate web pages contain information about
   various Wolter Kluwer N.V. affiliates or subsidiaries, depending on the web
   pages you visit. Where pages contain features that are specific to a
   particular Wolters Kluwer affiliate or subsidiary, such as contact forms and
   communication features and chat boxes, they are solely operated by that
   Wolters Kluwer affiliate or subsidiary. General features of the web pages,
   such as website analytics, are used by both the Wolters Kluwer affiliate or
   subsidiary and Wolters Kluwer N.V. and any associated personal data
   processing takes place on the basis of an arrangement that was put in place
   by Wolters Kluwer and its relevant affiliates and subsidiaries. Under this
   arrangement, Wolters Kluwer NV will at all times be available for data
   subjects to address any concerns or questions and / or allow them to exercise
   their rights under their local applicable data protection laws regarding
   their personal information.
   
   We are committed to safeguarding the personal information of our customers,
   users, employees and other stakeholders, while helping our customers,
   employees, investors and society create a deeper impact and make the right
   decisions.
   
   If you wish to contact us in relation to questions regarding your personal
   information, we refer you to the ‘HOW YOU CAN CONTACT US’ section below.

 * WHAT PERSONAL INFORMATION DO WE COLLECT?
   
   The type of personal information we collect depends on your relationship with
   us and the Services we deliver to you. To that end, we may collect the
   following personal information about you:
   
    * Name and contact details, such as, first and last name, email address,
      postal address, telephone number
    * Work-related information, such as, job title and other employment or
      education information
    * Account Credentials, such as, passwords and other security information for
      authentication and access
    * Financial Information, such as, bank account, credit and debit card
      numbers for processing of payments
    * Usage information, such as, behavioral information about how you navigate
      within our Services and which elements of our Services you use the most
      and information regarding the goods and/or services you wish to order,
      wish list, preferences, interest, etc. Other information shared by you
      through our websites, apps, web shops and other products.
    * Computer, device and connection information, such as, IP address, browser
      type and version and location
   
   If you are under 13 years of age, please do not use or access the Services.
   Wolters Kluwer does not knowingly collect or maintain personal information
   (as defined by the United States Children’s Online Privacy Protection Act)
   from persons under 13 years of age. If Wolters Kluwer learns that personal
   information of persons under 13 has been collected on or through the
   Services, we will take appropriate steps to delete this information.

 * HOW WE COLLECT PERSONAL INFORMATION
   
   We and our third-party service providers may collect personal information
   from the following sources:
   
    * Direct Interactions, such as when you register for our Services or make a
      purchase
    * Data from Third Parties, such as information on third-party websites or
      other information you may have made publicly available, or information
      provided by third party sources, including but not limited to government
      entities and data resellers
    * Automated Tracking Technologies, such as information automatically
      collected about your interaction with our Services and websites using
      various technologies such as cookies, web logs and beacons and internet
      tags

 * HOW WE USE YOUR PERSONAL INFORMATION
   
   The personal information collected is used for the purposes for which you
   have provided it, and might be further used for statutory or other legitimate
   purposes only. As an example, if you make use of our service contact form on
   our website, we will use the information you provided in the first place to
   respond to your service request. We might further use that information to
   improve the quality of our customer service process.
   
   Lawfulness of the processing is one of the main principles relating to the
   processing of your personal information - we apply the following legal
   processing grounds:
   
    * processing is necessary for the performance of a contract, or in order to
      take steps prior to entering into a contract;
    * processing is necessary for the purposes of our legitimate interests - for
      example, to improve the quality of our products and Services;
    * processing is necessary for compliance with a legal obligation to which we
      are subject, or that is otherwise lawful under the applicable data
      protection laws;
    * with your given consent.
   
   Depending on how you interact with us and the Service, we may use your
   personal information for the following purposes:
   
    * Administering our relationship with you and our business, such as
      providing and managing your access to and use of our Services. This
      processing is necessary for the performance of a contract;
    * Improving our Services and developing new products, such as inviting you
      to participate in surveys or to personalize your experience with our
      Services. This processing is necessary for the purposes of our legitimate
      interests;
    * Marketing, such as providing you with marketing or advertising
      communications that we think you may be interested in. This processing is
      with your given consent or for our legitimate interests;
    * Recruiting, such as assessing job applicants. This processing is in order
      to take steps prior to entering into a contract or with your given
      consent;
    * Providing online communities, such as making chat rooms, forums, message
      boards, or news groups available to you. This processing is necessary for
      the performance of a contract or our legitimate interests. Please remember
      that any information disclosed in these forums is public. We encourage you
      to exercise caution when disclosing personal information in these forums,
      as this information is made available to other users. Do not disclose
      information in these public forums that might be considered confidential
      or proprietary or that you do not wish to be publicly available or that
      you are prohibited from disclosing.
    * Other general business support purposes, including but not limited to
      procurement, financial and fiscal management, risk and compliance
      management, and external reporting. This processing is necessary for
      compliance with a legal obligation to which we are subject, or that is
      otherwise lawful under the applicable data protection laws or for our
      legitimate interests.

 * SHARING YOUR PERSONAL INFORMATION
   
   To be able to provide you the best possible Services and further our business
   operations, we may share certain information internally or with selected
   third parties. There might also be a certain statutory or legal obligation
   that we believe in good faith requires us to disclose your personal
   information externally. Parties we might share data with include:
   
    * other Wolters Kluwer affiliates or subsidiaries, e.g. for providing
      underpinning technology to support the Services we are delivering;
    * our service providers, e.g. for managing or hosting services and/or
      underpinning technology for the Services we are providing;
    * our business partners, to the extent you have purchased or expressed
      interest in a product or service of such a business partner, interacted
      with them or otherwise authorized the sharing of your personal information
      with such a business partner;
    * subscribing, accrediting or professional organisations, e.g. for providing
      utilization information to organisations that provide you with access to
      our Services and/or sharing tracking and redeeming credits for
      professional accreditation;
    * organisations involved in business transfers, e.g. to a purchaser or
      successor entity in the event of a sale or any other corporate transaction
      involving some or all of our business;
    * other parties, e.g. as needed for external audits, compliance, risk
      management, corporate development and/or corporate governance related
      matters; or
    * governmental authorities and regulators, as required under the applicable
      law.
   
   Whenever we share personal information internally or with third parties in
   other countries, we have appropriate safeguards in place in accordance with
   the applicable data protection laws, including as applicable the EU Model
   clauses. As required under the applicable law, third parties are required to
   use appropriate safeguards to protect personal information, and they can only
   access the personal information that is necessary for performing their
   specific tasks.

 * HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION?
   
   Your personal information will be processed to the extent necessary for the
   performance of our obligations, and for the time necessary to achieve the
   purposes for which the information is collected, in accordance with our data
   retention policies and the applicable data protection laws. When we no longer
   need your personal information, we will take all reasonable steps to remove
   it from our systems and records or take steps to properly anonymize it so
   that you can no longer be identified from it.

 * HOW WE PROTECT YOUR PERSONAL INFORMATION
   
   We have put in place an internal framework of policies and minimum standards
   across all our businesses to keep your data safe. In addition, we limit
   access to personal information by our employees, business partners, service
   providers and third-party service providers to a ‘need-to-know’ basis. More
   specifically and in accordance with the law, we take appropriate technical
   and organisational measures (policies and procedures, IT security and others)
   to ensure the confidentiality and integrity of your personal information and
   the way it is processed.

 * WHAT ARE YOUR RIGHTS?
   
   We will honor your rights under the applicable laws. To the extent provided
   under your local data protection laws, including the European data protection
   laws, your rights include the following:
   
    * Right of access (‘an overview of your personal information’): the right to
      get an overview of your personal information that we process.
    * Right to rectification (‘correct your personal information’): if your
      personal information is inaccurate or incomplete, the right to ask us to
      rectify or complete your personal information.
    * Right to erasure (‘right to be forgotten’): the right to request that we
      delete your personal information to the extent permitted by the applicable
      law. In certain circumstances, it may not be possible for us to accept
      your request; for example, when the processing is necessary to comply with
      a legal obligation, or if the processing is necessary for the performance
      of a contract. In some cases, your personal information is necessary in
      order to provide the Services and if you do not provide such information
      to us then you may be precluded from accessing and using the Services or
      using certain Services features.
    * Right to data portability (‘transfer your personal information’): the
      right to ask us to transfer your personal information directly to you.
      This applies to certain personal information if processed by automated
      means and with your consent, or based on a contract you have with us. On
      your request, and where technically feasible, we will transfer your
      personal information to another party of your choice.
    * Right to restrict processing: the right to request that we restrict or
      stop the processing of your personal information held by us for a certain
      period of time, or for an indefinite period. In certain circumstances, it
      may not be possible for us to accept your request; for example, when the
      processing is necessary to comply with a legal obligation, or if we can
      demonstrate compelling legitimate grounds otherwise.
    * Right to object: the right to object to the processing of your personal
      information. The reasons for an objection should relate to your particular
      situation, and be related to processing based on the legitimate interest
      condition. We will then no longer process the personal information, unless
      we can demonstrate compelling reasons otherwise. In certain circumstances,
      you have the unconditional right to object; for instance, in the context
      of direct marketing activities.
    * Withdrawal of Consent: the right to withdraw your consent to the
      processing of your personal information at any time; for instance,after
      you consented to us keeping you informed about our Services, you have the
      right to withdraw this consent at any time.
   
   To exercise your rights and/or for any other questions about the handling of
   your personal information, we refer you to the ‘HOW YOU CAN CONTACT US‘
   section below.
   
   If you feel we are unresponsive or disagree with our data privacy practices,
   you can also file a complaint with your national Data Protection Authority.

 * THE USE OF COOKIES
   
   We use cookies to optimize our websites and analyse website traffic. On
   occasion, if we have obtained your informed consent in advance, we may use
   third party cookies, notably social media plugins, to enable you to share
   ideas and information related to us instantly and for our own marketing
   purposes.
   
   Cookies or similar techniques (referred to collectively as “Cookies”) are
   small text files or pixels, which might be stored on your computer or mobile
   device. Cookies may be necessary to facilitate website browsing and making it
   more user-friendly. Third party Cookies may collect information to analyse
   personal browsing behavior.
   
   We may use Cookies belonging to one of the four categories listed below. Our
   website cookie banner facilitates you to manage your preferences for the
   non-mandatory cookie categories. The banner will also provide an overview of
   all cookies used under the categories.
   
    * Necessary Cookies - these mandatory Cookies are needed for our websites to
      function properly.
    * Functional Cookies - these Cookies add additional functionality to our
      websites.
    * Performance Cookies - these Cookies support analytic services that help us
      to improve our website’s functionality and user experience.
    * Interest Cookies - these Cookies can be applied to collect insights, to
      issue personalized content and advertising on our own and other websites.
   
   Additional information about the Cookies can be found here.
   
   Change your cookie consent preferences by clicking here.

 * LINKS TO OTHER WEBSITES
   
   Our websites may contain links to other Wolters Kluwer or third-party
   websites, which may have privacy notices that differ from ours. We are not
   responsible for the collection, processing or disclosure of personal
   information collected through other websites.
   
   We are also not responsible for any information or content contained on such
   websites. Links to other websites are provided solely for convenience. Your
   usage and browsing on any such website is subject to that website’s own
   policies. Please review the privacy notices posted on other websites that you
   may access through our website.
   
   Wolters Kluwer may provide you with additional or different privacy notices,
   in specific instances, on how your personal information is collected and used
   for a specific Service.

 * ADDITIONAL INFORMATION FOR CALIFORNIA RESIDENTS
   
   In addition to the information provided in this privacy policy, additional
   information for California residents can be found here.

 * HOW YOU CAN CONTACT US
   
   If you have any questions about how we process your personal information or
   if you want to exercise one of your rights, you can contact us by using the
   ‘INQUIRY AND OTHER REQUESTS’ form. You can also contact our Data Privacy
   Officer by using the ‘INQUIRY AND OTHER REQUESTS‘ form.
   
   If you feel we are unresponsive or disagree with our data privacy practices,
   you can also file a complaint with your national Data Protection Authority.
   
   In response to a request, we might ask you to verify your identity if needed,
   and to provide information that helps us to understand your request better.
   If we do not grant your request, whether in whole or in part, we will explain
   why.

 * UPDATES TO THIS NOTICE
   
   From time to time we may update this Privacy & Cookie Notice or any other
   specific privacy statement. When making changes to this Privacy & Cookie
   Notice, we will add a new date to this Privacy Statement. This version is
   effective per June 1, 2020.
   
   Version 1.0

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