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HIGHER LOGIC’S PRIVACY POLICY



Higher Logic, LLC (“Higher Logic”) is committed to protecting your privacy. We
are an industry leader in cloud-based engagement platforms. We offer an expanded
suite of engagement capabilities, including online and mobile communities, and
marketing automation services.

This Privacy Policy explains our data practices for subscribers to our Software
Services (“Subscribers”) and visitors to our Websites, choices available to you
regarding the use of, your access to, how to update and correct your Personal
Data (as defined below) and other information that we collect in connection
with:

(i) your visit to our Website www.higherlogic.com (where you can learn more
about the Higher Logic’s products and services, and request information and
content), hug.higherlogic.com (where Higher Logic Subscribers can engage and
network with other community managers within the Higher Logic User
Group), support.higherlogic.com (where Higher Logic Subscribers receive help and
support), academy.higherlogic.com (where Higher Logic Subscribers may take
e-learning courses), http://community.informz.net, our Subscribers’ community
for the Informz
product, http://www.realmagnet.com and http://www.informz.com (where you can
find information on our email marketing and marketing automation products and
services) (each a “Website” and, collectively, the “Websites”);

(ii) your use of our mobile applications Higher Logic User Group for members of
Higher Logic’s Users Group and Higher Logic Super Forum, used for Higher Logic’s
annual customer event (together, the “Apps”);

(iii) events you may attend to (for example, trade shows).

Our use of information on behalf of Subscribers who have registered to use the
Higher Logic online community platform (pursuant to which our Subscribers offer
access to a Website for their employees, customers and other authorized
individuals), and the Real Magnet and Informz platforms (each a “Platform” and,
collectively, the “Platforms”) is governed by our contract with that Subscriber
and the Subscriber’s own privacy policies. We are not responsible for the
privacy policies or privacy practices of Subscribers or other entities.

By using our Websites and/or the Apps, you consent to policies and practices
described in this Privacy Policy. If you do not agree with the data practices
described in this Privacy Policy, you should not use our Websites or Apps.

Our Collection of Your Personal Data

Higher Logic collects and uses information that, alone or in combination with
other information, could be used to identify you (“Personal Data”) in order to
deliver our products and services, process applications to join programs, inform
you of various opportunities, and provide support, as described below (please
also see the “How We Use Information” section below).

The following table describes (1) the categories of Personal Data we collect,
(2) examples of the types of information that fall within each category of
Personal Data collected, (3) how we use each category of Personal Data, and (4)
how we disclose Personal Information.

Categories of Personal InformationExamplesSources of Personal InformationUse of
Personal InformationDisclosure Of Personal InformationIdentification
InformationYour name, email address, postal address, telephone number, and your
company name, size, and job title.We collect Identification Information from you
voluntarily when you interact with our products, services, and customer service.



We may also receive information about you from publicly available and
third-party databases or services that provide information about business people
and companies, or from entities from whom we have purchased information.

We use Identification Information to (1) provide you support or other services
you have ordered from us, as well as product updates, product patches and fixes
and other similar operational communications; (2) respond directly to your
information requests (including registrations or other specific requests) or
other inquiries; and (3) facilitate your engagement in the Higher Logic User
Group. For EU Data Subjects, these uses are necessary for the performance of the
contract between you and us.



We also use Identification Information to update, expand and analyze our
records, identify new customers, and provide products and services that may be
of interest to you.

We disclose Identification Information to (1) service providers who provide
certain services to us to assist us in meeting business operation needs,
including:



 * Providers of payment processing and accounting, as necessary to process
   payment from our subscribers
 * Learning management systems that integrate with our platform
 * Customer service providers
 * Providers helping us fulfill subscription services (such as Salesforce)
 * Providers of research and analytics services, including Google Analytics
 * Providers of cloud computing infrastructure services

Employment InformationYour employment and education history as well as any other
information you submit through your resume and/or application for employment.We
collect Employment Information from applicants, employees, and contractors
through job applications and other job application interactions.We use
Employment Information to assess candidates for employment, for tax reporting
purposes, financial reporting matters, and for HR and legal purposes to manage
our business.We may disclose Employment Information to service providers who
provide certain services to us to assist us in meeting business operation needs,
including, for example, HR vendors and cloud management services.Interaction
InformationYour name and contact information and information that you elect to
upload to your profile, such as a biography, your education and job history,
company information. We also collect information that is provided, posted or
uploaded by users to the Higher Logic User Group.We collect Interaction
Information when you interact with our products, services, and customer service,
when you create a profile in the Higher Logic User Group on our Website
hug.higherlogic.com or our Apps, and from information that is provided, posted
or uploaded by users to the Higher Logic User Group.We use Interaction
Information to (1) provide you support or other services you have ordered from
us, as well as product updates, product patches and fixes and other similar
operational communications; (2) respond directly to your information requests
(including registrations or other specific requests) or other inquiries; and (3)
facilitate your engagement in the Higher Logic User Group. For EU Data Subjects,
these uses are necessary for the performance of the contract between you and us.



We also use Identification Information to update, expand and analyze our
records, identify new customers, and provide products and services that may be
of interest to you.

We disclose Interaction Information to (1) service providers who provide certain
services to us to assist us in meeting business operation needs, including:



 * Providers of payment processing and accounting, as necessary to process
   payment from our subscribers
 * Learning management systems that integrate with our platform
 * Customer service providers
 * Providers helping us fulfill subscription services (such as Salesforce)
 * Providers of research and analytics services, including Google Analytics
 * Providers of cloud computing infrastructure services

Automatically-Collected DataWhen you visit the Websites we may collect your IP
address, browser type/settings, search terms used, and the data and time of your
visit, ISP, site usage data, referring/exit pages, clicks, and ads viewed, among
other things.We collect Automatically-Collected Data through cookies, web
beacons and other technologies (“Tracking Technologies”).We use
Automatically-Collected Data for system administration, technology management,
including optimizing our websites and applications, information security and
cybersecurity purposes, including detecting threats, for recordkeeping purposes,
to better understand our customers and prospective customers and to enhance our
services, for online targeting and advertising purposes, and for our everyday
business purposes.We may disclose Automatically-Collected Data Information to
(1) service providers who provide certain services to us to assist us in meeting
business operation needs, including:



 * Providers of research and analytics services, including Google Analytics
 * Providers of cloud computing infrastructure services

 

Other Disclosures. We may also disclose Personal Data: (1) if you request or
authorize (2) to comply with law, including responding to a warrant or subpoena
or other government requests, (3) to protect the rights, property, or safety of
us or others, (4) to investigate fraud, (5) for law enforcement purposes, (5) if
we are involved in a merger, acquisition, financing due diligence,
reorganization, bankruptcy, receivership, sale of company assets, or transition
of service to another provider, in which case your Personal Data and other
information may be transferred to a successor or affiliate as part of that
transaction along with other assets or as part of the diligence process.

Service Data. In providing our services to Subscribers through the Platforms, we
also process on behalf of Subscribers information, including Personal Data, that
Subscribers upload to, integrate with or otherwise submit to our services. Our
Subscribers decide what data to submit (this typically includes information
about their customers, prospects, employees, consultants or independent
contractors, suppliers and other individuals or entities). We only collect such
information under the direction of Subscribers and have no direct relationship
with the individuals whose Personal Data we process.

Our use of information collected through the Platforms on behalf of our
Subscribers is limited to the purpose of providing the service for which the
Subscriber has engaged Higher Logic and is governed by our contract with that
Subscribers and the Subscriber’s own privacy policies.

Social Media

The Websites use interfaces with social media websites or platforms that are
owned and/or controlled by other entities, such as Facebook, LinkedIn, Twitter
and others (“Social Media Sites”). If you choose to “like” or share information
from a Website through any Social Media Sites, if you are a member of a Social
Media Site the interfaces on our Websites may allow the Social Media Site to
connect your Website visit to your Personal Data. The information that you share
with the Social Media Sites will be governed by the specific privacy policies
and terms of service of the Social Media Sites and not by this Privacy Policy.
You should review the privacy policy of that Social Media Site before choosing
to access and use any Social Media Sites, including interacting with our pages
on those sites.

How You Can Access and Change Information

Higher Logic acknowledges that you may have the right to access your Personal
Data. Our Websites and Apps allow you to access, correct, amend, or delete
inaccurate data. In case you request us to remove data, we will respond within a
reasonable timeframe.

Upon request, Higher Logic will provide you with information about whether we
hold any of your Personal Data. You may access, update or correct your Personal
Data or remove it from our system by making a request to us at the contact
information provided below. Requests typically receive a response within thirty
(30) days. If access cannot be provided within that time frame, we will provide
the requesting party with an estimated date by which the information will be
provided. If for some reason access is denied, we will provide an explanation of
why access has been denied.

Higher Logic has no direct relationship with the individuals whose personal data
it processes on behalf of Subscribers. An individual who seeks to access,
correct, amend, or delete inaccurate data should direct his query to the Higher
Logic Subscriber (the data controller). If requested to remove data, we will
respond within a reasonable timeframe.

If you are an EU Data Subject, please see the “EU Data Subject” section below
for information on your rights in relation to the Personal Data we hold about
you.

EU and UK Data Subjects

Scope. This section applies if you are an individual located in the European
Union (“EU”) (“EU Data Subject”) or in the United Kingdom (“UK”) (“UK Data
Subject”). For these purposes, reference to the EU also includes the European
Economic Area countries of Iceland, Liechtenstein and Norway and, where
applicable, Switzerland.

Data Controller. Higher Logic, LLC is the data controller for the processing of
your Personal Data, but we act as data processor on behalf of Subscribers for
Personal Data that we process through the Higher Logic Platform, as described
under the “Higher Logic Platform” section above.

Consent. Where required by the applicable law (for example, if you are an EU
Data Subject or UK Data Subject), we will send you marketing information or
notifications only with your consent, which was given at the time you provided
us with the Personal Data. In such case, if you do not provide us with your
consent to the processing of your Personal Data for this purpose, we will not
send you this information. With your permission, we may also use information you
provide to us as a testimonial posted on the Websites.

Your Rights. Subject to applicable law, you have the following rights in
relation to your Personal Data:

 * Right of access: If you ask us, we will confirm whether we are processing
   your Personal Data and, if so, provide you with a copy of that Personal Data
   (along with certain other details). If you require additional copies, we may
   need to charge a reasonable fee.
 * Right to rectification: If your Personal Data is inaccurate or incomplete,
   you are entitled to have it rectified or completed. If we have shared your
   Personal Data with others, we will tell them about the rectification where
   possible. If you ask us, where possible and lawful to do so, we will also
   tell you with whom we shared your Personal Data so that you can contact them
   directly.
 * Right to erasure: You may ask us to delete or remove your Personal Data and
   we will do so in some circumstances, such as where we no longer need it (we
   may not delete your data when other interests outweigh your right to
   deletion). If we have shared your data with others, we will tell them about
   the erasure where possible. If you ask us, where possible and lawful to do
   so, we will also tell you with whom we shared your Personal Data so that you
   can contact them directly.
 * Right to restrict processing: You may ask us to restrict or ‘block’ the
   processing of your Personal Data in certain circumstances, such as where you
   contest the accuracy of that Personal Data or object to us processing it. We
   will tell you before we lift any restriction on processing. If we have shared
   your Personal Data with others, we will tell them about the restriction where
   possible. If you ask us, where possible and lawful to do so, we will also
   tell you with whom we shared your Personal Data so that you can contact them
   directly.
 * Right to data portability: Effective 25 May 2018, you have the right to
   obtain your Personal Data from us that you consented to give us or that is
   necessary to perform a contract with you. We will give you your Personal Data
   in a structured, commonly used and machine-readable format. You may reuse it
   elsewhere.
 * Right to object: You may ask us at any time to stop processing your Personal
   Data, and we will do so:
   * If we are relying on a legitimate interest to process your Personal Data —
     unless we demonstrate compelling legitimate grounds for the processing; or
   * If we are processing your Personal Data for direct marketing.
 * Rights in relation to automated decision-making and profiling: You have the
   right to be free from decisions based solely on automated processing of your
   Personal Data, including profiling, that affect you, unless such processing
   is necessary for entering into, or the performance of, a contract between you
   and us or you provide your explicit consent to such processing.
 * Right to withdraw consent: If we rely on your consent to process your
   Personal Data, you have the right to withdraw that consent at any time. This
   will not affect the lawfulness of processing based on your prior consent.
 * Right to lodge a complaint with the data protection authority: If you have a
   concern about our privacy practices, including the way we have handled your
   Personal Data, you can report it to the data protection authority that is
   authorized to hear those concerns.

You may exercise your rights by contacting us as indicated under “Contact Us”
section below.

Legitimate Interest. “Legitimate interests” means the interests of Higher Logic
in conducting and managing our organization. For example, we have a legitimate
interest in processing your Personal Data to analyze how the Websites, Apps and
our products and services are being used by you, and to ensure network and
information security, as described in this Privacy Policy. When we process your
Personal Data for our legitimate interests, we make sure to consider and balance
any potential impact on you, and your rights under data protection laws. Our
legitimate interests do not automatically override your interests. We will not
use your Personal Data for activities where our interests are overridden by the
impact on you, unless we have your consent or those activities are otherwise
required or permitted to by law. You have the right to object to processing that
is based on our legitimate interests. For more information on your rights,
please see “Your Rights” section above.

Data Transfers. If you are located in the European Economic Area (“EEA”), the UK
or Switzerland, we rely on our EU-U.S. and Swiss-U.S. Privacy Shield
certification to transfer your Personal Data to the U.S. (for more information,
please read the “Privacy Shield” section below).

While Higher Logic remains self-certified under the E.U.-U.S. Privacy Shield and
the Swiss-U.S. Privacy Shield, it is not currently relying on these frameworks
for the transfer of personal data to the U.S.

Where applicable law requires that international data transfers are governed by
a data transfer mechanism, Higher Logic uses one or more of the following: EU
Standard Contractual Clauses with a data recipient outside the EEA or the UK,
verification that the recipient has implemented Binding Corporate Rules, or
verification that the recipient adheres to the EU-US and Swiss-US Privacy Shield
Framework.

Our Security Measures to Protect Your Personal Data

We are committed to taking reasonable efforts to secure the information that you
choose to provide us, and we use a variety of security technologies and
procedures to help protect against unauthorized access to or alteration,
disclosure, or destruction of Personal Data. We restrict access to Personal Data
to our employees, contractors and service providers (described in the
“Disclosure of Information” section above) who need to know the information in
order to operate, develop, or improve our services.

Unfortunately, no transmission of Personal Data over the Internet can be
guaranteed to be 100% secure. Accordingly, and despite our efforts, Higher Logic
cannot guarantee or warrant the security of any information you transmit to us,
or to or from our online products or services. Higher Logic has no
responsibility or liability for the security of information transmitted via the
Internet. If you have questions about this Privacy Policy or the security of
your Personal Data, please contact us as indicated under the “Contact Us”
section below.

We retain your Personal Data for as long as your account is active or as needed
to provide you services, comply with our legal obligations, resolve disputes and
enforce our agreements. We retain Personal Data collected through the Platforms
we process on behalf of our Subscribers for as long as needed to provide
services to our Subscriber and pursuant to our contract with that Subscriber.

Tracking Technologies

Higher Logic and its partners use cookies and other technologies to analyze
trends, administer the Websites, track users’ movements around the Websites, to
gather demographic information about our visitors and user base as a whole and
to collect information about your browsing habits in order to make advertising
relevant to you and your interests, as described below.

When you first visit the Websites, you will be asked to consent to the use of
cookies and similar technologies on the Websites in accordance with this Policy,
and if you accept we will store cookies and similar technologies on your
computer.

I. What Are Cookies
Cookies are pieces of data sent to your browser when you visit a website and
stored on your computer’s hard drive. Cookies may store user preferences and
other information. For example, cookies can store your session information for
easy log-in to a website or platform, or your language or user interface
customization preferences or may allow websites to record your browsing
activities (for example, number of page views, number of visitors, and time
spent on each page).

We use both session ID cookies and persistent cookies. A session ID cookie
expires when you close your browser. A persistent cookie remains on your hard
drive for a set period of time or until you delete it.

II. How We Use Cookies
We classify cookies in the following categories:

Categories of UsePurposeStrictly NecessaryThese cookies allow to link the
actions of a user during a browser session in order to allow navigation around
web pages, access to secure areas of the Websites or Platforms and help make the
services available through our Websites and Platforms work. Without these
cookies, basic functions of the Websites and Platforms would not work.



For example, on the www.higherlogic.com and hug.higherlogic.com Websites we use
a cookie called “ASP.NET”, a session cookie used to track a visitor’s identity
during a particular session, and a cookie named “HLAuthToken” which contains
credentials to authenticate a user.

On the Platforms, we use session cookies for authentication and authorization
purposes and to track a visitor’s identity during a particular session.

Because these cookies are strictly necessary to deliver our services, users
cannot refuse them.



You can block or delete these cookies by changing the browser settings as
explained below.

PreferencesThese cookies are used to store choices you make and your preferences
regarding our services (such as your user name, language or the region you are
in, enable user interface customization). These cookies allow us to provide
enhanced, more personal features (such as enabling customer support for users,
for example offering live support chat). These cookies are not essential for
using our services. However, without these cookies, certain functionality may
become unavailable or may not function properly.



For example, on the Websites we use cookies for use in managing the display of
items or content (such as PageSize, SortField).

On the Platforms, we use user interface customization cookies to store
Subscribers’ preferences such as grid preferences (columns, sort order, etc.) or
to enable certain functions, such as to prepopulate the input of the RSS feed
dialog.

You can block or delete these cookies by changing the browser settings as
explained below.AnalyticsThese cookies allow us to recognize and count the
number of visitors and to see how visitors move around the Websites and
Platforms when they are using it. This helps us to improve the way the Websites
and Platforms work, for example by making sure visitors are finding what they
need easily. The information collected through these cookies include anonymous
traffic statistics, like number of page views, number of visitors, and time
spent on each page.



In particular, we use cookies from Google Analytics, a web analytics service
provided by Google Inc. (“Google”) for our products Real Magnet and Informz. The
information collected by Google (including your internet protocol (IP) address)
will be transmitted to and stored by Google on servers in the United States.
Google will use this information on our behalf for the purpose of evaluating
your use of the Websites, compiling reports on the Websites activity and
providing further services to us relating to the Websites usage. Learn more
about Google Analytics’ privacy practices, and see a copy of Google’s privacy
policy, at the following
link: https://support.google.com/analytics/answer/6004245?hl=en&ref_topic=2919631.

We use Analytics cookies from HubSpot, Inc. on
the www.higherlogic.com and hug.higherlogic.com Websites to analyze and evaluate
the use of our sites and improve our services and features. Learn more about
HubSpot’s privacy practices here. If a user is logged in to HubSpot, the
application also sets the additional authentication cookies listed here.

On the Real Magnet and Informz Platforms, we use Higher Logic’s Analytics
cookies to track visits across pages on the Platforms and landing pages (for
example, on Real Magnet we use tracking cookies
named _rm_tk, _rm_ts and _rm_lprq; on the Informz Platform, we use tracking
cookies named _sp_id, _sp_ses).

You can block or delete these cookies by changing the browser settings as
explained below.



You can also prevent your data from being collected by Google Analytics on the
Websites by downloading and installing the Google Analytics Opt-out Browser
Add-on for your current web browser at the following
link: https://tools.google.com/dlpage/gaoptout?hl=en.

In their use of our services, Subscribers’ may enable various integrations which
may set additional cookies. These cookies are set and controlled by Subscribers
for various purposes such as website usage tracking and analytics and enabling
social media features. Higher Logic does not control the placement of such
cookies. Use of these cookies is governed by Subscriber’s own privacy and cookie
policies.

III.  Other Technologies

Higher Logic may use a tracking technique that employs embedded URLs to allow
use of the Websites without cookies. Embedded URLs allow limited information to
follow you as you navigate the Websites, but are not associated with Personal
Data and are not used beyond the session.

Higher Logic and its service providers may use embedded pixel technologies (or
pixel tags) for the purposes of identifying unique user visits (as opposed to
aggregate hits) and for advertising purposes. In addition, embedded pixels or
other technologies may be used in e-mails and our online display advertising to
provide information on when the e-mail or ad was opened to track marketing
campaign responsiveness; information collected using these technologies may be
associated with the recipient’s e-mail address.

We may use widgets, which are interactive mini-programs that run on our site to
provide specific services from another company (e.g., links to bookmarked
sites), along with buttons or other tools that link to other companies’ services
(e.g., a “Like” button or another entity’s map). The widget, button or tool may
collect and automatically send Personal Data, such as your e-mail address, or
other Information (such as your browser information, or IP address), to another
entity. Cookies may also be set or used by the widgets, buttons or tools to
enable them to function properly or for other purposes, which may include
advertising. Information collected or used by a widget, button or tool,
including cookie settings and preferences, is governed by the privacy policy of
the company that created it.

We use mobile analytics software to allow us to better understand the
functionality of our mobile software on your phone. This software may record
information such as how often you use the Apps, the events that occur within the
Apps, aggregated usage, performance data, and where the Apps was downloaded
from. We do not link the information we store within the analytics software to
any Personal Data you submit within the Apps.

IV. Your ChoicesOn most web browsers, you will find a “help” section on the
toolbar. Please refer to this section for information on how to receive a
notification when you are receiving a new cookie and how to turn cookies off.
Please see the links below for guidance on how to modify your web browser’s
settings on the most popular browsers:

 * Internet Explorer
 * Mozilla Firefox
 * Google Chrome
 * Apple Safari

Please note that if you reject cookies or disable cookies, your use of certain
features or functions on our Website or Platforms or service may be limited.

To find out more about cookies and similar technologies, including how to see
what cookies and similar technologies have been set and how to manage and delete
them, visit  www.allaboutcookies.org and/or or the Network Advertising
Initiative’s online resources, at http://www.networkadvertising.org, and follow
the opt-out instructions there. If you access the Websites on your mobile
device, you may not be able to control tracking technologies through the
settings. If you wish to not have your information used for the purpose of
serving you targeted ads, you may opt-out by visiting the Network Advertising
Initiative’s online resources available here and following the opt-out
instructions there, or if located in the European Union, visit the European
Interactive Digital Advertising Alliance’s Your Online Choices opt-out
tool here. By opting out of targeted advertisements you will no longer see
advertisements on our Websites from third-party partners that participate in the
Digital Advertising Alliance; however, you may still continue to see other
non-targeted advertisements on our Websites.

If you do not wish to receive marketing materials, brochures, push
notifications, or emails from Higher Logic, you may inform us of your preference
by calling Higher Logic at the contact information below, submitting a contact
form electronically through the Websites and unsubscribing from our marketing
communications by clicking on the “unsubscribe” link located on the bottom of
our e-mails.

We send you push notifications from time-to-time in order to update you about
any events or promotions that we may be running. If you no longer wish to
receive these types of communications, you may turn them off at the device
level.

Inapplicability of Privacy Policies of Any Linked Websites or Other Entities

This Privacy Policy only addresses Higher Logic’s use and disclosure of your
Personal Data. The Websites and Apps may contain links to other websites, so
please be aware that we are not responsible for the privacy practices of other
websites, and we are not liable for their misuse of Personal Data. We encourage
you to be aware that when you go to another website you should carefully read
their privacy policy.

California Privacy Rights

I. California Consumer Privacy Act (“CCPA”)
To the extent provided for by law and subject to applicable exceptions,
California residents have the following privacy rights in relation to the
Personal Data we collect:

 * The right to know what Personal Data we have collected and how we have used
   and disclosed that Personal Data;
 * The right to request deletion of your Personal Information;
 * The right to be free from discrimination relating to the exercise of any of
   your privacy rights.

We will acknowledge any request to know or to delete within 10 days of receipt,
and aim to respond to such requests with 45 days. If we need more than 45 days
to respond to your request to know or delete, we will inform you accordingly.

Higher Logic does not sell your Personal Data. However, we may share your
Personal Data (including your contact information and your browsing activity)
with social media platforms, including Facebook, that will use that information
to serve targeted advertisements on the social media platforms and third-party
websites. We do not control and are not responsible for the social media
platform’s processing of your Personal Data. You can opt out of such marketing
through Facebook here and you can contact us with any additional questions by
e-mailing privacy@higherlogic.com.

Exercising Your Rights: California residents can exercise the above privacy
rights as described here by e-mailing SRR@higherlogic.com or by calling Higher
Logic at 202-360-4402.

Verification: in order to protect your Personal Data from unauthorized access or
deletion, we may require you to verify your login credentials before you can
submit a request to know or delete Personal Data. If you do not have an account
with us, or if we suspect fraudulent or malicious activity, we may ask you to
provide additional Personal Data for verification. If we cannot verify your
identity, we will not provide or delete your Personal Data.

Authorized Agents: you may submit a request to know or a request to delete your
Personal Data through an authorized agent. If you do so, the agent must present
signed written permission to act on your behalf and you may also be required to
independently verify your identity with us.

II. Do Not Track
Higher Logic does not currently respond to “Do Not Track” signals sent by your
browser or mobile application and operate as described in this Privacy Policy
whether or not a “Do Not Track” signal is received. If we change our practices
in the future and begin to respond to “Do Not Track” signals, we will update
this Privacy Policy accordingly.

III.  Shine The Light Law

In addition to the information provided in this Privacy Policy, under
California’s “Shine the Light” law, California residents who provide “personal
information” (as defined in the statute) in obtaining products or services for
personal, family, or household use are entitled to request and obtain from us,
once a calendar year, information about the personal information we shared, if
any, with other businesses for marketing uses. If applicable, this information
would include the categories of personal information and the names and addresses
of those businesses with which we shared such personal information for the
immediately prior calendar year. To obtain this information, please contact us
by calling Higher Logic at the contact information below or by
e-mailing privacy@higherlogic.com.

Children

The Websites and Apps are not intended for use by or targeted at children under
13, and we do not knowingly or intentionally collect information about children
under 13.

Conditions of Use

By using the Websites, our Apps and our services, you agree to the terms and
conditions contained in this Privacy Policy and Conditions of Use and/or any
other agreement that we might have with you. If you do not agree to any of these
terms and conditions, you should not use the Websites, Apps and/or any Higher
Logic benefits or services. You agree that any dispute over privacy or the terms
contained in this Privacy Policy and Conditions of Use and any other agreement
we have with you will be governed by the laws of Virginia. You also agree to
arbitrate any such dispute in Arlington, Virginia, and to abide by any
limitation on damages contained in any agreement we may have with you.

Privacy Shield

Higher Logic, including its U.S. subsidiaries Higher Logic, International Inc.,
Informz, LLC, Kavi, Inc., Real Magnet, LLC, and Socious, LLC, complies with the
EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Frameworks
(Privacy Shield) as set forth by the U.S. Department of Commerce regarding the
collection, use, and retention of personal information transferred from the
European Union, the United Kingdom and/or Switzerland, as applicable, to the
United States in reliance on Privacy Shield. Higher Logic has certified to the
Department of Commerce that it adheres to the Privacy Shield Principles with
respect to such information. 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 the U.S. Department of Commerce’s Privacy Shield
List. [https://www.privacyshield.gov]

Higher Logic is responsible for the processing of personal data it receives,
under each Privacy Shield Framework, and subsequently transfers to a third-party
acting as an agent on its behalf. Higher Logic complies with the Privacy Shield
Principles for all onward transfers of personal data from the EU, UK and
Switzerland, including the onward transfer liability provisions.

With respect to personal data received or transferred pursuant to the Privacy
Shield Frameworks, Higher Logic is subject to the regulatory enforcement powers
of the U.S. Federal Trade Commission. In certain situations, we may be required
to disclose personal data in response to lawful requests by public authorities,
including to meet national security or law enforcement requirements.

If you have an unresolved privacy or data use concern that we have not addressed
satisfactorily, please contact our U.S.-based third-party dispute resolution
provider (free of charge) at https://feedback-form.truste.com/watchdog/request.
Under certain conditions, more fully described on the Privacy Shield website
[https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint], you may be
entitled to invoke binding arbitration when other dispute resolution procedures
have been exhausted.

Changes to the Privacy Policy

As Higher Logic, its products, and its services change from time to time, we may
update this Privacy Policy to reflect changes to our information practices. We
reserve the right to amend the Privacy Policy at any time, for any reason, and
may do so by posting a new version online. Your continued use of the Websites,
the Apps and/or continued provision of Personal Data to us will be subject to
the terms of the then-current Privacy Policy. If we make any material changes or
if otherwise required by the applicable law, we will notify you by email (sent
to the e-mail address specified in your account) or by means of a notice on this
website prior to the change becoming effective. We encourage you to periodically
review this page for the latest information on our privacy practices.


CONTACT US

If you have any questions about this Privacy Policy or our treatment of the
information you provide us, please contact as at:

Address: 1919 North Lynn Street, Suite 500, Arlington VA 22209
Phone: 202-360-4402
Email:  privacy@higherlogic.com

Last updated March 26, 2021


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Arlington, VA 22209
202-360-4402
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