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PRIVACY POLICY

GovLoop Privacy Policy (Last updated: January 28, 2022)


1.   OVERVIEW

Your information will be held by Granicus, LLC (“Granicus”). GovLoop,
(“GovLoop”, “Company”, or “We”), which is a division of Granicus, operates
within its own value streams and markets, and is committed to maintaining your
trust by protecting your personal data. This statement explains how we collect,
use, share and protect your personal data. Personal data is any information
relating to an identified or identifiable person. Your name, address, phone
number, bank account number, email address and your IP address are examples of
personal data. Unless otherwise specified, this notice applies to GovLoop’s
marketing efforts.

GovLoop will process your personal data in a transparent and lawful way. Any
personal data you provide when using this website or our products and services
will be used only in accordance with this privacy statement.

We may change this statement from time to time to reflect privacy or security
updates. If we make material changes, we will notify you via the email address
listed 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.

This privacy statement is provided in a layered format so you can click through
to the specific sections set out below.

Alternatively, you can download a pdf version of the statement here.

1. Overview

2. How Can You Contact Us?

3. What Personal Data Does GovLoop Collect, and for What Purpose?

4. How Do We Justify Collecting Your Data?

5. What Happens If We Process Your Data for Other Purposes?

6. What Happens If You Do Not Provide the Data?

7. Do We Use Algorithms to Make Decisions About You?

8. Do We Share Your Personal Data with Third Parties?

9. Do We Participate in Privacy Shield?

10. Where Does Your Data Go?

11. How Do We Protect Your Data?

12. How Long Will We Keep Your Data?

13. What Rights Do You Have?

13.1      Right to Request Access

13.2      Right to Rectification

13.3      Right to Object

13.4      Right to Erasure

13.5      Right to Restriction of Processing

13.6      Right to Portability

13.7      Right to Revoke Consent

13.8      Right to Make a Complaint

13.9      Right to Opt-Out of Data Sale

14. Will We Penalize You for Using Your Rights?

15. Do We Track You Online?


2.   HOW CAN YOU CONTACT US?

If you have any questions about this statement or if you would like to exercise
any rights you may have in relation to your personal data, please contact us at
info@govloop.com. If you have additional questions or need to escalate an issue,
use the below details for our Data Protection Officer (DPO).

Full name of legal entity: Granicus, LLC, as described above
Name of DPO: Data Protection Officer
Email address: dpo@granicus.com
Postal address: 408 St. Peter Street, Suite 600, St. Paul, MN 55102, USA
Telephone number: 01-651-400-8730

Name of EU representative: DataRep
Email address: granicus@datarep.com
You can also contact DataRep using this online form:
https://www.datarep.com/data-request
Postal address: The Cube, Monahan Road, Cork, T12 H1XY, Republic of Ireland


3.   WHAT PERSONAL DATA DOES GOVLOOP COLLECT, AND FOR WHAT PURPOSE?

We may collect your personal data such as your name, place of employment and
address, job position, e-mail address, and phone number. This data is collected
directly from you through forms on our website or over the phone and is used to
communicate and personalize such communications with you, including offering
products and services that we believe may be of interest to you.

Information about your chosen subscriptions is used to better provide you with
relevant e-mail content. We may also gather data about you from referrals from
existing community members. In certain situations, such as when you authorize a
social network to prefill a form on our website or if you interact with social
media buttons on our website, we may receive publicly available information from
your social media profile (such as first name, last name, e-mail address, date
of birth, gender, job title, and company).

In order to provide you with free resources, online trainings, and events,
GovLoop may share your data with online training, event or resource
underwriters. When you register for an online training/event or download a
resource, your information may be shared with the sponsors of that document or
training. You have the option to unsubscribe or opt-out from sponsor
communications with said sponsor at any time.

We also gather certain data automatically upon your visit to our website,
including Internet protocol (IP) addresses, browser type, Internet service
provider (ISP), referring/exit pages, the files viewed on our site and e-mails
(e.g., HTML pages, graphics, etc.), operating system, date/time stamp, and/or
clickstream data to analyze trends in the aggregate and administer the site.
Your IP address may also be utilized to infer your location, which we may use to
send you more relevant content.

We will not collect additional categories of personal information or use the
personal information we collect for materially different, unrelated, or
incompatible purposes without providing you notice.

In the preceding twelve (12) months, we have collected, disclosed or sold the
following categories of personal information:

Category Examples Collected (YES/NO) Shared



(YES/NO)

Sold



(YES/NO)

A. Identifiers. First Name
Last Name
Email Address
Job Title
Organization
Business Phone Number
Address
State
City
Zip
Country
Job Function
Type of Government
Mobile Phone Number (this is not shared or sold)
IP address (this is not shared or sold) YES YES YES B. Personal information
categories listed in the California Customer Records statute (Cal. Civ. Code §
1798.80(e)). Name, address, telephone number, credit card number, debit card
number, username or email address in combination with a password. Some personal
information included in this category may overlap with other categories. YES NO
NO C. Internet or other similar network activity. Browser type, Internet service
provider (ISP), operating system, date/time stamp YES NO NO D. Digital Behavior
Referring/exit pages, the files viewed on our site and e-mails (e.g., HTML
pages, graphics, etc.), clickstream YES YES YES E. Protected classification
characteristics under California or federal law. Age (40 years or older), race,
color, ancestry, national origin, citizenship, religion or creed, marital
status, medical condition, physical or mental disability, sex (including gender,
gender identity, gender expression, pregnancy or childbirth and related medical
conditions), sexual orientation, veteran or military status, genetic information
(including familial genetic information). NO NO NO F. Commercial information.
Records of personal property, products or services purchased, obtained, or
considered, or other purchasing or consuming histories or tendencies. NO NO NO
G. Biometric information. Genetic, physiological, behavioral, and biological
characteristics or activity patterns used to extract a template or other
identifier or identifying information, such as fingerprints, faceprints, and
voiceprints, iris or retina scans, keystroke, gait, or other physical patterns,
and sleep, health, or exercise data. NO NO NO H. Geolocation data. Physical
location or movements. NO NO NO I. Sensory data. Audio, electronic, visual,
thermal, olfactory, or similar information. NO NO NO J. Professional or
employment-related information. Current or past job history or performance
evaluations. NO NO NO K. Non-public education information (per the Family
Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part
99)). Education records directly related to a student maintained by an
educational institution or party acting on its behalf, such as grades,
transcripts, class lists, student schedules, student identification codes,
student financial information, or student disciplinary records. NO NO NO L.
Inferences drawn from other personal information. Profile reflecting a person’s
preferences, characteristics, psychological trends, predispositions, behavior,
attitudes, intelligence, abilities, and aptitudes. NO NO NO


4.   HOW DO WE JUSTIFY COLLECTING YOUR DATA?

We will use your personal data when the law allows us to. Most commonly, for
marketing purposes, we will process your personal data in the following
circumstances:

 * Where you consent; or
 * Where it is necessary for our legitimate interests (i.e. we have a business
   or commercial reason for using your information) and your interests and your
   fundamental rights do not override those interests.

When applicable, our legitimate interests may include:

 * Providing high-quality customer service.
 * Complying with laws or regulations that apply to us.
 * Developing our products and services, and what we charge for them.
 * Defining customers for our products and services.
 * Seeking your consent when we need it to contact you.
 * Providing our customers with relevant marketing, and other high-quality
   product and service features.
 * Keeping our marketing updated and relevant.


5.   WHAT HAPPENS IF WE PROCESS YOUR DATA FOR OTHER PURPOSES?

We will only use your personal data for the uses and purposes set out above
unless we reasonably consider that we need to use it for another reason and that
reason is compatible with the original uses and purposes. If we need to use your
personal data for an unrelated purpose, we will notify you and will explain the
legal basis which allows us to do so.


6.   WHAT HAPPENS IF YOU DO NOT PROVIDE THE DATA?

Where we need to collect personal data by law or under the terms of a contract
we have with you, and you fail to provide that data when requested, we may not
be able to perform the contract we have or are trying to enter into with you
(for example, to provide you with resources or services). In this case, we may
have to cancel a product or service you have with us, but we will notify you if
this is the case at the time.


7.   DO WE USE ALGORITHMS TO MAKE DECISIONS ABOUT YOU?

We will not use your personal data for decisions based solely on automated
processing if the decision has legal effects concerning you or if it
significantly affects you unless you gave your explicit consent for this
processing.


8. DO WE SHARE YOUR PERSONAL DATA WITH THIRD PARTIES?

We share your personal data with the following categories of recipient:

 * Agents and subcontractors. We may disclose your personal data with our agents
   or subcontractors for the purposes identified above. In these cases, the
   agent or subcontractor will be obligated to use that personal data in
   accordance with the terms of this privacy statement. Your data may be shared
   with these types of agents and subcontractors.
   * Marketing automation and analytics service provider
   * Transactional email service provider
   * Opt-in tool provider
   * Webinar hosting platform
   * Advertising platform

 * Government authorities as permitted or required by law. This may include
   disclosing your personal data to regulators, or law enforcement authorities.
   We may transfer and disclose the data we collect about you for the following
   reasons:

 * * To comply with a legal obligation, including, but not limited to responding
     to a court order;
   * To prevent fraud;
   * To comply with an inquiry by a government agency or other regulator;
   * To address security or technical issues; or
   * To assist government entities in responding to an emergency.

 * As part of a business transaction. In relation to an ongoing or proposed
   business transaction such as a transfer of the ownership or operation of
   Granicus, LLC or any companies in its group to another organization, if we
   merge with or are acquired by another organization, or if we liquidate our
   assets, your personal data may be transferred to a successor organization. If
   such a transfer occurs, the successor organization’s use of your data will
   still be subject to this statement and the privacy preferences you have
   expressed to us.

We share your personal data with the following categories of recipient and such
sharing constitutes a “sale” under the California Consumer Privacy Act.

 * Sponsors. We may disclose your personal data with our sponsors. Our sponsors
   generally underwrite resources and online training so that we may provide
   these resources at no cost to you. Sponsors are typically solution providers
   or consulting services who operate independently of GovLoop. They are
   disclosed by including their logos on their respective underwritten/sponsored
   content or on the landing page where you submit your information to register
   or download said resource. We may not share your data in all cases when
   downloading or registering for a sponsored resource. You can opt-out of
   communications with these sponsors at any time through that sponsor’s
   unsubscribe mechanisms.


9.  DO WE PARTICIPATE IN PRIVACY SHIELD?

Yes. We have certified to adhere to the Privacy Principles set forth in the
US-EU Privacy Shield Framework regarding the collection, use, and retention of
personal data transferred from the European Union (“EU”) and the United
Kingdom (“UK”) to the United States. To learn more about the Privacy Shield
program, and to view our certification, please
visit https://www.privacyshield.gov/.

We are responsible for the processing of personal data we receive or
subsequently transfer to a third party acting as an agent on our behalf. We will
comply with the Privacy Shield Principles for all onward transfers of personal
data from the EU and the UK, including the onward transfer liability provisions.

With respect to personal data received or transferred pursuant to Privacy
Shield, we are 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.

In addition, we will cooperate with the European Data Protection Authorities for
any unresolved complaints regarding personal data. You may engage your local
Data Protection and/or Labor Authority if you have concern regarding our
adherence to the Privacy Shield Principles or any applicable privacy law or
regulations. We will respond directly to such authorities regarding
investigations and resolution of complaints.  Under certain conditions, more
fully described on the Privacy Shield website, you may be entitled to invoke
binding arbitration when other dispute resolution procedures have been
exhausted.


10. WHERE DOES YOUR DATA GO?

GovLoop is owned and operated within the United States. Therefore, the data that
we collect from you will be transferred to, and stored at, a destination outside
the European Economic Area (“EEA”)/UK.

In light of the July 16, 2020 “Schrems II” decisions, the European Court of
Justice has decided that the EU-US Privacy Shield is no longer a valid
international data transfer option. We plan to maintain our Privacy Shield
certification as good practice; however, we will no longer rely upon it as a
basis for data transfer. We will discuss with any partner relying on it for
EU-US transfers their proposed alternative solutions.

The remaining option open to us for data transfers from EU to the US are
Standard Contract Clauses (SCCs)and we are therefore engaging with our partners
to:

1) Review all our data transfers globally to identify areas that require change,
2) Switch Privacy Shield transfers to EU approved Standard Contract Clauses as a
default, and
3) Introduce additional contractual, organizational and technical safeguards to
further protect your information.

Likewise, we are aware of the UK’s exit from the European Union and the end of
the current transition period on December 31st, 2020.   We will follow the new
UK Information Commissioner’s Office (ICO) and the European Data Protection
Board (EDPB) guidance on data transfer when it becomes available.

We will continue to rely on legal derogations for case-by-case transfers where
appropriate and will identify where this is the case.


11. HOW DO WE PROTECT YOUR DATA?

We are committed to ensuring that your personal data is secure. To prevent
unauthorized access or disclosure, we have put appropriate technical and
organizational measures in place to safeguard and secure your personal data.

If a data breach does occur, we will do everything in our power to limit the
damage. In case of a high-risk data breach, and depending on the circumstances,
we will inform you about remedial actions to prevent any further damage. We will
also inform the relevant supervisory authority or authorities of the breach.

Unfortunately, no security measures are completely secure. We, therefore, cannot
guarantee that your personal data will not be disclosed, misused or lost by
accident or by the unauthorized acts of others. Further, we cannot control the
dissemination of personal data you post in the public domain and you should have
no expectation of privacy in respect of such data.

The procedures and related standards include limiting access to data and
regularly testing and auditing our security practices and technologies.

Employees and temporary workers are required to follow policies and procedures
and complete confidentiality training to understand the requirement of
maintaining the confidentiality of customer information. If they fail to do so,
they are subject to disciplinary action. All employees are required to complete
privacy, security, ethics and compliance training. We also offer a wide variety
of other training to all employees and temporary workers to help us achieve our
goal of protecting your personal data.


12. HOW LONG WILL WE KEEP YOUR DATA?

We retain your personal data for as long as your account is still open. We
retain the personal data you provide while your account is in existence or as
needed to provide you services. Even if you only use our services every few
years, we will retain your information and keep your profile open until you
decide to close your account. However, it may not always be possible to
completely remove or delete all your personal data from our databases without
some residual data because of backups and other reasons.

To determine the appropriate retention period for the information we collect
from you, we consider the amount, nature, and sensitivity of the information,
the potential risk of harm from unauthorized use or disclosure of the data, the
purposes for which we process the data, whether we can achieve those purposes
through other means, and the applicable legal requirements.


13. WHAT RIGHTS DO YOU HAVE?

To exercise any of the following rights, please contact info@govloop.com. If you
need to escalate a matter or feel that your issue is unresolved, please contact
our DPO. You may also exercise some of these rights (such as access and edit
your information, or delete your profile) by visiting GovLoop’s website:
https://www.govloop.com/members/{your username}/

Removing your profile/account from GovLoop.com does not delete your data from
our marketing database. If you wish to remove this data, send a request to
info@govloop.com.

You have the option to unsubscribe or opt-out from any sponsor communications
with said sponsor at any time. You can also update your email subscription
preferences with GovLoop at any
time: https://go.govloop.com/EmailPreferences.html

You will not have to pay a fee to access your personal data (or to exercise any
of the other rights). However, we may charge a reasonable fee if your request is
clearly unfounded, repetitive or excessive. Alternatively, we may refuse to
comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your
identity and ensure your right to access your personal data (or to exercise any
of your other rights). This is a security measure to ensure that personal data
is not disclosed to any person who has no right to receive it. We may also
contact you to ask you for further information in relation to your request to
speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it
may take us longer than a month for particularly complex requests or if you have
made several requests. In this case, we will notify you and keep you updated.


13.1 RIGHT TO REQUEST ACCESS

You have the right to request details of your personal data that we hold,
including the categories of personal data collected, the sources from which it
was collected, the purpose for such collection, the categories of third parties
with whom such data is shared, and the specific data collected. Upon request, we
will provide a copy of such personal data within a reasonable timeframe.


13.2 RIGHT TO RECTIFICATION

If you believe that any personal data we are holding on you is incorrect or
incomplete, please contact us as soon as possible, at the address above. We will
promptly correct any personal data found to be incorrect, though we may need to
verify the accuracy of the new data you provide to us.


13.3 RIGHT TO OBJECT

You may choose to object to the processing of your personal data where we are
relying on a legitimate interest and there is something about your particular
situation which makes you want to object to processing on this ground as you
feel it impacts your fundamental rights and freedoms. In some cases, we may
demonstrate that we have compelling legitimate grounds to process your data
which override your rights and freedoms. You also have the right to object in
cases where we are processing your personal data for direct marketing purposes.
We will provide you with appropriate choices to opt-in or opt-out as set out
above in this statement.

Please note that your objection may be overridden by the legitimate interests of
GovLoop to process and collect your personal data.


13.4 RIGHT TO ERASURE

To the extent legally permissible, you may be entitled to have certain personal
data erased in the following circumstances:

 1. The personal data is no longer necessary in relation to the purposes for
    which it was collected or processed.
 2. You object to the collection or use of your personal data and there are no
    overriding legitimate grounds for the processing.
 3. The personal data has been unlawfully processed.
 4. The personal data has reached the defined retention period or for compliance
    with a legal obligation to which GovLoop is subject.

Note, however, that we may not always be able to comply with your request of
erasure for specific legal reasons which will be notified to you, if applicable,
at the time of your request.


13.5 RIGHT TO RESTRICTION OF PROCESSING

You may have the right to restrict further processing of your personal data in
the following situations:

 1. You contest the accuracy of the personal data.
 2. The processing of the data is unlawful.
 3. The personal data has reached the defined retention period, but you require
    the personal data to establish, exercise or defend legal claims.
 4. You object to the processing of data pursuant to the right to object as
    described above. The processing may be restricted pending the verification
    of whether GovLoop’s legitimate grounds override your rights as a data
    subject.


13.6  RIGHT TO PORTABILITY

You have the right to receive your personal data in a structured, commonly used
and machine-readable format. GovLoop will assist in the transmission of such
data to another entity, upon request, to the extent technically feasible. Note
that this right only applies to automated information which you initially
provided consent for us to use, or where we need the info to perform a contract
with you.


13.7 RIGHT TO REVOKE CONSENT

If you have consented to the processing of your personal data via the explicit
checkbox located on forms on landing pages, you have the right to revoke such
consent by emailing info@govloop.com at any time. The checkbox will only appear
for individuals who reside in countries within the EU/UK. Individuals from any
country can request to delete their data the same way – by emailing
info@govloop.com. However, if you withdraw your consent, this will not affect
the lawfulness of any processing carried out before you withdraw your consent.


13.8 RIGHT TO MAKE A COMPLAINT

You have the right to make a complaint at any time to the relevant local,
national or industry privacy regulator. We would, however, appreciate the chance
to deal with your concerns before you approach your supervisory authority so
please contact us in the first instance.


13.9 RIGHT TO OPT-OUT OF DATA SALE

For residents of California, you have the right to direct us to not sell your
personal information.  You may do so by accessing our CCPA portal.


14. WILL WE PENALIZE YOU FOR USING YOUR RIGHTS?

We will not discriminate against you for exercising any of your rights under
applicable law (such as GDPR, CCPA etc.). Unless permitted by applicable law, we
will not:

 * Deny you goods or services.
 * Charge you different prices or rates for goods or services, including through
   granting discounts or other benefits, or imposing penalties.
 * Provide you a different level or quality of goods or services.
 * Suggest that you may receive a different price or rate for goods or services
   or a different level or quality of goods or services.


15. DO WE TRACK YOU ONLINE?

GovLoop and its partners use cookies or similar technologies to analyze trends,
administer the website, track users’ movements around the website, and to gather
demographic information about our user base. You can control the use of cookies
at the individual browser level, but if you choose to disable cookies, it may
limit your use of certain features or functions on our website or service.

We also partner with third parties to display advertising on our website or to
manage our advertising on other sites. Our third-party partner may use cookies
or similar technologies in order to provide you advertising based upon your
browsing activities and interests. If you are in the UK, European Union or
California you will be provided with a cookie notice when you visit the site.
The cookie notice will provide you an option to update your preference.  In the
alternative, you may click here [or if located in the European Union click here]
to opt-out of interest-based advertising.  Please note you will continue to
receive generic ads.

Currently, various browsers offer a “do not track” or “DNT” option and global
privacy control which sends a signal to websites visited by the user about the
user’s browser DNT preference setting. We will do our best to respect such
signals we receive and notify you as required when placing tracking technologies
on your device.



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