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BREADCRUMB

1.
2. Legal
3. Privacy Notice

FLEXERA PRIVACY NOTICE

* Legal Home Page

This document was last updated April 14, 2022

We appreciate your interest in our offered services and products and our
websites (www.flexera.com, www.flexerasoftware.com, www.revenera.com,
www.flexera.de, www.flexerasoftware.de, www.revenera.de,
https://store.flexerasoftware.com, http://consumer.installshield.com,
https://community.flexera.com/t5/Flexera-Community/ct-p/Flexera_Community,
https://community.flexera.com/t5/Flexera-Software-Community/ct-p/Flexera_Software_Community,
www.flexnetoperations.com, www.flexnetmanager.com, www.flexnetmanager.eu,
www.brainwaregroup.com, https://app.secunia.com/,
https://app.flexerasoftware.com/, https://csi7.secunia.com/csi/,
https://portal.technopedia.com/login, https://login.rightscale.com/,
https://my.metasaas.com/login, https://www.riscnetworks.com,
https://portal.riscnetworks.com/, https://analytics.revulytics.com/), online
communities and service platforms owned and operated by Flexera (collectively,
our “Websites” and together with our services and products, our “Services”).
Privacy protection is very important to us, and we are committed to protecting
and respecting your privacy. This privacy notice sets out information about how
we collect, store, transfer, use and otherwise process personal information.

A. GENERAL PROVISIONS

1. Who we are.

Flexera Software LLC, 300 Park Blvd, Suite 500, Itasca, IL 60143, (“Flexera
Software LLC”) is generally responsible for and controls the processing of
your personal information collected through the Services.

However, if you retain Services directly from a local Flexera group company
(i.e., when you have concluded a contract with one of the local Flexera
group companies) or otherwise do business with that Flexera group company
and share personal information with that company, that company is the data
controller in relation to all personal information obtained, used and
otherwise processed in relation to such Services.

The expressions “Flexera,” “we” and “our” include Flexera Software LLC and
any other Flexera group company from whom you retain Services. For the
contact details of all Flexera group companies see:
https://www.flexera.com/about-us/contact-us/office-locations.

Any Services where a Flexera group company processes personal information
based on a data processing agreement entered with you or your employer (or
other similarly situated entity) are not covered by this privacy notice.
Transfers to subsequent third parties are covered by the service agreements
with our customers.

2. Global applicability and region-specific disclosures.

This privacy notice is designed to apply to our Website visitors, users of
our Services and other companies and users on a global basis. Therefore,
section A applies to any processing of personal information worldwide.

We may choose or be required by law to provide different or additional
disclosures relating to the processing of personal information about
residents of certain countries, regions or states. Please refer below for
disclosures that may be applicable to you:

Europe
The processing covered by the Europe-specific privacy disclosures contained
in section B include our processing of personal information (i) relating to
individuals in the European Union, the UK, Switzerland, Liechtenstein,
Norway and Iceland - all of which will, for the purpose of this privacy
notice, be defined as “Europe” - if we either offer goods or services to
such individuals or monitor their activities in Europe, or (ii) where the
processing is undertaken by or on behalf of a Flexera group company located
in Europe. Please click here for additional Europe-specific privacy
disclosures.

California
If you are a resident of the State of California in the United States,
please click here for additional California-specific privacy disclosures in
section C containing information about the processing of your personal
information and the rights granted to you by California law.

3. What is personal information?

When we use the term “personal information” in this privacy notice, we mean
information that identifies, relates to, describes, is capable of being
associated with or could reasonably be linked, directly or indirectly, to
you. It does not include aggregated information that is maintained in a
form that is not capable of being associated with or reasonably linked to
you.

4. What personal information do we collect?

In the context of rendering our Services, we may collect personal
information about you. This personal information regularly includes the
following:

* If you order any Service from us or ask for a quote (via our Websites or
via phone, email or letter): This in particular includes: Your name,
company name, company address, billing contact, billing address, company
email address, company phone number, job title, job function, industry,
price and Service information and customer ID. If you render services as
our customers, we may in particular also process the following personal
information: Log-in ID, password, employee ID, employment status,
manager, your corporate unit and cost center, account name, IP address,
computer and device information (such as MAC address, computer/device
name, host name, calculated user, hardware dongleID, UUID and FQDN). But
we also may process information we need to contact you or otherwise
communicate with you, information for order fulfilment and delivery of
requested materials or services as well as maintenance and training
associated with our Services, information to manage your account,
information to enable the download or usage of Services, information on
defects or erroneous Services, your feedback and complaints, quotes we
offer you and information for invoicing and payment follow-up.
* If you register on our Websites: Name, company name, company address,
company email address, company phone number, job title, job function,
industry and your interest(s) in Flexera and/or its Services.
* If you post on our blogs or forums: You also may provide information to
be published or displayed (hereinafter, "posted") on public areas of the
Websites, such as forums or blogs, for example, our community forum
(https://community.flexera.com/t5/Flexera-Community/ct-p/Flexera_Community)
(collectively, "User Contributions"). We may collect any of your User
Contributions, your username, your name, company name, company email
address as well as your IP address. Please note that we cannot control
the actions of other users of the Website with whom you may choose to
share your User Contributions. Therefore, we cannot and do not guarantee
that your User Contributions will not be viewed or processed by other
persons.
* If you contact us (via our Websites or via phone, email or letter), e.g.,
for a support request: Name, company name, company address, company email
address, company phone number and information on our communication with
you, your interest(s) in Flexera and/or its Services and any additional
information you provide us with.
* If you merely use our Websites: IP address, browser data, device type,
Uniform Resource Locators (URL), operating system, site preferences and
information on your usage of our Websites.
* If you participate in our events, such as webinars, and trade fair booth
events, or if you download our white papers: Name, company name, email
address, phone number, address, position/job title, job function, job
level and any information on the event or download.
* If you are in our email marketing campaigns: Name, company name, email
address, phone number, address, position/job title, job function,
information about whether you are already a customer, marketing campaign
information such as the newsletter option you have selected and your
reaction to our marketing and your interest in our products.

5. How do we collect your personal information?

The personal information is collected in many ways and may include:

* Personal information you provide to us. Most of the personal information
we receive comes to us voluntarily from our users in the course of using
our Services, communicating with us in the procurement of or in the
process of requesting our Services, registering to attend a seminar or
participate in a survey, interacting with us at trade shows or
conventions or other industry events or asking to be included in an email
or other communication list, or other product promotions.

You are free to choose which personal information you want to provide to
us or whether you want to provide us with any personal information at
all. However, some personal information, such as your name, address,
payment information and information on your requested Services may be
necessary for the performance of our contractual obligations. Without
providing this personal information, you will not be able to order
certain Services or enter into a contract with us.

* Personal information collected via technology. As you use our Services,
we may collect information automatically, such as log information and
through the use of cookies or other tracking technologies. Please see our
section “How do we use cookies and other Tracking Technology?” below for
more information.
* Personal information we receive from others. We may receive personal
information about users from publicly available databases or third
parties from whom we have purchased data, third parties such as social
media sites, law enforcement agencies, providers of denied party
screening and marketing consultants and partners. We may also receive
personal information, such as contact details, including name, position,
phone or email address from our partners and customers.

6. Why we collect and use your personal information?

The reasons for using your personal information may differ depending on the
purpose of the collection. Regularly, we use your personal information for
the following purposes:

* Providing our Services. If you order Services from Flexera or if you
contact us to request our Services, we use your personal information to
provide you with these Services.
* Pursue our business interests. The usage of your personal information may
also be necessary for our own business interests. For example, we may use
some of your personal information to evaluate and review our business
performance, create financial statements, improve our Services, provide
advertising or to identify potential cyber security threats. We may use
your personal information for marketing purposes, for example, to send
you relevant product updates and/or share your contact information such
as name, email address or phone number with reseller partners for them to
directly contact, qualify and manage the customer relationship. In the
case that a reseller partner uses your contact details for own marketing
purposes, we or the reseller will do so only if you have granted a
respective separate consent. If necessary, we may also use your personal
information to pursue or defend ourselves against legal claims.
* Purpose for which consent has been provided. In some cases, we may ask
you to grant us separate consent to use your personal information.

We often work on the basis of consent in relation to sales and marketing
campaigns. For example, if you sign up to our email newsletter, you allow
us to send marketing communication to you, or when our marketing partners
provide us with your email address, we will process your data to the
extent covered by your consent. If you want to learn about your options
regarding withdrawing your consent to receive marketing communication,
please see our section “E-Mail Settings and Preferences.” If you want to
learn more about your options to avoid Tracking Technology, please see
our section “How do we use cookies and other Tracking Technology?”.

If you have granted us consent to use your information, we will use it
only for the purposes for which you have granted your consent. You are
free to deny your consent and the denial will have no negative
consequences for you. You are also free to withdraw your consent at any
time with effect for the future.

* Comply with legal obligations. We are obligated to retain certain
information because of legal requirements, for example, tax or commercial
laws, or we may be required by law enforcement to provide personal
information on request.

7. With whom do we share your personal information?

As required in accordance with how we use it, we will share your personal
information with the following third parties:

* Flexera group companies. To support our sales and marketing efforts, as
well as in the performance of the Services, your personal information may
be disclosed to Flexera group companies. Further information regarding
the Flexera group companies can be obtained here.
* Service providers and advisors. We may use third party vendors and other
service providers to perform services on our behalf. Such services may
include marketing campaign services, providing mailing or email services,
tax and accounting services, product fulfilment, payment processing,
conducting surveys or contests, performing customer service, performing
data enhancement services, performing fraud prevention services,
performing web hosting services or providing analytic services. These
third parties, whose services Flexera Software LLC regularly uses
include, in particular: Eloqua, SalesForce.com, Lithium, Gainsight,
Melissa Data and Snowflake. Any such service providers will by
appropriate data processing agreements be bound to only process the data
on Flexera’s behalf and under its instructions, unless such service
providers act as their own controllers (e.g., in the case we seek advice
from lawyers and tax consultants).
* Promotional partners. Third parties with whom we partner to provide
promotional activities, which will be identified by name in the context
of these activities. We may, for example, share contact details with
reseller partners.
* Purchasers and third parties in connection with a business transaction.
Third parties in connection with a Flexera-related transaction, such as a
merger, sale of Flexera assets or shares, reorganization, financing,
change of control or acquisition of all or a portion of our business, or
in the event of a bankruptcy or similar proceedings.
* Law enforcement, regulators, and other parties for legal reasons. Third
parties as required by law or subpoena or if we reasonably believe that
such action is necessary to (a) comply with the law and the reasonable
requests of law enforcement; (b) to enforce our legal claims or to
protect the security or integrity of our Services; and/or (c) to exercise
or protect the rights, property or personal safety of Flexera employees,
our visitors or others.
* The public, when posted in certain public spaces. Remember, our Websites
allow you to connect and interact with others. Your profile information
or information that you post in a forum or on a blog, including personal
information, will be available publicly to other members of the Websites
by default when you create a profile, post in a blog or forum or interact
with others on the Websites in public groups and post content to public
spaces.
* Otherwise with consent. We may disclose an individual’s personal
information to certain other third parties with that individual’s
consent.

8. How do we safeguard your personal information when there is an
international transfer?

As Flexera Software LLC is located in the USA, any information you provide
will be processed and stored in the USA.

Furthermore, some other Flexera group companies who may process your
personal information depending on the Services you are using are also
located outside Europe. Our Flexera group companies are, for example,
located in Japan, Australia, India, and China. Further information
regarding the Flexera group companies can be obtained here.

This may mean that your personal information will be stored in a
jurisdiction that offers a level of protection that may, in certain
instances, be less protective of your personal information than the
jurisdiction you are typically a resident in.

Further Europe-specific information regarding the safeguards we have in
place can be obtained here.

9. How do we use cookies and other Tracking Technology?

When using our Services, we and our third-party partners may automatically
collect certain types of usage information. For this purpose, we often rely
on tracking technologies, including cookies, web beacons, embedded scripts
and similar technology (collectively, “Tracking Technologies”) in
accordance with this notice. Where legally required, we will inform you
about the use of such tracking technologies using so-called cookie-banners
and/or obtain your consent to use such Tracking Technology.

* How do these Tracking Technologies work? Cookies are pieces of code that
allow for personalization of the Services experience by saving your
personal information such as user ID and other preferences. A cookie is a
small data file that we transfer to your device's hard disk (such as your
computer or smartphone) for record-keeping purposes. Cookies store
certain settings and data for exchange with our system via your browser.
A cookie usually contains the name of the domain from which the cookie
has been placed, as well as information about the age of the cookie and a
random alphanumeric identifier, the so-called cookie-ID. They help to
recognize the device and make any pre-settings immediately available. Web
beacons are small graphical images that may be included on our Sites and
typically work in conjunction with cookies to identify our users and user
behaviour. An embedded script is programming code that is designed to
collect information about your interactions with the Site, such as the
links you click on. The code is temporarily downloaded onto your computer
or device from our web server or a third-party service provider, is
active only while you are connected to the Site and is deactivated or
deleted thereafter. Flash cookies are pieces of data that websites which
use Adobe Flash may store on a user's computer or device. Third parties
with whom we partner to provide certain features on our Sites or to
display advertising based upon your web browsing activity often use flash
cookies.
* What information do these Tracking Technologies collect? These tracking
technologies collect information about your browser and online usage
patterns (e.g., IP address, pages you view, the links you click and other
actions you take on the Services such as opening an email, log files,
browser type, browser language, referring/exit pages and URLs, etc.), and
information about the device(s) you use to access the Services (e.g.,
unique identification numbers associated with your device or our mobile
application (including, for example, a UDID, Unique ID for Advertisers
(IDFA), Google AdID or Windows Advertising ID), device type, model and
manufacturer, operating system brand and model and, depending on your
mobile device settings, your geographical location data). We, or our
third party partners, may link your various devices so that content you
see on one device can result in relevant advertising and content
displayed on another device so that we may recognize and contact you on
the various devices you may use.
* What are Cookies and other Tracking Technologies used for? Tracking
Technologies do lots of different jobs, like helping us understand how
our Websites are being used, helping us analyse trends, administering the
Websites, tracking users’ movements around the Websites, gathering
demographic information about our user base as a whole, letting you
navigate between pages efficiently, remembering your preferences and
generally improving your browsing experience. Tracking Technology can
also help ensure that you see marketing content that is more relevant to
you and your interests. Therefore, generally speaking, we use the data
collected through tracking technologies to: (a) remember information so
that you will not have to re-enter it during your visit or the next time
you visit the Website(s); (b) provide custom, personalized content and
information, including targeted content and advertising; (c) recognize
and contact you across multiple devices; (d) provide and monitor the
effectiveness of our Services; (e) monitor aggregate metrics such as
total number of visitors, traffic, usage and demographic patterns on our
Websites; (f) diagnose or fix technology problems; and (g) otherwise plan
for and enhance our Services.
* What types of cookies are used by Flexera? The types of cookies used on
our site can generally be put into one of the following categories:
Necessary; functional and advertising. You can find out more about each
of the cookie categories in the table below.
* Necessary Cookies. These cookies are essential to make our Websites
work. They enable you to move around the Websites and use their
features. Without these cookies, services that are necessary for you to
fully use our Websites may not be available, such as accessing certain
areas of the Websites.
* Functional Cookies. These cookies allow us to recognize you and tailor
our Websites to provide enhanced features and content to you. For
example, these cookies can be used to remember your IP address,
language choice, country selection and requested Services.
* Advertising Cookies. These cookies are used to deliver advertisements
that are more relevant to you and your interests. They are also used to
limit the number of times you see an advertisement as well as help
measure the effectiveness of the advertising campaign. They remember
that you have visited a website and may track you on other websites.
This information may be shared with other organizations such as
advertising partners.
* How long will cookies stay on your browsing device? The length of time a
cookie will stay on your browsing device depends on whether it is a
"persistent" or "session" cookie. Session cookies will only stay on your
device until you stop browsing the website that has set the cookie.
Persistent cookies stay on your browsing device after you have finished
browsing a particular website, until they are deleted or until they
expire. The actual period of validity of each persistent cookie depends
on each cookie. However, they generally expire within 3 months. You can
amend your cookie settings using your internet browser’s settings.
* Cookies by third parties. Some cookies belong to us, and we place them on
your device. Other cookies are placed on your browsing device by third
parties when you visit our Websites. Third parties setting cookies from
our Websites will be providing a service to us or a function of the
website, but we do not always control how third-party cookies are used.
Some third parties may use advertising cookies to help gather information
about your browsing activity so that they can deliver website advertising
to you that is relevant to your interests. You should check the third
party's website for more information about how they use cookies. The
third-party tracking technologies on our Websites include Adobe Audience
Manager, Adobe Test & Target, Google AdWords, Twitter Advertising,
LinkedIn Marketing Solutions, Eloqua, Facebook Customer Audience, Google
Analytics, LinkedIn Analytics, Visual Website Optimizer, Kenshoo and
Demandbase. You can, for example, also download the Ghostery browser
extension to find out the most current tracking technologies running on
our Websites.
* Interest-based advertising. We participate in interest-based advertising
and use third party advertising companies to serve you targeted
advertisements based on your online browsing history and your interests.
To do this, we or our advertising partners may collect information about
how you use or connect to our Services, or the types of other websites,
social media services, content and ads that you (or others using your
device) visit or view or connect to our Services. Typically, this
information is collected through cookies and similar tracking
technologies. Where legally required, we will obtain your consent.

If you only want to limit third-party advertising cookies, you can turn
such cookies off by visiting the following links (please bear in mind
that there are many more companies listed on these sites than those that
drop cookies via our website):

* Your Online Choices (http://www.youronlinechoices.com/)
* Network Advertising Initiative (http://www.networkadvertising.org/)
* Digital Advertising Alliance (http://www.aboutads.info/consumers)

To manage the Tracking Technologies, you may also follow the steps as
described below:

* How can you manage cookies from our Websites? The cookies we use are
designed to help you get the most from our Services, but if you do not
wish to receive cookies, most browsers allow you to: (i) change your
browser settings to notify you when you receive a cookie, which lets you
choose whether or not to accept it; (ii) disable existing cookies; or
(iii) set your browser to automatically reject cookies. You can also
avoid Tracking Technology by not consenting to the use of Tracking
Technology when asked for consent in cookie banners. Please check your
browser and browser settings to determine where cookies are stored and
whether and how they may be deleted. The help portion of the toolbar on
most browsers will tell you how to prevent your browser from accepting
new cookies, how to have the browser notify you when you receive a new
cookie or how to disable most cookies altogether. Depending on your
mobile device and operating system, you may not be able to delete or
block all Tracking Technologies. Please note that in the case you delete
existing cookies, your chosen pre-settings will be deleted as well. This
means that the next time you access our website, we may ask for your
consent again (to the extent required by law) and set new cookies. The
period of validity of those cookies will then start from the beginning.
You may also set your email options to prevent the automatic downloading
of images that may contain technologies that would allow us to know
whether you have accessed our email and performed certain functions with
it. In order to understand these settings, the following links may be
helpful, otherwise you should use the "Help" option in your browser for
more details.

Cookie settings in Internet Explorer

Cookie settings in Firefox

Cookie settings in Chrome

Cookie settings in Safari

Please note that if you choose to refuse cookies, you may not be able to
use the full functionality of the Services.

* How to withdraw consent for showing targeted ads on third-party websites
and for our use of Tracking Technology. To the extent we rely on your
consent to provide you with targeted advertising on third-party websites
and the use of Tracking Technology, you may withdraw such consent at any
time with effect for the future by contacting us using the contact
details set out at the end of this section A. Depending on the setting
options and the scope of your consent withdrawal, you may still receive
generic ads.
* Google Analytics. We use Google Analytics and have implemented the
following Google Advertising Feature: Google AdWords Conversion. Google
uses cookies to help the website analyze how users use the site. The
information generated by the cookie about your use of the website will
generally be transmitted to and stored by Google on servers in the United
States. However, if IP anonymization is activated on this website, your
IP address will be shortened by Google in advance within if data is
collected from within the Member States of the European Union and in the
European Economic Area. Only in exceptional cases is the full IP address
transmitted to a Google server in the USA and shortened there. We use
Google Analytics to recognize you and link the devices you use when you
visit our Websites on your browser or mobile device, login to your
account on our Websites, or otherwise engage with us. Google Analytics
allows us to better understand how our users interact with our Services
and to tailor our advertisements and content to you. For information on
how Google Analytics collects and processes data, as well as how you can
control information sent to Google, review Google's site "How Google uses
data when you use our partners' sites or apps" located at
www.google.com/policies/privacy/partners/. You can learn about Google
Analytics' currently available opt outs, including the Google Analytics
Browser Add-On here: https://tools.google.com/dlpage/gaoptout/.
* We use Demandbase to help us provide you with targeted ads on the basis
of cookies and online search behaviour. If you do not wish to receive
such ads, you can use the means set out above and also choose to withdraw
your consent (if provided before) or opt-out by using the means provided
here.

10. Social media.

Our Websites include links to social media sites, such as Facebook,
LinkedIn, Twitter, Instagram and YouTube. These social sites are hosted by
a third party, and your interactions with these features are governed by
the privacy notice of the company providing it.

11. Links to other Websites and services.

The Services may contain links to and from third-party websites of our
business partners, advertisers and social media sites, and our users may
post links to third-party websites. If you follow a link to any of these
websites, please note that these websites have their own privacy policies
and that we do not accept any responsibility or liability for their
policies. We strongly recommend that you read their privacy policies and
terms and conditions of use to understand how they collect, use, share and
otherwise process personal information. We are not responsible for the
privacy practices or the content on the websites of third-party sites.

12. How do we protect your personal information?

We implement a variety of security measures designed to maintain the safety
of your personal information when you use our Services.

However, no security system is impenetrable, and we cannot guarantee the
security of our systems 100%. In the event that any personal information
under our control is compromised as a result of a breach of security, we
will take reasonable steps to investigate the situation and, where
appropriate, notify those individuals whose personal information may have
been compromised, such notification will be made having regard to the
nature of the personal information involved and may include email
communications, written correspondence, or public statements and take other
steps in accordance with any applicable laws and regulations, such as
notify competent data protection authorities.

13. Children’s privacy.

We do not knowingly collect or solicit any personal information from anyone
under the age of 16 on or through the Services. In the event that we learn
that we have inadvertently collected personal information from a child
under age 16, we will delete that information as quickly as possible. If
you believe that we might have any information from a child under 16,
please contact us by using the contact details set out at the end of this
section A.

For Europe-specific information on children’s privacy, please our section
“Additional information on children’s privacy”.

For California-specific information on children’s privacy, please see our
section “Additional California-specific information on children’s privacy”.

14. What rights and choices do you have?

We want you to understand your rights and choices regarding how we may use
your personal information. Depending on how we use your personal
information, these rights and choices may include the following:

* Access, correction and deletion. Upon request, Flexera will provide you
with information about whether we hold any of your personal information.
You may access, correct, or request deletion of your personal information
by contacting us at marketingops@flexera.com. We will respond to your
request within a reasonable timeframe.
* Cookies Settings and Preferences. You may disable cookies and other
tracking technologies through the settings in your browser. In the case
you have provided consent to use marketing cookies and similar Tracking
Technology or would like to learn more about how to avoid Tracking
Technology, please see our section “How do we use cookies and other
Tracking Technology?”.
* E-Mail Settings and Preferences. If you have consented to receiving
marketing communication (e.g., by signing up for our newsletters), you
may easily withdraw your consent at any time with effect for the future.
You can also opt out from receiving marketing emails if we do not rely on
consent. You can withdraw your consent or opt out from receiving
marketing communication via or by using the link provided to you at the
end of each promotional communication. You may also contact us using the
contact details set out at the end of this section A to request that we
remove you from our email list.
https://info.flexera.com/Manage-Preferences.
* Deny or Withdraw of Consent. We may work on the basis of consent, in
particular in relation to sales and marketing campaigns. For example, if
you sign up to our email newsletter, you allow us to send marketing
communication to you, or when our marketing partners provide us with your
email address, we will process your data to the extent covered by your
consent. If you have granted us consent to use your personal information,
we will use it only for the purposes for which you have granted your
consent. You are free to deny your consent and the denial will have no
negative consequences for you. You are also free to withdraw your consent
at any time with effect for the future without negative consequences for
you. However, we will not / no longer be able to provide you with the
Services to which this consent relates. If you want to learn about your
options regarding withdrawing your consent to receive marketing
communication specifically, please see our section “E-Mail Settings and
Preferences” above. If you want to learn more about your options to avoid
Tracking Technology, please see our section “How do we use cookies and
other Tracking Technology?”
* Europe-specific rights. For further Europe-specific rights, please see
our section “Additional Europe specific disclosures.”
* California-specific rights. For further California-specific rights,
please see our section “Additional CCPA specific disclosures.”

15. Online privacy notice updates.

We may make changes to our privacy notice from time to time and will update
the “last updated” date at the beginning of this privacy notice. Please
review our policies regularly, as updated policies will apply to your
future use of our Services. To the extent that we have your contact
information, we will notify you of any material changes to our privacy
notice.

16. How to contact us?

If you have any questions or concerns about our privacy notice or if you
want to exercise your rights, please send an email to
DataProtectionTeam@flexera.com or write to us at:

Flexera Software LLC, 300 Park Boulevard, Suite 500, Itasca, IL 60143, USA

You may also contact the EU representative of all non-EU Flexera group
companies, which is Flexera Software GmbH, at
DataProtectionTeam@flexera.com or Paul-Dessau-Straße 8, 22761 Hamburg,
Germany.

For the individuals and supervisory authorities in the UK, the UK
representative of all non-EU Flexera group companies is Flexera Software
Ltd. Level 3, 401 Faraday Street Birchwood Park, Birchwood Warrington,
Cheshire WA3 6GA, United Kingdom. The UK representative may be contacted at
DataProtectionTeam@flexera.com.

If you obtain Services from one of our Flexera entities, you may of course
address any privacy related question to the Flexera entity that has
concluded a contract with you.

While the main contact information above is favored and would be happy to
respond to all queries for all entities within the Flexera family, you can
obtain contact information on each Flexera group company here.

17. Data Compliance Team.

For all enquiries regarding Flexera’s data processing activities, you may
also want to contact our Data Compliance Team, who can be reached at
DataProtectionTeam@flexera.com.

B. ADDITIONAL EUROPE-SPECIFIC DISCLOSURES

18. Scope of the disclosure.

These Additional Europe-specific disclosures supplement the information
contained in our privacy notice above to comply with the requirements under
applicable data protection law in Europe, in particular the General Data
Protection Regulation (“GDPR”). Unlike the generally applicable section A.
of this privacy notice, these Additional Europe-specific disclosures apply
only to our processing of personal information where the processing of
personal information relates to individuals in Europe -–where we either
offer goods or services to such individuals or monitor their activities in
Europe or where the processing is undertaken by or on behalf of a Flexera
company or branch established in Europe.

19. Information on data processing rendered by us on behalf of customers.

The use of personal information provided to us as a data processor by our
customers for the purpose of processing on their behalf shall be limited to
the purpose of providing the Service for which the customer has engaged
Flexera (data processing on behalf of customer).

Flexera acknowledges that you have the right to access your personal
information. Flexera has no direct relationship with the individuals whose
personal information it processes on behalf of its customers. An individual
who seeks access or who seeks to correct, amend or delete inaccurate data
should direct their query to Flexera’s customer (the data controller). If
requested to remove data we are processing for our customer, we will
respond within a reasonable timeframe. We may transfer personal information
to companies that help us provide our Services. Transfers to subsequent
third parties are covered by the service agreements with our customers.

20. Legal basis based on which we collect and use your personal information.

Regularly, we use your personal information based on the following legal
grounds according to the GDPR and the Data Protection Act 2018:

* Perform of our contractual services or prior to entering into a contract
with you. If you order Services from Flexera or if you contact us to
request our Services, we use your personal information to provide you
with these Services.
* Justified by our legitimate interests. The usage of your personal
information may also be necessary for our own business interests. For
example, we may use some of your personal information to evaluate and
review our business performance, create financial statements, improve our
Services, provide advertising or to identify potential cyber security
threats. We may use your personal information for marketing purposes, for
example, to send you relevant product updates and/or share your contact
information such as name, email address or phone number with reseller
partners for them to directly contact, qualify and manage the customer
relationship. To the extent we rely on legitimate interests to process
your data for marketing purposes (for example, in the case that you have
provided your email address in connection with the purchase of our
services), you may object to such processing at any time via
https://info.flexera.com/Manage-Preferences or by using the link provided
to you at the end of each promotional communication. You may also contact
us using the contact details set out at the end of section A to request
that we remove you from our email list. If necessary, we may also use
your personal information to pursue or defend ourselves against legal
claims.
* Consent In some cases, we may ask you to grant us separate consent to use
your personal information. Please see “What rights and choices do you
have?” regarding the choices and rights you have in this respect.

* Compliance with legal obligations. We are obligated to retain certain
personal information because of legal requirements, for example, tax or
commercial laws, or we may be required by law enforcement to provide
personal information on request.

We do not use your personal information for automated individual
decision-making.

21. Additional information on international data transfers.

We may transfer personal information about you outside Europe and when we
do so, we rely on appropriate or suitable safeguards recognized under
applicable law in Europe, including adequacy decisions, Standard
Contractual Clauses that have been adopted by the European Commission and
provide appropriate guarantees for the transfer of personal information.

* Flexera-internal transfers.

As regards the sharing of personal information with Flexera group
companies located outside Europe, Flexera has entered into data transfer
agreements based on the Standard Contractual Clauses issued by the
European Commission. The data transfer agreements between the Flexera
group entities also make use of the Standard Contractual Clauses issued
by the European Commission for data transfers to Flexera group entities
located in the US, the UK or any other country in which we have
subsidiaries for as long as these countries are not acknowledged by the
European Commission or Switzerland as providing for an adequate level of
data protection. If you would like to obtain further information, please
contact us using the contact details set out at the end of section A.

* External transfers.

We may transfer personal information about you to countries that the
European Commission has deemed to adequately safeguard personal
information. We may also use Standard Contractual Clauses when transferring
personal information from a country in Europe to a country outside Europe
that has not been deemed to adequately safeguard personal information. The
same applies to data transfers from the European Economic Area or
Switzerland to the UK as well as data transfers from the UK to other
countries that are not recognized by the UK to adequately safeguard
personal information. If you would like to obtain further information,
please contact us using the contact details set out at the end of section
A.

22. How long do we keep your personal information?

We will store personal information for as long as necessary to fulfil the
purposes for which we collect the personal information, and in accordance
with our legal obligations and legitimate business interests. Personal
information collected in connection with the Websites by Eloqua that offers
marketing services will be identified for manual removal after 18 months of
no interaction between the data subject and Flexera. Additionally, personal
information processed by Flexera as a data processor will be removed in
accordance with the instructions of the applicable data controller.

If you signed up for our promotional emails, we will delete the respective
personal information if you unsubscribe from receiving our promotional
emails. However, we will store your email address in a ‘do not contact’
list to ensure that you will not receive any further communication.

23. Additional Europe-specific information on children’s privacy.

From children under the age of 16 residing in Europe, we will not process
any personal information on the ground of a consent.

24. Europe-specific rights.

Subject to the applicable law in your jurisdiction, you have the following
rights in respect to your personal information that we hold:

* Right of access. The right to obtain access to your personal information.
* Right to rectification. The right to obtain rectification of your
personal information without undue delay where that personal information
is inaccurate or incomplete.
* Right to erasure. The right to obtain the erasure of your personal
information without undue delay in certain circumstances, such as where
the personal information is no longer necessary in relation to the
purposes for which it was collected or processed.
* Right to restriction. The right to obtain restriction of the processing
undertaken by us on your personal information in certain circumstances,
such as, where the accuracy of the personal information is contested by
you, for a period of time enabling us to verify the accuracy of that
personal information.
* Right to portability. The right to portability allows you to move, copy
or transfer personal information easily from one organization to another.
* Right to object. You have a right to object to any processing based on
our legitimate interests where there are grounds relating to your
particular situation. You can object to marketing activities for any
reason whatsoever.

If you wish to exercise one of these rights, please contact us by using the
contact details set out at the end of section A.

In addition to the foregoing listed rights, you also have the right to
lodge a complaint with your local data protection authority. However, we
encourage you to first reach out to us by using the contact set out at the
end of section A so that you have an opportunity to address your concerns
directly and find a solution together before you do lodge a complaint.

C. ADDITIONAL CALIFORNIA-SPECIFIC DISCLOSURES

25. Scope of notice.

These Additional California specific disclosures (the “CA Notice”)
supplements the information contained in the privacy notice above and
applies solely to individual residents of the State of California
(“consumers” or “you”).

This CA Notice provides additional information about how we collect, use,
disclose and otherwise process personal information of individual residents
of the State of California, either online or offline, within the scope of
the California Consumer Privacy Act of 2018 (“CCPA”).

Unless otherwise expressly stated, all terms in this CA Notice have the
same meaning as defined in our privacy notice above or as otherwise defined
in the CCPA.

26. General remarks on personal information disclosures.

When we use the term “personal information” in this CA Notice, we mean
information that identifies, relates to, describes, is reasonably capable
of being associated with or could reasonably be linked, directly or
indirectly, with a particular consumer or household.

For the purposes of this CA Notice, the term personal information does not
include:

* Publicly available information from government records.
* De-identified or aggregated information that is maintained in a form that
is not capable of being associated with or linked to you.
* Information excluded from the CCPA's scope, such as:
* Information reflecting a communication or a transaction between us and
a representative of another legal entity in the context of conducting
due diligence regarding, or providing or receiving, a product or
service to or from that legal entity.
* Information covered by certain sector-specific privacy laws, including
the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA)
or California Financial Information Privacy Act (FIPA), and the
Driver's Privacy Protection Act of 1994.
* Information relating to our job applicants, employees, contractors and
other personnel.

27. Information on data processing rendered by us on behalf of customers.

Where a Flexera group company processes personal information based on a
data processing agreement entered with you or your employer (or other
similarly situated entity), the respective Flexera group company is not the
“business” that determines the purposes and means of the processing of
consumers’ personal information, but a “service provider” within the
meaning of the CCPA.

The use of personal information provided to us as a service provider by our
customers for the purpose of processing on their behalf shall be limited to
the purpose of providing the Service for which the customer has engaged
Flexera (data processing on behalf of customer).

Flexera acknowledges that you have the right to access your personal
information. Flexera has no direct relationship with the individuals whose
personal information it processes on behalf of its customers. An individual
who seeks access, or who seeks to correct, amend, or delete inaccurate data
should direct their query to Flexera’s customer (the business). If
requested by our customer to remove data we are processing on their behalf
and at their direction, we will respond within a reasonable timeframe. We
may transfer personal information to companies that help us provide our
Services. Transfers to subsequent third parties are covered by the service
agreements with our customers.

28. Collection and use of personal information.

In the last 12 months, we have collected the following categories of
personal information from the following sources of personal information for
the following purposes, which reference the personal information, sources
and purposes described in the “What personal information do we collect?”
and “How do we collect your information” section of our privacy notice:

Category of Personal Information Collected Commercial or Business Purpose
Categories of Sources

Identifiers, including your name, email address, phone number, postal
address, username and password

* Monitor and run the use of services
* For customer service purposes
* For quality assurance purposes
* For regulatory compliance purposes
* For collecting feedback
* Personalization purposes
* For marketing purposes
* Product and services improvement
* For contests and sweepstakes
* For market research purposes

* Directly from you
* Your browser or device
* Our business partners and affiliates
* Third parties you direct to share information with us
* Push notification providers
* Customer service platforms

Internet/Network Information, such as IP address, device and browser
information, clickstream data, log data and analytics data

* To monitor and run the services
* Understanding consumer behavior
* Addressing software issues
* Personalization purposes
* Product and services improvement

* Directly from you
* Your browser or device

Geolocation Data, such as your general geographic location or more precise
location when permitted by law

* To generate recommendations for users
* Monitor the use of products
* Personalization purposes

* Directly from you
* Your browser or device

Other Personal Information, such as personal information you provide us in
relation to a question, request or inquiry, or information you post on our
social media pages or otherwise provide to us

* Monitor and run the use of services
* For market research purposes

* Directly from you
* Your browser or device
* Third parties you direct to share information from us

Inferences, including predictions about your interests and preferences.

* To generate recommendations for users
* Monitor the use of services
* Monitor habit formation
* For engagement analytics
* Personalization purposes
* For market research purposes

* Directly from you
* Your browser or device
* Information generated or derived from your purchases, online browsing
and usage activity

29. Disclosure and sale of personal information.

As described in the “With whom do we share your personal information?”
section in our privacy notice, we have disclosed personal information
within Flexera and with a variety of third parties for business purposes.

In the previous 12 months, we have disclosed the following categories of
personal information to third parties for a business purpose:

* All of the categories of personal information we collect, explained in
the table above.

*Note about “Sales”: Flexera does not “sell” personal information as most
people would typically understand that term. However, we do allow certain
third-party advertising partners to collect information about consumers
through our Services for purposes of serving ads that are more relevant,
for ad campaign measurement and analytics and for ad fraud detection and
reporting. To the extent these practices qualify as “sales” under the CCPA,
you may have the right to opt out as described in the “California-specific
rights” section below.

30. California-specific rights.

As a California resident, you may be able to exercise the following rights
in relation to the personal information about you that we have collected
(subject to certain limitations at law):

* Right of access. The right to access and obtain a copy of the personal
information we have collected about you in the last 12 months.
* Right to knowledge: The right to request the following information from
the last 12 months relating to the personal information we have collected
about you:
* The categories and specific pieces of personal information we have
collected about you;
* The categories of sources of the personal information;
* The purposes for collecting the personal information;
* The categories of third parties with whom we share the personal
information; and
* The categories of personal information we have disclosed for a business
purpose and the categories of recipients.
* Right to deletion. The right to request the deletion or erasure of
personal information we have collected about you.
* Right to opt out. The right to direct us not to sell personal information
we have collected about you to third parties now or in the future.
* Right to opt in. If you are under the age of 16: The right to authorize
us, or have your parent or guardian authorize us, to sell personal
information about you.
* Non-discrimination. The right to be free from discrimination for
exercising any of the rights described above. Please note, however, that
if the exercise of the rights described above limits our ability to
process personal information (such as in the case of a deletion request),
we may not be able to provide our services and offerings to individuals
who exercise these rights, or to otherwise engage with such individuals
going forward.

31. How to exercise your California-specific rights.
* To exercise your right to know or right to deletion. To exercise your
right to know and/or right to deletion, please submit a request by:
* Emailing DataProtectionTeam@Flexera.com with the subject line
“California Rights Request,”; or
* Filling out our California Resident Rights Request Form.

Before processing your request, we will need to verify your identity and
confirm you are a resident of the State of California. In order to verify
your identity, we will generally require you to (1) log into your account
if you have one, or (2) require you to provide sufficient information to
enable us to identify the information we maintain about you in our
systems. This process may require us to request additional personal
information from you, including, but not limited to your name, email,
address, and/or date of last interaction with customer service. We will
only use personal information provided in connection with a Consumer
Rights Request to review and comply with the request.

In certain circumstances, we may decline a request to exercise the rights
described above, particularly where we are unable to verify your identity
or locate your personal information in our systems. If we are unable to
comply with all or a portion of your request, we will explain the reasons
for declining to comply with the request.

Authorized Agents

In certain circumstances, you are permitted to use an authorized agent
(as that term is defined by the CCPA) to submit requests on your behalf
through the designated methods set forth in this CA Notice where we can
verify the authorized agent’s authority to act on your behalf by:

* For requests to know or delete personal information:
* receiving a power of attorney valid under the laws of California from
you or your authorized agent; or
* receiving sufficient evidence to show that you have:
* provided the authorized agent signed permission to act on your
behalf;
* verified your own identity directly with us pursuant to the
instructions set forth in these Disclosures; and
* directly confirmed with us that you provided the authorized agent
permission to submit the request on your behalf.
* For requests to opt-out of personal information “sales”: receiving a
signed permission demonstrating your authorized agent has been
authorized by you to act on your behalf.
* To exercise your right to opt out of personal information sales

As noted above, we do not “sell” personal information as most people
would typically understand that term. However, as is common practice
among companies that operate online, we permit third party advertising
networks, social media companies and other third party businesses to
collect and disclose your personal information (including
Internet/Network Information, Commercial Information, and Inferences)
directly from your browser or device through cookies or tracking
technologies when you visit or interact with our websites or engage with
us online. These third parties use this information for the purposes of
serving ads that are more relevant, for ad campaign measurement and
analytics, and for fraud detection and reporting and they may sell that
information to other businesses for advertising and other purposes. By
visiting www.privacyrights.info or https://optout.privacyrights.info/,
you can opt out from sales of this type of personal information by
businesses that participate in the opt out tool. To make opt-out requests
related to mobile apps on your device for businesses participating in the
DAA’s CCPA App-based Opt-Out Tool, you can download the appropriate app
at www.youradchoices.com/appchoices. To learn more about how third
parties collect information automatically and the choices you may have in
relation to those activities, please see “How can you manage cookies from
our Websites?” and “Interest-based advertising” in the “How do we use
cookies and other Tracking Technology?” section of our privacy notice.

32. Minors under age 16.

We do not sell the personal information of consumers we know to be less
than 16 years of age, unless we receive affirmative authorization (the
"Right to Opt In") from either the minor who is between 13 and 16 years of
age or the parent or guardian of a minor less than 13 years of age. Please
contact us at DataProtectionTeam@Flexera.com to inform us if you or your
minor child are under the age of 16.

33. Additional information.

Updates to This CA Notice
We will update this CA Notice from time to time. When we make changes to
this CA Notice, we will change the "Last Updated" date at the beginning of
this CA Notice. All changes shall be effective from the date of publication
unless otherwise provided in the notification.

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