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DOCEBO – PRIVACY POLICY


 * Privacy Policy
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Effective Date: 23/01/2024

WHAT THIS POLICY COVERS

This Privacy Policy covers the personal data we collect about you when you use
products, apps, services or websites provided by Us (“Services”) that links to
this document, or when you interact with us through a different channel (e.g.
Docebo investor relations portal), unless a different policy is displayed.

A reference to “Docebo”, “We” and “Us” means Docebo S.p.A. and/or any of its
other corporate affiliates, listed below in the “Contact us” section.

This Privacy Policy explains how Docebo collects and uses your personal data and
the choices and rights available to you about the collection and use of your
information, including how to update and correct your personal data.

Please read it carefully and if you do not want your information processed in
accordance with this Privacy Policy, do not use our Services or interact with
Us.

This Policy does not apply:

1. when We process personal data collected about you for our Docebo customers

In certain circumstances, We process your personal data as a data processor,
which means on behalf of our customers (for example, where Docebo provides
Services to an organisation, a company or academic institution). In these cases,
it is the Docebo customer that is responsible for the processing of your
personal data.

Docebo data protection practices will be regulated by the terms of a data
protection agreement entered with the customer.

If you have questions or concerns about how your personal data is handled in
these circumstances, including how to exercise your rights, you should contact
the customer that has control over your account (e.g. your employer or account
administrator) and refer to their separate privacy policies.

2. to third-party sites or integrations not controlled by Docebo

From time to time, We may include links on the Sites to third-party websites, or
be able to integrate Docebo services with third-party integrations. In these
cases, your personal data will be transmitted or otherwise made available,
automatically (e.g. through API) or otherwise, to third parties. Please be aware
that we do not control, monitor or are responsible for such websites, their web
content while you are visiting their websites, and the processing of your
personal data required by the third-party to use this integration. In these
cases, We encourage you to review their privacy policies.

WHAT INFORMATION WE COLLECT ABOUT YOU:

In this Policy any reference to ‘personal data’ or ‘personal information’ is
intended as any information that can identify or relate to you as individual
person. We collect the following personal information from you as further
described below:

1. Information provided voluntarily by you

● Contact information, such as name, business email address, phone number, your
photo, billing information, physical address, user ID, call recordings, login
credentials, information or documents you input in open text fields in
help/contact us forms, in the survey received or through our whistleblowing
portal. By using our Services, you might choose to add a display name, profile
photo, job title, and other details to your profile.

● Content information, such the information you may choose to post, send,
receive and share in our Services. Examples of Content information include the
content viewed in the Services, training interactions, the files and links you
upload and the aggregate insights obtained from this information.

● Customer Support information, such a summary of the problem you are
experiencing, and any other documentation or information that would be helpful
in resolving an issue submitted to Us.

● Sensitive information, such your dietary needs or your health information.

We do not collect your payment information, such as your credit card or your
Paypal account, but we ask our payment providers to manage this information on
our behalf.

Photos and videos during our events

During our events, We usually take photos and videos that might include you and
other attendees, speakers, or exhibitors to promote Docebo and our events. Such
photos and videos may be used on our websites, promotional materials or press
releases. This is voluntary, so please contact Us if you do not wish to appear
in any images captured or recordings.

2. Information We collect automatically from you

● Analytics information, such as when you visit and interact with any of our
Services. This information includes the features you use; configuration data (ie
the links you click on; the type, size and filenames of attachments you upload
to the Services; frequently used search terms); diagnostic information and your
interaction with third-party integrations and others on the Services.

● Device information, including your connection type and settings, information
about your operating system, browser type, IP address, URLs of referring/exit
pages, online identifiers, device identifiers, and crash activity, collected
through cookies, web beacons and similar technologies. For more information on
how We use these technologies and how to turn them off from collecting your
information, please see our Cookie Policy.

3. Information We receive from other sources

From time to time, We may receive information about you from:

● other end users,

● your colleagues,

● third-party providers,

● our corporate affiliates,

● professional social networks and publicly accessible websites,

● Third-party integrations set up with your Docebo account,

● and from our business partners.

We will collect this information only where these third parties are legally
permitted or required to share your personal information to Us.

HOW WE USE YOUR PERSONAL INFORMATION AND WHICH LEGAL BASIS WE RELY ON:

We collect and process personal information for a variety of purposes,
including:

Type of personal information

Purposes

Legal basis

Contact information

 * To send you an order confirmation and invoice you accordingly
 * To administer your account, including your single sign-on (SSO) access
 * To provide the Services to you
 * To respond to a demo or other customer service requests
 * To give you access to Docebo Community, Docebo University and connect you
   with other users
 * In case you are an investor, to send you financial, company related
   information and to allow you to exercise your rights as a shareholder.

Performance of a contract with you

 * To establish and manage our relationship with you, including informing you
   about Services or opportunities which might be of your interest
 * For safety and security to verify accounts and activity, to monitor
   suspicious or fraudulent activity and to identify violations of Service
   policies, including any ethics and whistleblower reporting from you

Docebo business legitimate interests

 * To send you marketing communications and newsletters
 * To conduct surveys and evaluate customer satisfaction
 * To interact with or use third-party tools or integrations

Docebo business legitimate interests, or, if required under applicable law, to
the extent you have provided your prior consent

 * To manage registrations at our events (e.g. conferences, webinars, annual
   general meeting) and customer participation (including updates, possible
   changes, cancellations, accessibility, parking, logistics for the event)
 * Recording calls for training and quality assurance purposes

Your consent to process your data

 * To comply with legal obligations, including the cases where Docebo needs to
   respond to requests by government or law enforcement authorities.
 * To protect our legitimate business interests and legal rights

To comply with a legal obligation

Content information

 * For data labelling and machine learning to improve our algorithms, models and
   your experience (e.g. to predict the most appropriate content to add in a
   selected area of your Docebo domain)

Docebo business legitimate interests

Customer Support information

– To resolve technical issues, to respond to requests for assistance

Performance of a contract with you

 * To analyse crash information and to improve the Services

Docebo business legitimate interests

Analytics information

 * For research and development of our Services
 * To troubleshoot and to identify trends, usage, activity patterns and areas
   for integration and improvement of the Services
 * to monitor suspicious or fraudulent activity and to identify violations of
   terms of use or agreements

Docebo business legitimate interests

Device information

 * Display content based upon your interests
 * For adverting purposes
 * To develop and improve our websites

Docebo business legitimate interests, or, if required under applicable law, to
the extent you have provided your prior consent

Sensitive information

 * To ensure that any catering available during our events can accommodate your
   dietary requirements
 * To make reasonable adjustments and accommodations to ensure accessibility to
   the event

Your consent to process your data

HOW WE SHARE YOUR PERSONAL INFORMATION:

We share your personal information with the third parties listed below in the
following circumstances:

● Service Providers

We provide your personal information to companies that provide services to help
Us with our business activities (such as processing your payments or for share
registry services). These companies are authorized to use your personal
information only as necessary to provide these services to Us, in compliance
with this Privacy Policy and appropriate data processing terms signed with them.

● Affiliates and Subsidiaries

We may share the information We collect within the Docebo group of companies to
provide services to you.

● Your organisation’s Docebo administrators

If you’re using Docebo Services in connection with an organization or academic
institution, your company’s own account administrator can have access to some
information associated with you and connected with the Docebo domain they
manage.

● Docebo Community

In our community you are able to upload and share comments or feedback publicly
with other Docebo users. Any information that you disclose in this forum is not
confidential, and Docebo may use it for any purpose. You should be aware that
any information you post openly in these ways will be potentially accessible
through third-party search engines. Also, in the Docebo Community, your posts
might remain accessible (but with your profile information removed where
possible) to ensure the correct functionality of the Community.

● Event sponsors

if you attend an event or webinar organized by Us, we may share your personal
data with the sponsors of the event with your explicit consent if required by
the applicable law.

● Legal Authorities

We may also disclose your personal data as required by law, such as to comply
with a subpoena or similar legal process when We believe in good faith that
disclosure is necessary to protect our rights, protect your safety or the safety
of others, investigate fraud, or respond to a government request. Unless We are
prohibited by law, We will notify you of any disclosure requirement.

● Potential parties involved in a business transaction

In case Docebo decides to merge with, or is acquired (entirely or partially) by,
another company, or sell some of the services provided or a business unit, your
personal data might be disclosed, under conditions of confidentiality, to our
advisers and any prospective purchaser’s advisers. In this case We will inform
you, via email and/or a prominent notice on our website, of any change in
ownership, use of your personal data, and choices you may have regarding your
personal data.

● Others

We may also disclose your personal data to any other third party with your prior
consent (e.g. when you connect Docebo Services with third-party integrations).

HOW YOUR INFORMATION IS KEPT SECURE:

The security of your personal information is important to Us.

We follow generally accepted security standards and We have adopted commercially
reasonable security measures to protect your personal data against accidental or
unlawful destruction, loss, alteration, or unauthorized disclosure or access. We
may use third-party products and services to secure or store your information.
For more information on where We store and how We secure your information,
please see our compliance and security page.

Depending on where you live, you may have a legal right to be notified in case
of security breach. Overall, if you have any reason to believe that your
interactions with the Services are no longer secure, please notify Us
immediately at privacy@docebo.com.

We may, subject to applicable law, transfer your information outside the country
where you are located, in countries to where information protection standards
may differ (e.g. your information may be stored on servers located in other
jurisdictions). We will utilise appropriate safeguards governing the transfer
and usage of your personal information. See the following Section ‘How we
transfer your data’ for further information.

HOW WE TRANSFER YOUR DATA:

Your personal information may be transferred to, and processed in, countries
other than the country in which you are based, where Docebos ’affiliates,
subsidiaries, partners or our third-party service providers operate.

Some of these countries, specifically Australia, are not offering an adequate
level of protection and security. As a result, We take measures to ensure that
your information is safe and protected in compliance with the applicable data
protection laws, including:

● reliance of Standard Contractual Clauses to transfer your data outside the
European Economic Area, United Kingdom and Switzerland;

● implementation of organisational, contractual and technical security measures
with our third-party service providers;

● establishment of an intra-group data transfer agreement for internal transfers
of personal data within Docebo group of companies around the world.

A quick note about the Data Privacy Framework

We participate in and have certified our compliance with the EU-U.S. Data
Privacy Framework, the UK Extension to the EU-U.S. Data Privacy Framework and
the Swiss-U.S. Data Privacy Framework (see our certification here). Docebo is
committed to adhere to the Data Privacy Framework Principles in relation to all
personal data received from European Union, UK and Switzerland.

Docebo NA Inc complies with the Data Privacy Framework 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 Data
Privacy Frameworks, Docebo is subject to the regulatory enforcement powers of
the U.S. Federal Trade Commission. In certain situations, Docebo may be required
to disclose personal data in response to lawful requests by public authorities,
including to meet national security or law enforcement requirements.

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

With respect to personal data received or transferred pursuant to the Data
Privacy Frameworks, Docebo is subject to the regulatory enforcement powers of
the U.S. Federal Trade Commission. In certain situations, Docebo 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, described in more details on the Data Privacy
Framework website, a binding arbitration might be available when other dispute
resolution procedures have been exhausted.

To learn more about the Data Privacy Framework, visit the U.S. Department of
Commerce’s Data Privacy Framework List at https://www.dataprivacyframework.gov/.

HOW LONG WE KEEP YOUR INFORMATION:

We will retain your information for the time needed to fulfil the purposes
described above, unless a longer retention period is required or permitted by
law.

If your account is deactivated or disabled, some of your information and the
content you have provided will remain in order to allow your team members or
other users to make full use of the Services.

After the expiry of the applicable retention period, We will either delete your
information or, if this is not possible (for example, because the information
has been stored in backup archives), We will securely store your information and
isolate it from any further use until deletion is possible.

In case you object from any marketing communications, or withdraw your consent,
We will promptly stop using your information collected for these purposes.
However, We will keep a permanent record of the fact that you have asked Us not
to process your information so that We can respect your request in future.

TRACKING TECHNOLOGIES:

We and our marketing partners, affiliates, or analytics or service providers,
use technologies such as cookies, beacons, pixel tags, scripts, and other
similar technologies to analyse trends, administer our websites, tracking usage
of our Services so we can provide a better experience to you.

In some cases, we partner with third parties to either display advertising on
our website or to manage our advertising on other sites. Our third party
partners may use technologies such as cookies to gather information about your
activities on Docebo websites in order to provide you advertising based upon
your browsing activities and interests.

Also, under California law, some of these activities may be interpreted as a
‘sale’ or ‘share’ of your Device information for commercial purposes, such as to
provide advertisements, to analyse our marketing campaigns.

You have the right to opt-out of such “selling” or “sharing” of your personal
information by changing your cookies preferences or by setting a Global Privacy
Control (“GPC”) signal.

You can find more information about cookies, similar technologies and how to
change your preferences in our Cookie Policy.

SOCIAL MEDIA WIDGETS:

Our website includes Social Media features, such as the Facebook Like button,
and widgets, such as the ‘Share This’ button, or interactive mini-programs that
run on our websites. These features may collect your IP address, which page you
are visiting on our website, and may set a cookie to enable the feature to
function properly. Social Media features and widgets are either hosted by a
third party or hosted directly on our website. Please read the privacy statement
of the company providing these features to understand how your personal data is
processed.

EXERCISING YOUR RIGHTS:

Regardless your location, you have the right to know if We process your data, to
amend or update inaccurate or incomplete information about you, to request
deletion of your personal data, or request that We no longer use it. You may
submit a request for access (i.e. request information on personal data
collected, used, disclosed or processed by Docebo) as well. Some of these
requests can be processed through the self-service features available inside the
Docebo admin portal (See the User Management section for more information about
these tools).

If you are a resident of European Economic Area, United Kingdom, Switzerland, or
Brazil you can also submit a request (i) for rectification, or (ii) to object to
our processing of your personal data, or even (iii) to have your data available
in a structured, electronic format (‘data portability’).

Where you gave Us consent to use your information for a specific purpose, you
can ask Us to withdraw that consent, but this will not affect the lawfulness of
any processing activity already taken place before your withdrawal.

You have the right to opt-out of marketing communications We send you at any
time. Please read the section ‘Marketing communications’ below for further
details on these requests.

In some circumstances, We might need to verify your identity and your
relationship with Docebo before proceeding with your request for security
reasons.

Subject to a request required by law, Docebo might not be able to entirely
comply with your request to withdraw.

In order to exercise your rights described above and/or submit inquiries or
complaints regarding our processing of your personal data, you can do so at any
time by contacting Us using the information given under the “Contact us” section
below.

If you believe that We have not been able to assist you with your requests, you
have the right to lodge a complaint with your local competent supervisory
authority (contact details for European data protection authorities for
countries can be found here and for the United Kingdom here).

1. Marketing communications

If you no longer want to receive marketing-related emails from Us, you can opt
out of receiving such emails by clicking the “unsubscribe” link at the bottom of
any marketing email you receive from Us. Please be aware that you will continue
to receive certain communications from Us that are necessary for the Service
(e.g. renewal notifications, invoices, technical updates).

If you are having difficulty unsubscribing from our marketing emails using the
above method, please contact Us directly at the email privacy@docebo.com.

2. Your rights as end user

As described above, We also collect and process personal data submitted by
Docebo customers under their instructions. If you wish to exercise any rights
you may have under applicable data protection laws, please check their privacy
policies and contact them directly.

If you make your request directly to Us, We will refer your request to the
relevant Docebo customer (as long as they can be identified from the details you
provided) and will support them as required.

3. California residents

In addition to the rights and information provided above, California consumers
and their authorized agents can request:

 * information about the categories of personal information that We collect
   about you, including how We collect it, from which the sources We collect it,
   the business purposes pursued with your information and the way We share it
   with third parties. Please read sections above to obtain further details on
   how We manage your personal information;
 * to delete all your personal information.

To exercise these rights or for any other questions, please contact Us at
privacy@docebo.com. We might need to take steps to confirm that you are
authorised to make the request (e.g. by asking for a proof of residency or the
consumer’s written authorization if you are an agent). You will not be
discriminated against for exercising any of your privacy rights. However if you
ask Us to delete your information, We may not be able to entirely provide our
Services to you.

4. Nevada residents

In addition to the rights and information provided above, Nevada consumers can
ask Us to opt out of any potential future sales (as defined in accordance with
the applicable data protection law) by contacting Us at privacy@docebo.com. At
the moment, Docebo does not sale any personal data collected from you.

CHANGES TO THIS PRIVACY POLICY:

We may change all or part of our Privacy Policy from time to time to reflect our
data collection practices, in case of new features involving your personal data,
or as required by the law. The version published on the Docebo main website
(https://www.docebo.com/company/privacy-policy/) will be the most current
version in force. Changes to our Privacy Policy will be effective immediately
once published. We invite you to periodically review our Privacy Policy to be
informed of any relevant changes, especially before providing any data to Us.

Your use of the Services following any amendments confirms that you have
accepted the practices described in the revised Privacy Policy. If We make any
material change to the Privacy Policy, 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 and ask for your consent if this
is required by applicable law.

Any translated version of the English Docebo Privacy Policy is provided for
reference purposes only. In the event of any differences between the English
version and translated version of this Policy, the English version (available
here) will prevail and control.

CONTACT US:

If you have any questions or concerns relating to our data protection practices,
or wish to exercise any of your rights, please contact Us at privacy@docebo.com
or by mail at Docebo headquarter:

Docebo S.p.A.

Legal department

Via Parco 47 – 20853 Biassono (MB) – ITALY









PLATFORM MODULES

 * Learning Management
 * Content Creation
 * Content Marketplace
 * Embedded Learning
 * Learning Intelligence

PLATTFORM-MODULE

 * Learning Management
 * Content Creation
 * Content Marketplace
 * Embedded Learning
 * Learning Intelligence

MODULI PIATTAFORMA

 * Learning Suite
 * Learn LMS
 * Content Creation [Previously Shape]
 * Content
 * Learning Impact
 * Learn Data

ADD-ONS

 * Extended Enterprise
 * Mobile App Publisher
 * Docebo for MS Teams
 * Docebo for Salesforce

 * SERVICES

 * Strategic Services
 * Partners
 * Integrations

ADD-ONS

 * Extended Enterprise
 * Mobile App Publisher
 * Docebo per MS Teams
 * Docebo per Salesforce

 * SERVIZI

 * Servizi Strategici
 * Partner
 * Integrazioni

ADD-ONS

 * Extended Enterprise
 * Mobile App Publisher
 * Docebo for MS Teams
 * Docebo for Salesforce

 * SERVICES

 * Strategic Services
 * Partners
 * Integrations

INDUSTRIES

 * Software
 * Financial Services
 * Manufacturing
 * Healthcare
 * Government
 * Restaurant & Hospitality
 * Tech / IT Services
 * Education
 * Retail

INDUSTRIEN

 * Software
 * Financial Services
 * Manufacturing
 * Healthcare
 * Government
 * Restaurant & Hospitality
 * Tech / IT Services
 * Education
 * Retail

SETTORI

 * Software
 * Financial Services
 * Manufacturing
 * Healthcare
 * Government
 * Restaurant & Hospitality
 * Tech / IT Services
 * Education
 * Retail

RESOURCES

 * Customer Stories
 * Blog
 * Webinars
 * Whitepapers

 * EDUCATION & COMMUNITY

 * Docebo U
 * Docebo Community
 * Product Updates

RISORSE

 * Customer Stories
 * Blog
 * Webinars
 * Whitepapers

 * EDUCATION & COMMUNITY

 * Docebo U
 * Docebo Community
 * Product Updates

RESSOURCEN

 * Customer Stories
 * Blog
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