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RECIPROCITY PRIVACY POLICY




Last Updated: September 14, 2021

Reciprocity is committed to protecting your privacy.  Our most important asset
is you and your trust and we want you to have confidence in the way we use your
Personal Information.

In this Privacy Notice, “us”, “we” and “our” refers to Reciprocity, Inc. and our
affiliates listed on this page (collectively “Reciprocity”). “Personal
Information” means any information relating to an identified or identifiable
individual. Please read the following carefully to understand our views and
practices regarding your Personal Information and how we will treat it.

This Privacy Notice provides Information about:

 * Reciprocity and our Privacy Notice
 * Personal Information We Collect
 * Cookies and similar technologies
 * How we use Personal Information
 * Our Promotional Updates and Communications
 * Who We Share Personal Information With
 * Where We Store Personal Information
 * Security
 * Retention
 * Your Rights and Choices
 * Links to Other Websites
 * Modifications to the Privacy Notice
 * Contacting Reciprocity


RECIPROCITY AND OUR PRIVACY NOTICE

Reciprocity is a computer software company. Our Governance, Risk, and Compliance
(GRC) software helps our customers to more effectively manage different business
risks.

This Privacy Notice describes how we collect, use, disclose and otherwise
process Personal Information about you when:

 * you visit our website at www.reciprocity.com (the “Site”); or
 * submit Personal Information directly to us on the Site; or
 * otherwise contact, or inquire or otherwise engage with us in respect of our
   products and services which we market through our Site (our “Services”).

Outside of customer account information, this Privacy Notice does not apply to
processing by our customers of Personal Information when they use Reciprocity
Services. Where Reciprocity host customer Personal Information within the
Reciprocity Services we do so in our capacity as a processor on the customer’s
behalf. Our customer is the controller in respect of Personal Information they
process when using Reciprocity Services.

For more information about how Reciprocity safeguards Personal Information
submitted by or processed within the Services by customers, please see our
ZenGRC and Services privacy policy.

By visiting and using our Site and engaging with us, you acknowledge that you
have read and understood this Privacy Notice.


PERSONAL INFORMATION WE COLLECT


INFORMATION PROVIDED BY YOU

You may provide us with the following categories of Personal Information about
you:

 * Contact information:  basic contact information such as your first and last
   name, email address, phone number and other contact information such as your
   address.
 * Professional information: job title, title level, title function, company
   name, which subject matter you are interested in, resume/curriculum vitae
   (CV).
 * Communications information: records of any correspondence and communications
   including the content of your message, the date and time and our response if
   you contact us or raise a question with us.
 * Marketing information: you may provide concerning your marketing preferences.

We may ask you to provide certain Contact and Professional information when you
register for events, request a demo, download white papers or literature, or
seek more information.

We may also collect any other Personal Information that you choose to provide to
us. For example, Communications and Marketing information if you decide to
contact us with a request, or Professional information where you contact us to
apply for a job with Reciprocity.


INFORMATION WE COLLECT ABOUT YOU

We may collect via automated means the following categories of Personal
Information about you or that relate to your use of our Site:

 * Technical information which may include:
   
   * Internet protocol (IP) address
   * Browser type and version
   * Device IDs
   * Google ID
   * Time zone setting
   * Operating system and platform
   * Hardware version
   * Device language settings

 * Information about your visit which may include:
   
   * Uniform Resource Locators (URL)
   * Clickstream to and through our Site (but not from our Site)
   * Page response times and download errors
   * Page interaction information (such as scrolling, clicks, frequency and
     length of visits, types of content viewed or engaged with)


COOKIES AND SIMILAR TECHNOLOGIES

We use cookies and similar technologies to collect and store certain
information. This includes saving cookies to your device. For information on
what cookies are, which ones we use, why we use them, and how you can manage
their use, please see our Cookies Policy.


HOW WE USE PERSONAL INFORMATION

We use information held about you in the following ways:


INFORMATION PROVIDED BY YOU

We will use this information to:

 * Ensure in our legitimate interests that:
   
   * content from our Site is presented in the most effective manner for you and
     for your device to provide you with a better experience
   * to communicate with you and respond to your inquiries.
   * to process your job applications with us

 * Take steps in order to enter into any contract or carry out our obligations
   arising from any contract entered into between you and us including:
   
   * administering an account you have with us;
   * notifying you about changes or updates to our Service.

 * Provide you with information about our Services we believe may interest you
   and which may be tailored to you, in our legitimate interests (provided these
   interests do not override your right to object to such communications) or if
   you have given your consent to receiving marketing material from us at the
   point we collected your information, where such consent is required by law or
   otherwise. For example we may:
   
   * send you an email to alert you about Service upgrades, upcoming events,
     updated information and about other of our Services. See ‘Our promotional
     updates and communications’.
   * call you on the telephone number you have provided to us with information
     regarding our Services or upcoming events. If you do not wish to receive
     such telephone calls, please let us know at the time you provide this
     information or by using the contact details provided below.


INFORMATION WE COLLECT ABOUT YOU

We will use this information in our legitimate interests:

 * For internal operations, including troubleshooting, data analysis, testing,
   research, statistical analysis purposes.
 * To understand how you use and interact with our Site
 * To keep our Site safe and secure.
 * To improve our Site to ensure that content is presented in the most effective
   manner for you and for your computer or device.
 * To measure and understand the effectiveness of our advertising and to deliver
   relevant advertising to you.


IF YOU ARE IN EUROPE

If you are located in Europe, we rely on one or more of the following grounds
when processing your Personal Information:

 * To fulfill a contract we have with you.
 * To comply with a legal obligation.
 * You have given clear consent for us to process your Personal Information for
   a specific purpose.
 * Data protection law allows us to use Personal Information for our genuine and
   legitimate reasons as long as we respect your rights and freedoms. This
   lawful basis for using your information is called ‘legitimate interests’.
   When we rely on our legitimate interests as the legal basis for processing
   your Personal Information for the purposes set out above, we will specify
   what our legitimate interests are, and carefully consider and balance any
   possible effect this may have on you and your rights. You have the right to
   object to this processing, however please bear in mind if you object this may
   affect our ability to carry out certain activities.


OUR PROMOTIONAL UPDATES AND COMMUNICATIONS

Where permitted in our legitimate interest or with your prior consent where
required by law, we will use your personal data for marketing analysis and to
provide you with promotional update communications by email or by telephone
about our Services.

You can object to further marketing at any time by selecting the “unsubscribe”
link at the end of all our marketing and promotional update communications to
you, or contact us directly. See Your Rights and Choices below.


WHO WE SHARE PERSONAL INFORMATION WITH

We may share your Personal Information with:

 * companies within our group including Reciprocity Europe who may support us in
   any of the purposes set out in this Privacy Notice
 * analytics and search engine providers that assist us in the improvement and
   optimization of our Platform, including by measuring the performance of our
   online campaigns and analysing visitor activity
 * business partners, suppliers and sub-contractors, performing services on our
   behalf (e.g., Site hosting providers and other parties who assist us in
   operating our Site, conducting our business, or serving our Site visitors and
   customers)
 * any company or prospective buyer of all or substantially all of the Company
   group’s assets in connection with the sale or transfer of assets to any
   prospective buyer
 * any person to whom disclosure is necessary to enable us to enforce our rights
   under this Privacy Notice or under the terms of use or to protect our rights
   or the rights of third parties. This includes exchanging information with law
   enforcement agencies or other similar government bodies
 * another party where required to do so by court order or where we are under a
   duty to disclose or share your information in order to comply with (and/or
   where we believe we are under a duty to comply with) any legal obligation

Click here to see a list of our subprocessors


WHERE WE STORE PERSONAL INFORMATION

The servers used to process your Personal Information collected from this Site
are in the USA, however we collect data from wherever visitors to our Site or
customers are situated. The information that we collect may therefore be
transferred to the USA from any other country in which you may be located.


IF YOU ARE IN EUROPE

Where we transfer Personal Information, we will take all steps reasonably
necessary to ensure that it is protected by appropriate safeguards. This
includes:

 * relying on a European Commission recognized legal adequacy mechanism, like
   the European Commission standard contractual clauses for transfers of
   personal information
 * ensuring it is treated securely and in accordance with this Privacy Notice.

We may transfer your personal information outside Europe:

 * in order to store it
 * in order to enable us to provide our Service to you and fulfill any contract
   with you. This includes the provision of support services
 * where we are legally required to do so
 * in order to facilitate the operation of our group of businesses, where it is
   in our legitimate interests and we have concluded these are not overridden by
   your rights.


HOW TO MAKE A COMPLAINT?

Reciprocity Inc. commits to resolve complaints about our collection or use of
your personal data. European Union individuals with inquiries or complaints
regarding the use of personally identifiable information should first contact us
at privacy@reciprocity.com.


DATA SHARING TO THIRD PARTIES

Reciprocity Inc. may provide personal data to third parties who perform services
on our behalf.


FEDERAL TRADE COMMISSION ENFORCEMENT

Reciprocity Inc. is subject to the investigation and enforcement actions of the
Federal Trade Commission. Reciprocity Inc. may be required to share your
personal data, including the disclosure of UK, Switzerland, and European Union
personal data, to public authorities and law enforcement agencies in response to
lawful requests, including requests to meet national security and law
enforcement requirements.


SECURITY

We are committed to ensuring that your Personal Information is adequately
protected. In order to prevent unauthorized access to or disclosure of your
Personal Information, we have implemented appropriate administrative, physical
and technical controls to safeguard our systems, applications and information,
as well as robust standard operating procedures in the event of a security
incident. We also maintain procedural safeguards to further restrict access to
your Personal Information to employees who need it to perform their tasks or
people working on our behalf and under confidentiality agreements.


RETENTION

We take measures to delete your Personal Information or keep it in a form that
does not permit identifying you when this information is no longer necessary for
the purposes for which we process it, unless we are required by law to keep this
information for a longer period.

When determining the retention period, we take into account various criteria,
such as the type of products and services requested by or provided to you, the
nature and length of our relationship with you, possible re-enrollment with our
products or services, the impact on the services we provide to you if we delete
some information from or about you, mandatory retention periods provided by law
and the statute of limitations.

If you opt-out from us sending you promotional updates and marketing, or object
to any other processing of your Personal Information, we may keep a record of
your objection for the legitimate purpose of ensuring that we can continue to
respect your wishes and not contact you further, during the term of your
objection.


YOUR RIGHTS AND CHOICES

You have options and choices over how we use your personal information. You may
have the right under applicable laws to ask for details of the personal
information we hold about you, or to amend, limit or delete your personal
information. You may also have the right to object to further processing under
certain circumstances.

We also respect the rights you may have under applicable laws to receive that
information in a commonly used electronic format (or ask for this information to
be provided in that format to a third party where feasible).

If you are in Europe, you have the right under certain circumstances:

 * to be provided with a copy of your personal information held by us
 * to request the correction or erasure of your personal information held by us
 * to request that we restrict the processing of your personal information
   (while we verify or investigate your concerns with this information, for
   example)
 * to object to the further processing of your personal information, including
   the right to object to marketing (as mentioned in our promotional updates and
   marketing section
 * to request that your provided personal information be moved to a third party
 * to withdraw consent
 * Where the processing of your personal information by us is based on consent,
   you have the right to withdraw that consent without detriment at any time by
   contacting us. You can also change your marketing preferences at any time as
   described in our promotional updates and marketing section and below. If you
   remain unhappy with a response you receive from us, you can also refer the
   matter to your data protection supervisory authority which can be found here.


OPTING OUT OF OUR MARKETING COMMUNICATIONS

To opt out from receiving electronic marketing communications from Reciprocity,
please:

 * Click on the unsubscribe link provided within each electronic communication,
   or
 * Reply to the email with the subject line “unsubscribe”


OPTING OUT FROM OUR MARKETING CALLS

 * Outside Europe: Call 1-877-440-7971 or email us at privacy@reciprocity.com
 * Within Europe: email us at privacy@reciprocity.com


LINKS TO OTHER WEBSITES

This Privacy Notice covers the privacy practices of Reciprocity and it does not
cover the privacy practices of third parties on their websites and other
features. Reciprocity is not responsible for the privacy notices and/or
practices of third-parties.

Reciprocity’s Site may provide links that can take you to other websites, which
may include partner websites. You should review the privacy and other policies
that govern the websites you visit, since those websites are not bound by
Reciprocity’s Privacy Notice, and Reciprocity has no control over the content of
those Websites, nor the usage of information they gather.


MODIFICATIONS TO THE PRIVACY NOTICE

Any changes we make to our privacy notice will be posted on this
page https://reciprocity.com/privacy and, in relation to substantive changes,
will be notified to you by e-mail.


CONTACTING RECIPROCITY

If you would like to contact us with questions or concerns about this Privacy
Policy, our privacy practices, or would like to exercise your privacy rights,
you may contact us via any of the following methods:

E-mail: privacy@reciprocity.com

Toll-free Number (USA): +1-877-440-7971

YOU MAY ALSO WRITE TO US AT:

 * Attn: Privacy Officer
 * Reciprocity, Inc.
 * 548 Market St, #73905
 * San Francisco, CA 94104

OUR EU REPRESENTATION:

 * Attn: Privacy Officer
 * Reciprocity d.o.o.
 * Celovška cesta 25
 * 1000 Ljubljana
 * Slovenia

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 * Content Registry

Company
 * About Us
 * Contact Us
 * Careers
 * Leadership
 * Trust Center
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(877) 440-7971

Contact Us


(877) 440-7971

Contact Us


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