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CUSTOMER LOGINS

Obtain the data you need to make the most informed decisions by accessing our
extensive portfolio of information, analytics, and expertise. Sign in to the
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ALLIUM PRIVACY POLICY

ALLIUM US LLC and its subsidiaries and affiliates (collectively "ALLIUM," "us,"
"we," or "our") are committed to protecting your privacy and providing you with
a positive experience while using our websites, products, or services
("Platform(s)").

ALLIUM reserves the right, at any time, to modify this Privacy Policy. If we
make revisions that change the way we collect, use, or share personal
information, we will post those changes in this Privacy Policy. If we make
material changes to our Privacy Policy, we may also notify you by other means
prior to the changes taking effect, such as by posting a notice on our Platform
or sending you a notification. You should review this Privacy Policy
periodically so that you keep up to date on our most current policies and
practices. We will note the effective date of the latest version of our Privacy
Policy at the end of this Privacy Policy.






1. SCOPE





This Privacy Policy applies to ALLIUM’s Platforms and provides you with guidance
on your rights and obligations in relation to your personal information. 

This Privacy Policy establishes and communicates the key principles that ALLIUM
follows in protecting the personal information that we collect. Please note that
some privacy rights and obligations may differ in certain locations based on
local law, in which case ALLIUM will comply with the local legal requirements.
To the extent a notice provided at the time of collection from a website or
specific product conflicts with this Privacy Policy, such specific notice or
supplemental privacy statement will control.






2. COLLECTION OF PERSONAL INFORMATION





"Personal information" is any information that can be used to identify an
individual or device, and may include things such as your name, physical
address, email address, phone number, login information, marketing preferences,
company affiliation, geographic location, or payment card information. ALLIUM
may collect personal information that is necessary for legitimate business
purposes, which will be disclosed to you at the time of collection. ALLIUM will
use this information for the purposes for which it was collected. ALLIUM may
also collect personal information from trusted third-party sources and engage
third parties to collect personal information to assist us.

One of the most common methods of collecting personal information is during the
online form submission or registration process, including where a website user
is requesting a free trial or a courtesy newsletter, registering for an event,
or responding to similar offers such as sample reports, white papers, or further
product information.

In some instances, ALLIUM and the third parties we engage may automatically
collect and aggregate data using cookies, weblogs, web beacons, and other
similar applications. This information is used to better understand and improve
the usability, performance, and effectiveness of our Platforms and to help us
tailor content or offers for you. Please read Section 9 (Cookies) below for more
information.






3. PURPOSE AND USE OF PERSONAL INFORMATION





ALLIUM may use your personal information for operational, legal, administrative,
and other legitimate purposes permitted by applicable law. Some of the ways we
may use personal information include:

 * Providing you with requested products or services.
 * Providing you with information regarding similar products or events.
 * Analyzing and monitoring extent of use.
 * Providing customized product and service information.
 * Allowing users to participate voluntarily in mailings or other events.
 * Providing product service updates, information, and alerts.
 * Sending communications, including for marketing or other customer
   satisfaction purposes.
 * Order processing and to provide transaction documents.
 * To contact users for information verification purposes.
 * Analyzing and monitoring extent of use and enhancing ALLIUM’s Platforms.






4. LEGAL BASIS FOR PROCESSING





ALLIUM’s legal basis for collecting and processing personal information depends
on the personal information concerned, the context in which ALLIUM collects it
and the applicable laws and regulations. Generally, ALLIUM collects personal
information from you when:

 * we have your consent to do so;
 * we need the personal information to perform our contractual obligations to
   you or your employer (for example, where you subscribe to one of our
   products);
 * the processing is in our legitimate interests and not overridden by your data
   protection interests or fundamental rights and freedoms and the processing is
   otherwise consistent with applicable law;
 * It is necessary to comply with a legal or regulatory obligation.






5. YOUR RIGHTS





We strive to make sure that our information is reliable, accurate, and
up-to-date. While personal information is maintained by ALLIUM, individuals in
certain jurisdictions will have rights over how their personal information is
processed. To find out what rights apply in your jurisdiction, please visit
Section 12 (Additional Information for Certain Jurisdictions).

To make a request regarding your personal information, please reach out to our
privacy team at privacy@accuris.co

Below is a brief description of rights that may apply to you:

5.1 RIGHT OF ACCESS

You may have the right to access your personal information to review, update,
and correct inaccuracies. There are some exemptions, which means you may not
always receive all the information we process. Additionally, there may be limits
to the amount of information we will provide access to. For example, in some
cases, we may limit access to personal information where the request is
manifestly unfounded or excessive, in particular because of the requests have
been repetitive in character, or where doing so would violate the rights of
others.

5.2 RIGHT TO INFORMATION

In some circumstances and subject to certain exceptions, you may have the right
to request information about the processing of your information. Information
typically requested includes:

 * The categories or specific types of personal information we have collected.
 * The business purpose for collecting, disclosing, and/or selling the
   information.
 * The sources from which personal information was collected.
 * The categories of third parties with whom we share personal information.
 * The criteria used to determine the time that personal information will be
   held.
 * The existence of automated decision-making, including profiling that uses
   your personal information.
 * The safeguards we’ve applied to protect your information when it is
   transferred internationally.

5.3 RIGHT TO RECTIFICATION

You may have the right to ask us to rectify personal information you think is
inaccurate. This could also include the right to ask us to complete information
you think is incomplete.

5.4 RIGHT TO ERASURE

In some circumstances and subject to certain exceptions, you may have the right
to ask us to erase your personal information.

5.5 RIGHT TO RESTRICT PROCESSING

In certain circumstances, you may have the right to ask us to restrict the
processing of your information.

5.6 RIGHT TO OBJECT TO THE PROCESSING OF YOUR PERSONAL INFORMATION

You may have the right to object to the processing of your information. The
right to object to the processing of personal information is most commonly used
by individuals when asking a business to cease direct marketing.

5.7 RIGHT TO DATA PORTABILITY

In some circumstances, you may request copies of your information in a portable
and, to the extent technically feasible, readily usable format that allows you
to transmit this information to another entity without hindrance.

5.8 RIGHT TO OPT OUT OF THE SALE OF YOUR PERSONAL INFORMATION

You may have the right to direct us not to sell your personal information.

5.9 RIGHT TO NONDISCRIMINATION

You may have the right to not be treated differently for exercising your rights.

Upon receipt of a valid request made through our privacy inbox
(privacy@accuris.co), we will take the necessary steps to assess and respond.
Please be aware that in order to accommodate some requests, we must verify your
identity before we can respond to a privacy request and this may require you to
provide photographic identity information to ALLIUM. Because your personal
information—for example, your email address—is often required to access or use
ALLIUM Platforms and technologies, we retain personal information as long as
your account is active. You may have the opportunity to correct, update, or
modify this information by logging into your account and updating your
information online. Please note that some information may be retained in our
systems, where permitted by law, even after you request deletion.






6. SHARING PERSONAL INFORMATION





To support the purposes listed in Section 3 (Purpose and Use of Personal
Information), ALLIUM may share or disclose personal information to:

 * ALLIUM's parent, subsidiary, affiliates, and other related companies for the
   purposes listed in Section 3 (Purpose and Use of Personal Information).
 * The organization that arranges your access to our products or services (if
   that is not you) to fulfill its contractual obligations and to provide our
   products and services.
 * Service providers, professional advisers, consultants and business partners
   for the purposes of operating our business, delivering, improving, and
   customizing our products or services, sending marketing and communications
   related to our business, payment processing, and for other legitimate
   purposes permitted by applicable law or otherwise with your consent.

Personal information handled by these service providers is subject to their
terms of use and privacy policies. Please review the service provider’s terms of
use and privacy policies to better understand how they manage your personal
information.

There may also be instances when ALLIUM may disclose your personal information
without providing you with a choice in order to:

 * Honor a request that you have made through the products or services.
 * Comply with the law or in response to a court order, government request, or
   other legal process.
 * Protect the interests, rights, safety, or property of ALLIUM or others.
 * Protect against fraud or for risk management purposes.
 * Respond to adverse third parties (i.e., adverse parties and their counsel and
   other agents) in the context of litigation.

In addition, if ALLIUM sells all or part of its business or makes a sale or
transfer of assets or is otherwise involved in a merger or business transfer,
you acknowledge that ALLIUM may transfer your personal information to a third
party as part of that transaction. You may be informed of the identity and
contact details of the third party where required by applicable law.

In all cases, ALLIUM requires all unaffiliated third parties to treat personal
information as confidential. ALLIUM will not provide personal information to
third parties for their own marketing purposes without your consent.

If you participate in a discussion forum, chat room, or provide comments related
to ALLIUM on a social media or other public platform, you should be aware that
the information you provide there (i.e., your public profile) will be made
broadly available to others, and could be used to contact you, send you
unsolicited messages, or for purposes neither ALLIUM nor you have control over.
Also, please recognize that social media forums and chat rooms not controlled by
ALLIUM may have additional rules and conditions. ALLIUM is not responsible for
the personal information or any other information you choose to submit on these
forums that are not controlled by ALLIUM.

The Platforms may offer you the ability to share personal information through a
social networking site (e.g., Facebook, Twitter), using integrated tools (e.g.,
Facebook “Like” button, or Twitter “Tweet” button). The use of such integrated
tools enables you to share personal information about yourself with other
individuals or the public, depending on the settings that you have established
with such social networking site. For more information about the purpose and
scope of data collection and use in connection with such social networking site
or a site’s integrated tools, please visit the privacy policies of the entities
that provide these social networking sites.






7. SECURITY OF PERSONAL INFORMATION





ALLIUM has physical, administrative, and technical safeguards in place to help
protect the personal information ALLIUM collects. While there is no such thing
as perfect security on the Internet, we will take reasonable and appropriate
steps to ensure the safety of your personal information.






8. RETENTION OF PERSONAL INFORMATION





ALLIUM will retain your personal information for as long as necessary to fulfill
the purposes for which it was collected. We will retain and use your personal
information as necessary to comply with our business requirements, legal
obligations, resolve disputes, protect our assets, and enforce our agreements.






9. COOKIES WE USE AND THEIR PURPOSE





We use four types of Cookies - ‘Strictly Necessary’, ‘Performance’, ‘Functional’
and ‘Targeted Advertising’. A detailed explanation of the types of Cookie and
the purposes for which we use them is found within the ALLIUM Cookie Notice
available here. However, if you are just looking for a summary, we use strictly
necessary cookies to make our site work. We also like to set optional
performance, functional, and advertising cookies to help us improve the site and
give you a bespoke experience so it works better for you.






10. CROSS BORDER TRANSFER OF PERSONAL INFORMATION





As a global organization, we may transfer your personal information to ALLIUM
affiliates, agents, contractors, service providers, and to third parties in
various countries and jurisdictions around the world. By using our Platforms, or
providing any personal information to us, where applicable law permits, you
acknowledge the transfer, processing, and storage of such information outside of
your country of residence where data protection standards may be different.

ALLIUM safeguards and enables the global transfer of personal information in a
number of ways:

STANDARD CONTRACTUAL CLAUSES

The EU Standard Contractual Clauses and the UK Addendum are examples of
mechanisms approved by the European Commission and under UK law to ensure
adequate safeguards for personal information transferred from the EU or UK to
countries not found to offer adequate protection for personal information. In
some circumstances, Allium will rely upon Standard Contractual Clauses or the UK
Addendum to lawfully transfer personal information.

ADEQUACY DECISIONS

According to EU Regulation and under the UK GDPR, international transfers may
take place when there is an adequate level of protection to the fundamental
right of individuals to data protection. The European

Commission and the UK GDPR have determined that several countries ensure an
adequate level of protection. In some circumstances, ALLIUM will rely upon an
adequacy decision to lawfully transfer personal information.






11. PROSPECTIVE EMPLOYEE AND EMPLOYEE INFORMATION





If you submit an application for employment to or are currently an employee of
ALLIUM, ALLIUM is authorized to collect the information in any form it obtains
through your application for employment or continued employment with ALLIUM, and
your submission of employee related documents, including but not limited to the
personal information that you submit in connection with your employment or
intended employment (collectively "Employee Information"). 

Examples of Employee Information collected in connection with your employment or
application for employment includes but is not limited to your name, date of
birth, government issued identification (passport, social security number,
driver’s license number), banking information, marital status, health
information, benefit information, title, employment history, education, job
qualifications, and other relevant employee personal information. We also
collect some of this information about your dependents when you provide it to
us. By providing personal information about family members or other individuals,
you represent that you have their consent to provide this information to us for
the purposes set forth in this Privacy Policy.

ALLIUM will collect, use, store and retain, and secure your social security
number in accordance with this Privacy Policy. ALLIUM will not intentionally
communicate or make available, in any manner, your social security number to the
general public. ALLIUM will not print your social security number on any card
required for you to access colleague member services provided by ALLIUM. ALLIUM
will not require you to transmit your social security number over the Internet,
unless the connection is secure or the social security number is encrypted.
ALLIUM will not print your social security number on any materials that are
mailed to you, unless state or federal law requires or permits the social
security number to be on the document to be mailed.

In accordance with applicable law, ALLIUM may use Employee Information to
evaluate applications for employment, manage work-related aspects of the
employee-employer relationship (e.g., training, payroll, benefits, travel,
reimbursement expenses, performance appraisals, succession planning, team member
health and safety), investigate and respond to any claims related to your
employment, and comply with applicable laws and regulations. Your professional
information, such as your name, job title, professional photo, area of
expertise, reporting line, and work experience may be shared with clients or
potential clients in connection with your job responsibilities. Your
professional information may also be shared through internal resources
accessible to ALLIUM colleagues, such as organizational charts and other
documents available on ALLIUM’s secure intranet. ALLIUM will not use your
Employee Information to market to you directly or through a third party service
provider, unless you specifically consent to such use.

ALLIUM shares your Employee Information with third parties who provide
outsourced human resource functions to us and are required to protect your
Employee Information. ALLIUM may disclose your Employee Information if required
or permitted to do so by law (such as when part of a governmental agency action
or litigation), governmental or quasi-governmental requests, or a regulatory
organization, or to relevant third parties such as site technicians, brokers,
auditors, lawyers, or professional advisors. In the event that ALLIUM considers
it necessary or where required by law to disclose Employee Information in
certain situations where the health, safety, or wellbeing of a team member is at
imminent risk, we may share your Employee Information with our outside lawyers,
law enforcement or others who are legally authorized. As ALLIUM continues to
develop our business, we may buy or sell assets. In the unlikely event that
ALLIUM or substantially all of our assets are acquired, Employee Information may
be one of the transferred assets.

Employee Information may be stored in hard copy or electronic format within your
branch office or in the cloud in the United States or other countries where
ALLIUM, its affiliates, agents, or contractors conduct business. Your Employee
Information may be transferred into our human resources systems and used to
manage your employment, may become part of your personnel file, and may be used
for other workrelated purposes. Your Employee Information will be kept for as
long as is legally required, and in some instances longer depending upon the
needs of the organization and industry practices.

If you have any complaints regarding our compliance with this Privacy Policy,
you should first contact us via our privacy mailbox, at privacy@accuris.co.
Alternatively, you can write to us at the address listed below under Section 15
(Contact Information). If you are a resident of the European Union or another
applicable jurisdiction and you have an unresolved concern regarding your
Employee Information that we have not addressed satisfactorily, please contact
your local data protection authority.






12. ADDITIONAL INFORMATION FOR CERTAIN JURISDICTIONS





EUROPEAN ECONOMIC AREA

EU General Data Protection Regulation

The ALLIUM Policy for the Processing of Data Governed by the GDPR addresses our
commitment to the processing of personal information under the EU General Data
Protection Regulation 2016/679.

CALIFORNIA

For the purposes of this section, “personal information” means information that
identifies, relates to, describes, is reasonably capable of being associated
with, or could reasonably be linked, directly or indirectly, with a particular
California resident or household.

In some circumstances and subject to certain exceptions, California residents
have the right to information; erasure; access/data portability; object to the
sale of information; and the right to nondiscrimination, as detailed in Section
5 (Your Rights). Residents of the State of California also have the right to
request information regarding third parties to whom the company has disclosed
certain categories of personal information during the preceding year for the
third parties' direct marketing purposes. 

For information about the requests we receive, including the number of requests
and the average number of days we’ve taken to respond to requests, please click
here. The data included here is from 2022, when Accuris was part of the SPGI
business.

The following is a summary of ALLIUM data collection practices, including the
personal information ALLIUM collects, whether ALLIUM discloses that information
for business purpose, and whether ALLIUM "sells" and/or "shares" (as those terms
are defined by California law). ALLIUM may use all of the information for any of
the purposes described in this Policy unless limitations are listed.  ALLIUM has
no actual knowledge that it sells or shares the personal information of
consumers under 16 years of age. As discussed elsewhere in the Privacy Policy,
ALLIUM uses cookies and similar tracking technologies for purposes of targeted
advertising. For more information, please see the ALLIUM Cookie Notice. The
categories we use to describe the information are those set out in the CCPA.





Category of Personal Information

Category of Recipients

Disclosures for a Business Purpose

Sharing for Cross-Context Behavioral Advertising

Sales

Identifiers – this may include real name, alias, postal address, unique personal
identifier, online identifier, email address, account name, or other similar
identifiers.

- Affiliates or subsidiaries

- Business partners

- Data analytics providers

- Data brokers

- Internet service providers

- Joint marketing partners

- Operating systems and platforms

- Other Service Providers

- Payment processors and financial institutions

- Professional services organizations, this may include auditors and law firms

- Social networks

Not shared.

Not sold.

Government Issued Identification – this may include social security number,
driver’s license number, or state issued identification number, passport number.

- Affiliates or subsidiaries

- Business partners

- Other Service Providers

Not shared.

Not sold.

Financial Information – this may include bank account number, credit card
number, debit card number, and other financial information.

- Affiliates or subsidiaries

- Business partners

- Payment processors and financial institutions

- Other Service Providers

Not shared.

Not sold.

Characteristics of protected classifications – this may include age, sex, race,
ethnicity, physical, or mental handicap, etc.

- Affiliates or subsidiaries

- Business partners

Not shared.

Not sold.

Commercial information – this may include information about products or services
purchased, obtained, or considered, or other purchasing or consuming histories
or tendencies.

- Affiliates or subsidiaries

- Business partners

- Data analytics providers

- Data brokers

- Other Service Providers

Not  shared.

Not sold.

Internet or other electronic network activity information – this may include
browsing history, search history, and information regarding an individual’s
interaction with an internet website, application, or advertisement.

- Affiliates or subsidiaries

- Business partners

- Data analytics providers

- Internet service providers

- Operating systems and platforms

- Other Service Providers

Not shared.

Not sold.

Geolocation data

- Affiliates or subsidiaries

- Business partners

Data analytics providers

- Operating systems and platforms

- Other Service Providers

Not shared.

Not sold.

Audio, electronic, visual, thermal, olfactory, or similar information

- Affiliates or subsidiaries

- Business partners

- Other Service Providers

Not shared.

Not sold.

Professional or employmentrelated information

- Affiliates or subsidiaries

- Business partners

- Other Service Providers

Not shared.

Not sold.

Non-public education information (as defined in the

Family Educational Rights and

Privacy Act)

- Affiliates or subsidiaries

- Business partners

- Other Service Providers

Not shared.

Not sold.

Inferences drawn from any of the information listed above

- Affiliates or subsidiaries

- Business partners

- Other Service Providers

Not shared.

Not sold.

Additional categories of personal information described in the California
Customer Records statute (Cal. Civ. Code § 1798.80(e)) – this may include
signature, physical characteristics, or description, insurance policy number.

- Affiliates or subsidiaries

- Business partners

- Payment processors and financial institutions

- Other Service Providers

Not shared.

Not sold.

For information about the requests we receive, including the number of requests
and the average number of days we’ve taken to respond to requests, please click
here. The data included here is from 2022, when Accuris was part of the SPGI
business



PEOPLE’S REPUBLIC OF CHINA

In some circumstances and subject to certain exceptions, individuals in the
People’s Republic of China (“PRC”) have the right to:

 * withdraw consent, which will not impact data processing by ALLIUM that took
   place prior to the withdrawal;
 * be informed regarding the processing of their personal information;
 * decide, restrict, or refuse the processing of their personal information;
 * access or copy their personal information;
 * data portability;
 * rectify or delete their personal information;
 * seek explanation with respect to ALLIUM's policies for the processing of
   their personal information;
 * make a complaint; and
 * opt out of any automated decision-making that may apply to them.

BRAZIL

ALLIUM is committed to complying with Brazil’s General Data Protection Law
(“LGPD”). Under the LGPD, you have the right to:

 * Confirm the existence of processing of your personal data;
 * Access data;
 * Correct incomplete, inaccurate, or out of date data;
 * Anonymize, block, or delete unnecessary or excessive data or data that is not
   being processed in compliance with the LGPD;
 * Portability of data to another service or product provider, by means of an
   express request;
 * Delete personal data processed with your consent;
 * Information about public and private entities with which we have shared data;
 * Information about the possibility of denying consent and the consequences of
   such denial;
 * Revoke consent;
 * Request review of decisions taken solely on the bases of automated processing
   of personal data that affects your interests.

You or an authorized agent may exercise your rights through the Privacy Request
Page. The LGPD also provides that you may file a complaint regarding your data
directly with the Brazilian data protection regulator, ANPD.

SOUTH AFRICA

ALLIUM, through its affiliate Allium UK Holding Limited (“Responsible Party”)
processes the personal information of natural persons and juristic persons in
South Africa in accordance with Protection of Personal Information Act 4 of 2013
("POPIA").

POPIA provides individuals with the right to:

 * Be notified that your personal information is being processed; and/or whether
   the personal information has been unlawfully accessed or acquired by an
   unauthorised person;
 * Access
 * Rectification
 * Erasure
 * Object to the processing of your personal information
 * Not be subjected to direct marketing by means of unsolicited electronic
   communications Not to be subjected to automated decision making that results
   in legal consequences and that is based solely on automated processing of
   personal information; and
 * Submit a complaint to the Information Regulator

To exercise these rights, please contact the ALLIUM Legal Department by using
the contact information in Section 15 of this Policy.

In circumstances where there are reasonable grounds to believe that a Data
Subject's personal information has been accessed or acquired by an unauthorised
person, ALLIUM may notify the Information Regulator and affected data subjects
where required by law.

In the event that your personal information is transferred outside of South
Africa to a third party in a foreign country, ALLIUM will ensure that your
information is adequately protected.

You may contact the Information Regulator using the following contact details:

Website:

http://justice.gov.za/inforeg/

Tel:

+27 12 406 4818

Fax:

+27 86 500 3351

Email:

POPIAComplaints@inforegulator.org
zainforeg@justice.gov.za

Physical address:

JD House
27 Stiemeans Street
Braamfontein
Johannesburg
2001

Postal address:

P.O. Box 31533
Braamfontein
Johannesburg
2017






13. OTHER CONTRACTUAL RELATIONSHIPS





If you enter into a separate contractual relationship with ALLIUM which
requires, or contemplates, collecting, using, or sharing information about you
in a manner that is different than that which is described in this Privacy
Policy, the terms of that agreement will apply.






14. OTHER WEBSITES





This Privacy Policy does not apply to sites or applications offered by other
companies or individuals, including third party products and services, that may
be displayed as content in a search on our website. ALLIUM encourages you to
read the privacy policy of any third-party site or applications before
transmitting personal information.






15. CONTACT INFORMATION





If you have any questions or concerns related to this Privacy Policy, please
contact the ALLIUM Legal Department:

ALLIUM

15 Inverness Way East
Englewood, CO 80112
Attn: ALLIUM Legal Department
privacy@accuris.co

If ALLIUM needs, or is required, to contact you concerning any event that
involves information about you, we may do so by email, telephone, or mail.

Updated March 22, 2023.




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