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PRIVACY POLICY

Welcome to the privacy policy of the GetBusy group which includes GetBusy plc
and its subsidiaries GetBusy UK Limited, GetBusy Australia Pty Limited, GetBusy
New Zealand Pty Ltd and GetBusy USA Corporation (referred to in this privacy
policy as “we”, “us” or “our”). You can contact us to find out further
information about our group structure.

We respect your privacy and are committed to protecting your personal
information. This privacy policy describes how we collect, use and disclose your
personal information, and what rights you have with respect to the use of your
information.

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


TABLE OF CONTENTS

 * Purpose of this privacy policy

 * The kinds of personal information we hold about you

 * How we collect your personal information

 * How we use your personal information

 * Marketing

 * How we share and disclose your personal information

 * Data security

 * Data retention

 * Your data protection rights

 * Changes to this privacy policy

 * Contacting us


PURPOSE OF THIS PRIVACY POLICY

This privacy policy sets out the information we hold about you, how we collect
and use the information and other key information about your rights in respect
of our use of your information.

We may hold your personal information either for our own purposes or on behalf
of our customers. Under European data protection laws, we are acting as a “data
controller” where we use your information for our purposes and determine how and
why we use your information. We are acting as a “data processor” where we hold
personal information on behalf of a Customer Organisation (or, in certain
circumstances, an Individual Customer). Whether we are acting as a data
controller or a data processor will depend on the circumstances.

In line with our obligations under European data protection laws, this privacy
policy sets out how we will collect, hold and use your personal information
where we are a data controller with respect to your personal information. In
particular the table in the section “How we use your personal information” below
specifies the purposes for which we may use your personal information as a data
controller. Where we refer to “you” and “your” in this privacy policy, we are
talking to the individual whose personal information we use as a data
controller.

We have used the following terms in this privacy policy:

 * “Customer Organisation”: a customer organisation (such as company or
   professional firm) that has signed up for a Service offered by the GetBusy
   group.

 * “Individual Customer”: an individual customer (for example, a sole trader)
   who has signed up for a Service offered by the GetBusy group (this does not
   include an individual employed or otherwise engaged by a Customer
   Organisation, who is authorised by the Customer Organisation to use the
   Service).

 * “Services”: the services supplied by the GetBusy group in connection with one
   or more of its proprietary software products which include Virtual Cabinet,
   Virtual Cabinet Portal, SmartVault and the GetBusy platform.

This privacy policy addresses our use of personal information about you as an
individual (in relation to your use of our Services) rather than our use of
information about our Customer Organisations, which is dealt with separately
through our terms of service.


PERSONAL INFORMATION WE HOLD ON BEHALF OF OUR CUSTOMERS

Some of the information stored by customers through our Services incorporates
personal information about individuals. This includes information we hold on
behalf of our Customer Organisations and information we hold on behalf of our
Individual Customers, where we hold information on their behalf about other
people.

Where we hold this information solely on behalf of our customers and do not use
it for our own purposes, under European data protection laws we will be acting
as a “data processor” and will hold that information in accordance with the
terms of our contracts with our customers. In these circumstances, our customers
will be acting as data controllers in respect of the information.

Though we will of course keep this information secure as a key feature of any
Services that we provide, this privacy policy does not address our use of
personal information where we are acting as a data processor because in those
circumstances it is our customers’ responsibility to provide this information to
the people whose information we hold.


THE KINDS OF PERSONAL INFORMATION WE HOLD ABOUT YOU

Personal data, or personal information means any information about an individual
from which that individual can be identified.

We may collect, use and hold the following different kinds of personal
information about you (depending on whether you are an Individual Customer or an
individual user of our Services employed by one of our Customer Organisations):

 * Identity Data including first name, last name, username or similar
   identifier, title, data of birth and gender.

 * Profile Data including your username and password, user preferences, comments
   feedback and other information that you submit to our Services.

 * Contact Data including postal address, email address and telephone numbers.

 * Customer Content Data being personal information contained in documents,
   messages, comments, text and images that you upload to or transmit through
   our Services that we provide.

 * Support Data being comments, feedback and information that you submit to us
   when using our support services.

 * Financial and Transaction Data including bank account, payment card details,
   billing address and other payment details.

 * Technical Data including unique user identifier, internet protocol (IP)
   address, login data, browser type and version, time zone setting and
   location, browser plug in types and versions, operating system and platform
   and other technology on the devices you use to access our Services.

 * Usage Data being information about how you use our Services (for example,
   through the services metadata, we log the areas, activity types, people,
   features, content and links you interact with, the type of files you share
   and what third party services you use, if any).

 * Marketing Data including your marketing preferences in relation to receiving
   marketing communications from us and, where relevant, third parties.

In limited circumstances, where you are an Individual Customer, we may be a data
controller in respect of special categories of data about you. This will only be
the case if you upload or otherwise transmit these types of data about yourself
when using our Services (for example, if you upload documents or send messages
that contain special categories of data about yourself). Special categories of
data attract a higher level of protection under data protection laws and include
data concerning health and sexual orientation and data revealing racial or
ethnic origin, political opinions, religious or philosophical beliefs or trade
union membership.


HOW WE COLLECT YOUR PERSONAL INFORMATION

We use the following different methods to collect data from and about you
including through:

 * Direct interactions with you. For example, you may submit your personal
   information (including Identity Data and Contact Data) to us as part of
   submitting an enquiry form on our website or setting up an account for one of
   our Services or we may send marketing materials and promotions to you (in
   accordance with your marketing preferences).

 * Automated technologies or interactions. As you interact with our Services, we
   may automatically collect Technical Data about your equipment, browsing
   actions and patterns. We collect this data by using cookies, server logs and
   other similar technologies. You can control cookies through your browser’s
   settings and other tools. However, if you block certain cookies, you may not
   be able to register, login, or access certain parts or make full use of the
   Services that you sign up for or are otherwise authorised to access. Please
   see our cookie policy for further details.

 * Third parties. We may receive your name and contact details from an existing
   customer who invites you to use a Service or through a referral arrangement
   with our business partners. We may also source marketing lists from third
   parties which contain personal information (ie Identity Data and Contact
   Data) about those that might be interested in our services. ie Identity Data
   and Contact Data) about those that might be interested in our services.


HOW WE USE YOUR PERSONAL INFORMATION

Where we are a data controller in respect of your personal information, we are
required by European data protection laws to be clear about the purposes for
which we are processing that personal information and our lawful basis for doing
so.

We set out below, in a table format, a description of the ways we plan to use
your personal information in our capacity as a data controller.

Note that we may process your personal information using more than one lawful
ground depending on the specific purpose for which we are using your
information. Please contact us if you would like details about the specific
legal ground we are relying on to process your personal information where more
than one ground has been set out in the table below.

Purpose/Activty Lawful basis for processing For account management and other
administrative purposes including keeping track of billing and payments.

Necessary for our legitimate interests (where you are (i) an Individual Customer
or (ii) a billing or other account management contact at the Customer
Organisation)

Performance of our contract with you (where you are an Individual Customer)

For marketing and communication purposes such as making suggestions and
recommendations to you about goods or services that may be of interest to you.
Necessary for our legitimate interests to develop our products/services and grow
our business To administer and protect our business and keep the Service
working, safe and secure (by troubleshooting, data analysis, testing, system
maintenance and monitoring and addressing other security/technical issues).

Necessary for our legitimate interests for running and protecting our business,
ensuring appropriate security, investigating and helping to prevent security
issues and abuse, to prevent fraud and so on

Necessary to comply with a legal obligation

To improve our website, products/services, marketing, customer relationships and
experiences (using data analytics etc.) Necessary for our legitimate interests
to define types of customers for our products and services, to keep our website
updated and relevant, to develop our business and to inform our marketing
strategy Where you are an Individual Customer, for providing the Service to you,
notifying you about changes or updates to the Service and responding to your
support queries. Performance of our contract with you Necessary for our
legitimate interests to develop our products/services and grow our business

Where you are an Individual Customer, the provision of your personal information
is necessary for us to enter into a contract with you and to perform that
contract. Where you are an Individual Customer, we will also ask for your
explicit consent to process any special categories of data about yourself that
you upload to or otherwise transmit through our Services. You are not required
to give your consent but, if you choose not to, you must not submit to our
Services any information about yourself that incorporates special categories of
data.

We are a provider of products and services and you are not obliged to provide
your personal details to us. However, if you choose not to provide your personal
information to us, we may not be able to respond to your queries or provide our
products and services to you.


MARKETING

We want to provide you with choices regarding certain personal information uses,
particularly around marketing and advertising. You can ask us at any time to
stop sending you messages by unsubscribing from emails or otherwise contacting
us to specify your marketing preferences.

We may use your Identity, Contact, Technical, Usage and Profile Data to form a
view on what we think you may want or need, or what may be of interest to you.
This is how we decide which products, services and offers may be relevant for
you.

You will receive marketing communications from us where you have requested
products or services from us as an Individual Customer or if you have requested
information from us and, in each case, you have not opted out of receiving that
marketing.


HOW WE SHARE AND DISCLOSE YOUR PERSONAL INFORMATION

We may share your personal data with the parties set out below to enable us to
carry out the activities specified in the table above (see “How we collect and
use your personal information” section):

 * Entities within the GetBusy group.

 * Our service providers, which include:

    * hosting providers to store and process your data
   
    * customer relationship management providers for customer communication,
      support, ideas portals and so on
   
    * data analytics providers to capture and analyse your usage data and so on
   
    * finance providers to provide financing services for certain products
   
    * marketing platform providers
   
    * plugin providers to enhance our products with additional functionality
   
    * hardware and services providers to provide you with hardware and services
      to support you use of our products; and

 * Our business partners, which include integrators.

In addition, if we choose to sell, transfer, or merge parts of our business or
our assets or if we seek to acquire other businesses or merge with them, we may
need to share your personal information with those other businesses. If a change
happens to our business, then the new owners may use your personal data in the
same way as set out in this privacy notice.

We require all third parties to respect the security of your personal
information and to treat it in accordance with the law. We do not allow our
third-party service providers to use your personal data for their own purposes
and only permit them to process your personal information for specified purposes
and in accordance with our instructions.


INTERNATIONAL TRANSFERS

We will transfer your personal information outside of the European Economic Area
(“EEA”) when we share the information with:

 * the entities within our GetBusy group;

 * our service providers (as specified in the section above) based in the US;
   and

 * our business partners including integrators.

Whenever we transfer your personal data outside of the EEA, we ensure that
safeguards are in place which meet the standards required by European data
protection laws.

Where we transfer your personal data to corporate entities within the GetBusy
group that are based outside of the EEA, we use specific contracts approved by
the European Commission which ensure that your personal information is given the
same protection it has in Europe. For further details and a copy of the relevant
contracts, see the European Commission’s webpage on the model contracts for the
transfer of personal data to third countries.

Where we transfer your personal data to our US based service providers or
business partners, we ensure that they are certified under the EU-US privacy
shield framework as having adequate safeguards in place. For further details on
the privacy shield framework, you can go to the privacy shield website at
https://www.privacyshield.gov/Program-Overview.

Please contact privacy@getbusy.com if you want further information on the
specific mechanism used by us when transferring your personal data out of the
EEA.


DATA SECURITY

We have put in place appropriate security measures to prevent your personal
information from being accidentally lost, used or accessed in an unauthorised
way, altered or disclosed. In addition, we limit access to your personal
information to those employees, agents, contractors and other third party
service providers who have a business need to know. They will only process your
personal information on our instructions and they are subject to a duty of
confidentiality.

We have put in place procedures to deal with any suspected personal data breach
and will notify you and any applicable regulator of a breach where we are
legally required to do so.


DATA RETENTION

We will only retain your personal information for as long as necessary to fulfil
the purposes we collected it for, including for the purposes of satisfying any
legal, accounting, or reporting requirements.

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

By law we have to keep basic information about our customers (including Contact,
Identity, Financial and Transaction Data) for six years after they cease being
customers for tax and legal purposes.

In some circumstances you can ask us to delete your data: see the “erasure”
right in the section below for further information.

In some circumstances we may anonymise your personal information (so that it can
no longer be associated with you) for research or statistical purposes in which
case we may use this information indefinitely without further notice to you.


YOUR DATA PROTECTION RIGHTS

Under certain circumstances, you have rights under data protection laws in
relation to your personal information. This may include the following rights:

 * Request access to your personal information (commonly known as a "data
   subject access request"). This enables you to receive a copy of the personal
   information we hold about you and to check that we are lawfully processing
   it.

 * Request correction of the personal information that we hold about you. This
   enables you to have any incomplete or inaccurate information we hold about
   you corrected.

 * Request erasure of your personal information. This enables you to ask us to
   delete or remove personal information where there is no good reason for us
   continuing to process it. You also have the right to ask us to delete or
   remove your personal information where you have exercised your right to
   object to processing (see below).

 * Object to processing of your personal information. This right applies where
   we are relying on our legitimate interests (or those of a third party) and
   there is something about your particular situation which makes you want to
   object to processing on this ground. You also have the right to object where
   we are processing your personal information for direct marketing purposes.

 * Request the restriction of processing of your personal information. This
   enables you to ask us to suspend the processing of personal information about
   you, for example if you want us to establish its accuracy or the reason for
   processing it.

 * Request the transfer of your personal information to another party (known as
   the “right to data portability”).

 * Withdraw consent. This right applies only if we are relying on your consent
   to process any of your personal information. This will not affect the
   lawfulness of any processing carried out before you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact
privacy@getbusy.com.

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

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

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


DATA PROTECTION AUTHORITY

You have the right to make a complaint at any time to the UK supervisory
authority for data protection issues. This is the Information Commissioner's
Office (ICO) whose details can be accessed via the ICO website at
https://ico.org.uk/global/contact-us/

We would, however, appreciate the chance to deal with your concerns before you
approach the ICO so please do get in touch using the details in our “Contacting
us” section below.


CHANGES TO THIS PRIVACY POLICY

We reserve the right to update this privacy notice at any time, and we will
provide you with a new privacy notice when we make any substantial updates. We
may also notify you in other ways from time to time about the processing of your
personal information.

If you have any questions about this privacy notice, please contact
privacy@getbusy.com.


CONTACTING US

We welcome you to contact us at any time. Our details are as follows:

GetBusy Privacy Team | privacy@getbusy.com

Last updated May 2018.


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