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AISERA, INC.
WEBSITE PRIVACY POLICY:

February 1, 2019

Aisera, Inc. (“Aisera”) considers your privacy paramount, and we take great care
in keeping the information of our users private and secure. This Privacy Policy
describes our policies and procedures regarding the information that we collect
when you use our services, software and website (the “Services”), as well as how
we use, disclose, protect and share your information. This Privacy Policy does
not apply to third party services that are not under Aisera’s control; those
parties’ services are governed by their own privacy policies.

We encourage you to read this Privacy Policy carefully as it will help you to
make informed decisions about sharing your personal information with us.

Please keep in mind when reading this Privacy Policy that Aisera does include
the ability for you to enroll in webinars or other events and will only store
the content necessary for these services. This Privacy Policy outlines how we
protect metadata about your content and your interactions with Aisera.

Types of Personal Information Collected

We may collect personal information from users in a variety of ways, including,
but not limited to, when you visit our website, place an order, and in
connection with other activities, services, features or resources we make
available through our Services.

Information collected through our Services and other means

We may collect information about you when you visit or use our Services (such as
electronic communications protocols, IP addresses, web pages visited on our
website, and your user preferences), or when you correspond with us by post,
email or telephone.

We also collect device specific information, such as hardware model, operating
system version, advertising identifiers, unique device identifiers, browser type
and language preferences.

Like many businesses, we also collect information through cookies and similar
technologies for functionality, analytics and targeted advertising purposes. You
can find out more about this in the ‘Cookies’ section below.

Purposes

When you provide personal information to us using these Services, we use it
primarily to deliver our Services to you.

We also collect and use personal information for the following purposes:

 * To develop, operate, improve, deliver, maintain and protect our Services,
 * to communicate with you

 * to market our products and services (where this is in accordance with your
   marketing preferences)
 * to customize the content we show you, including ads
 * to enhance the safety and security of our Services
 * to collect and handle feedback,
 * to improve customer service,
 * to comply with applicable laws and legal processes,
 * to enforce our terms and conditions and other usage policies,
 * to protect our rights, privacy, safety, or property, and/or that of our
   affiliates, you, or others, and to allow us to pursue available remedies or
   limit any damages that we may sustain.

 

Disclosures

Aisera may disclose information to the following types of third parties:

 * Business partners, trusted affiliates and advertisers, Aisera may disclose
   generic aggregated demographic information not linked to any personal
   identification information regarding visitors and users.
 * Third party service providers, Aisera may share personal information for the
   purpose of operating or administering the Services, such as sending out
   newsletters, surveys, or implementing marketing campaigns.
 * Law Enforcement, as we believe to be necessary or appropriate, we may
   disclose personal information: (a) under applicable laws, including laws
   outside your country of residence; (b) to comply with legal process; (c) to
   respond to requests from public and government authorities, including public
   and government authorities outside your country of residence, including to
   meet national security or law enforcement requirements; (d) to enforce our
   terms and conditions; (e) to protect our operations or those of any of our
   affiliates; (f) to protect our rights, privacy, safety, or property, and/or
   that of our affiliates, you, or others; and (g) to allow us to pursue
   available remedies or limit the damages that we may sustain.
 * Others, Aisera may disclose personal information to a third party in the
   event of any reorganization, merger, sale, joint venture, assignment,
   transfer, or other disposition of all or any portion of our business, assets,
   or stock (including in connection with any bankruptcy or similar
   proceedings).

When disclosing personal information from the EU and Switzerland to third
parties outside of the EU or Switzerland, Aisera will enter into a written
agreement with such third party that provides adequate protection for the data
(for example, by requiring that the third party provide at least the same level
of privacy protection as is required by the Privacy Shield Principles).

Under the Privacy Shield, we remain liable if our third-party agents process
your personal information in a manner inconsistent with the Shield’s Principles,
unless we prove that we are not responsible for the event giving rise to the
damage.

EU-US and Swiss-US Privacy Shield Framework

Aisera’s uses third-party servers are located around the world including the US.
If you are a non-US resident, this may mean that your personal information could
be transferred to the US.

Aisera complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S.
Privacy Shield Framework as set forth by the U.S. Department of Commerce
regarding the collection, use, and retention of personal information transferred
from the European Union and Switzerland to the United States, respectively.
Aisera has certified to the Department of Commerce that it adheres to the
Privacy Shield Principles. If there is any conflict between the terms in this
privacy policy and the Privacy Shield Principles, the Privacy Shield Principles
shall govern. To learn more about the Privacy Shield program, and to view our
certification, please visit the website.

In compliance with the EU-US and Swiss-US Privacy Shield Principles, Aisera
commits to resolve complaints about your privacy and our collection or use of
your personal information. European Union or Swiss individuals with inquiries or
complaints regarding this privacy policy should first contact Aisera at:
compliance@aisera.com or at the address given in the Contact Aisera section
below.

Aisera has further committed to refer unresolved privacy complaints under the
EU-US and Swiss-US Privacy Shield Principles to an independent dispute
resolution mechanism, BBB EU PRIVACY SHIELD, operated by the Council of Better
Business Bureaus. If you do not receive timely acknowledgment of your complaint,
or if your complaint is not satisfactorily addressed, please visit the
website for more information and to file a complaint.

Please note that if your complaint is not resolved through these channels, the
complaint may be referred to the US Department of Commerce or Federal Trade
Commission for further investigation.

Under limited circumstances, a binding arbitration option may be available
before a Privacy Shield Panel. For further information about the Privacy Shield
arbitration scheme, please visit here.

Aisera is subject to the investigatory and enforcement powers of the Federal
Trade Commission (FTC).

Retention of Personal Information

Aisera has the right, but not the obligation, to retain and use such information
stored in our databases and other information obtained from your current or
previous interactions with the Services for a reasonable period, not exceeding
any legal requirements or limitations, to resolve disputes, troubleshoot
problems and enforce Aisera’s rights and the terms and conditions of this
Privacy Policy.

Security

Aisera implements advanced security to safeguard the privacy of transmissions
over public networks. Aisera hosts the Services in a secure environment using
preventive, detective and corrective technology and processes to safeguard
information from attackers. Aisera requires unique user names and passwords that
must be entered each time a customer logs on. These safeguards help prevent
unauthorized access, maintain data accuracy and ensure the appropriate use of
data.

The security of your personal information is important to us. We encrypt any
information entered within the platform once users are logged into their
accounts. We also encrypt all communications between the Aisera client and our
web services. If you have any questions about security on our Web site, you can
contact us at compliance@aisera.com

Please keep in mind that we cannot guarantee that the internet itself is 100%
secure. Although we will do our best to protect your personal information,
transmission of personal information to or from

our site is at your own risk. You should only access our website and Services
within a secure environment.

How we protect your information

Aisera utilizes commercially reasonable measures to prevent unauthorized access
to personal information. These measures include policies, procedures, employee
training, physical access and technical elements relating to data access
controls. In addition, we use standard security protocols and mechanisms to
facilitate the exchange and the transmission of sensitive data, such as credit
card details. We do not process personal information in a way that is
incompatible with the purposes for which it has been collected or subsequently
authorized by the individual. Aisera utilizes commercially reasonable measures
to prevent unauthorized access to personal information. These measures include
policies, procedures, employee training, physical access and technical elements
relating to data access controls. In addition, we use standard security
protocols and mechanisms to facilitate the exchange and the transmission of
sensitive data, such as credit card details. We do not process personal
information in a way that is incompatible with the purposes for which it has
been collected or subsequently authorized by the individual.

Marketing Choices

Aisera provides you with choices about the use and disclosure of personal
information for marketing purposes.

Where it is in accordance with your marketing preferences, we may send you
marketing emails regarding our products and services, upcoming promotions and
other information that may be of interest to you.

If you do not wish to receive such marketing emails from us, you may use the
unsubscribe option at the bottom of our emails to opt out.

From time to time, where it is in accordance with your preferences, we may share
your personal information with certain selected affiliates. If you do not wish
that we share your personal information with our affiliates for marketing
purposes, you may opt-out by contacting us at legal@aisera.com.

Aisera will attempt to comply with your request as soon as reasonably
practicable. Please note that if you opt-out of receiving marketing-related
messages from us, we may still send you important administrative messages
regarding our Services, from which you cannot opt-out.

Access and Other Rights

We acknowledge the right of EU and Swiss individuals to access their personal
data. Where we collect personal information on our own behalf, and not on behalf
of our customers, you may at any time request to have incomplete, incorrect,
unnecessary or outdated personal information deleted or updated by contacting
Aisera. We will also grant individuals reasonable access to personal information
that we hold about them, though such requests may be subject to a fee specified
by applicable law. Please note that by requesting Aisera to delete your personal
information, we may not be able to provide you the Services you have inquired
about or ordered.

Individuals wishing to access, change or no longer desire our Services, may
view, correct, update of discontinue the use of our Service or delete it by
making the change on the Aisera account administrator page or by emailing our
Compliance department at compliance@aisera.com. Aisera will respond to your
request to access within 30 days.

We will retain your information for as long as your account is active or as
needed to provide you Services. We will retain and use your information as
necessary to comply with our legal obligations, resolve disputes, and enforce
our agreements.

Please note that where we are processing personal information on behalf of our
customers using our services (see “Personal Information” section above), we are
not responsible for their use of the data and cannot control their data
collection and privacy practices. Any individual who seeks to access, amend or
delete this personal information should direct their query to the customer in
question. For example, if you use Aisera’s services under a corporate account
set up by your employer, you should contact your employer directly.

Changes to this Privacy Policy

Aisera may change, modify or update this Privacy Policy at any time. When we do,
we will revise the date at the top of this page. If we make any material
changes, we will post a prominent notice on our website and/or notify you via
email or through the Services. We encourage you to frequently check this page
for any changes to stay informed about how we are helping to protect the
personal information we collect.

Contact Aisera

If you have any questions about this Privacy Policy, please contact us at:

Aisera, Inc.
Attn: Legal Department
2479 Bayshore Rd, Suite 270
Palo Alto, CA 94303 USA
legal@aisera.com

Cookies Policy

We, and third parties with whom we partner, may use cookies, web beacons, local
shared objects (sometimes called “flash cookies”), and similar technology in
connection with your use of the Services and third-party websites (“Cookies”).

Cookies are small data files that are placed on your computer or mobile device
when you visit a website. Cookies are widely used by website owners in order to
make their websites work, or to work more efficiently, as well as to provide
reporting or analytical information. Cookies are not the only way to recognize
or track visitors to a website. We may use other, similar technologies from time
to time, like web beacons and flash cookies, to collect and store information
about your use of our services, fraud prevention and for other site operations.

Cookies set by Aisera are called “first party cookies”. Cookies set by parties
other than Aisera are called “third-party cookies”. Third party cookies enable
third party features or functionality to be provided on or through the website
(e.g. advertising, interactive content and analytics). The parties

that set these third-party cookies may be able to recognize your computer both
when it visits the website in question and also when it visits certain other
websites.

Aisera uses first party and third-party cookies for several reasons. Some
cookies are required for technical reasons for our websites to operate, and we
refer to these as “essential” or ”strictly necessary” cookies. Other cookies
also enable us to track and target the interests of our users to enhance the
experience on our websites. For example, aggregate statistics, such as IP
addresses, operating systems, browser types and the addresses of any referring
websites, and general information about the Services’ traffic patterns and
related information are collected for analytical purposes. Aisera may link the
information stored in cookies to any personal information you submit through
online forms while accessing or using the Services.

Third parties serve cookies through our website for advertising and other
purposes. This is described in more detail below.

 

The Aisera Website

The specific types of first- and third-party cookies served through our website
and the purposes they perform are described in the table below:

Type of cookie – Essential website cookies: These cookies are strictly necessary
to provide you with services available through our website and to use some of
its features.

Who serves the cookies?

 * Aisera

How to opt out

Because the cookies are strictly necessary to deliver the website to you, you
cannot refuse them. You can block or delete them by changing your browser
settings – see below under the heading “How can I control cookies?”

Type of cookie – Performance and functionality cookies: These cookies are used
to enhance the performance and functionality of our website but are
non-essential to their use. However, without these cookies, certain
functionality may become unavailable.

Who serves the cookies

 * Google Analytics
 * Disqus
 * AddThis

How to opt out

To refuse these cookies, please follow the instructions below under the heading
“How can I control cookies?” Alternatively, please click on the relevant opt out
link below:

 * Google Analytics
 * Disqus
 * AddThis

Type of cookie – Analytics cookies: These cookies collect information that is
used in aggregate form to help us understand how our websites are being used or
how effective are marketing campaigns are, or to help us customize our websites
for you.

Who serves the cookies

 * Google Analytics

How to opt out

To refuse these cookies, please follow the instructions below under the heading
“How can I control cookies?” Alternatively, please click on the relevant opt out
link below:

 * Google Analytics

Type of cookie – Advertising cookies: These cookies are used to make advertising
messages more relevant to you and to serve Aisera ads to users who have visited
the Aisera website.

Who serves the cookies?

 * DoubleClick
 * HubSpot
 * AdRoll
 * Twitter

How to opt out

To refuse these cookies, please follow the instructions below under the heading
“How can I control cookies?” Alternatively, please click on the relevant opt out
link below:

 * DoubleClick
 * Hubspot
 * Marketo
 * AdRoll
 * Twitter

Please note that the table above describes the cookies that are served on the
Aisera public website as of February 1, 2019.

The Aisera Web Portal

Management of a customer’s tenant is performed through the Aisera web portal.
When interacting with the web portal, the cookies served are purely functional
and include cookies from Amazon Web Services CloudFront Cookies which are used
to deliver content that a user has downloaded. To refuse these cookies, please
follow the instructions below under the heading “How can I control cookies?”

How can I control cookies?

You have the right to decide whether to accept or reject cookies. You can
exercise your cookie preferences by clicking on the appropriate opt-out links
provided in the cookie table above. Alternatively, you can set or amend your web
browser controls to accept or refuse cookies. The links below will take you to
the ‘Help’ sections for some of the major browsers so that you can find out more
about how to manage your cookies:

 * Internet explorer
 * Google Chrome
 * Safari
 * Safari iOS
 * Opera

If you choose to reject cookies, you may still use our website and web portal
though your access to some functionality and areas of the sites may be
restricted. You should be aware that any preferences will be lost if you delete
cookies.

Do Not Track

We support Do Not Track. Users can therefore set their browser privacy settings
to “Do Not Track” to opt out of tracking. For details about Do Not Track, and
how to turn on the setting, visit the website.





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