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NetMotion Mobility is now Absolute Secure Access











PRIVACY AND COOKIE POLICY












Absolute Software Corporation and its affiliates (“Absolute”, “we”, “us”, or
“our”) are committed to respecting and protecting the accuracy, confidentiality,
and security of your personal information, and want you to feel secure when
visiting our website (the “Website”), downloading and using any mobile device
applications we offer from time to time (the “Mobile Apps”), and using our
services (the “Services”). This Privacy & Cookie Policy (this “Policy”) sets out
our policies concerning the collection, use, disclosure, and protection of
personal information we receive from individuals using the Website, or from
customers using the Mobile Apps or the Services, as well as the types of cookies
that Absolute uses on the Website.

“Personal information” means all information about an identified or identifiable
individual. In some jurisdictions, the terms “personal data”, and “personally
identifiable information” are used in local privacy laws rather than the term
“personal information”. Absolute uses the terms “personal information”,
“personal data”, and “personally identifiable information” interchangeably.


QUICK LINKS

 * Scope of this Policy
 * Accountability
 * Legal Basis and Purposes for Collecting Personal Information
   * The Services
   * Mobile Apps
   * The Website and Use of Cookies
 * Consent
 * Limited Collection
 * Limited Use, Disclosure, and Retention

 * Accuracy
 * Safeguarding Personal Information
 * Openness
 * Requests for Access
 * GDPR Compliance (European Union and European Economic Area)
 * CCPA Compliance (California)
 * Use by Children
 * Complaint Procedure
 * Effective Date and Updates


SCOPE OF THIS POLICY

This Policy was drafted with the objective of complying with or exceeding the
requirements of Canada’s Personal Information Protection and Electronic
Documents Act (“PIPEDA”) and British Columbia’s Personal Information Protection
Act (“PIPA”), as Absolute’s corporate headquarters are located in Canada and its
parent company is incorporated in British Columbia, Canada. However, Absolute
also does business in other countries, and non-Canadians also use the Website,
the Mobile Apps, and the Services. Many of these other countries, and their
sub-units, have their own laws applicable to the protection of personal
information, which may or may not conflict with or contain more restrictive
legal obligations than PIPEDA and PIPA. It is Absolute’s policy to comply with
all applicable privacy legislation. As such, this Policy outlines the minimum
standards for Absolute’s treatment of personal information. Where applicable
laws contain additional requirements, Absolute will ensure compliance with those
laws. Should there be, in any specific case, an inconsistency between this
Policy and an applicable privacy law, this Policy will be interpreted in that
case to give effect to and comply with the applicable privacy law.

Absolute will update this Policy from time to time in response to changing
legal, technical, and business developments. We will take appropriate measures
to notify you about material changes in a manner that is consistent with the
significance of the changes we make. As well, a history of material changes is
noted at the end of this Policy. However, it is your responsibility to review
the most current version.

Please note that this Policy applies to Absolute’s customers who use the
Services and the Mobile Apps, and to users of the Website. The Services and the
Mobile Apps may be used by Absolute’s customers (i.e., corporations, schools,
healthcare organizations, governments, or other organizations) to collect
personal information about individuals, such as their personnel, students, or
patients. If you are an individual who believes that one of Absolute’s customers
has collected personal information about you through its use of the Services or
the Mobile Apps and you wish to withdraw consent, access your personal
information, request correction or deletion, complain about the collection of
your personal information, or exercise any other rights that you may have
regarding your personal information, your query should be directed to that
party, not to Absolute.


ACCOUNTABILITY

Absolute is responsible for personal information under its control and will take
all reasonable steps to handle such personal information fairly and to ensure
compliance with applicable laws in relation to the collection, use, disclosure,
and protection of personal information.

In order to oversee overall compliance with this Policy and with applicable
personal information protection laws, Absolute has designated a Privacy Officer
(who is also Absolute’s Data Protection Officer for the purposes of the European
Union’s General Data Protection Regulation, known as the “GDPR”). Contact
information for Absolute’s Privacy Officer can be found at the end of this
Policy.

Please note that if you are a corporate customer or any other type of
organization, you are responsible for the legal collection and use of personal
information of individuals within your organization, in accordance with the
principles set out in your privacy policies and the applicable laws in the
jurisdictions in which you operate or in which you or your personnel use the
Services or the Mobile Apps. Absolute is not responsible for your privacy
practices and policies. If your use of the Services involves the collection of
personal information of your personnel or other individuals (whether in
connection with their use of your devices or otherwise), it is your
responsibility to ensure that you obtain the necessary consents, provide the
necessary notices, and otherwise comply with all applicable laws relating to the
collection, use, and disclosure of their personal information.


LEGAL BASIS AND PURPOSES FOR COLLECTING PERSONAL INFORMATION

Absolute’s legal basis for collecting and using personal information will depend
on the personal information concerned and the specific context in which we
collect it. We will normally collect personal information from you only where we
need the personal data to perform a contract with you, or where the processing
is in Absolute’s legitimate interests and not overridden by your privacy and
data protection interests or fundamental rights and freedoms, or where Absolute
has your consent to do so. In some cases, Absolute may also have a legal
obligation to collect personal information from you or may otherwise need the
personal information to protect your vital interests or those of another person.
If we collect and use your personal data in reliance on our legitimate interests
(or those of any third party) other than as described in this Policy, we will
make it clear to you at the relevant time what those legitimate interests are.

Through the Website, the Services, and the Mobile Apps, Absolute collects, uses
and discloses to certain third parties personal information for the following
primary purposes:

 * to develop, manage, deliver, and support our products and the Services to our
   customers;
 * to contact our customers, either directly or through one of our authorized
   resellers, to offer them the option to renew, expand, and/or upgrade the
   Services;
 * to contact our customers directly about products and services that may be of
   interest;
 * to ensure high standards of service to our customers;
 * to contact customers with product and service updates, upgrades, and
   enhancements, as well as administrative or account-related information;
 * to respond to inquiries and fulfill requests, such as sending requested
   materials or documents regarding Absolute’s products and the Services;
 * to provide marketing and promotional communications (in accordance with
   applicable laws), and to determine the effectiveness of marketing and
   promotional campaigns;
 * for our legitimate business purposes, such as data analysis, audits, fraud
   monitoring and prevention, developing new products, improving or modifying
   the Services, and identifying usage and performance trends;
 * to verify a customer’s identity;
 * to process transactions; and
 * to comply with applicable laws, to comply with legal and regulatory
   processes, enforce our terms and conditions, and to protect our operations,
   rights, safety or property.

The paragraphs below provide further information about what types of personal
information we collect and how we use and disclose it for each of the Services,
the Mobile Apps, and the Website.


THE SERVICES

Absolute’s products and the Services help keep devices and data safe and secure,
and our products are designed to help protect your privacy. Using a very small
software agent, our products allow your device to call into our confidential and
secure monitoring center on a regular basis and transmit to our servers certain
information relating to your computer (including, among other things, device IP
address, device name, user name, list of hardware, and installed software). With
your consent and participation, certain of our products may also collect
additional asset-related information for certain other purposes designated by
you, such as hardware/software inventory, lease management, PC migration, and
software license compliance, as well as the detection of specific types of data
stored in files on your devices. In addition, if you use Absolute’s geolocation
service, Absolute will also collect geolocation data from the device.

If the Services you purchase include device theft investigation and recovery
services and you report your device as lost or stolen, with your consent we may
collect further information from the lost or stolen device (such as key capture
logs, registry and file access information, and geolocation information) in
order to determine its location, the user, their activity on the device, and any
data accessed. Once we have gathered sufficient information to determine its
location, we may compile such information and deliver it to a law enforcement
agency having jurisdiction over the individual in possession of the lost or
stolen device. The law enforcement agency may then use this information to
attempt to recover the lost or stolen device.

The terms of your use of the Services will be governed by your license or other
agreement with us.


MOBILE APPS

For Absolute’s consumer customers (i.e., individuals who purchase our products
for their own personal use), the Mobile Apps may collect personal information
such as your name, email address, street address, phone number, device make and
model, serial number, and device IMEI (International Mobile Equipment Identity)
number. In addition, if you use Absolute’s geolocation service, Absolute will
also collect geolocation data from your device which can be done through IP,
Wi-Fi, or GPS.

Absolute will use this personal information for product registration and
installation purposes, as well as for customer verification in the event that
you contact our Global Support team for assistance. Some of this personal
information may also be used by Absolute in the event that you file a theft
report for your device. If you use Absolute’s geolocation service, Absolute may
use your geolocation data to map your device location and display it to you
through our Customer Centre.

Absolute may share your contact or product information with its Original
Equipment Manufacturer (“OEM”) partners if you contact our Global Support team
for assistance and Absolute needs to work with the OEM in order to assist you.
Finally, we may share certain personal information with our external service
providers to assist us with the delivery of email campaigns, and for product
renewal and upgrade purposes.

For Absolute’s non-consumer customers (i.e., corporations, schools, healthcare
organizations, governments, and other organizations), the Mobile Apps generally
do not collect personal information. Rather, they facilitate the collection of
information by our customers and utilize information already collected through
the use of the Services. The Mobile Apps generally serve as management agents
and self-service portals, facilitate the download of non-app software, and
perform administrative functions. They may, however, determine the jailbroken
status of a device.

Absolute will try to collect personal information directly from the individual
concerned unless authorized by that individual to collect it from a third party
or as otherwise permitted by law.

If personal information is collected for any other purposes than described above
(unless the purpose for collecting personal information is obvious and you
provide your personal information for that purposes, or unless otherwise
permitted or required by applicable law), Absolute will communicate the purpose
of collecting the personal information to you at the time of collection, either
orally or in writing, as well as its use and how it may be disclosed.

If personal information is gathered in writing, the purpose of its collection
will be communicated through printed materials, the Website, or email. If
personal information is gathered orally, Absolute will provide an oral
explanation of the purpose for the collection and use.


THE WEBSITE AND USE OF COOKIES

If you visit the Website and request a free evaluation or trial, request or
subscribe to marketing materials, download content (such as whitepapers or
webinars), contact us, place an order, or register to use the Services, we will
collect personal information that you voluntarily provide to us (including your
IP address, name, title, address, email address, telephone number, and contact
preferences) in order to respond to your request or inquiry.

In addition, we use certain types of Cookies on the Website. “Cookies” are small
text files containing small amounts of information which are downloaded to your
device when you visit a website so that the website can remember some
information about your browsing activity on the website, either for the duration
of your visit or for repeat visits. The cookies are then sent back to the
originating website on each subsequent visit, or to another website that
recognizes that cookie. Cookies are useful because they allow a website to
recognize a user’s device. They do many different jobs, like letting you
navigate between pages efficiently, remembering your preferences, and generally
improving your user experience. In general, cookies make the interaction between
you and the website faster and easier. They cannot be used to run programs or
deliver viruses to your device. In general, cookies do not identify you
personally.

The following describes the types of cookies that Absolute currently uses or may
in the future use on the Website:

SESSION COOKIES

These are temporary cookies that expire when you close your browser. A session
cookie assigns a randomly-generated, unique identification number to your device
when you access the Website. Assigning your device a number facilitates the
proper functioning of the features of the Website by permitting us to maintain a
persistent “state” for your session, including information relating to orders
that you may place. We also use session cookies to collect anonymous information
(i.e., information that does not identify you personally) about the ways users
use the Website, such as which pages they visit, which links they use, and how
long they stay on each page. We analyze this information (known as “click-stream
information”) to better understand our users’ interests and needs and to improve
the content and functionality of the Website.

PERSISTENT COOKIES

Unlike a session cookie, a “persistent cookie” does not expire when you close
your browser. It stays on your device until the expiration date set in the
cookie (for example, at the end of a calendar month) or until you delete it.
Persistent cookies can be used to “tag” your device so that the next time you
visit (or someone using your device visits), our server will recognize you, not
by name, but by the “tag” on your device. This will enable us to provide you
with a personalized experience even if we do not know who you are. It will also
allow us to collect more accurate information about the ways people use the
Website, for example, how people use the Website on their first visit and how
often they return. Using persistent cookies permits us to provide you with a
more personalized experience and, in some cases, may save you the trouble of
re-entering information already in our database.

STRICTLY NECESSARY COOKIES

These cookies are essential for the running of the Website. Without these
cookies, parts of the Website would not function. They enable you to move around
the Website and use its features, such as accessing secure areas. These cookies
do not track where you have been on the Internet and do not gather information
about you that could be used for marketing purposes.

PERFORMANCE COOKIES

These cookies are used to monitor the performance of the Website, for example,
to determine the number of page views and the number of unique users the Website
has. Web analytics services may be designed and operated by third parties on
Absolute’s behalf. The information provided by these cookies allows us to
analyze patterns of user behaviour, and we use that information to enhance user
experience or identify areas of the Website which may require maintenance. These
cookies do not collect information that identifies a visitor. All information
collected through these cookies is aggregated and therefore anonymous.

FUNCTIONAL COOKIES

These cookies allow the Website to remember choices you make (such as your
preferences, language, or the region you are located in) and provide enhanced,
more personal features. These cookies can also be used to remember changes you
have made to text size, fonts, and other parts of web pages that you can
customize. The information these cookies collect may be anonymized, and they
cannot track your browsing activity on other websites.

TARGETING OR ADVERTISING COOKIES

These cookies, which may be placed on your device by us or our trusted third
party service providers, remember that you have visited a website and use that
information to provide you with advertising which is tailored to your interests.
They are also used to limit the number of times you see an advertisement as well
as help measure the effectiveness of the advertising campaign. They remember
that you have visited a website. It may be disclosed to third parties, such as
advertisers, that you have visited our website. Although this type of cookies
can track your activity around the Internet, they cannot identify you
personally. Without these cookies, online advertising you encounter will be less
relevant to you and your interests. We do not sell your personal information or
cookie data to third parties, such as advertisers.

WEB BEACONS

When you visit the Website, your device may receive one or more “web beacons” in
order to assist us with delivering cookies, to collect anonymous information
about the use of the Website by our users, and to deliver customized or targeted
content to you on the Website and through our partners. Web beacons (also
referred to as “tracking pixels,” “1x1 gifs,” “single-pixel gifs,” “pixel tags,”
or “action tags”) are graphic images, usually no larger than a 1x1 pixel, placed
at various locations on the Website. They also help us identify browser types,
search terms that bring users to the Website, and the domain names of websites
that refer traffic to us. We also utilize web beacons to provide us with more
information on any emails we send out. In particular, a web beacon in an email
communication will send us information to let us know that you have received,
opened, or acted upon an e-mail you have chosen to receive from us.

JAVASCRIPT TAGS/PIXELS

These are used by us to collect anonymous information about the use of the
Website by our users, and to deliver customized or targeted content to you on
the Website and through our partners. We may use JavaScript tags to anonymously
track how visitors interact with the Website, including where they came from and
the manner in which they use the Website.

By using the Website, you agree that we can place these types of cookies on your
device.

Some people find the idea of a website storing information on their device
intrusive. If you would prefer to opt out of cookies, it is possible to manage
them by changing the cookie settings on your device, in your browser settings.
Existing cookies that have already been set can be deleted from your device. You
can also block some or all cookies. However, you should be aware that you might
lose some features and functionality of the Website if you do so. If you need
assistance with your cookie settings, consult the help menu within your browser.
For more detailed information about cookies and how to manage and delete them,
visit www.aboutcookies.org.

The Website may contain links to third party sites, and we recommend and
encourage you to read the privacy policies posted on those third party sites.
Absolute is not responsible for the privacy policies or practices of any third
party.

By using the Website, you will be deemed to have consented to the collection,
use, and disclosure of your personal information by Absolute in accordance with
this Policy.


CONSENT

As a general principle, Absolute will obtain your consent before collecting,
processing, storing, using, or disclosing your personal information for any
purpose other than as identified in this Policy. Such consents may be included
in our license or other agreement with you. Absolute will make an exception only
where legal, medical, or security reasons make it impossible or impractical to
obtain consent, as discussed further below. We will make reasonable efforts to
ensure you understand how your personal information may be used or disclosed. If
Absolute plans to use previously-collected personal information for a new use
that is incompatible with the original purpose, you will be informed of the new
purpose, and we will obtain consent from you prior to this new use.

The form of consent can vary, depending on the sensitivity of the information
and the circumstances. Consent may be express or implied depending on the nature
of the personal information or the use, and depending on applicable privacy
laws. At times, consent for one use can fairly be implied to include consent for
other included or related uses. When determining the appropriate form of
consent, Absolute will be guided by what a reasonable person would consider fair
and appropriate in the circumstances.

Your consent may be provided to Absolute orally, in writing, or electronically,
either personally or through an authorized individual. Consent can be implied
(where not prohibited by applicable privacy laws) when you are informed that
information will be used for certain purposes and you submit the information
with this knowledge, or consent can be implied where the purpose for collecting,
using, or disclosing the personal information would be considered obvious and
you voluntarily provide personal information for that purpose.

Absolute may collect, use or disclose personal information without your
knowledge or consent in the following limited circumstances:

 * when the collection, use, or disclosure of personal information is permitted
   or required by law (including via subpoenas, search warrants, court orders,
   or government/regulatory orders);
 * in an emergency that threatens an individual’s life, health, or personal
   security;
 * when the personal information is available from a public source (e.g., a
   telephone directory or website);
 * when we require legal advice from a lawyer;
 * for the purposes of collecting a debt;
 * in connection with criminal justice, taxation, or regulatory activities;
 * to protect ourselves from fraud or to protect the rights and property of
   Absolute;
 * to investigate an anticipated breach of an agreement or a contravention of
   law; or
 * in the event of a reorganization, merger, or sale of Absolute.

Subject to certain exceptions (e.g., where the personal information is necessary
to provide the Services or the withdrawal of consent would frustrate the
performance of a legal obligation), you may withdraw or refuse to provide your
consent to Absolute, or request that your personal information be removed from
our databases and records, by giving reasonable notice. All communications with
respect to the withdrawal of consent should be made in writing and addressed to
Absolute’s Privacy Officer.

If you refuse or withdraw consent, or request that your personal information be
removed from our databases and records, Absolute will make you aware of the
likely consequences of this action. In some cases, it may prevent Absolute from
providing you with the Services (or a portion thereof).


LIMITED COLLECTION

Absolute will restrict its collection of personal information to that
information which is necessary and relevant for the legitimate purposes
identified. Absolute will not collect excessive personal information, and will
limit the purposes of collection to what a reasonable person would consider fair
and appropriate in the circumstances. Absolute will collect personal information
only by fair and lawful means, will be transparent, up-front, and open with you,
and will communicate in a manner that is clear and reasonably understood.


LIMITED USE, DISCLOSURE AND RETENTION

Absolute will use and disclose personal information only as described in this
Policy, for the purposes for which it was collected, as agreed by you, and/or
without your consent for the limited circumstances listed above in the section
titled Consent. We will not use or disclose personal information for any
additional purpose that is incompatible with the original purpose unless we
obtain consent to do so. We do not sell your personal information to third
parties, including advertisers.

Absolute may share personal information with our employees, contractors,
consultants, affiliates, service providers, business partners, and other parties
who require such information to assist us with providing you with the Services.

The use, collection, and disclosure of personal information may involve Absolute
transferring personal information across borders. If this occurs, we will comply
with all applicable data transfer and data sovereignty laws.

Absolute will retain your personal information only for as long as necessary to
fulfill the purposes for which it was collected, as required for Absolute’s
legitimate business purposes, and/or to comply with applicable legal, tax, or
regulatory requirements. After this time, any personal information you have
provided to us will be destroyed, deleted, or anonymized.

Absolute may use and disclose aggregated and anonymous or de-identified
information to third parties, including the general public. For example, we may
analyze and publish reports on usage and performance trends or statistics from
across our global customer base for information or marketing purposes, but only
after we have removed any personal information that would identify or be
associated with any particular individual or customer. This type of aggregated
and anonymous or de-identified data can help Absolute to improve our products,
services, and advertising, and it can be used by customers and the public to
better understand trends in the industry. We will never sell this aggregated
data.


ACCURACY

Absolute will make reasonable efforts to ensure that the personal information
collected and used by us is accurate, complete, and up-to-date to meet the
purposes for which it is collected and used. Absolute does not routinely update
personal information unless it is necessary to meet the purposes for which it is
collected. Absolute therefore relies on you to keep your applicable personal
information accurate and current.

You may request a correction to your personal information in order to ensure its
accuracy and completeness. Any request to correct personal information must be
made in writing to Absolute’s Privacy Officer and must provide sufficient detail
to identify the personal information and the correction being sought.

If your personal information is demonstrated to be inaccurate or incomplete, we
will correct the information as required and send the corrected information to
any third party to whom we disclosed the personal information in the previous
year. If the correction is not made, we will note your correction request in the
relevant records.


SAFEGUARDING PERSONAL INFORMATION

Absolute will make reasonable security arrangements and use appropriate
technical and organizational measures to protect all personal information under
our control (regardless of the format in which it is held) against unauthorized
access, loss, theft, collection, use, disclosure, duplication, modification,
disposal, or similar risks, by both individuals outside of Absolute as well as
within. The types of security safeguards that we use vary, depending on the
nature and sensitivity of the personal information, the harm that might result
from its improper use or loss, and how it is stored (e.g., in paper or
electronically). Absolute’s security safeguards include locked filing cabinets,
physically secured offices where personal information is held, limited employee
access, the use of IDs, passwords, restricted servers, firewalls, and encryption
for electronic files, as well as contractual requirements for service providers
to provide comparable security measures.

Absolute will use appropriate security measures when disposing of and destroying
personal information, such as shredding documents and deleting electronically
stored information, in order to prevent unauthorized access.

Absolute trains all staff who handle personal information on the importance of
and our procedures for maintaining confidentiality. All employees, contractors,
consultants, and service providers of Absolute who are provided access to
personal information on behalf of Absolute are required to be familiar with and
comply with the provisions of this Policy and applicable laws.

Absolute will continually monitor compliance with this Policy and will
investigate any suspected breaches swiftly and effectively. If a breach is found
to have occurred, Absolute will comply with all applicable data breach laws,
including notifying relevant individuals and regulatory bodies where required.
Absolute and its employees will respond promptly and in accordance with
applicable laws to any notices or demands issued by a Privacy Commissioner or
similar regulatory body in any relevant jurisdiction. Absolute will also
continually review and update our security policies and controls as technology
changes to ensure ongoing personal information security.


OPENNESS

This Policy is available to the public on the Website so that information about
our policies and practices relating to the management of information is readily
available to everyone.


REQUESTS FOR ACCESS

You have certain rights to access your personal information, subject to limited
exceptions under applicable laws such as solicitor-client privilege, disclosure
that would reveal personal information about another person, legal obligations,
and proprietary rights. Absolute’s Privacy Officer can assist you with any such
request. Such a request may include:

 * identification of and access to any or all of your personal information under
   Absolute’s custody or control;
 * an explanation of how that personal information is or has been collected,
   used, or disclosed by Absolute; and/or
 * the names of any individuals and organizations to which your personal
   information has been disclosed by Absolute.

All requests should be made in writing (by mail or email), provide sufficient
detail to identify the information being sought, and be directed to Absolute’s
Privacy Officer. Absolute’s Privacy Officer may require further information
defining the request more succinctly.

We will respond to written requests within 30 days of receiving such request, or
sooner if required by applicable laws. We will either make the requested
information available within that time period, or provide written notice of an
extension where additional time is required to fulfill the request. If Absolute
cannot fulfill your request in full or in part, you will be provided with a
response in writing that documents the reason for refusal and the recourse
available to you.

A minimal fee may be charged for providing access to personal information, where
permitted under applicable law. Where a fee applies, we will inform you of the
cost and request further directions from you on whether or not we should proceed
with your request.

See below under CCPA Compliance (California) for specific data access and data
deletion rights applicable to our California consumer customers under the
California Consumer Privacy Act (the "CCPA").


GDPR COMPLIANCE (EUROPEAN UNION AND EUROPEAN ECONOMIC AREA)

This section applies specifically to Absolute customers residing or carrying on
business in the European Union or European Economic Area, where the GDPR (or
local legislation implementing the GDPR) applies.

Absolute will be the Processor and you will be the Controller (as those terms
are defined in the GDPR) with respect to any personal information that Absolute
processes on your behalf through your use of the Services or Mobile Apps.
Absolute will comply with its obligations as Controller under the GDPR with
respect to personal information processed by Absolute on your behalf.

For Absolute’s consumer customers (i.e., individuals who purchase our products
for their own personal use), you have certain rights under the GDPR which you
may exercise by contacting Absolute’s Privacy Officer. Absolute will respond to
such requests in accordance with its obligations under the GDPR.

As mentioned in the first section of this Policy, the Services and the Mobile
Apps may be used by Absolute’s non-consumer customers (i.e., corporations,
schools, healthcare organizations, governments, or other organizations) to
collect personal information about individuals. If you are an individual who
believes that one of Absolute’s customers has collected personal information
about you through its use of the Services or Mobile Apps and you wish to
exercise any of the rights under the GDPR, your request should be directed to
that customer, not to Absolute.


CCPA COMPLIANCE (CALIFORNIA)

This section applies specifically to Absolute’s consumer customers (i.e.,
individuals who purchase our products for their own personal use) who reside in
California. California consumers with disabilities may access this policy in an
alternative format by sending an email to: privacy@absolute.com.

For purposes of this CCPA Compliance section, “Personal Information” means
anything that identifies, relates to, describes, is reasonably capable of being
associated with, or could be reasonably linked, directly or indirectly, with a
particular California consumer or household.


ABSOLUTE DOES NOT AND WILL NOT SELL PERSONAL INFORMATION.

The categories of Personal Information we collect about California consumers
together with our sources of this information, business purposes for collecting
this information and entities with whom we share this information are described
in the Mobile Apps and the Website and Use of Cookies sections above.


RIGHT TO KNOW

California consumers have the right to know about the Personal Information we
collected and/or disclosed about you during the prior 12 months. Specifically,
you have a right to know:

 * the specific pieces of Personal Information we have collected about you and
   your household; and
 * the categories of Personal Information we have collected about you and your
   household, including the categories of sources from which your Personal
   Information was collected, business or commercial purposes for which your
   Personal Information was collected, the categories of third parties to whom
   we sold or disclosed the categories of Personal Information for a business
   purpose, and the business or commercial purpose for selling or disclosing
   your personal information to a third party.

You can obtain your Personal Information that we have collected and/or disclosed
by submitting a verifiable written request to us by  clicking here  and
completing the online questionnaire or by calling us at our toll-free telephone
number of 1-888-999-9857. You can also complete a written request form at one of
our physical locations. If you have questions about this process, please direct
them to privacy@absolute.com. Absolute will require you to verify your identity
in accordance with the provisions of the CCPA.

Within 14 days of receiving your request to know, we will confirm receipt of
your request and provide information about how we will process your request,
including a description of our process to verify your identity and when you
should expect our response. Generally, we will respond to your request within 45
days and provide you the requested Personal Information by mail or a readily
usable electronic format. Under certain circumstances, we may take up to 90 days
to respond to your request. In these circumstances, we will provide you with
notice and an explanation of the reason we will take more than 45 days to
respond to your request.

If you request to obtain specific pieces of your Personal Information and we are
unable to verify your identity, we will deny your request and inform you that we
cannot verify your identify and explain why we have no reasonable method to
identify you. However, we will treat your request as a request to obtain the
categories of Personal Information we collect, disclose, and/or sell as
described below.

If you request to obtain the categories of Personal Information we have
collected and/or disclose and we are unable to verify your identity, we will
deny your request, inform you that we cannot verify your identify, and direct
you to this Policy which describes our general business practices regarding our
collection and maintenance of Personal Information. We will also explain why we
have no reasonable method to identify you.

By law, we can deny your request to know specific pieces of your Personal
Information, in whole or in part, if it conflicts with US federal or state law.
If we deny your request for these reasons, we will notify you that your request
has been denied and explain the reasons for the denial. If your request in
denied only in part, we will disclose the remainder of the Personal Information
you requested.

By law, we cannot provide you with specific pieces of your Personal Information
if the disclosure creates a substantial, articulable, and unreasonable risk to
the security of your Personal Information. Additionally, we are prohibited by
law from disclosing to you your Social Security number, driver’s license number,
or other government-issued identification number, financial account information,
any health insurance or medical identification number, an account password, or
security questions and answers (each if and as applicable to our business).


RIGHT TO DELETE

You have the right to request us to delete the Personal Information that we have
collected or maintained about you and your household. You can request us to
delete your Personal Information by submitting a verifiable written request to
us by clicking here and completing the online questionnaire, or by calling us at
our toll-free telephone number of 1-888-999-9857, or by submitting a written
request to at one of our physical locations. If you have questions about this
process, please direct them to privacy@absolute.com. Absolute will require you
to verify your identity in accordance with the provisions of the CCPA.

Within 14 days of receiving your request to delete, we will confirm receipt of
your request and provide information about how we will process your request,
including a description of our process to verify your identity and when you
should expect our response. Generally, we will respond to your request within 45
days. Under certain circumstances, we may take up to 90 days to respond to your
request. In these circumstances, we will provide you with notice and an
explanation of the reason we will take more than 45 days to respond to your
request.

If we are able to verify your identity, we will delete your Personal Information
by one of the following deletion methods and will notify you of the deletion
method used:

 * permanently and completely erasing the Personal Information on our existing
   systems except our archived or back-up systems;
 * de-identifying the Personal Information; or
 * aggregating the Personal Information.

We may offer you the option to delete a select portion of the Personal
Information you requested to be deleted in addition to the option to delete all
of the Personal Information you requested to be deleted. If your Personal
Information is stored on or archived in our back-up systems, we will delete the
Personal Information as described above when our archived or back-up system in
next accessed or used. We will also direct our service providers to whom we have
provided your Personal Information to delete your Personal Information.

Prior to deleting your Personal Information, we will send you an email or call
you to confirm that you want your Personal Information deleted.

If we are unable to verify your identity, we will deny your request and inform
you that we cannot verify your identify. By law, we may also deny your request
to delete if retention of your Personal Information is necessary to:

 * complete our transaction with you, perform a contract with you, or if your
   Personal Information is reasonably anticipated within the contest of our
   ongoing business relationship with you;
 * detect security incidents, protect against malicious, deceptive, or illegal
   activity, or prosecute those responsible for such activity;
 * debug to identify and repair errors that impair existing intended
   functionality of our systems;
 * exercise free speech rights;
 * comply with the California Electronic Communications Privacy Act;
 * engage in public or peer-reviewed scientific, historical, or statistical
   research in the public interest;
 * enable solely internal uses that are reasonably aligned with your
   expectations;
 * comply with a legal obligation; or
 * otherwise use your Personal Information internally in a lawful manner that is
   compatible with the context in which you provided the information.

If we deny your request to delete, we will:

 * inform you that we have denied your request and describe the basis for the
   denial, including any legal exception permitting denial;
 * delete any Personal Information that is not subject to the legal exception
   above; and
 * refrain from using the Personal Information retained for any other purpose
   than provided for by that exception.

In responding to your request to delete, we will maintain a record of your
request for the legally required period of 24 months.


RIGHT TO NON-DISCRIMINATION

You have the right to receive our Services on equal terms regardless of whether
or not you exercise your rights under the CCPA.


RIGHTS REGARDING DIRECT MARKETING

Our California consumer customers may individually request information about our
disclosures of certain categories of Personal Information to our affiliates
and/or any third parties for their direct marketing purposes. We will provide a
list of the categories of Personal Information disclosed to our affiliates or
any third parties for their direct marketing purposes during the immediately
preceding calendar year, along with the names and addresses of these third
parties or affiliates. This request may be made by any individual no more than
once per calendar year. Individual California customers must submit their
requests to us either by email at privacy@absolute.com or write to our Privacy
Officer at the address listed in the Complaint Procedure below. We reserve our
right not to respond to requests submitted other than to the specified email or
mailing addresses.


USE BY CHILDREN

The Website, the Mobile Apps, and the Services are not intended for use by
minors. Absolute does not knowingly collect information about minors and
believes that minors should obtain their parents’ or legal guardians’ consent
before providing any personal information. If you believe that we have
mistakenly or unintentionally collected a minor’s personal information, please
contact Absolute’s Privacy Officer. By using the Website, the Mobile Apps, or
the Services, you represent that you are over the relevant age of majority.


COMPLAINT PROCEDURE

Complaints, concerns, or inquiries about Absolute’s privacy policies and
practices, including compliance with this Policy, should be made in writing to:

Privacy Officer / Data Protection Officer
Absolute Software Corporation
Suite 1400, Four Bentall Centre
1055 Dunsmuir Street
Vancouver, B.C. Canada, V7X 1K8

Tel: 604-730-9851 (ask for the Legal Department)
Fax: 604-730-2621 (attention to the Legal Department)
E-mail: privacy@absolute.com

Specific details about the inquiry or complaint must be provided. All complaints
will be investigated and will be responded to in accordance with applicable
laws. If Absolute’s Privacy Officer is unable to address your concerns, the
issue may be escalated to the office of Absolute’s Chief Executive Officer or to
the relevant Privacy Commissioner or similar regulatory authority for your
jurisdiction (for example, in British Columbia, the Information and Privacy
Commissioner for British Columbia).


EFFECTIVE DATE AND UPDATES

This Policy was initially published effective January 6, 2004 and was updated in
April 2014 and April 2016.

A further update to this Policy was made in October 2017, when a paragraph
regarding the use of aggregated, anonymous, or de-identified information was
inserted at the end of the section titled Limited Use, Disclosure, and
Retention.

A further update to this Policy was made in May 2018, when changes were made to
ensure further transparency and compliance with the GDPR. More specifically, (i)
we added new sections titled GDPR Compliance (European Union and European
Economic Area) and Use By Children, (ii) we added additional language in the
section titled Legal Basis and Purposes for Collecting Personal Information to
ensure greater openness and transparency about how and why we collect personal
information, and (iii) we added language clarifying that individuals who believe
one of Absolute’s customers has collected personal information about them
through that customer’s use of the Services should make any requests about that
personal information directly to that party, not to Absolute.

A further update to this Policy was made in January 2020 when, primarily,
changes were made to address the CCPA, in the new section titled CCPA Compliance
(California).

A further update to this Policy made on September 16 2022. When additional
changes were made in the CCPA and GDPR section to automate consumers requests
regarding the handling of their personal information





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