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ALATION WORLDWIDE PRIVACY POLICY

Version: August 8, 2024

This Privacy Policy describes the data privacy practices of Alation, Inc.
(“Alation,” “we,” “us,” or “our”). This Privacy Policy applies to information we
collect and use about you when you access or use an Alation website or other
online or offline Alation services.  We refer to these products and services
collectively as the “Services.”

PLEASE READ THIS PRIVACY POLICY CAREFULLY TO UNDERSTAND HOW WE HANDLE YOUR
INFORMATION. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, PLEASE DO NOT USE THE
SERVICES.

This Privacy Policy contains the following sections:

 * The Information We Collect

 * How We Use Your Information

 * Legal Bases for Use of Your Information

 * Cookies and Similar Technologies

 * Online Analytics and Advertising

 * How We Disclose Your Information

 * Retention of Your Information

 * Your Rights and Choices

 * Third-Party Links and Features

 * International Users

 * How We Protect Your Information

 * Additional Privacy Information for California Residents

 * Changes to Our Privacy Policy

 * Alation Contact Information


THE INFORMATION WE COLLECT

1. Information You Provide to Us

We collect a variety of information that you provide directly to us. For
example, we collect information from you through:

 * The Services you use

 * Requests or questions you submit to us via online forms, email, or otherwise

 * Uploads or posts to the Services

 * Requests for customer support and technical assistance

The types of data we may collect directly from you include:

 * Email address

 * First and last name

 * Information about how the Services are implemented and used

 * Information about your support and customer success interactions with us

 * Information provided in responses to surveys we conduct

 * Any other information you choose to directly provide to us in connection with
   your use of the Services

2. Information We Collect Through Automated Means

When you use our Services, we collect certain information as described in this
Section. As discussed further below, we and our service providers (which are
third-party companies that work on our behalf), may use various technologies,
including cookies and similar tools, to assist in collecting this information.

Specifically, when you use our website, we may collect and analyze information
such as your IP address, browser type, browser language, operating system,
software, and hardware attributes (including device IDs) referring and exiting
pages and URLs, files you download, domain names, pages viewed and the order of
those pages, the date and time you used the Services, error logs, and other
similar information. When you use the Services, we may also collect general
location information (e.g., IP address, city/state, and or postal code
associated with an IP address) from your computer or mobile device.

3. Information We Collect from Others

We may receive additional business information such as demographic and
statistical information from third parties, such as business partners,
marketers, researchers, analysts, and other parties that we may attribute to you
based on your assignment to certain statistical groups. We use this information
to supplement the information we collect directly from you to derive your
possible interests to provide more relevant experiences for you and improve our
products, analytics, advertising, and products. We obtain contact details and
other personal information regarding media contacts and influencers from a
variety of sources including Cision. If you wish to know more about how such
information is collected and used, please refer to Cision’s privacy notice here.


HOW WE USE YOUR INFORMATION

We, or our service providers, use your information for various purposes
depending on the types of information we have collected from and about you, to:

 * Respond to your request for information and provide you with more effective
   and efficient service

 * Contact you by email, postal mail, or phone regarding Alation and partner
   products, services, surveys, research studies, promotions, special events,
   and other subjects that we think may be of interest to you

 * Customize the content you see on the Services

 * Help us better understand your interests and needs and improve the Services,
   including through research and reports, and test and create new products,
   features, and services

 * Secure our Services and resolve technical issues being reported

 * Comply with any procedures, laws, and regulations that apply to us where it
   is necessary for our legitimate interests or the legitimate interests of
   others

 * Establish, exercise, or defend our legal rights where it is necessary for our
   legitimate interests or the legitimate interests of others

Note that we may use artificial intelligence and large language models and tools
to assist us in processing your information for these purposes.

Combined Information. For the purposes discussed in this Privacy Policy, we may
combine the information that we collect through the Services with information
that we receive from other sources, both online and offline, and use such
combined information in accordance with this Privacy Policy.

Aggregated/Anonymized Data. We may aggregate and/or anonymize information
collected through the Services so that such information does not identify you as
the source of the information. We may use such information to improve the
Services, for research and marketing purposes, and may also disclose such data
to third parties, including advertisers, promotional partners, customers, and
sponsors.


LEGAL BASES FOR USE OF YOUR INFORMATION

The legal bases for using your information as set out in this Privacy Policy are
as follows:

 * Where use of your information is necessary to perform our obligations under a
   contract with you (for example, to comply with: the terms of service of our
   websites or a purchase you made)

 * Where use of your information is necessary for our legitimate interests or
   the legitimate interests of others (for example, to provide security for our
   website and applications; operate our business and our Services; receive
   payments; comply with legal requirements and defend our legal rights; and
   prevent fraud)

 * Where we have a reason to process the data in accordance with EU Member State
   laws

 * Where we have your consent to engage in a particular processing activity


COOKIES AND SIMILAR TECHNOLOGIES

To collect the information in the “Information We Automatically Collect” section
above, we and our service providers may use Internet server logs, cookies,
tracking pixels, and other similar tracking technologies. We use these
technologies to offer you a more tailored experience in the future, by
understanding and remembering your particular browsing preferences. Cookies are
small text files that are placed on your computer or mobile device when you
visit a site, that enables us to: (i) recognize your computer; (ii) store your
preferences and settings; (iii) understand the web pages of the Services you
have visited; (iv) enhance your user experience by delivering and measuring the
effectiveness of content and advertising tailored to your interests; (v) perform
searches and analytics; and (vi) assist with security and administrative
functions.



We may also gather information through other methods as we adopt additional
technologies.

Please note that you can change your settings to notify you when a cookie is
being set or updated, or to block cookies altogether. Please consult your
browser's “Help” section for more information (e.g., Internet Explorer; Google
Chrome; Mozilla Firefox; or Apple Safari). Please note that by blocking,
disabling, or managing any or all cookies, you may not have access to certain
features or offerings of the Services. For more information on cookies, please
view our cookie notice here.


ONLINE ANALYTICS AND ADVERTISING

1. Analytics

We may use third-party web analytics services (such as those of Google
Analytics) on our Services to collect and analyze usage information through
cookies and similar tools; engage in auditing, research, or reporting; assist
with fraud prevention; and provide certain features to you. You may install the
Google Analytics Opt-out Browser Add-on by clicking here to prevent Google
Analytics from using your information for analytics. If you receive email from
us, we may use certain analytics tools, such as clear GIFs to capture data such
as when you open our message or click on any links or banners our email
contains. This data allows us to gauge the effectiveness of our communications
and marketing campaigns.

2. Online Advertising

If you are interested in information about tailored browser advertising and how
you can generally control cookies from being put on your computer to deliver
tailored advertising, you may visit the Network Advertising Initiative’s
Consumer Opt-Out link, the Digital Advertising Alliance’s Consumer Opt-Out link,
or Your Online Choices to opt-out of receiving tailored advertising from
companies that participate in those programs. To opt out of Google Analytics for
display advertising or customize Google display network ads, visit the Google
Ads Settings page. We do not control these opt-out links or whether any
particular company chooses to participate in these opt-out programs. We are not
responsible for any choices you make using these mechanisms or the continued
availability or accuracy of them.  You can also opt out of certain online
advertising activities by following the instructions in the "Your Rights and
Choices" section below.

Please note that if you exercise the choices above, you may still see
advertising when you use the Services, but it will not be tailored to you based
on your online behavior over time.

3. Notice Concerning Do Not Track

Do Not Track (“DNT”) is a privacy preference that users can set in certain web
browsers. We are committed to providing you with choices about the information
collected on our website for third-party purposes, and that is why we provide
the variety of opt-out mechanisms listed above. However, we do not currently
recognize or respond to browser-initiated DNT signals. To learn more about Do
Not Track, you can do so here.  Please note that Do Not Track is a different
functionality from the legally required browser-based global privacy control
signal discussed below, which Alation does honor in accordance with applicable
legal obligations.


HOW WE DISCLOSE YOUR INFORMATION

Alation will disclose your information in the following ways:

 * Affiliates and Subsidiaries. We may disclose the information we collect
   within the Alation family to deliver products and services to you, ensure a
   consistent level of service, and enhance our products, services, and your
   customer experience.

 * Service Providers. We provide access to or disclose your information to
   select third parties who perform services on our behalf. They have access to
   perform these services but are prohibited from using your information for
   other purposes. They provide various services to us, including billing,
   sales, marketing, product content and features, advertising, analytics,
   research, customer service, data storage, security, fraud prevention, payment
   processing, and legal services.

 * Protection of Alation and Others. By using the Services, you acknowledge and
   agree that we may access, retain and disclose the information we collect and
   maintain about you if required to do so by law or in a good faith belief that
   such access, retention or disclosure is reasonably necessary to: (a) comply
   with legal process (e.g. a subpoena or court order); (b) enforce our Terms of
   Service, this Privacy Policy, or other contracts with you, including
   investigation of potential violations thereof; (c) respond to claims that any
   content violates the rights of third parties; (d) respond to your requests
   for customer service; and/or (e) protect the rights, property or personal
   safety of Alation, its agents and affiliates, its users and/or the public.
   This includes exchanging information with other companies and organizations
   for fraud protection, and spam/malware prevention, and similar purposes.

 * Business Transfers. As we continue to develop our business, we may buy,
   merge, or partner with other companies. User information may be among the
   transferred assets in such transactions (including in contemplation of such
   transactions). If a portion or all of our assets are sold or transferred to a
   third party, customer information (including your email address) would likely
   be one of the transferred business assets. If such transfer is subject to
   additional mandatory restrictions under applicable laws, we will comply with
   such restrictions.

 * Aggregate/Anonymous Information. From time to time, we may disclose
   Aggregated and/or Anonymized Information about the use of the Services, such
   as by publishing a report on usage trends. The disclosure of such data is
   unrestricted.

Alation may also disclose your information to a third party when you
affirmatively consent to such disclosure.


RETENTION OF YOUR INFORMATION

We keep your information for no longer than necessary for the purposes for which
it is processed. The length of time we retain information depends on the
purposes for which we collect and use it and/or as required to comply with
applicable laws.


YOUR RIGHTS AND CHOICES

You have certain rights with respect to your information as further described in
this section.

1. Your Legal Rights

If you would like further information in relation to your legal rights under
applicable law or would like to exercise any of them, please contact us using
the information in the “Contact Information” section below at any time. Your
local laws (e.g., in Europe or California) may permit you to request that we:

 * provide access to and/or a copy of certain information we hold about you

 * provide you with information about categories of information we collect or
   disclose about you; the categories of sources of such information; the
   business or commercial purpose for collecting your information; and the
   categories of third parties to which we disclose your information. For your
   convenience and so you don’t have to request it, we’ve included that
   information in this Policy.

 * prevent the processing of your information for direct-marketing purposes
   (including any direct marketing processing based on profiling)

 * update information which is out of date or incorrect

 * delete certain information which we are holding about you

 * restrict the way that we process and disclose certain of your information

 * transfer your information to a third-party provider of services

 * revoke your consent for the processing of your information

If you request to exercise these rights, we will need to verify your identity
and may need to verify your relationship with Alation for security and to
prevent fraud. We may take additional steps to verify that you are authorized to
make the request. If you are an end user of Alation’s services and not a direct
customer of Alation (for example, your company uses Alation and you’re an
employee or authorized representative of that company), you should direct
requests relating to your information to the administrator of your company’s
Alation account. We will redirect you to your administrator or notify the
administrator directly. To exercise your privacy rights, please make a request
by completing this form.  We will not discriminate against you for exercising
these rights.

Please note, however, that certain information may be exempt from such requests
in some circumstances, including if we need to keep processing your information
for our legitimate interests or to comply with a legal obligation.  Depending on
applicable law, you may have the right to appeal our decision to deny your
request.  If we deny your request, we will provide you with information on how
to appeal the decision, if applicable, in our communications with you.

Notice of Right to Opt-Out of Sales of Personal Information and
Sharing/Processing of Personal Information for Targeted Advertising Purposes

We provide information about your device and online browsing activities to
third-party advertising providers for targeted advertising and related purposes,
so that we can provide you with more relevant and tailored ads regarding our
Services. The disclosure of your information to these third parties to assist us
in providing these services may be considered a “sale” of personal information
under applicable law or the processing/sharing of personal information for
targeted advertising purposes.

If you would like to opt out of our online disclosure such as through cookie and
pixel technology of your personal information for purposes that could be
considered “sales” for those third parties' own commercial purposes, or
“sharing” for purposes of targeted advertising, please click here. You can also
submit a request to opt out of our offline disclosures of information that are
subject to applicable opt-out rights by clicking here.

Please note that if you have a legally-recognized browser-based opt-out
preference signal turned on via your device browser, (e.g., global privacy
control) we recognize such preference in accordance with applicable law.

2. Marketing Communications 

You may instruct us not to use your contact information to contact you by email,
postal mail, or phone regarding products, services, promotions and special
events that might appeal to your interests by contacting us using the
information below. In commercial email messages, you can also opt-out by
following the instructions located at the bottom of such emails. Please note
that, regardless of your request, we may still use and disclose certain
information as permitted by this Privacy Policy or as required by applicable
law. For example, you may not opt out of certain operational emails, such as
those reflecting our relationship or transactions with you.

To exercise your Data subject rights, click here.


THIRD-PARTY LINKS AND FEATURES

The Services contain links to third-party websites such as social media sites,
and also contain third-party plug-ins (such as the Facebook “like” button and
Twitter “follow” button). If you choose to use these sites or features, you may
disclose your information not just to those third parties, but also to their
users and the public more generally depending on how their services function. We
are not responsible for the content or practices of those websites or services.
The collection, use, and disclosure of your information will be subject to the
privacy policies of the third-party websites or services, not this Privacy
Policy. We urge you to read the privacy and security policies of these third
parties.


INTERNATIONAL USERS

The information discussed in this Policy is processed in the United States by
Alation, whose principal office in the United States is located at 3 Lagoon
Drive, Suite 300, Redwood City, CA 94065. Your information will be processed in
the United States for the purposes described herein. As described above, we also
may subcontract the processing of your data to, or otherwise disclose your data
to, other members within Alation or our service providers in countries other
than your country of residence, including the United States, in accordance with
applicable law. Such third parties may be engaged in, among other things, the
provision of Services to you, the processing of transactions and/or the
provision of support services. By providing us with your information, you
acknowledge any such transfer, storage, or use.

If we provide any information about you to third-party information processors,
we will take appropriate measures to ensure such companies protect your
information adequately in accordance with this Privacy Policy. These measures
may include signing Standard Contractual Clauses (SCCs) in accordance with EU
and other data protection laws to govern the transfers of such data. For more
information about these transfer mechanisms, please contact us as detailed in
the “Contact Information” section below.

If applicable, you may complain to the data protection supervisory authority in
the country where you reside. Alternatively, you may seek a remedy through local
courts if you believe your rights have been breached.


HOW WE PROTECT YOUR INFORMATION

Alation takes technical and organizational security measures to protect the
information provided via the Services from loss, misuse, and unauthorized
access, disclosure, alteration, or destruction. However, no Internet or email
transmission is ever fully secure or error-free. Please remember this when
disclosing any information to Alation via the Internet.


ADDITIONAL PRIVACY INFORMATION FOR CALIFORNIA RESIDENTS

If you are a California resident, the California Consumer Privacy Act (“CCPA”)
requires us to provide you with the following additional information about: (1)
the purpose for which we use each category of “personal information” (as defined
in the CCPA) we collect; and (2) the categories of third parties to which we (a)
disclose such personal information for a business purpose, (b) “share” personal
information for “cross-context behavioral advertising,” and/or (c) “sell” such
personal information. Under the CCPA, “sharing” is defined as the targeting of
advertising to a consumer based on that consumer’s personal information obtained
from the consumer’s activity across websites, and “selling” is defined as the
disclosure of personal information to third parties in exchange for monetary or
other valuable consideration.  Our use of third-party online advertising
services, which are described in detail above,  may result in the disclosure of
online identifiers (e.g., cookie data, IP addresses, device identifiers, and
usage information) in a way that may be considered a “sale” or "sharing" under
the CCPA.

The following chart details these activities:

Category of personal information

Purposes of use

Categories of Third Parties to Which We Disclose this Personal Information

Categories of Third Parties to Which We “Share” and “Sell” this Personal
Information for Advertising/Analytics Purposes

Contact information

Provide the Services; Communicate with you; Marketing and advertising;
Personalize the Services; Improve the Services; Business Operations; With your
consent

Affiliated entities; Service providers; Online advertising and analytics
partners; Entities for legal purposes

Online advertising and analytics partners 

Customer service interaction information

Provide the Services; Communicate with you; Improve the Services; Business
Operations 

Affiliated entities; Service providers; Entities for legal purposes

We do not share/sell

Surveys and sweepstakes information

Provide the Services; Communicate with you; Marketing and advertising;
Personalize the Services; Improve the Services; Business Operations; With your
consent

Affiliated entities; Service providers; Entities for legal purposes

We do not share/sell

Internet network and device information

Provide the Services; Marketing and advertising; Personalize the Services;
Improve the Services; Business Operations; With your consent

Affiliated entities; Service providers; Online advertising and analytics
partners; Entities for legal purposes; 

Online advertising and analytics partners

User-generated content

Provide the Services; Communicate with you; Improve the Services; Business
Operations; With your consent

Affiliated entities; Service providers; Entities for legal purposes

We do not share/sell

For more information about each category of personal information, purpose of
use, and third parties to which we disclose personal information, please see the
"Information We Collect," "How We Use Your Information," and "How We Disclose
Your Information" sections of our Privacy Policy.

Your Choices Regarding “Sharing” and “Selling”: You have the right to opt out of
our  sale/sharing of your personal information for online analytics and
advertising by clicking here.  To opt out of the offline disclosure of your
information to third parties for these purposes, please click here. 

Other CCPA Rights.  If we ever offer any financial incentives in exchange for
your personal information, we will provide you with appropriate information
about such incentives.

The CCPA also allows you to limit the use or disclosure of your “sensitive
personal information” (as defined in the CCPA) if your sensitive personal
information is used for certain purposes.  Please note that we do not use or
disclose sensitive personal information other than for business purposes for
which you cannot opt out under the CCPA.

Please see the “Your Rights and Choices” section of our Privacy Policy above for
information about the additional rights you have with respect to your personal
information under California law and how to exercise them.

Retention of Your Personal Information. Please see the “Data Retention” section
above. 

California “Shine the Light” disclosure.  The California “Shine the Light” law
gives residents of California the right under certain circumstances to opt out
of the disclosure of certain categories of personal information (as defined in
the Shine the Light law) with third parties for their direct marketing purposes,
or in the alternative, that we provide a cost-free means for consumers to opt
out of any such disclosure.  We do not currently disclose your personal
information to third parties for their own direct marketing purposes.


CHANGES TO OUR PRIVACY POLICY

We reserve the right to amend this Privacy Policy at any time to reflect changes
in the law, our data collection and use practices, the features of our Services,
or technological advances. We will make the revised Privacy Policy accessible
through the Services, so you should review the Privacy Policy periodically. You
can know if the Privacy Policy has changed since the last time you reviewed it
by checking the “Last Updated” date included at the beginning of the document.
If we make a material change to the Policy, you will be provided with
appropriate notice in accordance with legal requirements. By continuing to use
the Services, you confirm that you have read and understood the latest version
of this Privacy Policy.


CONTACT INFORMATION

Please feel free to contact us if you have any questions about Alation’s Privacy
Policy or the information practices of the Services. You can reach us via
email, at privacy@alation.com, or by mail at 3 Lagoon Drive, Suite 300, Redwood
City, CA 94065.

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browser, mostly in the form of cookies. This information might be about you,
your preferences, or your device and is mainly used to make the site work as you
expect it to. The information does not usually directly identify you but can
give you a more personalized web experience. Because we respect your right to
privacy, you can choose not to allow some types of cookies. Click on the
different category headings to learn more and change our default settings.
However, blocking some types of cookies may impact your experience of the site
and the services we can offer.
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