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PRIVACY POLICY

December 5, 2023

Click here for PRIVACY NOTICE FOR CALIFORNIA RESIDENTS

This Privacy Policy describes the data handling practices of LiveAction, Inc.
and its affiliates (collectively, “LiveAction” or “we” or “us”). Maintaining the
trust of our customers and providing an exceptional customer experience are
LiveAction’s top priorities. We believe in respecting the personal privacy of
our customers and simply doing what is right.

At LiveAction, we are committed to safeguarding your personal information
through our compliance with this Privacy Policy. LiveAction is furthermore
firmly committed to comply with all applicable privacy and laws, including the
European Union’s General Data Protection Regulation (“GDPR”) and the California
Consumer Privacy Act, as amended by the California Consumer Privacy Act
(“CCPA”). LiveAction is a business-to-business provider of software products and
services (collectively, “Products”). This Privacy Policy describes the types of
information we may collect about visitors to our website (“Visitors”) and
individuals (“Customer Representatives”) acting on behalf of our business entity
customers (“Customers”) that use our Products and our practices for collecting,
using, maintaining, protecting, and disclosing that information.

We have drafted this Privacy Policy to be as clear and concise as possible.
Please read it carefully to understand our policies and practices regarding your
information and how we will treat it. By accessing or using this website or
using our Products, you agree to this privacy policy.

We have organized this Privacy Policy into the following sections:

 1.  Information you share with us
 2.  Information we collect from you
 3.  How we use your information
 4.  Legal grounds for processing your information
 5.  Information sharing and disclosure
 6.  Choices about our communications with you
 7.  Data security and retention
 8.  Your privacy rights, choices and disclosures, including those for Europe
     and California
 9.  Users outside the United States
 10. Privacy Policy changes
 11. Contact information

This Privacy Policy does not address: (1) personal information that is collected
by our Customers (either with or without the use of the Products) and provided
to LiveAction for processing (“Customer Information”). Such Customer Information
may include personal data of Customer’s employees, authorized users and
clients/customers. LiveAction’s processing of personal data contained in
Customer Information is governed by a separate data processing agreement between
LiveAction and the Customer. If you are an employee, authorized user or
client/customer of our Customer, please understand that LiveAction and Customer
are independent parties, and LiveAction has no control over the Customer’s
privacy practices; please review the privacy policy of the Customer to
understand the Customer’s practices and direct any questions, concerns, or data
rights requests to the Customer.

In addition, our website and our Products may contain applications and content
by third parties. This Privacy Policy does not apply to such applications and
third-party content. We encourage you to review the data privacy terms of any
third party providers you engage with.

1. Information You Share With Us.
If you communicate directly with LiveAction, LiveAction may collect and store
personally identifying information that you share with us, including, but not
limited to, your name, a home, business, or other address, billing address,
phone number, and email address, as well as other information that may be needed
to provide a service or information you requested. You may have provided or
provide such information (i) through forms you fill out on our website or
through your correspondence with us, (ii) if you have requested support from us,
(iii) through our blogs, webinars or social media channels or (iv) if you are
participating in a survey, contest or other promotional event we may offer from
time to time.

If you inquire about a career at LiveAction through the website’s careers page,
you will also be asked to provide additional information including your resume.
We utilize a third party provider to host our job applications and assist with
the application process which has their own terms of use and privacy policies,
and we encourage you to review those policies whenever you visit their websites
or interact with their platforms. We will use the personal data of job
applicants solely for employment evaluation purposes. Providing this information
is completely voluntary.

Our website contains links to other websites, but LiveAction is not responsible
for their privacy practices. We encourage you to learn about the privacy
policies of such third party partners you communicate with.

LiveAction does not intend to collect information from individuals who identify
themselves as under eighteen (18) years of age. No one under the age of 18 may
provide any personal information to or on the website or our Products.
LiveAction does not knowingly solicit personal information from children under
the age of 18 or send them requests for personal information. LiveAction will
not knowingly disclose personally identifiable information of children under 18
to any third party. If we learn we have collected or received personal
information from a child under 18 without verification of parental consent, we
will delete that information. If you believe we might have any information from
or about a child under 18, please contact us at legal@LiveAction.com.

2. Information We Collect From You.

As you navigate through and interact with our website, or use our Products,
subject to your settings and choices as discussed in this Privacy Policy, we may
use common data collection technologies to collect certain statistical
information. In particular, our Products may report telemetry data back to us.
Such information may include data about your network, including traffic data,
location data, logs, and other communication data, devices, internet connection,
browser type, internet service provider and operating system. We process and
analyze this information in order to build, run and continue to improve our
Products and in order to better understand our customers’ needs. The information
we collect through these tracking tools is statistical in nature, but may be
aggregated with personal information in order to help us to deliver a more
personalized website and Product, including by enabling us to estimate our
audience size and use patterns, store information about your preferences to
allow us to customize our website in accordance with your individual interests,
speed up your searches and to recognize you when you return to our website.

The processes we use for automated data collection may include:

Cookies. Cookies are small data files that certain websites write to your hard
drive when you visit them, and they record and store your information. A cookie
file can contain information such as a user ID that the site uses to track the
pages you’ve visited. The LiveAction website may use cookies to collect this
type of information to determine the usefulness of our website information to
our users and to see how effective our navigational structure is in helping
users reach that information.

Web Beacons. Web beacons also known as pixel tags are electronic images,
contained on a website that permit us to count users who have visited those
pages, to determine the effectiveness of our communications (e.g., whether you
opened an email), and for other website and marketing statistics.

Web Analytics. We also collect some information (ourselves or using third party
services) using web analytic tools. We use third-party services that use
tracking technologies to capture aggregate usage and volume statistics about
online activities over time and across our and third party websites and other
online services. We use Google Analytics to identify the frequency of use of
certain areas of our website and to identify preferences. For more information
regarding how Google collects, uses and shares your information, please visit
https://policies.google.com/technologies/partner-sites. You can deactivate
Google Analytics using a browser add-on if you do not wish the analysis to take
place. You can download the add-on here:
https://tools.google.com/dlpage/gaoptout?hl=en.

Social Media. We operate social media pages on third party networks and have
social media icons on our website. When you visit or link to our social media
pages, data is processed both by us and the applicable social media provider.
Social media providers are unaffiliated with us, and we are not responsible for
the content or privacy practices of social media providers. Social media
providers have their own terms of use and privacy policies, and we encourage you
to review those policies whenever you visit their websites or interact with
their platforms.

Recordings. From time to time our interactions with you will be conducted over
the telephone or video-conference, and such telephone calls and video
conferences may be recorded.

3. How We Use Your Information.

LiveAction uses information that you share with us or that we collect about you,
including personal information, for the following purposes:

 * To provide you with the Products you have requested from us, respond to your
   concerns and inquiries, and to provide maintenance and support;
 * To present our website and its contents to you and to personalize your
   experience on our website;
 * To help maintain the safety, security, and integrity of our website, Products
   and services, databases and other technology assets, and business;
 * For testing, research, analysis, and product development, including to
   develop and improve our website, products, and services;
 * As described to you when collecting your personal information;
 * To evaluate or conduct a merger, divestiture, restructuring, reorganization,
   dissolution, or other sale or transfer of some or all of our assets, whether
   as a going concern or as part of bankruptcy, liquidation, or similar
   proceeding, in which personal information held by us about you is among the
   assets transferred;
 * To keep you up to date on the latest Product announcements, software updates,
   special offers, changes to the website or other information we think you
   would like to hear about either from us or from our business partners — you
   may opt-out from receiving such communications by following the process
   described below;
 * To understand and analyze the usage trends of you and other users of our
   Products;
 * In anonymized form for internal purposes such as performing research and
   analysis and to provide reporting internally or externally;
 * To allow you to purchase and download Products and participate in their
   interactive features, when you choose to do so;
 * To better understand your needs and provide you with better Products;
 * To carry out our obligations and enforce our rights from any contracts
   entered into between you and LiveAction such as our license agreements or
   terms of use, including communications related to payments and changes to our
   terms, conditions and policies;
 * To respond to law enforcement requests and as required by applicable law,
   court order, or governmental regulations;
 * In any other way we describe to you at the time you provide the information
   or for which you have provided your consent; and for other legitimate
   business purposes.

The information you provide to LiveAction’s third party partners will also
enable such partners to let us know that you have contacted them. Such
communication information may be used to distribute information back to you
about LiveAction.

If you are using our Product, we may from time to time send you certain
communications such as service announcements or administrative messages. Such
communications are part of the functionality of our Product. You can therefore
not opt-out of receiving such Product communications.

4. Legal Grounds for Processing Your Information.

We rely on the following legal grounds to process your personal information:

Consent. Some uses of your personal data as described in this Privacy Policy are
subject to your consent, such as marketing email communications and the use of
non-necessary cookies.

Performance of a contract. We may need to collect and use your personal
information to enter into a contract with you and to perform services and
deliver Products that you request.

Legitimate Interests. We may use your personal information for our legitimate
interests to provide our Products and to improve our services and the content
contained thereon. We may use technical information as described in this Privacy
Policy and use personal information for our marketing purposes consistent with
our legitimate interests and any choices that we offer or consents that may be
required under applicable law.

Compliance with Legal Obligations. We may use your personal information as
necessary to comply with our legal obligations.

5. Information sharing and disclosure.

LiveAction is a provider of services headquartered in the United States, and as
such may need to share your personal information to other companies or people
(within or outside your country of residence) to operate our business, including
under the following circumstances: (i) to our subsidiaries and affiliated
companies; (ii) to LiveAction’s authorized partners and resellers to fulfill any
terms under your licensing relationship with us and to provide you with
technical and customer support; (iii) to third parties who perform services on
our behalf, including without limitation our technology providers, independent
contractors, support providers, and professional advisors; (iv) when we have
your consent to share the information; (v) to a buyer or other successor in the
event of a merger, divestiture, restructuring, reorganization or other sale or
transfer of some or all of LiveAction’s assets; (vi) if we want to keep you up
to date on the latest product announcements, software updates, special offers or
other information we think you would like to hear about (unless you have opted
out of these types of communications); (vii) to our job hosting provider(s) when
you apply for a position at LiveAction; (viii) to apply or enforce our license
agreement, terms of use and other agreements, including for billing and
collection purposes; (ix) as needed with the marketing and sales tools we use;
and (x) as specified in our Terms of Service and any contract between us and you
or your employer as necessary to carry out our contractual obligations.

LiveAction reserves the right to disclose your personally identifiable
information if required to do so by law, court order or legal process, including
to respond to any government or regulatory request or in the good-faith belief
that such action is reasonably necessary to (a) comply with legal process, (b)
respond to any claims against LiveAction, or (c) to protect the rights, property
or personal safety of LiveAction, its employees, its customers or the public —
this includes exchanging information with companies and organizations for the
purposes of fraud detection and credit risk reduction.

6. Choices About Our Communications With You.

We are excited about our Products and would like to tell you about updates and
new features from time to time. In case you prefer not to receive such
information from us or from third party partners we work with, we strive to give
you choices regarding whether or not you are contacted with direct marketing or
market research information from us. If you have provided personally
identifiable information to LiveAction, we will provide you with an opportunity
to limit promotional email communications from LiveAction by “opting-out” of
receiving direct marketing or market research information. When applicable, we
will provide you with the opportunity to “opt-in.” This means we will require
your affirmative action to indicate your consent before we use your information
for purposes other than the purpose for which it was submitted.

Some non-marketing communications may not be subject to a general opt-out, such
as communications about transactions, disclosures to comply with legal
requirements, software updates and other support-related information.

7. Data Security and Retention.

We have implemented industry-standard safeguards designed to secure your
personal information from accidental loss and from unauthorized access, use,
alteration, and disclosure. Any personal information you provide to us is stored
on our secure servers behind firewalls.

The safety and security of your information also depend on you. Where we have
given you (or where you have chosen) a password for access to certain parts of
our website or in our Product, you are responsible for keeping this password
confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the internet is not
completely secure. Although we do our best to protect your personal information,
we cannot guarantee the security of your personal information transmitted to our
website. Any transmission of personal information is at your own risk.

We retain the personal information we collect for so long as reasonably
necessary to fulfill the purposes for which the data was collected and to
perform our contractual and legal obligations. We will retain personal
information required to comply with privacy requests, to manage active accounts,
as required by law, in order to resolve disputes, or to enforce our agreements.
We will retain the personal information we process on behalf of our users as
directed by them. We may also retain copies of your personal information for
disaster recovery purposes, to prevent fraud or future abuse, or for our
legitimate business purposes.

8. Your Rights, Choices and Disclosures.

(a) General.
This section is subject to specific disclosures on privacy rights set forth
below. We are committed to facilitating the exercise of your rights granted by
the laws of your jurisdiction. Such rights generally include the right to
request the correction, modification or deletion of your personal information
and the right to opt out of the sale or sharing of your personal information (as
applicable). Subject to local law, you may have additional rights under the laws
of your jurisdiction regarding your personal data, such as the right to complain
to your local data protection authority and the right to appeal our decision
regarding a data access request. We will do our best to honor your requests
subject to any legal and contractual obligations, or if we believe the change
would violate any law or regulatory requirement, cause the information to be
incorrect or impose an undue hardship on us due to technical requirements.

We may deny your deletion request if retaining the information is necessary for
us or our service provider(s) to:

 * Complete the transaction for which we collected the personal information,
   provide a good or service that you requested, take actions reasonably
   anticipated within the context of our ongoing business relationship with you,
   fulfill the terms of a written warranty or product recall conducted in
   accordance with federal law, or otherwise perform our contract with you.
 * Detect security incidents, protect against malicious, deceptive, fraudulent,
   or illegal activity, or prosecute those responsible for such activities.
 * Debug products to identify and repair errors that impair existing intended
   functionality.
 * Exercise free speech, ensure the right of another consumer to exercise their
   free speech rights or exercise another right provided for by law.
 * Comply with the California Electronic Communications Privacy Act (Cal. Penal
   Code § 1546 et. seq.).
 * Engage in public or peer-reviewed scientific, historical, or statistical
   research in the public interest that adheres to all other applicable ethics
   and privacy laws, when the information’s deletion may likely render
   impossible or seriously impair the research’s achievement if you previously
   provided informed consent.
 * Enable solely internal uses that are reasonably aligned with consumer
   expectations based on your relationship with us.
 * Comply with a legal obligation.

Make other internal and lawful uses of that information that are compatible with
the context in which you provided it.

If you would like to make a request, contact us at legal@LiveAction.com or
submit the form located at https://liveaction.com/data-subject-request/. Section
(b) below describes the rights of those individuals located in the European
Union, the United Kingdom or another jurisdiction that has adopted laws
substantially similar to the European Union’s General Data Protection Regulation
(GDPR). Section (c) describes the rights of residents of California or another
jurisdiction that has adopted laws substantially similar to the California
Consumer Privacy Act.

(b) Your European Privacy Rights and Choices.
If you are located in the European Union, the United Kingdom or another
jurisdiction that has adopted laws substantially similar to the European Union’s
General Data Protection Regulation (GDPR), your privacy rights include the
following:

 * Transparency and the right to information. Through this policy we explain how
   we use and share your information. However, if you have questions or need
   additional information you can contact us any time.
 * Right of access, correction, restriction of processing, erasure. You may
   contact us to request information about the personal data we have collected
   from you and to request the correction, modification or deletion of such
   personal information, which requests we will do our best to honor subject to
   any legal and contractual obligations.
 * Right to withdraw your consent at any time. When we process your personal
   data based on your consent, you have the right to withdraw it at any time.
 * Right to object at any time. You have the right to object at any time to
   receiving marketing or promotional materials from us by either following the
   opt-out instructions in commercial e-mails or by contacting us, as well as
   the right to object to any processing of your personal data based on your
   specific situation. In the latter case, we will assess your request and
   provide a reply in a timely manner, according to our legal and contractual
   obligations. Some non-marketing communications are not subject to a general
   opt-out, such as communications about transactions and disclosures to comply
   with legal requirements.
 * Right to data portability. You have the right to data portability of your own
   personal data by contacting us.
 * Right not to be subject to an automated decision, including profiling. We do
   not make automated decisions using your personal data that may negatively
   impact you.
 * Right to lodge a complaint with a supervisory authority. If you consider that
   the processing of your personal data infringes your privacy rights according
   to the European Privacy regulation, you have the right to lodge a complaint
   with a supervisory authority, in the member state of your habitual residence,
   place of work, or place of the alleged infringement.

We endeavor to respond to a verifiable consumer request within thirty (30) days
of its receipt. If we require more time, we will inform you of the reason and
extension period in writing.

(c) California Disclosures.
California Consumer Privacy Act Disclosures. If you are a resident of California
or another state that has adopted laws substantially similar to the California
Consumer Privacy Act, as amended by the California Privacy Rights Act (“CCPA”),
you have the right to request:

 * The categories of personal information (including sensitive personal
   information if applicable) we have collected about you;
 * The categories of sources from which the personal information is collected;
 * The business or commercial purpose of collecting, selling or sharing personal
   information;
 * The categories of third parties with whom we share or sell personal
   information;
 * The categories of personal information about you that we have disclosed for
   business purposes; and
 * The specific pieces of personal information we have collected about you.

Additionally, you have the right:

 * To know the length of time we retain your personal information;
 * To request deletion of your personal information;
 * To request the correction of any inaccurate data;
 * To opt out of the sale or sharing of your information (if applicable);
 * To limit the use of sensitive personal information (if applicable); and
 * To not be discriminated against for exercising any of your CCPA/CPRA rights.

This Notice does not apply to employment-related personal information collected
from our California-based employees; such information is provided separately in
an employee handbook or other onboarding documentation.

We have collected the following categories of personal information within the
last twelve (12) months:

Personal Information Category Example Source of Personal Information Purpose for
Collecting the Personal Information To whom we disclose the Personal Information
Identifiers. A real name, alias, postal address, unique personal identifier,
online identifier, Internet Protocol address, email address, or other similar
identifiers Information you provide to us; Information we collect automatically;
Information collected from third party providers. See Sections 1, 2 and 3 above
See Section 5 above Personal information categories listed in the California
Customer Records statute (Cal. Civ. Code § 1798.80(e)) and not otherwise
addressed in this table Signature, social security number, physical
characteristics or description, telephone number, passport number, driver’s
license or state identification card number, insurance policy number, education,
employment, employment history, bank account number, credit card number, debit
card number, or any other financial information, medical information, or health
insurance information Information you provide to us See Sections 1 and 3 above
See Section 5 above Protected Classifications under California and federal law
Age (40 years or older), race, color, ancestry, national origin, citizenship,
religion or creed, marital status, medical condition, physical or mental
disability, sex (including gender, gender identity, gender expression, pregnancy
or childbirth and related medical conditions), sexual orientation, veteran or
military status, genetic information (including familial genetic information).
Information you provide to us; Information collected from third party providers
(such as our job application hosting providers). See Sections 1 and 3 above See
Section 5 above Commercial information Records of personal property, products or
services purchased, obtained, or considered, or other purchasing or consuming
histories or tendencies. Biometric information Genetic, physiological,
behavioral, and biological characteristics, or activity patterns used to extract
a template or other identifier or identifying information, such as,
fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke,
gait, or other physical patterns, and sleep, health, or exercise data. We do not
collect this information Internet or other similar network activity Browsing
history, search history, information on a consumer’s interaction with a website,
application, or advertisement Information you provide to us; Information we
collect automatically See Sections 1, 2 and 3 above See Section 5 above
Geolocation data that is sufficient to identify a precise physical location.
Physical location or movements. We do not collect this information Sensory data
Audio, electronic, visual, thermal, olfactory, or similar information. We do not
collect this Information. Professional or employment-related information Current
or past job history or performance evaluations Information you provide to us;
Information collected from third party providers (such as our job application
hosting providers). See Sections 1 and 3 above See Section 5 above Non-public
education information (per the Family Educational Rights and Privacy Act (20
U.S.C. Section 1232g, 34 C.F.R. Part 99)). Education records directly related to
a student maintained by an educational institution or party acting on its
behalf, such as grades, transcripts, class lists, student schedules, student
identification codes, student financial information, or student disciplinary
records. We do not collect this information. Inferences are drawn from other
personal information Profile reflecting a person’s preferences, characteristics,
psychological trends, predispositions, behavior, attitudes, intelligence,
abilities, and aptitudes. We do not collect this information.

Any sensitive data we collect is used only for a business purpose and not for
the purposes of inferring characteristics of a consumer.

We do not sell or share personal information for monetary consideration.
Personal data may be provided to our service providers, contractors and,
pursuant to Sections 1798.140(ad)(2)(A) and 1798.140(ah)(2)(A) of the CCPA, to
third parties. You may opt out of the use of cookies using your browser settings
and opt out of the use of Google Analytics Cookies by downloading the browser
add-on here: https://tools.google.com/dlpage/gaoptout?hl=en.

To exercise the rights described above, please submit a verifiable consumer
request to us by emailing us at legal@LiveAction.com or submit a request on our
website form located at https://liveaction.com/data-subject-request/. We will
ask for your name, email address and your country or state of residence. Only
you, or someone legally authorized to act on your behalf, may make a verifiable
consumer request related to your personal information. You may also make a
verifiable consumer request on behalf of your minor child. You may only make a
verifiable consumer request for access or data portability twice within a
12-month period. The verifiable consumer request must:

 * Provide sufficient information that allows us to reasonably verify you are
   the person about whom we collected personal information or an authorized
   representative
 * Describe your request with sufficient detail that allows us to properly
   understand, evaluate, and respond to it.

If the information we initially request from you is insufficient to verify your
identity and assess your privacy request, we may need to ask for additional
information. We cannot respond to your request or provide you with personal
information if we cannot verify your identity or authority to make the request
and confirm the personal information relates to you.

We will only use personal information provided in a verifiable consumer request
to verify the requestor’s identity or authority to make the request.

We endeavor to respond to a verifiable consumer request within forty-five (45)
days of its receipt. If we require more time, we will inform you of the reason
and extension period in writing.

Any disclosures we provide will only cover the 12-month period preceding the
verifiable consumer request’s receipt.

California’s “Shine the Light” law. Civil Code Section § 1798.83 permits users
of our website that are California residents to request certain information
regarding our disclosure of personal information to third parties for their
direct marketing purposes. To make such a request, please send an email to
legal@LiveAction.com.

California Do Not Track and Global Privacy Control Disclosures. We do not track
our customers over time and across third party websites to provide targeted
advertising on our website. Our website utilizes a tool designed to detect and
honor Global Privacy Control signals from visitors to our website in a
frictionless manner. If the website detects a Global Privacy Control signal, you
will see a message stating so. The website will automatically opt you out of
certain cookies depending on how you have set your signal. If the signal is set
to “not to share or sell my data”, then you will be automatically opted out of
all cookies except those that are strictly necessary. If the signal is set to
“Do Not Track”, then you will be automatically opted out of targeting cookies.
However, you will have the ability to override the automatic settings from your
GPC signal via the cookie banner that is presented on the website.

9. Users Outside the United States.

LiveAction is headquartered in the United States. If you are an individual from
the European Union, Canada or any other jurisdiction with laws or regulations
governing personal data collection, use, and disclosure that differ from United
States laws, please be advised that we may store the information we collect in
the United States which is not deemed an “adequate jurisdiction” by the European
regulatory authorities. By visiting our website or using our Products, you are
consenting to the transfer of your information from your jurisdiction to the
United States.

10. Privacy Policy Changes.

We may update this Privacy Policy from time to time and without prior notice to
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to contact us at Email: legal@LiveAction.com or at the following postal
addresses:

LiveAction, Inc
901 Campisi Way, Suite 222
Campbell, CA 95008

Alternatively, if you are in the UK or EU/EEA and would like to exercise your
rights or have questions about our processing of personal data, you may contact
our local representative for EU/EEA or the UK:

For the EU/EEA:
LiveAction France S.a.r.l.
1 Impasse Marcel Chalard
31100 Toulouse
France
legal@liveaction.com

For the UK:
LiveAction UK Limited
Suite 2, First Floor, Templeback
10 Temple Back, Bristol BS1 6FL
United Kingdom
legal@liveaction.com

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