PRIVACY POLICY: GLOBAL EMPLOYMENT COMPLIANCE

PRIVACY POLICY FOR EQUUS SOFTWARE AND GLOBAL EXPANSION

Last Updated: January 29, 2020. The following describes the Equus Software, LLC, along with, as applicable, any and all subsidiaries, affiliates, successors, and assigns (“Equus,” “we,” or “us”) privacy policy and the manner in which Equus handles information that it receives or collects specifically from individuals visiting this Website (“you” or “your”) that may constitute personal information. For clarity, the use of any Equus software products licensed by an Equus customer and any related subscriptions to Equus’ services (each a “Customer”) is subject to a separate agreement between Equus and such Customer (each a “Customer Agreement”).  Any personal information that may be processed by Equus pursuant to a Customer Agreement is governed by the terms of such Customer Agreement.  If you are an employee of a Customer of Equus, this Privacy Policy does not apply to you or your use of any products and/or services of Equus. Individual employees of Equus’ Customers who seek access to their data, or who seek to correct, amend, or delete inaccurate data should direct their requests to their employers who are Equus’ Customers. Equus’ intent is to comply with all applicable legal and regulatory requirements of those jurisdictions in which it does business, including, as applicable, compliance with the EU General Data Protection Regulation the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks (the “Privacy Shield Frameworks”) as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union, United Kingdom, and/or Switzerland to the United States. Equus has certified to the Department of Commerce that it adheres to the Privacy Shield Principles (the “Principles”). In addition, Equus commits to cooperate with EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) and comply with the advice given by such authorities with regard to human resources and non-human resources data transferred from the EU and Switzerland.  If there is any conflict between the terms in this Privacy Policy and the Principles, the Principles shall govern. To learn more about the Privacy Shield Frameworks, and to view our certification, please visit www.privacyshield.gov.

COLLECTION OF PERSONAL INFORMATION Equus may collect certain information from you directly, such as when you send a direct mail inquiry or online registration, participate in seminars or webinars or contact us through the Website. Information that we may collect includes individual names, telephone numbers, email addresses, company name, job title, and other personally identifiable information. Equus also collects certain information automatically from visitors to the Website, including the IP address, time visited, pages viewed, and related information.

LEGAL BASIS FOR PROCESSING PERSONAL INFORMATION
Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it. However, we will normally collect personal information from you only where we have your consent to do so or where we need the personal information to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to process personal information about you, or may need to process personal information in order to exercise, establish, or defend legal claims.

USE OF PERSONAL INFORMATION
Equus may use information we obtain about you for purposes including, without limitation:

  • Requesting a demonstration;
  • Send you information or materials you request;
  • Respond to your questions and comments;
  • Communicate with you about our products, services, offers, and promotions;
  • Operate, evaluate, and improve our business and the products and services we offer;
  • Analyze trends and statistics regarding use of the Website;
  • Protect against and prevent fraud, unauthorized transactions, claims, and other liabilities, and manage risk exposure, including by identifying potential hackers and other unauthorized users;
  • Enforce Equus’ Customer Agreements with you;
  • Comply with applicable legal requirements and industry standards.

We may combine the information we collect with publicly available information and information we receive from our affiliates, business partners, and other third parties. We may use that combined information to enhance and personalize your experience with us, to communicate with you about products, services, and events that may be of interest to you, for promotional purposes, and for other purposes described in this Privacy Policy. We also may use the information we obtain about you in other ways for which we provide specific notice at the time of collection.

DISCLOSURE OF PERSONAL INFORMATION
We may disclose aggregated information about our users, and information that does not identify any individual user, without restriction. We may disclose personal information about you:

  • To service providers as set forth in the section “Use of Information by Third Parties that are Agents of Equus,” below;
  • To enforce or apply our Customer Agreements;
  • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Equus, users of the Website, or others; and
  • With your consent.

We also reserve the right to transfer your personal information to a buyer or other transferee in the event of a merger, divestiture, restructuring, reorganization, dissolution, sale, or other transfer of some or all of our assets.  Should such a sale, merger, or transfer occur, we will use reasonable efforts to direct the transferee to use your personal information in a manner that is consistent with our Privacy Policy.

DATA SECURITY
Equus will use reasonable methods to secure all personal information by a variety of methods, including restricting access to such information only to those people who have a legitimate need to know in order to discharge their job responsibilities on behalf of Equus, securing access to the facility where the information is stored, and the use of technology and physical controls to secure the information. Equus is required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

DATA RETENTION
We will retain personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax, or accounting requirements). When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), we will securely store your personal information and isolate it from any further processing until deletion is possible.

USE OF INFORMATION BY THIRD PARTIES THAT ARE AGENTS OF EQUUS
Equus will require that all third parties that are acting on behalf of Equus, and to which personal or sensitive information is provided, give Equus adequate assurances that they will safe guard all such information in a manner consistent with both this Privacy Policy and the Privacy Shield Frameworks. Equus’ accountability for personal data that it receives under the Privacy Shield Frameworks and subsequently transfers to a third party is described in the Principles. In particular, Equus remains responsible and liable under the Principles if third-party agents that it engages to process the personal data on its behalf do so in a manner inconsistent with the Principles, unless Equus proves that it is not responsible for the event giving rise to the damage.

YOUR RIGHTS REGARDING YOUR PERSONAL INFORMATION

  • Review, correct, and delete your personal information:If you would at any time like to review, correct or delete the personal information that we hold about you, you can contact us using the contact information provided. Upon your request to terminate your account or delete your personal information, we will delete your personal information from our active databases.  Please note that some personal information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Customer Agreements with you and/or comply with legal requirements.
  • Cookies and similar technologies:Equus uses cookies on its website.  A “cookie” is a text file that websites send to a visitor’s computer or other Internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser.
  • Opt-Out of email marketing:You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below.  You will then be removed from the marketing email list – however, we will still need to send you service-related emails that are necessary your use of our services.  To otherwise opt-out, you may contact us using the contact information provided below.
  • Revoke consent:Where we process your personal information on the basis that you have consented to such processing, you have the right to withdraw your consent at any time by unsubscribing or contacting us.
  • Object to processing:You can object to the processing of your personal information, ask us to restrict processing of your personal information, or request portability of your personal information. You can exercise these rights by contacting us using the contact information provided
  • Additional rights:In addition to the above, you may also ask us to stop or restrict processing of the personal information we have about you.  You may also ask us to transfer your personal information to a third party in certain circumstances. If you would like any other information on these aspects of your rights, please contact us.

DO NOT TRACK FEATURES
Your web browser may let you choose your preference as to whether you want to allow the collection of information about your online activities over time and across different websites or online services.  At this time, Equus’ services do not respond to the preferences you may have set in your web browser regarding such collection of your information, and Equus may continue to collect information in the manner described in this Privacy Policy.

RESOLVING DISPUTES
Equus will investigate any complaints about the use and disclosure of personal information that are not in accordance with this Privacy Policy.  Equus is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (“FTC”). If you are located in the European Union, the United Kingdom, or Switzerland, Equus encourages you to contact Equus should they have a Privacy Shield Frameworks-related (or general privacy-related) complaint regarding Equus’ handling of their information. If Equus is unable to informally resolve any such matter to the individual’s reasonable satisfaction, it will cooperate with EU supervisory authorities (“SAs”) and comply with the information and advice provided to it by an informal panel of SAs in relation to such unresolved complaints (as further described in the Principles). Please contact us to be directed to the relevant SA contacts. As further explained in the Principles, a binding arbitration option will also be made available to you in order to address residual complaints not resolved by any other means. You also have the right to complain to an SA about our collection and use of your personal information.

ENFORCEMENT AND COMPLIANCE
Equus will conduct regular audits to monitor compliance with this Privacy Policy and will provide annual certifications to the U.S. Department of Commerce that it has done so.  Violations of this Privacy Policy will subject the violator to disciplinary action, up to and including termination.

CHILDREN'S INFORMATION
Equus’ services are not directed to, and Equus does not knowingly solicit personal information from, minors under the age of 16.  If you believe we might have any information from or about a child under the age of 16, please contact us at inquiries@equusoft.com.

CHANGES
Equus may amend or modify this policy from time to time by posting the amended or modified version on its website at http://www.equusoft.com. Amendments and modifications will be made in a manner so as to remain consistent with the Principles. This Privacy Policy may also be changed, or limited, to comply with legal or regulatory requirements, or as otherwise allowed or required by law. If we make a change to our Privacy Policy that materially changes our use, collection, or disclosure of your personal information, we will provide notice to you (by email and/or posting on our website) that our privacy practices have changed and will provide a link to the new policy. In the event we make a material change to how we use your personal information, we will provide you with an opportunity to opt out of such new or different use.

OUTREACH ACTIVITY
Our legal basis for collecting and using your information to reach out to you is in our legitimate interests and does not overwrite your data protection interests or fundamental rights and freedoms. Our legitimate interests in this case is to offer you content we believe is in line with the theme of your website and you would want to publish, this is why we need to process your data. For this purpose we will hold your data for 12 months after engagement.

CONTACT INFORMATION
Questions or comments about this policy, or concerns or complaints about possible violations, should be sent to:
Equus Software, 1809 Blake Street, Suite 200, Denver, CO 80202, (303) 292-4200 or
inquiries@equusoft.com

Global Expansion, 1 Norton Folgate, 3rd Floor
London, E1 6DB, +44 203 540 6248
jpeters@globalexpansion.com

If you have any questions, comments, or concerns regarding Equus’ compliance with the European Union’s General Data Protection Regulation, you may contact us through the above information reach out directly to our London office, which serves as our representative in the European Union:

Equus Software / Global Expansion
1 Norton Folgate, 3rd Floor
London E1 6DB
United Kingdom
Attn: Tyler Reynolds / James Peters

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