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PRIVACY STATEMENT




PRIVACY STATEMENT

This privacy statement (the “Privacy Statement”) is effective March 4, 2019.

Illumio, Inc. and its subsidiaries around the world (“Illumio” or “we”)
understand that when our clients, partners and other individuals provide
personal data to Illumio, they place their trust in us. Illumio takes this trust
seriously and is committed to compliance with the laws of all countries in which
it operates, including the General Data Protection Regulation and other
applicable data protection laws around the globe

This Privacy Statement describes Illumio’s practices regarding the collection,
use and disclosure of personal information about an identified or identifiable
natural person (“personal data”) processed through the use of Illumio’s website
at www.illumio.com (the “Site”).  This Privacy Statement does not apply to any
third-party websites, services or applications, even if they are accessible
through our Site.

If your company has engaged Illumio to provide Illumio products and/or services
(collectively, the “Services”), your company and Illumio have agreed to a
separate agreement that, among other things, governs the use of all of the data
collected and maintained by Illumio in connection with the operation of the
Services. The agreement between your company and Illumio takes precedence over
conflicting provision in this Privacy Statement.


PERSONAL DATA WE COLLECT

Our primary goals in collecting information are to provide and improve our Site,
to administer your use of the Site, and to enable you to enjoy and easily
navigate our Site. We collect and use personal data that you provide in order to
operate our business, provide our products and services, send marketing and
other communications, and comply with applicable laws and regulations. In
addition to the personal data you provide to us directly, we may also process
personal data about you that we receive from our clients or third parties. The
types of personal data we process will depend on the purpose.

Purpose Type To provide our products and services  Contact details (such as
name, email, address, company name, phone number and other information
necessary) to provide services to our clients and our client’s customers,
including providing product support updates To improve our products and services
Contact details to conduct quality controls and evaluate the performance of our
products and services, including conducting customer satisfaction surveys. To
conduct due diligence Contact details and publicly available information about
financial or reputational status of a client or third party supplier/partner To
generate sales and marketing leads  Contact details, marketing preferences,
publicly available social media information to maintain a client relationship
management database and send relevant newsletters, solution updates, event
notifications and other marketing communications To customize user experience
Contact details and information obtained through the use of digital collection
tools such as cookies (for more information about the way we use cookies,
click here) To manage relationships with clients, suppliers and partners 
Contact details and payment information in order to execute contracts, generate
invoices and make payments To respond to inquiries or requests for information
Contact details for electronic communication To secure our premises and
networks  Contact details for authentication to use guest networks,
collaboration tools and visit our offices; images captured through our video
systems set up for security purposes in our offices.


HOW WE PROCESS PERSONAL DATA

When we receive personal data about you from our clients in order to provide our
services, Illumio processes the personal data as instructed by our clients and
in accordance with our contractual obligations. Our clients are responsible for
complying with regulations or laws regarding notice, disclosure, and/or
obtaining consent prior to transferring the personal data to Illumio for
processing.


HOW WE SHARE PERSONAL DATA

We do not sell or otherwise disclose personal data about our website visitors or
others that interact with Illumio or our products or services, except as
described herein. We may share your personal data with authorized Illumio
personnel in our subsidiaries with a need to know the information in order to
process the personal data for the purpose we collected it. We also share
personal data with third parties who are acting on our behalf in order to
provide the products or services you request or to support our relationship with
you. These third parties are not authorized by us to use or disclose the
information except as necessary to perform services on our behalf pursuant to a
contractual obligation or to comply with legal requirements. Illumio requires
such third parties to comply with applicable data protection and privacy laws
and agree to implement and maintain appropriate technical and organizational
security measures to safeguard the personal data.

Our sharing may include:

 * with any of our subsidiaries and trusted third party suppliers/partners in
   order to perform our services or business operations;
 * with our professional advisors and insurers to run our business;
 * with competent legal authorities when required by applicable laws or
   regulations;
 * with law enforcement authorities or other government officials when we are
   required to do so by law or pursuant to legal process (including for national
   security purposes); when we believe disclosure is necessary or appropriate to
   prevent physical harm or financial loss or in connection with an
   investigation of suspected or actual fraud or illegal activity; or when we
   believe that disclosure is necessary to protect our rights, protect your
   safety or the safety of others; and
 * with appropriate third parties in connection with the sale, transfer or
   financing of all or part of a Illumio business or its assets, including any
   such activities associated with a bankruptcy proceeding.


HOW WE PROTECT PERSONAL DATA

We use reasonable security procedures and technical and organizational measures
to protect against accidental or unlawful destruction, loss, disclosure or use
of personal data we handle. Our network and systems used to provide services are
governed by corporate Information security policies, which are based upon
standards, including International Organization for Standardization (ISO) 27001
and National Institute of Standards and Technology (NIST). We limit access to
and use of your personal data to authorized persons and trusted third parties
who have a reasonable need to know the information in order to perform our
services and business operations and who are bound by confidentiality
obligations.


HOW LONG WE RETAIN PERSONAL DATA

We retain your personal data only for as long as is necessary to fulfill the
purpose for which the data was collected from you and in consideration of and
compliance with applicable legal or regulatory requirements to maintain the data
for legitimate purposes. For example, where required by law for audits or
accounting requirements, to enforce our agreements or handle disputes. When
personal data is no longer needed for the purpose it was collected or processed
or to comply with a legal obligation, we securely destroy it.


HOW TO REQUEST ACCESS TO PERSONAL DATA

We rely on you to provide accurate, complete and current personal data to us. If
you need to correct or update the personal data you provided to us, in many
cases, you can edit your data from the location where you provided the personal
data to us. If you are not able to access it yourself, we will respond in a
timely manner to all reasonable requests to access, correct or delete your
personal data. Requests and questions can be submitted to privacy@illumio.com.


FOR EU, EEA OR SWITZERLAND RESIDENTS

For individuals whose personal data we collect directly or instruct our trusted
third party to collect on our behalf, Illumio, Inc. or one of our subsidiaries
located in the EU, EEA or Switzerland is a data controller under the General
Data Protection Regulation. The type of data we process as a data controller
includes contact details such as name, company, email, phone, website
preferences and other information collected for marketing or business operation
purposes. We process personal data as a data controller using the following
legal basis:

 * to meet our legitimate business interest such as to develop and improve our
   solutions, support our sales and business operations, secure our systems,
   facilities and personnel;
 * to comply with applicable laws and regulations;
 * in order to perform or fulfill our obligations under an agreement with you or
   the entity with which you are affiliated; and
 * based upon the provision of your consent, which you may withdraw at any time
   by contacting us at privacy@illumio.com.

If you are resident of EU, EEA or Switzerland, you may exercise the following
rights:

 * to obtain confirmation from us if we are processing your personal data;
 * to request that we correct inaccurate personal data and to have incomplete
   data completed;
 * to object to the processing of your personal data for compelling and
   legitimate reasons relating to your particular situation and we will comply
   except in cases where legal provisions expressly provide for that processing;
 * in circumstances when the processing is based on your consent or a contract
   and the processing is carried out by automated means, to receive your
   personal data that you have provided to us, in a structured, commonly used
   and machine-readable format;
 * to restrict processing of your personal data if (i) you contest the accuracy
   of the data; (ii) the processing is unlawful and you oppose the erasure of
   the data and request restriction instead; (iii) we no longer need the data,
   but you tell us you need the data to establish, exercise or defend a legal
   claim; or (iv) you object to processing based on public or legitimate
   interest;
 * to erase your personal data where there is no compelling reason for its
   continued processing; and
 * to lodge a complaint with a supervisory authority, in particular in the EU
   Member State of your residence, place of employment, or the location where
   the issue that is the subject of the complaint occurred.

Please note that in case we ask for your consent to processing, you are free to
refuse to give consent and you can withdraw your consent at any time without any
adverse negative consequences. The lawfulness of any processing of your personal
data that occurred prior to the withdrawal of your consent will not be affected.
You can exercise these rights by contacting us at privacy@illumio.com. If you
consider that the way we process your personal data infringes your rights under
the GDPR or is not compliant, you can lodge a complaint with Illumio directly or
with a supervisory authority in the EU Member state in which you reside or where
the data was processed.


HOW WE TRANSFER PERSONAL DATA ACROSS INTERNATIONAL BORDERS

Illumio is a global enterprise based in the United States with operations in
countries around the world. Authorized Illumio personnel and third parties
acting on our behalf may access, use and process personal data collected from
you in a country that is different from the country where you entered the
personal data, which may have less stringent data protection laws.  As a network
security company, Illumio has implemented global privacy practices for
processing personal data protected under various data protection laws. Illumio
transfers personal data between the countries in which we operate in accordance
with the standards and conditions of applicable data privacy laws, including
standards and conditions related to security and processing and acceptable
transfer mechanisms.


CHILDREN

It is not our intent to collect personal data from children under the age of
consent in their country of residence. Our Site is not designed to attract
children and we request that children under the age of consent not submit
personal data to us through our Site.


CHANGES TO THIS PRIVACY STATEMENT

Any personal data that we process is subject to the Privacy Statement in effect
at the time such personal data is processed. We may, however, modify and revise
this Privacy Statement from time to time. If we make any material changes to
this Privacy Statement, we will notify you of such changes by posting the
updated Privacy Statement on the Site or by sending you an email or other
notification, and we will indicate when such changes will become effective.


QUESTIONS?

Please contact us at privacy@Illumio.com if you have any questions about our
Privacy Policy.

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