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PRIVACY STATEMENT


EFFECTIVE DATE/LAST UPDATED: DECEMBER 23, 2022

LAKESIDE SOFTWARE, LLC (together with its affiliated companies) (“we” or
“Lakeside”) is committed to protecting your privacy. This privacy statement
(together with any other documents referenced herein) explains how we collect,
use, disclose, and secure information about individuals that constitutes
personal data under applicable data protection and privacy laws (hereinafter,
“Personal Data”) that is obtained via our website(s), our software applications,
our communications (including email messages), and the services we provide to
our customers (collectively, the “Services”). This statement also describes your
choices and rights with respect to any Personal Data processed by Lakeside. By
using the Services, you consent to the collection activities and data practices
described in this privacy statement. If you do not agree to this privacy
statement, please do not use the Services.

If you provide Personal Data of a third-party to Lakeside (e.g., when you sign
up a colleague to receive information from or about Lakeside, when you provide
information about a person to enable such person to have credentials or receive
Services, or you analyze Personal Data of that person using Lakeside’s
Services), you represent and warrant to Lakeside that you have all necessary
authority to provide that information to Lakeside and to grant to Lakeside all
rights in the information necessary for Lakeside to do everything with that
information that this privacy statement permits Lakeside to do. Third-party
services or applications that are used in connection with the Services may have
their own privacy terms. Those terms should be read independent of this privacy
statement.

We may update this statement from time to time and we encourage you to review
this statement periodically. Lakeside will post any changes to this statement on
its website. Your continued use of the Services and/or your continued provision
of your information to Lakeside will be subject to the terms of the then-current
privacy statement. This privacy statement was last updated on December 23, 2022.


LEGAL BASES FOR PROCESSING OF PERSONAL DATA

Lakeside processes your Personal Data where (i) the processing is necessary to
provide you (or your employer) our Services or otherwise perform a contract with
you (or your employer), (ii) we have obtained your consent for an identified
activity, (iii) it is necessary to comply with a legal or regulatory obligation,
or (iv) for other legitimate interests (e.g., providing for the security and
safety of the Services, to make/receive payments, to prevent and detect fraud,
and/or to track your activities on our websites and/or software applications for
purposes of personalization, optimization and advertising).


COLLECTION OF PERSONAL DATA BY LAKESIDE

PERSONAL DATA THAT LAKESIDE COLLECTS

Lakeside may automatically receive and store certain information (e.g., IP
address and hostname) about you when you use our Services. Lakeside may also
collect information such as name, email address, associated account name,
information about your business role, information about the device you use to
access our Services, and information about your service requirements. If you or
your employer uses our software then we might also collect information such as
device identifier, web browsing data, application performance metrics,
application window focus, and file size information. As discussed in more detail
below, we and our service providers may use a variety of technologies, including
cookies, to assist in this activity. As discussed in more detail below, we and
our service providers may use a variety of technologies, including cookies, to
assist in this activity.

In addition, we use certain third parties to evaluate the use of our Services,
to gather user feedback, and to improve the Lakeside customer experience. If you
voluntarily provide us your email address when providing optional in-product
feedback, we may combine your email address with usage data collected by such
third parties.

If you sign up for one of our promotions, submit information to us via social
media sites, participate in our surveys, apply for a job with Lakeside, or
comment on any of our public message boards then we may also use that
information. In addition, Lakeside may collect payment and billing information
when you register for paid Services

HOW LAKESIDE COLLECTS PERSONAL DATA

Lakeside collects some information from you when you provide it to Lakeside.
This may occur through our website(s) or software applications, at conferences
or marketing events, or typical business outreach initiatives. If you are an
employee of our customer, we may also obtain data about you from your employer
or via your employer’s use of our Services. We collect and process such data
when:

 * Your employer provides us with your work-related information so that we may
   provide your employer with our Services
 * You contact our Help Desk for support
 * You interact with us for product research and development
 * You use or view our website(s)
 * Your employer deploys our Services to a device that you authenticate to or
   otherwise interact with

If you interact with our sales team or contact our Help Desk, we may also
collect your telephone number or other related contact information. Lakeside may
also source some of your information which is publicly available on the internet
or published by our third-party service providers. Whenever we collect
information about you from a third-party we ensure we are legally entitled to do
so.

When applying for a role with Lakeside you may be asked for specific personal
information to determine your potential suitability for employment with us. This
could include your physical location, contact information, resume details,
educational background, prior work experience, professional certifications, and
other information relevant to the role. In certain instances, we may ask you to
voluntarily disclose sensitive Personal Data for legitimate recruitment-related
purposes (e.g., to comply with anti-discrimination laws and/or for government
reporting obligations).

When a customer purchases our software, we process Personal Data under such
customer’s instructions and in accordance with the applicable customer’s
contract with Lakeside. Our customer controls and is responsible for correcting,
deleting, or updating the information it processes using the software and for
complying with any regulations or laws that require notice, disclosure, or the
obtaining of consent prior to transferring such Personal Data to Lakeside.


USE AND DISCLOSURE OF PERSONAL DATA

Lakeside, and/or our service providers, will use your information for various
business and operational purposes such as:

 * Administering your account with Lakeside
 * Conducting internal business operations in support of our Services
 * Contacting you regarding Lakeside products and other related subjects
 * Customizing content and offers provided to you
 * Investigating and helping to prevent security incidents
 * Analyzing trends impacting our Services or industry
 * Complying with applicable law and exercising our legal rights
 * For any other lawful purpose with your consent 

If you are an employee of our customer, Lakeside also collects your data so that
we can:

 * Provide, manage, support, and improve our Services
 * Respond to your or your employer’s requests for technical support
 * Create de-identified data for analytics and benchmarking purposes
 * Perform our obligations under the contract we have with your employer

For purposes set forth herein, we may combine the information that we collect
through the Services with information that we receive from other sources and use
such combined information in accordance with this statement. We may also
aggregate and/or de-identify (aka “pseudonymize”) any information collected
through the Services so that such information can no longer be linked to you or
your employer. We may use such aggregated or de-identified data in accordance
with this statement and the contract we have with your employer.

We may share your Personal Data in the following circumstances:

 * To Affiliates – We may share your Personal Data with our affiliates who have
   a need to know the information for our business purposes
 * To Third Parties for Marketing Purposes – We may share your Personal Data
   with third parties for their marketing purposes. This may include third
   parties whose services we believe you may be interested, or who are
   interested in providing you with services.
 * For Legal Obligation or Safety Reasons – When we have a good faith belief
   that access, use, preservation or disclosure of Personal Data is reasonably
   necessary to (a) satisfy or comply with any requirement of law, regulation,
   legal process, or enforceable governmental request, (b) enforce or
   investigate a potential violation of the Terms of Use, (c) detect, prevent,
   or otherwise respond to fraud, security or technical concerns, (d) support
   auditing and compliance functions, or (e) protect the rights, property, or
   safety of Lakeside, its users, or the public against harm.
 * In the Case of a Merger or Sale – If and when we are involved in a merger,
   acquisition, or any form of transfer or sale of some or all of its business,
   whether as a going concern or as part of bankruptcy, liquidation, or similar
   proceeding. Personal Data may be transferred along with the business. Where
   legally required we will give you prior notice and if you have a legal right
   to do so, an opportunity to object to this transfer.
 * To Service Providers – When we hire a service provider to help operate our
   website or our business, we may give access to Personal Data as necessary to
   perform the service for Lakeside. This may include service providers that
   operate our Site, send our communications, or run our promotions.


DATA TRANSFERS TO RECIPIENTS OUTSIDE OF THE EEA/UK

Lakeside is a global company headquartered in the United States. To facilitate
our global operations we may transfer your data to countries where our
affiliated companies and third-party service providers are located, including
the United States, Australia, India, Japan, Europe, and the United Kingdom.
Lakeside has executed Standard Contractual Clauses with each of its affiliates
and third-party service providers and has implemented other appropriate
safeguards with them. These clauses permit Lakeside to transfer data from the
EEA/UK to third countries, including the United States. You can ask for more
information at privacy@lakesidesoftware.com.

Disclosure of Personal Data to Third Parties
Lakeside may share, transfer or disclose your Personal Data to third parties, as
required or permitted by applicable law. We share Personal Data with our
subsidiaries, affiliates, and contractors who process Personal Data on behalf of
Lakeside. We also provide Personal Data to our channel partners, such as
distributors and resellers, to fulfill product and information requests, and to
provide customers and prospective customers with information about Lakeside and
its products and services. We also share Personal Data with other third parties
for the purposes for which we receive the Personal Data (e.g., performance of
contractual obligations and rights). We may also disclose Personal Data where
necessary or appropriate to (i) comply with applicable law and regulatory
processes, (ii) response to requests from public and government authorities,
(iii) enforce our contracts, or (iv) protect our own legal rights. Additionally,
we may share, transfer or disclose your Personal Data with third parties (e.g.,
advisors, potential transactional partners, or service providers) in connection
contemplation and completion of any corporate transaction in which Lakeside is
acquired by or merged with another company. From time to time we may aggregate
or de-identify information about use of the Services and individuals. We may
share or disclose such aggregate or de-identified information with any third
party for any lawful purpose.


MARKETING

Lakeside may contact you in your role as an employee of a potential customer to
market our Services.  You may opt-out of receiving such marketing outreach by
following the instructions at the bottom of the applicable communication or at
any time by e-mailing privacy@lakesidesoftware.com.

Data Retention
Lakeside will retain your information for only so long as needed to provide you
(or your employer) our Services and to otherwise fulfill the purposes described
in this statement. We will retain and use your Personal Data as required or
permitted by applicable law, including to comply with our legal or business
record keeping obligations.


PROTECTION OF PERSONAL DATA

Lakeside maintains reasonable physical, technical, administrative, and
organizational security measures intended to protect your Personal Data from
accidental loss, alteration, unauthorized disclosure or unlawful destruction.
These measures are commensurate with the sensitivity of the Personal Data we
maintain about you.

Information About Our Use of Cookies
When you visit our websites, sign up for a Lakeside account, attend a virtual
event hosted by us, or request more information about Lakeside then we may
collect information automatically using tracking technologies like cookies or
similar functionalities. Cookies are text files placed on your computer to
collect standard Internet log information and visitor behavior details.

Lakeside and our partners use cookies or similar technologies to analyze trends,
administer our websites, monitor visitor behavior, gather information about site
traffic, and remember user preferences. You can set your browser to notify you
when cookies are being set or to block certain cookies altogether. However, in a
few cases, some of our website features may not function as a result of cookies
being blocked by you. Please consult the “help” section of your browser for more
information customizing your cookie settings.

We use the following types of cookies:

 * Essential
 * Preferences
 * Analytics

Essential cookies are strictly necessary to provide you with our Services. They
allow us to provide you with the essential features of our website, such as
website navigation or logging in the secured areas.

We use other types of cookies only with your prior consent. Preferences cookies
allow our websites to remember your preferences for use, such as your login
details, preferred language, and other customizable details. Analytics cookies
provide us with information about the traffic and users’ behavior on our
websites. This includes the number of visitors, number of clicks to pages, and
others. Most often, the data these cookies collect is anonymous. However, in
some cases, the data may be related to a pseudonymous identifier that may be
related to your device.


INFORMATION ABOUT PERSONS UNDER THE AGE OF 18

It is Lakeside’s policy to refrain from knowingly collecting or maintaining
Personal Data relating to any individual under the age of 18. If you are under
the age of 18, please do not supply any Personal Data to Lakeside. If you are
under the age of 18 and have already provided Personal Data to Lakeside, please
have your parent or guardian contact Lakeside immediately using the information
below so that Lakeside can remove such information from its files. If you are
the parent or guardian of a person under the age of 18 and you have reason to
believe that that person’s Personal Data has been collected by Lakeside, please
contact Lakeside immediately.

Your Rights
Subject to local data protection laws, you may have certain rights with respect
to any of your Personal Data provided to Lakeside. Depending on the applicable
laws these rights may include the following:

 * The right to access and review such Personal Data
 * The right to request that Lakeside amend or correct any inaccurate or
   outdated information
 * The right to request that your Personal Data no longer be processed by
   Lakeside or that such processing be restricted
 * The right to request portability of your Personal Data
 * The right to request that your Personal Data be deleted by Lakeside
 * The right to complain to a data protection authority about processing of your
   Personal Data (Contact details for data protection authorities in the EEA are
   available here)
 * The right not to be discriminated against or denied Services for exercising
   your privacy rights

To exercise your rights, please contact us by using the information set forth in
the Contact Information section below. Lakeside will evaluate all requests and
provide our response within the time period mandated by applicable law. Please
note, however, that you may be directed by Lakeside to make a separate request
of your employer in the event that your employer is a customer of Lakeside using
our Services to process your Personal Data. Lakeside may also require that you
provide us with confirming information to verify your identity before we respond
to your request. Additionally, you should be aware that certain Personal Data
may be exempt from such requests (e.g., where Lakeside is required to keep such
information to comply with a legal obligation).


ADDITIONAL DISCLOSURES FOR CALIFORNIA RESIDENTS

This section applies to our collection and use of “Personal Information” if you
are a resident of California, as required by the California Consumer Privacy Act
of 2018 and its implementing regulations, as amended by the California Privacy
Rights Act (“CCPA”), where “Personal Information” has the definition set forth
in the CCPA. This section describes (1) the categories of Personal Information
collected and disclosed by us, (2) your privacy rights, and (3) how to exercise
your rights.

Lakeside makes the following disclosures regarding the categories of Personal
Information (enumerated in Section 1798.140(o)(1) of the CCPA) that we have
collected within the last 12 months:

Category of Personal InformationCollectedCategory of Source from which Personal
Information is CollectedPurpose of CollectionThird Parties to whom Personal
Information is Disclosed for a Business PurposeThird Parties to whom Personal
Information is Sold or SharedRetention PeriodIdentifiersYesDirectly from our
customers’ authorized users, employees, contractors, agents, or representatives;
cookies and other tracking technologies.To operate and make our services
available to our users.Service ProvidersWe do not sell this category of Personal
Information. However, we share this category of information with third parties
for purposes of cross-context behavioral advertising.Lakeside retains this
category of Personal Information for the length of the applicable customer
contract and for as long as necessary to fulfill legal and contractual
obligations, which does not exceed 7 years.Personal information categories
listed in the California Customer Records statute (Cal. Civ. Code §
1798.80(e))YesDirectly from our customers’ authorized users, employees,
contractors, agents, or representatives.To operate and make our services
available to our users, billing, identification, authentication, and to contact
users about their use of our services.Service ProvidersWe do not sell or share
this category of Personal Information.Lakeside retains this category of Personal
Information for the length of the applicable customer contract and for as long
as necessary to fulfill legal and contractual obligations, which does not exceed
7 years.Protected classification characteristics under California or federal
lawYesDirectly from our customers’ authorized users, employees, contractors,
agents, or representatives.To operate and make our services available to our
users.Service ProvidersWe do not sell or share this category of Personal
Information.Lakeside retains this category of Personal Information for the
length of the applicable customer contract and for as long as necessary to
fulfill legal and contractual obligations, which does not exceed 7
years.Commercial informationNoN/AN/AN/AN/AN/ABiometric
informationNoN/AN/AN/AN/AN/AInternet or other similar network
activityYesDirectly from our customers’ authorized users, employees,
contractors, agents, or representatives; and cookies and other tracking
technologies.To operate and make our services available to our users; to improve
the content and functionality of our services and website; and to conduct data
analytics.Service ProvidersWe do not sell this category of Personal Information.
However, we share Personal Information collected via cookies and other tracking
technologies with third parties for purposes of cross-context behavioral
advertising.Lakeside retains Personal Information collected directly from its
customers for the length of the applicable customer contract and for as long as
necessary to fulfill legal and contractual obligations, which does not exceed 7
years. For information collected via cookies/trictrac technologies, it varies
depending on the type of cookie collecting this category of Personal
Information, but no more than 2 years.Geolocation dataYesDirectly from our
customers’ authorized users, employees, contractors, agents, or
representatives.To operate and make our services available to our users.Service
ProvidersWe do not sell this category of Personal Information.Lakeside retains
this category of Personal Information for the length of the applicable customer
contract and for as long as necessary to fulfill legal and contractual
obligations, which does not exceed 7 years.Sensory
dataNoN/AN/AN/AN/AN/AProfessional or employment-related
information.NoN/AN/AN/AN/AN/ANon-public education information (per the Family
Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part
99))NoN/AN/AN/AN/AN/AInferences drawn from other personal
information.YesInternally derivedTo conduct analytics, business operations, and
product development.Service ProvidersWe do not sell or share this category of
Personal Information.Lakeside retains this category of Personal Information for
the length of the applicable customer contract and for as long as necessary to
fulfill legal and contractual obligations, which does not exceed 7 years.


IF YOU ARE A CALIFORNIA RESIDENT YOU HAVE THE FOLLOWING RIGHTS:

Privacy RightDescriptionNoticeRight to be notified of what categories of
Personal Information will be collected at or before the point of collection and
the purposes for which they will be used and shared.AccessThe right to be
notified of what categories of Personal Information will be collected at or
before the point of collection and the purposes for which they will be used and
shared.ErasureThe right to have your Personal Information deleted. However,
please be aware that we may not fulfill your request for deletion if we (or our
service provider(s)) are required or permitted to retain your Personal
Information for one or more of the following categories of purposes: (1) to
complete a transaction for which the Personal Information was collected, provide
a good or service requested by you, or complete a contract between us and you;
(2) to ensure our website integrity, security, and functionality; (3) to comply
with applicable law or a legal obligation, or exercise rights under the law
(including free speech rights); or (4) to otherwise use your Personal
Information internally, in a lawful manner that is compatible with the context
in which you provided it.CorrectionYou have the right to request that we correct
any incorrect personal information that we collect or retain about you, subject
to certain exceptions. Once we receive and confirm your verifiable consumer
request (see below), we will correct (and direct any of our service providers
that hold your data on our behalf to correct) your personal information from our
records, unless an exception applies. We may deny your correction request if (a)
we believe the personal information we maintain about you is accurate; (b)
correcting the information would be impossible or involve disproportionate; or
(c) if the request conflicts with our legal obligations.Automated Decision
MakingYou have the right to request information about the logic involved in
automated decision-making and a description of the likely outcome of processes,
and the right to opt out. Lakeside does not currently engage in any automated
decision making practices.Automated Decision MakingYou have the right to request
information about the logic involved in automated decision-making and a
description of the likely outcome of processes, and the right to opt out.
Lakeside does not currently engage in any automateddecision making practices.To
Opt Out of Sales or Sharing of Personal InformationWe do not sell Personal
Information. When you opt out of sharing, we will not share your Personal
Information with third parties for purposes of cross-context behavioral
advertising.Limit Use of Sensitive Personal InformationLakeside does not use or
disclose Sensitive Personal Information other than to provide our services to
our users. However, if we used or disclosed Sensitive Personal Information for
other purposes, you would have the right to opt out.

Only you, or a person registered with the California Secretary of State that you
authorize to act on your behalf, may make a request related to your Personal
Information. You may also make a request on behalf of your minor child.

You may only make a request for access or data portability twice within a
12-month period. The 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.

We must verify your identity before fulfilling your requests. If we cannot
initially verify your identity, we may request additional information to
complete the verification process. We will only use Personal Information
provided in a request to verify the requestor’s identity. If you are an
authorized agent making a request on behalf of a California consumer, we will
also need to verify your identity, which may require proof of your written
authorization or evidence of a power of attorney.

We endeavor to respond to requests within the time period required by applicable
law. If we require more time, we will inform you of the reason and extension
period in writing. We will deliver our written response electronically via
e-mail.

We do not charge a fee to process or respond to your request unless it is
excessive, repetitive, or manifestly unfounded. If we determine that the request
warrants a fee, we will tell you why we made that decision and provide you with
a cost estimate before completing your request.

We may deny certain requests, or only fulfill some in part, as permitted or
required by law. For example, if you request to delete Personal Information, we
may retain Personal Information that we need to retain for legal purposes.

To exercise your California rights described in this section, please contact us
at privacy@lakesidesoftware.com.

Lakeside will not discriminate against you in the event you exercise any of the
aforementioned rights under CCPA, including, but not limited to, by:

 * denying goods or services to you;
 * charging different prices or rates for goods or services, including through
   the use of discounts or other benefits or imposing penalties;
 * providing a different level or quality of goods or services to you; or
 * suggesting that you will receive a different price or rate for goods or
   services or a different level or quality of goods or services.

Under California Civil Code Section 1798.83, individual customers who reside in
California and who have an existing business relationship with us may request
information about our disclosure of certain categories of personal information
to third parties for the third parties’ direct marketing purposes, if any.

To make such a request, send an email with the subject heading “California
Privacy Rights” to privacy@lakesidesoftware.com.

In your request, please attest to the fact that you are a California resident
and provide a current California address for our response. Please be aware that
not all information sharing is covered by these California privacy rights
requirements and only information on covered sharing will be included in our
response. This request may be made no more than once per calendar year.

Contact Information
If you have questions, concerns or suggestions related to our privacy statement
or our data protection practices then you may contact us via email
at: privacy@lakesidesoftware.com or write to us at: 2 Oliver Street, Suite 700,
Boston, MA 02109, USA, Attn: Legal Department. If you are contacting Lakeside to
exercise your rights regarding your Personal Data please indicate in which
country and/or state you reside. Lakeside is committed to working with you to
obtain a fair resolution of any complaint or concern about privacy.This Policy
is available to consumers with disabilities. To access this Policy in an
alternative downloadable format, please contact us via email
at privacy@lakesidesoftware.com.

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