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GLOBAL DATA PROTECTION AND PRIVACY NOTICE


1. INTRODUCTION

Rocket Software (“Rocket,” “we,” “us” or the “Company”) has issued this Global
Data Protection and Privacy Notice (“Notice”) to describe how we handle personal
information that you may provide to us.

We respect the privacy of individuals and are committed to handling personal
information responsibly and in accordance with applicable law. This Notice sets
out the personal information that we collect and process about you, the purposes
of the processing and the rights that you have in connection with it.

If you are in any doubt regarding the applicable standards, or have any comments
or questions about this Notice, please contact us at the contact details in
Section 10 below.  

 


2. THE TYPES OF PERSONAL INFORMATION WE COLLECT

We may require basic information which identifies you as an individual
(“Personal Information”), such as your name, email address and phone number, in
order to transact business with you, on behalf of the company you work for, as
our customer.  We will only use such Personal Information for the purposes of
providing information which you have requested, fulfilling business
transactions, or for other purposes set out in this Notice.

We may also collect Personal Information indirectly from third parties, such as
our business partners or third party providers of marketing lists.

We may collect the following information:

 * Name and job title
 * Company or organisation
 * Contact information including email address and telephone number(s)
 * Demographic information such as postal code, preferences and interests
 * Language spoken
 * Other information relevant to customer surveys and/or offers
 * IT information required to provide access to systems and networks such as IP
   addresses, log files and login information
 * Information pertinent to fulfilling business transactions on a customer’s
   behalf.

We do not intentionally collect sensitive information such as racial or ethnic
origin, political opinions, religious or philosophical beliefs, or trade union
membership, genetic data, biometric data, or data concerning health or sexual
orientation. However, please note, that you might choose to voluntarily make
available to us such sensitive information when reporting a concern to support
your concern (see Section 3.4 Legal purposes below).

 


3. PURPOSES FOR PROCESSING PERSONAL INFORMATION

3.1 Business transactions with customers

We process Personal Information through the Company’s global IT systems, which
include tools and systems that help us to administer customer accounts, orders
and business transactions and share information across Company systems, and with
related corporate entities, as described in Section 4.1 below. This includes
transferring Personal Information to our servers in the US (see also Section 6.1
below). Our parent company in the US, Rocket Software, Inc. may host these
servers or utilize third party servers and applications, but in either case will
be responsible for the security access of Personal Information on the systems.

3.2 Rocket websites, marketing, subscriptions, social media

You may provide Personal Information to the Company through our website
“contact” page, to request product information or other resources such as
product demos, webinars, downloads or documentation, or participate in the
Company’s online forums or customer community. Personal Information gathered
from the forms you fill out on our websites is used in any of the following
ways:

 * To provide you with information about our products and services and select
   third party products, including product alerts, releases, upgrades and
   patches
 * To ask you to participate in surveys about products, services, news and
   events
 * To allow you to download products, access webinars or product demos
 * To access customer support portals or participate in a Blog
 * To aggregate broad demographic information to understand general user trends
 * To enable our compliance with export control and other laws and regulations

We may make use of Personal Information that we collect to help us administer
the website and/or for marketing purposes. We may send you information about
products that might be of particular interest to you. In addition to product
updates, promotional and informational e-mails that we send to users from time
to time, we may, on occasion, invite you to participate in a focus group, phone
survey or send you postal mail.

On occasion, we may offer customers and website users the opportunity to
participate in third party or co-branded promotions, sweepstakes or special
programs. The use or transfer of any Personal Information provided for such
purposes may be subject to additional terms.

The Internet is a global environment and using the Internet to collect and
process data can involve the transmission of data on an international basis. By
browsing our website and communicating electronically with us, you acknowledge
our processing of data in this way.

The Company’s websites contain links to other websites. Portions of our website
make chat rooms, forums, blogs, message boards, and/or news groups available to
you. Any information that you disclose in these areas could be made public.
Please exercise caution when deciding to disclose any Personal Information. When
you have used these links to leave our website, we cannot be responsible for the
protection and privacy of any information which you provide while visiting such
sites and such sites are not governed by this Notice. You should review the data
protection and privacy statements applicable to such websites.

Our websites use cookies. Most browsers allow you to turn off cookies or to
receive a warning before a cookie is stored on your hard drive. Find out more
about our cookies in our Cookie Notice.
You may always opt-out of receiving marketing communications through our
subscription center at http://www.rocketsoftware.com/unsubscribe  or, for e-mail
communications, by clicking on the link provided at the bottom of our e-mail to
you.

If you do not wish us to make use of your Personal Information in this way,
please email gdpr.compliance@rocketsoftware.com.

3.3 Other legitimate business purposes

We may also collect and use Personal Information when it is necessary for other
legitimate purposes, such as to help us conduct our business more effectively
and efficiently, for example, for general IT resourcing on a global level and
information security/management.

3.4 Legal purposes

We also may use your personal information where we consider it necessary for
complying with laws and regulations, or to exercise or defend the legal rights
of the Company’s global group of companies. At times, you might also voluntarily
decide to make available personal information including sensitive personal
information to us when making us aware of a concern in relation to Rocket’s Code
of Conduct, Rocket’s other or customers’ policies, and laws and regulations and
such disclosure is necessary to support your concern. When this happens and
provided local privacy laws in your country permit this, such voluntarily
provided personal information would be used only in investigating a concern to
help defend your rights or ensure Rocket remains in compliance.

 


4. WHO WE SHARE YOUR PERSONAL INFORMATION WITH

4.1 Within Rocket

Employees, contractors and agents of the Company may be given access to Personal
Information which we collect, but their use will be limited to the performance
of their duties and the reason for processing. Our employees, contractors and
agents who have access to your Personal Information are required to keep that
information confidential and are not permitted to use it for any other purposes.

Personal Information may be shared among related entities within the Rocket
group of companies, including Rocket Software Inc. in the United States.  As the
parent company, Rocket Software, Inc. provides products, support and operations
services, and centralized corporate functions to its subsidiaries. The Company’s
subsidiaries include but are not limited to: Rocket Software (Beijing) Co.,
Ltd., Rocket Software Canada, Inc., Rocket Software Pty. Ltd., S.A.S. Rocket
Software France, Computer Corporation of America (Intl) Ltd., Rocket Software
B.V., Rocket Software Deutschland GmbH, Rocket Software UK Limited, Rocket
Software Japan Ltd., Computer Corporation of America, Rocket Software
Development India Pvt. Ltd. and Fundi Software Pty Ltd., Rocket Software
Switzerland S.A., RSD America, Inc., RSD Software Australia Pty Ltd., RSD
Singapore Pty Ltd., Rocket Software Lithuania UAB (For a list of Rocket global
locations, please see: http://www.rocketsoftware.com/company/locations.)

4.2 Business partners

We will never sell, rent or disclose to unaffiliated third parties your Personal
Information unless we have your permission or are required by law to do so. When
we permit a third party to access Personal Information, we will implement
appropriate measures to ensure the information is used in a manner consistent
with this Notice and that the security and confidentiality of the information is
maintained.

We disclose the Personal Information we collect to the following third parties:

 * Business partners for the purposes of providing services, support and
   products to customers. If you purchase a product or service developed or
   owned by a third party, we may provide to the product owner or licensor the
   same information you provide to us for purposes of the third party providing
   the products or services to you.
 * Third parties where disclosure is required or authorized by law
 * Service Providers who provide business services to us. We do so on a "need to
   know basis" and in accordance with applicable data privacy law.

The Company has entered into Data Protection Addenda with its third party
subprocessors as applicable. A list of such subprocessors is available at:
http://www.rocketsoftware.com/third-party-sub-processors.

4.3 Lawful grounds

We may disclose Personal Information to third parties on other lawful grounds,
including:

 * To comply with our legal obligations, regulation or contract, or to respond
   to an administrative or judicial process
 * In response to lawful requests by public authorities (including for national
   security or law enforcement purposes)
 * If necessary to exercise or defend against potential, threatened or actual
   litigation
 * If necessary to protect the vital interests of another person
 * In connection with the sale, assignment or other transfer of all or part of
   our business, or
 * With your consent.

 


5. CONTROLLING YOUR PERSONAL INFORMATION

You can request correction, update and deletion of your Personal Information via
e-mail sent to gdpr.compliance@rocketsoftware.com, and we will use reasonable
efforts to contact you regarding your request. To update or delete your Personal
Information or correct an inaccuracy, we may ask you to verify your identity and
cooperate with us in our effort.

 


6. EXERCISING YOUR PRIVACY RIGHTS

6.1 Transfer of personal information

As we operate at a global level, we may need to transfer Personal Information to
countries other than the ones in which the information was originally collected.
When we export your personal information to a different country, we will take
steps to ensure that such data exports comply with applicable laws. For example,
if we transfer personal information from the European Economic Area to a country
outside it, such as the United States, we will implement an appropriate data
export solution such as entering into EU standard contractual clauses with the
data importer, or taking other measures to provide an adequate level of data
protection under EU law.

6.2 Privacy rights

If you are a resident of the European Union, a country benefitting of an
European Commission Adequacy Decision, or a country with similar data protection
laws, you can object to 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 details provided in Section 5 above.

You have the right to complain to a data protection authority about our
collection and use of your Personal Information. For more information, please
contact your local data protection authority. If we have collected and process
your Personal Information with your consent, then you can withdraw your consent
at any time.  Withdrawing your consent will not affect the lawfulness of any
processing we conducted prior to your withdrawal, nor will it affect processing
of your Personal Information conducted in reliance on lawful processing grounds
other than consent.

We respond to all requests we receive from individuals wishing to exercise their
data protection rights in accordance with applicable data protection laws.

If you are an individual who is an ordinarily residing in the State of
California, please you have these rights under the California Consumer Privacy
Act as amended by the California Privacy Regulations, effective January 1, 2023:

 * Know what personal data is being collected about you.
 * Know whether your personal data is sold or disclosed and to whom.
 * Say no to the sale of personal data.
 * Access your personal data.
 * Request deletion of your personal information.
 * Not be discriminated against for exercising your privacy rights.

For State of California residents, the personal data mentioned here in this
policy, are classified as follows:

Category A: Identifiers consisting of, as the case may be, Data Subjects’ full
names, their company/business email addresses and telephone numbers as well as
company/business addresses;

Category B: California Customer Records Personal Information categories
consisting of a name, signature and job title on fully executed contracts;

Category C: Characteristics of protected classifications under California or
federal law, such as race or ethnicity, national origin (i.e. nationality),
citizenship status, religion, sex (including pregnancy, childbirth, and related
medical conditions), age (40 and older), marital status, sexual orientation,
gender identity and gender expression, AIDS/HIV, medical condition, political
activities or affiliations, military or veteran status. Category C only applies
exceptionally, if and when you freely and voluntarily make this available to
Rocket as explained under Section 3.4 Legal purposes above; and

Category D: Commercial information such as Rocket products or services the Data
Subject purchased, obtained, or was interested in.

Rocket does not sell your Personal Information. If you exercise your rights
under the CCPA, Rocket will not discriminate against you.

To learn more about the CCPA and your privacy rights, visit California Consumer
Privacy Act of 2018.


7. DATA RETENTION

Personal Information will be retained no longer than necessary in relation to
the business purposes for which such Personal Information is provided and to
fulfill legal requirements.

 


8. SECURITY

We are committed to ensuring that your information is secure and confidential.
We have put in place appropriate technical, physical and administrative
procedures and means to safeguard and secure the information we may collect or
might receive from you in order to prevent unauthorized access or disclosure.

 


9. UPDATES TO THIS NOTICE

We reserve the right, in our discretion, to make changes to any part of the
website or this Notice.  We may change Notice from time to time by updating this
page. You should check this page from time to time to ensure that you are aware
of any changes. This Notice is effective from January 1, 2023. By continuing to
use the Company’s website and business services, you consent to this Notice as
amended.

 


10. CONTACT INFORMATION

If you have any questions about this Notice, or wish to make a complaint about
our data handling practices, you may contact:

Data Protection Officer
Rocket Software UK Limited
4 The Square, Stockley Park
Uxbridge, UB11 1ET   United Kingdom
0800 520 0439 (toll free)
Email: DataProtectionOfficer@rocketsoftware.com

We will investigate any complaints received in writing and do our best to
resolve them with you as soon as possible.

77 4th Avenue
Waltham, MA 02451 USA

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