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WORKBOARD SECURITY AND PRIVACY POLICY


SECURITY AUDIT

WorkBoard is SOC2 Type II, ISO 27001:2013, and TISAX certified. We employ
industry standard technological measures that are reasonably designed to help
protect your personal information from loss, unauthorized access, disclosure,
alteration or destruction. WorkBoard may use, without limitation, firewalls,
password protection, secure socket layer, and other security measures to help
prevent unauthorized access to your personal information. While we take
reasonable efforts to guard personal information, no security system is
impenetrable.






WORKBOARD, INC. PRIVACY NOTICE

Date of Last Revision: October 14, 2022 (previous version)

WorkBoard, Inc., (“WorkBoard,” “we,” “us,” or “our”) knows you, and your User’s
(see definition below) (“you,” or “your,”), Personal Information is important.
We appreciate the trust you place in us when you visit the WorkBoard platform
and use our services. As a result, we process the Personal Information we
receive from you responsibly and in accordance with applicable laws and
regulations.

This Privacy Notice describes how we process the Personal Information collected
when you access this website (“Website”) or our mobile application (“Mobile
App”). Together the Website and Mobile App are the WorkBoard Platform
(“WorkBoard Platform” or the “Services”). When you leave the WorkBoard Platform,
this privacy notice no longer applies. Any subsequent website, application or
service you access will have its own privacy notice and other applicable terms.

This Notice also tells you about your rights and choices with respect to your
Personal Information, and how you can contact us if you have any questions or
concerns. In this Notice, “Personal Information“ means any information relating
to an identified or identifiable individual.

Please read this Notice carefully. If you do not agree with this Privacy Notice
or any part thereof, you should not access or use any part of the Services. If
you change your mind in the future, you must stop using the Services and you may
exercise your rights in relation to your Personal Information as set out in this
Notice.

PLEASE NOTE: If you are entering Personal Information on behalf of your Users
into the WorkBoard Platform this WorkBoard Platform Privacy Notice must be
incorporated into your own privacy notice that you deliver to your Users.


1. PERSONAL INFORMATION WE COLLECT

When you visit the WorkBoard Platform, we collect: (1) technical information
that is used to deliver the contents and services and for other purposes as
described below, and (2) information that you, or your Users, voluntarily
submit.

PERSONAL INFORMATION YOU PROVIDE TO US

We collect a variety of information that you provide to us. The specific types
of information we collect will depend upon your engagement with the WorkBoard
Platform.

 * Account Information. If a customer creates an account for you to use the
   Services as an account administrator (“Administrator”), or by accepting the
   invitation to register as a user (“User”) under a customer’s account, we
   collect Personal Information to allow you to use our Services via this
   account. When you sign up, you provide us with your name, password, email
   address, physical address, mobile phone number, job title and other account
   information necessary to create and maintain your account.
 * Contact Information and Other Information You Choose to Provide to Us. You
   have the ability to provide a variety of information during your interactions
   with us, such as through emails or other communications. When you contact us
   via a contact form, email, or other means, you provide us with Personal
   Information, such as your name and contact details, and the content of your
   communications.
 * Support Information. When you request technical support services, we will
   process your Personal Information such as your name and the contact details
   you use to contact us, as well as information regarding the reasons for your
   support request, the support that was provided, and any additional
   information you may provide in that context.
 * Financial Information. If you purchase our Services, you will need to provide
   payment information. We will use that information solely for the purpose of
   fulfilling your purchase request. We ourselves do not store any of your (or
   your Users) financial information, but rely on the services of payment
   providers to carry out any payments you wish to make to us.
 * Other Information. You may choose to directly provide us with information
   associated with your use of the Services. For example, if you decide to use
   the Services offered by us we will collect and store the content and
   information you or your Users create or upload to the account on the
   WorkBoard Platform (“User Content”).

INFORMATION COLLECTED VIA AUTOMATED MEANS

We automatically collect certain information based upon your behavior on the
WorkBoard Platform. We use this information to conduct internal research on
system usage, demographics, interests, and behavior to better understand who is
visiting the WorkBoard Platform, for marketing purposes and to improve our
related services. Whenever possible, the collected data is de-identified,
aggregated and/or anonymized.

 * Single Sign-On Through Internet Service Providers. We may collect Personal
   Information from internet service providers when you decide to use their
   single sign-in servers to connect to our Services. Your interactions with
   these tools are governed by the privacy notices of the corresponding
   platform.
 * Device and Usage Information. When you access and use the WorkBoard Platform,
   we receive and store information about your (and your User’s) interactions,
   such as date/time stamps, usage information and statistics, your internet
   protocol (IP) address, hardware and software information (including operating
   system version and type), browser type, device identifiers, device event
   information, crash data, cookie data, and the pages you have viewed or
   engaged with before or after accessing the WorkBoard Platform including
   content accessed, time viewed, links clicked, referring/exit pages, and
   clickstream data. This information could be used to identify you and or your
   device and may provide us with your location.
 * Cookies and Similar Technologies. We collect Personal Information via
   cookies, pixel tags, or similar technologies on the WorkBoard Platform
   (collectively referred to as “Cookies“). For more information on our use of
   Cookies, please read our Cookie Notice.


2. HOW WE USE PERSONAL INFORMATION WE RECEIVE OR COLLECT

We use the Personal Information we receive or collect for the following
purposes:

 * To Create Your Account for our Services and to secure and maintain it.
 * To Provide Our Services, including to operate, maintain and support our
   Services by making available our online database with business contact
   details to Administrators and Users.
 * To Communicate With You, including to contact you for administrative purposes
   such as security or support and maintenance advisories, to provide services
   and information that you request, to respond to comments and questions, to
   contact you regarding issues concerning your use of our Services, including
   changes to this Notice, and to otherwise provide customer support.
 * Subject to any consent requirements, to Send Marketing Materials, alerts
   about the latest developments and features or other promotional materials,
   and to develop new promotional materials that can be useful or relevant to
   our customers. You will always be provided with an opportunity to opt out of
   receiving such communications. For example, You opt out by following the
   instructions located at the bottom of any commercial emails you may receive
   or by contacting us as outlined in the Contact Us section in this Privacy
   Notice.
 * For Personalization to customize our Services.
 * For Analytics and Product Development, including to measure and analyze usage
   trends and preferences in order to improve our Services, and to develop new
   products, services, and features.
 * For Customer and Vendor Relationship Management, including to track emails,
   phone calls, and other actions you have taken as a prospective customer or
   our customer or vendor.
 * For Aggregation. We sometimes aggregate or anonymize Personal Information in
   a form that does not allow our Administrators or Users to be personally
   identified and use the resulting information for statistical analysis
   regarding the use of the Services, such as to better understand our customer
   base, or for other purposes.
 * For Administrative and Legal Purposes, such as for compliance purposes,
   including enforcing our contractual rights or enforcing or defending other
   legal rights, or as may be required by applicable laws and regulations or
   requested by any judicial process or governmental agency, and to comply with
   our legal obligations and internal policies as permitted by law.


3. LEGAL BASES FOR THE PROCESSING OF PERSONAL INFORMATION

If you are located in the EEA, UK or Switzerland, we only use your Personal
Information as described in this section if we have a valid legal ground for the
processing, including:

 * Consent. This is the case where you have consented to the use of your
   Personal Information.
 * Contract. We need your Personal Information to provide you with our Services
   in order to perform our end of our contracts with you, such as to create and
   secure your account, or to respond to your inquiries.
 * Legitimate Interest. We have a legitimate business interest in processing
   your Personal Information to provide the Services to our Customers. We only
   rely on legitimate interest as a legal basis when such legitimate interests
   are not overridden by your interests or your fundamental rights and freedoms
   and we ensure we comply with any request you make to exercise your rights.
 * Legal Obligation. We may have a legal obligation to process your Personal
   Information, for example to comply with tax and accounting obligations, and
   we may process your Personal Information when necessary to establish,
   exercise, or defend legal claims. We may also process your Personal
   Information when necessary to protect your or another individual’s vital
   interests.


4. WHO WE SHARE PERSONAL INFORMATION WITH

We may disclose Personal Information about you under the following
circumstances:

 * Group Entities. We may disclose Personal Information about you to our
   affiliates and subsidiaries, if any.
 * Service Providers. We work with third parties to provide services such as
   hosting, maintenance, and support. These third parties may have access to or
   process your Personal Information as part of providing those services to us.
   For example:
   * Cloud service providers who we rely on for data storage, disaster recovery
     and to perform our obligations to you.
   * We use providers of business communication tools for providing product
     information and marketing materials to you.
 * Legal. Information about our Administrators and Users, including Personal
   Information, will be disclosed to law enforcement agencies, regulatory
   bodies, public authorities or pursuant to the exercise of legal proceedings
   if we are legally required to do so, or if we believe, in good faith, that
   such disclosure is necessary to comply with a legal obligation or request, to
   enforce our terms and conditions, to prevent or resolve security or technical
   issues, or to protect the rights, property or safety of WorkBoard, our
   Administrators or Users, a third party, or the public.
 * Change of Corporate Ownership. Information about our Administrators or Users,
   including Personal Information, may be disclosed and otherwise transferred to
   an acquirer, successor, or assignee as part of any merger, acquisition, debt
   financing, sale of assets, or similar transaction, as well as in the event of
   an insolvency, bankruptcy, or receivership in which information is
   transferred to one or more third parties as one of our business assets.
 * Aggregated Information. We may use and disclose aggregated or otherwise
   anonymized information for any purpose, unless we are prohibited from doing
   so under applicable law.
 * Business Partners. We may share Personal Information such as name, email,
   phone, work history, location, skillset, social profiles and related data
   with our business partners, including for the purposes of sales, marketing,
   recruiting and other related purposes. We may share Personal Information with
   our business partners in order to contact potential customers, market
   products and services, recruit new employees and for other related purposes.
   You will always be provided with an opportunity to opt out of this type of
   sharing.

A list of current sub-processors is located here. We will provide notice if this
list of sub-processors changes. If you do not agree with the changes you may
terminate your use of the WorkBoard Platform in accordance with the terms of
your contractual agreement with WorkBoard.

 * Protection of Us and Others. By accessing the WorkBoard Platform you
   acknowledge and agree that we may also release your information when required
   by law or in good faith when we believe that disclosure is reasonably
   necessary to comply with the law or legal process (e.g., a subpoena or court
   order), enforce our privacy notice or other contracts with you, including
   investigations of potential related violations, or to protect ours or others’
   rights, property, or safety, respond to claims that any content violates the
   rights of third parties; or to respond to your requests for customer service.
   This includes exchanging information with other companies and organizations
   for fraud protection, and spam/malware prevention, and similar purposes.
 * Business Transfers. As we continue to develop our business, we may buy,
   merge, or partner with other companies. In such transactions (including in
   contemplation of such transactions), user information may be among the
   transferred assets. If a portion or all of our assets are sold or transferred
   to a third-party, customer information (including your email address) would
   likely be one of the transferred business assets. If such transfer is subject
   to additional mandatory restrictions under applicable laws, we will comply
   with applicable restrictions.
 * Native Integrations. You can use native integrations to share data with other
   work applications. WorkBoard does not share data from integrated apps with
   any other services or clients. For example, if you integrate your Slack
   account, we access your Slack account to gather information that is required
   for the integration endpoint. PLEASE NOTE: We do not “sell” your Personal
   Information to any third-parties, as defined by your Data Processing
   Agreement with us, which is located on the Website or as agreed with the
   Administrator.


5. PRIVACY NOTICE FOR RESIDENTS OF CERTAIN U.S. STATES

Some U.S. state laws provide state residents with additional privacy rights. We
are not currently subject to any U.S. state law which grants its residents with
additional privacy rights, including the California Consumer Protection
Act/California Privacy Rights Act.

DO NOT TRACK DISCLOSURE

Regulatory agencies such as the U.S. Federal Trade Commission have promoted the
concept of Do Not Track as a mechanism to permit Internet users to control
online tracking activity across websites through their browser settings.

We currently do not process or comply with any web browser’s “do-not-track”
signal or other similar mechanism that indicates a request to disable online
tracking of individual users who visit our Sites or use our Services.

CHILDREN’S ONLINE PRIVACY PROTECTION ACT COMPLIANCE

Our Services are all directed to people who are at least 16 years old or older.

We do not knowingly collect any “Personal Information” (as defined by the U.S.
Children’s Online Privacy Protection Act) from anyone under 16 years of age
without valid parental consent. If we become aware that we have collected such
Personal Information without parental consent, we will take reasonable steps to
delete it as soon as possible. We also comply with other age restrictions and
requirements in accordance with applicable local laws.

RETENTION OF INFORMATION

We keep your information for no longer than necessary for the purposes for which
it is processed. The length of time for which we retain information depends on
the purposes for which we collected and use it and/or as required to comply with
applicable laws. For example, we will delete User Content thirty (30) days
following the termination of a customer’s subscription unless we agree to an
extension.

SECURITY

We implement a variety of security measures designed to protect the safety of
your Personal Information from loss, misuse, and unauthorized access,
disclosure, alteration, or destruction when you enter or submit your Personal
Information on the WorkBoard Platform. However, no Internet or email
transmission is ever fully secure or error free. Please keep this in mind when
disclosing any information to us via the Internet.


6. YOURS (AND YOUR USER’S) DATA SUBJECT RIGHTS

You have the following rights associated with the processing of your personal
information:

 * Right to Access. You have the right to obtain access to the Personal
   Information we hold about you and to request certain information about our
   processing. More in particular, you have the right to receive an explanation
   of (i) why we process your Personal Information, (ii) the categories of
   Personal Information we have about you, (iii) who we share your Personal
   Information with, (iv) how long we store your Personal Information and (v)
   who we received your Personal Information from, if it was not collected from
   you directly. We will also inform you about your privacy rights.
 * Right to Rectification. You have the right to correct, update or complete any
   Personal Information we hold about you that is inaccurate or incomplete.
   Please note that we may rectify or remove incomplete or inaccurate
   information, at any time and at our own discretion.
 * Right to Erasure. You may request to have your Personal Information
   anonymized, erased or deleted, as appropriate. In this case, if there is no
   overriding legitimate interest to continue processing your Personal
   Information we will erase your data.
 * Right to Object to Processing. You have the right to object to our processing
   of your Personal Information where we are relying on a legitimate interest or
   if we are processing your Personal Information for direct marketing purposes.
 * Right to Restrict Processing. You have a right in certain circumstances to
   stop us processing your Personal Information other than for storage purposes.
 * Right to Portability. You have the right to receive, in a structured,
   commonly used and machine-readable format, Personal Information that we hold
   about you, if we process it on the basis of our contract with you, or with
   your consent, or to request that we transfer such Personal Information to a
   third party.
 * Right to Withdraw Consent. You may withdraw any consent you previously
   provided to us regarding the processing of your Personal Information at any
   time and free of charge. We will apply your preferences going forward. This
   will not affect the lawfulness of the processing before you withdrew your
   consent.
 * Right to Lodge a Complaint. You may lodge a complaint with a supervisory
   authority, including in your country of residence, place of work, or where
   you believe an incident took place.
 * Right to non-discrimination related to the exercising of your rights provided
   by law.

EXERCISE YOUR DATA SUBJECT RIGHTS UNDER GDPR

We provide you with an easy way to submit us privacy related request like a
request to access or erase your personal data. If you want to make use of your
data subject rights, please visit our public privacy landing page

Please note that, prior to any response to the exercise of such rights, we will
require you to verify your identity. In addition, we may have valid legal
reasons to refuse your request and will inform you if that is the case. Note
that applicable laws contain certain exceptions and limitations to each of these
rights.

Only the registered account Administrator may close an account. The
Administrator may decided to terminate the ability of one or more of the invited
Users to use their account. Only the Administrator or User’s manager may request
the deletion of the User Content in the account.

INTERNATIONAL DATA TRANSFERS

If you provide us with your Personal Information when using the Services from
the EEA, Switzerland or the UK or other regions of the world with laws governing
data collection and use that may differ from U.S. law, then please note that you
are transferring your Personal Information outside of those regions to the
United States for storage and processing.

If we transfer your Personal Information internationally, we will ensure that
relevant safeguards are in place to afford adequate protection for your Personal
Information and we will comply with applicable data protection laws, in
particular by relying on an EU Commission adequacy decision, or the current
standard contractual protections for the transfer of your Personal Information
or if a derogation is available.

The specific legal basis for the international or cross-border transfer of your
Personal Information is located in your Data Processing Agreement with WorkBoard
(“DPA”), which is located on our website, or as has been agreed to with your
organization.

THIRD PARTY LINKS AND WEBSITES

This Privacy Notice does not address, and we are not responsible for, the
privacy practices of any third parties, including those that operate websites to
which the WorkBoard Platform links. The inclusion of a link on the WorkBoard
Platform does not imply that we or our affiliates endorse the practices of the
linked website.

CO-BRANDED WEBSITES

In the event that our Website links to other websites that include our branding,
this Privacy Notice does not apply to those other websites. Visitors to those
websites are advised to carefully read the notices on those individual websites.

SECURITY

We employ industry standard technological measures that are reasonably designed
to help protect your personal information from loss, unauthorized access,
disclosure, alteration or destruction. WorkBoard may use, without limitation,
firewalls, password protection, secure socket layer, and other security measures
to help prevent unauthorized access to your personal information. While we take
reasonable efforts to guard personal information, no security system is
impenetrable.

CHANGE OF OWNERSHIP

In the event of a change in ownership, or a merger with, acquisition by, or
transfer or sale of all or a portion of our assets to, another entity, we
reserve the right to transfer all of your Personal Information, including email
addresses, to that entity. We will use reasonable efforts to notify you of any
such transfer to an unaffiliated third party (by a posting on our homepage, or
by email to your email address that you provided to us, as chosen by us in our
discretion).


7. CHANGES TO OUR PRIVACY NOTICE

We reserve the right to amend this privacy notice at any time to reflect changes
in the law, our data collection, use or sharing practices or advances in
technology. We will make the revised Privacy Notice accessible throughout the
WorkBoard Platform. You should review this privacy notice periodically. The
“Date of Last Revision" included at the beginning of this privacy notice will
indicate when it was last updated.

By continuing to access or use our WorkBoard Platform, you are confirming you
have read and understand the latest version of this Privacy Notice.

COMPLAINTS

If you wish to lodge a complaint about how we process your Personal Information,
please contact us as described in the Contact Us section below. We will endeavor
to respond to your complaint as soon as possible. You may also lodge a claim
with the applicable supervisory authority.

CONTACT US

WorkBoard, Inc. is the entity responsible for the processing of your Personal
Information and for the purpose of the European Union’s General Data Protection
Regulation, is the Data Processer (you are the Data Controller) regarding the
processing of your Personal Information. If you have any questions or comments
about this Privacy Notice, our privacy practices, or if you would like to
exercise your rights with respect to your Personal Information, please contact
us by one of the following methods:

 * Send us an e-mail at: privacy@workboard.com, or
 * Write to us at: 487 Seaport Ct., Suite 100, Redwood City, CA 94063

REPRESENTATIVE FOR DATA SUBJECTS IN THE EU AND UK

WorkBoard, Inc. does not have an EU Data Protection Officer. We value your
privacy and your rights as a data subject and have therefore appointed Prighter
Group with its local partners as our privacy representative and your point of
contact.

Prighter gives you an easy way to exercise your privacy-related rights (e.g.
requests to access or erase personal data). If you want to contact us via our
representative, Prighter or make use of your data subject rights, please visit
the following website: https://prighter.com/q/11225937575

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© 2014-2022 WorkBoard Inc. All Rights Reserved.

WorkBoard, Results Foundry, Outcome Mindset, Outcome Mindset Method, and
Enterprise Results Management are trademarks of WorkBoard Inc.

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