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GRANICUS PRIVACY POLICY





WE ARE COMMITTED TO MAINTAINING YOUR TRUST

Granicus, LLC (“Granicus”, “Company”, or “We”) is committed to maintaining your
trust by protecting your personal data. The Granicus privacy policy was last
updated on: September 13, 2023.

Overview What Personal Data Does Granicus Collect From Me and Use? Why Does
Granicus Carry Out These Processing Activities Using My Personal Data? For How
Long Does Granicus Keep My Personal Data? Your Rights In Relation To Your
Personal Data Data Security What Should I Do if I Am Not Happy With How My
Information Is Being Used? Privacy Notice for United States Residents Looking
for product privacy policies?

Granicus is committed to protecting the privacy of your personal information. We
have written this Privacy Statement to let you know how Granicus uses your
personal data. In this statement you will find information about the types of
personal data we collect from you, when we collect your personal data and how
long we keep it for, how we collect your personal data, our reasons for
collecting and using your personal data, and information about how we share your
personal data. When we say “we”, “us”, or “our” in this Privacy Statement, we
mean Granicus LLC.

Granicus complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK
Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework
(Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce.  Granicus has
certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data
Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the
processing of personal data received from the European Union in reliance on the
EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK
Extension to the EU-U.S. DPF.  Granicus has certified to the U.S. Department of
Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles
(Swiss-U.S. DPF Principles) with regard to the processing of personal data
received from Switzerland in reliance on the Swiss-U.S. DPF.  If there is any
conflict between the terms in this privacy policy and the EU-U.S. DPF Principles
and/or the Swiss-U.S. DPF Principles, the Principles shall govern.  To learn
more about the Data Privacy Framework (DPF) program, and to view our
certification, please visit https://www.dataprivacyframework.gov/.

This Privacy Notice does not apply to other online services and applications
operated by Granicus, nor to any information that we handle as a processor or
service provider to our customers. We have also provided below notices related
to Granicus employees who are California residents for purposes of the
California Consumer Privacy Act of 2018 (“CCPA”) as amended by the California
Privacy Rights Act of 2020 (“CPRA”).

Please take a moment to review this Privacy Statement in detail to understand
our views and practices regarding your personal data and how we will treat it.

The Granicus entities which adhere to this Privacy Notice include but are not
limited to the following: Granicus Inc., Granicus-Firmstep Ltd., Granicus Canada
Holdings ULC, Granicus Australia Pty Ltd., Granicus Technologies India Pvt Ltd.

Any changes to this Privacy Statement will be communicated on www.granicus.com
and, unless stated otherwise, will take effect immediately once posted.

For the purpose of applicable data protection laws, the data controller is
Granicus LLC and you can contact us using the following contact information:

Office for Data Protection Compliance
E: dpo@granicus.com

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WHAT PERSONAL DATA DOES GRANICUS COLLECT FROM ME AND USE?

We collect, store and use the following categories and types of data which
identifies you or which can be used to identify you:

Data Collected When Purpose Your name, business or personal email address,
business or personal address, business or personal telephone number. When you
visit any of our websites, or where you use our contact functionality and or
chatbot on the websites. To contact you occasionally regarding our services and
products, subject to applicable laws (for example, where required, subject to
your consent). Information about your job, such as your position, title,
management level, work location, division, department, and position level. When
registering to a webinar or other event on the website; or other ad hoc forms
that we may add to the website on occasion. To process your registration and
participation in a webinar or other event to you which you have registered.
To contact you occasionally regarding our services and products, subject to
applicable laws (for example, where required, subject to your consent).
Information about your access to our network and premises. CCTV images, when
visiting our premises, when you swipe a card access, time recording software and
internet access usage. To comply with our business, regulatory and legal
obligations. IP address, location and time zone setting, operating system and
platform, browser plug-in types, domain name and your choice of browser. When
you agree to the use of cookies and when you provide data passively (by using
the website, by navigating the screens, clicking on buttons etc.). To improve,
modify and update services and content offered on the website.
To monitor and ensure the orderly and proper operation and development of the
website and associated services.
To analyse and provide statistical information to third parties.
To improve and customize your experience and the content that is presented to
you on the website. Applying for a position with Granicus. When you seek a
career opportunity on our website processing of personal data is subject to and
is governed by the Granicus Candidate Privacy Policy located here. To process
your application.

 

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WHY DOES GRANICUS CARRY OUT THESE PROCESSING ACTIVITIES USING MY PERSONAL DATA?

Some of the laws that apply to us require us to tell you the legal reason for
using your personal data. We list these below:

Consent: Where applicable and appropriate, we will ask for your consent to
collect and use your personal data. If we need your consent to collect and use
your personal data we will make clear to you that the provision of your consent
is voluntary. You have the right to withdraw your consent at any time by
contacting us using the contact information set out above.

Our core activities: In many cases using your personal data is core to our
legitimate business interests. Where we use your personal data for these
purposes you will have the right to object to our use of your personal data by
contacting us using the contact information set out above.

We use your personal data for our legitimate interests to provide you with
information about our products and services and to understand your use of our
website, products, and/or services. We use information collected via cookies
(electronic text files) that we place on to your machine in order to provide you
with the best level of service when using our tools. These analytics tell us
whether you had technical difficulties when using our website or to provide you
with a service that is tailored to you.

Our Cookie Policy provides you with more information about our use of cookies.

Legal Requirement: At times we may receive requests from regulators or other
authorised bodies to use your personal data in order to comply with a legal or
regulatory obligation. Where this is the case, we will ensure that the request
is legitimate.

Overall, the provision of your personal data is voluntary for you and not
required by law. However, in order to provide the website to you, to carry out a
contractual relationship with you and/or to offer other products and services to
you, your personal data are necessary. Not providing your personal data may
result in disadvantages for you – for example, we may not be able to carry out a
contractual relationship with you or you may not be able to use certain products
and services or may accept limited functionality. However, not providing your
information will not result in legal consequences for you.

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FOR HOW LONG DOES GRANICUS KEEP MY PERSONAL DATA?

We keep your personal information for no longer than is necessary for the
purpose for which the information is collected and to manage our relationship
with you. Where personal information is kept, that period will be determined
based on applicable local law. For further information, please contact us as set
out above.

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YOUR RIGHTS IN RELATION TO YOUR PERSONAL DATA

We explain here the rights that you may have in relation to personal data if you
live in the UK or European Union:


HOW CAN I FIND OUT WHAT PERSONAL DATA GRANICUS’ HOLDS ABOUT ME?

You may contact us using the contact information above if you would like more
detailed information about what personal data we have collected from you,
including the categories of personal data processed, the purposes of the
processing and the third parties to whom that data is transferred. You may also
request a copy of your data. Note that we do have to take into account the
interests of others, and certain other legal obligations or restrictions, so
this is not an absolute right.


CAN I ASK GRANICUS TO DELETE OR CORRECT MY PERSONAL DATA?

You may contact us using the contact information above if you would like us to
delete your personal data or to have your personal data corrected and, if
required to do so, we will comply with your request.


CAN I ASK GRANICUS TO STOP USING MY PERSONAL DATA?

You may contact us using the contact information above if you would like us to
stop using your personal data (either entirely or for some of our Processing
Activities) and, if required to do so, we will comply with your request.


CAN I ASK GRANICUS TO TRANSFER MY PERSONAL DATA TO A THIRD PARTY?

You may contact us using the contact information above if you would like us to
transfer your personal data to a third party in a structured, commonly used and
machine readable format and, if required to do so, we will comply with your
request.


DOES GRANICUS SECURELY STORE MY PERSONAL DATA?

We apply strict security standards, controls and processes to protect your
personal information from unauthorised access, loss or accidental deletion.
These include restricting who can have access to your personal data and
protecting your data with security tools appropriate to the type of information
e.g. encryption software and secure file transfer tools. We also require that
our third party processors who handle your personal data do the same.


DOES GRANICUS USE COOKIES?

Cookies are text files containing small amounts of information which are
downloaded to your computer or mobile device when you visit a website. Cookies
are then sent back to the originating website on each subsequent visit, or to
another website that recognizes that cookie. Cookies are useful because they
allow a website to recognize a user’s device. Cookies allow you to navigate
between pages efficiently, remembering your preferences and generally improving
the user experience.

Our Cookie Policy provides you with more information about our use of cookies.


DOES GRANICUS SHARE MY PERSONAL DATA WITH THIRD PARTIES?

To help us carry out our Processing Activities, we may need to share your
personal data with entities within and outside of Granicus as follows:

Granicus Entities – we may transfer your data to other Granicus entities who may
collect, transfer and/or use the personal data we have collected from you for
some or all of our Processing Activities. Where we share your personal
information with other Granicus entities, they will use your information in a
manner consistent with the purposes for which it was originally collected and
consistent with this Privacy Statement and applicable data protection and
privacy laws.

Our Data Processors – from time to time, we may share your personal data with
our third party service providers or with other Granicus entities who provide us
with investor relationship, company secretarial, legal, regulatory, corporate
advisory, event management, talent management, recruitment, marketing,
communication and/or IT support services (“Data Processors”). In order to
provide such services, our Data Processors process your personal data on our
behalf. Our Data Processors have met our criteria as trusted guardians of
personal data and are subject to contractual obligations to implement
appropriate security measures to safeguard your personal data and to process
personal data only as instructed by us.

Other Third Parties – your personal data may also be transferred to regulators,
courts, and other authorities (e.g. tax and law enforcement authorities) and
independent external advisors (e.g. lawyers, auditors). We may also share
certain personal data with business partners, customers and suppliers to carry
out our business activities.

For the full list of the Granicus entities, Data Processors and other third
parties that we may share your data with, please contact us as set out above.
Our website may, from time to time, contain links to and from the websites of
our partner networks, advertisers and affiliates. If you follow a link to any of
these websites, please note that these websites have their own privacy policies
and that we have no control over how they may use your personal information. You
should check the privacy policies of third party websites before you submit any
personal information to them.

Granicus may share personal data with its service providers for the purpose of
helping Granicus execute certain tasks outsourced to them, or providing
capabilities Granicus requires. The service providers to which Granicus provides
personal data in connection with the personal data collected through the Website
are: (1) email service providers for email campaigns management and to send you
emails on our behalf, with the express provision that their use of such
information must comply with our instructions; (2) recruiting service providers,
in relation to activities on the Website related to submission and processing of
CV and job applications through the Website; (3) registration management of
users to events through the website; (4) billing, processing payments, marketing
automation, Granicus advertisements on social media, CRM platform, analytics
tools providers, web page building tools, cloud services, support and
maintenance operation tools. Our service providers do not have any right to use
your personal data collected from the Website beyond what is necessary for the
purpose of facilitating their services for us and are subject to data protection
agreements to the extent required under applicable law.

Granicus is also entitled to transfer or share anonymous, statistic or
aggregative information with companies or organizations connected to Granicus,
and with suppliers, business partners, advertisers, and every third party,
according to Granicus’s absolute discretion.

Social media features – the Website includes social media plugins, including
links to Facebook, LinkedIn and Twitter. These features may collect your IP
address, which page you are visiting on our site, and may set a cookie to enable
the plugin to function properly. Social media features are governed by the
privacy policy of the company providing it.


DOES GRANICUS TRANSFER MY PERSONAL DATA OVERSEAS?

Some of the Granicus entities, Data Processors and other third parties that we
share your personal data with are located outside of the UK or European Economic
Area (EEA).

If we transfer your personal data to entities outside of the EEA (which include
our IT service providers, recruitment partners and other Granicus entities in
the US and India), we will make sure that your data is being protected as
required by applicable data protection law, as described in more detail below.

Granicus complies with the European Commission’s adequacy decision for the
EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the Swiss-U.S. Data Privacy
Framework (Swiss-U.S. DPF) entered into force. The EU-U.S. DPF and Swiss-U.S.
DPF serves as a data transfer mechanism under the EU General Data Protection
Regulation (GDPR).  Organizations that participate in the EU-U.S. DPF are
eligible to participate in the UK Extension to the EU-U.S. DPF.

You can ask for a copy of the appropriate safeguards by contacting us as set out
above.

.

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DATA SECURITY

Granicus implements data security systems and procedures to secure the
information stored on Granicus computer servers. Such systems and procedures
reduce the risk of security breaches, but they do not provide absolute security.
Therefore, Granicus cannot guarantee that the Website is immune to unauthorized
access to the information stored therein and to other information security
risks.

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WHAT SHOULD I DO IF I AM NOT HAPPY WITH HOW MY INFORMATION IS BEING USED?

You can contact us using the contact information above if you are not happy with
how we are handling your personal data.

You also have the right to complain to our relevant supervisory authority, which
is the Information Commissioner’s Officer (ICO) in the UK, who is responsible
for ensuring we correctly follow the General Data Protection Regulations 2016 or
to any other competent data protection supervisory authority.

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UNITED STATES REGIONAL PRIVACY NOTICE

This United States Regional Privacy Notice is for people living in the United
States and can be found here.

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Déclaration en matière de confidentialité (Link to Granicus Privacy Policy in
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