Date last revised: December, 2023

Aprimo is committed to protecting the privacy of individuals. This Privacy Notice explains what types of personally identifiable information we collect through our marketing and recruiting websites and software-as-a-service offerings (the “Sites”) to our customers and prospects and how we use that information.

Scope

This Privacy Notice applies to all Aprimo personnel, websites, and environments.

Personally Identifiable Information We Collect and How We Use It

Aprimo collects personally identifiable information (such as your name, mailing address, telephone number, or email address, employer name, employer address or products and operating systems you use) when it is voluntarily submitted to us via the Sites. We use your information only as necessary to respond to your request for materials or as otherwise disclosed to you on the Sites where you submit your information. For example, if you request technical support assistance, we need to know who you are, what product you are using and in what computer system environment you are using the product to respond to your request as efficiently and effectively as possible. In addition, from time to time, we may refer to your personally identifiable information to better understand your needs and how we can improve our products and services. We may use this information to contact you.

In addition, our customers may transmit your personally identifiable information (such as your name, mailing address, telephone number, email address, employer name, employer address or products and operating systems you use) to us through our software-as-a-service offerings. For example, some of our offerings allow our customers to generate and send marketing communications to end users. We utilize personally identifiable information transmitted to us only as instructed by our customers in order to deliver services to our customers or facilitate requests from our customers. Aprimo may use Pendo and other sub processors to improve the user experience within the Aprimo System. Analytics are utilized to provide insight, determine how users interact with the System and assist Aprimo in providing a best-in-class product. We require our customers to transmit data to us only with your consent and in accordance with applicable laws. Nevertheless, if you believe that your personally identifiable information is misused through the Sites or wish to opt out of this activity, please contact us using the contact information provided at the bottom of the page.

Aprimo provides links to third party sites strictly as a service to you. Your personally identifiable information is not shared with these third parties. However, Aprimo is not responsible for the privacy practices of third-party Internet sites. If you leave the Sites to visit a third-party site, the privacy notice of that third-party site will apply to your visit.

We use standard server-side logging to track the number of visitors to the Sites, gather HTTP header information, and generate statistics about visits to the Sites. For example, this information is used to generate analytics related to the Sites and for troubleshooting purposes.

Some pages within the Sites may use a technology called “cookies”. A cookie is a token that a server gives to your browser when you access an Internet website. Cookies are capable of storing many types of data. Cookies help provide additional functionality to the Sites or help us analyze site usage more accurately. In all cases in which cookies are used, the cookie will not collect personally identifiable information except with your explicit permission. However, information gathered from the use of cookies may be combined with other data sources to identify you. To learn more about the utilization of cookies as it pertains to our marketing and developers sites please visit our Marketing and Developers Sites Cookie Policy.

The Sites are not intended or designed to attract children under the age of 13. Aprimo does not collect personally identifiable data from any person it knows to be under the age of 13.

Do Not Track Signals

Certain web browsers and other devices you may use to access the Sites may permit you to indicate your preference that you do not wish to be “tracked” online. Currently, the Sites do not respond to “Do Not Track” signals.

Disclosure of Personally Identifiable Information to Third Parties

We will not sell or otherwise transfer the personally identifiable information you provide via the Sites to any third party unless (1) otherwise disclosed to you when you submit your information; (2) in connection with the sale of all or substantially all of the assets of a business division of Aprimo, a line of Aprimo’s business or Aprimo’s entire business, or through merger with another company; (3) to provide necessary information to our agents, resellers, partners and contractors who may provide products and/or services to you; (4) as necessary for processing your transactions; or (5) for compliance with possible legal or governmental disclosure requirements. Notwithstanding the foregoing, in the event that one of our customers transmits or stores your personally identifiable information in the Sites, that customer may utilize your personally identifiable information in accordance with the consent you provided when that customer collected your information or otherwise in accordance with applicable law.

Protecting Personally Identifiable Information

Aprimo is committed to protecting the personally identifiable information entrusted to us. We have implemented physical, electronic and administrative procedures designed to safeguard personally identifiable information from unauthorized access or disclosure. However, Aprimo cannot ensure or warrant that personally identifiable information will be completely secure from misappropriation by hackers or from other nefarious or criminal activities, or from loss in the event of a failure of computer hardware, software, or a telecommunications network. We will notify you in the event we become aware of a security breach involving your personally identifiable information (as defined by the applicable state and federal laws) stored by or for us. By disclosing your email address to us, you expressly consent to receive electronic notice from us in the event of such a security breach.

Data Privacy Framework

Aprimo 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. Aprimo 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) under the UK Extension to the EU-U.S. DPF. Aprimo 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/.

Aprimo is responsible for the processing of personal data it receives, under the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and Swiss-U.S. DPF and subsequently transfers to a third party acting as an agent on its behalf. Aprimo complies with the EU-U.S. DPF Principles and the Swiss-U.S. DPF Principles for all onward transfers of personal data from the EU, UK, and Switzerland, including the onward transfer liability provisions.

The Federal Trade Commission has jurisdiction over Aprimo’s compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF. In certain situations, Aprimo may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

In compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF, Aprimo commits to refer unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF to TRUSTe, an alternative dispute resolution provider based in the United States. If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit https://feedback-form.truste.com/watchdog/request for more information or to file a complaint. These dispute resolution services are provided at no cost to you.

For complaints regarding EU-U.S. DPF, the UK Extension to the EU-U.S DPF, and Swiss-U.S. DPF compliance not resolved by any of the other DPF mechanisms, you have the possibility, under certain conditions, to invoke binding arbitration. Further information can be found on the official DPF website: https://www.dataprivacyframework.gov/s/article/ANNEX-I-introduction-dpf’tabset-35584=2.

GDPR

The General Data Protection Regulation (“GDPR”) is a comprehensive data protection adopted by the EU commission to protect personally identifiable information of EU individuals. Aprimo takes the protection of personally identifiable information seriously and will comply with GDPR as applicable to the personally identifiable information that Aprimo collects. As a part of our compliance with GDPR, Aprimo enters into standard contractual clauses as set forth by the European Commission with our customers.

EU individuals have the right to access their personally identifiable information. You may also request Aprimo to limit the use and disclosure of your personally identifiable information and Aprimo will fulfill such requests. To make such a request, please contact us using the information below.

UK GDPR

The UK General Data Protection Regulation (“ UK GDPR”) is a comprehensive data protection adopted by the United Kingdom to protect personal identifiable information. Aprimo takes the protection of personally identifiable information seriously and will comply with the UK GDPR as applicable to the personally identifiable information Aprimo collects. As a part of our compliance with the UK GDPR, Aprimo enters into standard contractual clauses as set forth by the European Commission combined with the UK ICO Addendum when transferring data.

UK individuals have the right to access their personally identifiable information. You may also request Aprimo to limit the use and disclosure of your personally identifiable information. Aprimo will fulfill these requests. To make such a request, please contact us using the information below.

In cases of onward transfer to third parties of Personal Data, Aprimo is potentially liable, as further described in applicable contracts.

Your Privacy Rights in the United States

California and other states’ privacy laws provide that consumers have a right to request businesses to inform consumers how their personal information has been shared with third parties, if at all, for the third parties’ direct marketing purposes. Consumers have control over with whom, how, and when businesses can sell or share a consumer’s personal information and the ability to opt out of sharing. To make such a request, please contact us using the information below.

Enforcement and Arbitration

Aprimo is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission. Under certain circumstances, individuals may invoke binding arbitration to resolve disputes with Aprimo.

Contacting Aprimo

If you have any inquiries or complaints related to this Privacy Notice, please contact us using our Contact Us page. Aprimo commits to resolve complaints about our collection or use of your personal information.

Aprimo has further committed to refer unresolved privacy complaints to an alternative dispute resolution provider located in the United States. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third-party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.