Censinet, Inc. Privacy Policy

Censinet, Inc. (“Censinet”, “we” or “us”) collects certain information from you (“you” or “User”) when one of the following applies: (1) you visit and interact with Censinet’s public-facing website www.censinet.com (the “Public-Facing Site”), (2) the connect.censinet.com website (the “Product Site”), and (3) any other website controlled by Censinet that links to or references this Privacy Policy (collectively, including the Public-Facing Site and the Product Site, the “Sites”), (2) use Censinet’s software and services to assess, manage, and develop best practices associated with the ongoing risk of third party vendor management (the “Censinet Product”), and/or (3) use any other software, products or online services provided to you by Censinet that reference this Privacy Policy (collectively, including the Sites and the Censinet Product, the “Services”).

This Privacy Policy explains what information we collect, why we collect it, how we use it, and your choices related to your information. This Privacy Policy is in addition to, and is intended to supplement, any other agreements between you (or your employer) and Censinet, including any customer or account agreements, and any other agreements that govern User’s use of information, content, tools, products and services available on or through the Services (each, an “Other Agreement”). If you or your employer is a party to any Other Agreement, the terms of the Other Agreement will control over any conflicting terms of this Privacy Policy.

By using our Services, you agree that we may treat your information in the ways we describe in this Privacy Policy. If you do not agree with any term of this Privacy Policy, you must refrain from using our Services.

Please use the following links to jump to the different sections of this Privacy Policy:

• Scope of this Privacy Policy
• Third-Party Sites
• What Information We Collect
• How We Collect Information
• How We Use Information
• How We Share Information
• Data Collection Technologies
• Your California Rights
• How to Access, Modify or Delete Information
• Children’s Information
• How We Protect Your Information
• Note to International Visitors
• Changes to this Privacy Policy
• Contacting Us

Scope of this Privacy Policy

This Privacy Policy covers information about yourself as required by Censinet to enable access to the Services (“Profile Data”) and other demographic, usage and personal information relating to you and your use of the Services. The types of information we collect is described below in the section “What Information We Collect”. For the avoidance of doubt, this Privacy Policy does not govern (i) questionnaires, assessments, information relating to business practices and other information that does not relate to you individually and that is collected as part of your use of the Services on behalf of your employer, and (ii) any information that is disclosed between your organization and Censinet pursuant to an Other Agreement.

Third-Party Sites

Our Services may contain links to other sites that are not owned or controlled by us. Please be aware that we are not responsible for the privacy practices or content of such other sites. We encourage you to be aware when you leave our Sites. We encourage you to review the privacy policies of each and every website that collects personal information as the privacy policy may differ from ours.

What Information We Collect

When you access and use the Services, we may collect the following types of information from you:

• “Company Information” is information provided by you as part of the risk assessment process. You control who has access to that information.
• “Personal Information” is information that can be used to identify, contact or locate you. Examples of Personal Information include your name, address, email address, telephone number, employer, medical specialty and profession. Your Profile Data is Personal Information.
• “Location Information” is a subset of Personal Information that can be used to locate the device you use to access the Services. Location Information may include: (i) the location of the device derived from GPS or WiFi use; (ii) the IP address of the device or internet service used to access the Services, and (iii) other information made available by a user or others that indicates the current or prior location of the user.
• “Usage Data” is information that we automatically collect about your use of the Services and your device. This type of information does not usually, by itself, uniquely identify an individual, and may include your IP address, web browser and operating system, device model and manufacturer, and your activity on the Services.

How We Collect Information

Through the Services, Censinet receives actively submitted data and passively tracks data and may combine data from both types of interactions as follows:

• Actively Submitted Data: When you voluntarily request information, subscribe to a mailing list, register for an event, register for an account to be a user of the Services, contact us with inquiries and comments, request a demo or support, complete and submit forms offered on the Services, apply for employment, or otherwise actively enter data, Censinet collects the data you provided us. Such data may include Personal Information. In each such instance, you will know what data Censinet collects, because you actively submit it. You are not required to submit any data, however, if you do not provide certain information (e.g., Profile Data) it may affect your ability to use or interact with the Services.
• Passively Tracked Data: Censinet uses tracking technology that has become standard operating procedures employed by most websites and online services including, without limitation, “cookies” or small data files stored on your computer’s hard drive, to collect such information. When you visit the Sites, Censinet also passively tracks information from your computer and Internet connection, such as the IP address of your computer and/or Internet service provider, the date and time you access the Sites, the Internet address of websites from which you link to our Sites, the computer technology you are using and your movements and preferences on our Sites. In some instances, Censinet also uses cookies to collect information that, on future visits to the Sites, identifies you as a previous visitor, or tracks your activity on our Sites. If you follow a link to the Sites from an affiliate or promotion, Censinet stores information about your arrival from that affiliate or promotion in a “session cookie.” You do not need to have cookies turned on to visit our Sites. You can refuse cookies by turning them off on your browser. But, if you choose to access Web pages that require registration, you need to accept a mandatory session cookie, which you may delete after you leave the Sites.
• Outside Sources: We may also obtain information about you from other sources, including commercially available sources such as data aggregators, public databases and other third parties.
• Combinations: To the extent permitted by law, Censinet reserves the right to combine information received under the methods described above.

How We Use Information

We may use your information in the following ways:

• Provide you the Services and fulfill your requests. We may use your information to register you, administer your account, and provide you the information, products and services that you request. For example, we provide demos of our Services when you request them, respond to your questions when you contact us, and assist with any problems you report about our Services.
• Communicate with you. We may contact you to share information and promotional materials that we think might be of interest to you. You may unsubscribe from receiving marketing emails from us by emailing us at support@censinet.com or using the unsubscribe link included in the marketing email. If you are a user of the Censinet Product, we may also share information with you through the Censinet Product regarding new features and functionality of the Censinet Products or new products and services.
• Enhance your experience. We use your information to better understand the preferences of our users, to identify server problems, to compile aggregated statistics about Service usage, and to help improve your experience on our Services.
• Improve our Services. We also use your information for purposes of administering, protecting and improving our Services, our information helps us improve the content and functionality of our Services. For example, we may use our users’ demographics, interests, and behaviors to create new features, functionality and content.

We may link Usage Data to the Personal Information we have collected about you. If we link Usage Data to your Personal Information, we will treat such linked information as Personal Information in accordance with this Privacy Policy. We also may also anonymize your information or aggregate your information with other users of the Services (“Aggregate Information”). This Aggregate Information is not Personal Information, because it cannot be used to identify you, and may be used by us for any lawful purpose.

How We Share Information

Censinet is not in the business of selling or licensing information we collect. We only share your information for the reason(s) disclosed to you at the time we collect it, with your authorization or consent, as well as in the following ways:

• At Your Direction. We will share your information with third parties only you direct us to. For example, when you are completing a risk assessment questionnaire in Censinet for a potential customer and you direct us to share your responses with that potential customer.
• With our Affiliates, Business Units and Brands. We may share your business contact information internally among our business units, brands, and our affiliates in order to provide you our Services and generally to improve our product and service offerings.
• With Our Vendors. Censinet may share information with companies that perform services on behalf of Censinet, such as vendors that provide email delivery or online marketing programs, third party hosting providers and vendors managing online account access. Censinet may disclose Personal Information that Censinet collects about you to these companies to enable them to perform these services, but they are required to safeguard the Personal Information and are not authorized to use it for any purpose other than completing their contractual requirements to Censinet.
• With Business Partners and Parties to Whom We Provide Services. Censinet may share information with business partners, such as system integrators, distributors, and referral partners in order to provide you our Services, and generally to improve our product and service offerings. Censinet may share the Personal Information Censinet collects with other companies with whom Censinet has joint marketing arrangements.
• In the Event of a Corporate Transaction. It is possible that in the future another company may acquire Censinet or its assets, or Censinet may undergo a merger, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy or sale of all or a portion of our assets. It is also possible that Censinet may partner with or purchase another company to continue to do business as a combined entity. In the event that this occurs, it is possible that our Subscriber information, including your Personal Information, may be transferred to the new business entity as one of Censinet’s assets. In such an event, Censinet will update this policy to reflect any change in ownership or control of your Personal Information.
• For Legal Purposes. We will disclose your information when we think it is necessary to investigate or prevent actual or expected fraud, criminal activity, injury or damage to us or others or when otherwise required by law, regulation, subpoena, or court order, or if necessary to protect our rights. For example, Censinet reserves the right to disclose Personal Information, including account information, when Censinet believes such disclosure is appropriate to cooperate with an investigation of activities claimed to be unlawful or to protect the rights or property of Censinet or others.

We may share Aggregate Information about our users in all legally permissible ways.

Data Collection Technologies

We use cookies, pixel tags, log files, and other technologies (collectively, “Data Collection Technologies”) to help us provide the Services, tailor our content and enhance your online experience. Our Data Collection Technologies include:

• Cookies. A cookie is a small file placed on your computer’s hard drive that collects and stores information about your equipment, preferences and browsing patterns. We use cookies to analyze web page traffic, usage patterns, and to tailor our Services to your individual interests. For more information about cookies, visit www.allaboutcookies.org.
• Web Beacons. A web beacon (also referred to as clear gif, pixel tag or single-pixel gif) is a transparent graphic image used in tandem with cookies that enables us to record a user’s actions. We use web beacons to count users who have visited those pages, verify system and server integrity and for similar statistical measures.

You can set your Internet browser settings to stop accepting new cookies, to receive notice when you receive a new cookie, to disable existing cookies, and to omit images (which will disable pixel tags). Note that the opt-out will apply only to the browser that you are using when you elect to opt out of advertising cookies. Please note, without cookies or pixel tags, you may not be able to take full advantage of all features of our Services.

Some web browsers incorporate a “Do Not Track” feature (“DNT”) that signals to the websites that you visit that you do not want to have your online activity tracked. Many websites and applications, including our Services, do not currently respond to web browser DNT signals because such signals are not yet uniform. For more information about DNT signals, please visit http://allaboutdnt.com.

Your California Rights

California Civil Code Section 1798.83 permits individual California residents to request certain information regarding our disclosure of certain categories of Personal Information to third parties for those third parties’ direct marketing purposes. To make such a request, please contact us using the information in the “Contact Us” section below. This request may be made no more than once per calendar year, and we reserve our right not to respond to requests submitted other than to the email or mailing addresses specified below. Note that we do not currently share Personal Data with third parties for those third parties’ direct marketing purposes.

How to Access, Modify or Delete Information

If you have any questions about accessing, modifying or deleting your Personal information, including Personal Information that you submit to us through the Services, please contact us using the contact information below.

Children’s Information

Censinet respects the privacy of all online users, especially children. Our Services are not intended for use by children under 18 years of age, and we do not knowingly collect information, including personal information as defined by the Children’s Online Privacy Protection Act, from children under the age of 13. If you are a parent or guardian of a child under the age of 13 and believe he or she has disclosed personal information to us, you may contact us at support@censinet.com to request that we delete and stop use of that information. If we learn that we have received any information directly from a child under age 13 without first receiving his or her parent’s verified consent, we will use that information only to respond directly to that child (or his or her parent or legal guardian) to inform the child that he or she cannot use the Services. We will then subsequently delete that child’s information.

How We Protect Your Information

The security of Personal Information is important to us. We use reasonable safeguards aimed to protect against unauthorized use, disclosure, alteration or destruction of the Personal Information we collect and maintain. You should keep in mind, however, that no data transmitted over the Internet is 100% secure and any information disclosed online can potentially be collected and used by parties other than the intended recipient. As a result, while we strive to protect your information, we cannot guarantee or warrant the security of any information you transmit to or from our Services.

Note to International Visitors

The Services are intended for use in the United States of America only. All matters relating to our Services are governed by the laws of the Commonwealth of Massachusetts in the United States of America. If you visit our Services or contact us from outside of the United States of America, please be advised that (i) any information you provide to us or that we automatically collect will be transferred to the United States of America; and (ii) that by using our Services or submitting information, you explicitly authorize its transfer to and subsequent processing in the United States of America in accordance with this Privacy Policy.

Changes to this Privacy Policy

We reserve the right to change or replace this Privacy Policy at any time. Please check back from time to time to ensure that you are aware of any changes or updates to the notice. We will indicate the Privacy Policy’s effective date at the top of this page. Your continued use of the Services after changes have been posted indicates your consent to and amended terms of the Privacy Policy.

If we make material changes that would impact your use of the Services, we will endeavor to notify you of the changes, such as by posting a notice directly on the Services, by sending an email notification (if you have provided your email address to us), or by any other reasonable method. You hereby consent to receive electronic communications from us.

Contact Us

Please contact us with any comments, questions, complaints, or suggestions you might have regarding the privacy policy described in this statement. You may send us an email at support@censinet.com; or write us at Censinet, 101 Arch Street, Suite 800, Boston, MA 02110