Effective Date: May 16, 2018 Privacy Policy Overview This Privacy Policy (this “Policy”) describes how InRule Technology, Inc. (“InRule”) collects and uses personal information about you when you visit and use our website located at www.inrule.com and its associated webpages (collectively, the “Website”) and related services, when you purchase our products and services, and when you correspond or otherwise communicate with us. In this Policy, “we” and “us” means InRule, and “you” means any person who visits our Website, corresponds with us, or calls us on the phone. When we refer to “personal information” in this Policy, we mean information that directly identifies you (such as your name, postal address, or email address) or data that could be used to indirectly identify you. To provide some background to our customers and their data subjects, we are a data processor that processes personal information solely on behalf of and in accordance with the instructions of our customers (the data controllers). Our customers collect such personal information from their data subjects using our products and services, and such information is automatically stored on servers that are under our or our hosting provider’s control. Our data processing activities are limited to the minimum necessary for performance of the contracts between us and our customers. For more information regarding how a data subject’s information is processed, please refer to the applicable customer’s privacy policy. As part of the account registration process or when you otherwise submit personal information to us through our Website, you will be required to affirmatively consent to the terms of this Policy. By checking the appropriate box(es) and clicking “I accept (or “Accept Cookies”),” you agree that you have read and understand this Policy and that you accept and consent to the privacy practices (including the uses, disclosures, and transfers to third countries outside of the European Union of information about you by InRule) that are described in this Policy. Kindly note that any consent you provide will be entirely voluntary. HOWEVER, IF YOU DO NOT ACCEPT THIS POLICY, THEN YOU SHOULD NOT USE, AND ARE NOT AUTHORIZED TO USE, THE WEBSITE. What Information We Collect We collect a variety of types of information, including: Contact information, such as your name, email address, job title, and company address and phone number; Purchase information, such as the products and services you purchase, credit card or other payment information, and billing and shipping address; Preference information, such as your contact and marketing preferences; Account information, which may include your account username and password, and other information about your account; User-generated information, such as the content you submit in comments to the blog posts on our Website; Correspondence information, including information about your email or other written communications with us, and information that you share in your emails and other written communications with us; Call recordings and voicemail message transcripts including information about your call and information you share when you call us on the phone or leave us a voicemail; and Device and browsing information, including information about your phone, tablet, computer, or other device, and online browsing activity (collectively, “automatically collected information”). Automatically collected information may include IP addresses, countries of origin, unique device identifiers, cookie identifiers, device and browser settings and information, and Internet service provider information. Automatically collected information also may include information about when and how you access and use our Website, such as the date and time of your visit or use, the websites you visit before coming to and after leaving our Website, how you navigate and what you search for using our Website, and the website pages and items you view using our Website. Cookies We Use Strictly Necessary Cookies These cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the site will not then work. These cookies do not store any personally identifiable information. Cookies used OptanonConsent OptanonAlertBoxClosed Performance Cookies These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site. They help us to know which pages are the most and least popular and see how visitors move around the site. All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies we will not know when you have visited our site, and will not be able to monitor its performance. Cookies used _ga _gid _gat Functional Cookies These cookies enable the website to provide enhanced functionality and personalisation. They may be set by us or by third party providers whose services we have added to our pages. If you do not allow these cookies then some or all of these services may not function properly. Cookies Categories vimeo.com vuid Targeting Cookies These cookies may be set through our site by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant adverts on other sites. They do not store directly personal information, but are based on uniquely identifying your browser and internet device. If you do not allow these cookies, you will experience less targeted advertising. Cookies used __ar_v4 _te_ Cookies Categories facebook.com datr fr lu bidswitch.net c tuuid_lu tuuid advertising.com APID IDSYNC outbrain.com adrl 3lift.com tluid casalemedia.com CMPRO CMID CMDD CMST CMRUM3 CMPS CMSC ads.linkedin.com BizoID UserMatchHistory lang linkedin.com lidc bcookie __utma lang __utmv bscookie __qca visit d.adroll.com __adroll google.com APISID SSID PREF SID SAPISID HSID pubmatic.com PUBMDCID PugT KRTBCOOKIE_10 pippio.com pxrc didts nnls did openx.net i taboola.com t_gid taboola_usg doubleclick.net id rlcdn.com pxrc How We Collect Information We collect information on our Website and through email and other communications and interactions with you. We also obtain information from you and from third parties. We collect and obtain information: You provide, such as when you visit or use our Website, make a purchase, contact us through our Website, register for an online account, participate in a survey, fill out a form, or sign up for emails or marketing; From third parties, such as service providers that we use, analytics companies, advertising networks and cooperatives, third parties that provide us with information about you and the different devices you use online, and other third parties that we choose to collaborate or work with; From social media platforms and networks that you use in connection with our Website, or that share or allow you to share information with us, such as LinkedIn and Twitter. For example, if you use functionalities, plugins, widgets, or tools from social media platforms or networks in connection with our Website (for example, to share content from our Website with your friends and followers on social media), we will collect the information that you share with us, or that those social media platforms or networks share with us; Using cookies and other automatic collection methods. For example, we and third parties we work with may collect information from the computer, tablet, phone, or other device that you use to access our Website, or that you use to open an email or click on an advertisement from us. This collection includes automatically collected information, and generally does not include personal information that directly identifies you unless you provide it through our Website or you choose to share it with us. Automatic collection methods we use include: Cookies, which are small text files that many websites automatically download to a user’s computer or other device when they browse online. Cookies are often used to collect standard Internet log information and visitor behavior data. We use cookies to personalize content and ads, to provide social media features, and to analyze our Website traffic. We also share information about your use of our Website with our social media, advertising, and analytics partners. The cookies that our Website uses may include both session-based cookies and persistent cookies (which remain on your computer or other device after your browsing session has ended). For more information about cookies, including how to manage them, visit allaboutcookies.org; Web beacons or tags, which are small images embedded into websites or emails that send information about your computer, tablet, phone, or other device when you visit our Website, or open an email we send to you; Website log files, which we or our service providers tend to create automatically in connection with access to and use of our Website; and Other technologies, which may be similar to or different than the methods noted above. How We Use Information We use the information that we collect and obtain to conduct our business and to provide you with the products, services, and experiences that you request or that we think may be of interest to you. We also may combine any or all of the information that we collect or obtain with other information that we collect or obtain, including but not limited to information obtained from third parties with which we choose to work. We use information: To provide you with products and services, to process, maintain, and service your account, and to provide you with products and services that you request or that we think may be of interest to you; To respond to you, when you contact us through our Website, correspond with us by email, or otherwise communicate with us, complete a form or survey, make a request or inquiry, or share a comment or concern; For personalization of your experiences with us, including to remember your interests and preferences, to personalize Website content, to customize the products and services we share with you, to track and categorize your activity and interests on our Website (including by identifying the different devices you use), and to enrich your experience and on our Website; For marketing and advertising, including to provide social media features, to send you marketing and advertising communications, to segment and build audiences and engage in interest-based advertising, and to personalize the marketing and advertising that we show you (for choices about marketing and advertising, see the “Your Choice and Access Requests” Section below); For analytics, including to understand how you use our Website, to analyze our Website traffic, to determine the methods and devices used to access our Website, and to improve our Website and associated products and services; For our business purposes, including to operate and improve upon our business and lawful business activities, to maintain our accounts and records, for research, to determine your satisfaction with our products and services, to detect and prevent fraud or misuse of our services, to enforce, apply, or comply with any of our terms or policies, including but not limited to this Policy, and for any other business purpose that is permitted by law; For legal, contractual and safety purposes, including to defend or protect us, our customers, you, or third parties from harm or in legal proceedings, to protect our rights, to protect our security and the security of our customers, employees, and property, to respond to court orders, lawsuits, subpoenas, and government requests, to address legal and regulatory compliance, to verify your identity or communications from you, to comply with contracts and other agreements to which we are a party, and to notify you of changes to our terms, policies, or practices. We do not use profiling or make any decisions based solely on the automated processing of your personal information. How We Share Information We share personal information with: Third parties and service providers that provide products or services to us (i.e.: payment processors), that help us market or advertise to you (including co-branded/reseller marketing and advertising), including our advertising and analytics partners (see “Online Advertising, Analytics, and Other Partners We Work With” section below for more information). We may use third parties or service providers to perform any of the actions or activities allowed under this Policy; Social media platforms and networks, such as LinkedIn and Twitter, that offer functionalities, plugins, widgets, or tools in connection with our Website (for example, to share purchases and other content from our website with your friends and followers on social media). If you choose to use these functionalities, plugins, widgets, or tools, certain information will be shared with or collected by those social media companies. For more information about what information is shared or collected, and how it is used, and information about privacy settings on those social media platforms, please see the applicable social media company’s privacy policy; Parties to business transactions,such as those we deal with in mergers, acquisitions, joint ventures, sales of assets, reorganizations, divestitures, dissolutions, bankruptcies, liquidations, or other types of business transactions. In these types of transactions, personal information may be shared, sold, or transferred, and it may be used subsequently by a third party; and Additional third parties,such as law enforcement, government entities, courts, our legal advisors, or other third parties as required or allowed by applicable law, such as for the legal and safety purposes described under the “How We Use Information” Section above, or otherwise to help prevent harm or fraud to us, you, our customers, or other third parties. We also may share personal information with third parties upon your request or with your consent, although we may not be able to accommodate all requests. Online Advertising, Analytics and Other Third Parties We Work With We work with third-party companies for measurement, analytics, and advertising purposes, including to measure website activity, track conversions, target and serve advertisements across the Internet, track and categorize your activity and interests over time on our Website and on third party websites and mobile applications, build a profile of your apparent interests and show you ads on other websites that may be relevant to your apparent interests, and to identify the different device(s) you use to access websites and mobile applications. We share information with these companies, and these companies may collect information, including automatically collected information, when you use our Website through the methods described in the “How We Collect Information” Section above (see “Using cookies and automatic collection methods”). These third-party companies also may possess or obtain information about you from your interactions directly with the third-party companies, with other websites, mobile applications, or other companies that the third-party companies work with, or from your interactions with advertisements the third-party companies help to display to you. The information that these companies collect or that we share may be used to customize or personalize the advertisements that are displayed to you. We may share personal information with the third-party companies we work with for our purposes, though in general we do not share personal information that directly identifies you with third parties for those third-parties’ marketing or advertising purposes unless you request or consent to such sharing and use, or as otherwise described in this Policy. We may also share other information in our discretion, including automatically collected information, which may be used by third parties for third-party marketing, advertising, and other purposes. For information about the choices you have about the online advertising practices described in this section, please see the “Your Choices and Access Requests” Section below. We use Google Ads to serve ads to you on the Google ad network. For more information about Google Ads and how it collects and processes data, click here. For more information about how Google Ads uses cookies and other technologies to personalize ads, click here. Google’s ability to use and share information collected by Google Ads is restricted by Google’s Terms of Service and Privacy Policy. If you would like to learn more about how to manage your Google Ad Settings to opt-out of receiving personalized ads served by Google, click here. Click here if you would like to learn more about how you can install a browser plugin to maintain your preference to opt out of personalized ads from Google, even if you’ve cleared your cookies. We use Google Analytics to measure and report how users interact with our Website, emails, and advertisements to analyze the traffic to our Website and for the other purposes set forth in the “How We Use Information” Section above. For more information about Google Analytics and how it collects and processes data, please see “How Google Uses Data When You Use Our Partners’ Sites or Apps.” For more information about how Google Analytics uses cookies to measure user interactions on websites, click here. Google’s ability to use and share information collected by Google Analytics about your visits to the Site is restricted by Google’s Terms of Service and Privacy Policy. If you do not want your website visit data reported by the Google Analytics JavaScript, you can install the Google Analytics opt-out browser add-on. This add-on instructs the Google Analytics JavaScript to prohibit sending visit information to Google Analytics, but does not prevent information from being sent to the website itself or in other ways to other website analytics services. Click here if you would like to learn more about the Google Analytics opt-out browser add-on, and click here to install the opt-out browser add-on. We use AdRoll to serve personalized ads to you when you visit other websites on the Internet. AdRoll’s ability to use and share information collected by AdRoll is restricted by AdRoll’s Terms of Service and Privacy Policy. If you would like to learn more about how to opt out of personalized advertising served by AdRoll advertisers, click here. Your Choices and Access Requests We offer you choices about how certain personal information is used and shared. Your choices include: Online Advertising.In addition to using the management tools linked-to in the “Online Advertising, Analytics, and Other Third Parties We Work With” Section above, you can manage third-party advertising preferences for some of the third parties we work with to serve advertising across the Internet by utilizing the choices available at http://www.networkadvertising.org/managing/opt_out.asp and http://www.aboutads.info/choices. For mobile users, you also have numerous controls in your Operating System that enable you to choose whether to allow cookies, or share your advertising ID with third parties. For some information on controlling your mobile choices, click here. To help control or block certain ads in mobile applications, you may choose to download and utilize the Digital Advertising Alliance’s mobile app by clicking here. We do not guarantee that all of the third parties we work with will honor the elections you make using those options. Social Media Platforms and Networks.We encourage you to review your privacy options and settings with the social media platforms and networks you use to understand what choices you have about sharing information from those platforms and networks with us. Email Choices.You can opt out of marketing or advertising emails by utilizing the “unsubscribe” link or mechanism noted in marketing or advertising emails you receive from us. Please note that opting out of receiving marketing or advertising emails from us will not apply to transactional communications or legal notices, for example, emails about your orders or about changes to our terms, policies, or business practices. Managing Cookies. You can activate settings on your Internet browser to refuse the setting of some or all cookies. In addition, the website linked to below will tell you how you can remove existing cookies from your browser if you wish. Please keep in mind, however, that if you use your Internet browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our Website and services. For further information about managing cookies, please visit allaboutcookies.org. Please note that disabling or clearing cookies also may affect cookie-based opt-outs by either preventing you from using such cookie-based opt-outs or clearing opt-outs that you have previously set, in which case you would have to revisit the applicable pages and renew your opt-out after clearing cookies. Mobile Devices. Your mobile device may offer settings relating to cookies, pixel tags, and other similar technologies. We encourage to you to visit your device’s help menu to learn about your options to limit tracking when using your device. Access Requests.You may make a request for access to your personal information that we have on file by contacting us through our Website, sending an email, or writing to us at the address specified in the “Additional Information and Contacting Us” section below. We are not able to grant all access requests, and we may request additional information from you in order to verify your identity before accommodating an access request. Rights of Residents in the European Union. If you are a resident of the European Union, you may have certain rights under European data protection law with respect to your personal information, including the right to request access to, correct, amend, delete, limit the use of, or withdraw your consent for the processing of your personal information. You may also have the right to receive a copy of your personal information in a commonly used and machine-readable format and to transmit such data to another controller. To request deletion of, access to, or to make changes to information, or to otherwise exercise any of your rights in this paragraph, email us at info@inrule.com. Please remember that if you delete or limit the use of your personal information, you may not be able to use the services provided through our Website. Security and Retention Although we take steps to help protect the security of personal information you share with us through our Website, information transmitted through the Internet may not be perfectly secure. We do not guarantee the security of your personal information. We will keep your personal information only for as long as necessary for the purposes for which it was collected, to provide you with products or services, to carry out legitimate business interests, and where otherwise required or permitted by law. Links to Other Websites and Services Our Website may provide links to other Internet sites, content, or videos (embedded or direct links) maintained by third parties. We are not responsible for the sites, content, or videos accessed via the links, and we have not reviewed the privacy practices of those third parties. We encourage you to review the privacy practices of those third parties. Browsers Do Not Track Signals Some browsers have incorporated “Do Not Track” (DNT) features that can send a signal to the websites you visit indicating that you do not wish to be tracked. There is not yet a common understanding of how to interpret the DNT signal. We currently do not respond to web browser DNT signals. For information about the choices you have about limiting how you are tracked online (for example, for advertising practices described in this Policy), please see the “Your Choices and Access Requests” Section above. Your California Privacy Rights If you are a California resident under the age of 18, and have a registered account on our Website, California Business and Professions Code Section 22581 permits you to request and obtain removal of content or information you have publicly posted. To make such a request, please send an email with a detailed description of the specific content or information to info@inrule.com. Please be aware that such a request does not ensure complete or comprehensive removal of the content or information you have posted and that there may be circumstances in which the law does not require or allow removal even if requested. Children’s Privacy Our Website is not directed to or intended to be used by individuals under the age of 16. We do not knowingly request or collect personal information from any person under 16 years of age without prior verifiable parental consent. If you believe that your child under the age of 16 has submitted personal information to us in connection with our Website, and without prior verifiable parental consent, please email us at info@inrule.com so that we can take steps to delete the personal information that she or he provided as required in accordance with applicable law. International Users If you provide personal information through our Website, you agree that the personal information will be transferred to and processed in the United States of America and any other country or jurisdiction at our sole discretion. The laws that apply to the use and protection of personal information in the United States or other countries or jurisdictions in which we transfer or process personal information may be different than the laws and protections in your country. Those who access or use our Website from jurisdictions outside the United States do so at their own choice and risk and are solely responsible for compliance with local law. While we take certain steps to safeguard your personal information, please note that the United States has NOT been deemed by the European Commission to ensure an adequate level of protection for personal information. Accordingly, the level of safeguards and legal protections provided in the United States or other non-European countries from which you may access our Website may not be as stringent as that under European Union privacy standards or the privacy laws of some other countries, possibly including your home jurisdiction. BY CHECKING THE APPROPRIATE BOX(ES) AND CLICKING “I ACCEPT” (OR “ACCEPT COOKIES” or “SUBSCRIBE”) YOU AGREE THAT YOU ACCEPT AND FULLY UNDERSTAND THE RISKS OF, AND EXPRESSLY CONSENT TO, THE TRANSFER, STORAGE, AND PROCESSING OF YOUR PERSONAL INFORMATION IN THE UNITED STATES AND OTHER COUNTRIES OUTSIDE OF THE EUROPEAN UNION BY INRULE IN ACCORDANCE WITH THIS POLICY. Additional Information and Contacting Us If you have questions about this Policy or our privacy practices, please contact us by email at info@inrule.com or write to us at: InRule Technology, Inc. 651 W. Washington Blvd, Suite 500 Chicago, IL 60661 If you are a resident of the European Union and your inquiry with InRule has not been satisfactorily addressed, or if you believe we are processing your personal information not in accordance with the law or this Policy, you may file a complaint with the supervisory authority in your country of residence. Updates to This Policy We may make changes to this Policy, and may apply any changes to information previously collected, as permitted by law. When we make material changes to this Policy, we will notify you by posting the updated Policy on our Website, and we will update the effective date at the top of this Policy. By continuing to use our Website after being notified of material changes to this Policy, you agree that the terms of this Policy as of the effective date will apply to information previously collected or collected in the future, as permitted by law. Cookie Removal The following downloadable programs will remove tracking cookies left behind by the websites you have visited: http://www.lavasoftusa.com/products/ad-aware_se_personal.php, http://www.spybot.info/en/download/index.html, and http://www.webroot.com/consumer/products/spysweeper/ Accept, Subscribe, Unsubscribe Visit these pages to accept our Privacy Policy and subscribe to InRule updates. 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