Privacy Policy

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Purpose

Engios Digital LLC respects the privacy of its customers, business partners, and website visitors (collectively “you”). TheEngios Privacy Statement (the “Privacy Statement”) describes the information that we collect, how we obtain theinformation, and how we may use or disclose that information. This Privacy Statement also describes the measures we taketo protect the security of the information and how individuals can contact us about our privacy practices.Engios complies with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework as set forth by the U.S.Department of Commerce regarding the collection, use, and retention of personal information transferred from theEuropean Union and Switzerland to the United States. If there is any conflict between the terms in this privacy policy andthe Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, andto view our certification, please visit https://www.privacyshield.gov/.


Scope

This Privacy Statement covers our privacy practices with respect to the collection, use, and disclosure of personal
information obtained through:

1. Interaction with all Engios website properties. In addition to its websites, Engios provides web-based tools which require individuals to log-in to retrieve data or to update product information. These web-based tools and the Engios websiteproperties, collectively, are referred to as the Engios Websites (the “Engios Websites”).
2. Marketing services provided to Customers including but not limited to website design & development and inbound
marketing services, (collectively, “Engios Marketing Services”).
3. Tracking services provided to Customers including but not limited to website tracking services and call tracking services,
(collectively, “Engios Tracking Services”)

In this Privacy Statement, the Engios Websites, Engios Product Data Solutions and Engios Marketing Services and Engios
Tracking Services are collectively referred to as the “Engios Service” or “Engios Services.”

You should review this Privacy Statement carefully, because if you do not agree with our practices, you should not use the
Engios Services. By using the EngiosServices, you accept and agree to our privacy practices.

Definition


For the purposes of this Privacy Statement, where not otherwise defined, the following terms have the meanings set forth:
“Customer” means any entity that purchases Engios Product Data Solutions or Engios Marketing Services from Engios.
“Providers” means third parties that advertise on Engios Websites or provide services, features or information in
connection with Engios Websites.
“Suppliers” means companies that are a part of Engios' database of companies.

How we collect information

As further described below, we collect information from visitors to the Engios Websites and users of the Engios Services
from several sources: We collect information you provide to us when you:

  • register for a Engios Website;
  • fill out forms on a Engios Website;
  • submit data and content via a Engios Website, participate in bulletin boards, engage in a chat, post a comment,participate in forums or other interactive features of a Engios Website or request further information or services fromus, one of our Customers or other Suppliers listed on the site;
  • enter a contest or promotion we sponsor;
  • report a problem with a Engios Website;
  • contact us;complete our surveys;
  • or subscribe to our email newsletters.

We collect information from third parties as follows:Engios may collect reporting and analytics information from third parties in connection with your use of the Services. We automatically collect information as you navigate through the Engios Websites.We use cookies to collect information. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to the Engios Websites. You may refuse to accept cookies by activating the appropriate setting on your browser. You may also set your browser to alert you when cookies are being sent.

However, if you do so, please note that some parts of the Engios Websites may then be inaccessible or function improperly. See more detailed information about what cookies are and how we use them under “Cookies and Other Forms of Automated Collection” below.Engios collects personal information on behalf of our Customers from visitors or users who:

  • engage in e-commerce transactions with Customers via the Engios Services;
  • submit informational requests and requests for pricing or quotations from Customers.submit forms that may be required to download Supplier Research Reports or other product information requests fromCustomers.access Customer websites that use Engios Tracking Services

Customers, not Engios, are obligated to obtain consent from users to collect personal information for these purposes.

Information we collect

We collect personal information including, without limitation, company name and address, mailing address, email address,IP address and telephone number.

We collect details about your website visits, including, but not limited to, your IP address, usage patterns, traffic data,location data, logs and other communication data and the resources that you access, as well as information about your computer and internet connection, including your operating system and browser type.Via persistent cookies, which are data files that remain on your computer for future visits until deleted, we may track your behavior at other websites, including what sites you visit and how long you spend there.In addition to the foregoing, Engios may collect information on behalf of Customers who have provided forms residing within the Engios Services, or Customers who have implemented a Engios Tracking Service, namely

  • Company name and address.
  • User contact information including, first name, last name, phone number and email address.
  • Payment information (credit/debit card information) in connection with an ecommerce transaction.
  • Informational requests and requests for pricing or quotes.Information about the user’s movements as they navigate throughout the Engios Services.

How we use information collected

We use information that we collect about visitors to the Engios Services for the following purposes:

  • To present Engios Websites and Customer websites and catalogs and their contents in a suitable and effective mannerfor you and for your computer or mobile device.
  • To diagnose and resolve technical problems with a Engios Website and Customer websites and catalogs.
  • To improve Engios Websites and Customer websites and catalogs.
  • To provide you with information, products or services that you request from us or our Customers.
  • To provide usage reports to Customers who advertise or provide other services on Engios Websites.
  • To provide reporting to Customers who provide information, applications and other services.
  • To carry out our obligations and enforce our rights arising from any contracts entered into between Engios and ourCustomers, including without limitation, Engios Website Terms and Conditions.
  • To notify you about changes to a Engios Service or obtain any required consent.
  • To allow you to participate in interactive features of a Engios Website and Customers’ websites and catalogs, when youchoose to do so.For industry analysis, benchmarking, analytics, marketing, and other business purposes.
  • To track your browsing behavior, such as the pages you visited over time.
  • To improve your content experience as a newsletter subscriber.
  • To improve your Engios Website experience

For example, Engios uses a third party for reporting and analytics to measure the effectiveness of our Engios Websites,marketing efforts for the Engios Websites (for example, the effectiveness of email promotions) and to identify areas for improvement.

Cookies and Other Forms of Automated Collection

We use “cookies” to help us improve the Engios Websites. A cookie is a small piece of data sent from a website and storedon a visitor’s computer by the visitor’s web browser. We use session cookies while you are visiting to obtain informationabout your general Internet usage and to:

  • Estimate our audience size and usage patterns.
  • Store information about your preferences, allowing us to customize our Engios Websites.
  • Speed up your searches.Authenticate your access to various areas of a Engios Website.
  • Recognize you when you return to a Engios Website.Track when you respond to surveys.
  • Provide a consistent website look and feel.
  • Capture feedback from site users.
  • Connect via social media applications.
  • Conduct site testing.Provide analytics services about the use of the Engios Websites.Authenticate a user’s access to the Service.
  • Track session state in the Service.
  • Recognize the user when returning to the Service.

We use third-party ad servers or ad networks, to serve advertisements within and after you visit Engios Websites. Thesecompanies can also send their own cookies. Please note that if an advertiser asks us to show an advertisement to a certainaudience or audience segment and you respond to that ad, the advertiser or ad-server may conclude that you fit thedescription of the audience they are trying to reach. We only authorize our third-party ad servers to employ anonymouscookies for ad delivery and anonymous targeting. These third-party ad servers do not collect, nor do we give them access,to any personally identifying information about you.

Analytics and Interest-Based Advertising

Certain companies may participate in the Digital Advertising Alliance ("DAA") AdChoices Program and may display anAdvertising Option Icon for interest-based ads that links to an opt-out tool which allows you to exercise certain choicesregarding targeting. You can learn more about the DAA AdChoices Program at http://www.youradchoices.com/. In addition,certain advertising networks and exchanges may participate in the Network Advertising Initiative (“NAI”). NAI has developeda tool that allows consumers to opt-out of certain targeted advertising delivered by NAI members' ad networks. To learnmore about opting out of targeted advertising or to use the NAI tool, visit http://www.networkadvertising.org/choices/.Please be aware that, even if you are able to opt-out of certain kinds of targeted advertising, you will continue to receivenon-targeted ads. We are not responsible for effectiveness of, or compliance with, any third-parties’ opt-out options orprograms or the accuracy of their statements regarding their programs.

Sharing of Information We Collect

As set forth more fully above, we collect certain data when you use the Engios Services. We do not share, sell, rent or tradepersonal information collected through the Engios Services with third parties for their promotional purposes except asexpressly set forth herein, or with your explicit consent.We may disclose personal information that you provide to us via the Engios Services to our subsidiaries and affiliates(including those located outside the European Economic Area and Switzerland) as well as to the following third partiesunder certain conditions:

  • Contractors, business partners and service providers we use to support our business or who provide services on ourbehalf. Personal information is shared only to the extent necessary for the third party to provide specific services orfunctions. These third parties (and any subcontractors) are subject to strict data processing requirements and arerestricted from utilizing, sharing or retaining your personal information for any other purpose.
  • A buyer or acquirer in the event of merger, acquisition, or any form of sale or transfer of some or all of our assets(including in the event of a reorganization, dissolution or liquidation). In such case personal information held by usabout our website visitors will be among the assets transferred.
  • Our Customers when we provide you with their products and services you have requested.
  • Customers to enable them to provide their website users with information, products or services that such usersrequest.
  • If you ask us to contact you about goods and services that may be of interest to you, we may use your personalinformation or permit selected third parties to use your personal information to provide you with such services.

We may also disclose your personal information to the forgoing third parties or others:

  • To facilitate communications with you or between you and the companies that appear on the Engios Websites ornewsletters.
  • To comply with any court order or other legal obligation.
  • In response to lawful requests by public authorities, government, law enforcement officials or private parties as we, inour sole discretion, believe necessary or appropriate to respond to claims and legal process (such as subpoenarequests) or to meet national security or law enforcement requirements. To the extent we are legally permitted to doso, we will take reasonable steps to notify you in the event that we are required to provide your personal information tothird parties as part of the legal process.
  • To enforce or apply our Engios Website Terms and Conditions or terms of any other agreement, including agreementbetween Customer and Engios pursuant to which the Customer purchased access to the Service.
  • To protect the rights, property, or safety of Engios, our Customers, and our Customer’s website visitors or others.
  • To prevent or stop activity we consider to be illegal or unethical.

Solely with regard to the Engios Websites, we aggregate information we collect to provide usage reports to Customers whoadvertise or provide other services on Engios Websites

Accountability for Onward Transfer of Personal Information

Engios transfers personal data to third parties acting as agents of Engios. Engios will only transfer personal information tothird parties for limited and specified purposes and has determined that the agent is able to provide at least the same levelof privacy protection as is required by the Privacy Shield Principles. Engios ensures that the agent can effectively processthe personal information transferred by Engios in a manner consistent with Engios’s obligations under the Privacy ShieldPrinciples. We also require agents to notify us if they can no longer meet their obligation to provide the same level ofprotection as is required by the Privacy Shield Principles. Engios, after receiving such notice will take reasonable andappropriate steps to stop and remediate unauthorized processing of personal information. Engios can provide a summaryor a representative copy of the relevant privacy provisions of its contract with that agent to the Federal Trade Commissionupon request.

Engios remains liable if its agent processes personal data in a manner inconsistent with the Privacy Shield principles, unlessEngios proves that it is not responsible for the event giving rise to the damage.

Communicating With Suppliers and Providers

When you use the communication features and software applications on Engios Websites to initiate contact with Suppliersor Providers, you may be asked to supply personal information, including one or more of the following: name, telephonenumber, fax number, postal address and email address, required by these companies to respond to your request tocontact you, depending on how you wish the Supplier or Provider to respond to your request. We will only forward aSupplier or Provider the information you provide.If you choose to call a phone number listed on the Engios Websites for a Supplier or Provider, your phone contactinformation, including such information as your phone number, name and location, may be collected and provided to theSupplier or Provider. Additionally, the phone call may be monitored or recorded if a recorded message or other notificationis provided at the beginning of the call to this effect, and the recording will be made available to the Supplier or Provider.Engios and its affiliates, agents, contractors or service providers may also monitor, store, review and access suchinformation and call recordings and use them in connection with the provision of services to Suppliers or Providers forbusiness and marketing purposes.Additionally, many Suppliers or Providers may make certain services, information and software applications, such asSupplier Research Reports or white papers, available to the users of Engios Services free of charge. Some of these Suppliersor Providers may require that you provide your contact and personal information in exchange for access to these services,information and applications. If you do not provide the required information, you will not be able to access these services,information and applications. Once information has been provided to a Supplier or Provider, it is out of the control ofEngios and subject to the policies of that Supplier or Provider.

Public Forums and Comments

Your contributions in public forums, including comment threads, are posted on and transmitted to other visitors of theEngios Websites at your own risk. Please be aware that no security measures are perfect or impenetrable. Additionally, wecannot control the actions of other visitors of the Engios Websites with whom you may choose to share your contributions.Therefore, we cannot and do not guarantee that your contributions will not be viewed by unauthorized persons. We are notresponsible for circumvention of any privacy settings or security measures contained on the Engios Websites. Youunderstand and acknowledge that, even after removal, copies of your contributions may remain viewable in cached andarchived pages, or might have been copied or stored by other websites. Proper access and use of information provided onthe Engios Websites, including your contributions, is governed by the Engios Website Terms and Conditions and known orsuspected violations should be reported to our Privacy Officer via email. We recommend that you do not share personalinformation in your contributions.

International Transfer of Data

Engios may store and process any information collected in connection with the Engios Services in any country where wehave facilities or in which we engage service providers. A list of Engios’ global offices is provided below. By using EngiosServices, you consent to the collection, storage, transfer and processing of information outside of your country ofresidence, including in the United States.

Engios Digital

LLC503

Lawrence Street

Ann Arbor, MI 48104USA

Transfers of Personal Data

Engios complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by theU.S. Department of Commerce regarding the collection, use and retention of personal information transferred from theEuropean Economic Area and Switzerland to the United States. To learn more about the Privacy Shield Framework(s) andthe scope of Engios’ participation, please visit the Department of Commerce’s website, located athttps://www.privacyshield.gov/. With respect to personal information received or transferred pursuant to the Privacy ShieldFramework(s), Engios is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission.

Data Integrity and Purpose Limitation

Engios limits collection of personal information to the information that is relevant for the purposes of processing and wewill not process such personal information in a way that is incompatible with the purposes for which it has been collectedor subsequently authorized by you. To the extent necessary for those purposes, we will also take reasonable steps toensure that personal information is reliable for its intended use, accurate, complete and current.

Security Statement

Engios maintains reasonable and appropriate measures to protect the personal information obtained through the Servicefrom loss, misuse and unauthorized access, disclosure, alteration and destruction.

Accessing and Correcting Your Personal Information

You may send us an email to request access to, correct or delete any personal information that you have provided to us inconnection with the Website. We will make reasonable efforts to respond to such requests, but reserve the right to enforcereasonable limits in cases where the legitimate rights of persons other than the individual would be violated or where theburden or cost of providing access would be disproportionate to the risks to the individual's privacy

Customer End-User Data

Since each Customer is in control of what information, including any personal information, it collects from its users, howthat information is used and disclosed, and how that information can be changed, users of the Service must contact theapplicable Customer administrator identified within the Customers privacy policy with any inquiries about how theCustomer uses and discloses personal information and how to access or correct personal information contained inCustomer data.

Communication Preferences and Choices

We provide certain choices regarding the information website visitors provide to us. We have created mechanisms toprovide you with the following control over your information when using the Engios Services. If you no longer wish to haveyour email address used for promotional purposes by Engios, you may withdraw consent at any time by clicking on the“unsubscribe” link located in the emails sent by Engios or by contacting us, or via your user preference settings.

Third Party Websites and Applications

Engios Websites may link to websites that are not owned or controlled by Engios. As such, this Privacy Statement does notapply to information collected on any third-party site or by any third-party application that may link to or be accessible fromEngios Websites. In addition, Customers and other third parties, including our business partners and consultants, maydevelop applications or provide services to you or other third parties using our Service. This Privacy Statement does notapply to information collected by Customers, our business partners and other third parties or third-party applications orservices, even if this information is collected using Engios Services.

Changes to Our Privacy Statement

Engios reserves the right to update or change this Privacy Statement from time to time. Your continued use of the Websiteor Service is deemed to be acceptance of any updates or changes we make to this Privacy Statement and as such, we askthat you review the Privacy Statement periodically for any updates or changes that we may have made.

Contact Information

To ask questions or comment about this Privacy Statement and our privacy practices or if you need to update, change orremove your information, contact us.

Engios Digital

LLCAttn:

Privacy503

Lawrence StreetAnn Arbor, MI 48104

Independent Recourse Mechanism

In compliance with the Privacy Shield Principles, Engios commits to resolve complaints about our collection or use of yourpersonal information. EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should firstcontact Engios.

Engios has further committed to refer unresolved Privacy Shield complaints to ICDR/AAA, an alternative dispute resolutionprovider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we havenot addressed your complaint to your satisfaction, please contact or visit ICDR/AAA complaint linkhttp://go.adr.org/privacyshield.html for more information or to file a complaint. The services of ICDR/AAA are provided at nocost to you.

PRIVACY RIGHTS IN NON-U.S. JURISDICTIONS

Accuracy and Access to Personal Information

EU and Swiss persons may request access to their personal information under this policy to the full extent required byapplicable law in the home country of the person making the request. Such persons may request the correction,amendment, or deletion of their personal information that is inaccurate or has been processed in violation of the PrivacyShield Principles. Engios will reasonably fulfill such requests to the extent required by applicable law.EU and Swiss persons have the right to ask us not to process their personal information for marketing purposes. We willinform you (before collecting your information) if we intend to use your information for such purposes or if we intend todisclose your information to any third party for such purposes. You can exercise your right to prevent such processing bydeclining to submit your personal information when so informed. You can exercise these rights at any time by contacting usor by sending a letter to the addresses set forth in Contact Information above.

Revocation of consent

EU and Swiss persons also have the right to revoke their given consent regarding the use and sharing of their personalinformation. However, it is important to note that in some cases such requests may not be immediately or fully executedbecause it is possible that we have a legal obligation to keep using your personal information. Also, you must consider thatfor certain purposes, the revocation of consent means that we cannot continue providing the services you requested. Youcan revoke your consent at any time by contacting us by sending a letter to the addresses set forth Contact Informationabove.

Accountability and Inquiries

Any EU or Swiss person who is not satisfied with Engios’s compliance with Privacy Shield may contact Engios to resolve suchcomplaints or by sending a letter to the addresses set forth Contact Information above. If any EU or Swiss person believesthat such a complaint has not been resolved, he or she agrees first to try and settle the dispute by mediation, administeredby the International Centre for Dispute Resolution under its Mediation Rules, before resorting to arbitration, litigation, orsome other dispute resolution procedure. The rules governing these procedures and information regarding how to file aclaim free of charge can be found here: http://go.adr.org/privacyshield.html.Any EU or Swiss person who remains dissatisfied may contact his or her national Data Protection Authority in the countrywhere the person resides. Engios has agreed to cooperate and comply with appropriate EU Data Protection Authorities andthe Department of Commerce in resolving such disputes. If an EU or Swiss person remains dissatisfied and meets the prearbitration requirements of Annex I Part C of the EU – U.S. Privacy Shield Framework, the person may invoke bindingarbitration pursuant to procedures in Annex I of the EU – U.S. Privacy Shield Framework Principles found here:https://www.privacyshield.gov/article?id=ANNEX-I-introduction

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Scope

This Privacy Statement covers our privacy practices with respect to the collection, use, and disclosure of personal
information obtained through:

1. Interaction with all Engios website properties. In addition to its websites, Engios provides web-based tools which require individuals to log-in to retrieve data or to update product information. These web-based tools and the Engios websiteproperties, collectively, are referred to as the Engios Websites (the “Engios Websites”).
2. Marketing services provided to Customers including but not limited to website design & development and inbound
marketing services, (collectively, “Engios Marketing Services”).
3. Tracking services provided to Customers including but not limited to website tracking services and call tracking services,
(collectively, “Engios Tracking Services”)

In this Privacy Statement, the Engios Websites, Engios Product Data Solutions and Engios Marketing Services and Engios
Tracking Services are collectively referred to as the “Engios Service” or “Engios Services.”

You should review this Privacy Statement carefully, because if you do not agree with our practices, you should not use the
Engios Services. By using the EngiosServices, you accept and agree to our privacy practices.

How we collect information

As further described below, we collect information from visitors to the Engios Websites and users of the Engios Services
from several sources: We collect information you provide to us when you:

  • register for a Engios Website;
  • fill out forms on a Engios Website;
  • submit data and content via a Engios Website, participate in bulletin boards, engage in a chat, post a comment,participate in forums or other interactive features of a Engios Website or request further information or services fromus, one of our Customers or other Suppliers listed on the site;
  • enter a contest or promotion we sponsor;
  • report a problem with a Engios Website;
  • contact us;complete our surveys;
  • or subscribe to our email newsletters.

We collect information from third parties as follows:Engios may collect reporting and analytics information from third parties in connection with your use of the Services. We automatically collect information as you navigate through the Engios Websites.We use cookies to collect information. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to the Engios Websites. You may refuse to accept cookies by activating the appropriate setting on your browser. You may also set your browser to alert you when cookies are being sent.

However, if you do so, please note that some parts of the Engios Websites may then be inaccessible or function improperly. See more detailed information about what cookies are and how we use them under “Cookies and Other Forms of Automated Collection” below.Engios collects personal information on behalf of our Customers from visitors or users who:

  • engage in e-commerce transactions with Customers via the Engios Services;
  • submit informational requests and requests for pricing or quotations from Customers.submit forms that may be required to download Supplier Research Reports or other product information requests fromCustomers.access Customer websites that use Engios Tracking Services

Customers, not Engios, are obligated to obtain consent from users to collect personal information for these purposes.

Information we collect

We collect personal information including, without limitation, company name and address, mailing address, email address,IP address and telephone number.

We collect details about your website visits, including, but not limited to, your IP address, usage patterns, traffic data,location data, logs and other communication data and the resources that you access, as well as information about your computer and internet connection, including your operating system and browser type.Via persistent cookies, which are data files that remain on your computer for future visits until deleted, we may track your behavior at other websites, including what sites you visit and how long you spend there.In addition to the foregoing, Engios may collect information on behalf of Customers who have provided forms residing within the Engios Services, or Customers who have implemented a Engios Tracking Service, namely

  • Company name and address.
  • User contact information including, first name, last name, phone number and email address.
  • Payment information (credit/debit card information) in connection with an ecommerce transaction.
  • Informational requests and requests for pricing or quotes.Information about the user’s movements as they navigate throughout the Engios Services.

How we use information collected

We use information that we collect about visitors to the Engios Services for the following purposes:

  • To present Engios Websites and Customer websites and catalogs and their contents in a suitable and effective mannerfor you and for your computer or mobile device.
  • To diagnose and resolve technical problems with a Engios Website and Customer websites and catalogs.
  • To improve Engios Websites and Customer websites and catalogs.
  • To provide you with information, products or services that you request from us or our Customers.
  • To provide usage reports to Customers who advertise or provide other services on Engios Websites.
  • To provide reporting to Customers who provide information, applications and other services.
  • To carry out our obligations and enforce our rights arising from any contracts entered into between Engios and ourCustomers, including without limitation, Engios Website Terms and Conditions.
  • To notify you about changes to a Engios Service or obtain any required consent.
  • To allow you to participate in interactive features of a Engios Website and Customers’ websites and catalogs, when youchoose to do so.For industry analysis, benchmarking, analytics, marketing, and other business purposes.
  • To track your browsing behavior, such as the pages you visited over time.
  • To improve your content experience as a newsletter subscriber.
  • To improve your Engios Website experience

For example, Engios uses a third party for reporting and analytics to measure the effectiveness of our Engios Websites,marketing efforts for the Engios Websites (for example, the effectiveness of email promotions) and to identify areas for improvement.

Cookies and Other Forms of Automated Collection

We use “cookies” to help us improve the Engios Websites. A cookie is a small piece of data sent from a website and storedon a visitor’s computer by the visitor’s web browser. We use session cookies while you are visiting to obtain informationabout your general Internet usage and to:

  • Estimate our audience size and usage patterns.
  • Store information about your preferences, allowing us to customize our Engios Websites.
  • Speed up your searches.Authenticate your access to various areas of a Engios Website.
  • Recognize you when you return to a Engios Website.Track when you respond to surveys.
  • Provide a consistent website look and feel.
  • Capture feedback from site users.
  • Connect via social media applications.
  • Conduct site testing.Provide analytics services about the use of the Engios Websites.Authenticate a user’s access to the Service.
  • Track session state in the Service.
  • Recognize the user when returning to the Service.

We use third-party ad servers or ad networks, to serve advertisements within and after you visit Engios Websites. Thesecompanies can also send their own cookies. Please note that if an advertiser asks us to show an advertisement to a certainaudience or audience segment and you respond to that ad, the advertiser or ad-server may conclude that you fit thedescription of the audience they are trying to reach. We only authorize our third-party ad servers to employ anonymouscookies for ad delivery and anonymous targeting. These third-party ad servers do not collect, nor do we give them access,to any personally identifying information about you.

Analytics and Interest-Based Advertising

Certain companies may participate in the Digital Advertising Alliance ("DAA") AdChoices Program and may display anAdvertising Option Icon for interest-based ads that links to an opt-out tool which allows you to exercise certain choicesregarding targeting. You can learn more about the DAA AdChoices Program at http://www.youradchoices.com/. In addition,certain advertising networks and exchanges may participate in the Network Advertising Initiative (“NAI”). NAI has developeda tool that allows consumers to opt-out of certain targeted advertising delivered by NAI members' ad networks. To learnmore about opting out of targeted advertising or to use the NAI tool, visit http://www.networkadvertising.org/choices/.Please be aware that, even if you are able to opt-out of certain kinds of targeted advertising, you will continue to receivenon-targeted ads. We are not responsible for effectiveness of, or compliance with, any third-parties’ opt-out options orprograms or the accuracy of their statements regarding their programs.

Sharing of Information We Collect

As set forth more fully above, we collect certain data when you use the Engios Services. We do not share, sell, rent or tradepersonal information collected through the Engios Services with third parties for their promotional purposes except asexpressly set forth herein, or with your explicit consent.We may disclose personal information that you provide to us via the Engios Services to our subsidiaries and affiliates(including those located outside the European Economic Area and Switzerland) as well as to the following third partiesunder certain conditions:

  • Contractors, business partners and service providers we use to support our business or who provide services on ourbehalf. Personal information is shared only to the extent necessary for the third party to provide specific services orfunctions. These third parties (and any subcontractors) are subject to strict data processing requirements and arerestricted from utilizing, sharing or retaining your personal information for any other purpose.
  • A buyer or acquirer in the event of merger, acquisition, or any form of sale or transfer of some or all of our assets(including in the event of a reorganization, dissolution or liquidation). In such case personal information held by usabout our website visitors will be among the assets transferred.
  • Our Customers when we provide you with their products and services you have requested.
  • Customers to enable them to provide their website users with information, products or services that such usersrequest.
  • If you ask us to contact you about goods and services that may be of interest to you, we may use your personalinformation or permit selected third parties to use your personal information to provide you with such services.

We may also disclose your personal information to the forgoing third parties or others:

  • To facilitate communications with you or between you and the companies that appear on the Engios Websites ornewsletters.
  • To comply with any court order or other legal obligation.
  • In response to lawful requests by public authorities, government, law enforcement officials or private parties as we, inour sole discretion, believe necessary or appropriate to respond to claims and legal process (such as subpoenarequests) or to meet national security or law enforcement requirements. To the extent we are legally permitted to doso, we will take reasonable steps to notify you in the event that we are required to provide your personal information tothird parties as part of the legal process.
  • To enforce or apply our Engios Website Terms and Conditions or terms of any other agreement, including agreementbetween Customer and Engios pursuant to which the Customer purchased access to the Service.
  • To protect the rights, property, or safety of Engios, our Customers, and our Customer’s website visitors or others.
  • To prevent or stop activity we consider to be illegal or unethical.

Solely with regard to the Engios Websites, we aggregate information we collect to provide usage reports to Customers whoadvertise or provide other services on Engios Websites

Accountability for Onward Transfer of Personal Information

Engios transfers personal data to third parties acting as agents of Engios. Engios will only transfer personal information tothird parties for limited and specified purposes and has determined that the agent is able to provide at least the same levelof privacy protection as is required by the Privacy Shield Principles. Engios ensures that the agent can effectively processthe personal information transferred by Engios in a manner consistent with Engios’s obligations under the Privacy ShieldPrinciples. We also require agents to notify us if they can no longer meet their obligation to provide the same level ofprotection as is required by the Privacy Shield Principles. Engios, after receiving such notice will take reasonable andappropriate steps to stop and remediate unauthorized processing of personal information. Engios can provide a summaryor a representative copy of the relevant privacy provisions of its contract with that agent to the Federal Trade Commissionupon request.

Engios remains liable if its agent processes personal data in a manner inconsistent with the Privacy Shield principles, unlessEngios proves that it is not responsible for the event giving rise to the damage.

Communicating With Suppliers and Providers

When you use the communication features and software applications on Engios Websites to initiate contact with Suppliersor Providers, you may be asked to supply personal information, including one or more of the following: name, telephonenumber, fax number, postal address and email address, required by these companies to respond to your request tocontact you, depending on how you wish the Supplier or Provider to respond to your request. We will only forward aSupplier or Provider the information you provide.If you choose to call a phone number listed on the Engios Websites for a Supplier or Provider, your phone contactinformation, including such information as your phone number, name and location, may be collected and provided to theSupplier or Provider. Additionally, the phone call may be monitored or recorded if a recorded message or other notificationis provided at the beginning of the call to this effect, and the recording will be made available to the Supplier or Provider.Engios and its affiliates, agents, contractors or service providers may also monitor, store, review and access suchinformation and call recordings and use them in connection with the provision of services to Suppliers or Providers forbusiness and marketing purposes.Additionally, many Suppliers or Providers may make certain services, information and software applications, such asSupplier Research Reports or white papers, available to the users of Engios Services free of charge. Some of these Suppliersor Providers may require that you provide your contact and personal information in exchange for access to these services,information and applications. If you do not provide the required information, you will not be able to access these services,information and applications. Once information has been provided to a Supplier or Provider, it is out of the control ofEngios and subject to the policies of that Supplier or Provider.

Public Forums and Comments

Your contributions in public forums, including comment threads, are posted on and transmitted to other visitors of theEngios Websites at your own risk. Please be aware that no security measures are perfect or impenetrable. Additionally, wecannot control the actions of other visitors of the Engios Websites with whom you may choose to share your contributions.Therefore, we cannot and do not guarantee that your contributions will not be viewed by unauthorized persons. We are notresponsible for circumvention of any privacy settings or security measures contained on the Engios Websites. Youunderstand and acknowledge that, even after removal, copies of your contributions may remain viewable in cached andarchived pages, or might have been copied or stored by other websites. Proper access and use of information provided onthe Engios Websites, including your contributions, is governed by the Engios Website Terms and Conditions and known orsuspected violations should be reported to our Privacy Officer via email. We recommend that you do not share personalinformation in your contributions.

International Transfer of Data

Engios may store and process any information collected in connection with the Engios Services in any country where wehave facilities or in which we engage service providers. A list of Engios’ global offices is provided below. By using EngiosServices, you consent to the collection, storage, transfer and processing of information outside of your country ofresidence, including in the United States.

Engios Digital

LLC503

Lawrence Street

Ann Arbor, MI 48104USA

Transfers of Personal Data

Engios complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by theU.S. Department of Commerce regarding the collection, use and retention of personal information transferred from theEuropean Economic Area and Switzerland to the United States. To learn more about the Privacy Shield Framework(s) andthe scope of Engios’ participation, please visit the Department of Commerce’s website, located athttps://www.privacyshield.gov/. With respect to personal information received or transferred pursuant to the Privacy ShieldFramework(s), Engios is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission.

Data Integrity and Purpose Limitation

Engios limits collection of personal information to the information that is relevant for the purposes of processing and wewill not process such personal information in a way that is incompatible with the purposes for which it has been collectedor subsequently authorized by you. To the extent necessary for those purposes, we will also take reasonable steps toensure that personal information is reliable for its intended use, accurate, complete and current.

Security Statement

Engios maintains reasonable and appropriate measures to protect the personal information obtained through the Servicefrom loss, misuse and unauthorized access, disclosure, alteration and destruction.

Accessing and Correcting Your Personal Information

You may send us an email to request access to, correct or delete any personal information that you have provided to us inconnection with the Website. We will make reasonable efforts to respond to such requests, but reserve the right to enforcereasonable limits in cases where the legitimate rights of persons other than the individual would be violated or where theburden or cost of providing access would be disproportionate to the risks to the individual's privacy

Customer End-User Data

Since each Customer is in control of what information, including any personal information, it collects from its users, howthat information is used and disclosed, and how that information can be changed, users of the Service must contact theapplicable Customer administrator identified within the Customers privacy policy with any inquiries about how theCustomer uses and discloses personal information and how to access or correct personal information contained inCustomer data.

Communication Preferences and Choices

We provide certain choices regarding the information website visitors provide to us. We have created mechanisms toprovide you with the following control over your information when using the Engios Services. If you no longer wish to haveyour email address used for promotional purposes by Engios, you may withdraw consent at any time by clicking on the“unsubscribe” link located in the emails sent by Engios or by contacting us, or via your user preference settings.

Third Party Websites and Applications

Engios Websites may link to websites that are not owned or controlled by Engios. As such, this Privacy Statement does notapply to information collected on any third-party site or by any third-party application that may link to or be accessible fromEngios Websites. In addition, Customers and other third parties, including our business partners and consultants, maydevelop applications or provide services to you or other third parties using our Service. This Privacy Statement does notapply to information collected by Customers, our business partners and other third parties or third-party applications orservices, even if this information is collected using Engios Services.

Changes to Our Privacy Statement

Engios reserves the right to update or change this Privacy Statement from time to time. Your continued use of the Websiteor Service is deemed to be acceptance of any updates or changes we make to this Privacy Statement and as such, we askthat you review the Privacy Statement periodically for any updates or changes that we may have made.

Contact Information

To ask questions or comment about this Privacy Statement and our privacy practices or if you need to update, change orremove your information, contact us.

Engios Digital

LLCAttn:

Privacy503

Lawrence StreetAnn Arbor, MI 48104

Independent Recourse Mechanism

In compliance with the Privacy Shield Principles, Engios commits to resolve complaints about our collection or use of yourpersonal information. EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should firstcontact Engios.

Engios has further committed to refer unresolved Privacy Shield complaints to ICDR/AAA, an alternative dispute resolutionprovider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we havenot addressed your complaint to your satisfaction, please contact or visit ICDR/AAA complaint linkhttp://go.adr.org/privacyshield.html for more information or to file a complaint. The services of ICDR/AAA are provided at nocost to you.

PRIVACY RIGHTS IN NON-U.S. JURISDICTIONS

Accuracy and Access to Personal Information

EU and Swiss persons may request access to their personal information under this policy to the full extent required byapplicable law in the home country of the person making the request. Such persons may request the correction,amendment, or deletion of their personal information that is inaccurate or has been processed in violation of the PrivacyShield Principles. Engios will reasonably fulfill such requests to the extent required by applicable law.EU and Swiss persons have the right to ask us not to process their personal information for marketing purposes. We willinform you (before collecting your information) if we intend to use your information for such purposes or if we intend todisclose your information to any third party for such purposes. You can exercise your right to prevent such processing bydeclining to submit your personal information when so informed. You can exercise these rights at any time by contacting usor by sending a letter to the addresses set forth in Contact Information above.

Revocation of consent

EU and Swiss persons also have the right to revoke their given consent regarding the use and sharing of their personalinformation. However, it is important to note that in some cases such requests may not be immediately or fully executedbecause it is possible that we have a legal obligation to keep using your personal information. Also, you must consider thatfor certain purposes, the revocation of consent means that we cannot continue providing the services you requested. Youcan revoke your consent at any time by contacting us by sending a letter to the addresses set forth Contact Informationabove.

Accountability and Inquiries

Any EU or Swiss person who is not satisfied with Engios’s compliance with Privacy Shield may contact Engios to resolve suchcomplaints or by sending a letter to the addresses set forth Contact Information above. If any EU or Swiss person believesthat such a complaint has not been resolved, he or she agrees first to try and settle the dispute by mediation, administeredby the International Centre for Dispute Resolution under its Mediation Rules, before resorting to arbitration, litigation, orsome other dispute resolution procedure. The rules governing these procedures and information regarding how to file aclaim free of charge can be found here: http://go.adr.org/privacyshield.html.Any EU or Swiss person who remains dissatisfied may contact his or her national Data Protection Authority in the countrywhere the person resides. Engios has agreed to cooperate and comply with appropriate EU Data Protection Authorities andthe Department of Commerce in resolving such disputes. If an EU or Swiss person remains dissatisfied and meets the prearbitration requirements of Annex I Part C of the EU – U.S. Privacy Shield Framework, the person may invoke bindingarbitration pursuant to procedures in Annex I of the EU – U.S. Privacy Shield Framework Principles found here:https://www.privacyshield.gov/article?id=ANNEX-I-introduction