SureWerx (SW) respects your right to privacy. This policy summarizes what personal information we may collect, how we may use this information, and other important topics relating to your privacy and data protection.

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It is SW policy to comply with all applicable privacy and data protection laws. This commitment reflects the value we place on earning and keeping the trust of our customers, business partners and others who share their personal information with us.

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This Policy applies to all Internet sites and mobile applications operated by or on behalf of SW and includes SW entities worldwide. It also applies to personal information SW may otherwise collect: (i) through our products and services; (ii) when you interact with us by means other than a SW Internet Site or App, for example, in person, by telephone, or at a trade show or training; and (iii) from our customers, distributors, suppliers, vendors, and other business partners.

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General Principles of SW’s Collection, Use and Disclosure of Personal Information

To the extent required by applicable law, whenever SW collects personal information, SW will:

• provide timely and appropriate notice to you about our data practices;

• collect your personal information only for specified and legitimate purposes. The information we collect will be relevant, adequate and not excessive for the purposes for which it is collected;

• process your personal information in a manner consistent with the purposes for which it was originally collected or to which you have subsequently consented;

• take commercially reasonable steps to ensure that your personal information is reliable for its intended use, accurate, complete, and, where necessary, kept up-to-date;

• not use your personal information for direct marketing purposes without giving you an opportunity to “opt-out”; and

• take appropriate measures, by contract or otherwise, to provide adequate protection for personal information that is disclosed to a third party or transferred to another country, including transfers within SW.

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Personal Information SW Collects

SW collects the following types of personal information:

• Information You Provide

  • SW collects personal information you provide us, which may include: (i) contact information, such as your name, company name, job title, address, e-mail address, and phone number; (ii) additional information about you to help us get to know you better, such as your gender, age, date of birth, nationality, professional associations and registration numbers, information about how you use our products, and demographic information; (iii) comments, questions, requests and orders you may make; (iv) financial information needed to process payments if you make purchases, such as credit card or account information or tax identification number; (v) log-in information, including, if applicable, social media account information for login purposes; and (vi) information about your preferences, such as your preferred methods of communication and product types in which you are interested.

• Information Automatically Gathered from Your Device

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• Device and browser information. SW may collect technical information about your device, such as device type, browser type, IP address, operating system, and device identifier. SW collects this information automatically from your device and web browser through cookies and similar technologies.

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• Information about how you interact with us. SW may collect technical data about your usage of SW Internet Sites and Apps and how you interact with our digital advertisements and promotions, such as content viewed or downloaded, features used, links clicked, promotional emails opened, and dates and times of interactions. SW collects this information using cookies and similar technologies.

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• Location information. SW may collect location information, including precise real-time location information from your device and imprecise location information derived from, for example, your IP address or postal code. SW Apps will NOT access precise-real time location information from your device unless you grant permission to do so.

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How SW Uses Your Personal Information

SW may use your personal information to:

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• Develop and manage our relationships with you and our Business Partners. This may include: (i) providing information about SW products, services, and transactions, and advertisements, that may be of interest to you; (ii) providing you and our Business Partners a more consistent experience in interacting with SW, including by learning more about you and how you use and interact with SW Internet Sites, Apps, products, and services; and (iii) planning, managing, and performing under our contractual relationships with our Business Partners.

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• Communicate with you or your company. This may include: (i) informing you of SW products, services, and promotional activities that may be of interest to you or your company; (ii) providing information about relevant SW products, services, and transactions, including, for example, pricing information, technical data, invoice, shipping, or production information, warranty or recall information, or information about product or service improvements; (iii) responding to questions or inquiries that you make, including customer service requests; and (iv) inviting you to participate in, or informing you of the results of, customer satisfaction or market research surveys.

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• Provide and improve our Internet Sites, Apps, products, and services. This may include: (i) customizing them to your preferences or interests, making them more compatible with your technology, or otherwise making them easier to use; (ii) maintaining the security of and otherwise protecting them; and (iii) and developing new SW Internet Sites, Apps, products and services.

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• Address legal issues. This may include: (i) complying with our obligations to retain certain business records for minimum retention periods; (ii) establishing, exercising, or defending legal claims; (iii) complying with laws, regulations, court orders, or other legal process; (iv) detecting, preventing, and responding to fraud, intellectual property infringement, violation of our contracts or agreements, violations of law, or other misuse of SW Internet Sites, Apps, products or services; and (v) protecting SW’s rights or property, or yours or others’ health, safety, welfare, rights, or property.

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SW may also use your personal information for other uses consistent with the context in which the information was collected or with your consent.

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SW may anonymize or aggregate any of the information we collect and use it for any purpose, including for research and product-development purposes. Such information will not identify you individually.

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When SW May Share Your Personal Information

SW will not disclose your personal information except as described here:

• SW may share your personal information with other SW entities, including those in different countries. When we do so, these other SW entities will use your information in a manner consistent with this Policy, any applicable Specific Privacy Statements, and all applicable privacy and data protection laws.

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• SW may also share your personal information with third parties we hire to perform support services for us. These third parties are required to use the personal information we share with them only to perform services on our behalf and to treat your personal information in compliance with all applicable privacy and data protection laws.

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• In some cases, SW may share your personal information with third parties who partner with us to provide products and services to our customers, such as distributors. If so, we will require our Business Partners to use that information in a manner consistent with this Policy, any applicable Specific Privacy Statements, and all applicable privacy and data protection laws.

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• SW may share your personal information with third parties when we have a good faith belief that disclosure is necessary: (i) to comply with a law, regulation, court order, or other legal process; (ii) to detect, prevent, and respond to fraud, intellectual property infringement, violation of our contracts or agreements, violation of law, or other misuse of SW Internet Sites, Apps, products or services; (iii) to protect SW rights or property or yours or others’ health, safety, welfare, rights, or property; or (iv) under similar circumstances. If such an event occurs, we will take appropriate steps to protect your personal information.

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• SW may share your personal information with third parties in connection with the sale, purchase, merger, reorganization, liquidation or dissolution of SW or a SW business unit, or under similar circumstances. If such an event occurs, we will take appropriate steps to protect your personal information.

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• SW may share your information with your permission or at your request.

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SW may share anonymized or aggregated information internally and with third parties for any purpose. Such information will not identify you individually.

·Security of Your Personal Information

Your personal information will generally be stored in SW databases or databases maintained by our service providers. SW takes appropriate measures, by contract or otherwise, to provide adequate protection for personal information that is disclosed to a third party or transferred to another country, including transfers within SW.

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SW maintains reasonable safeguards to protect the confidentiality, security and integrity of your personal information. Although we use security measures to help protect your personal information against unauthorized disclosure, misuse, or alteration, as is the case with all computer networks linked to the Internet, we cannot guarantee the security of information provided over the Internet and will not be responsible for breaches of security beyond our reasonable control.

Links to Third Party Internet Sites and Plugins

SW Internet Sites and Apps may contain links to websites or mobile apps that are not operated by SW and plugins from social media platforms and other third parties. An example of a social media plugin is the Facebook “Like” button. We provide these links and plugins as a service and do not imply any endorsement of the activities or content of the related websites, apps, or social media platforms, nor any association with their operators. To learn about the information collected by these third-party websites, apps, and plugins, please visit their privacy policies. We encourage you to review the privacy policies for the websites, apps, and social media platforms you visit before using them or providing personal information.

Access to Your Personal Information

You may review, correct and update personal information you provide to us by completing a request to do so and sending it to us.

Retention of Your Personal Information

How long we keep your personal information will vary and will depend on the purpose and use of information collected. There are legal requirements that we keep some types of data for specific periods. Otherwise, we will retain it for no longer than is necessary for the purposes for which the data was collected.

Additional Information for EU Residents

• Data controller and contact information

• The controller for personal data collected under this Privacy Policy is the relevant SW entity in your country.

• Your individual rights

  • In accordance with the applicable laws in the European Union, you have the following rights with respect to your personal data, which apply differently in different circumstances: right of access, right to rectification, right to erasure, right to restriction of processing, right to data portability and right to object to processing.

Changes to this Policy and our Privacy Statements

Changes to this Privacy Policy will be posted on this site, along with information on any material changes. SW reserves the right to update or modify this Policy and any Specific Privacy Statements at any time and without prior notice. Any modifications will apply only to the personal information we collect after the posting.

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This Policy was last revised in Jan 2021.