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GDPR Notice

This GDPR Notice (“Notice”) supplements our Privacy Policy and applies to the “personal data,” as defined in the European Union General Data Protection Regulation (“GDPR”), of natural persons who visit our Site including prospective or current customers, business contacts, vendors, and other visitors (“Site Visitors”) and who are located in the European Economic Area (“EEA”) (Individuals,” “you,” or “your”). This Notice is intended to provide you with certain information about your personal data and your rights under GDPR.   Any capitalized terms or other terms not defined herein shall have the meaning ascribed to them in the Privacy Policy or, if not defined herein or in the Privacy Policy, the GDPR. If you are located elsewhere, please see the rest of our Privacy Policy here.

The term “European Economic Area” (or “EEA”) shall mean the then-current member states and member countries of the European Union and European Economic Area, respectively, Switzerland, and the United Kingdom.

With respect to any conflict between this GDPR Notice and the Privacy Policy, the GDPR Notice shall control only with respect to EEA Individuals and their personal data.

GDPR Disclosures

Processor Disclosure: We are a data processor of personal data of our customers (including customers’ customers to who we may transmit data) and other third parties. When serving as a processor, we have certain obligations under GDPR including only processing personal data pursuant to our customers’ instructions reflected in the applicable agreement, providing assistance with fulfilment of rights requests, and implementing appropriate security for personal data. We will forward any inquiries, complaints, or requests received from data subjects with respect to the personal data to the appropriate customer and await instructions before taking any action.

Controller Disclosure & Details:  In some circumstances, we are a data controller of personal data regarding the following categories of EEA Individuals: prospective/current customers and vendors, as applicable (collectively, “Business Contacts”), and our Site Visitors for the purposes and under the legal bases described in the table below. Please note that, in some cases, the categories of data subjects above may overlap (e.g., Business Contacts using the Site are also Site Visitors).

Data Subject Category	Purpose & Legal Basis of Processing
General (applies to all data subjects below)	Information Security: Our web servers will log your IP address and other information (e.g., browser information, operating system, request date/time, user agent string, referral and exiting URL) in order to maintain an audit log of activities performed. We use this information pursuant to our legitimate interests in tracking Site and platform usage, combating DDOS or other attacks, and removing or defending against malicious individuals or programs on the Site and platform.
Business Contacts	Direct Marketing; Platform Demonstrations; Executing Contracts and other Legal Documents; and General Business Development: We use this information for our legitimate interest in sending current or prospective customers email marketing; setting up demos with prospective customers pursuant to their requests; the performance, as necessary, of contracts to which Business Contacts are a party (such as our Terms of Use) or to take requested steps to enter into such contracts; and furthering business relationships (such as by storing Business Contact information within a CRM or other file), ensuring customer satisfaction, and answering inquiries.
Site Visitors	Audience Measurement and Retargeting: We use this information for our legitimate interest to understand how Site Visitors interact with the Site and where such Site Visitors are located (up to city-level only) in order to optimize the Site experience. Note that the last octets of Site Visitors’ IP Addresses have been anonymized.  Site Visitors voluntarily provide personal data for the purpose of receiving additional information or registering for a service or event. The personal data provided by Site Visitors is used only to provide them with communications in specialty areas they select.  When Site Visitors register via our Sites for an event (including webinars and hosted events), we use the personal data they have provided solely for purposes of contacting them about the event, and to let them know about future events if they have indicated that they would like to receive that information.  We also use the information provided by our Site Visitors to respond to and process their requests. Usage and analytics information regarding Site Visitors is used to maintain audit logs of activity on our Sites, track usage of the Sites, improve, maintain and operate our Sites, and for security purposes.

EU Representative: Our representative in the European Union is one of our subsidiaries, Telcordia Operations Ltd.  For contact details, please see under the heading “How to Contact Us”.

Recipients: We receive and process your personal data for the purposes described herein. Such personal data is also disclosed to effectuate the purposes described herein to the following recipients, which recipients may change from time to time: 

• AWS (US): Cloud-based storage provider
• MailChimp (US): Cloud-based marketing automation platform
• Dropbox (US): Enterprise solution for secure file share
• Google Analytics (US): Site audience measurement
• AdRoll (US): Retargeting solution
• Pardot(US): Email Marketing System
• Zoom Info(US): Business Analytics
• Service Desk (US): Support ticket system

We use various service providers to manage our Sites and provide services such as event registration or managing e-mail communications.  Our service providers change from time to time.  Our service providers have entered into contracts with us that restrict what they can do with your personal data and require compliance with GDPR and other applicable laws. If you would like specific information about our service providers who have received your information, please contact us at privacy@���Ƕ���Ƶ.com and we will provide that information to you.

Retention: Please see below for our general retention periods. Please note that the below retention periods may be extended or shortened, as appropriate, based on the context of our relationship with an EEA Individual, and for compliance with legal obligations (e.g., accounting, finances, tax).

We will retain the personal data of prospective customers for seven (7) years, as, historically, we have seen that prospective customers convert into paying customers within such time period. At that point, the prospective customer will have to sign up for marketing or affirmatively demonstrate interest in our products and services.  This retention period may be extended for prospective customers that are in current negotiations with ���Ƕ���Ƶ near the end of such retention period.

Current customers’ personal data will be retained until the relationship terminates, at which point their personal data will be retained by us for six (6) years from the last transaction involving this customer, and any other related legal documentation will be retained permanently, or pursuant to our record retention policies. At that point, the former customer will have to sign up for marketing or affirmatively demonstrate interest in any applicable Service. Other personal data will be retained by us in accordance with our record retention policies.

Your GDPR Rights: As a natural person, you have a right to: (i) request access to, correction and/or erasure of your personal data; (ii) object to processing of your personal data; (iii) restrict processing of your personal data; and (iv) request a copy of your personal data, or have a copy thereof sent to another controller, in a structured, commonly used and machine readable format under the right of data portability. You may exercise these rights and submit a GDPR complaint by contacting: privacy@���Ƕ���Ƶ.com with the subject line “GDPR Notice.”&�Բ�����;

You also have the right to lodge a complaint about the processing of your personal data with an appropriate data protection authority.  As applicable, you may also have a right to exercise third-party beneficiary rights under Standard Contractual Clauses that you may have entered into with us.

Objecting to Legitimate Interest/Direct Marketing: You may object to personal data processed by us. In such case, we will no longer process your personal data unless we can demonstrate appropriate, overriding legitimate grounds for the processing or if needed for the establishment, exercise, or defense of legal claims. You may also object at any time to processing of your personal data for direct marketing purposes by clicking “Unsubscribe” within an automated marketing email or by submitting your request to marcom@���Ƕ���Ƶ.com  with the subject line “GDPR Notice” (the latter for instances where, for example, you would not like to receive follow-ups from our sales team). In such case, your personal data will no longer be used for that purpose.

Transfer of Personal Data outside the EEA: We rely on Standard Contractual Clauses and other approved data transfer mechanisms to ensure adequate protection for your personal data.

Disclosure to Public Authorities: ���Ƕ���Ƶ may be required to disclose personal data in response to lawful requests by public authorities, including for the purpose of meeting national security or law enforcement requirements. We may also disclose personal data to other third parties when compelled to do so by government authorities or required by law or regulation including, but not limited to, in response to court orders and subpoenas.

Corporate Restructuring:  In the event of a merger, reorganization, dissolution or similar corporate event, or the sale of all or substantially all of our assets, we expect that the information that we have collected, including personal data, would be transferred to the surviving entity in a merger or the acquiring entity. All such transfers shall be subject to our commitments with respect to the privacy and confidentiality of such personal data as set forth in this GDPR Notice.

Updates to this GDPR Notice: If, in the future, we intend to process your personal data for a purpose other than that which it was collected, we will provide you with information on that purpose and any other relevant information at a reasonable time prior to such processing. After such time, the relevant information relating to such processing activity will be revised or added appropriately within this GDPR Notice, and the “Effective Date” at the top of this page will be updated accordingly.

How to Contact Us: ���Ƕ���Ƶ is located at 100 Somerset Corporate Blvd., Bridgewater, NJ 08807 USA. Please use this address or, preferably, contact privacy@���Ƕ���Ƶ.com with any questions, complaints, or requests regarding this GDPR Notice; please include the subject line “GDPR Notice.”