Privacy Policy

FOGLOGIC INC.
PRIVACY POLICY

Last Updated: April 12, 2017

This Privacy Policy (“Privacy Policy“) explains how information is collected, used and disclosed
by FogLogic Inc., a Delaware corporation (“FogLogic”, “we”, or “us”), and applies to information
we collect when you use or access our online or mobile websites (www.foglogic.com), products,
services or applications (collectively, the “FogLogic Services“), or when you otherwise interact
with us. We respect the privacy rights of users and recognize the importance of protecting
information collected about you.
FogLogic complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S.
Privacy Shield Framework. See the section entitled EU-U.S. Privacy Shield and Swiss-
U.S. Privacy Shield, below, for further information.
Changes to This Policy
We may change this Privacy Policy from time to time. If we make any changes, we will notify
you by revising the “Last Updated” date at the top of this Privacy Policy and, in some cases, we
may provide you with additional notice (such as adding a statement to our homepage or sending
you an email notification). We encourage you to review our Privacy Policy whenever you access
the FogLogic Services to stay informed about our practices in connection with your information
and the ways you can help protect your privacy. Your use of any of the FogLogic Services after
the posting of such changes shall constitute your consent to such changes and your consent to
the revised Privacy Policy.
Information Collected
Information You Provide To Us. We collect information you provide directly to us.
• For example, we collect information when you register with FogLogic for an account,
create or modify your account, access and use the FogLogic Services (including but not
limited to when you upload, download, or share data or other information), participate in
any interactive features of the FogLogic Services, make a purchase, request customer
support, communicate with us via third party social media sites or otherwise
communicate with us.
• The types of information we may collect directly from you include your name, username,
email address, postal address, phone number, information about your data collection,
processing and storage preferences, employer’s name, job title, transactional
information (including services purchased or subscribed to and billing address) as well
as any contact or other information you choose to provide. We also store the data or
other information that you upload or provide to the FogLogic Services (“Content”) in
order to be able to provide you with the features and functionality of the FogLogic
Service.
Information We Collect Automatically When You Use the FogLogic Services.

When you access or use the FogLogic Services, we may automatically collect information about you,
including:
• Usage Information: We monitor user activity in connection with the FogLogic Services
and may collect information about the applications and features you use, the websites
you visit, the sizes and names of the files you upload, download, share or access while
using the FogLogic Services, the Content you access and any actions taken in
connection with the access and use of your Content in the FogLogic Services.
• Log Information: We log information about you when you access and use the FogLogic
Services including your Internet Protocol (“IP”) address, access times, browser type and
language, Internet Service Provider (“ISP”), the Web pages that you visit, the Content
you use and the URL of the Web page you visited before navigating to the FogLogic
Services.
• Device Information: If you access the FogLogic Services from a mobile device, we
collect information about the device, including the hardware model, operating system
and version, unique device identifiers, mobile network information (as allowed by the
mobile network) or platform information (as allowed by the specific platform type). We do
not ask for, access or track any location based information from your mobile device at
any time while downloading or using our mobile apps.
• Information Collected by Cookies and Other Tracking Technologies: We use
various technologies to collect information, which may include saving cookies to your
computer or mobile device. Cookies are small data files stored on your hard drive or in
device memory that help us to improve the FogLogic Services and your experience,
customize your experience and preferences, allow you to access and use the FogLogic
Services without re-entering your member ID and/or password, understand which areas
and features of the FogLogic Services are most popular and count visits. We may also
collect information using web beacons (also known as “tracking pixels”). Web beacons
are electronic images (also called “gifs”) that may be used in the FogLogic Services or in
emails that help us to deliver cookies, count visits, understand usage and campaign
effectiveness and determine whether an email has been opened and acted upon. For
more information about cookies and how to disable them, please see “Your Choices”
below.
• Third party cookies: the use of cookies by third party applications is not covered by our
Privacy Policy. We do not have access to or control over such cookies.
• Advertising Cookies: We may partner with third parties to manage our advertising on
other sites. Such third parties may use technologies such as cookies to gather
information about your activities on this site and other sites you visit in order to provide
you advertising based upon your browsing activities and interests.
Use of Information
We may use the information we collect about you for a variety of purposes, including to:
• Provide, operate, maintain and improve the FogLogic Services;
• Enable you to access and use the FogLogic Services, including collecting, uploading,
downloading, processing, storing and sharing Content;
• Send you technical notices, updates, security alerts and support and administrative
messages;
• Provide and deliver the services and features you request, process and complete
transactions, and send you related information, including purchase confirmations and
invoices;
• Respond to your comments, questions, and requests and provide customer service and
support;
• Communicate with you about services, features, offers and events, and provide other
news or information about FogLogic and our select partners;
• Monitor and analyze trends, usage, and activities in connection with the FogLogic
Services and for marketing or advertising purposes;
• Investigate and prevent fraudulent transactions, unauthorized access to the FogLogic
Services, and other illegal activities;
• Personalize and improve the FogLogic Services, and provide content, features, and/or
advertisements that match your interests and preferences or otherwise customize your
experience on the FogLogic Services;
• Link or combine with other information we receive from third parties to help understand
your needs and provide you with better service;
• Enable you to communicate, collaborate, and share files with users you designate; and
• For other purposes about which we notify you.
Processing
By accessing or using the FogLogic Services or otherwise providing information to us, you
consent to the processing and transfer of information in and to the U.S. and other countries and
territories, which may have different privacy laws from your country of residence.
EU-U.S. Privacy Shield and Swiss-U.S. Privacy Shield
FogLogic complies with the EU-U.S. Privacy Shield Framework and the 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 the European Union and Switzerland
to the United States. We have certified to the Department of Commerce that we adhere to the
Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data
Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability. If there is
any conflict between the policies in this privacy policy and the Privacy Shield Principles, the
Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to
view our certification page, please visit https://www.privacyshield.gov/.
Our participation in the Privacy Shield applies to all personal data that is subject to the this
Privacy Policy and which is received from the European Union, European Economic Area, and
Switzerland. We will comply with the Privacy Shield Principles in respect of such personal data.
Our accountability for personal data that we receive under the Privacy Shield and subsequently
transfer to a third party is described in the Privacy Shield Principles. In particular, we remain
responsible and liable under the Privacy Shield Principles if third-party agents that we engage to
process the personal data on our behalf do so in a manner inconsistent with the Principles,
unless we prove that we are not responsible for the event giving rise to the damage.
We encourage European individuals (including Swiss individuals) to contact us should you have
a Privacy Shield-related (or general privacy-related) complaint at legal@foglogic.com. We have
further committed to refer unresolved privacy complaints under the EU-U.S. Privacy Shield
Principles or the Swiss-U.S. Privacy Shield Principles to BBB EU PRIVACY SHIELD, a nonprofit
alternative dispute resolution provider located in the United States and operated by the
Council of Better Business Bureaus. If you do not receive timely acknowledgment of your
complaint, or if your complaint is not satisfactorily addressed, please visit https://www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint. As further
explained in the Privacy Shield Principles, a binding arbitration option will also be made
available to you in order to address residual complaints not resolved by any other means.
FogLogic is subject to the investigatory and enforcement powers of the U.S. Federal Trade
Commission (FTC).
Sharing and Disclosure of Information.
We will not share personal information about you or any Content with any third parties except as
described in this Privacy Policy or in connection with the FogLogic Services. For example, we
may share personal information about you as follows:
• Vendors, Consultants and Other Service Providers: We may share your information
with third party vendors, consultants and other service providers who are working on our
behalf and require access to your information to carry out that work, such as to process
billing, provide customer support, etc.
• Third Party Applications: Certain aspects of the FogLogic Services allow or require
you to connect with third party applications or services. In connection with your use of
any such third party applications or services, such third parties may receive information
about you including your username and any Content you choose to use in connection
with those applications and services, and such third parties may contact you directly as
necessary. The FogLogic Services may automatically collect and upload certain data
from such applications. This Privacy Policy does not apply to your use of such third party
applications and services, and we are not responsible for how those third parties collect,
use and disclose your information and Content. We encourage you to review the privacy
policies of those third parties before connecting to or using their applications or services
to learn more about their information and privacy practices.
• Compliance with Laws: We may disclose your information to a third party if (a) we
believe that disclosure is reasonably necessary to comply with any applicable law,
regulation, legal process or governmental request, (b) to enforce our agreements,
policies and Terms of Service, (c) to protect the security or integrity of the FogLogic
Services, (d) to protect FogLogic, our customers or the public from harm or illegal
activities, or (e) to respond to what we believe in good faith to be an emergency. We
also may be required to disclose an individual’s personal information in response to a
lawful request by public authorities, including to meet national security or law
enforcement requirements.
• Business Transfers: We may share or transfer your information in connection with, or
during negotiations of, any merger, sale of company assets, financing, or acquisition of
all or a portion of our business to another company.
• Aggregated or Anonymized Data: We may also share aggregated or anonymized
information with third parties that does not directly identify you.
Security
While no service is completely secure, FogLogic takes reasonable measures to help protect
information about you from loss, theft, misuse and unauthorized access, disclosure, alteration
and destruction.
The servers on which personal information is stored are kept in a controlled environment with
limited access. While we take reasonable efforts to guard personal information we knowingly
collect directly from you, no security system is impenetrable. In addition, we cannot guarantee
that any passively-collected personal information you choose to include in files you store on our
systems are maintained at levels of protection to meet specific needs or obligations you may
have relating to that information.
You may access your account information and our service only through the use of an individual
user ID and password. To protect the confidentiality of personal information, you must keep your
password confidential and not disclose it to any other person. Please advise us immediately if
you believe your password has been misused. In addition, always logout and close your
browser when you finish your session.
Your Choices
Account Information & Retention. You may update, correct or delete information about you at
any time by logging into your online account and modifying your information or by emailing us
at sales@foglogic.com. We will retain your personal information for the period necessary to fulfill
the purposes outlined in this Privacy Policy. If you wish to deactivate your account, please email
us at sales@foglogic.com, but note that we may retain certain information as required by law or
for legitimate business purposes. We may also retain cached or archived copies of information
about you for a certain period of time.
We will retain your information for as long as your account is active or as needed to provide you
services. We will retain and use your information to comply with our legal obligations, resolve
disputes and enforce our agreements.
Promotional and Newsletter Communications. You may opt out of receiving promotional and
newsletter emails from FogLogic by following the opt-out instructions provided in those emails. If
you opt out, we may still send you non-promotional communications, such as security alerts and
notices related to your access to or use of the FogLogic Services or those about your online
account or our ongoing business relations.
Cookies. Most web browsers are set to accept cookies by default. If you prefer, you can usually
choose to set your browser to remove or reject browser cookies or to prompt you before
accepting such a cookie. Please note that, if you choose to remove or reject browser cookies,
this could affect the availability or functionality of the FogLogic Services.
Direct Marketing Opt-out. All users who have an established business relationship with
FogLogic may choose to opt out of FogLogic’s disclosure of personal information about them to
third parties for direct marketing purposes. If you choose to opt-out at any time after granting
approval email marketing@foglogic.com.
Links to Third Party Websites
We may include links to third party websites from the FogLogic Services. When you click on a
link to a third party website, your activity and use on the linked website is governed by that
website’s policies, not by those of FogLogic. We encourage you to visit their websites and
review their privacy and user policies.
Our Policy Toward Children
The FogLogic Services are not directed to individuals under 13. We do not knowingly collect
personal information from children under 13. If you become aware that a child has provided us
with personal information, please contact us at legal@foglogic.com. If we become aware that a
child under 13 has provided us with personal information, we will take steps to delete such
information.
Contacting Us
Any questions about this Privacy Policy should be addressed to legal@foglogic.com.

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