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Aptaero Website Data Privacy Policy

Aptaero is committed to protecting your privacy. This Data Privacy Policy tells you about Aptaero’s policy and practice for the collection, use, processing, storage, transfer, protection, and disclosure of information that we may collect about you through our website, www.aptaero.com or any subdomains or Aptaero websites.

Before you access and use our websites, you will be asked to provide your authorization and consent by agreeing to the terms and conditions of this Aptaero Data Privacy Policy and consenting to the collection, your submission (if applicable), and processing of information about you as described herein, in compliance with relevant data

protection laws. The collection, use, processing, storage, transfer and disclosure of your Personal Information (as defined below) will be limited to the terms under which you provide Aptaero your authorization. Aptaero is committed to compliance with all relevant country-specific data privacy laws, including EU Standard Contractual Clauses, model contracts / transfer agreements, privacy statements and policies, and country-specific filings if applicable. This Data Privacy Policy covers www.aptaero.com and all other Aptaero websites.

Collection of Your Personal Information

Personal information (“Personal Information”) is data that can be used to identify, either directly or indirectly, an individual to whom the information applies. The information that we may collect from you includes your name, mailing address, phone number, email address, contact preferences, occupation, login information (account number, password), marketing preferences, social media account information, and as applicable, IP address.

Aptaero will not collect any Personal Information about you unless you voluntarily choose to provide it to us or our partners (e.g. to obtain a newsletter subscription, white papers, participate in surveys, generate product downloads, register for marketing events, promotions

or job applications), you provide your explicit consent, or unless it is permitted by applicable laws and regulations. You can always “opt out” at any time by visiting your subscription preferences page, click the “unsubscribe” link in any email.

Use of Your Personal Information

When you do voluntarily provide us with Personal Information, we will use it to provide you information about our products, process your order, register you for an event, create an account, provide customer service, respond to a specific question, , manage a job application, or provide access to

additional information or offers. We also use the information we collect to improve the content of our website, to notify customers of updates to our website, products, services, maintenance notices, and also to contact customers for marketing and sales purposes, including renewals, that are related to a customer’s specific needs and interests. We do not sell your personal information to any third parties.

Disclosure to Third Parties, Service Providers, and Others

In order to support and enhance the customer relationship with you, Aptaero may store, process, or share your Personal Information with our worldwide partners and affiliates (e.g. channel partners, credit card processors, data hosts and service providers) to perform a function or complete a transaction related to your purchase of Aptaero products and services.

Aptaero also leverages its worldwide partners and affiliates to provide valuable services on our behalf. To provide these services to you we need your explicit consent to share your Personal Information with them. Third parties with whom we share your Personal Information

are all bound by all relevant and applicable data privacy laws, terms of confidentiality and Aptaero’s Privacy Policy.  Aptaero may also share non-personal summary information with our worldwide partners and affiliates. In the event Aptaero shares any information with a worldwide partner or affiliate, Aptaero only does so with your explicit consent and Aptaero ensures that all worldwide partners or affiliates who do receive information protect the information with the same care and policies as Aptaero does. For purposes of this Privacy Policy, non-personal information combined with personal information is treated as Personal Information.

There are times when Aptaero may be required to disclose your Personal Information by law, legal process, litigation, and/or requests from public and governmental authorities. Aptaero may also disclose your Personal Information for purposes of investigations of threats to national security, compliance with requests from law enforcement, or other issues of public importance, or when we determine that disclosure is reasonably necessary to enforce our terms and conditions or protect our operations or users.

Purpose Limitation

Aptaero will collect, use or disclose Personal Information supplied by you, for the purposes

disclosed to you, unless the disclosure is a use of the Personal Information for an additional purpose related to the original purpose, is necessary to prepare, negotiate and perform a contract with you, is required by law or competent governmental authority, is necessary to establish or preserve a legal claim or defense against a legal claim, or is necessary to prevent fraud or other illegal activities.

Cookies and Other Technologies

Aptaero’s websites, advertisements, emails, and online services may use certain automatic

data collection technologies such as cookies to collect data, including personal information, about you while you use our website, our products, and when you interact with us. Collection of user data helps us to understand our users’ behavior, web searches, and where on our websites users have visited. Our website uses cookies to distinguish you from other users of our website, helps us to provide you with a good experience when you browse our website, and allows us to improve our website. A cookie is a piece of information that is stored on your computer’s hard drive by your web browser. When you visit www.aptaero.com (or any of the Aptaero websites), our server recognizes the cookie, giving us information about your last visit to the website. Many browsers accept cookies automatically, but you can adjust the settings in your browser to disable automatic acceptance of cookies. If you choose not to use essential cookies you may experience limited functionality of our website. This Data Privacy Policy only covers Aptaero’s use of cookies and does not cover the use of any propensity management by advertisers that you may connect to through our site. Aptaero does not sell or release your information to any third party advertisers.  Information collected by cookies and similar technologies are treated as non-personal information except to the extent under local law that IP addresses (or like identifiers) are otherwise considered Personal Information.

Accuracy and Retention of Personal Information

Aptaero strives to make it easy for you to keep your Personal Information up to date and to help us maintain its accuracy. Your Personal Information will be stored only for the time period necessary to fulfill the purposes outlined in this Privacy Policy unless otherwise required or permitted by law.

Access

Individuals may request access to personal information about them that Aptaero holds for the purpose of correcting, amending, or deleting that information where it is inaccurate, or has

been processed in violation of the Principles, except where the burden or expense of providing access would be disproportionate to the risks to the individual’s privacy in the case in question, or where the rights of persons other than the individual would be violated.

 

Communications and Subscription Preferences

You have the choice to determine what information you receive from Aptaero about

products and services, and how such information is received,  by specifying your communication preferences by your subscription details at the subscription preferences page. If you wish to discontinue receiving marketing and/or non-transactional e-mails from us, you may do so by using an “unsubscribe” link in any email or by reaching out to your assigned account manager. We would like to emphasize that this provision does not apply to transactional emails related to users’ business relationship with Aptaero.

In the event you choose not to provide certain personal information, we may not be able to respond completely or adequately to your questions, provide updates, and/or information about our products and services. You can always “opt out” of receiving certain communications at any time by clicking the “unsubscribe” link in any email or by contacting your account manager. We will however continue to use your Personal Information for the limited purpose of sending you important notices relating to information about your purchases and changes to our policies and agreements, or for other reasons permitted by applicable law.

Data Security

Aptaero takes the security of Personal Information seriously. To protect your Personal Information that you have provided us against accidental or unlawful destruction, loss or

alteration, Aptaero uses technical and organizational security measures to prevent any unauthorized disclosure or access.

Data Security Breach

Aptaero has implemented strict security controls, intrusion detection software and processes to alert us in the case of a potential or actual intrusion of our information systems. Aptaero has a Data Breach Notification Policy and an established Incident Response Team that will react immediately and execute a Remediation Plan in response to any unauthorized access to our information systems or databases. If any data security breach occurs and it may

impact your Personal Information, you will be notified as soon as possible once the breach has been determined.

Collection and Use of Non-Personal Information

When you access www.aptaero.com (or other Aptaero websites), we may automatically collect non-Personal Information even if you don’t register. For example, this information may include the operating system used, the hardware or device ID used, the domain name of the website that directed you to our website, the number of visits, average time spent on a page and what pages you viewed. We may use this data and share it with our worldwide affiliates to monitor the content and relevancy of the content on our websites to improve the performance, content or your experience on our websites. Through your use of services to access our website and services, your communications data (for example, Internet Protocol Address, or IP Address) or utilization data (information on the telecommunications services you accessed) may be technically generated and could, depending on the applicable law, constitute Personal Information. To the extent it is a necessity, the collection and processing of your communications or utilization data, and the subsequent use of such data will only occur and be performed in accordance with the applicable data privacy protection framework and laws.

Forums, Blogs, Social Media, Third Party Websites and Links

Aptaero is only responsible for privacy practices of Aptaero and its websites. Aptaero’s website may contain links to other websites for additional information and convenience. Aptaero does not control those other websites, endorse or make any representation about other websites, and is not responsible for the privacy practices of those other websites. Some of Aptaero’s websites contain interactive elements such as discussion forums and blogs that allow users to publish their own content. Any information posted on these blogs and forums becomes public, which means it could be read, collected or used by other users in any manner. Aptaero is not responsible for any Personal Information you choose to submit in forums.

Consent to Transfer, Process, and Store Personal Information

Aptaero is a global organization so the information you provide to Aptaero may be transferred or accessed by Aptaero partners, contractors, and affiliates in other countries around the world, each of which are responsible for the Personal Information which it collects and protects your Personal Information in accordance with this Privacy Policy. Aptaero uses approved Model Contractual Clauses for the international transfer of personal information collected in the European Economic Area and Switzerland.

Career Page and Apply for a Job with Aptaero

If you browse or apply for a job in the careers portion of our website, your application and any additional information that you provide may be used to assess your skills and interests against career opportunities at Aptaero. Aptaero may retain this information for reporting purposes that may be required by applicable law.

Right to be Forgotten

Aptaero is committed to taking reasonable steps to ensure that any Personal Information requests to be forgotten will be done so in a reasonable time of the request. However, this doesn’t apply to information that you have made public by posting on our forums, blogs, or have made available to third parties yourself, this information is beyond the reach of what Aptaero can erase. Aptaero will do everything possible to erase your Personal Information if you withdraw your consent (opt out) from receiving information for us and request the right to be forgotten. However, Aptaero will not be able to erase all of your Personal Information if it is technically impossible due to limitations to existing technology, or for legal reasons (for example if Aptaero is mandated by local law to keep the Personal Information). We also do not erase information which is essential for the provision of services to you by Aptaero, or our file information concerning your account with us.

Children’s Privacy

Aptaero will not knowingly collect Personal Information from any person that is not a legal adult, as defined by local law, without insisting that they seek prior parental consent, if such consent is required by applicable law. Aptaero does not target children in connection with its products, services, and websites. In the event Aptaero uses or discloses Personal Information of a person that is not a legal adult, Aptaero will seek parental consent

pursuant to local laws and regulations in order to protect the person that is not a legal adult.

Privacy Shield

With respect to the personal information of our employees, Aptaero, Inc. complies with the EU-US Privacy Shield Framework and adheres to the Privacy Shield Principles of Notice,

Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability. To learn more about the Privacy Shield program, and to view our certification page, visit https://www.privacyshield.gov/.

In compliance with the Privacy Shield Principles, Aptaero is committed to resolving complaints or concerns you may have about privacy or how your personal information is used (refer to the Requests to Access or Correct Information and Resolving Concerns sections of this Privacy Policy). Aptaero, Inc. is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC) with respect to the Privacy Shield. Under certain conditions you may invoke binding arbitration before the Privacy Shield Panel. Where applicable for employee matters, Aptaero, Inc. commits to cooperation with the panel of the EU Data Protection Authorities (DPAs), the state or national data protection authority where the employee works, as applicable, to investigate unresolved complaints. Notwithstanding any language to the contrary in this Privacy Policy, in cases of onward transfer to third parties of personal information of individuals received pursuant to the EU-US Privacy Shield, Aptaero, Inc. is potentially liable.

Changes to this Privacy Policy

As a technology company, our systems will mature and change as will this Data Privacy Policy. Changes to this Data Privacy Policy with the most recent revision date will be posted at www.aptaero.com. We will take the steps to notify you of the material changes to this Data Privacy Policy by posting the changes here or contacting you by e-mail.

Questions

Aptaero is committed to responding to reasonable requests to review any of your Personal Information we may have and to amend, correct, or delete any inaccuracies. To have your information amended, corrected, or deleted, or if you have any questions that weren’t answered in this Data Privacy Policy, you can contact us at Aptaero Inc., 300 N Martingale Rd Suite 250, Schaumburg, IL 60173 or email us at privacy@aptaero.com.