Effective Date: September 26, 2016

Qvidian is committed to protecting the privacy of your information. This Privacy Statement describes Qvidian’s practices, policies and procedures for the collection, use, management and protection of your information.

Qvidian Privacy Statement

Definitions:

"Personal Data" means information relating to an identified or identifiable person. An identifiable person is a person who can be identified, directly or indirectly, by way of example, by particular reference to an identification number associated with one or more identifying factors specific to a person. “Service” means Qvidian’s software that is provided online via web browser, and support in connection therewith, which may store and process Personal Data. “Site” means the Qvidian company website that can be found at www.qvidian.com.

Scope of This Privacy Statement:

This Privacy Statement applies to Personal Data collected on or through the Site and Service by Qvidian.

Information Collected:

The Site collects the following Personal Data:

• Name

• Company

• Email Address

• Phone Number

• Title

The Service collects the following Personal Data:

• Name

• Company

• Address

• Email Address

• Phone Number

• Job Title

Use of Information Collected:

Through the Site and the Service, Qvidian collects and uses your Personal Data to:

• respond to your requests

• make current marketing and sales initiatives relevant to your needs

• communicate product or service information

• provide service and support

• communicate significant website or web content changes

• inform you of future conferences, events, etc.

• deliver product

• receive documents from Qvidian's Service

• manage pages accessed and visited

As part of the Service, customers may upload Personal Data to Qvidian servers located in the United States. In operating and providing the Service, Qvidian acts as a data processor and does not control a customer's Personal Data.

Sharing of Information Collected:

Qvidian does not sell, trade, or rent your Personal Data to others. If in the future, our business practices change we will notify individuals and offer them opt-in or opt-out choice. Unless Qvidian has your permission or is required to do so by law, Qvidian will only share the Personal Data you provide with business partners who are acting on Qvidian's behalf to operate the Site or perform the Service, including third party hosting facilities and infrastructure, and the sales, marketing and operational activities described above (see "Use of Information Collected"). Such Qvidian entities and business partners are subject to this Privacy Statement in addition to certain contractual obligations with respect to the use of your Personal Data. Notwithstanding such legal and contractual obligations between Qvidian and its business partners, Qvidian remains potentially liable for any misuse of Personal Data by its business partners. Qvidian may be required to disclose Personal Data in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.

When customers use the Service, Qvidian will not review, share, distribute, or reference customers’ Personal Data, except as provided in the Qvidian Master Service Agreement and Hosted Services Agreements.

Cookies:

"Cookies" are small pieces of information that are stored by your browser on your computer's hard drive. Qvidian's cookies do not contain any personally identifying information, but do enable us to recognize that you are a returning visitor, user, and/or customer to our Site or Service. Qvidian uses cookies to record user-specific information concerning the pages users access or visit and to record past activity at the Site to provide better service to returning visitors.

Data Security:

Qvidian maintains reasonable physical, electronic, and procedural safeguards to protect Personal Data from loss, misuse and unauthorized access, disclosure, alternation, and destruction. Qvidian hosts its Site and Service in a secure server environment that uses firewalls and other advanced technology to prevent interference or access from outside intruders. Qvidian also offers enhanced security features within the Service that permit Customers to configure security settings to the level they deem necessary.

Your Consent:

By visiting the Site and/or utilizing the Service, you are accepting the policies that are described in this Privacy Statement and consenting to the collection and use of Personal Data by Qvidian.

Changes to this Privacy Statement:

Qvidian reserves the right to change this Privacy Statement. Qvidian will provide notification of any material changes to this Privacy Statement through the Site thirty (30) days prior to the changes taking effect.

Choice - Right of Access, Correct and Update Personal Data:

You have the right to access your Personal Data, as well as a right to correct, update, or have your Personal Data removed. You also have the right to obtain a copy of the Personal Data held by Qvidian. Any such inquiries or requests can be made to the Qvidian contact information specified in this Privacy Statement.

Enforcement:

Qvidian uses a self-assessment approach to ensure compliance with this Privacy Statement and periodically verifies that the policy is accurate, comprehensive for the information intended to be covered, prominently displayed, completely implemented, and accessible.

We encourage interested persons to raise concerns using the contact information provided, and Qvidian will investigate and attempt to resolve any complaints and disputes regarding use and disclosure of Personal Data.

In addition to self-assessment, as a participant in the EU-US Privacy Shield program, Qvidian is subject to the investigatory and enforcement powers and authority of the U.S. Federal Trade Commission with respect to maintenance of, and adherence to, this Privacy Statement

EU-US Privacy Shield:

Qvidian complies with the EU-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries. Qvidian has certified that it 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. If there is any conflict between the policies in this Privacy Statement 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/

Privacy Complaints by European Union Citizens:

In compliance with the EU-US Privacy Shield Principles, Qvidian commits to resolve complaints about your privacy and our collection or use of your personal information. European Union individuals with inquiries or complaints regarding this Privacy Statement should first contact Qvidian at:

Qvidian Corporation 1 Executive Drive, Suite 302 Chelmsford, MA 01824 Telephone: 800-272-0047 Email: privacy@qvidian.com

-or-

The Sant Corporation (U.K.) Limited Forum 3, Solent Business Park Whitely, Hampshire PO15 7FH Registered Agent/Address: Rothmans, Fareham House, 69 High Street Fareham, Hampshire PO16 7BB Email: privacy@qvidian.com

Qvidian has further committed to refer unresolved privacy complaints under the EU-US Privacy Shield Principles BBB EU PRIVACY SHIELD, a non-profit 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 www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint.

Under certain limited and prescribed circumstances and conditions, you have the right to invoke a “last resort” binding arbitration process between you and Qvidian to resolve a dispute related to Qvidian’s collection, use or disclosure of your Personal Data.

Privacy Complaints by Swiss Citizens under the US-Swiss Safe Harbor:

Qvidian complies with the US-Swiss Safe Harbor Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from Switzerland. Qvidian has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. If there is any conflict between the policies in this Privacy Statement and the Safe Harbor Privacy Principles, the Safe Harbor Privacy Principles shall govern. To learn more about the US-Swiss Safe Harbor and to view our certification page, please visit http://www.export.gov/safeharbor/swiss In compliance with the US-Swiss Safe Harbor Principles, Qvidian commits to resolve complaints about your privacy and our collection or use of your personal information. Swiss citizens with inquiries or complaints regarding this Privacy Statement should first contact Qvidian at:

Email: privacy@qvidian.com Telephone: 800-272-0047 Mail: 1 Executive Drive, Suite 302 Chelmsford, MA 01824

-or-

The Sant Corporation (U.K.) Limited Forum 3, Solent Business Park Whitely, Hampshire PO15 7FH Registered Agent/Address: Rothmans, Fareham House, 69 High Street Fareham, Hampshire PO16 7BB Email: privacy@qvidian.com

Qvidian has further committed to refer unresolved privacy complaints under the US-Swiss Safe Harbor to an independent dispute resolution mechanism 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 www.bbb.org/us/safe-harbor-complaints for more information and to file a complaint.