Privacy Statement, effective as of January 1, 2018

Vintra, Inc. (“Vintra,” “we,” “us,” “our,” or the “Company”) is committed to protecting the privacy of individuals who visit the Company’s Web sites (“Visitors”), individuals who register to use the Services as defined below (“Customers”), and individuals who register to attend the Company’s corporate events (“Attendees”). This Privacy Statement describes Vintra’s privacy practices in relation to the use of the Company’s Web sites and the related applications, services, and programs offered by Vintra (collectively, the “Services”), as well as individuals’ choices regarding use, access and correction of personal information. If you have questions or complaints regarding Vintra’s Privacy Statement or associated practices, please contact us at info@vintra.io.

• Web sites covered

This Privacy Statement covers the information practices, including how the Company collects, uses, shares and secures the personal information you provide, of Web sites that link to this Privacy Statement (collectively referred to as “Vintra’s Web sites” or “the Company’s Web sites”). Vintra’s Web sites may contain links to other Web sites. The information practices or the content of such other Web sites is governed by the privacy statements of such other Web sites. The Company encourages you to review the privacy statements of other Web sites to understand their information practices.

• Information collected

When expressing an interest in obtaining additional information about the Services, or registering to use the Web sites or other Services, or registering for an event, Vintra requires you to provide the Company with personal contact information, such as name, company name, address, phone number, and email address (“Required Contact Information”). When purchasing the Services or registering for an event, Vintra may also require you to provide the Company with financial qualification and billing information, such as billing name and address, credit card number, and the number of employees within the organization that will be using the Services (“Billing Information”). Vintra may also ask you to provide additional information, such as company annual revenues, number of employees, or industry (“Optional Information”). When Visitors apply for a job with the Company, Vintra may also require you to submit additional personal information as well as a resume or curriculum vitae (“Applicant Information”). Required Contact Information, Billing Information, Applicant Information, Optional Information and any other information you submit to Vintra to or through the Services are referred to collectively as “Data.” As you navigate the Company’s Web sites, Vintra may also collect information through the use of commonly-used information-gathering tools, such as cookies and Web beacons (“Web Site Navigational Information”). Web Site Navigational Information includes standard information from your Web browser (such as browser type and browser language), your Internet Protocol (“IP”) address, and the actions you take on the Company’s Web sites (such as the Web pages viewed and the links clicked).

• Use of information collected

The Company uses Data about Vintra Customers to perform the services requested. For example, if you fill out a “Contact Me” Web form, the Company will use the information provided to contact you about your interest in the Services. The Company also uses Data about Vintra Attendees to plan and host corporate events, host online forums and social networks in which event Attendees may participate, and to populate online profiles for Attendees on the Company’s Web sites. Additional information on the Company’s privacy practices with respect to Data about Vintra Attendees may be found in additional privacy statements on the event Web sites, as the case may be. The Company may also use Data about Vintra Customers and Attendees for marketing purposes. For example, the Company may use information you provide to contact you to further discuss your interest in the Services and to send you information regarding the Company, its affiliates, and its partners, such as information about promotions or events. Vintra may also receive information about Customers and Attendees from other sources, including third parties from whom we have purchased data, and combine this information with Data we already have about you. This helps us to update, expand and analyze our records, identify new customers, and create more tailored advertising to provide products and services that may be of interest to you. Vintra uses credit card information solely to check the financial qualifications and collect payment from prospective Customers and Attendees. Vintra uses Web Site Navigational Information to operate and improve the Company’s Web sites. The Company may also use Web Site Navigational Information alone or in combination with Data about Vintra Customers and Data about Vintra Attendees to provide personalized information about the Company. Vintra partners with third parties to display advertising on our Web sites and Services or to manage our advertising on other sites. Our third-party partners may use cookies or similar technologies provide you advertising based upon your browsing activities and interests. If you wish to opt out of interest-based advertising click here, or if located in the European Union click here. Please note you will continue to receive generic ads.

• Privacy Shield:

Vintra, Inc. 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 PII transferred from the European Union and Switzerland to the United States, respectively. Vintra, Inc. has certified to the Department of Commerce that it adheres to the Privacy Shield Principles of both Frameworks, and any reference to “Privacy Shield Principles” shall include such Principles under both the EU and Swiss Frameworks. If there is any conflict between the terms in this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. For further information about the requirements for compliance with the Privacy Shield, and further detail about the Privacy Shield Principles, please visit https://www.privacyshield.gov. For purposes of our participation in the Privacy Shield, Vintra, Inc. confirms that we are subject to the jurisdiction of the United States Federal Trade Commission (FTC), and to its investigatory and enforcement powers. Complaints and Dispute Resolution If you have any complaint or concern regarding your PII (personal data) under this Privacy Policy, or arising under the Privacy Policy please contact us at info@vintra.io. We suggest that you put in the subject line of any email or communication “Privacy Policy” or “Privacy Complaint.” We will respond within 45 days. If this does not resolve your concern, you have two (2) options. (1) If you have an unresolved privacy or data use dispute or concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://www.jamsadr.com/eu-us-privacy-shield. (2) If you still believe that your complaint or dispute has not been resolved, you can invoke binding arbitration as a last resort (if permitted with respect to your complaint), by providing notice to us in the manner indicated in Annex I to the EU – U.S. Privacy Shield Principles, available online, and following the procedures set forth in such Annex. The location of the arbitration will be in the United States. You may choose video or telephone participation, which will be provided at no cost to you. In-person participation will not be required. To the maximum extent permitted by applicable law, you will not be entitled to recover attorneys’ or arbitration fees, even if you would otherwise be entitled to them. In addition, EU citizens have the right to initiate a private cause of action. Finally, with respect to any PII transferred from Switzerland to the U.S., the Swiss Federal Data Protection and Information Commissioner’s authority shall substitute for the EU Data Protection Authority, and Vintra, Inc. agrees to cooperate with such Swiss Commissioner in this context. Vintra, Inc. commits to follow up in its verification that the attestations and assertions made in this Privacy Policy are true, and to remedy any problems that may arise if we fail to comply with the Privacy Shield Principles. U.S. Federal Trade Commission enforcement Vintra Inc.’s commitments under the Privacy Shield are subject to the investigatory and enforcement powers of the United States Federal Trade Commission.

• Web Site Navigational Information

Cookies, Web Beacons and IP Addresses Vintra uses commonly-used information-gathering tools, such as cookies and Web beacons, to collect information as you navigate the Company’s Web sites (“Web Site Navigational Information”). As described more fully below, we and our partners use these cookies or similar technologies to analyze trends, administer Web sites and Services, track users’ movements around our Web sites and Services, serve targeted advertisements and gather demographic information about our user base as a whole. This section describes the types of Web Site Navigational Information used on the Company’s Web sites and Services, and how this information may be used. Cookies Vintra uses cookies to make interactions with the Company’s Web sites easy and meaningful. When you visit one of the Company’s Web sites, Vintra’s servers send a cookie to your computer or device. Standing alone, cookies do not personally identify you; they merely recognize your Web browser. Unless you choose to identify yourself to Vintra, either by responding to a promotional offer, opening an account, or filling out a Web form (such as a “Contact Me” or a “30 Day Free Trial” Web form) or have previously identified yourself to Vintra, you remain anonymous to the Company. Vintra uses cookies that are session-based and persistent-based. Session cookies exist only during one session. They disappear from your computer or device when you close your browser software or turn off your computer. Persistent cookies remain on your computer or device after you close your browser or turn off your computer. You can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functions on our Web sites or Services. The following sets out how Vintra.com uses different categories of cookies and your options for managing cookies’ settings:

Web Beacons Vintra uses Web beacons alone or in conjunction with cookies to compile information about Customers and Visitors’ usage of the Company’s Web sites and interaction with emails from the Company. Web beacons are clear electronic images that can recognize certain types of information on your computer, such as cookies, when you viewed a particular Web site or Service tied to the Web beacon, and a description of a Web site or Service tied to the Web beacon. For example, Vintra may place Web beacons in marketing emails that notify the Company when you click on a link in the email that directs you to one of the Company’s Web sites. Vintra uses Web beacons to operate and improve the Company’s Web sites, Services and email communications.

Log Files, IP Addresses, URLs and Other Data As is true of most Web sites, we gather certain information automatically to analyze trends in the aggregate and administer our Web sites and Services. This information may include your Internet Protocol (IP) address (or the proxy server you use to access the World Wide Web), device and application identification numbers, your location, your browser type, your Internet service provider and/or mobile carrier, the pages and files you viewed, your searches, your operating system and system configuration information, and date/time stamps associated with your usage. Due to Internet communications standards, when you visit or use the Company’s Websites and Services, we automatically receive the URL of the website from which you came and the website to which you go when you leave our Website. This information is used to analyze overall trends, to help us improve our Websites and Services, to track and aggregate non-personal information, and to provide the Websites and Services. For example, Vintra uses IP addresses to monitor the regions from which Customers and Visitors navigate the Company’s Web sites. Vintra also collects IP addresses from Customers when they log into the Services as part of the Company’s “Identity Confirmation” and “IP Range Restrictions” security features.

Social Media Features and Single Sign-on The Company’s Web sites may use social media features, such as the Facebook “like” button (“Social Media Features”). These features may collect your IP address and which page you are visiting on the Company’s Web site, and may set a cookie to enable the feature to function properly. You may be given the option by such Social Media Features to post information about your activities on the Company’s Web site to a profile page of yours that is provided by a third party social media network in order to share with others within your network. Social Media Features are either hosted by a third party or hosted directly on the Company’s Web site. Your interactions with these features are governed by the privacy policy of the company providing the relevant Social Media Features. Vintra also allows you to log in to certain of our Web sites and Services using sign-in services such as Facebook Connect. These services will authenticate your identity and provide you the option to share certain personal information with us such as your name and email address to pre-populate our sign-up form.

Do Not Track Currently, various browsers — including Internet Explorer, Firefox, and Safari — offer a “do not track” or “DNT” option that relies on a technology known as a DNT header, which sends a signal to Web sites’ visited by the user about the user’s browser DNT preference setting. Vintra does not currently commit to responding to browsers’ DNT signals with respect to the Company’s Web sites, in part, because no common industry standard for DNT has been adopted by industry groups, technology companies or regulators, including no consistent standard of interpreting user intent. Vintra takes privacy and meaningful choice seriously and will make efforts to continue to monitor developments around DNT browser technology and the implementation of a standard.

• Public forums, refer a contact, and customer testimonials

Vintra may provide bulletin boards, blogs, or chat rooms on the Company’s Web sites. Any personal information you choose to submit in such a forum may be read, collected, or used by others who visit these forums, and may be used to send you unsolicited messages. Vintra is not responsible for the personal information you choose to submit in these forums. Customers and Visitors may elect to use the Company’s referral program to inform contacts about the Company’s Web sites and Services. When using the referral program, the Company requests the contact’s name and email address. Vintra will automatically send the contact a one–time email inviting him or her to visit the Company’s Web sites. Vintra does not store this information. Vintra posts a list of Customers and testimonials on the Company’s Web sites that contain information such as Customer names and titles. Vintra obtains the consent of each Customer prior to posting any information on such a list or posting testimonials.

• Sharing of information collected

Service Providers Vintra may share Data about Vintra Visitors, Customers and Attendees with the Company’s contracted service providers so that these service providers can provide services on our behalf. These service providers are authorized to use your personal information only as necessary to provide the requested services to us. Without limiting the foregoing, Vintra may also share Data about Vintra Visitors, Customers and Attendees with the Company’s service providers to ensure the quality of information provided, and with third–party social networking and media Web sites, such as Facebook, for marketing and advertising on those Websites. Unless described in this Privacy Statement, Vintra does not share, sell, rent, or trade any information with third parties for their promotional purposes. Vintra, Inc. maintains contracts with these third parties restricting their access, use and disclosure of personal data in compliance with our Privacy Shield obligations, and Vintra, Inc. may be liable if they fail to meet those obligations and we are responsible for the event giving rise to damage. Vintra Affiliates The Company may share Data about Vintra Customers with other companies in order to work with them, including affiliates of the Vintra corporate group. For example, the Company may need to share Data about Vintra Customers with other companies within the Vintra corporate family for customer support, marketing, technical operations and account management purposes. Business Partners From time to time, Vintra may partner with other companies to jointly offer products, services, or programs (such as webinars or downloadble content). If you purchase, specifically express interest in, or register for a jointly–offered product, service, or program from or through Vintra, the Company may share Data about Vintra Customers collected in connection with your purchase or expression of interest with our partner(s). Vintra does not control our business partners’ use of the Data about Vintra Customers that we collect, and their use of the information will be in accordance with their own privacy policies. If you do not wish for your information to be shared in this manner, you may opt not to purchase or specifically express interest in a jointly offered product or service. Vintra does not share Data about Vintra Attendees with business partners unless: (1) you specifically opt in to such sharing via an event registration form; or (2) you attend a Company event and allow Vintra or any of its business partners to scan your attendee badge. If you do not wish for your information to be shared in this manner, you may choose not to opt in via event registration forms and elect not to have your badge scanned at Company events. If you choose to share your information with business partners in the manners described above, your information will be subject to the business partners’ respective privacy statements. Third Parties Section 4 of this Privacy Statement, Web Site Navigational Information, specifically addresses the information we or third parties collect through cookies and web beacons, and how you can control cookies through your Web browsers. We may also disclose your personal information to any third party with your prior consent. Billing Vintra uses a third-party service provider to manage credit card processing. This service provider is not permitted to store, retain, or use Billing Information except for the sole purpose of credit card processing on the Company’s behalf. Compelled Disclosure Vintra reserves the right to use or disclose information provided if required by law or if the Company reasonably believes that use or disclosure is necessary to protect the Company’s rights and/or to comply with a judicial proceeding, court order, or legal process. Your Rights to Access, to Limit Use, and to Limit Disclosure EU individuals and Swiss individuals have rights to access personal data about them, and to limit use and disclosure of their personal data. With our Privacy Shield certification, Vintra, Inc. has committed to respect those rights.

• International transfer of information collected

The Company primarily stores Data about Vintra Customers and Data about Vintra Attendees in the United States. To facilitate Vintra’s global operations, the Company may transfer and access such information from around the world, including from other countries in which the Company has operations. This Privacy Statement shall apply even if Vintra transfers Data about Vintra Customers or Data about Vintra Attendees to other countries.

• Communications preferences

Vintra offers Visitors, Customers, and Attendees who provide contact information a means to choose how the Company uses the information provided. You may manage your receipt of marketing and non-transactional communications by clicking on the “unsubscribe” link located on the bottom of the Company’s marketing emails.

• Correcting and updating your information

Vintra may retain your information for a period of time consistent with the original purpose of collection. For instance, we may retain your information during the time in which you have an account to use our Web sites or Services and for a reasonable period of time afterward. We also may retain your information during the period of time needed for Vintra to pursue our legitimate business interests, conduct audits, comply with our legal obligations, resolve disputes and enforce our agreements. You may request to review, correct, delete or otherwise modify any of the personal information that you have previously provided to us through the Company’s Web sites and Services. If you have registered for an account with Vintra, you may generally update your user settings, profile, organization’s settings or event registration by logging into the applicable Website or Service with your username and password and editing your settings or profile. To update your billing information, discontinue your account, and/or request return or deletion of Your Data associated with your account, please contact your account representative or the customer service team for the applicable Service. For other requests to access, correct, modify or delete Your Data, please review the “Contacting Us” section below. Requests to access, change, or delete your information will be addressed within a reasonable timeframe. If you are an employee of a Vintra customer, you may also wish to contact your company’s system administrator for assistance in correcting or updating your information.

• Customer Data

Vintra’s Customers may electronically submit data or information to the Services for hosting and processing purposes (“Customer Data”). Vintra does not sell or obtain ownership in any Customer Data. Full details of how Vintra protects Customer Data can be found in the Master Subscription Agreement, or as may be required by law. In accordance with Vintra’s Master Subscription Agreement, Vintra may access Customer Data only for the purpose of providing and improving the Services or preventing or addressing service or technical problems or as may be required by law. Additional information about the Company’s privacy and security practices with respect to Customer Data is available here. Vintra acknowledges that you have the right to access your personal information. If personal information pertaining to you as an individual has been submitted to us by a Vintra customer and you wish to exercise any rights you may have to access, correct, amend, or delete such data, please inquire with our customer directly. Because Vintra personnel have limited ability to access data our customers submit to our Services, if you wish to make your request directly to Vintra, please provide the name of the Vintra customer who submitted your data to our Services. We will refer your request to that customer, and will support them as needed in responding to your request within a reasonable timeframe.

• Security

Vintra uses robust security measures to protect Data about Vintra Customers and Data about Vintra Attendees. Because the Company uses the Services to maintain Data about Vintra Customers and Data about Vintra Attendees, this information, which is stored in the Services, is secured in the same manner as described here.

• Mobile applications

Without limiting the generality of this Privacy Statement, in addition to information gathered through its Web sites or submitted to its Services, Vintra may obtain information through applications (“Mobile Applications”) that Customers or their authorized individuals (“Users”) download to, and run on, their mobile devices (“Devices”). Mobile Applications provided by Vintra may obtain information from, or access data stored on, Users’ Devices to provide services related to the relevant Mobile Application. For example, a Mobile Application may: access a camera on a User’s Device to enable the User to upload photographs to the Services; access the call history on a User’s Device to enable the User to upload that information to the Services; access calendar information on a User’s Device to enable the User to match meeting attendees with contacts submitted by the User to the Services; access the geographic location of a User’s Device to enable the User to identify contacts submitted by the User the Services who are nearby; or access contact information on a User’s Device to enable the User to sync contact information between the information that is stored on the User’s Device and the information that is submitted to the Services. Information obtained to provide Mobile Application services may include information obtained in preparation for anticipated updates to those services. Mobile Applications may transmit information to and from Devices to provide the Mobile Application services. Mobile Applications may provide Vintra with information related to Users’ use of the Mobile Application services, information regarding Users’ computer systems, and information regarding Users’ interaction with Mobile Applications, which Vintra may use to provide and improve the Mobile Application services. For example, all actions taken in a Mobile Application may be logged, along with associated information (such as the time of day when each action was taken). Vintra may also share anonymous data about these actions with third party providers of analytics services. In addition, if a User downloads a Vintra Mobile Application after clicking on a third-party mobile advertisement for the Mobile Application or for Vintra, the third-party advertiser may provide Vintra with certain information, such as the User’s Device identification information, which Vintra may use to track the performance of its advertising campaigns. Customers may configure Vintra Mobile Application services, and the information accessed or obtained by the Mobile Application on a User’s Device may be affected by the Customer’s configuration. In addition, if a Customer purchases more than one Service from Vintra and its affiliates, a Mobile Application may be designed to interoperate with those Services; for instance, to provide a User with access to information from any or all of those Services or to provide information from a User’s Device to any or all of those Services. Information accessed or obtained by the Mobile Application on a User’s Device may be accessible to the Customer and its organization, depending on the intended functionality of the Mobile Application. Vintra may provide updated versions of its Mobile Applications. If your mobile device’s settings permit, those updates will be downloaded and installed automatically on your mobile device. By installing a Vintra Mobile Application on your mobile device, you consent to the downloading and updating of that Mobile Application. In addition to Mobile Applications offered by Vintra, the Company may offer platforms for the creation of third-party Mobile Applications, including but not limited to the Vintra for Mobile platform. Third parties may obtain information from, or access data stored on, Users’ Devices to provide services associated with any third-party Mobile Applications that Users download, install, use, or otherwise interact with over a Vintra platform. Vintra’s Mobile Applications may also contain links or integrations to other Mobile Applications provided by third parties. Third parties’ use of information collected through third-party Mobile Applications is governed by the privacy statements of such third parties. The Company encourages you to review the privacy statements of third-party providers of Mobile Applications to understand their information practices. Notices and contractual terms related to a particular Mobile Application may be found in the End User License Agreement or relevant terms of service for that application. The Company encourages you to review the End User License Agreement or relevant terms of service related to any Mobile Applications you download, install, use, or otherwise interact with to understand that Mobile Application’s information practices. The Mobile Application’s access to information through a User’s Device does not cause that information to be “Customer Data” under Vintra’s Master Subscription Agreement with the Customer or under this Privacy Statement, except as follows: To the extent that a User uses a Mobile Application to submit electronic data and information to a Customer account on our Services pursuant to the Customer’s Master Subscription Agreement with Vintra (or a similar agreement that governs the Customer’s subscription(s) to Vintra’s Services), that information constitutes “Customer Data” as defined in such agreement, and the provisions of that agreement with respect to privacy and security of such data will apply. Additional information about the Company’s privacy and security practices with respect to Customer Data is available here.

• Changes to this Privacy Statement

Vintra reserves the right to change this Privacy Statement. Vintra will provide notification of the material changes to this Privacy Statement through the Company’s Web sites at least thirty (30) business days prior to the change taking effect.

Contacting us

Questions regarding this Privacy Statement or the information practices of the Company’s Web sites and Services should be directed to Vintra Privacy by emailing info@vintra.io or by mailing us at:
Vintra Privacy 1530 The Alameda, Suite 205 San Jose, CA 95126