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By creating an account you are agreeing to the Echo360 Online Terms and Conditions and Privacy and Policies.

Echo360 Online Terms and Conditions

Echo360 Tech Intermediate, Inc. d/b/a Echo360 (“Echo360,” “we,” or “us”) provides certain information and online services that may be accessible at www.echo360.com or other Web locations where these Online Terms and Conditions are posted (collectively, the “Echo360 Sites”) or that may be directly accessible by individual end users of our various software products through a link that we provide within those products. Throughout these Online Terms and Conditions (the “Terms”), all such information and online services are referred to as the “Services.” These Terms apply to your access to and use of the Echo360 Sites and do not alter in any way the terms and conditions of any other agreement you may have with us for products, services or otherwise.

You represent and warrant that you have full power and authority to enter into these Terms and in doing so will not violate any other agreement to which you are a party. If you are an individual end user accessing the Services, you understand and agree that the Services are provided to you subject to these Terms as well as our Privacy Policy https://echo360.com/privacy/, which is incorporated herein by reference. PLEASE READ THE TERMS CAREFULLY. BY USING THE SERVICES, YOU ACKNOWLEDGE AND REPRESENT THAT YOU HAVE READ THESE TERMS AND AGREE TO BE BOUND BY THEM AND ALL APPLICABLE LAWS AND REGULATIONS INCLUDING COMPLIANCE WITH ANY APPLICABLE LOCAL LAWS. IF YOU DO NOT AGREE TO ANY OF THESE TERMS, WE ARE UNWILLING TO GRANT YOU ACCESS TO THE SERVICES.

NOTICE TO EDUCATIONAL END USERS. Echo360 makes available software and hardware tools to educational institutions like colleges and universities, and those institutions use our products to create audiovisual recordings of classes and lectures and later make such recordings available for viewing online, usually from the institution’s own websites (in each case, a “School Site”). Some of our Services may enable students to hold online discussions, make and store notes about the classes that they view online, or otherwise interact with recorded classroom materials. You understand that, even if you access our Services from a link within a School Site, these Terms apply to your use of our Services, but these Terms do not apply to your use of any School Site.

I. OWNERSHIP AND ACCESS TO ECHO360 SERVICES AND TOOLS

A. Ownership Access to Features of Online Services

The Echo360 Sites, the Services, all Downloadable Tools (as further defined herein), all related intellectual property rights, as well as its contents, features, functionality (including but not limited to all information, software, text, displays, images, video, and audio, and the design, selection, and arrangement thereof), and all information, products, and services offered by us to you in connection with the Echo360 Sites (sometimes collectively referred to herein as the “Content”) are protected under applicable copyrights, trademarks, and other proprietary (including but not limited to intellectual property) rights pursuant to international conventions and U.S. and other laws. The Echo360 Sites and the Content are the property of us and/or the applicable third-party licensors, and all right, title, and interest in and to the Echo360 Sites and the Content will remain with us or such third-party licensors. Our logos, page headers, custom graphics, and other icons are service marks, trademarks, registered service marks, or registered trademarks of us. All other products, names, and company logos mentioned on the Echo360 Sites or in the Content are trademarks of their respective owners.

Echo360, the Echo360 logo, the EchoSystem and Apreso are trademarks of Echo360, Inc. Unless you first obtain the copyright owner’s prior written consent, you may not copy, distribute, publicly perform, publicly display, digitally perform (in the case of sound recordings), or create derivative works from any copyrighted work made available or accessible via the Services.

For so long as you agree to these Terms and abide by them, you may use the Services. Subject to these Terms, we also grant you a limited, non-exclusive, nontransferable personal license to download, install and operate any software, scripts and other content that we may from time to time have specifically identified within the Echo360 Sites or Services as available for download (“Downloadable Tools”).

B. General Restrictions on Use

The rights granted to you by these Terms will remain in force only for so long as these Terms remain in effect. You may not resell or sublicense access to the Service to any third-party. You may use the Services and Downloadable Tools only for your lawful, personal, informational, and other non-commercial purposes. You do not acquire ownership rights to the Echo360 Sites or any Content, other than those rights in the materials that you submit to us or otherwise enter through the Echo360 Sites, if any, that you may have or any rights that we may specifically grant you in writing, such as the limited license to use the Echo360 Sites, as further described below. These Terms do not grant you any right, title, interest, license (express or implied) to any patent, trademark, service mark, copyright, trade secret or other intellectual property right of Echo360 or the respective intellectual property owners. You will abide by any and all additional copyright notices, information, or restrictions contained in any Content.

We accommodate and do not interfere with standard technical measures used by copyright owners to protect their materials. Where applicable, pursuant to 17 U.S.C. Section 512 as amended by Title II of the Digital Millennium Copyright Act, we reserve the right to terminate your use of the Echo360 Sites or the information and Content contained therein if we determine in our sole and absolute discretion that you are involved in infringing activity, regardless of whether such alleged infringement is a first-time or repeat occurrence and/or whether the material or activity is ultimately determined to be infringing.

You may only use the Echo360 Sites and the Content as expressly permitted under these Terms and only for lawful purposes; any other use is prohibited. Any use of the Echo360 Sites or the Content not expressly permitted by these Terms is a breach hereof and may violate copyright, trademark, and other laws. Without limiting the foregoing, you agree that you will not attempt to or in fact:

Combine or integrate the Service and/or any Downloadable Tools with hardware, software or other technology or materials not provided by us;
Modify, adapt, translate, or create any derivative product based on the Services or Downloadable Tools;
Decompile, disassemble, reverse engineer or otherwise attempt to obtain or perceive the source code from which any component of the Services and/or Downloadable Tools is compiled or interpreted, and nothing in these Terms should be interpreted as granting you any right to obtain or use source code;
Introduce to the Echo360 Sites (or the servers, networks, and databases associated with the Echo360 Sites) any spyware, viruses, Trojan horses, worms, keystroke loggers, rootkits, logic bombs, or other material which is malicious or technologically harmful.
Reproduce, redistribute, republish, duplicate, copy, display, sell, rent, sublicense, trade or resell any Content or other aspect of the Echo360 Sites for any commercial purpose (except for Content specifically and expressly made available for redistribution)
Remove, delete, efface, alter, obscure, translate, combine, supplement, or otherwise change any trademarks, copyrights, warranties, disclaimers, or other proprietary notations
Forge headers or otherwise manipulate identifiers in order to disguise the origin of any content transmitted through the Echo360 Sites or develop restricted or password-only access pages, or hidden pages or images.
Use the Services or Downloadable Tools to:
1. violate any local, state, federal, or international law or regulation;
2. transmit or send unsolicited commercial communications;
3. abuse, stalk, harass, threaten, harm, or otherwise violate the legal rights of another individual;
4. conduct any systematic or automated data collection or storage activities (including without limitation scraping, data mining, data extraction and data harvesting) on or in relation to the Echo360 Sites;
5. impersonate any person or entity, or otherwise misrepresent your affiliation with a person or entity;
6. access the Echo360 Sites through any robot, spider, or other automated means;
7. “screen scrape,” “monitor,” “mine,” “copy,” or “mirror” the Echo360 Sites;
8. gain unauthorized access to, interfere with, damage, disrupt, or circumvent any of the security features of the Services or the Echo360 Sites (or the servers, networks, and databases associated with the Services or the Echo360 Site);
9. otherwise interfere with or disrupt the Services or servers or networks connected to the Services, or disobey any requirements, procedures, policies or regulations of networks connected to the Services; or
10. upload or transmit information or content that is infringing, defamatory, obscene, indecent, fraudulent or otherwise illegal.

Without our written consent, you may not:

Use any high volume, automated, or electronic means to access the Services (including, without limitation, robots, spiders or scripts); or
Frame the Echo360 Sites, place pop-up windows over their pages, or otherwise affect the display of their pages.

You are solely responsible for (and we have no responsibility to you or to any third party for) any breach of your obligations under these Terms and for the consequences (including any loss or damage which you may suffer) of any such breach. You represent and warrant that any information about yourself that you voluntarily provide to us will be true, accurate, complete and current. Without limiting any rights or remedies that Echo360 may have available at law or in equity, including, without limitation, any right to seek monetary damages for your breach, you agree that Echo360 may seek a court order to compel you to comply with these terms, and You understand that we may immediately terminate your access to the Echo360 Sites and/or Services at any time if you violate the restrictions set forth above.

C. Use of Third-Party Offerings

You may be able to access websites, content or services provided by third-parties through links that are made available within the Services. Additionally, from time to time Echo360 may refer you to one or more of our business partners who make available products or services through their respective websites or by other means (e.g., by mail or otherwise). We refer to all such websites, content, services and products as “Third-Party Offerings.” For example, we may permit third parties to advertise their products and services from within the Services, and those advertisements may contain links to the website(s) of the advertisers. Unless we otherwise inform you within the Services, your use of such Third-Party Offerings is not ordinarily required in order to access and/or use the Services. If you elect to use such Third-Party Offerings, you understand that your use of them is entirely at your own risk and will be subject to any terms and conditions required by the applicable third-party provider(s). You understand that we are not the provider of, and are not responsible for, any such Third-Party Offerings, that we have not reviewed the Third Party Offerings, and we are not responsible for any changes to or content on them. We have no control over the content of those Third Party Offerings or resources, and we accept no responsibility for them or for any loss or damage that may arise from your use of them. and these Terms do not themselves grant you any rights to access, use or purchase any Third-Party Offerings. Our inclusion of any content is not an endorsement of that material or linked site or the companies that own or operate the material or linked sites. We are not responsible, or liable to you or any third party, for the content or accuracy of any materials provided by any third parties.

D. Feedback

Your feedback is welcome and encouraged. You agree, however, that (i) by submitting unsolicited ideas to Echo360, you automatically forfeit your right to any intellectual property rights in those ideas; and (ii) unsolicited ideas submitted to Echo360 or any of its employees or representatives automatically become the property of Echo360.

E. Security Measures

Echo360 will apply reasonable measures to protect the security of nonpublic personal information and other data essential for use of the Echo360 Sites, such as information you upload or enter when using the Echo360 Sites in accordance with applicable industry standards, applicable law, and our Privacy Policy. You shall protect the confidentiality and security of your credentials, and you shall not allow any person to have access to or to use your credentials.

Echo360 is entitled (but not required) to apply security measures to protect the Echo360 Sites and the Content, and Echo360 may block users (or IP addresses) identified or suspected as being used to access the Echo360 Sites (i) without authorization, (ii) for unlawful purposes or for purposes of disrupting, or (iii) in any manner that presents a risk of damaging the Echo360 Sites.

You shall immediately notify Echo360 of any activity on the Echo360 Sites suspected as being for unlawful purposes including any activity liable to disrupt, gain unauthorized access to, or cause any damage to the Echo360 Sites.

You shall immediately notify Echo360 of any security breach involving the Echo360 Sites of which you become aware, including any loss of nonpublic personal information and any incident where nonpublic personal information relating to you becomes available to unauthorized persons through the Echo360 Sites

II. DISCLAIMERS, LIMITATIONS AND EXCLUSIONS OF LIABILITY

A. No Warranties

THE SERVICES, THE ECHO360 SITES, THE DOWNLOADABLE TOOLS AND ALL INFORMATION AND OTHER MATERIALS RELATED TO THE FOREGOING, INCLUDING THE CONTENT, ARE PROVIDED ON AN “AS IS” AND “AS AVAILABLE” BASIS. TO THE FULLEST EXTENT PERMISSIBLE UNDER APPLICABLE LAW, ECHO360 AND ITS AFFILIATES DISCLAIM ALL WARRANTIES, EXPRESS OR IMPLIED, ORAL OR WRITTEN, STATUTORY OR OTHERWISE, INCLUDING, BUT NOT LIMITED TO, ANY WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, TITLE, NON-INFRINGEMENT, NON INTERFERENCE, SYSTEM INTEGRATION AND ACCURACY OF DATA (WHETHER OR NOT WE KNOW, HAVE REASON TO KNOW, HAVE BEEN ADVISED, OR OTHERWISE IN FACT ARE AWARE OF ANY SUCH PURPOSE) AND WHETHER ALLEGED TO ARISE BY LAW, BY REASON OF CUSTOM OR USAGE IN THE TRADE, BY COURSE OF DEALING, OR OTHERWISE. NEITHER US NOR ANY PERSON ASSOCIATED WITH US MAKES ANY WARRANTY OR REPRESENTATION WITH RESPECT TO THE COMPLETENESS, SECURITY, RELIABILITY, QUALITY, ACCURACY, OR AVAILABILITY OF THE ECHO360 SITES OR THE CONTENT OR THAT ACCESS TO OR USE OF THE ECHO360 SITES WILL BE UNINTERRUPTED, ERROR-FREE, OR COMPLETELY SECURE. ECHO360 AND ITS AFFILIATES DO NOT WARRANT THAT YOUR USE OF THE SERVICES WILL BE UNINTERRUPTED, ERROR -FREE OR VIRUS FREE. THE SUBMISSION OF ANY PERSONAL CONTENT AND THE DOWNLOAD OR UPLOAD OF ANY MATERIAL THROUGH THE SERVICES ARE DONE AT YOUR OWN DISCRETION AND RISK. YOU WILL BE SOLELY RESPONSIBLE FOR ANY DAMAGE TO YOUR COMPUTER SYSTEM OR LOSS OF DATA THAT MAY RESULT FROM THE DOWNLOAD OR UPLOAD OF ANY SUCH MATERIAL OR FROM RELIANCE UPON THE SERVICES, AND YOU ARE ADVISED TO MAINTAIN OFFLINE BACKUP COPIES OF ALL PERSONAL CONTENT. ECHO360 IS NOT THE PROVIDER OF, AND MAKES NO WARRANTIES WITH RESPECT TO, ANY THIRD-PARTY OFFERINGS OR SCHOOL SITES. ECHO360 DOES NOT GUARANTEE OR OTHERWISE WARRANT THE SECURITY OF ANY INFORMATION TRANSMITTED TO OR FROM THE SERVICES; AND YOU AGREE TO ASSUME THE SECURITY RISK FOR ANY INFORMATION YOU PROVIDE USING THE SERVICES.

WE CANNOT AND DO NOT GUARANTEE OR WARRANT THAT FILES AVAILABLE FOR DOWNLOADING FROM THE INTERNET OR THE ECHO360 SITES WILL BE FREE OF VIRUSES OR OTHER DESTRUCTIVE CODE. YOU ARE RESPONSIBLE FOR IMPLEMENTING SUFFICIENT PROCEDURES AND CHECKPOINTS TO SATISFY YOUR PARTICULAR REQUIREMENTS FOR ANTI-VIRUS PROTECTION AND ACCURACY OF DATA INPUT AND OUTPUT, AND FOR MAINTAINING A MEANS EXTERNAL TO OUR SITE FOR ANY RECONSTRUCTION OF ANY LOST DATA.

TO THE FULLEST EXTENT PROVIDED BY LAW, WE WILL NOT BE LIABLE FOR ANY LOSS OR DAMAGE CAUSED BY A DISTRIBUTED DENIAL-OF-SERVICE ATTACK, RANSOMWARE, VIRUSES, OR OTHER TECHNOLOGICALLY HARMFUL MATERIAL THAT MAY INFECT YOUR COMPUTER EQUIPMENT, COMPUTER PROGRAMS, DATA, OR OTHER PROPRIETARY MATERIAL DUE TO YOUR USE OF THE ECHO360 SITES OR ANY SERVICES OR ITEMS OBTAINED THROUGH THE ECHO360 SITES OR TO YOUR DOWNLOADING OF ANY CONTENT POSTED ON IT, OR ON ANY SITE LINKED TO IT.

THE FOREGOING DOES NOT AFFECT ANY WARRANTY THAT CANNOT BE EXCLUDED OR LIMITED UNDER APPLICABLE LAW

B. Limitation Of Liability

USE OF THE SERVICES, THE ECHO360 SITES AND/OR ANY DOWNLOADABLE TOOLS IS AT YOUR OWN RISK. IN NO EVENT WILL ECHO360 OR ITS AFFILIATES BE LIABLE UNDER OR IN CONNECTION WITH THESE TERMS UNDER ANY LEGAL OR EQUITABLE THEORY, INCLUDING BREACH OF CONTRACT, TORT (INCLUDING NEGLIGENCE), STRICT LIABILITY, AND OTHERWISE, FOR ANY: (A) CONSEQUENTIAL, INCIDENTAL, INDIRECT, EXEMPLARY, SPECIAL, ENHANCED, OR PUNITIVE DAMAGES; (B) INCREASED COSTS, DIMINUTION IN VALUE OR LOST BUSINESS, PRODUCTION, REVENUES, OR PROFITS; (C) LOSS OF GOODWILL OR REPUTATION; (D) USE, INABILITY TO USE, LOSS, INTERRUPTION, DELAY OR RECOVERY OF ANY DATA, OR BREACH OF DATA OR SYSTEM SECURITY; (E) ERRORS, INACCURACIES, OMISSIONS, OTHER DEFECTS IN, UNTIMELINESS, OR UNAUTHENTICITY OF INFORMATION OR CONTENT PROVIDED BY, CONTAINED WITHIN, OR OBTAINED THROUGH THE ECHO360 SITES; OR (F) COST OF REPLACEMENT GOODS OR SERVICES, IN EACH CASE REGARDLESS OF WHETHER WE WERE ADVISED OF THE POSSIBILITY OF SUCH LOSSES OR DAMAGES OR SUCH LOSSES OR DAMAGES WERE OTHERWISE FORESEEABLE..

IN NO EVENT WILL THE AGGREGATE LIABILITY OF ECHO360 TO YOU FOR ANY AND ALL CLAIMS ARISING IN CONNECTION WITH THESE TERMS EXCEED ONE DOLLAR (U.S. $1.00).

YOU ACKNOWLEDGE THAT THIS LIMITATION OF LIABILITY IS AN ESSENTIAL TERM BETWEEN YOU AND ECHO360 RELATING TO THE PROVISION OF ACCESS TO THE ECHO360 SITES, THE SERVICES, AND ANY DOWNLOADABLE TOOLS TO YOU, AND ECHO360 WOULD NOT PROVIDE THE SAME TO YOU WITHOUT THIS LIMITATION.

C. Indemnification

YOU AGREE TO INDEMNIFY, HOLD HARMLESS AND, AT ECHO360’S OPTION, DEFEND ECHO360 (INCLUDING ITS AFFILIATES, OFFICERS, DIRECTORS, EMPLOYEES, AGENTS, LICENSORS, SUPPLIERS AND ANY THIRD-PARTY INFORMATION PROVIDERS) FROM AND AGAINST ALL DAMAGES LIABILITIES, AND EXPENSES, INCLUDING REASONABLE ATTORNEYS’ FEES, ARISING OUT OF OR RELATING TO (I) YOUR BREACH OF THESE TERMS; (II) YOUR VIOLATION OF ANY THIRD PARTY’S RIGHT, INCLUDING, WITHOUT LIMITATION, ANY COPYRIGHT, TRADEMARK, PROPERTY RIGHT, OR PRIVACY RIGHT; OR (III) ANY CLAIM THAT CONTENT PROVIDED BY YOU CAUSED DAMAGE OR LOSS TO A THIRD PARTY. THIS DEFENSE AND INDEMNIFICATION OBLIGATION WILL SURVIVE YOUR USE OF THE SITE AND ANY TERMINATION OF THIS AGREEMENT

III. TERM AND TERMINATION

These Terms will become effective and binding when you use the Services, when you voluntarily provide any information about yourself to us, or when you indicate your agreement by following any instructions we place on the Site (such as buttons labeled “I Agree”). You do not need to inform us if you wish to stop using the Services. We reserve the right to terminate these Terms and your access to the Echo360 Sites and the Service at any time without notice. Your rights under these Terms will automatically and immediately terminate if you fail to comply with your promises and obligations stated in these Terms. The provisions of sections I.B, I.C, I.D, II, III, and IV will survive the termination of these Terms.

IV. MISCELLANEOUS MATTERS

A. Privacy

In the course or accessing and/or using the Services and/or any Downloadable Tools, we may obtain information about you or you may be required to provide certain personal information to us. All uses of your personal information will be treated in accordance with our Privacy Policy, which forms an integral part of these Terms. If you use the Services and/or the Downloadable Tools, you are accepting the terms and conditions of our Privacy Policy, as may be amended from time to time. If you do not agree to have your information used in any of the ways described in the Privacy Policy, you must discontinue use of the Services and the Downloadable Tools. To review our current Privacy Policy, click here https://echo360.com/privacy/.

B. International Users

The availability of products and services described on the Echo360 Sites, as well as associated fees, charges, interest rates, and balance requirements may differ among geographic locations. We make no representation that the Echo360 Sites are appropriate or available for use in all locations or by all users. The information provided on the Echo360 Sites are not intended for distribution to, or use by, any person or entity in any jurisdiction or country where such distribution or use would be contrary to law or regulation or which would subject us or our affiliates, employees, directors, officers or agents to any registration requirement within such jurisdiction or country.

By using the Echo360 Sites, you consent to the collection, storage, processing, and transfer of your information in accordance with our Privacy Policy https://echo360.com/privacy/. Note that not every country offers the same level of privacy protection as you may have in your home country. We commit to uphold the privacy protections explained in this Terms and our Privacy Policy and any data protection laws that apply to the Echo360 Sites.

C. Copyrights

If you believe your copyright has been violated by works or Third-Party Offerings accessible through the Services, please contact us by email at copyright@echo360.com.

D. Waiver and Severability

No waiver by us of any term or condition set out in these Terms shall be deemed a further or continuing waiver of such term or condition or a waiver of any other term or condition, and any failure by us to assert a right or provision under these Terms shall not constitute a waiver of such right or provision. Enforcement of these Terms is in our sole discretion.

If any provision of these Terms is held by a court or other tribunal of competent jurisdiction to be invalid, illegal, or unenforceable for any reason, such provision shall be eliminated or limited to the minimum extent such that the remaining provisions of the Terms will continue in full force and effect.

E. Modifications to Terms

We may change these Terms from time to time. Any such changes will become effective when posted within the Services. If you object to any such changes, your sole recourse will be to cease using the Services and the Downloadable Tools. Continued use of the Services and/or any Downloadable Tools following posting of any such changes will indicate your acknowledgement of such changes and your agreement to be bound by the revised Terms, inclusive of such changes. In addition, certain features of the Services may be subject to additional terms of use. By using such features, or any part thereof, you agree to be bound by the additional terms of use applicable to such features. In the event that any of the additional terms of use governing such area conflict with these Terms, the additional terms will govern.

F. Modifications to Services

We reserve the right to modify the Services at any time without notice. If you object to any changes to the Services, your sole recourse will be to cease using them. Continued use of the Services following posting of any such changes will indicate your acknowledgement of such changes and satisfaction with the Services as so modified. We also reserve the right to discontinue the Services at any time without notice. We will not be liable to you or any third-party should we exercise our right to modify or discontinue the Services.

G. No Refunds

All sales for services are final, and we do not offer any money-back for any of our services. You recognize and agree that you shall not be entitled to a refund for any services such as FastPass purchased under any circumstances. In addition, in the event that these Terms expire or are terminated, no portion of any payments previously provided by you shall be refunded for any services.

H. General Terms

You agree to comply with all laws, rules and regulations that apply to your use of the Services and the Downloadable Tools. These Terms will be subject to and construed in accordance with the laws of the Commonwealth of Virginia, excluding its rules regarding conflicts of law. You consent to jurisdiction and venue exclusively in the Commonwealth of Virginia. You agree that any claim or cause of action that you may have related to the Services, the Downloadable Tools, and/or these Terms must be filed within one (1) year after such claim or cause of action arose or be forever barred. These Terms constitute the entire agreement between you and Echo360 with regard to the matters described above.

I. Contact Information

All feedback, comments, requests for support, and other communications relating to these Terms, the Echo360 Sites, the Echo360 Privacy Policy https://echo360.com/privacy/ (which is hereby incorporated into these Terms by this reference) should be directed to support@echo360.com or Echo360 Privacy Office by mailing:

Echo360

ATTN: Privacy Office
6000 Mahoning Avenue, Suite 254

Youngstown, OH 44515, USA
privacy@echo360.com

Privacy and Policies

ECHO360 GLOBAL PRIVACY POLICY

Last Updated on January 12, 2024

PLEASE READ THIS PRIVACY POLICY CAREFULLY TO UNDERSTAND HOW WE TREAT YOUR PERSONAL INFORMATION AND WHAT CHOICES AND RIGHTS YOU HAVE IN THIS REGARD. IF YOU DO NOT AGREE WITH THE TERMS AND CONDITIONS OF THIS POLICY, YOU SHOULD NOT ACCESS OR USE THE PLATFORM OR ENGAGE IN COMMUNICATIONS WITH US.

INTRODUCTION

Echo360 Tech Intermediary, Inc. d/b/a Echo360 (“Echo360,” “we,” “us,” or “our”) is strongly committed to protecting the privacy and security of the personal information we collect, use, share, and otherwise process as part of our business. We also believe in transparency, and we are committed to informing you about how we treat your personal information. We have established this Privacy Policy (the “Policy”) to inform you about the privacy practices that we apply to personal information and inform you about your rights and choices in this regard.

Personal Information means any information or set of information, whether alone or in combination with other Personal Information, processed by Echo360, which is sufficient to identify an individual (“Personal Information”). Personal Information does not include information that is anonymous, nor does it include publicly available information that has not been combined with non-public Personal Information. For Personal Information (or Personal Data) originating from or processed in the EEA, as defined below, those terms shall have the meaning given to it in the “Rights of EU/EEA Residents” and “International Data Transfers” sections of this Policy.

What processing activities are covered by this Policy? This Policy applies to the processing of Personal Information or Personal Data when you visit our website https://www.echo360.com/ and any features, subdomains, content, functionality, services, media, applications, or solutions offered on or through our website (collectively referred to as the “Site”). By accessing and using the Site, or by otherwise signaling your agreement when the option is presented to you, you consent to the collection, use and disclosure of information as described in this Policy. This Policy only governs the Site, and it does not govern off-line data collection, or any other website or service operated by third parties that do not specifically refer to this Policy. Any materials submitted through the Site and your use of the Site are subject to the Echo360 Terms and Conditions: https://echo360.com/terms-and-conditions/.

“Processing” shall mean any operation or set of operations that is performed upon Personal Information or Personal Data or sets thereof, whether or not by automatic means, such as collection, recording, organization, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, blocking, erasure or destruction and the verb “to process” shall be construed accordingly.

Who is responsible for your personal information? If you are a user in the European Union (“EU”) or European Economic Area (“EEA”), for purposes of the EU General Data Protection Regulation 2016/79 the “GDPR”), we act as a data controller with respect to the Personal Data described in this Policy. In this role, we are responsible for implementing the applicable data protection principles and for safeguarding Personal Data. We also recommend you consult the “Rights of EEA Residents” and “International Data Transfers” sections of this Policy for more information about provisions that may apply to you.

PRIVACY PRINCIPLES

When processing personal information, Echo360 shall follow these principles:

· Echo360 endeavors to inform persons whose Personal Information Echo360 collects, in accordance with applicable law, when those persons are first asked to provide personal information to Echo360, or as soon as practicable thereafter. This includes providing information about (i) the purposes for which Echo360 collects and uses the Personal Information, (ii) the types of third parties to which Echo360 discloses (or may disclose) that Personal Information, and (iii) the choices and means Echo360 offers the subjects of the Personal Information for limiting the use and disclosure of their Personal Information.

· Unless permitted by applicable law, no Personal Information is collected without first obtaining the consent of the individual for the collection, use and disclosure of that Personal Information. In some circumstances the consent for Echo360 to collect Personal Information may arise from the nature of the relationship between Echo360 and the individual, or an individual’s interaction with Echo360, such as by using an Echo360 website or engaging in a transaction with Echo360.

· Echo360 will collect your Personal Information only for specified and legitimate purposes. The information we collect will be relevant, adequate and not excessive for the purposes for which it is collected.

· Echo360 will process your Personal Information in a manner consistent with the purposes for which it was originally collected or to which you have subsequently consented.

· Echo360 will take commercially reasonable steps to ensure that your Personal Information is reliable for its intended use, accurate, complete, and, where necessary, kept up-to-date.

· Echo360 will not use your Personal Information for direct marketing purposes without giving you an opportunity to “opt-out.”

· Echo360 will take appropriate measures, by contract or otherwise, to provide adequate protection for Personal Information that is disclosed to a third party or transferred to another country, including transfers within Echo360.

· When you provide Personal Information to Echo360, you acknowledge that you have read this Policy and, where required under applicable law, consent to the collection, use and disclosure of your Personal Information in accordance with this Policy and other applicable Echo360 policies. You may, as provided by applicable law, be free to refuse or withdraw your consent.

· Echo360, and third parties on its behalf, as more fully set forth herein, use the Personal Information collected from you for purposes such as, but not limited to, user registration; administering and tracking a purchase, payment, return, warranty or rebate; arranging for services; inviting participation in online surveys; requesting feedback on products and services; and otherwise communicating with you through various channels.

HOW DO WE COLLECT AND PROCESS YOUR INFORMATION?

We collect and process the following Personal Information from you for the purposes set forth below.

Category	Types of Data and Purpose
Identity Information	Any factual or subjective information about an identifiable individual, which may include, but not be limited to, first name, last name and email address, as well as profile information that you choose to provide for your profile, such as your username, password, preferences, and other information you provide for your profile. We will collect this Personal Information with your express consent or as otherwise permitted by applicable law. This information is necessary to enable us to provide you the account you have requested and to maintain the account and your profile. You may update your account information by editing the information associated with your account. We process Identity Information to provide our Site, to provide our services to you, to honor our terms of use and contracts, to ensure the privacy and security of our Site and services, to maintain our databases and back-ups, to manage our relationships with you, to communicate with you, and to keep records of our communications with you. The legal basis for this processing is consent or, where applicable, our legitimate interests in the proper administration of our Site and business, the proper management of our customer relationships, and the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
Contact Information	You may provide to us your first name, surname, title, government ID, type, and number, as well as your email address, physical address, and phone number. We process Contact Information to provide our Site, to provide our services to you, to honor our terms of use and contracts, to ensure the privacy and security of our Site and services, to maintain our databases and back-ups, to manage our relationships with you, to communicate with you, and to keep records of our communications with you. The legal basis for this processing is consent or, where applicable, our legitimate interests in the proper administration of our Site and business, the proper management of our customer relationships, and the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
Social Network Information	You may connect with us through a third-party social network, such as Facebook, Twitter, LinkedIn and other networks (each, a “Social Network”). If you choose to do so, we may collect information from your profile on such Social Network, such as your name, username, and email address. In addition, our Site offers features that will allow you to share information from our Site to a Social Network or share information from our Social Network sites. If you decide to use such features, they may allow the sharing and collection of information both to and from such Social Network so you should check the privacy policy of each Social Network before using such features. We process Social Network Information to provide our Site and services, to manage our relationships with you, to communicate with you, and to keep records of our communications with you. The legal basis for this processing is consent or, where applicable, our legitimate interests in the proper administration of our Site and business and the proper management of our customer relationships.
Cookies and Similar Technologies	When you visit the Site, we collect cookies and use similar technologies as described in the “Cookies and Similar Technologies” section of this Policy. If you choose to disable cookies and similar technologies, some areas and features of the Site may not work properly. Please see the “Cookies and Similar Technologies” section of this Policy for more information. We process Cookies and Similar Technologies to analyze use of the Site and our services, to operate the Site, to serve you the content and functionality you request, to ensure the privacy and security of our Site and services, to develop new services, to enhance your experience, to track visits to the Site, to provide you with a more personal and interactive experience on the Site, and for usage analytics. We rely on your express opt-in consent for the use of marketing, performance, and analytic cookies and similar technologies. The legal basis for processing of strictly necessary cookies is our legitimate interests in the proper administration of our Site and business.
Usage Data	When you visit our Site, we automatically collect information from your browser or device, which includes the date and time of your visit as well as your location, Internet Protocol (IP) address, unique device identifier, language preference, device type, browser type, domain server, access time, referring website, mobile network information, data about which pages you visit, support document searches, features enabled for your account, and interactions with other parts of our Site. We process Usage Data to analyze use of the Site and our services, to operate the Site, to serve you the content and functionality you request, to ensure the privacy and security of our Site and services, to develop new services, to enhance your experience, to track visits to the Site, and to provide you with a more personal and interactive experience on the Site, and for usage analytics. The legal basis for this processing is our legitimate interests in monitoring and improving our Site and services.
Location Information	When you visit our Site, we may determine your approximate location from your Internet Protocol (IP) address. We process Location Information to analyze use of the Site and our services, to operate the Site, to track visits to the Site, to provide you with a more personal and interactive experience on the Site, and for usage analytics. The legal basis for this processing is our legitimate interests in monitoring and improving our Site and services.
Feedback or Support Inquires, Marketing and Communications Preferences	If you provide us with feedback or respond to surveys, we will collect your name, email address, phone number, marketing preferences, communications preferences, and any written correspondence or comments provided by you. We process Feedback or Support Inquiries to operate the Site and services, to manage our relationships with you, to improve our customer service, to communicate with you, and to keep records of our communications with you. The legal basis for this processing is consent or, where applicable, our legitimate interests in the proper administration of our Site and business, the proper management of our relationships, and the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
Contact Us Data	If you contact us, we collect your email address and the content of your correspondence to us. We process Contact Us Data to operate the Site and services, to ensure the privacy and security of our Site and services, to maintain our databases and back-ups, to manage our relationships with you, to improve our customer service, to communicate with you, and to keep records of our communications with you. The legal basis for this processing is consent or, where applicable, our legitimate interests in the proper administration of our Site and business, the proper management of our relationships, and the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

Additional Personal Data We May Collect:

Payment Data. If you sign up for Paid Services, we receive a portion of your payment information from our payment processor (such as the last four digits, the country of issuance and the expiration date of the payment card) and we ask you to select your jurisdiction.

Communications Data. The emails and other communications that you send us or otherwise contribute, such as customer support inquiries or posts to our customer message boards or forums. Please be aware that information on public parts of our sites is available to others. We may also collect information you share with us in connection with surveys, contests or promotions.

Sub-Domain Data. Information from your use of the Echo360 services or users’ sub-domains. This may include: IP addresses, preferences, information about your browser, network or device (such as browser type and version, operating system, internet service provider, preference settings, unique device IDs and language and other regional settings), information about how you interact with the Services and our Users’ sub-domains (such as timestamps, clicks, scrolling, browsing times, searches, transactions, load times, and problems you may encounter, such as loading errors).

Partner Information. Information we get from our partners to support our marketing initiatives, improve our services and better monitor, manage and measure our ad campaigns, such as details about when our partner shows you one of our ads on or via its advertising platform.

Third-Party Services. Other information you submit to us directly or through third-party services if you use a third-party service to create an Account (based on your privacy settings with such third-party service).

Is entry of personal information required? The entry of Personal Information is required to access certain portions of the Site. You may choose not to provide us with any Personal Information and may still access certain portions of the Site but will not be able to access any portions of the Site that require your Personal Information.

In addition, where we need to process your Personal Information either to comply with law, or to perform the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with the functionalities of the Site). In this case, we may have to stop you from using our Site and terminate the contract you have with us. We will notify you if this is the case at that time.

Aggregated Data. We also collect, use and share “Aggregated Data” such as statistical or demographic data for any purpose. Aggregated Data may be derived from your Personal Information, but once in aggregated form it will not constitute Personal Information for the purposes of the GDPR as this data does not directly or indirectly reveal your identity. However, if we combine or connect Aggregated Data with your Personal Information so that it can directly or indirectly identify you, we treat the combined data as Personal Information which will be used in accordance with this Privacy Policy.

Special Categories of Personal Information. We do not collect any additional “Special Categories of Personal Information” or “Sensitive Personal Information” about you, including, details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, and information about your health. Nor do we collect any information about criminal convictions and offenses.

Protected Health Information. We do not collect, store, maintain, or use any Protected Health Information (“PHI”) as that term is defined in the Health Insurance Portability and Accountability Act of 1996, as amended (“HIPAA”). You are expressly prohibited from entering, submitting, disclosing, or otherwise providing any PHI through or by the Site; any violation of this section is at your sole and voluntary risk and Eche360 shall bear no responsibility or have no liability therefor.

Other Processing Activities. We may process any of the Personal Information identified in this Policy for any of the following purposes:

· Provision of the Echo360 services and products. Create and manage your account, provide and personalize our services, process payments and respond to your inquiries.

· To protect your vital interests.

· Communicating with you. To respond to communications, reach out to you about your transactions or account, market our products and services, provide other relevant information, or request information or feedback. From time to time, we may use your Personal Information to send important notices, such as communications about purchases and changes to our terms, conditions, and policies. Because this information is important to your interaction with Echo360, you may not opt out of receiving these important notices.

· Surveys and contests. Administer surveys, contests and other promotions.

· Customizing the services. Provide you with customized services. For example, we use your location information to determine your language preferences or display accurate date and time information. We also use cookies and similar technologies for this purpose.

· Improving our Services. Analyze and learn about how the services are accessed and used, evaluate and improve our services (including by developing new products and services and managing our communications) and monitor and measure the effectiveness of our advertising. We usually do this based on anonymous, pseudonymized or aggregated information which does not focus on you individually. For example, if we learn that most users of paid services use a particular integration or feature, we might wish to expand on that integration or feature.

· Security and Fraud Protection. To protect individuals, employees, and Echo360 and for loss prevention and to prevent fraud, including to protect individuals, employees, and Echo360 for the benefit of all our users, and prescreening or scanning uploaded content for potentially illegal content, including child sexual exploitation material.

· Third-party relationships. Manage our vendor and partner relationships.

· Enforcement. Enforce our end user subscription agreement and other legal terms and policies.

· Protection. Protect our and others’ interests, rights and property (e.g., to protect our users from abuse).

· Complying with law. Comply with applicable legal requirements, such as tax and other government regulations and industry standards, contracts and law enforcement requests, as well as to keep records of our compliance processes.

· The establishment, exercise, or defense of legal claims, whether in court, administrative, or other proceedings. (The legal basis for such processing is our legitimate interest in the protection and assertion of our legal rights, your legal rights, and the legal rights of others.).

· Because our legitimate interests, or those of a third-party recipient of your Personal Information, make the processing necessary, provided those interests are not overridden by your interests or fundamental rights and freedoms.

· Obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice (the legal basis for this processing is our legitimate interest in the proper protection of our business).

· Purposes that are consistent with, related to and/or ancillary to the purposes and uses described in this Policy for which your personal information was provided to us.

If we need to use your Personal Information for an unrelated purpose, we will update this Privacy Policy and we will explain the legal basis which allows us to do so.

We do not use Personal Information for making any automated decisions affecting or creating profiles other than as described herein.

Marketing Communication Preferences: We process your Personal Information to contact you with information regarding services that may be of interest to you. You can ask us to stop sending you marketing messages at any time by following the update email preferences or unsubscribe links on any marketing message sent to you or by contacting us at any time using the contact details in the Contact Us section. Please note that we may still find it necessary to communicate with you regarding your use of the Site.

Google API Services Compliance

We utilize certain Google API Services including, but not limited to, Google Classroom, in connection with the EchoPoll service we provide to you. Our Site’s use and transfer of information received from or provided to Google APIs will adhere to Google API Services User Data Policy, found at the following link: https://developers.google.com/terms/api-services-user-data-policy, including its Limited Use requirements as set forth in the Limited Use section of this policy. Specifically, we collect certain data from you via surveys, questionnaires, and quizzes provided through EchoPoll and we provide that data to Google API for the purpose of data analytics, and to support our continued provision and enhancement of services to you, in addition to the identified Processing Activities listed in “Other Processing Activities”.

End Users Personal Information

Our customers may establish a sub-domain using services and are responsible for what they do with the Personal Information they collect about their End Users. This section is directed to such customers.

If you are one of our Users, you may collect Personal Information about your End Users. For example, you may ask your End Users to provide their name, and email address in order to establish an account for them. You are solely responsible for complying with any laws and regulations that apply to your collection and use of your End Users’ information, including Personal Information you collect about them.

You may choose to publish your own privacy policy and comply with them. We are not liable for your relationship with your End Users or how you collect and use Personal Information about them (even if you collect it through the use of Echo360 functionality) and we will not provide you with any legal advice regarding such matters nor will we defend or represent you in any way with regard to any disputes with your End Users.

How and When Is Your Information Shared With Other Parties? We may share your information in the following contexts, but we will not share your Personal Information if such sharing is prohibited by applicable privacy and data protection law. We do not sell, trade or license Personal Information about our users for marketing purposes.

HOW DO WE SHARE OR DISCLOSE YOUR PERSONAL INFORMATION?

Where permitted by applicable law, we may share your Personal Information in the following contexts. If we are acting as a data processor, disclosures in the following contexts will be limited in accordance with the instructions from the data controller.

Category	Context
Corporate Affiliates	We may share your Personal Information with our corporate subsidiaries and affiliates and with their respective officers, directors, employees, accountants, attorneys and agents.
Service Providers	We may share your Personal Information with our contractors, service providers, and other third parties that need access to your information to provide operational or other support services on our behalf. Among other things, service providers help us to administer the Site; support our provision of services requested by you; send marketing promotions and communications to you about our services; provide payment processing; provide technical support; and assist with other legitimate purposes permitted by law.
Legal Obligations and Rights	We may disclose your Personal Information in response to subpoenas, warrants, court orders or other legal process, or to comply with relevant laws. We may also share your Personal Information in order to establish or exercise our legal rights, to defend against a legal claim, and to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property, or a violation of our Terms of Use or other contracts. We may also disclose Personal Information as needed to protect vital interests.
Acquisitions and Similar Transactions	We may share your Personal Information in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our company assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us is among the assets transferred.
Disclosures with Consent	We may share your Personal Information to fulfill the purpose(s) disclosed by us when you provided your Personal Information and for which you have provided consent. We may further ask if you would like us to share your Personal Information with other unaffiliated third parties who are not described elsewhere in this Policy. We will only disclose your Personal Information in this context with your consent.
De-identified or Aggregated Data	We may disclose aggregated information about our users, and information that does not identify any specific individual, such as groupings of demographic data or customer preferences, for new services and marketing development.
Professional Advisors	We may share your Personal Information with our insurers and other professional advisors, including attorneys and accountants, that need access to your information to provide operational or other support services on our behalf.
Process Payments	We may disclosure your identity data and payment data via an encrypted connection to our payment processor.

HOW LONG DO WE STORE AND PROCESS YOUR INFORMATION?

We retain and use your Personal Information for as long as is necessary to fulfill the purposes for which it was collected, to comply with our business requirements and legal obligations, to resolve disputes, to protect our assets, to provide our services, and to pursue legitimate business purposes, to enforce our agreements.

We take reasonable steps to delete the Personal Information we collect when (1) we have a legal obligation to do so, (2) we no longer have a purpose for retaining the information, and (3) if you ask us to delete your Personal Information, unless we determine that doing so would violate our existing, legitimate legal, regulatory, dispute resolution, contractual, or similar obligations. We may also decide to delete your Personal Information if we believe it is incomplete, inaccurate, or that our continued storage of your Personal Information is contrary to our legal obligations or business objectives.

To the extent permitted by law, we may retain and use anonymous, de-identified, aggregated information for performance reporting, benchmarking, and analytic purposes and for product and service improvement. When we delete data, it will be removed from our active servers and databases; but it may remain in our archives when it is not practical or possible to delete it.

We are required by law to maintain records of consumer requests submitted under the California Consumer Privacy Act and how we responded to such requests for at least twenty-four (24) months. We only use this information for recordkeeping purposes. If you are a resident of California, please see the California Residents section for more information.

HOW DO WE PROTECT YOUR PERSONAL INFORMATION?

We have put security measures in place to protect the Personal Information that you share with us from being accidentally lost, used, altered, or disclosed or accessed in any unauthorized manner. From time to time, we review our security procedures to consider appropriate new technologies and methods.

While our security measures seek to protect the Personal Information in our possession, no security system is perfect, and no data transmission is 100% secure. As a result, while we strive to protect your Personal Information, we cannot guarantee or warrant the security of any information you transmit to or from the Site. Your use of the Site is at your own risk. We cannot guarantee that your data will remain secure in all circumstances.

We have implemented reasonable security measures to detect fraudulent identity-verification activity and to prevent the unauthorized access to or deletion of Personal Information. Our information security program is based on the internationally recognized standards of ISO 27001 and AICPA SOC2 (SSAE 18). Key Echo360 business systems are GDPR, CCPA, and CPRA compliant and certified as SOC2 compliant. Systems and processes have been scrutinized for limiting access to only required personnel, and the proper protections and restrictions to physical accessibility have been implemented to secure your Personal Information from accidental loss and from unauthorized access, use, alteration or disclosure. We use reasonable security measures when transmitting Personal Information to consumers in responding to requests under the California Consumer Privacy Act.

The safety and security of your Personal Information also depends upon you. Where you use a password for access to restricted parts of the Site, you are responsible for keeping your password confidential. Do not share your password with anyone.

If a data breach compromises your Personal Information, we will notify you and any applicable regulator when we are required to do so by applicable law.

RIGHTS AND CHOICES REGARDING HOW WE USE AND DISCLOSE YOUR INFORMATION

Please use the “Contact Us” details at the end of this Policy to exercise your rights and choices under this Policy. If you would like to manage, change, limit, or delete your Personal Information nor if you no longer want to receive any text message or email contact from us in the future, such requests may be submitted via the “Contact Us” details at the end of this Policy.

Communication Preferences. If you no longer wish to receive communications from us via email, you may opt-out of certain types of communications (as described below) by clicking the “unsubscribe” link at the bottom of our emails or by contacting us at the “Contact Us” details provided at the end of this Policy and providing your name and email address so that we may identify you in the opt-out process. Once we receive your instruction, we will promptly take action.

· Communications Regarding Our Services. We will send you email notifications and free newsletters from time to time with offers, suggestions and other information. You may “opt-out” from receiving such communications by following the “Unsubscribe” instructions provided in the email.

· Legal or Security Communications. We also send out notices that are required for legal or security purposes. For example, certain notifications are sent for your own protection. In other cases, these notifications involve changes to various legal agreements, such as this Policy or the Terms of Service. Generally, you may not opt out of such emails.

· Account and Order Communications. If you subscribe to our services, we may send you communications regarding such services. We may also send communications providing customer support or responses to questions regarding the operation of the services. Generally, you may not opt out of such emails.

COOKIES AND SIMILAR TECHNOLOGIES

Cookies. A “cookie” is a small file created by a web server that can be stored on your device (if you allow) for use either during a particular browsing session (a “session” cookie) or a future browsing session (a “persistent” or “permanent” cookie). “Session” cookies are temporarily stored on your hard drive and only last until they expire at the end of your browsing session. “Persistent” or “permanent” cookies remain stored on your hard drive until they expire or are deleted by you. Local shared objects (or “flash” cookies) are used to collect and store information about your preferences and navigation to, from, and on a website. First-party cookies are set by the website you’re visiting, and they can only be read by that site. Third-party cookies are set by a party other than that website.

First and Third-Party Cookies. Our Site use 1st party cookies (set by Echo360), 3rd party cookies (which are set by third parties), and other similar technologies. First party cookies are set by us (Echo360). Third party cookies are set by third parties when you access some content or applications, including advertisements, on our Site. These third parties include advertisers, ad networks and servers, content providers, application providers, and social media sites. Unless you set your browser to refuse cookies as described below, these third parties may use cookies (alone or in conjunction with web beacons or other tracking technologies) to collect information about you when you access our Site. The information they collect may be associated with your Personal Information or they may collect information, including Personal Information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising and other targeted content. We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about advertisement or other targeted content, you should content the responsible provider directly. Below is a list of the different types of cookies that we use on our Site.

Essential Cookies and Similar Technologies. Essential cookies and other similar technologies used by us enable you to navigate the Site and use their services and features. Without these essential cookies, the Site will not perform correctly, and we may not be able to provide the Site to you or provide you with certain services or features of our Site.

Preference Cookies and Similar Technologies. Preference cookies collect information about your choices and preferences and allow us to remember language and other local settings and to customize our Site accordingly.

Social Media Cookies and Similar Technologies. Social Media cookies and other similar technologies used by us collect information about your use of social media websites.

Other Similar Technologies. In addition to cookies, there are other automatic data collection technologies, such as Internet tags, web beacons (clear gifs, pixel tags, and single-pixel gifs), and navigational data collection (log files, server logs, etc.) that can be used to collect data as users navigate through and interact with a website. For example, web beacons are tiny graphics with unique identifiers that are used to understand browsing activity. In addition, UTM codes are strings that can appear in a URL when you move from one web page or website to another. The string can represent information about browsing, such as which advertisement, page, or publisher sent the user to the receiving website.

Analytics Cookies and Similar Technologies. Analytics cookies and other similar technologies used by us collect information about your use of the Site and enable us to improve the way they work and operates. Specifically, analytics cookies provide us with information regarding what the most frequently visited pages on the Site are, help us record and debug any issues you may have with the Site, and show us how effective our advertising is. These analytics cookies do not allow us to see the usage of a single user but does allow us to see overall patterns of usage on the Site. We do not examine this information for individually identifying information, but we do use this information to understand the traffic on our Site.

Advertising Cookies and Similar Technologies. Advertising and other similar technologies used by us cookies are used to display targeting promotions or advertisements based on your use of the Site and interests and to manage our use of advertising resources. These cookies collect information about your activities on this and other sites to provide you with interest-based advertising. You can learn more about interest-based advertisements and your opt-out rights and options from members of the Network Advertising Initiative (“NAI”) on its website (www.networkadvertising.org) and from members of the Digital Advertising Alliance on its website (www.aboutads.info). We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can also opt out of receiving targeted ads from members of the NAI on its website.

Facebook. We use Facebook’s technologies to serve relevant advertisements and to track Facebook ad-driven visitor activity. Facebook Connect also gives you the option to post information about your activities to your profile page to share with others within your network by using a single sign-in service to authenticate your identity. You may learn more about Facebook’s policies by visiting https://www.facebook.com/policy.php, and you can also find instructions for opting out of receiving advertisements via that page.

HubSpot. We use HubSpot to collect, monitor, and analyze navigational information from your web browser, your IP address, and the actions you take the Site, such as the web pages viewed and the links clicked, to increase the functionality of the Site and our services. To opt out of HubSpot’s processing of your information for analytics purposes please visit this page: https://privacyportal.onetrust.com/webform/9fd092df-0b2a-4194-89f1-820b83267af4/13da1ce4-8542-4d34-a84c-379495aa666c. For more information on the privacy practices of HubSpot, please visit the HubSpot Privacy Policy web page: https://legal.hubspot.com/privacy-policy.

Google Analytics. We use Google Analytics to collect and process statistical data about the number of people using the Site and to better understand how they find and use the Site. The data collected includes data related to your device/browser, your IP address, and on-site activities to measure and report statistics about user interactions. The information stored is reduced to a random identifier. Any data collected is used in accordance with this Policy and Google’s privacy policy. You may learn more about Google Analytics by visiting https://www.google.com/policies/privacy/partners/ and https://support.google.com/analytics/answer/6004245. You can learn more about Google’s restrictions on data use by visiting the Google Privacy Policy at: https://www.google.com/policies/privacy. To opt-out of Google Analytics, visit https://tools.google.com/dlpage/gaoptout and install the opt-out browser add-on feature. For more details, visit the “Google Analytics opt-out browser add-on” page located at https://support.google.com/analytics/answer/181881?hl=en.

Google Tag Manager. We use Google Tag Manager, which allows marketed website tags to be managed using an interface. The tool itself (which implements the tags) does not use cookies and does not register identifiable data. The tool causes other tags to be activated which may, for their part, register personal data under certain circumstances. Google Tag Manager does not access this information. Google Tag Manager is subject to the Google Privacy Policy located at https://www.google.com/intl/en/policies/privacy.

Google Marketing. We use Google’s marketing technologies (DoubleClick) to track user activity and to serve personalized advertisements. Your browser is assigned a pseudonymous ID, which is used to track the ads that have been served to your browser and to identify those on which you’ve clicked. The cookies enable Google and its partners to select and display ads based on your browsing behavior. For more information on how Google uses this information, you can visit https://policies.google.com/technologies/ads and https://support.google.com/displayvideo/answer/7621162. To block certain ads served by Google, please visit https://support.google.com/ads/answer/2662922 and https://adssettings.google.com. Google’s Privacy Policy is available at: https://www.google.com/policies/privacy.

Choices About Cookies and Similar Technologies. You may choose to not allow analytic cookies via the cookies consent banner or you may set your browser to refuse all or some browser cookies or to alert you when cookies are being set. For more information on how to modify your browser settings to block or filter cookies, visit http://www.aboutcookies.org/. You may learn more about internet advertising practices and related consumer resources at http://www.aboutads.info/consumers/, http://www.networkadvertising.org/choices, and http://youronlinechoices.eu/. These settings may affect your enjoyment of the Site’s functionality. Adjusting the cookie settings may not fully delete all of the cookies that have already been created. To delete them, you should review your web browser settings after you have changed your cookie settings. In addition to the above, the links below provide additional information about how to disable cookies or manage the cookie settings:

Google Chrome: https://support.google.com/chrome/answer/95647?hl=en

Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences

Microsoft Edge: https://support.microsoft.com/en-us/microsoft-edge/delete-cookies-in-microsoft-edge-63947406-40ac-c3b8-57b9-2a946a29ae09

Safari: https://support.apple.com/guide/safari/manage-cookies-sfri11471/mac and https://support.apple.com/en-us/HT201265

Zoom. Some services that we offer may use Zoom. When you join meetings and webinars on Zoom, other people or organizations, including third parties outside the meeting or webinar, may be able to see content and information that you share. Our customers, not Echo360, designates one or more people (called an Admin. User or “Administrator”) to manage the User’s Zoom account. Administrators may be able to see content and information shared in a Zoom meeting. You may learn more about Zoom’s policies by visiting https://explore.zoom.us/en/privacy/.

Online Tracking Signals. We do not currently recognize browser settings or signals of tracking preferences, which may include “Do Not Track” instructions. “Do Not Track” is a web browser setting that seeks to disable the tracking of individual users’ browsing activities. We adhere to the standards set out in this Policy and do not currently respond to “Do Not Track” signals on the Site or on third-party websites or online services where we may collect information.

Accuracy and Updating Your Personal Information. Our goal is to keep your Personal Information accurate, current, and complete. If any of the Personal Information you have provided to us changes, please update it in your user/account profile, or let us know via the “Contact Us” details at the end of this Policy. For instance, if your email address changes, you may wish to let us know so that we can communicate with you. If you become aware of inaccurate Personal Information about you, you may want to update your information. We are not responsible for any losses arising from any inaccurate, inauthentic, deficient or incomplete personal data that you provide to us.

Complaints. If you believe that your rights relating to your Personal Information have been violated, you may lodge a complaint with us by contacting us via the “Contact Us” details at the end of this Policy.

California Residents

CCPA and CPRA Notice at Collection. For purposes of the California Consumer Privacy Act (“CCPA”) and California Privacy Rights Act (“CPRA”), in collecting the information described above, we collect the categories of Personal Information listed below.

CCPA/CPRA Category	Description
Identifiers	When collecting Account Information, we will receive your name, email address, username, and unique personal identifier. When collecting Social Media Information, Feedback or Support Inquiries, and Contact Us Data, we will receive your name and email address. When collecting Social Media Information, we will receive your name and email address. When collecting Cookies and Similar Technologies and Usage Information, we will receive your Internet Protocol (IP) address or unique device identifier. We use Identifiers as set forth in the “How Do We Collect and Use Personal Information” and the “How Do We Share or Disclose Personal Information” sections of this Policy.
Categories of personal information described in the California Customer Records statute	When collecting Account Information, we will receive your name, email address, username, and unique personal identifier. When collecting Social Media Information, Feedback or Support Inquiries, and Contact Us Data, we will receive your name and email address. When collecting Social Media Information, we will receive your name and email address. When collecting Cookies and Similar Technologies and Usage Information, we will receive your Internet Protocol (IP) address or unique device identifier. We use Categories of Personal Information described in the California Customer Records statute as set forth in the “How Do We Collect and Use Personal Information” and the “How Do We Share or Disclose Personal Information” sections of this Policy.
Internet or other electronic network activity information	When collecting Cookies and Similar Technologies and Usage Information, we will receive data about which webpages you visit. When collecting Location Information and Usage Information, we will automatically receive information from your browser and your device, which includes the date and time of your visit as well as your location, Internet Protocol (IP) address, domain server, browser type, access time, and data about which pages you visit. We use Internet or Other Electronic Network Activity Informationas set forth in the “How Do We Collect and Use Personal Information” and the “How Do We Share or Disclose Personal Information” sections of this Policy.
Geolocation data	When collecting Cookies and Similar Technologies, Location Information and Usage Information we will receive your geolocation while using the Site. We use Geolocation Data as set forth in the “How Do We Collect and Use Personal Information” and the “How Do We Share or Disclose Personal Information” sections of this Policy.
Audio, electronic, visual, thermal, olfactory, or similar information	We use Audio, electronic, Visual, Thermal, Olfactory, or Similar Informationas set forth in the “How Do We Collect and Use Personal Information” and the “How Do We Share or Disclose Personal Information” sections of this Policy.
Commercial Information	When collecting Contact Us Data, we will receive your preferred method of contact and the message that you choose to provide. We use Commercial Information as set forth in the “How Do We Collect and Use Personal Information” and the “How Do We Share or Disclose Personal Information” sections of this Policy.
Professional or employment-related information	When collecting Account Information and Contact Us Data, we will receive your work email address, work telephone number, company name, and company address. We use Professional or Employment-Related Information as set forth in the “How Do We Collect and Use Personal Information” and the “How Do We Share or Disclose Personal Information” sections of this Policy.
Inferences	Examples: Derivation of information, data, assumptions, or conclusions from facts, evidence, or another source of information or data) drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Data Practices During Last 12 Months

Personal Information Collected: As described in this Policy, we have collected the categories of Personal Information listed below during the preceding 12 months:

· Identifiers

· Categories of personal information described in the California Customer Records statute

· Internet or other electronic network activity information

· Geolocation data

· Audio, electronic, visual, thermal, olfactory, or similar information

· Commercial Information

· Professional or employment-related information

Categories of Sources: We have collected the Personal Information identified in this Policy from you directly when you provide it to us, automatically as you navigate through the Site, which may include, but not be limited to, usage details, IP addresses, and information collected through cookies and other tracking technologies, and from our business partners, as applicable.

Business and Commercial Purposes for Collecting: We have collected the categories of Personal Information listed above for the following purposes:

· Operate the Site;

· Provide our services to you;

· Honor our terms of use and contracts;

· Ensure the privacy and security of our Site and services;

· Maintain our databases and back-ups;

· Manage our relationships with you;

· Communicate with you;

· Keep records of our communications with you;

· Analyze use of the Site and our services;

· Serve you the content and functionality you request;

· Develop new services;

· Enhance your experience;

· Track visits to the Site;

· Provide you with a more personal and interactive experience on the Site; and

· Usage analytics purposes.

Personal Information Sold: We have not sold or shared categories of Personal Information during the preceding 12 months.

Personal Information Disclosed for a Business Purpose. We have disclosed for a business purpose the categories of Personal Information listed below during the preceding 12 months:

· Identifiers

· Categories of personal information described in the California Customer Records statute

· Characteristics of protected classifications

· Commercial information

· Internet or other electronic network activity information

· Commercial Information

· Geolocation data

We have disclosed each category of Personal Information to the following categories of third parties: (1) corporate parents, subsidiaries, and affiliates; (2) advisors (accountants, attorneys); (3) contractors and service providers (data analytics, data storage, mailing, marketing, website and platform administration, technical support); and (4) operating systems and platforms.

Personal Information Retention. We will store your Personal Information for as long as is reasonably necessary to fulfill the purposes described in this Policy or as required by law or Echo360’s data retention policy.

Children

Echo360 does not collect or maintain Personal Information on any minors under the age of 16. We do not knowingly sell or share Personal Information of minors under 16 years old, however, to the extent we knowingly “sell” or “share” as those terms are defined under the CCPA and the CPRA, respectively, the Personal Information of minors under 16 years old who are California residents, we either obtain prior affirmative authorization from such minor to the opt-in to the sale of the minor’s Personal Information or obtain affirmative authorization from the minor’s parent or guardian. A minor, or parent/guardian, who has opted in to the sale of the minor’s Personal information has the right to opt-out at any time. To exercise your right to opt-out see the Right to Opt-Out section below. See also the Submitting a Request and Right to Delete sections with regard to Personal Information of any minors under the age of 16.

No Financial Incentive

We do not offer financial incentives or any price or service difference in exchange for the retention, sale, or sharing of your Personal Information.

Right to Opt-Out/Do Not Sell or Share My Personal Information or Sensitive Personal Information

Under the CCPA and CPRA, you have the right to direct us to stop selling and sharing your Personal Information to third parties and to refrain from doing so in the future. To the extent we sell or share your Personal Information, as those terms are defined in the CCPA and CPRA, respectively, you have the right to opt-out of the sale or sharing of your Personal Information at any time. You may submit a request to opt-out using the link on our website, or by contacting or us at 1-877-ECHO360 x2 or by email at support@echo360.com or privacy@echo360.com. For purposes of the CCPA and the CPRA, we do not sell or share Personal Information or Sensitive Personal Information as defined under applicable law.

Requests to Know, Requests to Delete, and Requests to Correct

The CCPA and CPRA gives consumers the right to request that we (1) disclose what Personal Information we collect, use, disclose, sell, and share and (2) delete certain Personal Information that we have collected or maintain. You may submit these requests to us as described below, and we honor these rights where they apply.

If a request is submitted in a manner that is not one of the designated methods for submission, or if the request is deficient in some manner unrelated to our verification process, we will either (1) treat the request as if it had been submitted in accordance with the designated manner, or (2) provide you with specific directions on how to submit the request or remedy any deficiencies with the request, as applicable.

Request to Know. As a California resident, you have the right to request: (1) the specific pieces of Personal Information we have collected about you; (2) the categories of Personal Information we have collected about you; (3) the categories of sources from which the Personal Information is collected; (4) the categories of Personal Information about you that we have sold or shared and the categories of third parties to whom the Personal Information was sold or shared; (5) the categories of Personal Information about you that we disclosed for a business purpose and the categories of third parties to whom the Personal Information was disclosed for a business purpose; (6) the business or commercial purpose for collecting, disclosing, selling, or sharing Personal Information; and (7) the categories of third parties with whom we share Personal Information. Our response will cover the 12-month period preceding our receipt of a verifiable request, except as otherwise required by applicable law.

Request to Delete. As a California resident, you have a right to request the erasure/deletion of certain Personal Information collected or maintained by us. As described herein, we will delete your Personal Information from our records and direct any service providers (as defined under applicable law) to delete your personal information from their records. However, we are not required to honor a deletion request if an exemption applies under the law.

Request to Correct. As a California resident, you have a right to request the correction of certain inaccurate Personal Information collected or maintained by us. Upon receipt of a verifiable request to correct inaccurate Personal Information, we will use commercially reasonable efforts to correct the inaccurate Personal Information as directed by you, pursuant to applicable law.

Right to Limit Use and Disclosure of Sensitive Personal Information

As a California resident, you have a right to request that use and disclosure of Sensitive Personal Information be limited to that use which is necessary to perform the services or provide the goods reasonably expected by a similarly situated consumer and as authorized in accordance with applicable law. You further have the right to opt-out of the selling or sharing of your Sensitive Personal Information. See the Right to Opt-Out section for further instructions as to how to Opt-Out.

Submitting a Request

Submission Instructions. You may submit a request to know or to delete via your Account Page or by email to support@echo360.com or privacy@echo360.com. Regarding requests to delete, we may present you with the choice to delete select portions of your Personal Information, but a global option to delete all Personal Information will be offered and more prominently presented.

Verification Process. We are required by law to verify the identities of those who submit requests to know or to delete. To determine whether the individual making the request is the consumer about whom we have collected information, we will verify your identity by matching the identifying information provided by you in the request to the personal information that we already maintain about you. As a part of this process, you will be required to provide your full name, account number, address, and telephone number. We will inform you if we cannot verify your identity.

· If we cannot verify the identity of the person making a request for categories of Personal Information, we may deny the request. If the request is denied in whole or in part for this reason, we will provide a copy of, or direct you to, our privacy policy.

· If we cannot verify the identity of the person making the request for specific pieces of Personal Information, we are prohibited from disclosing any specific pieces of Personal Information to the requestor. However, if denied in whole or in part for this reason, we will evaluate the request as if it is seeking the disclosure of categories of personal information about the consumer.

· If we cannot verify the identity of the person making a request to delete, we may deny the request.

· If there is no reasonable method by which we can verify the identity of the requestor to the degree of certainty required, we will state this in our response and explain why we have no reasonable method by which we can verify the identity of the requestor.

Authorized Agents. Authorized agents may submit requests via the methods identified in this Policy. If you use an authorized agent to submit a request to know or a request to delete, we may require you to: (1) provide the authorized agent with signed permission to do so; (2) verify your identity directly with us; and (3) directly confirm with us that you provided the authorized agent permission to submit the request. However, we will not require these actions if you have provided the authorized agent with power of attorney pursuant to the California Probate Code.

Excessive Requests. If requests from a consumer are manifestly unfounded or excessive, in particular because of their repetitive character, we may either (1) charge a reasonable fee, or (2) refuse to act on the request and notify the consumer of the reason for refusing the request. If we charge a fee, the amount will be based upon the administrative costs of providing the information or communication or taking the action requested.

Time Period to Comply with Requests. Echo360 will disclose and deliver the required information as requested by you pursuant to this Section free of charge, correct inaccurate Personal Information, or delete your Personal Information, based on your request, within 45 days of receiving a verifiable request, but will confirm receipt of your request within 10 business days of receipt of same. We will promptly take steps to determine whether the request is a verifiable consumer request, as set forth herein, but this shall not extend our duty to disclose and deliver the information, to correct inaccurate Personal Information, or to delete Personal Information within 45 days of receipt of the request. However, the time period to provide the required information, to correct inaccurate Personal Information, or to delete Personal Information may be extended once by an additional 45 days when reasonably necessary, provided we provide you with notice of the extension within the first 45-day period.

Non-Discrimination

You have the right not to receive discriminatory treatment by us due to your exercise of the rights provided by the CCPA and CPRA. We do not offer financial incentives and price or service differences, and we do not discriminate against consumers for exercising their rights under the CCPA and CPRA.

California Shine the Light

Under California Civil Code Section 1798.83, California residents who provide Personal Information in obtaining products or services for personal, family, or household use may be entitled to request and obtain from us once a calendar year information about the information we shared, if any, with other businesses for direct marketing uses. At present, we do not share your Personal Information with third parties for those third parties’ direct marketing purposes. Please be aware that not all information sharing is covered by the “Shine the Light” requirements and only information on covered sharing, if any, will be included in our response. As part of the California Online Privacy Protection Act, all users of our Site may make any changes to their information at any time by contacting us at privacy@echo360.com.

Nevada Residents

You may submit a verified request to us at privacy@echo360.com to request that we not make any sale (as defined under Nevada law) of any covered information (as defined under Nevada law) that we have collected or will collect about you. Please provide your name and contact information in your request, and we will respond to your request in accordance with Nevada law. However, please know that we do not currently sell data triggering the Nevada statute’s opt-out requirements.

Colorado, Connecticut, Virginia, and Utah

If you are a resident of Colorado, Connecticut, Utah or Virginia, you may have certain privacy rights under the applicable privacy laws in your state (“State Privacy Laws”). This section describes those rights and how you can exercise them with Echo360.

Rights Requests

Right to Know, Right to Deletion and Right to Correct

You can request what Personal Information we have collected, used, disclosed, and sold.

You can request to correct inaccuracies in your Personal Information, taking into account the information’s processing purpose.

You can opt-out of profiling in furtherance of decisions that produce legal or similarly significant effects including, but not limited to, automated processing performed on personal information to evaluate, analyze or predict personal aspects related to your economic situation, health, personal preferences, interests, reliability, behavior, location or movements (“Profiling”). To submit a request to opt out pursuant to this section, please contact us using the information provided in the Contact Us section of this Policy. To opt out of cookie-based or digital advertising-based Profiling, please opt out of the selling/sharing of your information for targeted advertising, as described above. Note that if you opt out of profiling, your experience with Echo360 will be less personalized.

We will not be able to opt you out of Profiling where one of the following exceptions applies:

· Legal: To comply with applicable laws, rules or regulations; to comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons by governmental authorities; to cooperate with law enforcement; to investigate, exercise, prepare for or defend actual or anticipated legal claims; or to assist another party with any of its obligations under applicable laws;

· Security: To prevent, detect, protect against, or respond to security incidents, identity theft, fraud, harassment, or malicious, deceptive, or illegal activity; preserve the integrity or security of systems; or investigate, report, or prosecute those responsible for any such action;

· Improvement of Services and Products/Internal use: To conduct internal research to improve, repair or develop products, services or technology;

· Transactional: To provide a product or service specifically requested by you; to complete a transaction with you or to complete a contract we have with you; and

· Public Interest: To protect your vital interests or those of another individual.

You can also request that we delete your Personal Information. We may not delete all of your Personal Information if one of the following exceptions applies:

· Transactional: To complete a transaction for which the Personal Information was collected, provide a good or service requested by you, or perform a contract we have with you;

· Security: To detect data security incidents; preserve the integrity or security of systems; or investigate, report, or prosecute those responsible for any such action;

· Error Correction: To debug or repair any errors;

· Legal: To protect against fraud, harassment, malicious or deceptive activities, or illegal activity or to comply with applicable law or a legal obligation, or exercise rights under the law, such as the right to free speech; to assist another party with any of its obligations under applicable privacy laws; or

· Internal Use: To use your Personal Information, internally, in a lawful manner that is compatible with the context in which you provided the information (i.e., to improve our services).

Right to Appeal

If you are a Colorado, Connecticut or Virginia resident and we were unable to fulfill your request, you may appeal our request by contacting us using the information provided in the Contact Us section of this Policy within fourteen days of our decision, and submitting an appeal request, with a detailed reason for your appeal, as well as your state of residence.

Retention

We will store your Personal Information for as long as is reasonably necessary to fulfill the purposes described in this Privacy Policy or as required by applicable law.

To exercise any of these rights or to appeal a decision regarding a consumer rights request, please contact us using any of the methods listed in Contact Us section of this Policy.

Canada Residents

If you are located in Canada, you have the following rights under Canada’s main federal law relating to privacy, the Personal Information Protection and Electronic Documents Act (PIPEDA):

· ask whether we hold Personal Information about you and request copies of such Personal Information and information about how it is processed;

· request that inaccurate Personal Information is corrected;

· request deletion of Personal Information that is no longer necessary for the purposes underlying the processing, processed based on withdrawn consent, or processed in non-compliance with applicable legal requirements; and

· lodge a complaint with us regarding our practices related to your Personal Information.

To exercise any of these rights, please contact us using any of the methods listed in the Contact Us section of this Policy.

Australia Residents

If you are an individual located in Australia whose Personal Information is collected or held by us at a time when the collecting or holding entity has an ‘Australian link’ within the meaning of the Privacy Act 1988 (Cth) (the “Australian Privacy Law”), you may:

· request access to your Personal Information processed by Echo360;

· seek correction of your Personal Information processed by Echo360;

· make a complaint to us about a breach of the Australian Privacy Law;

by contacting us using any of the methods listed in the Contact Us section of this Policy.

Prior to providing you with access to, or correcting your, Personal Information, we will seek to verify your identity. We will not charge you a fee for requesting corrections of your Personal Information, however, in some circumstances, we may charge you a fee for providing you access to your Personal Information to cover reasonable administrative costs in locating, copying, and supplying that information to you.

We will investigate any complaint you may have with respect to the handling of your Personal Information and endeavor to resolve any issue to your satisfaction. If we do not adequately answer your concerns, you will have the right to make a complaint to the Office of the Australian Information Commissioner (OAIC) by phone at 1300 363 992 or completing the OAIC’s privacy complaint fo/rm.

EU/EEA Residents

If you are located in the EU or EEA, you have the following rights under the GDPR. All requests should be sent to the address noted in the “Contact Us” section of this Policy, and we will fulfill requests to the extent required by applicable law.

Personal Data. Under the GDPR, Personal Data is defined as any information relating to an identified or identifiable natural person (“Data Subject”). A Data Subject is an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Collection of Personal Data. Your Personal Data may be collected whenever Echo360:

· interacts with individuals who are prospective and existing customers/suppliers;

· interacts with individuals who are representatives or contact persons of prospective and existing customers/suppliers that are legal entities (e.g., for the selling/ordering of products or for marketing related purposes); or

· uses public databases to facilitate the provision of goods or services (e.g., to link a license plate with car identification information).

Categories of Personal Data Collected. Echo360 may collect:

· basic identification information, such as name, title, position, company name, email and/or postal address and the fixed and/or mobile phone number;

· financial information (e.g., bank account details, credit card information);

· information regarding the status of direct marketing emails (e.g., not delivered, delivered, opened);

· any additional information you voluntarily provide, (e.g., by filling in a form or registering for an email newsletter).

This information may either be directly provided by the above individuals or provided by the legal entity for whom they work (e.g., if they are the contact person designated by their employer to manage the commercial relations with Echo360).

Legal Basis of the Processing. We are not allowed to process Personal Data if we do not have a valid legal ground. Therefore, we will only process Personal Data if:

· we have obtained your prior consent;

· the processing is necessary to perform our contractual obligations towards you or to take pre-contractual steps at your request;

· the processing is necessary to comply with our legal or regulatory obligations (e.g., tax or accounting requirements); or

· the processing is necessary for the legitimate interests of Echo360 and does not unduly affect your interests or fundamental rights and freedoms. Please note that, when processing your Personal Data on this basis, we seek to maintain a balance between our legitimate interests and your privacy.

Right of Access. To the extent required by law, you have the right to receive confirmation as to whether or not Personal Data concerning you are being processed, and, where that is the case, access to the Personal Data and the following information: the purposes of the processing; the categories of Personal Data concerned; and the recipients or categories of recipient to whom the Personal Data have been or will be disclosed. We will provide a copy of your Personal Data in compliance with applicable law.

Right of Rectification. Our goal is to keep your Personal Data accurate, current, and complete. Please contact us if you believe your information is not accurate or if it changes.

Right to Erasure. In some cases, you have a legal right to request that we delete your Personal Data when (1) it is no longer necessary for the purposes for which it was collected, (2) consent has been withdrawn in certain instances, (3) you have objected to the processing in certain instances, (4) the Personal Data has been unlawfully processed, (5) the Personal Data have to be erased for compliance with a legal obligation; and (6) the Personal Data were collected in relation to the offer of information society services. However, the right is not absolute. When we delete Personal Data, it will be removed from our active servers and databases as well as the Site; but, it may remain in our archives when it is not practical or possible to delete it. We may also retain your Personal Data as needed to comply with our legal obligations, resolve disputes, or enforce any agreements.

Right to Restrict Processing. You have the right to restrict the processing of your Personal Data when (1) the accuracy of the Personal Data is contested, for a period enabling the controller to verify the accuracy of the Personal Data; (2) the processing is unlawful and you oppose erasure and request a restriction instead; (3) we no longer need the Personal Data, but you need us to keep it for the establishment, exercise, or defense of legal claims; or (4) you have objected to us processing the Personal Data, pending resolution of the objection.

Right to Object. In certain circumstances, you have the right to object to the processing of your Personal Data where the processing is necessary for performance of a task carried out in the public interest, for our legitimate interests, or for the legitimate interests of others. You also have the right to object where Personal Data are processed for direct marketing purposes or for scientific or historical research purposes or statistical purposes.

Right to Withdraw Consent. If you have provided your consent to the collection, processing, and transfer of your Personal Data, you may have the right to fully or partially withdraw your consent. Once we have received notice that you have withdrawn your consent, in whole or in part, we will no longer process your information for the purpose(s) to which you originally consented and have since withdrawn unless there are compelling legitimate grounds for further processing that override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims. Withdrawal of consent to receive marketing communications will not affect the processing of Personal Data for the provision of our services.

Right to Complain. If you believe we have not processed your Personal Data in accordance with applicable provisions of the GDPR, we encourage you to contact us at dpo@echo360.com or privacy@echo360.com. You also have the right to make a GDPR complaint to the relevant Supervisory Authority or seek a remedy through the courts. A list of Supervisory Authorities is available at: https://edpb.europa.eu/about-edpb/board/members_en. If you need further assistance regarding your rights, please contact us using the contact information provided below and we will consider your request in accordance with applicable law.

INTERNATIONAL DATA TRANSFERS

Because Echo360 does business in many countries, Personal Information or Personal Data, as applicable, collected by Echo360 in one country may be transferred to, stored, or processed in another country, the data protection, privacy and other laws of which might not be as protective or comprehensive as those in your country. Personal Information or Personal Data, as applicable, gathered in one country may be subject to access by and disclosure to law enforcement agencies of jurisdictions other than the country where the Personal Information or Personal Data was first collected. Echo360 also may share Personal Information or Personal Data, as applicable, with organizations and entities that perform services on its behalf, and these organizations and entities may be located in countries other than the country in which the Personal Information or Personal Data was first collected.

Echo360 will endeavor to obtain appropriate and reasonably enforceable assurances from third parties, including its subsidiaries and affiliates, to which it discloses or transfers Personal Information or Personal Data that these third parties will safeguard Personal Information or Personal Data, as applicable, in a manner consistent with this Policy. When Echo360 becomes aware that a third party is using or disclosing Personal Information or Personal Data in a manner contrary to this Policy, Echo360 will endeavor to take reasonable steps to prevent or stop such use or disclosure. To the extent applicable law requires an individual’s consent before disclosing Personal Information or Personal Data to third parties, Echo360 will endeavor to obtain the individual’s consent prior to such transfer. There may be circumstances where Echo360 is required to transfer Personal Information or Personal Data without obtaining prior consent, including (i) where required by a court order; (ii) where Echo360 believes, upon reasonable grounds, that it is necessary to protect the rights, privacy, or safety or property of a person or group of persons; (iii) where it is necessary to establish or collect monies owing to Echo360 or to complete a transaction with a third party; (iv) where it is necessary to permit Echo360 to pursue available remedies or limit any damages we may sustain; or (v) where the information is public. When Echo360 is obliged or permitted to disclose Personal Information or Personal Data, Echo360 will endeavor not to disclose more than is required.

The Personal Information or Personal Data transferred within or outside Echo360 may also be processed in a country outside the EU and the EEA. We rely on recognized legal bases to lawfully conduct cross-border/international transfers of such information outside of the EU and EEA, such as your express informed consent to do so (as noted above), when transfer is necessary for us to deliver services pursuant to an agreement between us and you, for the conclusion or performance of a contract concluded in the interest of the Data Subject between the controller and another natural or legal person, or when the transfer is subject to safeguards that assure the protection of your Personal Information or Personal Data, as applicable, such as the European Commission’s approved standard contractual clauses. To that end, if your Personal Information or Personal Data is transferred outside the EEA, we will enter into EU standard contractual clauses approved by the European Commission prior to such transfer to ensure the required level of protection for the transferred Personal Information. You may request additional information in this respect and obtain a copy of the relevant safeguard we have put in place by exercising your rights as set out int this Policy.

LINKS TO OTHER SITES

This Policy only applies to the Site, and it does not apply to any third-party websites or applications.

The Site may contain links to, or media and other content from, third-party websites. These links are to external websites and third parties that have their own privacy policies. If you follow any links that direct you away from the Site, including links to social media sites or to other websites, this Policy will not apply to your activity on the other sites you visit. Because of the dynamic media capabilities of the Site, it may not be clear to you which links are to the Site and which are to external, third party websites. If you click on an embedded third-party link, you will be redirected away from the Site to the external third-party website. You can check the URL to confirm that you have left this Site.

We cannot not (i) guarantee the adequacy of the privacy and security practices employed by or the content and media provided by any third parties or their websites, (ii) control the privacy policies or the privacy practices of any third parties regarding their independent collection or use or your personal information, or (iii) endorse any third party information, products, services or websites that may be reached through embedded links on this Site.

We rely on recognized legal bases to lawfully conduct cross-border/international transfers of personal information outside of the EU and EEA, such as your express informed consent to do so (as noted above), when transfer is necessary for us to deliver services pursuant to an agreement between us and you, for the conclusion or performance of a contract concluded in the interest of the data subject between the controller and another natural or legal person, or when the transfer is subject to safeguards that assure the protection of your personal information, such as the European Commission’s approved standard contractual clauses.

Any Personal Information provided by you or automatically collected from you by a third party will be governed by that party’s privacy policy and terms of use. If you are unsure whether a website is controlled, affiliated, or managed by us, you should review the privacy policy and practices applicable to each linked website.

CHILDREN UNDER 18

The Children’s Online Privacy Protection Act (“COPPA”), as well as other data privacy regulations, restrict the collection, use, or disclosure of personal information from and about children on the Internet. The Site is restricted to the use of adults over the age of majority in their place of residence. No portion of the Site is directed to children under the age of 18, and no one under the age of 18 may access, browse, or use the Site or provide any information to or on the Site. Consequently, we do not knowingly collect Personal Information from any person under the age of 18. If we learn that we have collected Personal Information from a child under age 18 without a parent’s or legal guardian’s consent, we will take steps to stop collecting that information and delete that information as quickly as possible. If you are a parent or guardian of a child under 18 years of age and you believe your child has provided us with Personal Information, please contact us at compliance@Echo360.com.

For more information about COPPA, please visit the Federal Trade Commission’s website at: https://www.ftc.gov/enforcement/rules/rulemaking-regulatory-reform-proceedings/childrens-online-privacy-protection-rule.

UPDATES AND CHANGES TO THIS POLICY

We reserve the right to add to, change, update, or modify this Policy at any time to reflect any changes to how we treat your information or in response to changes in law. In the event we make changes to this Policy, such policy will be re-posted on this page, with the date such modifications were made indicated on the top of the page. If we make material changes to how we treat your information, we may contact you to inform you about the revisions with a link to the revised Policy or notify you through a notice on the homepage of the Site for a reasonable period of time. All changes are effective on the date listed at the top of this page and will apply to all information that we have about you.

You are expected to, and you acknowledge and agree that it is your responsibility to, carefully review this Policy prior to using the Site, and from time to time, so that you are aware of any changes. Your continued use of the Site or our services after the “Last Updated” date indicates your acceptance of the changes and your continued consent to our processing of your Personal Information according to the terms of the then-current Policy. If at any point you do not agree to any portion of this Policy, then you should immediately stop using the Site and the services. Because this Policy contains legal obligations, we encourage you to review this Policy carefully.

CONTACT US

For more information, or if you have any questions concerning this Policy or our information collection, storage and disclosure practices, wish to exercise your rights, or wish to lodge a complaint with us, you may contact us using the information below. Please note, if your communication is sensitive, you may wish to contact us by postal mail or telephone.

In Writing: Echo360 Tech Intermediate, Inc., d/b/a Echo360

Attn: Privacy Officer/Customer Information

6000 Mahoning Ave, Suite 254

Youngstown, OH 44503, United States of America

By Email: privacy@echo360.com

When you contact us, please describe in as much detail as possible the nature of your inquiry. We will investigate your inquiry promptly.

In the event you feel we have not adequately resolved your complaint, we have other recourse mechanisms available to you. If you are a European resident and have a complaint regarding this Policy, please note that the under the GDPR you have the right to contact your local data protection supervisory authority. In other jurisdictions, please refer to your local Data Protection Legislation for other appropriate recourse mechanisms that may be available to you should you have any unresolved complaints regarding this Policy.

The GDPR requires us to appoint a “Data Protection Officer”, this is a person who is responsible for overseeing and advising us in relation to our compliance with the GDPR (including compliance with the practices described in this Privacy Policy). If you want to contact our Data Protection Officer directly, you can email: dpo@echo360.com.

COMMITMENT TO THE UNITED NATIONS GLOBAL COMPACT

Echo360 has committed to the United Nations Global Compact and seeks to embrace, support and enact, within our sphere of influence, a set of core values in the areas of human rights, labour standards, the environment and anti-corruption. The principles are as follows:

Human Rights

Principle 1: Businesses should support and respect the protection of internationally proclaimed human rights; and

Principle 2: make sure that they are not complicit in human rights abuses.

Labour

Principle 3: Businesses should uphold the freedom of association and the effective recognition of the right to collective bargaining;

Principle 4: the elimination of all forms of forced and compulsory labour;

Principle 5: the effective abolition of child labour; and

Principle 6: the elimination of discrimination in respect of employment and occupation.

Environment

Principle 7: Businesses should support a precautionary approach to environmental challenges;

Principle 8: undertake initiatives to promote greater environmental responsibility; and

Principle 9: encourage the development and diffusion of environmentally friendly technologies.

Anti-Corruption

Principle 10: Businesses should work against corruption in all its forms, including extortion and bribery.

EQUAL EMPLOYMENT OPPORTUNITY/NON-DISCRIMINATION POLICY

Echo360 is an equal opportunity employer and will provide equality in employment for all people employed or seeking employment. Every person will be given a fair and equitable chance to compete for appointment, promotion or transfer, and to pursue their career as effectively as others. Employment decisions relating to appointment, promotion and career development will be determined according to individual merit and competence.

We provide equal employment opportunity to all individuals, without consideration of any status or category protected by applicable law. Protected categories include, for example, race, color, hair texture or style, religion, national origin or ancestry, citizenship, ethnicity, disability, pregnancy (including childbirth and conditions related to pregnancy), sex, gender, sexual orientation, gender identity or expression, age, military/veteran status, or genetic information (collectively, these are called “Protected Categories” or referred to as a “Protected Category”).

The company prohibits discrimination and harassment against any member of a Protected Category. The company also prohibits retaliation for raising good-faith concerns related to the company’s commitment to an equal employment opportunity workplace. This policy applies to all terms and conditions of employment, including recruitment, hiring, classification, compensation, promotion, transfer, leaves of absence, and termination.

If you learn of, observe, or have reason to be concerned about conduct in violation of this policy, please follow the procedures in the Reporting Procedures Policy below.

DISCRIMINATION, HARASSMENT, AND RETALIATION PREVENTION

Echo360 is committed to providing a workplace that is free of verbal, physical and visual forms of harassment so that everyone can work in a productive, respectful and professional environment. We prohibit all forms of discrimination, harassment, and retaliation, as defined below. The company expects all relationships between employees will be business-like and free of bias, prejudice, and harassment. These expectations apply in the workplace and in any work-related settings. This policy applies to in-person conduct, email, text message, social media, and other communications. Please know that conduct may violate this policy and our expectations regarding workplace behavior even if it is not considered unlawful.

Discrimination. Discrimination means treating employes differently in the terms or conditions of employment or denying a benefit because of or based on a Protected Category.
Sexual Harassment. Sexual harassment is a type of harassment that is illegal. Sexual harassment is defined as unwelcome sexual advances, requests for sexual favors, and other unwelcome verbal or physical conduct of a sexual nature when: submitting to the conduct is explicitly or implicitly made a term or condition of employment; submitting to or rejecting the conduct is used as the basis for an employment decision; or the conduct has the purpose or effect of unreasonably interfering with your work performance or creates an intimidating, hostile, or offensive working environment, even if the person making the report is not the intended target of the conduct. Sexual harassment also occurs when a person in authority tries to trade job benefits for sexual favors. This can include hiring, promotion, continued employment or any other terms, or conditions or privileges of employment. This is also called “quid pro quo” harassment.

Sexual harassment may include a range of subtle and not so subtle behaviors. Sexual harassment includes harassment based on sex, sexual orientation, gender identity, gender expression, and the status of being transgender or gender non-conforming. It can occur between males and females, persons of the same sex, and involve individuals who are transgender or gender non-conforming. An act may be sexual harassment regardless of the sexual desire, sexual orientation, or intent of the harasser.

Depending on the circumstances, these behaviors may include unwanted sexual advances or requests for sexual favors; sexual jokes and innuendos; verbal abuse of a sexual nature; commentary about an individual’s body, sexual capability or sexual deficiencies; staring, whistling or touching; obscene comments or gestures; display in the workplace of sexually suggestive objects or pictures, including texting (a/k/a sexting) other such sexually suggestive objects or pictures via the company or personal cell phone or computer; and other physical, verbal or visual conduct of a sexual nature.

Protected Categories: Protected categories include, for example, race; color; religion; creed; national origin; ancestry; citizenship; age; sex (including pregnancy, childbirth or related medical conditions and transgender status); gender (including gender identity and gender expression); sexual orientation; familial/marital status; reproductive health decision-making; genetic information (including predisposing genetic characteristics); disability; medical condition; military/veteran status; prior arrest/conviction record; or status as a victim of domestic violence, sexual assault, or stalking; or any characteristic protected by federal law or the state or local laws in your work location (“Protected Categories”).

Harassment. This policy also applies to and prohibits harassment which is unwelcome verbal, non-verbal, or physical conduct that degrades or shows hostility or aversion toward an individual because of their Protected Category and creates an intimidating, hostile, or offensive work environment or unreasonably interferes with an individual’s work performance. Examples of this type of prohibited harassment include, for example: use of racial or religious epithets, slurs, or physical gestures; mocking, ridiculing, or mimicking someone’s culture, accent, appearance, or customs; and/or making jokes, pranks, or behaving in a threatening, intimidating, or hostile way because of someone’s protected status.

Retaliation. Retaliation is any type of action that adversely affects the terms of employment or the working environment because the individual made a complaint pursuant to the company’s policies against discrimination, harassment, or retaliation; encouraged someone to make a report or complaint; participated in the company investigation or legal/administrative proceeding under this policy; or opposed practices or conduct prohibited by the company’s policies prohibiting discrimination and harassment.

REPORTING EEO, DISCRIMINATION, HARASSMENT, AND RETALIATION CONCERNS

If you see, witness, or experience a violation of the company’s expectations surrounding EEO, non-discrimination, harassment, and/or retaliation promptly follow the reporting procedures below:

If possible, document in writing the date, time, place, witnesses, what was said or done, and the surrounding circumstances.
If you are comfortable doing so, communicate your objections to the conduct and promptly tell the person engaging in the conduct it is unwelcome and offensive. In many cases, if an employee makes their feelings known to the offending persons, tells them the conduct is not appropriate, and asks them to stop, this may take care of the situation.
Promptly report any offending behavior, whether such behavior is directed towards them personally or to other employees at Echo360 to any member of the Human Resources staff. You may also escalate concerns to the CEO.
You may provide your name or remain anonymous. If you wish to remain anonymous, we partner with EthicsPoint, and you may submit an anonymous message through contacting 855-233-3139. Anonymous complaints, however, are often more difficult to investigate. With that in mind, we strongly recommend that anyone who makes an anonymous complaint provide as much specific information as possible.
If you are a member of company management and you learn about conduct that is or may be in violation of this policy, whether informally, through a formal complaint, or otherwise, you must immediately report it to Human Resources.

If you see, witness, or experience a violation of another company policy, we encourage you to share your concerns by reporting right away – even if you are not certain a violation occurred. When you report concerns, you help us handle issues properly, fix problems before they occur and remedy situations that have already happened. You also help build trust with each other and with our customers, our suppliers and other business partners. To report concerns, please reach out in the following order: your manager; another manager at Echo360; Human Resources; the CEO.

When reporting a concern, we will do all we can to protect your identity consistent with conducting a thorough investigation. We take every report seriously and will investigate it thoroughly and as confidentially as possible. We expect everyone involved to cooperate fully and honestly.

The company encourages prompt reporting of complaints or concerns so it can take rapid and constructive action. Early reporting and intervention have proven to be the most effective method of resolving actual or perceived incidents of harassment, discrimination, and retaliation. We ask that you report your violations of this policy as described above, because we believe that it is the most efficient way to address issues that may arise. We recognize that employees may have other means to resolve workplace issues, and this policy is not intended to prevent employees from utilizing other avenues that may be available to them under state or federal law.

The company will promptly and thoroughly investigate all claims of harassment, discrimination, or retaliation. Complaints will be handled with sensitivity, discretion and confidentiality to the extent allowed by the circumstances and the law. Generally, this means that allegations are shared with those who have a need to know so that the company can conduct an effective investigation.

The complaining employee is usually requested to provide as many details as possible, such as the dates(s), location(s), names(s) of witnesses, or information about the alleged harasser(s). Persons with relevant information are interviewed as needed. During the investigation, steps may be taken, when appropriate, to minimize contact between the involved employees, like schedule changes, temporary transfers or investigatory leave. The company will evaluate the information gathered; reach reasonable conclusions based on the evidence collected; and take appropriate remedial, corrective, and/or disciplinary action as necessary. Such action may include, by way of example only, discipline, reassignments, changes in reporting relationships, training, suspension, or termination of employment.

No action will be taken against any employee who in good faith files a complaint of harassment, discrimination, or retaliation or assists in the investigation of such a complaint. Employees who believe they have been retaliated against for having reported harassment or participated in an investigation must promptly notify any member of the Human Resources staff so such concerns can be investigated.

GENDER EQUALITY POLICY

Within the principle of providing equal employment opportunities for all qualified employees and applicants, the Company is committed to promoting a workplace culture that is inclusive, supportive, and respectful of all employees, regardless of gender. Our commitment to gender equality is manifest in the following areas:

1. Non-discrimination

We do not tolerate discrimination based on gender, gender identity, gender expression, or any other protected characteristic. We expect all employees to treat each other with respect and dignity, and to avoid any behavior or language that could be considered discriminatory.

2. Equal Opportunity

We provide equal employment opportunities to all employees, including opportunities for promotion, training, and development. We do not discriminate based on gender, and we are committed to creating a workplace where everyone has the opportunity to succeed.

3. Pay Equity

We are committed to paying all employees fairly and equitably, regardless of gender. We regularly review our pay practices to identify and address any disparities, and we strive to provide competitive compensation packages to all employees.

4. Harassment and Bullying

We do not tolerate any form of harassment or bullying, including sexual harassment, in the workplace. We take all complaints of harassment or bullying seriously and investigate them thoroughly. We provide support and resources to employees who experience harassment or bullying, and we take appropriate disciplinary action against anyone found to have engaged in such behavior.

5. Flexible Work Arrangements

We offer flexible work arrangements to help employees balance their work and personal responsibilities. We understand that everyone’s needs are different, and we strive to accommodate individual preferences as much as possible.

6. Support for Caregivers

We recognize the challenges that caregivers face and are committed to supporting employees who have caregiving responsibilities. We offer a range of support services, such as flexible work arrangements, access to child care or elder care resources, and time off for caregiving responsibilities.

TRANSGENDER POLICY

Echo360 does not discriminate on the basis of sex, sexual orientation, gender identity, or gender expression. This policy is designed to create a safe and productive workplace environment for all employees.

This policy sets forth guidelines to address the needs of transgender and gender non-conforming employees and clarifies how the law should be implemented in situations where questions may arise about how to protect the legal rights or safety of such employees. This policy does not anticipate every situation that might occur with respect to transgender or gender non-conforming employees, and the needs of each transgender or gender non-conforming employee must be assessed on a case-by-case basis. In all cases, Echo360 strives to secure a safe and non-discriminatory work environment for all employees.

The definitions provided here are not intended to label employees but rather to assist in understanding this policy and the legal obligations of employers. Employees may or may not use these terms to describe themselves.

• Gender identity: A person’s internal, deeply-felt sense of being male, female, or something else, regardless of the sex they were assigned at birth. Everyone has a gender identity.

• Gender expression: An individual’s characteristics and behaviors (such as appearance, dress, mannerisms, speech patterns, and social interactions) that may be perceived as associated with a gender.

• Transgender: An umbrella term that can be used to describe people whose gender identity and/or expression is different from their sex assigned at birth.

A person whose sex assigned at birth was female but who identifies as male is a transgender man (also known as female-to male transgender person, or FTM).
A person whose sex assigned at birth was male but who identifies as female is a transgender woman (also known as male-to-female transgender person, or MTF).
Some people described by this definition don’t consider themselves transgender – they may use other words, or may identify simply as a man or woman. A person does not need to identify as transgender in order for an employer’s nondiscrimination policies to apply to them.

Gender non-conforming: This term describes people who have, or are perceived to have, gender characteristics and/or behaviors that do not conform to traditional or societal expectations. Keep in mind that these expectations can vary across cultures and have changed over time.

Transition: The process of changing one’s gender from the sex assigned at birth to one’s gender identity. There are many different ways to transition. For some people, it is a complex process that takes place over a long period of time, while for others it is a one- or two-step process that happens more quickly. Transition may include “coming out” (telling family, friends, and coworkers); changing the name and/or sex on legal documents; and, for many transgender people, accessing medical treatment such as hormones and surgery.

Sexual orientation: A person’s physical or emotional attraction to people of the same and/or other gender. Straight, gay, and bisexual are some ways to describe sexual orientation. It is important to note that sexual orientation is distinct from gender identity and expression. Transgender people can be gay, lesbian, bisexual, or straight, just like non-transgender people.

LGBT: A common abbreviation that refers to the lesbian, gay, bisexual, and transgender community.

Privacy: Transgender employees have the right to discuss their gender identity or expression openly, or to keep that information private. A transgender employee may decide when, with whom, and how much to share their private information, and Echo360 will strive to handle communications with regard to changes to an employee’s gender identity or expression with sensitivity and input from the employee.

Official Records: Echo360 will change an employee’s official record to reflect a change in preferred name or gender identity upon request from the employee. Certain types of records, like those relating to payroll and retirement accounts, may require a legal name change before the person’s name can be changed. Most records, however, can be changed to reflect a person’s preferred name without proof of a legal name change. If a new or transitioning employee has questions about company records or ID documents, the employee should contact Human Resources.

Names/Pronouns: An employee has the right to be addressed by the name and pronouns that correspond to the employee’s gender identity. A court-ordered name or gender change is not required. The intentional or persistent refusal to respect an employee’s gender identity (for example, intentionally referring to the employee by a name or pronoun that does not correspond to the employee’s gender identity or preferred name) can constitute harassment and is a violation of this policy. If you are unsure what pronoun a transitioning coworker might prefer, you can politely ask your coworker how they would like to be addressed.

ANTI-CORRUPTION POLICY

The Company is committed to conducting our business with integrity and in compliance with all applicable laws and regulations. Corruption in any form is strictly prohibited and will not be tolerated. We have a responsibility to act with honesty and transparency in all of our business dealings.

The Company’s Anti-Corruption Policy includes but is not limited to:

• Bribery, including offering or accepting gifts, money, or other benefits in exchange for business or personal favors.

• Kickbacks, including giving or receiving money or other benefits in exchange for business referrals or contracts.

• Fraud, including misrepresenting company information or falsifying records.

• Any other corrupt or unethical behavior that violates the law or company policies.

All employees are required to comply with this policy and any applicable laws and regulations. Employees who violate this policy may be subject to disciplinary action, up to and including termination of employment. The company reserves the right to take legal action against any employee or third party involved in corruption or unethical behavior.

FREEDOM OF EXPRESSION POLICY

The Company recognizes and respects our employees’ right to express their opinions and views freely, both inside and outside of the workplace. We believe that open communication and the exchange of ideas are essential to creating a productive, creative, and supportive workplace culture, and we foster employee freedom of expression through the following:

Open Communication

We encourage open communication and the exchange of ideas among all employees, and we strive to create an environment where everyone feels comfortable expressing their opinions and views. We believe that diverse perspectives lead to better decision-making and problem-solving, and we value the contributions of all employees.

Respectful Communication

While we encourage open communication, we also expect all employees to communicate in a respectful and professional manner. We do not tolerate any form of harassment, discrimination, or bullying in the workplace, including any communication that could be considered threatening or offensive.

Confidentiality

We recognize that certain information must be kept confidential, such as trade secrets, proprietary information, and personal information. We expect all employees to respect the confidentiality of such information and to avoid disclosing it to unauthorized parties.

Social Media

We recognize that social media has become an important tool for communication and expression, both inside and outside of the workplace. We expect all employees to use social media in a responsible and professional manner, and to avoid any communication that could be considered defamatory, harassing, discriminatory, or offensive.

ECHO360 MODERN SLAVERY POLICY

Modern slavery is a crime and a violation of fundamental human rights; it includes slavery, servitude, forced labour, forced marriage, child labour violations, debt bondage, deceptive recruiting for labour or services, and human trafficking.

Echo360 is committed to acting ethically and with integrity in all our business dealings and relationships, and to implementing and enforcing systems and controls to ensure modern slavery is not present or permitted in our own business practices or across any of our controllable supply chains. Our practices and policies in this regard are guided by the United Kingdom’s Modern Slavery Act 2015 and the Australian Modern Slavery Act 2018.

This policy applies to all persons working for Echo360 or on our behalf in any capacity, including employees, directors, officers, volunteers, interns, agents, contractors, consultants, third-party representatives, and business partners. The policy is applied to and enforced for all Echo360 business activities in all Echo360 markets.

Responsibility for the policy

Echo360 has responsibility for ensuring this policy complies with our legal and ethical obligations, and that those under our direct or indirect management comply with it.

Compliance with the policy

All persons working for Echo360 must comply with this policy. The prevention, detection, and reporting of modern slavery in any part of our business or supply chains is the responsibility of those working for us or under our control.

All persons are required to avoid any activity that might lead to or suggest a breach of this policy and must notify their line manager OR a company Director as soon as soon as they believe or suspect that a conflict with this policy has occurred or may occur in the future.

If any person working for Echo360 is unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of Echo360’s supply chains constitute any of the various forms of modern slavery, they must raise it with Human Resources via email to HR@echo360.com.

Communication & awareness of this policy

Internal employees will be trained on and indicate acceptance of Echo360’s policy at time of hire, with updates provided using established methods of communication between Echo360 management and employees.

External suppliers, contractors, consultants, and partners will be advised and encouraged to accept Echo360’s policy at the outset of our business relationship with them, and reinforced as appropriate thereafter.

Breaches of this policy

Any employee or external entity who breaches Echo360’s policy will face commensurate disciplinary action, which could result in dismissal or termination.

REASONABLE ACCOMMODATIONS FOR DISABILITIES

The company is committed to providing reasonable accommodations to qualified individuals with disabilities. The goal of reasonable accommodations is to enable people with disabilities to overcome work-related barriers and to fostering an inclusive workplace. An individual may be considered disabled if they have an impairment that substantially limits one or more of their major life activities, a record or history of such an impairment, or is perceived as having such an impairment. The definition of disability also may include pregnant employees impacted by medical conditions related to pregnancy or childbirth.

If you believe you need an accommodation because of your disability, you are responsible for requesting a reasonable accommodation from the Human Resources Department. You may make the request orally or in writing. The company encourages employees to make their request in writing on a company form, available from Human Resources, and to include relevant information, such as:

• A description of the accommodation you are requesting.

• The reason you need an accommodation.

• How the accommodation will help you perform the essential functions of your job.

After receiving your oral or written request, the company will engage in an interactive dialogue with you to determine the precise limitations of your disability and explore potential reasonable accommodations that could overcome those limitations. The company encourages you to suggest specific reasonable accommodations that you believe would allow you to perform your job. Please understand, however, that the company is not required to make the specific accommodation requested by you and may provide an alternative effective accommodation, to the extent any reasonable accommodation can be made without imposing an undue hardship on the company.

The company makes determinations about reasonable accommodations on a case-by-case basis, considering various factors and based on an individualized assessment in each situation and strives to make determinations as expeditiously as possible. During the interactive process, Human Resources will partner with you, management, and healthcare provider(s) to assess if a reasonable accommodation is possible. Communication with healthcare professionals may be necessary to verify the existence of a disability or work restrictions, to identify potential reasonable accommodations, and/or to assess if an accommodation would cause undue hardship. Employees are required to cooperate with this process by providing all necessary documentation supporting the need for accommodation and to consider alternative accommodations when applicable. The company will treat medical information as confidential.

The company strictly prohibits discrimination and retaliation against qualified individuals with disabilities who, with or without reasonable accommodation, can perform the essential functions of their job and prohibits retaliation for requesting an accommodation. If you believe you were retaliated against, please follow the reporting procedures in the Reporting EEO, Discrimination, Harassment, and Retaliation Concerns policy.

RELIGIOUS ACCOMMODATIONS

The company recognizes and respects the diversity of religious beliefs, practices, and observances. When work obligations conflict with religious beliefs, the company is committed to exploring whether the company may provide an accommodation that will eliminate the conflict, while preserving your ability to fully perform the essential functions of your job.

If you need a religious accommodation, discuss your request with Human Resources. The company will not retaliate against you for requesting an accommodation under this policy. If you believe you were retaliated against promptly notify Human Resources.

ENVIRONMENTAL POLICY STATEMENT

Echo360 is committed to reducing its impact on the environment. We will strive to improve our environmental performance over time and to initiate additional projects and activities that will further reduce our impacts on the environment.

Our commitment to the environment extends to our customers, our staff, our partners, and the community in which we operate. We are committed to:

• Comply with all applicable environmental regulations;

• Prevent pollution whenever possible;

• Train all staff on our environmental program and empower them to contribute and participate;

• Communicate our environmental commitment and efforts to our customers, staff, and our community; and

• Continually improve over time by striving to measure our environmental impacts and by setting goals to reduce these impacts each year.

ENVIRONMENTAL POLICY IMPACT A: Solution Sustainability

Echo360’s solution is hosted by Amazon Web Services and Echo360 trusts AWS to minimise its impact on the environment as much as possible. AWS has publicly shared its commitment to sustainable energy with a goal to power the global AWS infrastructure with 100% renewable energy by 2025.

AWS is rapidly progressing towards meeting these goals by focusing on four complementary areas.

• First, AWS is continuously working on ways to increase the energy efficiency of its facilities and equipment, innovating the design and manufacture of its servers, storage, and networking equipment to reduce energy use and improve operational excellence as the business grows.

• Second, AWS works with industry associations, international, federal, and state governments to increase incentives and create a more favourable environment for renewable energy.

• Third, AWS works with its various power providers that supply AWS data centres around the world to increase the availability of renewables in their power supply while maintaining low prices.

• And fourth, AWS has funded many wind and solar PPAs to increase the overall amount of renewable energy available on the grids that serve AWS data centres.

These initiatives will be extended to the global AWS data centres over time.

Amazon is part of the American Council on Renewable Energy (ACORE – http://www.acore.org/) and participates in the U.S. Partnership for Renewable Energy Finance (US PREF – http://uspref.org/) to increase its work with state and federal policymakers and other stakeholders to enable more renewable energy opportunities for cloud providers.

Please visit https://aws.amazon.com/about-aws/sustainability/ for more details about AWS’s approach to sustainability.

ENVIRONMENTAL POLICY IMPACT B: Employee Energy and Resource Use

Below are the guidelines followed at the Company’s workplace settings and encouraged at employees’ remote work settings:

Energy Use

• Echo360 off lights, computers, and other equipment when not in use.

• Adjusting the thermostat to save energy during non-business hours.

• Using energy-efficient appliances and equipment where possible.

Resource Use

• Reducing paper use by printing double-sided and only when necessary.

• Using refillable water bottles and coffee cups instead of disposable ones.

• Recycling paper, plastics, and other materials.

• Using reusable bags and containers for lunch and snacks.

Personal Responsibility

• Considering the environmental impact of your actions both at work and at home.

• Encouraging colleagues to adopt sustainable practices.

• Reporting any energy or resource waste to management.