Privacy

1.0 OVERVIEW
Livewire is committed to protecting your privacy. The following policy describes how we collect, store, use and distribute the information of individuals for whom we render our services.

2.0 PURPOSE
The intent of this policy is to generally describe Livewire’s use and protection of your private information. Due to the nature of our services, we may revise or expand upon this policy on a per-engagement basis.

3.0 SCOPE
Our goal is to collect, use and disclose only that information reasonably required to enable us to provide the particular product or service that you have requested, to maintain our customer/ visitor lists and/or to respond to your inquiries or feedback and for other purposes further described in this Policy.

4.0 POLICY
4.1 Acceptance of Terms
By retaining us to provide you with our services, you voluntarily consent to the collection, use and disclosure of various types of information as specified in this Privacy Policy. Clients will be notified of any material amendment to this Privacy Policy by email (sent to the email address specified in your account), or by postal mail (sent to the billing address specified in your account).

4.2 Collection of Information
Three types of information may be collected: Personal Information, Non-Personal Information, and Confidential Information.

4.2.1 Personal Information
“Personal Information” means personally identifiable information, such as your name, address, telephone number, e-mail address and credit card information. At the time of collection, we will set out clearly the information that we are collecting and the purposes for which we will use it. It is always your choice whether or not to provide Personal Information. If you choose not to provide requested Personal Information, you will not be able to use certain features of the Website and/or Services and you will not be able to engage in transactions through the Website. We also may receive Personal Information from our business partners and other third parties, provided that such third parties confirm to us that their use of the Personal Information conforms to applicable privacy laws. Business contact information such as the name, title, business address or telephone number of a business or professional person or an employee of an organization is not considered Personal Information.

4.2.2 Non-Personal Information
“Non-Personal Information” is information that is collected or derived by us in the course of operating the Website and the Services. We need this information in order to operate the Website and the Services, but we do not share it with any third parties. This policy does not restrict our use of Non- Personal Information. For example, our web servers may automatically collect information of an anonymous nature that is provided through your browser or stored on a Cookie when you choose to visit the Website, such as an Internet Protocol Address (IP Address), the domain used to access the Website, and the type and version of browser or operating system being used. Aggregate information, such as demographic statistics of our users (e.g. average age or geographical allocation of our users), number of visitors, what pages users access or visit, average time spent on the Website, and information volunteered by the user, such as survey information, is also considered Non- Personal Information. “Cookies” may be used by Livewire to track content usage and traffic on the Website. Livewire uses Cookies to help us compile aggregate statistics about usage of the Website, such as how many users visit the Website, how long users spend viewing the Website, and what pages are viewed most often. This information is used to improve the content of the Website.

4.2.3 Confidential Information
“Confidential Information” refers to information that might be confidential to your organization. Livewire only has access to the Confidential Information of our clients through the course of providing the Services and does not have access to the Confidential Information of visitors to the Website. We do not use or retain any Confidential Information except where such retention and use are ancillary to providing the Services to our clients. Duly-authorized representatives from customer organizations are required to review this Policy and consent to the access required by Livewire to provide the Services prior to finalizing a Service Contract.

4.3 Use of Information
Livewire collects information mainly for the following purposes: To contact and correspond with you; To enable your use of the Services; To understand your needs and develop and recommend suitable products and services; To process transactions and payments; To facilitate and enhance your use of the Website; and To meet legal and regulatory requirements. Your Personal Information will not be used for any purpose other than the reasons stated at the time of collection without your consent. Livewire does not actively collect personally identifiable user information for the purpose of sale or marketing in a way that specifically identifies the individual. In other words: we don’t sell customer lists. The Confidential Information of our customers will not be used for any purpose other than to deliver the Services. Only that Confidential Information which is needed to deliver the Services will be accessed and used by Livewire as described in this Policy.

4.4 Disclosure of Information
Livewire feels very strongly about the confidentiality of your Personal Information and of our customers’ Confidential Information. Livewire will not share this information with any third party, except as indicated below. From time to time we may employ or partner with third parties to provide various technologies and services (e.g. hosting, database management, maintenance, etc.) to help us improve our Website and to provide our Services. These third parties may have access to Personal Information and/or Confidential Information solely for the purpose of helping us to provide our Services.

4.4.1 Important Exceptions
We may disclose your Personal Information to a third party without your consent if we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be causing injury to or interference with (either intentionally or unintentionally) our rights or property, other Website or Service users or anyone else that could be harmed by such activities. We may disclose Personal Information when we believe in good faith that such disclosure is required by and in accordance with the law. We may also disclose your Personal Information in connection with a corporate re-organization, a merger or amalgamation with another entity, or a sale of all or a substantial portion of our assets provided that the information disclosed continues to be used for the purposes permitted by this Privacy Policy by the entity acquiring the information.

4.5 Outside Parties and Sites
Through Livewire, you may be introduced to a variety of third-party vendors and websites. The privacy policies of these third parties are not under our control and may differ from ours. The use of any information that you may provide to any third party, or the use of Cookie technology by any third party, will be governed by the privacy policy of the operator of the website that you are visiting. If you have any doubts about the privacy of the information you are providing on another website, we recommend that you contact that website directly for more information and review its privacy policy.

4.6 Security
The security of your Personal Information and Confidential Information are important to us. We use commercially reasonable efforts to ensure that your Personal Information and Confidential Information are stored and maintained in a secure environment and are encrypted during transmission to Livewire using industry standard authentication and encryption technologies. We will never ask you for your password in an unsolicited phone call or in an unsolicited e-mail.

4.7 Retention
Livewire will keep your Personal Information for as long as it remains necessary for the identified purposes in Section 4.3, or for as long as defined in our relevant Data Lifecycle Policy, or as required by law, which may extend beyond the termination of our relationship with you. You acknowledge and agree that if you request that your name be removed from our databases, it may not be possible to completely delete all your Personal Information due to technological and legal constraints. The Confidential Information of our customers is not retained by Livewire except where retention is necessary to deliver the Services. If an organization ceases to be a Livewire customer, certain Confidential Information such as that contained within Customer Relationship Management tools, correspondence, and reports, will be retained as long as necessary to complete final reporting and billing cycles, as well as to complete and comply with year-end financial reporting requirements.

4.8 Amendment of this Policy
If we find it necessary or desirable to change our Privacy Policy in the future, we will post an appropriate notice on the Website. Any change to this Privacy Policy will become effective 30 days following the date the change is posted and will apply to information collected from the date of the posting of the revised Privacy Policy and to existing information held by Livewire. The date on which the latest update was made is indicated at the top of this document. We recommend that you print a copy of this Privacy Policy for your reference and revisit this Policy from time to time to ensure you are aware of any changes. You will be notified of any material changes to this policy as described in section 4.1 above.

4.9 Access and Accuracy
You have the right to access your Personal Information to verify the Personal Information that we have collected in respect of you. Upon receipt of your written request, we will provide you with a copy of your information. We will make every reasonable effort to keep your Personal Information accurate and up-to-date, and we will enable you to revise the Personal Information as appropriate. Having accurate Personal Information about you e nables us to give you the best possible service. You can help us ensure the accuracy of the data we hold about you by keeping us informed of any changes such as a change of address or telephone number. If you would like to access your information, or if you find any errors in our information about you, or if you have any questions, comments, or suggestions about this Privacy Policy or Livewire’s privacy practices that were not answered here, please contact us by telephone or email using the contact information currently available on our website: https://www.livewireinc.com/contact/ Livewire will endeavor to deal with all such requests for access and modifications in a timely manner.

4.10 Additional Privacy Protections for Children
Livewire joins the industry in recognizing that children, including young teens, may not be able to make informed choices about Personal Information requested online. Accordingly, Livewire does not target children or teenagers (younger than eighteen years of age) for collection of information online. Livewire does not solicit or collect Personal Information targeted at children and teenagers under eighteen. In addition, Livewire will encourage children to seek the consent of their parents before providing any information about themselves or their households to anyone on the Internet.

5.0 ENFORCEMENTS
This policy will be enforced by the VP, Digital and/or Leadership Team. Violations may result in disciplinary action, which may include suspension, restriction of access, or more severe penalties up to and including termination of employment. Where illegal activities or theft of company property (physical or intellectual) are suspected, Livewire may report such activities to the applicable authorities.

6.0 DEFINITIONS
Information – All files and records, whether digital or printed, including communications, attachments, and records submitted via our website, collected in the course of providing the Services, and entered into line-of-business applications.