Avasant, LLC (“Avasant”) respects concerns about privacy. This Privacy Policy (“Privacy Policy”) is incorporated into and made subject to the Terms and Conditions for the web site (the “Terms”). Subject to the terms herein, Avasant, LLC and its affiliates (hereinafter “Avasant”) reserve the right to modify or amend this Privacy Policy at any time. This Privacy Policy applies to all visitors (hereinafter referred to as “You”, “Your”) to the www.avasant.com and other owned or operated websites which provide a link to this Privacy Policy (hereinafter the “Site(s)”). Capitalized terms used, but not defined in this Privacy Policy, have the meanings given to them in the Terms. This Privacy Policy describes the types of information we collect on the Site(s), including Personal Information, how we may use that information, with whom we may share it and what we do to protect it. We also tell you how you can reach us to ask us to update your preferences regarding how we communicate with you or answer any questions you may have about our privacy practices. Please note that this Privacy Policy does not address use and disclosure of your information by our business partners who may offer services through our Site(s) or link to our Site(s). These entities have their own policies describing their practices.

Data Controller

Avasant will be the controller of Personal Information you provide to Avasant. Our contact information is below. Information We Collect Avasant is a management consulting firm and offers various consulting and technical solutions for corporate and public sector customers, and does not actively sell consumer products and services to end user consumers through the Sites. However, Avasant may collect Personal Information when you request publications, sign up for events, apply for jobs, participate in surveys, or make inquiries to learn more about Avasant’s suite of management consulting services and other solutions. We may also use the information we collect to perform data analytics on visitors to our site and to communicate with potential customers who may be interested in Avasant’s suite of management consulting services. We also use the data collected on our web site to help us improve how we operate our business. The information we collect from You may include name, mailing address, email address, phone number, company information location information and to set up and maintain accounts on our site. We may also receive information about You from other sources, including third parties that help us update, expand and analyze our records and identify new customers. We may use third-party advertising companies to display ads when You visit our websites or other sites on the Internet. These companies may collect information about Your visits to this and other websites. We may also share Personal Information, subject to the user rights and options set forth herein, with these companies. We do not collect Sensitive Personal Information (as such term is understood within the meaning of the GDPR) such as information relating to health, race, ethnicity, sexual orientation and political opinions. We do not collect and store credit card data. Any updates to the types of information we collect will be provided on this Site and you will have opt-in rights as set forth herein.

Automatic Information

Like many other websites, we also collect information through cookies and other automated means. Cookies are commonly used by websites to save data on Your computer. The information we collect from cookies may include Your IP address, browser and device characteristics, referring URLs, and a record of Your interactions with our websites. We use cookies to create a more personalized shopping experience on our websites. Our web servers may log information such as your device and operating system type, browser type, domain, device ID, Internet Protocol (“IP”) address and other system settings, as well as the language your system uses and the country and time zone where your device is located. The web server logs also may record information such as the address of the web page that referred you to our Site(s) and the IP address of the device you use to connect to the Internet. To help us understand and enhance our interactions with visitors to our websites, we may permit web analytics providers to collect information on our websites using automated tools like cookies or web beacons, which are small files that allow us to understand the actions of visitors to our Site(s). We may use similar technology in email we send, which may enable the placing or accessing of cookies and also enable us to know if you received the email, if the email was opened and if you clicked on any links in the email. We will not collect more Personal Information than is reasonably necessary or relevant to enable you to fully enjoy the use of our Site(s) and associated features.

Public Forums

Our website may offer publicly accessible blogs or community forums. You should be aware that any information You provide in these areas may be read, collected, and used by others who access them.

How We Use the Information We Collect

Avasant is a management consulting firm and offers various consulting and technical solutions for corporate and public sector customers, and does not actively sell consumer products and services to end-user consumers through the Sites. We will retain Your information for as long as Your account is active or as needed to provide You services, comply with our legal obligations, resolve disputes, and enforce our agreements.

How We Share the Information We Collect

We may share Your information with third parties to perform services on our behalf such as: providing services, sending marketing communications, including marketing new products or services, conducting research and analysis, and to provide interactive functions (e.g., chat). We may be required to share personal information in response to a regulation, court order or subpoena. We may also share information when we believe it’s necessary to comply with the law or when we believe that disclosure is necessary to protect the rights of Avasant, our customers, or others; to prevent harm or loss; or in connection with an investigation of suspected or actual unlawful activity. Transfers Outside of Geographic Point of Collection. We may transfer the Personal Information we collect about you to locations in the United States or other countries that differ from the one in which the information originally was collected.Those countries may not have the same data protection laws as the country in which you initially provided the information. When we transfer your information internationally, we will protect that information as described in this Privacy Policy and in accordance with applicable law. With respect to the European Union (EU), Avasant has offices in countries which as of yet have not been deemed to meet an adequate standard of data protection. In such instances, should Avasant transfer EU sourced data to third countries, it will only do so by way of Data Transfer Agreements which incorporate standard clauses approved by the EU Commission governing the roles and responsibilities of data processors and data controllers to meet the compliance standards set forth in the GDPR.

User Choices

If you would like to update, modify, or remove your information or cancel subscription preferences, you may contact us as described in the “Contact Us” section below. On certain Site(s), you may be able to make these choices directly by logging into your account. You also may unsubscribe from any of our promotional emails by clicking on the “unsubscribe” link in any promotional email you receive from us. Changes made to your profile will be effective once saved into our systems in accordance with our standard procedures for implementing user questions regarding your Personal Information. Depending on the data protection law of your country, you may have a legal right to obtain access to Personal Information we maintain about you. In addition, if you believe the Personal Information is inaccurate, you may have the legal right to request that we correct or amend the information. To make these requests, or to object to our processing of your Personal Information or withdraw consent to such processing (rights provided by the laws of certain countries), you may contact us as described in the Contact Us section below. You may follow the directions in a marketing e-mail or direct mail or mobile communication that You receive from us to effect changes to Your use of the Web Site, or You may contact us using the contact information listed below. Opt-In (for Sensitive Personal Information) As referenced above, we do not presently collect Sensitive Personal Information. Should we decide to collect Sensitive Personal Information, we will only do so if you provide your consent. If you wish to opt-in to the collection and use of Sensitive Personal Information by us to provide services to you, which may include the transfer of such Sensitive Personal Information to third parties, then you may opt-in to such uses by checking the ‘opt-in’ box in your user preferences. If none of the available options meets your requirements, or you have other questions, please contact us directly. Opt-Out (for third party transfers) We disclose Personal Information to our third party partners as described in the Data Transfer section. If you wish to limit or restrict the disclosure of your Personal Information to third parties, you may opt-out of such third party disclosures by changing your preferences in your profile or sending us a notice via email or through this opt-out request form. If you have previously granted an ‘opt-in’ for certain collection and use practices with respect to Personal Information, you may issue a subsequent ‘opt-out’ by changing your preferences in your profile or sending us a notice via email. Our contact information is below.

How We Protect the Information We Collect

The security of your Personal Information is important to us, but despite our efforts, we cannot promise that our security program will always eliminate all possible security risks, and our liability is limited as set forth in the Terms. Company uses commercially reasonable efforts to safeguard and protect the security of all data, inclusive of any Personal Information collected by the Company from you through the Site(s). Company maintains certain administrative, technical and physical safeguards in an effort to protect the security of the Personal Information we collect on the Site(s). Personal Information and other data are stored in hosted and secured environments which utilize accepted industry standards for data security. Company uses commercially reasonable efforts to partner with third party service providers that meet accepted industry standards to support the collection, storage, hosting, processing and retention of data, inclusive of Personal Information. Notwithstanding the foregoing, Company cannot, however, ensure, warrant or guarantee that the information collected by the Company will not be accessed, disclosed, altered, or destroyed by system malfunction or circumvention of our safeguards. It is also important for you to comply with the access controls (e.g., username/password management) and other applicable provisions of the Terms to protect against unauthorized access to your account and to the devices you use to access the Site(s).

EU Residents

If you reside in the EU and you utilize our Site(s) to either buy services which are offered to EU residents, or if we collect, track and/or process or transfer Personal Information from you, or personal data which you submit to us through the Site(s), your data will be managed in accordance with this Privacy Policy, the applicable Terms, and in compliance with requirements of the General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679).

Transfers Outside the EU

If you are an EU resident and your Personal Information is collected through our Site(s), we may transfer such data to third parties for data processing and data control purposes as described in this Privacy Policy. Our commercial agreements with third party data processors or data controllers will comply with standard EU data protection contractual clauses as approved by the EU Commission (as amended). Opt-in If you are an EU resident, you have the right to opt-in to the collection, tracking and use of your personal data. We will not collect personal data from you unless you affirmatively accept our data practices as described in this privacy statement. Opt-Out/Corrections As an EU resident, you will, at any time, have the right to opt-out or withdraw consent to the collection or use of your data. If you withdraw consent, please be advised that it may inhibit or limit our ability to provide you with certain services and to perform certain functions. However, you may continue to use the Site(s) in accordance with the Terms and Privacy Policy. As an EU resident, you may also request to view and change your data preferences, security settings, and consent preferences in your account dashboard provided that you set up a user profile on our site, or by emailing utilizing the contact information below. Additionally, as an EU resident, you may also opt out or withdraw consents, ask to correct errors in collected or submitted data, request that your personal data be erased or removed by informing us utilizing the link to our contact information below. If you withdraw consent, Company will erase or remove the relevant personal data collected.

Protecting Children’s Privacy

We are committed to protecting children’s privacy on the Internet and we do not knowingly collect personal information from children under the age of 13.

Links to Other Websites

Our Site(s) may provide links to other websites for your convenience and information. Those websites may be operated by companies not affiliated with us. Linked websites may have their own privacy policies, which we strongly suggest you review if you visit any linked websites. We are not responsible for the content of any websites that are not affiliated with us, any use of those websites, or the privacy practices of those websites.

Complaints

Should you have any complaints regarding the use of Personal Information by us, you may contact us at the address below. If you are a resident of the EU, you have the right to lodge a complaint about the treatment of your Personal Information by contacting the data protection authorities in your home country.

Contact Us

If You have any questions about our Privacy Policy or Avasant’s use of your Persona Information, please contact us: Avasant, LLC 1960 E. Grand Ave., Ste. 1050, El Segundo, CA 90245 Phone: (310) 643-3030 E-mail: info@avasant.com Attn: Data Protection Officer