Privacy Policy Actian Corporation Respects Your Privacy Actian Corporation (“Actian” “we” or “us”) and its subsidiaries respect your privacy and are committed to protecting it. Actian provides this Privacy Statement to inform you of our Privacy Policy and practices and of the choices you can make about the way your information is collected online and how that information is used. We’ve structured our websites so that, in general, you can visit Actian on the Web without identifying yourself or revealing any personal information. We make this notice readily available at the bottom of every Actian Web page. EU-U.S. Privacy Shield Actian Corporation participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework. We are committed to subjecting all personal data received from European Union (EU) member countries, respectively, in reliance on each Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Frameworks, and to view our certification, visit the U.S. Department of Commerce’s Privacy Shield List. [https://www.privacyshield.gov] Actian Corporation is responsible for the processing of personal data it receives, under each Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. Actian Corporation complies with the Privacy Shield Principles for all onward transfers of personal data from the EU, including the onward transfer liability provisions. With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, Actian Corporation is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request. Under certain conditions, more fully described on the Privacy Shield website [https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint], you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted Information Related to Data Collected for our Clients Actian collects some information under the direction of its Clients, and with respect to such information has no direct relationship with the individuals whose personal data it processes. Our use of information collected for our Clients through our service shall be limited to the purpose of providing the service for which the Client has engaged Actian. If you are a customer of one of our Clients and would no longer like to be contacted by one of our Clients that uses our service, please contact the Client that you interact with directly. We may transfer personal information to companies that help us provide our service. Transfers to subsequent third parties are covered by the service agreements with our Clients. Access and Retention of Data Controlled by our Clients Actian acknowledges that you have the right to access your personal information. With respect to information collected under direction of its Clients, Actian has no direct relationship with the individuals whose personal data it processes. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct his query to the Actian’s Client (the data controller). If the Client requests Actian to remove the data, we will respond to their request. We will retain personal data we process on behalf of our Clients for as long as needed to provide services to our Client. Actian will retain and use this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. Sites covered by this Privacy Statement Types of information we collect Use of Tracking Technologies Response to Do Not Track signals Children’s privacy How we use your information Who we share your information with Your choices Access to and accuracy of your information Keeping your information secure Changes to this Statement Contacting us 1. Sites covered by this Privacy Statement This Privacy Statement applies to Actian-owned websites and domains, and our wholly owned subsidiaries (“Actian Corporation websites”) including www.actian.com and www.pervasive.com. Links to non-Actian websites The Actian websites may provide links to third-party websites for your convenience and information. If you access those links, you will leave the Actian website. Actian does not control those sites or their privacy practices, which may differ from Actian’s. We do not endorse nor make any representations about third-party websites. The personal data you choose to give to unrelated third parties is not covered by the Actian Privacy Statement. We encourage you to review the privacy policy of any company before submitting your personal information. Some third-party companies may choose to share their personal data with Actian; that sharing is governed by that third-party company’s privacy policy. Social Media Widgets Our Web site includes Social Media Features, such as the Facebook button and Widgets, such as the Share this button or interactive mini-programs that run on our site. These Features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the Feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on our Site. Your interactions with these Features are governed by the privacy policy of the company providing it. Testimonial We display personal testimonials of satisfied customers on our site in addition to other endorsements. With your consent we may post your personal testimonial along with your name. If you wish to update or delete your personal testimonial, you can contact us at privacy@actian.com. 2. Types of information we collect This Privacy Statement covers personal information, non-personal data collection and aggregate reporting. Personal information Personal information is information that is associated with your name or personal identity. Actian uses personal information to understand better your needs and interests and to provide you with better service. Once you choose to provide us with personal information, you can be assured that we take seriously the trust you place in us. In some Actian websites, you can order products or services, download software, contact the service desk, enroll for support, become a partner, apply for instant credit, request information, subscribe to marketing or support materials, register yourself or your Actian products, apply for a job at Actian, contact us with questions or comments, or provide us with feedback. The types of personal information you provide to us on these pages may include name, address, phone number, e-mail address, user IDs and passwords, billing and transaction information, credit card information, contact preferences, educational and employment background, and job interest data. Additionally, we may collect personally identifiable information about you that you provide to us when you contact us or that you voluntarily post in blogs, chat rooms, forums, message boards, and/or news groups available from our websites and other users will be able to see any information that you post to such forums. To request removal of your personal information from our blog or community forum, contact us at privacy@actian.com. We may use your personally identifiable information to deliver and provide certain services, products, software or information you have requested, provide you with notices regarding services, products or information that you have purchased or that you may want to purchase in the future, verify your authority to enter our websites, contact you or your employer for marketing purposes, and improve the content and general administration of our websites and our services. If you give us personal information about somebody else, such as a spouse, friend or work colleague, you represent and warrant that you have their permission to do so. To personalize our websites, services or communications and improve our products and services, we may also ask you to provide us with information regarding your personal or professional interests, demographics, and experiences with our products or services. Providing this additional information is optional. 3. Use of Tracking Technologies Technologies such as: cookies, beacons, tags and scripts are used by Actian and our partners (such as marketing partners), affiliates, analytics or service providers (such as online customer support providers). These technologies are used in analyzing trends, administering the site, tracking users’ movements around the site and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis. We do link the information we store in cookies to personal information you submit while on our site. We use cookies for our shopping cart, to remember users’ settings (e.g. language preference), for authentication and to analyze traffic patterns on our site. This can enable us over time to provide a better experience on our site by improving content or personalization and making our site easier to use. We also use cookies to facilitate shopping, personalization and registration services. For example, cookies can keep track of what you have selected to purchase as you continue to shop and allow you to enter your password only once on Web pages where a login is required. Users can control the use of cookies at the individual browser level. If you reject cookies, you may still use our site, but your ability to use some features or areas of our site may be limited. Log Files – As is true of most web sites, we gather certain information automatically and store it in log files. This information may include Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. We may combine this automatically collected log information with other information we collect about you. We do this to improve services we offer you, to improve marketing, analytics, and site functionality. We partner with a third party to either display advertising on our Web site or to manage our advertising on other sites. Our third party partner may use technologies such as cookies to gather information about your activities on this site and other sites in order to provide you advertising based upon your browsing activities and interests. If you wish to not have this information used for the purpose of serving you interest-based ads, you may opt-out by clicking here (or if located in the European Union click here). Please note this does not opt you out of being served ads. You will continue to receive generic ads. We use Local Storage Objects (LSOs) such as HTML5 or Flash to store content information and preferences. Third parties with whom we partner to provide certain features on our site or to display advertising based upon your Web browsing activity use LSOs such as HTML 5 to collect and store information. Various browsers may offer their own management tools for removing HTML5 LSOs. To manage Flash LSOs please click here: https://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html 4. Response to Do Not Track signals We do not respond to Do Not Track signals when sent by the web browser. 5. Children’s privacy Actian is committed to protecting the privacy needs of children. Actian does not knowingly collect information from children under the age of 13 and Actian does not target its websites to children under 13. 6. How we use your information Actian uses your personal information to provide you with services and to help us better understand your needs and interests. Specifically, we use your information to help you complete a transaction or order, to communicate with you, to provide service and support, to improve the capabilities of our products and services, to update you on services and benefits, to personalize promotional offers and to personalize some Actian websites. Actian may transfer personal information to companies that help us provide and sell our products and services. Occasionally we may also use your information to contact you for market research regarding Actian products or services. We will give you the opportunity to choose your privacy preferences regarding such communications (see section 8, “Your choices”). Credit card information is used only for payment processing and fraud prevention. Credit card information and sensitive personal data are not used for any other purpose by our financial services providers or Actian. Personal data collected online may also be combined with information you provide Actian through other sources such as product registration, call centers or public events such as trade shows or seminars. Personal data given to Actian may be transferred across state and country borders for the purposes of data consolidation, storage and simplified customer information management. Non-personal data is aggregated for reporting about Actian website usability, performance and effectiveness. It is used to improve the customer experience, usability and site content. Based upon the personal information you provide us, we will communicate with you to provide the services you request, and we will use the information to manage your account. We will communicate with you by email or telephone in accordance with your wishes. 7. Who we share your information with Actian shares customer information across Actian-owned business entities and companies working on our behalf, but only as described above in “How we use your information.” For instance, if you download an evaluation product, we may share your information with an authorized Actian reseller in your territory. We will share your personal information with third parties only in the ways that are described in this privacy policy. We do not sell your personal information to third parties. If you do not want us to share your personal information with these companies, you may contact us at: privacy@actian.com. Actian contracts with third-party service providers and suppliers such as credit card processing companies, marketing campaign management companies, SaaS software providers, email service providers or third party customer service companies to deliver complete products, services and customer solutions described in “How we use your information.” Suppliers and service providers are required to keep confidential the information received on behalf of Actian and may not use it for any purpose other than to carry out the services they are performing for Actian. These service providers may change or we may contract with additional service providers to better accommodate our customers. In certain situations, Actian may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. Actian will not share personal information with any other third parties without your permission, unless required by law enforcement action, subpoena, or local law, or in our sole discretion, to law enforcement agencies to assist in any investigation, when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud or unlawful conduct or respond to a government request. Certain Actian services are linked with those from unrelated third-party companies, some of which offer you the option to share with both Actian and the third party personal data you provide. Examples include the ability to register software products from multiple vendors from a single Actian Web page, to request communications from Actian marketing or solution partners, or to enable order completion through a reseller. Actian or its related entities could merge with or be acquired by another business entity or some or all of their respective assets could be acquired, including some or all of your personal information. You will be notified via email and/or a prominent notice on our Web site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information. 8. Your choices Actian will deliver a variety of information that complements our products and services. Actian-wide communications may include new product information, special offers, or an invitation to participate in market research. Out of respect for the privacy of our users we present the option to not receive these types of communications. To be removed from our list, email us at privacy@actian.com. Subscription services To opt-out of receiving communications use any of the following methods: Select the e-mail “opt-out” or “unsubscribe” link, or follow the opt-out instructions included in each subscription communication Users who no longer wish to receive our newsletters and promotional communications may opt-out of receiving these communications by visiting our unsubscribe page at https://go.actian.com/UnsubscribePage.html 9. Access to and accuracy of your information Actian strives to keep your personal information accurate. We have implemented technology, management processes and policies to maintain customer data accuracy. Upon request Actian will provide you with information about whether we hold, or process on behalf of a third party, any of your personal information. We will provide you with access to your information, including making reasonable effort to provide you with online access and the opportunity to change or delete inaccuracies or modify your information. To protect your privacy and security, we will also take reasonable steps to verify your identity, such as a password and user ID, before granting access to your data. Certain areas of Actian websites may limit access to specific individuals through the use of passwords and other personal identifiers. If there is an issue with the accuracy of your personal information, you may submit a request to us at privacy@actian.com to update your information. We will respond to your update request within 30 days. We will retain your information for as long as your account is active or as needed to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements 10. Keeping your information secure Actian is committed to protecting the information you provide us. To prevent unauthorized access or disclosure, to maintain data accuracy, and to ensure the appropriate use of the information, Actian has in place appropriate physical and managerial procedures to safeguard the information we collect. We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage is 100% secure, however. Therefore, we cannot guarantee its absolute security. We use Secure Sockets Layer (SSL) encryption when collecting or transferring sensitive data such as credit card information. SSL encryption is designed to make the information unreadable by anyone but us. This security measure is working when you see either the symbol of an unbroken key or closed lock (depending on your browser) on the bottom of your browser window. If you have any questions about security on our Web site, you can contact us at privacy@actian.com. Credit card numbers are used only for processing payment and are not used for other purposes. 11. Changes to this Statement We may update this privacy statement to reflect changes to our information practices. If we make any material changes we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on this Site prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices. 12. Contacting us We value your opinion. If you have comments or questions about our privacy policy, please send them to the privacy@actian.com or write to us at the following address: Actian Corporation Attention: Marketing Programs Phone: +1.650.587.5500 Email: privacy@actian.com Postal Address: 2300 Geng Road, Suite 150, Palo Alto, CA 94303 USA Web site URL: www.actian.com Effective Date: Rev. June 28, 2017
