ACCTON PRODUCT
‍PRIVACY POLICY

Last updated: 1 July 2022

We, at Accton (collectively "Accton", "we," "us" or "our"), are committed to protect the privacy of our business partners who are licensed to use our products (the "Software") on their internal network ("you" or "Client") and our Client's end users which have access to any of the data resources monitored by our Software ("End Users").

General Information
This Privacy Policy ("Privacy Policy") applies to Accton, which means First Middlegate Ltd. trading as "Accton" with its registered offices at 24 Court Close, Maidenhead SL6 2DL, UK.Accton is the data controller and is responsible for deciding how we use and hold your personal information.

Privacy Policy Contents
This Privacy Policy describes how we handle and protect your personal data and the choices available to you. Additional information on our personal data practices may be provided in terms and conditions of use, product settings, contractual terms, or notices provided prior to or at the time of data collection.

Client's Obligation
We encourage you and your End Users to read this Privacy Policy carefully and use it to make informed decisions. By using our Software, you agree to the terms of this Privacy Policy, and your continued use of the Software constitutes your ongoing agreement to it.Official Software NameAccton Insight Hub and its modules (which may also be treated as separate products) Accton Explorer, Accton Auditor, Accton Cataloger, Accton Framework.Core FunctionalityAccton Insight Hub is an analytics catalogue serving as a single portal for all reports in the company. Its modules (which may also be treated as separate products) provide easy analytics access, multi-tool search engine, light business intelligence governance, usage analysis, dynamic business requirements, technical documentation storage, business terms glossary and organizational structure by industries.

Personal Data We Collect
All personal data collected by Accton is recorded, stored, used, and managed on protected servers, as well as on other devices that allow these operations with standard industry security measures. Also, all Accton websites are hosted on protected servers having standard industry security measures.We collect two types of information when you or your End Users are using our Software:The first type of information is individually identifiable information, namely information that identifies an individual or may with reasonable effort identify an individual ("Personal Information"), which includes the following:

Your Representatives' Personal Details, Contact Information and Professional Affiliations
To organize efficient communication with you, we will collect and process your representatives' personal details which may include full name, e-mail, phone number, business name, title, address, etc.

End Users' Personal
DetailsWhen you allow us (or our trusted third-party software and service providers) to receive your End Users' feedback and rating with regard to Software ("Feedback"), we may gather Personal Information which may include the following: email address of the End User, End User's full name, End User's IP address, and the Client's email. In addition, we may collect Personal Information which your End User voluntarily shares with us when they send us Feedback (e.g., identifying content, images; etc.).

Client Operational and Financial Data
Upon the acceptance of Accton Terms and Conditions of Use, we will collect some operational details including transactions, sales, purchases, uses, supplier information, credentials to online services and platforms etc., and some financial information like bank account number, account details, and any further information required for credit verification, compliance/ethics checks, or customer due diligence.

The second type of information is unidentified and non-identifiable information pertaining to you or to your End Users, which may be made available or gathered via your use of the Software ("Non-Personal Information"). We are not aware of the identity of the user from which the Non-Personal Information was collected. Such information may include the following:

Technical Information
Non-Personal Information which is being collected may include usernames, directory names, server names, share names, file names, configurations, logs related to Software and Client (e.g. event logs), browsing events and technical information transmitted by your device or your End Users' devices, including certain software and hardware information (e.g., the type of browser and operating system the device uses, language preference, access time and the domain name from which you or your End Users are linked to the Software; etc.).

Feedback Information
In addition, when you allow us (or our trusted third party product and service providers) to receive your End Users' Feedback with regard to Software, we may gather Non-Personal Information which may include the following: Feedback rating, Feedback tags, Feedback text, browser type and language, operating system, viewport of the screen, page URL on which the Feedback has been given, screenshot of the screen on which Feedback was provided (with all textual strings redacted), and our clients.

How we use the information we collect?

‍The information we collect, which may include your Personal Information, is used for legitimate business purposes only, such as:
• To set up your account and to provide our services to you and to your End Users;
• To identify and authenticate End Users' access to the Software;
• To obtain End Users' Feedback with regard to the Software;
• To improve our Software;To support and troubleshoot our Software and to respond to queries;
• To investigate violations and enforce our policies, and as required by law, regulation or other governmental authority, or to comply with a subpoena or similar legal process or respond to a governmental request.

We also reserve the right to use your Personal Information to send you marketing-related emails with information about our services, new products and other news about our Software. We will only engage in this activity with your consent or where we have a legitimate interest. Another activity where the collected information may be used is for business reporting and providing personalized services, for example (i) to analyze or predict our users' preferences in order to prepare aggregated trend reports on how our digital content is used, so we can improve our services; (ii) to personalize our interactions with you and provide you with information and/or offers tailored to your interests; (iii) to deliver content via our services that we believe will be relevant and interesting to you.We use the Personal Information only to the extent required and while maintaining your right to privacy.

What are the Conditions for Processing Personal Information?‍

We will process your Personal Information for a variety of reasons, each of which is prescribed by relevant data protection laws.

Performance of a contract, compliance with a legal obligation
It is necessary for us to process your Personal Information where it is necessary for the performance of a contract (such as for our agreement) or in order for us to comply with our various legal and/or regulatory responsibilities.

Legitimate interests
We also process your Personal Information where we deem such processing to be in our (or a third party's) legitimate interests and provided always that such processing will not prejudice your interests, rights and freedoms. Examples of us processing in accordance with legitimate interests would include: (i) where we disclose your Personal Information to any one or more of our associate companies following a restructure or for internal administrative purposes; (ii) processing for the purposes of ensuring network and information security, including preventing unauthorized access to our electronic communications network; (iii) sharing personal information with our advisers and professional services providers (such as auditors).

With whom we share the information we collect?
We do not rent, sell or share your Personal Information with third parties except as described in this Privacy Policy.We may transfer or disclose Personal Information to our affiliated companies. In addition, the Client's and End User's Personal Information may be disclosed to other trusted third-party service providers or partners for the purpose of (i) storing Personal Information on our behalf (e.g., cloud computing service providers); (ii) assisting us with our business operations and Software and improving it (e.g., processing and analyzing End Users' Feedback); and (iii) performing research, technical diagnostics and analytics with regard to the Software.

We may disclose Personal Information or any information you submitted via the Software if we have a good faith belief that disclosure of such information is helpful or reasonably necessary to (i) comply with any applicable law, regulation, legal process or governmental request; (ii) enforce our policies (including this Privacy Policy), including investigations of potential violations thereof; (iii) investigate, detect, prevent or take action regarding illegal activities or other wrongdoing, suspected fraud or security issues; (iv) to establish or exercise our rights to defend against legal claims; (v) prevent harm to the rights, property or safety of us, our users, yourself or any third party; or (vi) for the purpose of collaborating with law enforcement agencies or in case we find it necessary in order to enforce intellectual property or other legal rights.

Third-party collection of information
Our policy only addresses our use and disclosure of personal information from you and from your End Users through the Software. To the extent that you or your End Users disclose your information to other parties through the Software, different rules may apply to their use or disclosure of the information disclosed to them.

How long do we retain the information we collect?
Please note that we retain the information we collect for as long as needed to provide our services (including marketing and communication) and to comply with our legal obligations, resolve disputes and enforce our agreements (including exercising any of our rights under our agreements, such as audit and record-keeping).We may rectify, replenish or remove incomplete or inaccurate information, at any time and at our own discretion.

How do we protect and transfer the information we collect?
We are committed to making reasonable efforts, in accordance with market best practices, to ensure the security, confidentially and integrity of the Personal Information.

Although we take steps to safeguard such information, we cannot be responsible for the acts of those who gain unauthorized access or abuse our Software, and we make no warranty, express, implied or otherwise, that we will prevent such access. If a password is used to help protect your accounts and Personal Information, it is your responsibility to keep your password confidential.

We collect information globally and may transfer, process and store your information outside of your country of residence, to wherever we or our third-party product and service providers operate for the purpose of providing you the Software or connected services. Whenever we transfer your information, we take steps to protect it.We use our best efforts to ensure that your Personal Information is protected in accordance with our Privacy Policy, through contractual means (such as by using the standard contractual clauses approved by the European Commission for data transfers) or other means (such as by transferring data only to recipients located in jurisdictions which were granted an "adequacy decision" with regard to their level of protection of personal data by the European Commission).

Your personal data rights
According to GDPR, data subjects have the right to access to data, right to rectification, right to erasure and the right not to be subject to individual decisions. Data subjects also have the right to restriction of personal data processing and to request the deletion of the collected personal data, as well as the right to data portability.For any data processing based on consent, you have the right to withdraw the consent at any time.

To exercise these rights, you may send a written request via email to support@accton.io.Data subjects are not subject to decisions based solely on automated processing, including profiling, which may produce legal effects or similarly significantly affects them.

Data subjects also have the right to lodge a complaint with a supervisory authority and the right to address a court.

Minors
The Software is not designated to End Users under the age of 16. In the event that we become aware that End Users under the age of 16 have shared any information, we will discard such information. If you have any reason to believe that a minor has shared any information with us, please contact us at support@accton.io.

Publication date
The privacy policy has been adopted on the date mentioned in the title of the document and will be modified each time when necessary without prior or future notice of the changes. The new version will enter into force when published on the website and it will be marked accordingly.

Contact Us
If you have any questions about this Privacy Policy or our privacy practices, or if you have a disability and need to access this notice in a different format, contact us at support@accton.io.

You may also contact us by postal mail:
To the attention of the Executive
First Middlegate Ltd
24 Court Close, Maidenhead, SL6 2DL, United Kingdom