PLEASE READ THIS PRIVACY POLICY CAREFULLY AS IT CONTAINS IMPORTANT INFORMATION THAT YOU SHOULD KNOW BEFORE USING THE Eltima IBC INC. WEBSITE AND/OR SERVICES. BY ACCESSING AND USING THE Eltima IBC INC. WEBSITE AND/OR SERVICES, YOU WILL BE DEEMED TO HAVE WHOLLY ACCEPTED Eltima IBC INC.’S PRIVACY POLICY.

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Your use of the Eltima IBC Inc. and its affiliates (“Eltima IBC”), if and as applicable, Website and Services, including any dispute concerning Your online privacy therewith, is subject to Eltima IBC’s Privacy Policy (“Privacy Policy”) and Eltima IBC’s Terms of Service (“Terms of Service”), located at https://wiki.eltima.com/policies/eltima-privacy-policy.html. By using the Eltima IBC Website and/or Services, You ACCEPT the practices set forth in this Privacy Policy and the Terms of Service. For this reason, please frequently refer to this Privacy Policy to ensure Your continued ACCEPTANCE of all Eltima IBC practices relating to Your personal and user information. Your continued use of any portion of the Website and/or Services following the posting of an updated Privacy Policy will constitute Your full ACCEPTANCE of any changes.

Eltima IBC has created this privacy statement in order to fully disclose its information gathering and dissemination practices for the Eltima IBC Website (“Website”), and the Services offered and provided through the Website (“Services”).

Changes in Privacy Policy

Eltima IBC reserves the right to modify this Privacy Policy at any time and will notify You as to any changes via the Website, by email, or as outlined in the Terms of Service. Eltima IBC wants You to always be aware of what personal and other information it collects, how Eltima IBC uses that information, and under what circumstances Eltima IBC may disclose such information. All personal information that Eltima IBC collects will be handled in accordance with the Privacy Policy in effect at the time the information is collected. If the Privacy Policy changes in any significant respect in the meantime, Eltima IBC will not (without Your permission) use Your personal data in a manner that is inconsistent with the Privacy Policy in effect at the time Your information was collected.

Table of Contents

C. Information Eltima IBC Collects
D. Purpose of Processing & Use and Disclosure of Information
E. Data Choices Available to You
F. Rights of European Users under the General Data Protection Regulation (GDPR)
- GDPR Rights:

A. BACKGROUND INFORMATION

Upon reading this Privacy Policy, You will be informed of the following:
(1) Description of the types of personally identifiable information (Yours and that of third parties) collected through the Website and Services;
(2) How collected personally identifiable information is used;
(3) With whom the collected personally identifiable information may be shared;
(4) The choices available to You regarding the collection, use, and distribution of such information;
(5) Security procedures that are in place to protect against the loss, misuse, or alteration of personally identifiable information under Eltima IBC’s control; and
(6) Instructions on how You can access and correct any inaccuracies in the information collected about You.

A note about the Website and Services: Some of Eltima IBC’s Services, data centers, service providers, affiliates or operating partners and servers may be located in other countries. As such, the Website and Services may be subject to the laws of numerous countries and jurisdictions, some of which may require Eltima IBC to disclose certain information about its users. Eltima IBC is committed to keeping Your information private while using its best efforts to comply with all applicable laws in the jurisdiction(s) in which it operates.

Should You have any concerns or believe that there are problems or issues relating to compliance with the policies outlined in this Privacy Policy, please notify Eltima IBC’s Data Protection Officer by email at , as also outlined in Section G, below.

B. A WORD FROM ELTIMA IBC

Eltima IBC has a strong commitment to providing superior service to all of its customers, users, and visitors, particularly with respect to their concerns about privacy. Eltima IBC understands that You may have questions about how the Website and Services collect and use Your information. Accordingly, Eltima IBC prepared this statement to best inform You of the privacy principles that govern the Website and Services. Eltima IBC will not sell or rent Your personally identifiable information or a list of its customers and/or users to third parties. However, as described in more detail below, there are limited circumstances in which some of Your information may be shared with third parties—under strict restrictions—so it is important for You to carefully review this Privacy Policy.

This Privacy Policy contains numerous general and technical details about the steps Eltima IBC takes to respect Your privacy. Eltima IBC has organized this Privacy Policy by major processes and areas so that You can quickly find the information of most interest to You. The bottom line is that meeting Your needs and expectations forms the foundation of everything Eltima IBC does, including the protection of Your privacy.

C. INFORMATION ELTIMA IBC COLLECTS

Information Eltima IBC Collects Through the Website

The Website does not collect personally identifiable information from Your computer when You browse the Website and request pages from Eltima IBC servers. This means that, unless You voluntarily and knowingly provide Eltima IBC with personally identifiable information, Eltima IBC will not know Your name, email address, or any other personally identifiable information.

When You request a page from the Eltima IBC Website, Eltima IBC’s servers log the information provided in the HTTP request header, JavaScript or similar technical tools, including the IP address, the time of the request, the URL of the request, and other technical information. Eltima IBC collects this information in order to make its Website function correctly and to provide You the functionality that You see on the Website, as Eltima IBC’s servers use this information to deliver the internet pages You request. Eltima IBC also uses this information to better understand how visitors use the Website and how Eltima IBC can better tune its Website, contents, and functionality to best meet Your needs. However, this information is not associated with any personally identifiable information of persons browsing the Website.

When You use the Website, Eltima IBC, or trusted authorized third parties, may also collect certain technical and routing information about Your computer (also known as environmental variables) to facilitate Your use of the Website and the Services enabled thereby. When You browse the Internet, Your Internet browser (such as Mozilla Firefox, Google Chrome, or Microsoft Internet Explorer) automatically transmits some information to Eltima IBC every time You access content on one of Eltima IBC’s internet domains. Examples of such information include the URL of the particular web page You visited, the IP address of the computer You are

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