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Privacy Policy for Equus Software

The following describes the Equus Software, LLC ("Equus" or the "Company") privacy policy and the manner in which Equus handles information that it receives that may constitute either personal or sensitive information concerning individuals. Equus’ intent is to comply with all applicable legal and regulatory requirements of those jurisdictions in which it does business, including the EU-U.S.  Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States.  Equus has certified to the Department of Commerce that it adheres to the Privacy Shield Principles.  If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.  To learn more about the Privacy Shield program, and to view our certification, please visit www.privacyshield.gov.  

Collection of Commercial Information 

Equus collects certain information involuntarily from visitors to its website, and those of its subsidiaries, including the IP address, time visited, pages viewed and related information.  The Company also collects certain information voluntarily when someone sends a direct mail inquiry, an email or online registration, participates in seminars or webinars, or requests Company information at tradeshows.  Examples of such information include individual names, telephone numbers, email addresses, Company name, person’s title, and other personally identifiable information.  Equus uses such information to monitor the performance, and improve the quality of, its website, respond to requests about the Company and its business, provide information about products and services, fulfill customer requests, marketing and other business purposes and to comply with various legal and/or regulatory requirements.  The Company may share this information with business partners to respond to customer needs, or to engage in joint marketing activities.  Equus may also share this information with third-party agents who may be acting on its behalf; e.g., providing notice of an upcoming webinar or tradeshow that may be of interest to the target audience, or during solicitation for business purposes.

Collection of Personal and Sensitive Information

Equus collects personal information only directly from the individuals affected.  Personal information is information that identifies a particular individual, and does not include aggregated, compiled or publicly available data.  Personal information that is related to commercial purposes is used as described in the preceding section.  Sensitive information is personal information that reveals a particular person’s: (i) race; (ii) religion; (iii) ethnicity;(iv) sexual orientation; (v) political or philosophical beliefs; (vi) trade union membership; (vii) or information regarding a person’s medical status or condition.  Sensitive information is collected solely for employment-related and other internal business matters, as well as to comply with legal and regulatory obligations.

Use and Treatment of Personal and Sensitive Information Gathered by Others

From time to time Equus may have access to Personal and Sensitive Information gathered by others, including our clients.  Equus will use reasonable methods to secure all personal and sensitive information by a variety of methods, including restricting access to such information only to those people who have a legitimate need to know in order to discharge their job responsibilities on behalf of Equus, securing access to the facility where the information is stored, and the use of technology and physical controls to secure the information.

Other Uses of Personal and Sensitive Information

In addition to the uses described above, Equus will inform individuals of any other intended uses of their personal or sensitive information at the time such information is collected, or before such use is implemented, including disclosure to third parties that are not agents of Equus.  The individual will have the ability to advise the Company if he/she does not consent to such intended or additional use (i.e., "opt-in").  For other personal or commercial information, the individual has the ability to advise the Company at any time that he/she no longer wishes to allow such intended or additional use (i.e., "opt-out"), again, including disclosure to third parties that are not agents of Equus.

Data Security

Equus will use reasonable methods to secure all personal and sensitive information by a variety of methods, including restricting access to such information only to those people who have a legitimate need to know in order to discharge their job responsibilities on behalf of Equus, securing access to the facility where the information is stored, and the use of technology and physical controls to secure the information.  Equus is required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.  

Use of Information by Third Parties That are Agents of Equus

Equus will require that all third parties that are acting on behalf of Equus, and to which personal or sensitive information is provided, give Equus adequate assurances that they will safeguard all such information in a manner consistent with this policy, the EU-US Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework .  Equus’ accountability for personal data that it receives under the Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles.  In particular, Equus remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process the personal data on its behalf do so in a manner inconsistent with the Principles, unless Equus proves that it is not responsible for the event giving rise to the damage.

Ability to Access and Correct Information

Upon an individual’s request, Equus will provide reasonable access to any personal or sensitive information it has about that person.  Equus will also take reasonable steps to allow such individuals to correct, change, modify or delete any such information that is shown to be incorrect, inaccurate or incomplete.

Resolving Disputes

Equus will investigate any complaints about the use and disclosure of personal or sensitive information that are not in accordance with this policy.  Equus encourages individuals to contact Equus should they have a Privacy Shield-related (or general privacy-related) complaint regarding Equus’ handling of their information. 

If Equus is unable to informally resolve any such matter to the individual’s reasonable satisfaction, it will cooperate with EU data protection authorities (DPAs),  the Swiss Federal Data Protection and Information Commissioner (FDPIC) and comply with the information and advice provided to it in relation to such unresolved complaints (as further described in the Privacy Shield Principles).  Please contact us to be directed to the relevant DPA  and/or FDPIC contacts.  As further explained in the Privacy Shield Principles, a binding arbitration option will also be made available to you in order to address residual complaints not resolved by any other means.  Equus is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC).

Enforcement and Compliance

Equus will conduct regular audits to monitor compliance with this policy and will provide annual certifications to the U.S. Department of Commerce that it has done so.  Violations of this policy will subject the violator to disciplinary action, up to and including termination.

Changes

Equus may amend or modify this policy from time to time by posting the amended or modified version on its website at http://www.equusoft.com.  Amendments and modifications will be made in a manner so as to remain consistent with the Privacy Shield Principles.  This policy may also be changed, or limited, to comply with legal or regulatory requirements, or as otherwise allowed or required by law.

Contact Information

Questions or comments about this policy, or concerns or complaints about possible violations, should be sent to: Equus Software, 1809 Blake Street, Suite 200, Denver, CO 80202, (303) 292-4200 or inquiries@equusoft.com