Applicable date: May 24, 2019

MeaningCloud LLC — 1030 Salem Rd, Union, NJ 07083, USA

This Privacy Policy sets forth our policies regarding the collection, use and disclosure of certain information relating to your use of the MeaningCloud Services. Your use of this Site signifies your understanding and acceptance of the terms of this Privacy Policy. This Privacy Policy is incorporated into, and part of, the Terms and Conditions http://www.meaningcloud.com/terms-and-conditions/, which govern your use of the MeaningCloud Services in general. Should you have any questions concerning this Agreement, you may contact us by visiting https://www.meaningcloud/developer/support.

By using or registering with MeaningCloud Services or by providing personal information, you agree to abide by these terms. We may from time to time modify these terms and will post a copy of the amended Agreement at http://www.meaningcloud.com/data-protection-policy/.

If you do not agree to, or cannot comply with, the Agreement as amended, you must stop using the MeaningCloud Services (as defined below) or, if applicable, cancel your MeaningCloud Services subscription. You will be deemed to have accepted the Agreement as amended if you continue to use any of the MeaningCloud Services after any amendments are posted on the Site. We will not use or share your information with anyone except as described in this Privacy Policy. This Privacy Policy does not apply to information we collect by other means (including offline) or from other sources.

MeaningCloud uses information we collect to operate, maintain and provide you the features and functionality of the Service, to analyze how the Service is used, diagnose service or technical problems, maintain security, personalize content, remember information to help you efficiently access your account, monitor aggregate metrics such as total number of visitors, traffic, and demographic patterns, and track content and users as necessary to comply with the Digital Millennium Copyright Act, EU GDPR (General Data Protection Regulation) and other applicable laws. You provide us information about yourself, such as your name and e-mail address, if you register for an account with the Service, including by connecting with the Service via a third-party service, or by “following,” “becoming a fan,” adding the MeaningCloud application, etc., on a third party website or network. We may use your email address to send you Service-related notices (including any notices required by law, in lieu of communication by postal mail). We may also use your contact information to send you marketing messages. If you don’t want to receive these messages, you can opt out by following the instructions in the message. If you correspond with us by email, we may retain the content of your email messages, your email address and our responses. If you choose to use our invitation service to invite a friend to the Service, we will ask you for that person’s email address and automatically send an email invitation. MeaningCloud stores this information to send this email, to register your friend if your invitation is accepted, and to track the success of our invitation service. You also provide us information in the content you post to the Service. MeaningCloud can, but has no obligation, to monitor the content you post on the Service. We can remove any information you post for any reason or no reason. We have implemented encryption or other appropriate security controls to protect your personal information when stored by MeaningCloud. MeaningCloud and MeaningCloud employees will not view your content except: (i) to maintain, provide or improve the Service; (ii) to help you and resolve your support requests; or (iii) as MeaningCloud believes, in its sole opinion, is necessary to comply with or avoid the violation of applicable law or regulation or to cooperate with law enforcement.

Users of the MeaningCloud service: as part of our service, MeaningCloud will contact you to inform you of any circumstance that you need to know and necessary for the provision of such service: of operation, maintenance or billing incidents, launch of new products or new versions of existing ones, replacement or discontinuation of products, etc. To unsubscribe from the contents necessary for the provision of the service, it is necessary to unsubscribe from the service itself.

Users registered to receive marketing communications: if you have registered to receive our marketing communications, you can receive information on the following topics:

• Product news: launch of new products or new versions of existing ones, substitution or discontinuation of products, training events, use tutorials, etc.
• Invitations to events and other content of interest for your position or industry: conferences, webinars, white papers, customer cases, etc.
• Periodical Newsletter: an updated summary about MeaningCloud and its industry (product news, new clients, events, presence in media, etc.)

You can control your subscription to all these types of content through our Communications Preference Center.

When you use the Service, we may send one or more “cookies” – a small data file – to your computer to uniquely identify your browser and let MeaningCloud help you log in faster and enhance your navigation through the site. A cookie may convey anonymous information about how you browse the Service to us. A persistent cookie remains on your hard drive after you close your browser so that it can be used by your browser on subsequent visits to the Service. Persistent cookies can be removed by following your web browser’s directions. A session cookie is temporary and disappears after you close your browser. You can reset your web browser to refuse all cookies or to indicate when a cookie is being sent. However, some features of the Service may not function properly if the ability to accept cookies is disabled. MeaningCloud website can use the following types of cookies:

Disabling cookies in your browser

You can easily disable cookies from being installed on your machine, by configuring your browser settings. These are instructions for the most common browsers:

• Google Chrome
• Mozilla Firefox
• Microsoft Internet Explorer
• Apple Safari

When you use the Service, our servers automatically record certain information sent by your web browser. These server logs may include information such as your web request, Internet Protocol (“IP”) address, browser type, referring / exit pages and URLs, number of clicks and how you interact with links on the Service, domain names, landing pages, pages viewed, mobile carrier, and other such information. When you use the Service, we may employ clear gifs (also known as web beacons) which are used to track the online usage patterns. In addition, we may also use clear gifs in HTML-based emails sent to our users to track which emails are opened by recipients. The information is used to enable more accurate reporting and make MeaningCloud better for our users. When you use the Service by or through a mobile device, we may access, collect, monitor and/or remotely store “location data,” which may include GPS coordinates (e.g. latitude and/or longitude) or similar information regarding the location of your mobile device. Location data may convey information about how you browse the Service to us. Location data does not collect or share any personally identifiable information about you. Location data may be used in conjunction with personally identifiable information. Some features of the Service, particularly location-based services, may not function properly if use or availability of location data is impaired or disabled. When you access the Service by or through a mobile device, we may access, collect, monitor and/or remotely store one or more “device identifiers.” Device identifiers are small data files or similar data structures stored on or associated with your mobile device, which uniquely identify your mobile device and are used to enhance the Service. A device identifier may be data stored in connection with the device hardware, data stored in connection with the device’s operating system or other software, or data sent to the device by us. A device identifier may convey information about how you use the Service to us. A device identifier does not collect or share any personally identifiable information about you. A device identifier may be used in conjunction with personally identifiable information. A device identifier may remain persistently on your device, to help you log in faster and enhance your navigation through the Service. Some features of the Service may not function properly if use or availability of device identifiers are impaired or disabled. MeaningCloud may access, collect and/or store device identifiers upon enabling MeaningCloud’s Services. MeaningCloud uses third party analytics tools to help understand use of the Service. Many of these tools collect the information sent by your browser as part of a web page request, including cookies and your IP address. These analytics tools also receive this information and their use of it is governed by their privacy policy. We will display your Personal Information in your profile page You can review and revise your profile information at any time. We may also share or disclose your information with your consent, for example if you use a third party application to access your account (see below). MeaningCloud may share your personally identifiable information with other third parties for the purpose of providing the Service to you. If we do this, such third parties’ use of your information will be bound by this Privacy Policy. We may also store personal information in locations outside the direct control of MeaningCloud (for instance, on servers or databases co-located with hosting providers). As we develop our business, we may buy or sell assets or business offerings. Customers, email, and visitor information is generally one of the transferred business assets in these types of transactions. We may also transfer or assign such information in the course of corporate divestitures, mergers, or dissolution. We may share your information with a third party application with your consent, for example when you choose to access our Services through such an application. We are not responsible for what those parties do with your information, so you should make sure you trust the application and that it has a privacy policy acceptable to you. MeaningCloud may disclose your personal information if required to do so by law or subpoena or if we believe that it is reasonably necessary to comply with a law, regulation or legal request; to protect the safety of any person; to address fraud, security or technical issues; or to protect MeaningCloud’s rights or property. We may disclose your non-private, aggregated, or otherwise non-personally identifiable information, such as anonymous usage data, platform types, etc., with interested third parties to help them understand the usage patterns for certain MeaningCloud Services. The security of your information is important to us. When you enter sensitive information (such as a credit card number) as part of our service, we encrypt the transmission of that information using secure socket layer technology (SSL). We do not store your credit card information or other sensitive data on our servers. For any transaction we use the services of a secure payment gateway to provide safe and secure payment procedures. Your credit card information is never transmitted via our website since the payment gateway is responsible for collecting, storing and encrypting your data. MeaningCloud uses commercially reasonable physical, managerial, and technical safeguards to preserve the integrity and security of your personal information, once we receive it. For example, we continuously and regularly back up your data to help prevent data loss and aid in data recovery. We also guard against common web attack vectors, and implement firewalls and access restrictions on our servers to secure our network and better protect your information. No method of electronic transmission of storage is 100% secure, however, and we cannot ensure or warrant the absolute security of any information you transmit or store in the Service. In the event that personal information is compromised as a result of a breach of security, MeaningCloud will promptly notify those persons whose personal information has been compromised, in accordance with the notification procedures set forth in this Privacy Policy, or as otherwise required by applicable law. You may, of course, decline to submit personally identifiable information through the Service, in which case MeaningCloud may not be able to provide certain services to you. You may update or correct your account information at any time by logging in to your account. Our Service offers publicly accessible community services including blogs, and forums. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. Your posts may remain even after you cancel your account. Protecting the privacy of young children is especially important. Our Service is not directed to persons under 13. MeaningCloud does not knowingly collect or solicit personal information from anyone under the age of 13 or knowingly allow such persons to register with the Service. If we become aware that we have collected personal information from a child under age 13 without verification of parental consent, we take steps to remove that information. If you believe that we might have any information from or about a child under 13, please contact us at privacy@meaningcloud.com. We may transfer information that you provide to us, including personal information across borders and from your country or jurisdiction to other countries or jurisdictions around the world. If you are located in the European Union or other regions with laws governing data collection and use that may differ from U.S. law, please note that you are transferring information, including personal information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction, and you consent to the transfer of information to the U.S. and the use and disclosure of information about you, including personal information, as described in this Privacy Policy. EU and Swiss individuals should visit our Privacy Shield policy for information about MeaningCloud’s practices with regard to data received and processed in the U.S. pursuant to Privacy Shield. We are not responsible for the practices employed by websites linked to or from the Service, nor the information or content contained therein. Please remember that when you use a link to go from the Service to another website, our Privacy Policy is no longer in effect. Your browsing and interaction on any other website, including those that have a link on our website, is subject to that website’s own rules and policies. If we change our Privacy Policy, we will post those changes on this page to keep you aware of what information we collect, how we use it and under what circumstances we may disclose it. Changes to this Privacy Policy are effective when they are posted on this page. Please contact us at privacy@meaningcloud.com with any questions regarding this Privacy Policy. This Privacy Policy was last updated on: May, 2018.

MeaningCloud LLC ("MeaningCloud") has adopted this Privacy Shield Policy ("Policy") to establish and maintain an adequate level of Personal Data privacy protection. This Policy applies to the processing of Personal Data that MeaningCloud obtains from Individual Customers located in the European Union and Switzerland and to personal data received in the U.S. from other Data Subjects in the EU and Switzerland, including EEA Employees of MeaningCloud.

MeaningCloud complies with the EU-U.S. Privacy Shield Framework and Swiss-US Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from Individual Customers in the European Union member countries and Switzerland transferred to the United States pursuant to Privacy Shield. The term “Individual Customers” needs to be interpreted in a broad sense: these are actual (paying or not) users of MeaningCloud’s products, but also prospective customers that register with MeaningCloud and opt-in to attend its events or download its contents. MeaningCloud stores and processes their data to keep these people informed about its products and services.

MeaningCloud has certified that it adheres to the Privacy Shield Principles with respect to such data. If there is any conflict between the policies 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 page, please visit https://www.privacyshield.gov/participant_search.

The Federal Trade Commission (FTC) has jurisdiction over MeaningCloud's compliance with the Privacy Shield.

All MeaningCloud employees in the U.S. who handle Personal Data from Europe and Switzerland are required to comply with the Principles stated in this Policy.

Capitalized terms are defined in Section XIV of this Privacy Shield Policy.

For the full terms and conditions governing your use of the MeaningCloud service, please see our Terms and Conditions (http://www.meaningcloud.com/terms-and-conditions).

Please also review our full Data Protection Policy (http://www.meaningcloud.com/data-protection-policy).

This Policy applies to the processing of Individual Customer Personal Data that MeaningCloud receives in the United States concerning Individual Customers located in the European Union and Switzerland. MeaningCloud provides products and services to businesses and consumers.

The term “Individual Customers” designates actual (paying or not) users of MeaningCloud’s products, but also prospective customers that register with MeaningCloud and opt-in to attend its events or download its contents.

This Policy does not cover data from which individual persons cannot be identified or situations in which pseudonyms are used. (The use of pseudonyms involves the replacement of names or other identifiers with substitutes so that identification of individual persons is not possible.)

MeaningCloud has designated the Legal Department to oversee its information security program, including its compliance with the EU and Swiss Privacy Shield program. The Legal Department shall review and approve any material changes to this program as necessary. Any questions, concerns, or comments regarding this Policy also may be directed to privacyshield@meaningcloud.com.

MeaningCloud will maintain, monitor, test, and upgrade information security policies, practices, and systems to assist in protecting the Personal Data that it collects. MeaningCloud personnel will receive training, as applicable, to effectively implement this Policy. Please refer to Section 7 for a discussion of the steps that MeaningCloud has undertaken to protect Personal Data.

MeaningCloud will renew its EU-U.S. Privacy Shield and Swiss-US Privacy Shield certifications annually, unless it subsequently determines that it no longer needs such certification or if it employs a different adequacy mechanism.

Prior to the re-certification, MeaningCloud will conduct an in-house verification to ensure that its attestations and assertions about its treatment of Individual Customer Personal Data are accurate and that the company has appropriately implemented these practices. Specifically, as part of the verification process, MeaningCloud will undertake the following:

1. Review this Privacy Shield policy and its publicly posted website privacy policy to ensure that these policies accurately describe the practices regarding the collection of Individual Customer Personal Data.
2. Ensure that the publicly posted privacy policy informs Individual Customers of MeaningCloud's participation in the EU-U.S. Privacy Shield and Swiss-US Privacy Shield programs and where to obtain a copy of additional information (e.g., a copy of this Policy).
3. Ensure that this Policy continues to comply with the Privacy Shield principles.
4. Confirm that Individual Customers are made aware of the process for addressing complaints and any independent dispute resolution process (MeaningCloud may do so through its publicly posted website, Individual Customer contract, or both).
5. Review its processes and procedures for training employees about MeaningCloud's participation in the Privacy Shield programs and the appropriate handling of Individual's Personal Data.

MeaningCloud will prepare an internal verification statement on an annual basis.

MeaningCloud provides various solutions to its Individual Customers who purchase its products. MeaningCloud collects Personal Data from Individual Customers when they purchase its products, register with our website, log-in to their account, complete surveys, request information or otherwise communicate with us. For example, MeaningCloud Individual Customers may choose to seek live support or post to a message board.

The Personal Data that we collect may vary based on the Individual Customer's interaction with our website and request for our services. As a general matter, MeaningCloud collects the following types of Personal Data from its Individual Customers: contact information, including, a contact person's name, work email address, work mailing address, work telephone number, title, and company name, as well as payment information (which might include credit card and/or bank account information). Individual Customers have the option to log into their accounts online and to request service online, including through a live support option; we will collect information that they choose to provide to us through these portals.

When Individual Customers use our services online, we will collect their IP address and browser type. We may associate IP address and browser type with a specific customer. We also may collect Personal Data from persons who contact us through our website to request additional information; in such a situation, we would collect contact information (as discussed above) and any other information that the person chooses to submit through our website.

The information that we collect from Individual Customers is used for selling the products and services they buy from us, managing transactions, reporting, invoicing, renewals, other operations related to providing services and products to the Individual Customer.

MeaningCloud uses Personal Data that it collects directly from its Individual Customers for the following business purposes, without limitation:

1. maintaining and supporting its products, delivering and providing the requested products/services, and complying with its contractual obligations related thereto (including managing analysis requests, reporting, invoices, renewals, and other operations related to providing services to a Individual Customer);
2. satisfying governmental reporting, tax, and other requirements (e.g., import/export);
3. storing and processing data, including Personal Data, in computer databases and servers located in the United States;
4. verifying identity (e.g., for online access to accounts);
5. as requested by the Individual Customer;
6. for other business-related purposes permitted or required under applicable local law and regulation;
7. and as otherwise required by law.

MeaningCloud does not disclose personal information to third parties other than our agents. Should this change in the future, we will provide individuals with the option to opt-out, or opt-in for sensitive data, for any personal information so disclosed.

MeaningCloud provides an individual opt-out choice, or opt-in for sensitive data, before we use your personal information for a purpose other than which it was originally collected or subsequently authorized. To request to limit the use and disclosure of your personal information, please submit a written request to privacyshield@meaningcloud.com.

Except as otherwise provided herein, MeaningCloud discloses Personal Data only to Third Parties who reasonably need to know such data only for the scope of the initial transaction and not for other purposes. Such recipients must agree to abide by confidentiality obligations.

MeaningCloud may provide Personal Data to Third Parties that act as agents, consultants, and contractors to perform tasks on behalf of and under our instructions. For example, MeaningCloud may store such Personal Data in the facilities operated by Third Parties. Such Third Parties must agree to use such Personal Data only for the purposes for which they have been engaged by MeaningCloud and they must either:

1. comply with the Privacy Shield principles or another mechanism permitted by the applicable EU & Swiss data protection law(s) for transfers and processing of Personal Data;
2. or agree to provide adequate protections for the Personal Data that are no less protective than those set out in this Policy;

MeaningCloud also may disclose Personal Data for other purposes or to other Third Parties when a Data Subject has consented to or requested such disclosure. Please be aware that MeaningCloud may be required to disclose an individual's personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements. MeaningCloud is liable for appropriate onward transfers of personal data to third parties.

MeaningCloud’s accountability for personal data that it receives in the United States under the Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles. In particular, MeaningCloud 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 MeaningCloud proves that it is not responsible for the event giving rise to the damage.

MeaningCloud does not collect Sensitive Data from its Individual Customers.

MeaningCloud uses reasonable efforts to maintain the accuracy and integrity of Personal Data and to update it as appropriate. MeaningCloud has implemented physical and technical safeguards to protect Personal Data from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. For example, electronically stored Personal Data is stored on a secure network with firewall protection, and access to MeaningCloud's electronic information systems requires user authentication via password or similar means. MeaningCloud also employs access restrictions, limiting the scope of employees who have access to Individual Customer Personal Data.

Further, MeaningCloud uses secure encryption technology to protect certain categories of personal data. Despite these precautions, no data security safeguards guarantee 100% security all of the time.

MeaningCloud notifies Individual Customers about its adherence to the EU-US Privacy Shield and Swiss-US Privacy Shield principles through its publicly posted website privacy policy, available at: https://www.meaningcloud.com/data-protection-policy and takes Individual Customers approval and adherence to the current policy when they provide their information to us in the transactional process.

MeaningCloud personnel may access and use Personal Data only if they are authorized to do so and only for the purpose for which they are authorized.

A. Right to Access. Individual Customers and other Data Subjects have the right to know what Personal Data about them is included in the databases in the United States and to ensure that such Personal Data is accurate and relevant for the purposes for which MeaningCloud collected it. Individual Customers may review their own Personal Data stored in the databases and correct, erase, or block any data that is incorrect, as permitted by applicable law and MeaningCloud policies. Upon reasonable request and as required by the Privacy Shield principles, MeaningCloud allows Individual Customers and other Data Subjects access to their Personal Data, in order to correct, amend, or delete such data where inaccurate or collected in a manner inconsistent with the Principles. Individual Customers may edit their Personal Data by logging into their account profile or by contacting MeaningCloud by phone or email. In making modifications to their Personal Data, Data Subjects must provide only truthful, complete, and accurate information. To request erasure of Personal Data, Individual Customers should submit a written request to local MeaningCloud office.

B. Requests for Personal Data. MeaningCloud will track each of the following and will provide notice to the appropriate parties under law and contract when either of the following circumstances arise: (a) legally binding request for disclosure of the Personal Data by a law enforcement authority unless prohibited by law or regulation; or (b) requests received from the Data Subject. If MeaningCloud receives a request for access to his/her Personal Data from a Data Subject, then, unless otherwise required under law or by contract with such Data Subject, MeaningCloud will refer such Data to the Data Subject.

C. Satisfying Requests for Access, Modifications, and Corrections. MeaningCloud will endeavor to respond in a timely manner to all reasonable written requests to view, modify, or inactivate Personal Data.

This Policy may be amended from time to time, consistent with the Privacy Shield Principles and applicable data protection and privacy laws and principles. We will make employees available of changes to this policy either by posting to our intranet, through email, or other means. We will notify Customers if we make changes that materially affect the way we handle Personal Data previously collected, and we will allow them to choose whether their Personal Data may be used in any materially different manner.

In compliance with the Privacy Shield Principles, MeaningCloud commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to Privacy Shield. European Union and Swiss individuals with Privacy Shield inquiries or complaints should first contact MeaningCloud by email at privacyshield@meaningcloud.com.

MeaningCloud has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD . If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint. This service is provided free of charge to you.

If your complaint involves human resources data transferred to the United States from the EU and/or Switzerland in the context of the employment relationship, and MeaningCloud does not address it satisfactorily, MeaningCloud commits to cooperate with the panel established by the EU data protection authorities (DPA Panel) and/or the Swiss Federal Data Protection and Information Commissioner, as applicable and to comply with the advice given by the DPA panel and/or Commissioner, as applicable with regard to such human resources data. To pursue an unresolved human resources complaint, you should contact the state or national data protection or labor authority in the appropriate jurisdiction. Contact details for the EU data protection authorities can be found at https://edpb.europa.eu/about-edpb/board/members_en. Complaints related to human resources data should not be addressed to the BBB EU PRIVACY SHIELD.

If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction

Capitalized terms in this Privacy Policy have the following meanings:

"Individual Customer" means an individual customer or client of MeaningCloud from EU or Switzerland. The term also shall include any individual agent, representative, of an individual customer of MeaningCloud and any employee of Individual Customers where MeaningCloud has obtained his or her Personal Data from such Individual Customer as part of its business relationship with MeaningCloud.

"Data Subject" means an identified or identifiable natural living person. An identifiable person is one who can be identified, directly or indirectly, by reference to a name, or to one or more factors unique to his or her personal physical, psychological, mental, economic, cultural or social characteristics. For Customers residing in Switzerland, a Data Subject also may include a legal entity.

"EEA Employee" means an employee (whether temporary, permanent, part-time, or contract), former employee, independent contractor, or job applicant of MeaningCloud or any of its affiliates or subsidiaries, who is also a resident of a country within the European Economic Area.

"Personal Data" as defined under the European Union Directive 95/46/EC means data that personally identifies or may be used to personally identify a person, including an individual's name in combination with country of birth, marital status, emergency contact, salary information, terms of employment, job qualifications (such as educational degrees earned), address, phone number, e-mail address, user ID, password, and identification numbers. Personal Data does not include data that is de-identified, anonymous, or publicly available. For Switzerland, the term "person" includes both a natural person and a legal entity, regardless of the form of the legal entity.

"Sensitive Data" means Personal Data that discloses a Data Subject's medical or health condition, race or ethnicity, political, religious or philosophical affiliations or opinions, sexual orientation, or trade union membership.

"Third Party" means any individual or entity that is neither MeaningCloud nor a MeaningCloud employee, agent, contractor, or representative.

MeaningCloud LLC

Phone: +1 (646) 403-3104

Mailing Address: 1030 Salem Rd, Union, NJ 07083, USA

Email Address: privacy@meaningcloud.com