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Privacy Notice

This privacy notice describes how Page Tiger Limited (a company registered in England and Wales with company number 06907710)(referred to as "PageTiger" or "we" or "us") uses personal data when providing services to its customers. It also describes our direct marketing activities relating to existing and potential customers.

It is intended to provide information both for customers and for individuals whose information we hold, including Account Owners, Administrators, Authors, Analysts and Visitors to our websites and publications, and recipients of marketing communications (referred to as "you").

This privacy notice was last updated on: 8 May 2018.

1. OVERVIEW

1.1 PageTiger's activities as a Controller

We hold some personal data for our own business purposes and are responsible for how such data is used. This includes, for example, our use of Administrator and Author details in managing PageTiger Accounts. More information is provided in paragraph 2 below.

Note: A customer may provide PageTiger with individuals' details for these purposes (for example when specifying administrators or authors for an account). The customer should ensure such individuals are comfortable for PageTiger to use their details in accordance with this privacy notice.

We may also send marketing communications about our services to customers and other businesses, and may track and analyse information about how marketing materials are accessed and viewed. More information is provided at paragraph 4 below.

As at the date of this notice, we are registered with the UK Information Commissioner's Office (ICO) as a controller under registration number ZA113062. Registration requirements are changing in May 2018, and the information available from the ICO about our processing activities will be more limited. However, we aim to provide you with information about our activities within this notice.

1.2 PageTiger's activities as a Processor

We also hold some personal data solely on behalf of our customers, which means it is used for purposes determined by our customers, and they are primarily responsible for how such data is used. This includes, for example, our use of information about individuals within the content of customer publications or materials, or about Visitors who view customer publications or enter surveys within customer publications. More information is provided in paragraph 3 below.

Note: It is the customer's responsibility to ensure such individuals are made aware of how their details are being used, and to obtain any required consents.

1. HOW WE USE YOUR DATA

2.1 PageTiger account details

In order to receive our services, customers may create one or more PageTiger Accounts.

Account information includes:

• names of the account owner, other Administrators, Authors and Analysts;

• individual email addresses and other contact details;

• login details for PageTiger services; and

• business postal address.

We use such information to manage the PageTiger Account and provide the associated services, and to manage payment and invoicing.

You and we may also discuss additional information about you or your business during the course of setting up an Account or providing our services. This may include, for example, job titles or roles and the structure of the customer's business. This may be used by us to manage our services and customer relationships.

Our legal basis for processing the information as described above is our legitimate interests in providing our services and managing our business.

2.2. Payment details

We do not currently store customer payment card or bank details, other than:

• such details as appear within our bank statements when a customer makes payments to us; and

• copies of standing order forms, should a customer choose to pay us by standing order.

For VAT-registered customers, we also request and retain the VAT number.

Any such payment details will generally relate to a corporate customer, rather than to an individual. Where our customer is an individual, our legal basis for processing this information is that it is necessary for our contract with the customer.

Note: We generally request payments by direct electronic transfer to our bank account but, in some cases, we may direct you to a third party payment provider, such as PayPal.

2.3. Marketing activities

We may use your personal data for our marketing activities - see paragraph 4 below.

2.4. Records of services and logs of access

We collect and maintain other records relating to our services to a customer, including details of specific services provided and communications exchanged.

We may maintain logs and audit trails of access to our systems by specific account holders, Administrators, Authors or Analysts, which may be used to address queries about account activities.

Our legal basis for processing the information as described above is our legitimate interests in providing our services and managing our business.

2.5 We also maintain logs of Visitors to our websites, publications and materials, and opening of emails, either for our own analysis and marketing activities (see paragraphs 4 below) or as part of our services to customers (see paragraph 3 below).Visiting our websites or contacting us

We use cookies and web beacons as outlined in our Cookies Notice. Note in particular that we analyse who visits our site and what pages they view in order to develop our services and marketing materials. This analysis may be undertaken by reference to identifiable users and/or specific email addresses. See also paragraph 4 below. Our Cookies Notice also describes how you may disable cookies at any time.

You may complete a contact form or sign up for a trial of our services on our website, in which case we collect your email address and other relevant information, in our legitimate interests, in order to respond to your query and provide the trial services. You may also be given the option to register as a visitor - see paragraph 2.6 below.

If you contact us by other means, we may also retain your contact details and your communication in our legitimate interests, in order to handle your query and maintain records of communications.

2.6. Registered visitors

We may give you the option, as a Visitor, to register with PageTiger as a reader or viewer of customer publications, in which case you will need to provide us with your email address and set up login details. Some customers may require you to register with us in order to view their publications.

Our legal basis for processing this registration information is our legitimate interests in providing our services to registered Visitors.

Registration also enables us to provide reader verification services to our customers, and we may also collect and analyse registered visitor information on behalf of our customers (see paragraph 3 below).

2.7. Other use of your personal data

We may also use your personal data (in our legitimate interests in managing our business and maintaining appropriate business records) for:

• contacting you in relation to the services we are providing, which may include communications on system updates and availability, and subscription renewal notifications;

• administration and maintenance of the services and our business;

• reviewing and enforcing your compliance with our terms of service and fair use policy; and

• compliance with legal obligations, or protection and enforcement our legal rights and those of customers or other individuals.

3. PERSONAL DATA HELD ON BEHALF OF OUR CUSTOMERS

Note: Our customers have primary responsibility to ensure PageTiger's use of the information as outlined in this paragraph complies with data protection and privacy laws. PageTiger also takes steps to ensure that such data is held securely - see paragraph 5 below. If you have any queries about use of your data for these purposes, they should be directed to the customer.

3.1 Content of publications

Customers (or individuals authorised by Customers to use our services) may provide us with personal data forming part of the content of publications or materials created or hosted by PageTiger, such as names, contact details, images and other personal data relevant to the materials being produced using our services. We use these to provide the services and for administration and maintenance of the services.

3.2 Visitors to publications We may collect information about visitors or expected visitors to customer publications, including login details (where required), email addresses (from lists provided by our customers, or if used to login or where a visitor clicks through from an email), visits, page views and interactive responses (including to surveys and emails). These are stored and analysed by us as part of our services to customers in order to provide reports and statistics, and to maintain logs of use.

[Note: If a customer integrates forms or other interactive components provided by third parties into its publications, PageTiger does not collect and is not responsible for the use or security of information collected within such forms or interactive components.] Note: If a visitor registers with PageTiger, we will also maintain registration information as a Controller – see paragraph 3 above.

4. MARKETING AND TRACKING ACTIVITIES

4.1 Customers

We may send marketing communications about our services by email to existing or former customers and specified account holders and administrators. We provide an option to opt out of receiving such communications when setting up the relevant PageTiger Account, and you may also opt out of receiving these at any time within the PageTiger Account or otherwise by contacting us using the contact details at paragraph 9 below.

We send these communications in our legitimate interests in promoting our business (whilst giving you the opportunity to opt out if you do not wish to receive these).

Note: Even if you opt out of receiving marketing communications, we may still use your email address to contact you in relation to the services you are receiving as described elsewhere in this notice, for example communications on system updates and availability, subscription renewals and payments.

4.2 Other businesses

We may purchase email marketing lists from reputable third parties for specific marketing campaigns. Further information about the source of your email address is available upon request. Email addresses may be selected by reference to specific types of business or job roles within a business. If you do not wish to receive any further marketing emails from us, please let us know using the "unsubscribe" link within the email, or otherwise by contacting us using the contact details at paragraph 9 below. We will then put your email address on a "block list" to suppress it from our future marketing campaigns.

4.3 Opening marketing emails and viewing marketing material

We may record that you opened a marketing email sent by us. If you click through to our marketing material from an email, we may keep a record of the areas you view by reference to your email address. This assists us to develop our marketing materials and tailor our marketing activities to appropriate audiences. More information is provided within our Cookies Notice. We may also contact you again in relation to the material which you viewed (unless you have opted out or unsubscribed as described above).

5. SECURITY OF DATA AND INTERNATIONAL DATA TRANSFERS

PageTiger takes steps to protect personal data from loss or misuse, as outlined within our Security Policy.

Our activities are based in the United Kingdom and, as at the date of this notice, our data centres are located within the United Kingdom.

[We do not otherwise generally transfer your personal data to countries outside the European Union[, unless our customer has requested this as part of the services, or otherwise used our services to make such a transfer (such as emailing someone outside the European Union).]

Note: Customers should not rely on PageTiger for storage or maintenance of any data, and it is the customer's responsibility to take such other steps as it may require to back up data which it needs. The customer is also responsible for maintaining confidentiality of login details and passwords used to access PageTiger accounts and services.

6. DISCLOSURES OF DATA TO OTHER PARTIES

6.1 Customers

We may share personal data relating to a PageTiger account with the relevant customer and Account Owner, Administrators and Analysts, as appropriate to the services being provided (and in our legitimate interests in providing such services).

6.2. Third party publication tools and other service providers

Where a customer integrates third party tools or components into a publication using our services, personal data may be shared, where relevant .

Your personal data may also be held or processed by PageTiger's technology providers or service providers detailed within our Procurement Portal including data centres, CRM, email and user support software.

These parties act as processors on our behalf, meaning that we remain primarily responsible for how they use your data.

6.3. Other

We may also disclose personal data, where appropriate, to:

• our professional advisers;

• governmental or regulatory bodies and law enforcement authorities;

• any purchaser or (on terms of confidentiality) likely purchaser of our business; and

• other third parties where required or permitted by law.

The legal bases for such disclosures are our legitimate interests in managing our business, or in order to comply with a legal obligation.

7. RETENTION OF DATA

[We may retain records containing your personal data for the purposes described above whilst we are still providing services to the relevant customer and/or the relevant account is live.]

Where we process personal data on behalf of our customers (see paragraph 3 above), our customer determines the relevant retention period.

We may retain some personal data for appropriate periods following termination of our services and/or closure of the associated PageTiger account in order to maintain records of our services, to comply with our legal obligations and to defend our legal rights. We may also continue to send you marketing communications, subject to your right to opt out as described in paragraph 4 above.

Further information about our retention periods is available on request.

Note: We are not, however, obliged to maintain records on behalf of a customer and our standard practice is to delete information stored on behalf of a customer 90 days after termination of the relevant services.

8. ACCESSING YOUR DETAILS AND OTHER RIGHTS

You can update your contact and login details, and opt out of receiving marketing communications within a PageTiger account. Alternatively, please send us an email to support@pagetiger.com.

In accordance with data protection laws, you also have a right:

• to obtain a copy of the personal data we hold about you, together with other information about how we process it;

• to withdraw any consent which you have given relating to use of your data;

• to request rectification of inaccurate or incomplete data, and, in some circumstances, to request us to erase or restrict our use of your data, or otherwise to object to our processing of your data for direct marketing purposes or for reasons relating to your particular situation;

• to receive a copy (in a machine-readable format) of personal data which you have provided to us (otherwise known as the "right to data portability"), to the extent we process it electronically based on necessity for a contract or your consent (described as the "legal basis" in the relevant sections above);

• not to be subject to a decision based solely on automated processing, which significantly affects you, unless additional legal requirements are met; and

• to make a complaint about how we handle your data to the UK Information Commissioner's Office. Please visit www.ico.org.uk for further information about how to do this.

If you would like to access a copy of the data we hold about you or exercise any of your other rights, please send a request by email to us at: support@pagetiger.com. Please also contact us if you have any other concerns over how we use your email address or other data.

Note: Your rights under data protection laws are limited to our use of personal data relating to you as an individual, and we are not obliged to respond to requests relating to non-personal business information. As our customers are businesses, not all the information described in this privacy notice will necessarily be your personal data – this will depend on the circumstances. Note also that data protection laws provide certain exemptions to the rights listed above which we may apply on a case by case basis.

Note: To the extent we hold your personal data on behalf of a customer (as outlined at paragraph 3 above), you should direct requests and queries relating to use of such data to the customer.

9. CONTACT DETAILS

Postal correspondence should be addressed to 22 Falstaff House, Bardolph Road, Richmond, Surrey, England TW9 2LH

Email correspondence should be addressed to support@pagetiger.com