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Idera Notice of Certification Under the EU-US Privacy Shield Framework and Swiss-US Privacy Shield Framework

Effective for Idera, Inc. and its subsidiaries on April 23, 2018.

Idera, Inc. and its United States subsidiaries, CopperEgg Corporation, Uptime Software, Inc., AquaFold, Inc, Embarcadero Technologies, Inc., Sencha, Inc., Precise Software Solutions, Inc. and Whole Tomato Software, LLC (collectively, “Idera”), participate in the EU-US Privacy Shield Framework and Swiss-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information transferred from European Union member countries and Switzerland to the United States, respectively. Idera has certified with 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 principles, please visit https://www.privacyshield.gov/welcome.

In compliance with the EU-US and Swiss-US Privacy Shield Principles, Idera commits to resolve complaints about your privacy and our collection or use of your personal information. European Union or Swiss individuals with inquiries or complaints regarding this privacy policy should first contact Idera at compliance@idera.com.

Idera has further committed to refer unresolved privacy complaints covering non-Human Resource data under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU Privacy Shield, operated by the Council of Better Business Bureaus. 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. If your concern continues to be unresolved, you may pursue binding arbitration through the Privacy Shield Arbitration Panel. To learn more about the Privacy Shield Panel, please visit https://www.privacyshield.gov/article?id=F-The-Arbitration-Panel.

Please note that Idera also receives some data via other compliance mechanisms, including data processing agreements based on the EU Standard Contractual Clauses.

In regard to Human Resource data, Idera commits to cooperate with the panel established by the EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner, as applicable and comply with the advice given by them with regard to human resources data transferred from the European Union and Switzerland, as applicable in the context of the employment relationship. For more information about Idera Human Resource data and the Human Resource Privacy Policy, please contact humanresources@idera.com. As an employee, you can always review Idera Human Resource Privacy Policy here.

As explained in our Privacy Statement we sometimes provide personal information (such as name, email address, purchases, and billing information) to third parties to perform services on our behalf, or in response to contractual requirements. If we transfer personal information received under the Privacy Shield to a third party, the third party’s access, use, and disclosure of the personal data must also be in compliance with our Privacy Shield obligations, and we will remain liable under the Privacy Shield for any failure to do so by the third party unless we prove we are not responsible for the events giving rise to such failure to comply with the Privacy Shield obligations.

European Union individuals and Swiss individuals have rights to access personal data about them, and to limit use and disclosure of their personal data. With our Privacy Shield certification, Idera has committed to respect those rights. If you wish to access, to limit use, or to limit disclosure, please access your customer account after you enter your customer log in information and revise the information that you entered into our system or contact us at compliance@idera.com and we will assist you through this process.

Idera is subject to the investigatory and enforcement powers of the US Federal Trade Commission. Idera may be required to disclose personal information that we handle under the Privacy Shield in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

If you have any questions about our handling of your personal data under Privacy Shield, or about our privacy practices generally, please contact us at compliance@idera.com or at our mailing address below. We will work with you to address your inquiry in a timely manner.

Idera Inc.
Attn: Legal Department
2950 North Loop Freeway West
Suite 700
Houston, Texas 77092