GATEWAY CHECKER CORPORATION PRIVACY POLICY
(GCC PP Rev. 15-FEB-20)

This Privacy Policy (“Privacy Policy”) applies to your (“You” and/or “Your”) use of the web services (the “Services”) offered Gateway Checker Corporation (“Gateway Checker”, “We”, “Us,” and/or “Our”)and its affiliates, the website located at www.gatewaychecker.com (the “Gateway Checker Site”) , and other interactions (e.g., customer service inquiries, user Communities, user conferences, etc.) You may have with Us (You, Your, We, Us, and/or Our may collectively be referred to as the “Parties” and individually as “Party”). The Gateway Checker Corporation “Terms of Use”, a copy of which can be located at www.gatewaychecker.com/legal, is hereby incorporated by reference. All capitalized terms not defined herein shall have the meaning set forth in the Terms of Use, as defined therein. If You do not agree to be subject to the terms and conditions of the Terms of Use and this Privacy Policy, do not access or use the Services, the Gateway Checker Site or any other aspect of Our business.

WHAT INFORMATION WE COLLECT

We may ask You to register and provide information when You register as a visitor to the Gateway Checker Site, purchase Services or place orders, register to access an online demonstration or respond to a marketing campaign. We may also receive Your information if You participate in a focus group, contest, activity or event, apply for a job, request support, interact with Our social media accounts or otherwise communicate with Us. We may collect and receive use Your Data and other information and data in a variety of ways through user Data.

We also collect, generate and/or receive information, as follows:

1. Account Information. To create or update a Service or user account, You shall supply Us with an email address, phone number, password, domain and/or similar details.

2. Usage Information.

(a). Services Metadata. When an Authorized User interacts with the Services, metadata may be generated that provides additional context about the way Authorized Users work.

(b). Log Data. As with most websites and technology services delivered over the Internet, Our servers automatically collect information when You access or use the Gateway Checker Site or some of Our Services and record it in log files. This log data may include the Internet Protocol (“IP”) address, the address of the web page visited before using the Gateway Checker Site or Services, browser type and settings, the date and time the Services were used, information about browser configuration and plugins, language preferences and cookie data.

(c). Device Information. We collect information about devices accessing the Services, including type of device, what operating system is used, device settings, application IDs, unique device identifiers and crash data. Whether We collect some or all of this Other Information often depends on the type of device used and its settings and the Services being used.

(d). Location Information. We receive information from You, Your user and other third parties that helps Us approximate Your location. We may, for example, use a business address submitted by Your employer, or an IP address received from Your browser or device to determine approximate location. We may also collect location information from devices in accordance with the consent process provided by Your device.

3. Cookie Information.

We use Cookies and similar technologies in the Gateway Checker Site and Services that help Us collect Other Information. The Gateway Checker Site and Services may also include Cookies and similar tracking technologies of third parties, which may collect Other Information about You via the Gateway Checker Site and Services and across other websites and online services. For more details about how We use these technologies, please see below.

4. Third Party Services.

Users can choose to permit or restrict third-party services for their Services. Typically, third-party Services are software that integrate with Our Services, and You can permit its Authorized Users to enable and disable these integrations for their accounts. Once enabled, the provider of a third-party service may share certain information with Us. Authorized Users should check the privacy settings and notices in these third -party services to understand what data may be disclosed to Us. When a third-Party Service is enabled, We are authorized to connect and access other information made available to Us in accordance with Our agreement with the third-party Provider. We do not, however, receive or store passwords for any of these third-party services when connecting them to the Services.

5. Third-Party Data.

We  may  receive  data  about  organizations, industries,  the  Gateway  Checker  Site  visitors,  marketing campaigns and other matters related to Our business from parent corporation(s), affiliates and subsidiaries, Our partners or others that We use to make Our own information better or more useful. This data may be combined with Other Information We collect and might include aggregate level data, such as which IP addresses correspond to zip codes or countries (e.g. how well an online marketing or email campaign performed, etc.).

6. Additional Information Provided to Us.

We receive Other Information when submitted to the Gateway Checker Site or if You participate in a focus group, contest, activity or event, apply for a job, request support, interact with Our social media accounts or otherwise communicate with Us. Generally, no one is under a statutory or contractual obligation to provide any user Data or Other Information (collectively, Information). However, certain Information is collected automatically and, if some Information, such as account setup details, is not provided, We may be unable to provide the Services.

HOW WE USE THE COLLECTED INFORMATION

User Data will be used by Us in accordance with user’s instructions, including any applicable terms in the user Agreement and user’s use of Services functionality, and as required by applicable law. We are a processor of user Data and user is the controller. User may, for example, use the Services to grant and remove access to an account, assign roles and configure settings, access, modify, export, share and remove user Data and otherwise apply its policies to the Services. We use Other Information in furtherance of Our legitimate interests in operating Our Services, the Gateway Checker Site and business. More specifically, We use Other Information:

1. To provide, update, maintain and protect Our Services, the Gateway Checker Site and busines This includes use of Other Information to support delivery of the Services under a user Agreement, prevent or address service errors, security or technical issues, analyze and monitor usage, trends and other activities or at an Authorized User’s request.

2. As required by applicable law, legal process or regulation.

3. To communicate with You by responding to Your requests, comments and questions. If You contact Us, We may use Your Other Information to respond.

4. To develop and provide search, learning and productivity tools and additional features.

5. To send emails and other communication We may send You service, technical and other administrative emails, messages and other types of communications. We may also contact You to inform You about changes in Our Services, Our Services offerings, and important Services-related notices, such as security notices. These communications are considered part of the Services and You may not opt out of them. In addition, We sometimes send emails about new product features, promotional communications or other news about Our company. These are marketing messages, so You can control whether You receive them.

6. For billing, account management and other administrative matte We may need to contact You for invoicing, account management and similar reasons and We use account data to administer accounts and keep track of billing and payments.

7. To investigate and help prevent security issues and abuse.

If Information is aggregated or de-identified so it is no longer reasonably associated with an identified or identifiable natural person, We may use it for any business purpose. To the extent Information is associated with an identified or identifiable natural person and is protected as personal data under applicable data protection law, it is referred to in this Privacy Policy as Personal Data. Contact the user if You wish to request the removal of Personal Data under their control.

DATA RETENTION

We will retain user Data in accordance with a user’s instructions, including any applicable terms in the user Agreement and user’s use of Services functionality, and as required by applicable law. Depending on the Services, user may be able to customize its retention settings and apply those customized settings at the account level. We may retain Other Information pertaining to You for as long as necessary for the purposes described in this Privacy Policy. This may include keeping Your Other Information after You have deactivated Your account for the period of time needed for Us to pursue legitimate business interests, conduct audits, comply with (and demonstrate compliance with) legal obligations, resolve disputes and enforce Our agreements.

WHO WE SHARE DATA WITH

We may share the information You provide with Our business partners acting on Our behalf for the uses described above. We do not sell Your information to third parties.

HOW WE OFFER OUR CUSTOMERS A CHOICE

If You do not want Us to contact You or Your company for marketing purposes by email, postal mail, fax or phone, You may opt out by contacting Our customer service department or by sending an email or writing to Us at the below address. Please note that We do not allow Our Customers to opt out of contact that is required for the functionality of Our Services or to maintain user accounts.

SECURITY OF YOUR INFORMATION

We use state-of-the-art security technology to protect Our user Data, and access to user information is restricted to authorized personnel only. We are very sensitive to the privacy concerns of Our Customers and visitors to the Gateway Checker Site.

CHILDREN, YOUNG ADULTS, AND PRIVACY

We do not knowingly target or solicit personal information from children under the age of 18 or send them requests for personal information.

THIRD-PARTY SITES

The Gateway Checker Site may contain links to websites operated by third parties. We do not share Your personal information with those websites and We are not responsible for their privacy practices. Once You have left Our site, You should check the applicable privacy statement of the third-party website to determine how they handle information they collect from You. Please view the privacy policies of those companies by visiting their respective websites.

USE OF COOKIES

1. Cookie Tracking Technology.

We use cookies and other similar tracking technologies to remember Your preferences with the Gateway Checker Site, improve Your user experience, and provide You with relevant information (“Cookies”). You can learn more about how cookies are used at the Digital Advertising Alliance (www.aboutads.info/choices), the Digital Advertising Alliance of Canada (www.youradchoices.ca/), and/or the European Interactive Digital Advertising Alliance (www.youronlinechoices.eu/).

2. The Information You Provide.

You may provide information to Us including, but not limited to, Your name, e-mail address, and credentials. Submitting this information to Us is voluntary, and You will still have access to the Gateway Checker Site without providing the information, except when needed to provide the information to access certain pages, resources, user groups, services or features.

3. Automated Information Collected.

The Gateway Checker Site may automatically collect information about You during Your visit. Cookies can be accepted or declined in Your browsers setting. Examples of information We may collect include browser type, operating system, pages You view, links You click on, and Your IP address.

4. How do We Use This Information.

We use information collected to provide You with information about products and services We offer, increase Your user experience, and collect data to produce and provide You with information relating to Your activity on the Gateway Checker Site.

ADDITIONAL THIRD-PARTY COOKIES

We may provide links to third-party websites or content. We have no control over Cookies, external or third- party websites set when You interact with the link or their website.

We may utilize web beacons, images or scripts to collect data about Your visit and user behavior with Gateway Checker Site. Information collected from any of these include Your Cookies, time information of Your site visit and a description provided about Your visit.

We  may  collect  Your  IP  address,  operating  system  and  browser  information to  track  non-personal information including Your user-behavior on the Gateway Checker Site navigation flow. Information collected is used for marketing purposes and to help manage the Gateway Checker Site by providing relevant content.

Other third-party tracking may be used on the Gateway Checker Site. We do not provide personal information to third parties.

To delete and block Cookies please see the settings on Your browser which allow You to set Your preferences and/or settings.

To withdraw consent to collect Cookies, You will need to delete the Cookies in Your browser settings and adjust Your preferences to block Cookies in Your browser preferences/settings. Cookies are used to identify You and Your user behavior and does not give access to Your computer. This privacy and Cookie policy does not cover the use of Cookies or similar technology by other sites which We have no control or access of. By visiting and navigating through the Gateway Checker Site, You are agreeing to the use of Cookies and similar technologies for the purposes We describe in this Privacy Policy.

SOCIAL MEDIA

We use social media features on the Gateway Checker Site, including like and share button features. Using social media features may initiate information to be collected such as Your IP address and pages You navigate. Each social media feature has their own privacy policy as listed below:

1. Twitter. Twitter Cookies are used on the Gateway Checker Site to share content with Our audien Twitter uses Cookies to understand user behavior on a website and how users interact with services, monitor usage, and traffic. To remove or block Twitter Cookies, please adjust Your preferences to block Cookies in Your browser preferences/settings. For more on Twitter’s Private Policy go to www.twitter.com/privacy.

2. LinkedIn. LinkedIn Cookies are used on the Gateway Checker Site using sharing and other featur LinkedIn also uses AppNexus to help deliver remarketing ads based on a visit, interest or target audience list. Cookies could be utilized to recognize a visit on the Gateway Checker Site and on LinkedIn, remember preferences, and provide a personalized experience. LinkedIn uses two types of Cookies: persistent Cookies and session Cookies. A persistent cookie helps recognize an existing user, to simplify identifying You. After You sign in, a persistent cookie stays in Your browser and will be read by LinkedIn. Session Cookies only last the duration of Your current session. For more information on LinkedIn’s Privacy Policy go to  www.linkedin.com/legal/privacy-policy.

3. Facebook. We use Facebook as an advertising channel to display Our sponsored post and remarketing ads to visitors of the Gateway Checker Site who may be interested in Our Services. We also use Facebook Cookies to help measure performance of ad campaigns, including insights of the audience interacting with Our ads on the Facebook network. Facebook and any third-party vendors use Cookies to show remarketing ads. Cookies are used to track remarketing ads and serve ads based on Your past visits to the Gateway Checker Third-party Cookies are not controllable by Us. For more information about Facebook Cookies please go to www.facebook.com/policies/Cookies. For more on Facebook’s privacy policy please go to www.facebook.com/privacy/explanation. To set Your Facebook ad preferences please visit www.facebook.com/ads/preferences/edit/.

INTERNATIONAL DATA TRANSFERS

We may transfer Your Personal Data to countries other than the one in which You live. We deploy the following safeguards if We transfer Personal Data originating from the European Union to other countries not deemed adequate under applicable data protection law.

GENERAL DATA PROTECTION REGULATION (EU) 2016/679

Where and only to the extent that We process Your Data, on Your behalf, under the requirements of the EU’s General Data Protection Regulation (EU) 2016/679 (“GDPR”), We and You hereby agree to comply with the following provisions with respect to any Personal Data, defined below, which is subject to the GDPR’s requirements, each acting reasonably and in good faith.

1. GDPR Specific Definitions.

“Data Subject” means the identified or identifiable person to whom Personal Data relates.

“Data Subject Request” means a request from a Data Subject to exercise the Data Subject’s rights under the GDPR including the right of access, right to rectification, restriction of Processing, erasure (“right to be forgotten”), data portability, object to Processing, or its right not to be subject to automated individual decision making.

“Personal Data” means any information relating to (i) an identified or identifiable natural person and, (ii) an identified or identifiable legal entity (where such information is protected similarly as personal data or personally identifiable information under the GDPR), where for each (i) or (ii), such data is Your Data.

“Processing” means any operation or set of operations which is performed upon Personal Data, whether or not by automatic means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

“Sub-processor” means any Processor that may be engaged by Us.

“Supervisory Authority” means an independent public authority, which is established by an EU Member State pursuant to the GDPR.

2. Processing of Personal Data.

(a) Roles of the Parties. The Parties acknowledge and agree that where Your use of the Services includes processing, which is subject to GDPR requirements with regard to the Processing of Personal Data, You are the Controller, We are the Processor, and may engage Sub-processors pursuant to the requirements set forth herein.

(b) Your Processing of Personal Data. Where Your use of the Services includes processing, which is subject to GDPR requirements, You shall Process Personal Data in accordance with the GDPR requirements directly applicable to Our provision of its Services.  For clarity, Your instructions for the Processing of Personal Data shall comply with GDPR. You shall have sole responsibility for the accuracy, quality, and legality of Personal Data and the means by which You acquired Personal Data.

(c) Our Processing of Personal Data. We shall treat Personal Data as Confidential Information and shall only Process Personal Data on behalf of and in accordance with Your written instructions, which shall include email from You, for the following purposes: (i) Processing in accordance with applicable Order Form(s) and related documents; (ii) Processing initiated by Users in their use of the Services; and (iii) Processing to comply with other documented reasonable instructions provided by You (e.g., via email) where such instructions are consistent with the terms contained herein.

(d) Data Protection Impact Assessment. Upon Your request, We shall provide You with reasonable cooperation and assistance needed to fulfil Your obligation under GDPR to carry out a data protection impact assessment related to Your use of the Services, to the extent You do not otherwise have access to the relevant information, and to the extent such information is available to Us. We shall provide reasonable assistance to You in the cooperation or prior consultation with the Supervisory Authority in the performance of its tasks herein or to the extent required under the GDPR.

3. Rights of Data Subjects.

Taking into account the nature of the Processing, We shall use commercially reasonable efforts to assist You by appropriate technical and organizational measures, insofar as this is possible, to fulfil Your obligation to respond to a Data Subject Request under the GDPR. In addition, to the extent You, in Your use of the Services, do not have the ability to address a Data Subject Request, We shall upon Your request use commercially reasonable efforts to assist You in responding to such Data Subject Request, to the extent We are legally permitted to do so and the response to such Data Subject Request is required under the GDPR. You shall be responsible for responding to all Data Subject Requests and for any and all costs, at Our then-current commercial rate, arising from Our provision of such assistance.

4. Our Personnel.

We shall ensure that our personnel engaged in the Processing of Personal Data are informed of the confidential nature of the Personal Data, have received appropriate training on their responsibilities and have executed written confidentiality agreements. We shall ensure that such confidentiality obligations survive the termination of the personnel engagement. We shall take commercially reasonable steps to ensure the reliability of any of Our personnel engaged in the Processing of Personal Data. We shall ensure that Our access to Personal Data is limited to those personnel performing Services in accordance with the Agreement. We have appointed a data protection officer. The appointed person may be reached at  legal@nullgatewaychecker.com.

5. Sub-Processor.

You acknowledge and agree that We may engage third-party Sub-processors in connection with the provision of the Services. We will enter into a written agreement with each Sub-processor containing data protection obligations not less protective than those in this Agreement with respect to the protection of Your Data to the extent applicable to the nature of the Services provided by such Sub-processor.

6. Security.

We shall maintain appropriate technical and organizational measures for protection of the security (including but not limited to protection against unauthorized or unlawful Processing and  against accidental or  unlawful

destruction, loss or alteration or damage, unauthorized disclosure of, or access to, Your Data), confidentiality and integrity of Your Data, in accordance with then-current industry best-practices. We shall use commercially reasonable efforts to monitor compliance with these measures, in accordance with then-current industry best-practices. We will not materially decrease the overall security of the Services during the Agreement term.

7. CLIENT DATA INCIDENT MANAGEMENT AND NOTIFICATION

We shall notify You without undue delay after becoming aware of the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to Your Data, including Personal Data, transmitted, stored or otherwise Processed by Us or Our Sub-processors of which We become aware (a “Your Data Incident”). We shall make reasonable efforts to identify the cause of such a Your Data Incident and take those steps as We deem necessary and reasonable in order to remediate the cause of such a Your Data Incident to the extent the remediation is within Our reasonable control. The obligations herein shall not apply to incidents that are caused by You or Your Users.

8. Return and Deletion of Client Data.

Upon written request from You or upon termination of the Agreement, We shall return Your Data to You and, to the extent allowed by applicable law, delete Your Data.  We reserve the right to charge a reasonable fee for the return of  Your Data.

YOUR RIGHTS

Individuals located in certain countries, including the European Economic Area, have certain statutory rights in relation to their personal data. Subject to any exemptions provided by law, You may have the right to request access to Information, as well as to seek to update, delete or correct this Information.

To the extent that Our processing of Your Personal Data is subject to the General Data Protection Regulation, We rely on Our legitimate interests, described above, to process Your data. We may also process Other Information that constitutes Your Personal Data for direct marketing purposes and You have a right to object to Our use of Your Personal Data for this purpose at any time.

CHANGES TO THIS PRIVACY POLICY

We may amend this Privacy Policy from time to time. Laws, regulations and industry standards evolve, which may make those changes necessary, or We may make changes to Our business. If We make any substantial changes in the way We use Your personal information, We will make that information available by posting a notice on the Gateway Checker Site.

QUESTIONS OR SUGGESTIONS

Please also feel free to contact Us if You have any questions about this Privacy Policy or Our practices, or if You are seeking to exercise any of Your statutory rights. You may contact Us here or at Our email address at info@nullgatewaychecker.com.

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