This privacy policy (“Policy”) describes how Wave Computing® (including its majority owned subsidiaries, “Wave Computing”, “Wave,” “we,” “us,” “our”) collects, uses and shares personal information of consumer users of the Wave Computing websites (the “Sites”) or any products or services available on or through the Sites. Wave Computing is the sole owner of the information collected on the Sites or through your use of the Wave Computing products and services. We will not sell, share, or rent this information to others in ways different from what is disclosed in this Policy.

Wave Computing respects your privacy, and is committed to protecting your personal data in line with applicable data protection laws and regulations, including the General Data Protection Regulation - Regulation (EU) 2016/679 (GDPR). This Policy will inform you as to how we will look after your personal data when you interact with us, including visiting our Sites. It also tells you about your rights in relation to your personal data.

What Is Personal Data, and Who Is Responsible for Looking After My Personal Data?
Personal data is any information about an identifiable individual, such as your name, address, telephone number, e-mail address, and other information you provide and/or are required to effectuate a transaction, deliver a product or communication, or provide a service. Wave Computing is responsible for personal data which we collect from you and, along with our distributors, resellers, dealers and other sales channels, we are also responsible for how we handle personal data which we collect from Wave Computing’s sales partners.

Data Collected and Its Use
Wave Computing allows you to provide us voluntarily with contact information through our website and when you purchase or redeem offers or register products you purchased from other authorized retailers. The information we may collect includes your name, email address, phone number, and past purchases. We do not collect or store credit card information. If you have requested information or if you have purchased products or services from us in the past we may use this information to provide you with news and offers for upgrades and discounts. In addition, if you contact us, we may keep a record of your communication to help solve any issues you might be facing. But we only want to stay in contact with people that are interested in what we’re doing. If you do not want to receive e-mails or other contacts from Wave Computing, Inc. you can remove yourself from our mailing lists by unsubscribing. You can unsubscribe by clicking the unsubscribe link at the bottom of any of our marketing emails, by clicking unsubscribe.

If you use a blog, bulletin board or similar means of communication on or through our Sites, please be aware that any data you submit there can be read, collected, or used by other users of these forums. Wave uses industry standard measures, including administrative, technical, and physical safeguards, to help protect personal data from loss, theft, misuse, and unauthorized access, disclosure, alteration, and destruction. However, no data transmission over the Internet can be guaranteed to be entirely secure. As a result, while we always use all reasonable efforts to protect your personal data, we cannot guarantee the security of your information and the submission of data is thus at your own risk.

Prospective employees may submit information to apply for employment with Wave Computing or affiliates, by visiting our web page(s) which may be operated by an authorized vendor. Information collected through an online job application may include personal data.

Data Integrity and Security
Wave Computing uses industry standard security measures to protect against the loss, misuse and/or alteration of data located on our systems. We implement appropriate measures and processes, such as using encryption when transmitting certain sensitive information, to help us to keep your information secure and to maintain its quality. We regularly review our security and related policies to adapt the technology as new threats evolve, and monitor our systems to help ensure the highest level of availability. If you have any questions about the security at our Sites, you may send an email to Wave at [email protected].

Lawful Grounds for Using Your Personal Data
There are various lawful grounds on which we use your personal data including the following legitimate interests:

(a) understanding how our customers use our products and services;

(b) keeping our records up to date;

(c) to develop our products and services and to grow our business;

(d) to inform our marketing strategy, including to define customers for our products and services.

Your Right To Make A Complaint And How To Contact Us
Your privacy is very important to us. You have the right to make a complaint at any time to the supervisory authority for data protection issues in your country. We would, however, appreciate the chance to deal with your concerns so if you have any questions or concerns regarding our privacy policies please contact us at [email protected].

Non-Personal Data
Wave Computing collects non-personal identification information about you whenever you interact with our website. Non-personal identification information may include browser name, type of computer, and technical information about your means of connecting to our website, such as the operating system, the Internet service provider utilized, and other similar information. We use this information to optimize and improve our website.

Cookies and Web Beacons
Wave Computing uses cookies on its website. These cookies are tracking technologies stored by your browser for record-keeping purposes. Also, through the use of cookie technology or otherwise, we may track and collect information about your computer and software when you visit the Sites or use our products or services. This information is automatically collected, and may include, but is not limited to: (i) your Internet Protocol (“IP”) address; (ii) domain server; (iii) type of computer; (iv) your operating system; (v) type of web browser and browser language; (vi) access times; (vii) pages viewed and how long you spend on a page; (viii) referring websites addresses; and (ix) other information about your use of and actions on our Sites (collectively “Traffic Data”). Traffic Data is anonymous information that does not personally identify you. Traffic Data assists us to design and arrange our web pages in the most user-friendly manner and to continually improve our Sites to better meet the needs of users. Wave Computing also analyzes the data through the use of Google Analytics and Google AdWords.

We may also use web beacons (small pieces of data that are embedded in images on the pages of websites) and auditing software to track page views and entry and exit points to and from our Sites. In addition, we may use web beacons, cookies, customized links and/or similar technologies to determine whether electronic newsletters sent by us to those who have requested them from us have been opened and which links are clicked. Any data collected will only be used in an aggregate form and will not contain any personal information.

You may choose to set your web browser to refuse cookies. Further, you may opt out of a third-party vendor’s use of cookies by using the NIA opt-out site at http://www.networkadvertising.org/choices/, or for those in Europe, the EDAA opt out site at http://www.youronlinechoices.com/. A user who does not accept cookies from our Sites may not be able to access certain areas of the Sites. Further, third-party vendors including AdRoll and Google may use the cookie information about your prior visits to the Wave Computing website in order to place targeted Wave Computing advertisements on other sites you visit.

Some Wave Computing downloads or software generate a computer ID value during installation. This computer ID value does not contain specific information about you or the data on your computer.

Surveys and Responsive Requests
If you have opted to participate, from time to time, we may request information from users via surveys or similar responsive requests. Participation in these surveys or responsive requests is completely voluntary, so the user therefore has a choice whether or not to disclose this information. Information requested may include contact information (such as name, email and shipping address), and demographic information (such as zip code, age level). If you give us personal information about somebody else, such as a spouse or work colleague, we will assume that you have their permission to do so. Survey information may be used to monitor or improve the use and satisfaction of the Sites or our products and services.

Information Sharing and Disclosure
Wave Computing will not sell or rent any personal data, except to successors in interest, without your consent. Wave Computing reserves the right to release account information when exchanging information with other companies and organizations for fraud protection and credit risk reduction.

Wave Computing will send personal data when it needs to share information to provide the product or service you have requested, to send the information to companies who work on behalf of Wave Computing to provide a service to you, to respond to subpoenas, court orders or legal process, or if Wave Computing finds that your actions on our Web sites violate our usage guidelines. This policy does not protect information you post to any on-line bulletin board, chat room, newsgroup or other public forum from within our Web sites.

If Wave is involved in a merger, acquisition or asset sale, such information may be shared with the acquiring entity or successor-in-interest, but we will continue to ensure the confidentiality of any personal data pursuant to the terms of this Policy.

We may also share personal data in the event of an emergency, for the protection and safety of our employees and agents, our customers, or any other person, and we also 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.

Recipient List
The third parties to whom we may disclose your personal data for the purpose of providing services to us are listed on the personal data disclosure page. The personal data disclosure page will also specify the nature of the service provided.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes, and we only permit our third-party service providers to process your personal data for purposes we specify and in accordance with our instructions.

International Transfers
Wave Computing is an entity based in the United States of America, but many of our service providers are based outside of the European Economic Area (EEA). Whenever we may transfer your personal data out of the EEA, we take steps to implement a similar degree of protection by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
• Where we use certain service providers, we may use specific contracts approved by the European Commission which confers upon personal data the same protection that personal data has in Europe.
• Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

Other Sites
Wave Computing contains links to other sites on the Web. Wave Computing has no control over these external sites and is not responsible for the privacy practices or content of these sites. We advise you to read the privacy policies of those websites thoroughly so that you are aware of the manner in which those websites will use your personal data.

Wave Computing reserves the right to remove content that does not comply with the conduct stated above or is otherwise deemed objectionable. Wave Computing reserves the right, in its sole discretion, to terminate your access to any part or this entire site without notice.

How Long Will We Keep Your Personal Data For?
We will retain your personal data only for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data, whether we can achieve those purposes through other means, and the applicable legal requirements for each.

In some circumstances, you can ask us to delete your data: see the “Your rights” section below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

Your Rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. We have explained your rights below; if you wish to exercise any of your rights, please contact us at [email protected].

You have the right to:

• Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you do not want to receive promotional or other e-mail from Wave Computing, Inc. you can remove yourself from our mailing lists.

No Fee Usually Required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What We May Need from You
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Choice and Access; Time Limit to Respond
We will provide individuals with an opt-out or opt-in choice before we share their data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized.

To limit the use and disclosure of your personal information, please submit a written request to [email protected]. EU and Swiss individuals have the right to access the personal information that we maintain about them. An EU or Swiss individual who seeks access, or who seeks to correct, amend, or delete inaccurate data, should direct their query to [email protected]. If requested to remove data, we will respond within a prompt, reasonable timeframe.

Acceptance of Privacy Policy
By using the Sites, you consent to the collection, use and storage of your information by us in the manner described in this Policy. We reserve the right to make changes to this Policy at any time. If we decide to change our Policy, we will post those changes on our Sites so that our users are aware of what information we collect, how we use such information, and under what circumstances, if any, we disclose such information.

If you do not agree with this Policy, please do not use our Sites. Your continued use of our Sites following posting of changes to these terms will mean you accept those changes.

Children’s Privacy
The Children’s Online Privacy Protection Act restricts the collection and use of Personal Information pertaining to children under the age of 13. We do not allow such children to register as users and will not knowingly collect or solicit Personal Information from anyone under the age of 13. No one under the age of 13 should provide any Personal Information on or through this Site or otherwise. In the event we learn that we have collected Personal Information from a child under age 13, we will terminate the any account and communications, and delete such information. If you believe that we might have any information from or about a child under 13, please contact us at [email protected]. Minors aged 13 and over should not use this site or post any information or other content without adult supervision.

California Notices
Users who reside in California and have provided personal data to us have the right to receive: (a) information identifying any third party to whom we may have disclosed, within the past year, personal data pertaining to you and your family for that party’s direct marketing purposes; and (b) a description of the categories of personal data disclosed. To obtain such information, please email your request to [email protected]. This request may be made no more than once per calendar year. We reserve our right not to respond to requests submitted other than to the address specified in this paragraph.

Contact us: If you have comments or questions, you can email us or send us mail at the address below. Please include your contact information and a detailed description of your request or privacy concern.

Wave Computing, Inc.
Attn: Legal
300 Orchard City Drive, Suite 170
Campbell, California 95008
[email protected]