Privacy Policy for Website Visitors

ALLVUE SYSTEMS’ WEBSITES PRIVACY POLICY
July 1, 2020

This privacy policy (this “Policy”) describes how Allvue Systems, LLC (“Allvue,” “we,” “us,” “our”) collects, handles, secures, shares and uses the personal information you, as a visitor to our websites (“you” or “your”), provide through any of Allvue’s website(s) (each, a “Website”). It also describes your choices regarding use, access, and correction of your personal information. For purposes of this privacy policy, personal information is information that can be used to identify an individual.

SCOPE
This Policy applies only to the personal information collected from visitors (i.e., users) to our Websites, but this Policy does not describe the treatment of data (including personal information) used, processed or collected in connection with the use of Allvue’s software products or services or personal information in connection with employment opportunities with Allvue.

COLLECTION PURPOSES, USE OF PERSONAL INFORMATION
Personal information you provide to us through our Websites. When you request information, a free demo, schedule a consultation, respond to an online survey, or otherwise contact us, you are providing us with personal information which we collect. Such personal information may include the following:

By providing us with the above personal information, you consent to your information being collected, used, disclosed, processed and stored by us in accordance with this Policy.

You can opt out of providing personal information by not entering it when asked. If personal information is required in order to allow us to respond to your inquiry, you will receive a notice advising you of this. If you do not provide us with some or all of the requested personal information, we may not be able to provide the requested information or services to you.

Information Allvue collects automatically through our Websites. Our Websites also collect certain information by automated means. For example, when you visit a Website, we track certain information about your computer and Internet connection, such as the IP address of your computer and/or Internet service provider, the date and time you access the site, the Internet address of website from which you link to our Website, the computer technology you are using and your movements and preferences on our site.

Allvue also uses cookies. For more information about cookies and how we use them, please read our cookie page.

Personal information collected through third-party sources. Although not obtained through our Websites, we also obtain personal information about you from third party sources as permitted by applicable law, such as:

Allvue Website Employment Opportunities. As part of our hiring activities, our Websites have features for visitors to submit different types of personal information in connection with employment opportunities with Allvue. This Policy does not address Allvue’s collection of such personal information.

How we use personal information. Allvue will use your personal information for the following purposes:

If you wish to subscribe to our newsletter(s), we will use your name and the email address provided to send the newsletter to you. If you wish to no longer receive these emails you can also unsubscribe from our marketing communications by following the unsubscribe mechanism in the applicable e-mail message. Please note that if you do opt-out of receiving marketing- related emails from Allvue, we may still send you important administrative messages, and you cannot opt-out from receiving account-related or other administrative messages.

DATA TRANSFERS TO THIRD PARTIES
Allvue does not sell or loan personal information to any third parties; however, Allvue may share your personal information with third parties only in the ways that are described in this Policy. We rely on service providers to perform a variety of services on our behalf. In so doing, we may need to share your personal information with them. Please note that we only provide our service providers with the personal information they need to perform their services and we require that they protect this information and not use it for any other purpose. These service providers are also not permitted to use your personal information for their own promotional or business purposes.

We may share your business contact information with our trusted business partners, with whom we have a strategic partnership, or our investors.

Your information may also be transferred to another company in connection with a corporate transaction, such as a divestiture, merger, acquisition, consolidation, or asset sale (or the negotiation thereof) of a substantial amount or all of the assets of Allvue, or in the unlikely event of bankruptcy. We may assign or transfer your information as part of the transaction.

Finally, with respect to personal information we collect as part of our hiring activities, we may disclose your personal information to our partners to include our service providers and private equity sponsor, Vista Equity Partners, and its affiliates, including Vista Consulting Group (collectively, “Vista”), for administration, research, database development and business operation purposes, in line with the terms of this Policy. Vista processes your personal information on the basis of its legitimate interests in overseeing the recruitment process and, if applicable, your employment relationship with Allvue. If you have consented to us doing so, we also share your personal information with other Vista portfolio companies for the purpose of being considered for other job opportunities in the pooling system, both inside and outside the EEA. Please find a full list of all Vista portfolio companies at: https://www.vistaequitypartners.com/companies/.

LINKS TO OTHER SITES AND SOCIAL MEDIA
Our Website includes links to other websites and Social Media whose privacy practices may differ from those of our Website. If you submit personal information to any of those other websites, your information is governed by their specific privacy policies. We encourage you to carefully read the privacy policy of any website that you visit.

OTHER DISCLOSURES
Allvue will share your personal information with third parties only in the ways that are described in this Policy unless we obtain your consent otherwise, except in the following instances: (i) as required by law, (ii) in response to lawful requests by public authorities, including to meet national security or law enforcement requirements, or (iii) when we believe that disclosure is necessary to to comply with a judicial proceeding, court order, or legal process served on our Websites, (iv) to respond to any other government-related request, (v) to protect our rights and interests (including without limitation, for our own safety), (vi) to protect your interests (including without limitation, for your safety), (vii) to protect the interests of others (including without limitation, for their safety), or (viii) to investigate alleged or actual fraud, misrepresentation or other misconduct.

SECURITY
Allvue maintains appropriate physical, technical, administrative, and organizational security measures to protect personal information from loss, misuse, and unauthorized access, disclosure, alteration, and destruction, including where appropriate:

All our employees, contractors and data processors who have access to, and are associated with, the processing of your personal information are obligated to keep the information confidential and not use it for any other purpose than to carry out the services they are performing for us.

RETENTION
Allvue will retain your information for so long as we have an ongoing legitimate business interest, including for as long as your account is active, or you have not unsubscribed or otherwise contacted us directly to remove your information from our database, or as necessary for the following purposes:

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

CROSS BORDER TRANSFERS
Personal information will not be transferred outside of the European Economic Area or the United States (where the EU-US Privacy Shield Framework applies) without additional contractual or extra contractual measures that have been adopted or approved by the European Commission being taken.

Allvue complies with the EU-US Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal data transferred from the European Economic Area to the United States.

Allvue has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view Allvue’s certification, please visit https://www.privacyshield.gov.

With respect to personal information received or transferred pursuant to the Privacy Shield Framework, Allvue is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission and commits to cooperate with EU data protection authorities.

DATA ACCESS
Allvue takes reasonable steps to determine who gains access to Personal Information. Allvue’s User Access Management guidelines are based on the “Principle of Least Privilege,” and access to Personal Data shall be limited by that principle, which requires that privileged access must be provisioned with the minimum level of access to non-public data which is required to satisfy a user’s job responsibilities.

GENERAL DATA REQUESTS
Allvue acknowledges that you have the right to access your personal information. If your personally identifiable information changes, or if you no longer desire our service, you may choose to correct, update, delete/deactivate or access it by emailing us directly at dataprivacy@allvuesystems.com. We will respond to your request within a reasonable timeframe, not to exceed thirty (30) days.

DISPUTE RESOLUTION
Allvue commits to resolve complaints regarding processing, use and disclosure of Personal Data in accordance with this Policy. Individuals with inquiries or complaints regarding Allvue’s compliance with this Policy should first contact Allvue at dataprivacy@allvuesystems.com. Allvue will investigate and attempt to resolve all complaints and disputes.

Allvue has a policy of responding to individuals within forty-five (45) days of a complaint. If an individual has an unresolved complaint or concern that is not addressed satisfactorily or timely, that individual may contact our U.S. based third party dispute resolution provider (free of charge), the International Center for Dispute Resolution/American Arbitration Association (“ICDR/AAA”). Please contact or visit ICDR/AAA for more information or to file a complaint (http://go.adr.org/privacyshield.html).

In certain circumstances, you may have the ability to invoke binding arbitration to address any complaint that Allvue has violated its obligations under this Policy to you and has not been otherwise resolved such violation.

HOW TO CONTACT US
If you have any questions regarding this Policy or if you need to request access to or update, change or erase your personal information that Allvue processes on your behalf, you can do so by contacting:

Allvue’s Systems Privacy Team at:
396 Alhambra Cir | Suite 1100 | Coral Gables | FL 33134
Main: +1.305.901.7060
Email: dataprivacy@allvuesystems.com

AMENDMENTS
Allvue reserves the right to change, modify, add or remove portions of this Policy from time to time and in its sole discretion but will update the public that changes have been made by indicating on this Policy the date it was last updated.