PRIVACY POLICY
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PRIVACY POLICY
November 3, 2016

July Systems, Inc. (“July Systems”, “our”, “us” or “we”) provides this Privacy Policy to inform you of our policies and procedures regarding the collection, use and disclosure of personal information we receive from users of www.JulySystems.com (this “Site”) and our corresponding software applications and interactive services for devices (each an “App”).

This Privacy Policy may be updated from time to time. We will notify you of any material changes by posting the new Privacy Policy on the Site. You are advised to consult this policy regularly for any changes. Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Terms of Service, accessible at http://July Systems.com/privacy-policy.

Information Collected
July Systems may collect information from you in several ways.

When you use our website, you may choose to provide certain information directly to us to request more information or services, including personally identifiable information (“Personal Information”), for example, your name, email address, company name, phone number and other information.
When you visit our Website or use an App, some information will be automatically collected. For example, when you visit our Website your computer’s operating system, Internet Protocol (IP) address, access times, browser type and language, and the website you visited before our site are logged automatically (“Usage Information”). In addition, when you use an App, the following types of Usage Information may all be logged automatically:

•Type of mobile device you use
•Operating system of your mobile device
•Wireless carrier
•Browser type
•precise geographic location (Technical information about your device, system, App software, and peripherals

We may place “cookies” on your computer’s hard drive. A cookie is a small data file that we transfer to your computer or mobile device’s hard disk for record-keeping purposes. We use cookies for two purposes. First, we utilize persistent cookies to save your login information for future logins to the Site and App. Second, we utilize session ID cookies to enable certain features of the Site and App, to better understand how you interact with the Site and App and to monitor aggregate usage by users and web traffic routing on the Site and App. Unlike persistent cookies, session cookies are deleted from your computer when you log off from the Site, App and Service and then close your browser.

Third-party advertisers on the Site and App may also place or read cookies on your browser. You can instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. If you do not accept cookies, however, you may not be able to use all portions of the Site and App or all functionality of the applicable Service. While most browsers are set up to automatically accept cookies, you may change your settings to prevent this from happening. Please note that not accepting cookies may prohibit our Site and other Web pages from operating properly in providing you with a personalized experience.


Use of Information
We use Personal Information and Usage Information for the following purposes:

•operate and improve our Website, Apps, products, and services;
•understand you and your preferences to enhance your experience and enjoyment using our Website, Apps, products, and services;
•track, collate, and analyze your use of the Website and/or App, and your progress in
•respond to your comments and questions and provide customer service;
•provide and deliver products and Services you request;
•to send you related information, including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages;
•link or combine it with other personal information we get from third parties, to help understand your needs and provide you with better service.
• We store and process your Personal Information in the United States.

Sharing of Information
We do not share your personal information with third parties other than as follows:

•with your consent, for example, when you agree to our sharing your information with other third parties for their own marketing purposes subject to their separate privacy policies;
•our resellers, distributors, and other service providers who work with us and need access to your information to do that work;
•to (i) comply with laws or to respond to lawful requests and legal process, (ii) to protect the rights and property of July Systems, our agents, customers, members, and others including to enforce our agreements, policies and terms of use or (iii) in an emergency to protect the personal safety of July Systems, its customers, or any person;
•in connection with or during negotiation of any merger, financing, acquisition, or dissolution, transaction or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets to another company.
We may also share aggregated anonymous or de-identified information.

Opt-Out
Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Website.

Children
The Website is not directed to children under the age of 13.

European Users
July Systems complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union to the United States.

July Systems 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 privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit http://www.privacyshield.gov.

Our participation in the Privacy Shield applies to all Personal Information that is received from the European Union and European Economic Area. July Systems will comply with the Privacy Shield Principles in respect of such Personal Information.

July Systems has also certified to the Department of Commerce that it adheres to the U.S.-Swiss Safe Harbor Framework and its principles.

July Systems remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process the Personal Information on its behalf do so in a manner inconsistent with the Principles, unless July Systems proves that it is not responsible for the event giving rise to the damage.

You may request access to any Personal Information maintained on you by July Systems at any time by emailing privacy@julysystems.com.

For complaints left unresolved by all other available mechanisms, you may invoke binding arbitration the Privacy Shield Panel, which consists of a pool of 20 arbitrators designated by the Department of Commerce and the European Commission, from which the parties will be able to select either one or three arbitrators.

If you believe that we have not adhered to this Policy, please contact us by e-mail at privacy@julysystems.com. We will do our best to address your concerns. If you feel that your complaint has been addressed incompletely, we invite you to let us know for further investigation. For any complaints that cannot be resolved with July Systems directly, July Systems has chosen to settle the dispute exclusively under the JAMS Streamlined Arbitration Rules or JAMS International Mediation Rules). To file a complaint via JAMS, please visit https://www.jamsadr.com/eu-us-privacy-shield. July Systems is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC).

Information Security
We take reasonable steps to help protect Personal Information against loss, misuse, unauthorized access or disclosure. July Systems is now Service Organization Control (SOC) 2 Type 1 Compliant. Service Organization Control (SOC) 2 report is covered for the evaluation of July’s Information Systems relevant to Trust Service principles viz. Security, Availability, Processing Integrity, Confidentiality. Controls over the security of a system prevent or detect the breakdown and circumvention of segregation of duties, system failure, incorrect processing, theft or other unauthorized removal of data or system resources, misuse of software, and improper access to, or use of, alteration, destruction, or disclosure of information. A SOC2 report based on the ISO 27001 Control Objectives has the same look and feel as a SOC1 report (ISAE 3402 report, formerly known as SAS70 report) and provides our clients with sufficient information (independent service auditor’s opinion, management assertion, system description, tests performed by service auditor and test results) to meet their assurance needs.

Except for the foregoing statement to be SOC 2 Type 1 Compliant, July Systems expressly disclaims any representation or warranty, whether express or implied, with respect to offering any definitive promise of security.

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July Systems | 533 Airport Blvd, Suite 395 Burlingame, CA-94010, USA | +1 650 685 2460