Escalate ("Zebra Ltd.") is the operator of our Sites and the controller of data collected from you by our Sites and through our Services. With respect to the use of our Services by EU data subjects, we are either a controller or processor of your data, depending upon the circumstances that give rise to our processing of your data. We are a Russian Federation corporation located in Saint-Petersburg.

"Personal Data" are data elements that identify you as an individual or relate to an identifiable individual. Personal Data includes the term "personal information" as used in the California Privacy Rights section below. We collect Personal Data in accordance with law and this Policy. Examples of such data are:

• Name
• Surname
• Postal address
• Telephone number
• Email address
• Language preference
• Geolocation information
• Social media account ID, profile photo and other data publicly available, or data made available by linking your social media and accounts
• Pictures, audio files, or videos you submit, including pictures of yourself
• Credit card and billing information (if you submit payment for Services)
• Credit and Financial information in limited circumstances
• Information about your device, network and internet connection, such as your IP address, or other device ID (UUID)
• Device type, operating system type and version, and browser type and version
• Information about your usage of our site including the pages and files viewed and referrer URL and exit pages
• Other information you provide or create, such as comments you make on articles and blogs or posts in community forums.

We collect Personal Data in a variety of ways as described below.


Directly From You
We may ask you to provide Personal Data for various reasons. As a prospective customer of our Services, when you contact us or request information about our Services, we ask you for contact information such as your name, surname, email address, phone number, geographic and job information or title. We also collect similar information from you when you sign up to receive our newsletters or other offers.

We may ask you for similar and additional information at other times, such as when you apply for a job through our Sites or contact our customer service team.

You may also provide us your personal information when you sign up for a webinar, download a whitepaper directly on our Sites or from one of our Advertising partners, or complete a "contact us" form on our Sites.

From Third Party Sources/Clients
Through our Sites and Services, we may receive information, including, with your consent where required, from third party providers and sources that, alone or in combination with other information, could be used to identify an individual, including you.

We do not control the privacy practices of these third parties that we collect information from.

We also may receive your personal information such as name, business email, company and job title, from trade shows or other similar events that we sponsor or from third parties that provide such information. We use this information to send marketing messages to you as described below.


Information Automatically Collected
We automatically collect information about your use of our Sites and Services, including through cookies, web beacons, and other data collection technologies designed for use with websites, internet services or mobile devices or apps that you use. We may combine this information with other information we collect about you. If you can be identified from this information, for example by combination with other pieces of information, then we will treat this information as Personal Data. Please see the information below to learn more about how we use cookies and other data collection technologies, and how you can control such uses.
This information can include your browser type and operating system, your IP address, the length and times of day you use our Sites or Services, and the referring URL or webpage that led you to our Sites or Services.
We also use this technology to record your preferences, track the use of our products and your exposure to our online advertisements. We may also use these technologies to monitor traffic, improve the products and make it easier and/or relevant for your use. For example, we may recommend articles similar to the ones you're reading or display advertisements that you haven't already seen.

What Kinds of Cookies Do We Use?

• Analytics cookies
• Advertising cookies
• Essential cookies
• Functionality cookies
• Social Media cookies

To help us make e-mails more useful and interesting, we often receive a confirmation when you open e-mail from us if your computer supports such capabilities. You can opt out of receiving emails or other electronic marketing communications from us, other than emails related to your use of the Services or management of your account. Please see the Your Choices section below.

We might also use a pixel tag which is a small graphic file that allows us and third parties to monitor the use of the Sites and Services and provide us with information based on your interaction with the Sites, Services and e-mails. These tags may collect the IP address from the device which you loaded the page, your browser type, and other data. Pixel tags are also used by our third parties to collect information when you visit our Site, the links and other actions you take on our Site, and we may use this information in combination with cookies to display targeted advertisements.

Other data technologies may be used that collect comparable information for security and fraud detection purposes.

For more information, please see our Cookie Policy.

We use the Personal Data collected for a number of purposes as described below.

To Provide our Services
Escalate uses your information, including Personal Data, for the following purposes:

• Provide you with access to the content and services we produce;
• Analyze demographic or behavioural data to improve or personalize the products we offer to you;
• Provide you with more relevant advertising content;
• To respond to any emails or requests you directly make to us;
• For our own marketing and retargeting purposes by tracking preferences which allow us to create new services, features and content that may be more personalized to your interests;
• For our statistical, research, recordkeeping, and reporting purposes to understand trends related to our offerings and services;

• To monitor our products for compliance with our Terms of Use;
• To protect the security of our network and to monitor abuse and prevent illegal activities and fraud;
• To comply with the law;
• For any other purpose identified at the time of collection.

We will not use the information provided to us in ways unrelated to the ones described above without notifying you first and getting your consent where required.
If you are a new customer, Escalate will only contact you when you have provided consent.


To Communicate with You
We use the information that we collect when you visit our Sites or sign up for our Services to respond to questions, comments or requests for information from us and to send applicable and personalized marketing messages in accordance with this Privacy Policy and applicable laws. These marketing messages may include emails, texts, online advertisements, or phone calls. Written marketing related communications to you will contain instructions on how to unsubscribe from receiving them. See more on how to opt-out in the Your Choices section below.

When you send an email or other communications to us, we may keep those communications and use the Personal Data they contain in order to process your questions, respond to your requests and improve our Sites or Services. In particular, we may use your email address to communicate with you about our Services, such as to provide you with support.


Other Uses of Data
We may anonymize, de-identify and/or aggregate the information that we collect and use such anonymized, de-identified and/or aggregated data for our own business purposes, including but not limited to sharing anonymized or de-identified data with our current and prospective business partners, clients, service providers, affiliates, agents and other third parties for commercial, statistical and market research purposes, for example, to allow those parties to analyze patterns among groups of people, and conducting research on consumer demographics, interests and behaviour.

We use Personal Data and other data for data analysis, security and fraud monitoring and prevention, product development and testing, improving or modifying our Sites and Services, analyzing website traffic patterns and behaviours, statistical and survey purposes, determining the effectiveness of our promotional campaigns and operating and expanding our business activities.

Escalate does not share your personal information with others except as indicated within this policy or when we inform you and give you an opportunity to decline or opt-out of having your personal information shared. Escalate may share your information, including Personal Data, in the circumstances described below.

Clients & Partners. Sometimes we create joint or co-branded whitepapers, webinars and other forms of content with third parties. We will inform you who the Partner is when we offer such content. If you opt-in to receive joint or co-branded Partner content, we may provide your information to these third parties & partners for use in marketing and in designing or providing their own services and to send you information about their products or services. If you don't want us to send your information to the third party, you should not sign up for this joint or co-branded content. You should contact the other third party directly who may already be sending you messages in order to request that these communications stop, and to review their privacy policies.

Third Party Data Sources. We share your information with third party data sources to verify the accuracy of the information you provide to us, like your email address, and to request information about you.

Aggregate and Anonymized Information. We may share aggregate information or anonymized and/or de-identified information about users and prospective users of our Sites and Services with third parties for marketing, advertising, research or similar purposes.

Service Providers. We share information with our third party vendors and service providers to perform certain functions on our behalf, such as hosting specific portions of the Service, maintaining databases, helping us collect job applications, delivering content, sending emails on behalf of our customers and for our own marketing communications, using text messaging services for multifactor authentication protocols, administering content, mailing information, processing payments or otherwise operating the Services or the Sites.

Business Transfers. If we are acquired by or merged with another company, if all or some portion of our assets are transferred to another company, or as part of a bankruptcy proceeding, financing due diligence, reorganization, or receivership, we may transfer the information we have collected from you to the other company or bankruptcy trustee or administrator.

In Response to Legal Process. We may disclose the information we collect from you in order to comply with the law, a judicial or regulatory proceeding, court or governmental agency order, or another legal process, such as in response to a court order or a subpoena.

To Protect Us and Others. We may disclose the information we collect from you where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms of Use or this Privacy Policy, or as evidence in litigation in which Escalate is involved.

Our Sites and Services may contain links to other content and websites not operated or controlled by Escalate ("Third Party Sites"). The privacy practices described in this Privacy Policy do not apply to Third Party Sites or any linked content. By providing these links we do not imply that we endorse or have reviewed these sites. Please contact the operators of Third Party Sites directly for information on their privacy practices and policies.

Escalate uses reasonable administrative, logical, physical and organizational measures to safeguard your personal information against loss, theft and unauthorized access, use and modification. Unfortunately, no measures can be guaranteed to provide 100% security. Accordingly, Escalate cannot guarantee the security of your information. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your e-mail or any other account via unauthorized password activity.Escalate uses reasonable administrative, logical, physical and organizational measures to safeguard your personal information against loss, theft and unauthorized access, use and modification. Unfortunately, no measures can be guaranteed to provide 100% security. Accordingly, Escalate can not guarantee the security of your information. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your e-mail or any other account via unauthorized password activity.

Cookies
On most web browsers, you will find a "help" section on the toolbar. Please refer to this section for information on how to receive a notification when you are receiving a new cookie and how to control cookies, including turn them off. Please see the links below for guidance on how to modify your web browser's settings on the most popular browsers:

• Cookie settings in Internet Explorer
• Cookie settings in Firefox
• Cookie settings in Chrome
• Cookie settings in Safari

Note, however, that if you turn cookies off or reject our request to use cookies, you may be unable to access certain parts of the Sites or Services and you may not be able to benefit from the full functionality of the Sites or Services.

To find out more about cookies and similar technologies, including how to see what cookies and similar technologies have been set and how to manage and delete them, visit www.allaboutcookies.org, and/or the Digital Advertising Alliance's (DAA) online resources at http://youradchoices.com/control, and/or the Network Advertising Initiative's (NAI) online resources at http://www.networkadvertising.org, and follow the opt-out instructions there, or if located in the European Union, visit the European Interactive Digital Advertising Alliance's (EDAA) Your Online Choices opt-out tool at www.youronlinechoices.com.

Opting out from one or more companies listed on the DAA Consumer Choice Page, the NAI Consumer Opt-Out Page, or the EDAA Your Online Choices opt-out page will opt you out from the delivery of interest-based content or ads to you by the third parties participating in those opt-out services, but it does not mean you will no longer receive any personalized advertising through our Services or on our Sites or other websites. You may continue to receive advertisements, for example, advertisements for which you have given us consent, non-personalized advertisements or advertisements based on the particular website that you are viewing (i.e., contextually based ads). Also, if your browsers are configured to reject cookies when you opt out on the DAA, NAI or EDAA websites, your opt out may not be effective. Additional information is available at these websites.

Third Party Analytics
We use automated devices and applications, such as Google Analytics and Yandex.Metrica, to evaluate usage of our Sites and our Services. We also may use other analytic means to evaluate our Sites and Services. We use these tools to help us improve our Sites and Services, performance and user experiences. These entities may use cookies and other tracking technologies to perform their services.


Third Party Advertisers
We use third parties such as network advertisers to serve advertisements on third-party websites or other media (e.g., social networking platforms). This enables us and these third parties to personalize advertisements to you for products and services in which you might be interested. Third-party ad network providers, advertisers, sponsors and/or traffic measurement services may use cookies, JavaScript, web beacons (including Pixel Tags or clear GIFs), and other tracking technologies to measure the effectiveness of their ads and to personalize advertising content to you. These third-party cookies and other technologies are governed by each third party's specific privacy policy, not this one.

Opting out of email
We may send periodic promotional or informational emails to you. You may opt-out of such communications by following the opt-out instructions contained in the email. Please note that it may take up to 10 business days for us to process opt-out requests. If you opt-out of receiving emails about recommendations or other information we think may interest you, we may still send you emails about your account or any Services you have requested or received from us.


EU Data Subjects
This section applies if you are an EU data subject (for these purposes, reference to the EU also includes the European Economic Area countries of Iceland, Liechtenstein and Norway and, where applicable, Switzerland). Escalate is the data controller for processing Personal Data provided to Escalate in relation to the Sites and Services. Unless you have given us your consent for our independent uses of your Personal Data or we have another lawful basis for processing your Personal Data, we act strictly as a data processor for Personal Data that we process through the Services, as described under the "Information Collected Through our Services" section above. For example, we process data on behalf of Clients in relation to transactions you may be conducting or considering with them. We rely on the following legal bases for processing your Personal Data:

Processing of your Personal Data based on your consent for such processing. You have the right to withdraw your consent, as further described below.

Processing of your Personal Data that you provide to us (such as your name, email address, postal address, telephone number, company name and role) when you request information about the Escalate Services or when you otherwise send inquiries about our Services and processing of this data is necessary to respond to or implement your request prior to entering into a contract with us or a data controller that is using our Services.

We may send you information by email or through other electronic communications on our new products or services or other promotions if you consent to receiving them. If you have not opted-in to these marketing emails, we do this either because we are relying on an exception to opt-in requirements or because of our legitimate interest to promote the success of our business.

Our use of data relating to your use of the Sites and/or the Services, described above, is necessary for our legitimate interests in understanding how the Sites and the Services are being used by you, to improve your experience on it and our Service offerings.

We also have a legitimate interest in aggregating and/or anonymizing or de-identifying the information that we collect through our Sites and/or the Services and using this information for our business purposes, as described above.

When we process your Personal Data for our legitimate interests, we make sure to consider and balance any potential impact on you, and your rights under data protection laws. Our legitimate business interests do not automatically override your interests – we will not use your Personal Data for activities where our interests are overridden by the impact on you, unless we have your consent for our processing activities or those activities are otherwise required or permitted by law. You have the right to object to processing that is based on our legitimate interests, as further described below.

Subject to applicable law and reasonable steps that we may take to verify your identity with respect to your requests, you have the following rights in relation to your Personal Data:

Right of access: If you ask us, we will confirm whether we are processing your Personal Data and, if so, provide you with a copy of that Personal Data (along with certain other details). If you require additional copies, we may need to charge a reasonable fee.

Right to rectification: If your Personal Data that we control is inaccurate or incomplete, you are entitled to have it rectified or completed. Note that we may not be able to rectify data obtained from a third party such as a governmental agency or other data that we do not control, and you will need to contact that third party directly. If we have shared your Personal Data with others, we will tell them about the rectification where possible. If you ask us, where possible and lawful to do so, we will also tell you with whom we shared your Personal Data so that you can contact them directly.

Right to erasure: You may ask us to delete or remove your Personal Data and we will do so in some circumstances, such as where we no longer need it (we may not delete your data when other interests outweigh your right to deletion, for example, if we are required by law to keep it). If we have shared your data with others, we will tell them about the erasure where possible. If you ask us, where possible and lawful to do so, we will also tell you with whom we shared your Personal Data so that you can contact them directly.

Right to restrict processing: You may ask us to restrict or 'block' the processing of your Personal Data in certain circumstances, such as where you contest the accuracy of that Personal Data or object to us processing it. We will tell you before we lift any restrictions on processing. If we have shared your Personal Data with others, we will tell them about the restriction where possible. If you ask us, where possible and lawful to do so, we will also tell you with whom we shared your Personal Data so that you can contact them directly.

Right to data portability: Effective 25 May 2018, you have the right to obtain your Personal Data from us that you consented to give us or that is necessary to perform a contract with you, to the extent it is available. We will give you your Personal Data in a structured, commonly used and machine-readable format.

Right to object: You may ask us at any time to stop processing your Personal Data, and we will do so if we are processing your Personal Data for the Services, for direct marketing, or otherwise. However, if we are relying on a legitimate interest to process your Personal Data and we demonstrate compelling legitimate grounds for the processing we may continue; or you may exercise your rights by contacting us as indicated under "Contact Us". Note you will be asked to verify your identity when submitting a request.

Rights in relation to automated decision-making and profiling: You have the right to be free from decisions that we make based solely on automated processing of your Personal Data, including profiling, which produces a significant legal effect on you, unless such profiling is necessary for entering into, or the performance of, a contract between you and us, or with your explicit consent.

Right to withdraw consent: If we rely on your consent to process your Personal Data, you have the right to withdraw that consent at any time. Your withdrawal of consent will not apply to or affect prior processing of data that was processed prior to our receipt of your withdrawal of consent.

Right to lodge a complaint with the data protection authority: If you have a concern about our privacy practices, including the way we have handled your Personal Data, you can report it to the data protection authority that is authorized to hear those concerns.

EU Data Subjects may contact us about these rights at yulia.antonova@e-escalate.ru or at the address set out in the Contact Us section below.

Escalate operates its site in the Russian Federation. If you are located in another jurisdiction, you are notified that your information will be transferred to, stored, and processed in Russia.

BY USING THIS SITE AND PROVIDING ESCALATE WITH INFORMATION, YOU CONSENT TO THIS TRANSFER, PROCESSING AND STORAGE OF YOUR INFORMATION IN RUSSIAN FEDERATION.

If you do not consent to this, you should not use our Sites or Services.

It is important to note that the privacy laws in the Russian Federation may not be as comprehensive as those in other countries such as the European Union. Escalate service providers use appropriate safeguards for your Personal Data when transferred to and processed in Russia.

Escalate will retain Personal Data for the period necessary to provide our Services or for the purposes for which it was collected, or as otherwise required by our contracts or by law.

When determining how long we should keep data, we consider the length of time we will have a relationship with you or our clients, and provide our Services, whether there is a legal obligation that would require us to keep the information for a specified period of time, the reasons why we process your data, the risk of harm from unauthorized use or disclosure of your Personal Data.

We may also anonymize or de-identify Personal Data so it would no longer be associated with you and use such anonymized or de-identified data for research or analytical purposes. If data is anonymized or de-identified, we may use this data for as long as we have a legitimate business purpose for such use, without additional notice to you.

Escalate will retain Personal Data for the period necessary to provide our Services or for the purposes for which it was collected, or as otherwise required by our contracts or by law.

When determining how long we should keep data, we consider the length of time we will have a relationship with you or our clients, and provide our Services, whether there is a legal obligation that would require us to keep the information for a specified period of time, the reasons why we process your data, the risk of harm from unauthorized use or disclosure of your Personal Data.

We may also anonymize or de-identify Personal Data so it would no longer be associated with you and use such anonymized or de-identified data for research or analytical purposes. If data is anonymized or de-identified, we may use this data for as long as we have a legitimate business purpose for such use, without additional notice to you.

Our Services and Sites are not directed at children under 16 years of age (or older where required by law), and we do not knowingly collect or receive Personal Data from them. If we learn that we have received Personal Data from a child whose age requires parental consent for processing, we will delete the data. If you believe that we have received Personal Data from a child whose age requires parental consent, you may contact us at yulia.antonova@e-escalate.ru.

Personal Information We Collect about California Consumers

Additional Notice for California Consumers - This part of our Privacy Policy applies to consumers who reside in California. If this section differs from other terms in this Privacy Policy, this section governs for California consumers only.

We describe the personal information we have collected from consumers in the twelve (12) months preceding the effective date of this Privacy Policy in the part of our Privacy Policy titled, "Collection of Personal Data" above. The information we collect includes the following:

Identifiers such as name, address, email address, phone number, and other data listed in the "Collection of Personal Data" section above.

The following categories of personal information described in California Civil Code §1798.80(e): (1) the personal information listed in the preceding bullet point as "identifiers," and (2) the other information that identifies, relates to, describes, or is capable of being associated with a particular individual that we describe in "Collection of Personal Data" above such as credit card information, debit card information and other financial related information.

Characteristics of protected classifications under California or federal law: national origin.

• Commercial information, including information about orders or purchases of any of our products or services; registration information, specials, and information you provide or submit to us when you participate in any event, program, survey or other promotion that we may offer from time to time.
• Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with our websites, advertisements that we display on our websites or on third party sites and apps, or accounts on third-party social media platforms.
• Geolocation data.
• Audio information from calls placed with customer service and accounting centers which may be reported, and electronic information in the form of Internet or other electronic network activity information described above.
• Inferences drawn from (1) the information we collect when you visit our websites, tools, widgets and plug-ins, (2) information we collect, including through third-party suppliers, regarding content and other data posted on the Internet (such as public locations on the Internet), and (3) information about consumer preferences and behaviors that we collect on our Sites or purchase from third parties in order to create a profile about a consumer, which may include inferences reflecting the consumer's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes.

For more information, please see "Collection of Personal Data" and "How We Collect Personal Data" above.

Disclosures of Personal Information for Monetary or Other Valuable Consideration or for Business Purposes
We don't sell our customer lists or our users' personal information to third parties for monetary value. However, the California Consumer Privacy Act broadly defines the word "sale" to include any sharing or disclosing of personal information to another party. To the extent that "sale" is interpreted to include interest based advertising or other data uses described in this Policy, we will comply with applicable law as to those activities. You can read more in our Cookie Policy and how to exercise your rights to opt out of interest-based advertising.

We have disclosed personal information in all or substantially all of the categories identified in this Additional Notice for California Resident Consumers for various business purposes and as directed by you in your interactions with our Services.

Your California Privacy Rights
If you are a California resident, you have the following rights. We will honour requests received to the extent required by applicable law and within the time provided by law.
Right to Access and Information Regarding Personal Information
You have the right to request that we disclose to you the categories and specific pieces of personal information we have collected about you. Specifically, you have the right to request that we disclose the following to you, in each case in the twelve-month period preceding your request:

• The categories of personal information we have collected about you;
• The categories of sources from which the personal information is collected;
• Our business or commercial purpose for collecting or selling personal information;
• The categories of third parties with whom we share personal information;
• The specific pieces of information we have collected about you;
• The categories of personal information about you, if any, that we have disclosed for monetary or other valuable consideration and the categories of third parties to which we have disclosed the information, by category or categories of personal information for each third party to which we disclosed the personal information; and
• The categories of personal information about you that we disclosed for a business purpose

We will deliver personal information that we are required by law to disclose to you in the manner required by law within 45 days after receipt of a verifiable request unless we notify you that we require additional time to respond, in which case we will respond within such additional period of time required by law.
Right to Deletion of Personal Information
You have the right to request that we delete Personal Information about you that we have collected from you.
Right to Opt-Out
You have the right at any time to direct us not to sell your personal information, which is your right to opt-out. In the preceding twelve months, we have not sold personal information.
Right to No Discrimination
We may not discriminate against you because of your exercise of any of the foregoing rights under the California Consumer Privacy Act, including by:
Denying you goods or services;
Charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
Providing you with a different level or quality of goods or services; or
Suggesting that you will receive different prices or rates for goods or service or at a different level or quality of goods or services.
We may, however, charge different prices or rates, or provide a different level or quality of goods or services, if that difference is reasonably related to the value provided to us by your personal information.
Requests to Exercise Your Rights
You may request to exercise the foregoing rights by submitting a request:
Submit a request to yulia.antonova@e-escalate.ru

Please note that we may take steps to verify your identity before granting you access to information or acting on your request to exercise your rights, as required or permitted by law. We may limit our response to your exercise of the above rights as permitted by law.
Data Sharing for Direct Marketing Purposes
California Civil Code § 1798.83 further permits California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. If you are a California resident, you may ask us to refrain from sharing your personal information with certain of our affiliates and other third parties for their direct marketing purposes. Please tell us your preference by contacting us as specified below.

We may change this Privacy Policy at any time. We will post all changes to this Privacy Policy on this page and will indicate at the top of the page the modified policy's effective date. We, therefore, encourage you to refer to this page on an ongoing basis so that you are aware of our current privacy policy. If required by the applicable law, we will notify you of the changes. By continuing to use the Sites and/or the Services or providing us with information following such a replacement Policy being provided, you agree that you will be deemed to have agreed to be bound by the Privacy Policy as changed.