Privacy and Cookies Statement

This is the privacy and cookies statement of Avantcard DAC (Avantcard). Avantcard is the registered trading name of Avantcard DAC in the Republic of Ireland. Avantcard DAC is part of the EVO Banco Group.

Further protection of your privacy – policies of other service providers

What we collect and how long we will keep it for

Who we share Personal Information with

Automated Decision Making and Profiling

While you explore the services offered through this website and websites owned by other members of the EVO Banco group, please be alert for and review any specialised privacy statements and terms of use applicable to particular products or websites, or portions of them, as they may differ depending on group, company, product or service. Please be aware that other online retailers, partners, third party internet sites, and third party services accessible through this website have separate privacy and data collection policies and practices which are independent of and may differ from Avantcards policies and practices. Avantcard is not responsible or liable for these independent policies and practices. It is your responsibility to review them and decide whether such policies and practices protect your rights to your satisfaction before proceeding.

We are committed to providing you with products that are suitable to your needs and are backed by consistently top-quality service but we also take our obligations under data protection law very seriously. This privacy policy explains how we will handle your personal information in order to provide you with those products and services and gives you the information you need to decide whether or not to provide your personal information to us.

We will take measures to ensure that personal data will be processed in a manner that ensures appropriate security and confidentiality of the personal data, including for the prevention of unauthorised access to or use of personal data and the equipment used for the processing.

We have appropriate technical and organisational measures to ensure an appropriate level of security, including:

the pseudonymisation and encryption of personal data;

verification of the identity of our customers through the use of personal passwords or other information before assisting them;

the use of vigilant protection measures in order to protect our customers accounts from fraudulent use;

the ability to ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and services;

the ability to restore the availability and access to personal data in a timely manner in the event of a physical or technical incident;

a process for regularly testing, assessing and evaluating the effectiveness of technical and organisational measures for ensuring the security of the processing.

We ensure that anyone acting on our behalf that has access to personal data does not process them except on instructions from us.

The personal information that Avantcard collects about you may include the following:

Information that you give us, and credit intermediaries appointed by us, in connection with your application for one of our products, which includes your name, address, email address, phone number, marital status, number of dependents, anti-money laundering documentation (e.g. copies of official identification and household bills), bank account details, income and expenditures, assets, debts, and credit history.

Avantcard must retain these records for six years from the date on which we ceased to provide any product or service to you. This is aligned to the requirements of the Consumer Protection Code 2012.

Information we gather about you through your interactions with us and credit intermediaries appointed by us, which may include your credit card details.

Avantcard must retain these records for six years from the date on which we ceased to provide any product or service to you. This is aligned to the requirements of the Consumer Protection Code 2012.

Information we gather about you through your interactions with us and credit intermediaries appointed by us, which may include any phone number you call us from.

Avantcard will only retain this number if you have agreed to us using this number for communication purposes. If you have agreed to this, we will retain these records for six years from the date on which we ceased to provide any product or service to you. This is aligned to the requirements of the Consumer Protection Code 2012.

Information we gather about you through your interactions with us and credit intermediaries appointed by us, which may include electronic details about you, your computer or your internet protocol address.

Avantcard will retain this information for 12 months from the date the electronic details about you, your computer or your internet protocol address were gathered.

Information we gather about you through your interactions with us and credit intermediaries appointed by us, which may include details of the financial transactions processed by us and our credit intermediaries.

Avantcard must retain details of individual transactions for six years after the date on which the particular transaction is discontinued or completed.

Information we gather about you through your interactions with us and credit intermediaries appointed by us, which may include your debit card details.

Avantcard will normally retain your debit card details for 30 days following the completion of debit card transactions that you authorise us to complete; however, if a dispute arises, we mayneed to retain until such time as that dispute is resolved.

Information we receive from searches made by us or any member of the EVO Bank Group in your name with credit reference and fraud prevention agencies.

Avantcard must retain these records for six years from the date on which we ceased to provide any product or service to you. This is aligned to the requirements of the Consumer Protection Code 2012.

Information about any Avantcard DAC account which you, or any member of your household, hold with or through us.

Avantcard must retain these records for six years from the date on which we ceased to provide any product or service to you. This is aligned to the requirements of the Consumer Protection Code 2012.

Information we receive from anyone who is allowed to give us (or any member of the EVO Bank Group) information about you.

Avantcard must retain these records for six years from the date on which we ceased to provide any product or service to you. This is aligned to the requirements of the Consumer Protection Code 2012.

The personal information requested from you is necessary to allow Avantcard to properly and appropriately provide or administer its products and services. An absence of sufficient information in this regard may give rise to Avantcard being unable to provide such products or services to you.

Your personal information will be stored by Avantcard on a computerised database and/or in any other secure manner. Any personal information which you provide to us when you apply for a product or hold an account with us will be used in accordance with the terms and conditions of the particular agreement which you have entered into with us and in accordance with the Data Protection Acts 1988 and 2003 and, when it comes into effect, the General Data Protection Regulation (2016/679) and the Data Protection Act 2018 (together well call these the Data Protection Acts).

Avantcard uses your personal information for the following purposes:

To assess any application you make to us. When you are completing an application for credit we may contact you by phone (including your place of employment), SMS or email in relation to that application or any subsequent credit agreement.

This is necessary before we can enter into a contract with you and to fulfill our contractual obligations to you. Under our legal obligations, we also rely on your consent (if you have given it) to call you at your place of employment. You can withdraw this consent at any time by going to the Settings menu of your Avantcard online banking account or by contacting us.

To carry out searches (for anti-money laundering, credit history and legal purposes) and to disclose information to credit reference agencies for the purpose of assessing applications for credit and credit related services and for on-going credit review.

This is necessary before we can enter into a contract with you, to fulfill our obligations once we have entered into a contract with you, and in some cases to comply with Irish law. This is also necessary to achieve our legitimate interest in promoting greater financial stability by supporting a full and accurate assessment of loan applications, aiding in the avoidance of over-indebtedness, assisting in lowering the cost of credit, complying with and supporting compliance with legal and regulatory requirements, enabling more consistent, faster decision-making in the provision of credit and assisting in fraud prevention.

To administer the services or products that we supply to you.

This is necessary to fulfill our contractual obligations to you.

To establish and confirm how you operate your account(s) with Avantcard and to ensure compliance with any applicable terms and conditions. This includes where you become an Avantcard customer following the purchase by us of your card and account from another card provider; we will need to process your personal information to allow us to plan and prepare for the proper transfer of your account from your previous card providers systems to our systems.

This is necessary to fulfill our contractual obligations to you, and to achieve our legitimate commercial interest in operating our business efficiently.

To review your financial position with Avantcard.

This is necessary to fulfill our contractual obligations to you in terms of any financial products you have with us and in making any decisions in respect of further requests for products that you may make. This is also necessary to achieve our legitimate commercial interest in operating our business efficiently.

To provide your personal information to third party processors and contractors who provide services to Avantcard, such as IT systems providers and professional services firms.

This is necessary to fulfill our contractual obligations to you.

To provide your personal information to debt collection agencies who act on behalf of Avantcard.

Where it becomes necessary, this is to achieve our legitimate commercial interest in ensuring we are paid for our products and services in accordance with the contract we have agreed with you.

To prevent and detect fraud, or other unlawful activity and to trace those responsible.

This is necessary to fulfill our contractual obligations to you, and in some cases to comply with Irish law.

To comply with any applicable laws and regulations.

This is necessary to comply with Irish law.

To carry out statistical analysis and market research to analyse, monitor and improve our business or to instruct a third party to perform this on our behalf.

This is necessary to achieve our legitimate commercial interest in operating our business efficiently.

To evaluate whether there are other products that we offer suitable to your needs.

This is necessary to achieve our legitimate commercial interest in ensuring products offered are appropriate.

For direct marketing purposes so that we may inform you of our products or services.

For marketing through email, SMS, voice call (landline) and direct mail, we rely on our legitimate commercial interest in marketing similar products and services to you. For marketing through voice calls to your mobile phone, we rely on your consent. You can update your marketing preferences by going to the Settings menu of your Avantcard online banking account or by contacting us onmarketing..

Where Avantcard transfers personal information to third parties for processing we ensure that we have an appropriate contracts in place that protects your personal information and complies with our obligations under the Data Protection Acts. For transaction data, we transfer your transaction information to anywhere in the world where you make a financial transaction through a payment system using one of our products.

Where any person working for us (including any member of the Evo Bank Group) is processing personal data on our behalf and that processing is outside of Europe, Avantcard will ensure that the processing is on the basis of either an adequacy decision by the European Commission or appropriate or suitable safeguards as required by applicable laws or regulations and that appropriate contracts are in place to confirm this.

A number of firms working for us avail of Binding Corporate Rules. Binding Corporate Rules or BCRs were developed by the European Union Article 29 Working Party to allow multinational corporations, international organizations, and groups of companies to make intra-organizational transfers of personal data across borders in compliance with EU Data Protection Law. A copy of these Binding Corporate Rules is available on request.

Mastercard and Visa International Transfers

Some of the processing of personal data by Mastercard and Visa may be located outside of Europe and where this is the case, both will ensure that processing is in line with EU Data Protection Law.

Any person working for us (including any member of the Evo Bank Group) for the purposes we have listed above in the How we use Personal Information section.

If you arrange insurance through us, to the insurer.

Any organisation which backs any of our products which you hold.

Any guarantor of any agreement between you and us.

Any payment system under which we issue your card (i.e. Visa or Mastercard).

Any person we transfer our rights or obligations to under any agreement we may have with you.

Anyone you authorise us to give personal information to.

Any merchant or third party that you have a disputed transaction with.

Any credit intermediary appointed by or payment services agent of Avantcard.

Credit Reference Agencies (Central Credit Register and Irish Credit Bureau).

Any partner providing benefits to you on your card purchase transactions.

Any communications provider that acts on our behalf in relation to communications we may send to you.

As a result of the introduction of the General Data Protection Regulation (GDPR), from 25th May 2018, ICB will be using Legitimate Interests (GDPR Article 6 (f)) as the legal basis for processing of your personal and credit information. These Legitimate Interests are promoting greater financial stability by supporting a full and accurate assessment of loan applications, aiding in the avoidance of over-indebtedness, assisting in lowering the cost of credit, complying with and supporting compliance with legal and regulatory requirements, enabling more consistent, faster decision-making in the provision of credit and assisting in fraud prevention.

Please review ICBs Fair Processing Notice which is availablehere. It documents who they are, what they do, details of their Data Protection Officer, how they get the data, why they take it, what personal data they hold, what they do with it, how long they retain it, who they share it with, what entitles them to process the data (legitimate interests), what happens if your data is inaccurate and your rights i.e. right to information, right of access, right to complain, right to object, right to restrict, right to request erasure and right to request correction of your personal information.

Under the Credit Reporting Act 2013, Avantcard is required to provide personal and credit information for credit applications and credit agreements of €500 and above to the CCR. This information will be held on the CCR and may be used by other lenders when making decisions on your credit applications and credit agreements. We, along with other lenders, must transfer personal and credit information on a monthly basis to the CCR for loans and credit cards.

It is important to note that if you do not keep up your repayments on your loans or credit cards you have with us, the missed payments will be reported to the CCR and will appear on your credit report. In addition, should you enter into a restructure arrangement with us arising out of financial difficulties; this restructure will be reported to the CCR.

When credit reports become available, you will have the right to:

Request your credit report at any time and the first credit report each year is free;

Insert a 200 word explanatory statement on your credit report;

Apply to have your information amended if you believe it is:

Make a report to the CCR if you reasonably believe that someone has, is, or is about to impersonate you.

For more information about the Central Credit Register

As part of the agreement between Avantcard and Mastercard, Mastercard will process your personal data in line with section 3.10 of the Mastercard rules which you can findhere, including for internal research, fraud, security and risk management purposes. Some of this processing will be located outside of Europe and where this is the case, Mastercard will ensure that processing is in line with EU Data Protection Law.

The Mastercard Binding Corporate Rules have been approved by the EEA data protection authorities and you have the right to enforce these rules as a third party beneficiary. The Mastercard Binding Corporate Rules can be viewedhere.

When you apply for one of our products, we will use an automated decisionmaking system to process the personal information that you provide and the personal information that we are allowed to collect from others. These automated decisions can affect the products and services we may offer you now or in the future, or the price that we charge you for them. This automated decision-making system can lead to quicker decisions which are more appropriate and consistent.

For credit applications, the system analyses your personal information, your credit score from the credit reference agencies and whether you meet our minimum credit requirements. If the system finds that you do not meet our minimum credit requirements, we may not approve your application.

In assessing your application, the automated decision-making system will look at various pieces of information to assess your Stability, Ability and Willingness to pay. This assists in making fair and responsible lending decisions.

Stability How stable is your situation in relation to time in employment and residential status. This is assessed by looking at employment, residential status etc

Ability – Can you afford the payments based on the income and expenditure information provided or other outstanding debts you hold etc

Willingness How reliable and responsible are you in relation to your other bills and paying other debt?

If requested, we shall manually assess your application. As part of this assessment, one of our credit underwriters will review the decision made by the automated decision-making system and the data created and considered as part of the automated decision-making.

In addition, when you apply for one of our products and while you are a customer of Avantcard, we will use automated tools to review the personal information you provide or that we are allowed to collect from others to evaluate and tailor other products or services that may be suitable to your needs. We will only contact you in relation to these offers if you have agreed to this contact. You have the right to object to this profiling at any time by .

We regularly test our automated decisioning tool to ensure that the decisions made through it are fair, effective and unbiased.

If you believe that the results of any automated decision-making are incorrect, you can appeal the results by contacting our Customer Services team on 0818 409 511 and we will review the results.

Under the Data Protection Acts you have the following rights:

Access, Rectification or Erasure: You have the right of access to personal information we hold about you in our records. You are also entitled to have your personal data corrected if it is inaccurate or erased if we do not have a legitimate reason for retaining your data.

To be Informed: you have the right to be informed how your personal information is being processed

To Restrict Processing: you have the right to restrict the processing of your personal information where you are contesting the accuracy of that information, you have objected to processing (as described below), or where the processing is unlawful

To Object: where your personal information is being processed based solely on our legitimate interests (seesection 5), you have the right to object to that processing.

To Data Portability: for personal information which you have provided to a controller, where processing was based on your consent, or where processing is done by automated means, you have the right to be able to move your data from one IT system to another in a safe and secure way

Below are the contact details to exercise any of the above rights:

In writing- Data Protection Officer, Avantcard DAC, Dublin Road, Carrick-onShannon, Co Leitrim

If you believe we are processing your personal information improperly, please let us know. You can also file a complaint with the Irish Data Protection Commissioner. For information on how to file a complaint, go to theData Protection Commissioners website.

We may disclose your personal information to potential acquirers of Avantcard, or of any part of our business, as part of a due diligence process including for testing purposes in preparation for migration. Where we make such disclosures we will do so subject to strict confidentiality agreements and security arrangements. Where there is a transfer of our business, or any part of it, to a third party, we may transfer your personal information to that third party in order to allow them to continue to provide services to you.

We record inbound and outbound telephone calls for quality assurance and training purposes.

We may change this privacy statement and data protection notice from time to time and to ensure we continue to follow best practice when it comes to your privacy. When such a change is made, we will post a revised version on this website. Changes will be effective when they are posted. It is your responsibility to review this privacy statement and data protection notice from time to time to be aware of any such change. Your continued use of the service will indicate your agreement to any such change. This privacy statement and data protection notice was last updated in March 2018.

Avantcard welcomes your question and comments about privacy and you can do so by writing to the Data Protection Officer, Avantcard DAC, Dublin Road, Carrick-on-Shannon, Co Leitrim.

This website and online services use cookies for optimizing our services.

Cookies are text files containing small amounts of information which are downloaded to your device when you visit a website. Cookies are then sent back to the originating website on each subsequent visit, or to another website that recognises that cookie. Cookies are useful because they allow a website to recognise your device. You can find more information about cookieshere. Cookies help us collect data about you and how you use our services for example, were interested in which internet browser you used to visit our website, how long you visited and which pages you looked at. We monitor our website to better serve you in future.

Avantcard uses the following types of cookies on this website:

Necessary cookies- These cookies are essential in order to enable you to move around our website and use its features. Without these cookies, services you have asked for, like accessing secure areas of the website, cannot be provided.

Functionality cookies- These cookies allow the website to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personal features. The information these cookies collect may be anonymised and they cannot track your browsing activity on other websites.

Performance cookies- These cookies collect information about how you use our website, for instance which pages you visit most often, and if you get error messages from web pages. These cookies dont collect information that identifies you. The information these cookies collect enables us to create statistics on how our website is used, is aggregated and therefore anonymous. It is only used to improve how the website works.

Targeting/Advertising cookies- These cookies are set through our site by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant adverts on other sites. They do not store directly personal information but are based on uniquely identifying your browser and internet device. If you do not allow these cookies, you will experience less targeted advertising.

You can set your internet browser to disable or block cookies. If cookies are disabled then some of the content on avantcard.ie will also be disabled or may not be displayed correctly. To prevent this we recommend that cookies are enabled. For more information on how to disable cookies in your internet browser, please go .

Avantcard DAC trading as Avantcard is regulated by the Central Bank of Ireland.

Avantcard DAC is a designated activity company incorporated in Ireland under number 541980 and having its registered office at Dublin Road, Carrick-on-Shannon, Co Leitrim.

Privacy Policy and Cookie Statement

The Types of Data Acquired About You

Personally Identifiable Information (PII)

Processing Your Requests for Products

Combining Your Anonymous Data with PII

Sharing Your Data for Marketing; Opt-Out; How to Update Your Data

Credit/Debit Card and Payment Account Data

How to Opt-Out of Sharing for Marketing

How to Opt-Out of Marketing Messages from Us

Cookies and Related Technologies; Do Not Track (DNT)

You May Disable Local Device Storage

Online Behavioral Advertising (OBA) and How to Opt-Out of OBA

Transfer of Your Data Among Jurisdictions

Notice to California Customers Your Privacy Rights

This Privacy Policy governs all websites, apps, and other Services that link to, or contain references to, this document and are published or made available by Advance Local Media LLC, its parent, subsidiaries and affiliates (we, us or our). Please read this Privacy Policy carefully. It summarizes the various ways we acquire and treat your Data when you access, visit and/or use the Service. It also governs your Data that we may acquire offline. This Privacy Policy does not cover information collected on sites, applications, destinations, or services linked to from the Service that we do not own or control.

You can access this Privacy Policy any time in the footer of the Services home page, via the menu button/hamburger icon or on the Service description screen, or as otherwise indicated depending on the Service you are using. By purchasing a Product, registering for any aspect of the Service, or otherwise accessing, visiting or using the Service, you consent to this Privacy Policy. If you do not agree with the terms and conditions of this Privacy Policy, you should not access, visit and/or use the Service. We advise that you print or retain a digital copy a copy of this Privacy Policy for future reference.

In addition to reviewing this Privacy Policy, please also review our User Agreement and any other terms and conditions that may be posted elsewhere in the Service or otherwise communicated to our users, because the User Agreement and all such terms and conditions are also part of the Agreement between you and us.

All capitalized terms used in this Privacy Policy that are not otherwise defined have the meanings set forth in the Glossary. Personally Identifiable Information that alone or in combination with other information or in certain contexts can be used to identify, distinguish or trace you or your Device(s) is referred to in this document as PII. PII, together with all other information about you and/or your Device(s) that we acquire is referred to collectively as your Data.

This Privacy Policy may be modified from time to time, so check back often. So that you are aware changes have been made, we will adjust the Last Revised date at the beginning of this document. If we make a significant change in the way we use or share your PII, we will also post on the Service a prominent notice that a change was made. Continued access of the Service by you will constitute your acceptance of any changes or revisions to the Privacy Policy.

We acquire PII that may include, in certain contexts, your name, postal address, zip code, email address, and telephone number. We also acquire your IP address, User ID, and/or Device ID, which certain jurisdictions consider to be PII because it could be used to identify an individual or Device if it were combined with other identifying information.

In certain circumstances, such as when purchasing a Product, you may provide a credit, debit, or payment account number, or other payment information which we recognize as more sensitive than other PII. We generally do not request on or through the Service other Data that is often considered highly sensitive, such as other financial account information (e.g., credit report information, bank account numbers), personal health information, or government issued identification numbers (e.g., social security number, drivers license number, or passport number), although we reserve the right to do so when such Data is necessary to offer you certain services.

Some of the Data that we acquire cannot identify, distinguish or trace you or your Device, even if combined with other identifying information, and some Data that could be considered PII when combined with other identifying information is not used in a way that identifies, distinguishes or traces you or your Device, but is instead used in an anonymous way, often aggregated with other anonymous Data about other users.

We mostly receive PII because you provide it to us. For instance, when you enter a contest, complete a survey, purchase a Product, or register and/or set up an account/profile, you may be provided, or required to choose, a password and/or User ID, and you may provide a credit, debit, or payment account number, or other payment information, as well as your name, telephone number(s), email and/or street address. Other Data such as your age, gender, an avatar, and preferences may also be requested. In addition, we may acquire your Data when you contact us by telephone, postal mail, social media interaction or messaging (e.g., email, SMS, MMS, or similar technologies). We also may acquire information that you provide about other people, for example, when you use our refer-a-friend email feature or purchase one of our Products as a gift.

The Service may also automatically collect Data about you, your online behavior and your Device. The Data collected may include, without limitation, the make, model, settings, specifications (e.g., CPU speed, connection speed, browser type, operating system, device identifier) and geographic location of you and/or your Device, as well as date/time stamp, IP address, pages visited, time of visits, Content viewed, ads viewed, the site(s), application(s), destination(s), and/or service(s) you arrived from, and other clickstream data. The Service may collect your Data even if the Service is not open on your Device or youre not logged in.

We may also acquire your PII or other Data offline or otherwise outside of the Service. For example, we may purchase or otherwise acquire such Data from third party data suppliers. We reserve the right to merge or co-mingle this other Data with your PII and Data collected on or through the Service.

If you choose to access, visit and/or use any third party social networking service(s) that may be integrated with the Service, we may receive your Data that has been made available to those services, including information about your contacts on those services. For example, some social networking services allow you to push Content from our Service to your contacts or to pull information about your contacts so you can connect with them on or through our Service. Some social networking services also will facilitate your registration for our Service or enhance or personalize your experience on our Service. Your decision to use a social networking service in connection with our Service is voluntary. However, you should make sure you are comfortable with your Data the third party social networking services may make available us by visiting those services privacy policies and/or modifying your privacy settings directly with those services. We reserve the right to use, transfer, assign, sell, share, and provide access to all of your Data that we receive through third-party social networking services in the same ways as all of your Data we receive through our Service (as described in Section IV below).

Please be aware that Content and PII that you disclose in publicly accessible portions of the Service may be available to other users, and may also be made available outside the Service by third parties, so you should be mindful of all PII, especially sensitive PII, that you may wish to post.

We use your Data to process your request for Content and/or other Product(s). For example, if you subscribe to any of our Products we may use your e-mail address to send you a confirmation notice and your mailing address to send you the Product. Similarly, if you enter a contest, we will use your PII to notify you if you are a winner. If you enter a contest or submit Content to us (e.g., a letter to our editors or online review or comment), we may also publish your name, screen name, home town and other PII you have provided to us.

We also use your Data for any lawful business purpose in connection with administering the Service, including without limitation for customer service, to help diagnose problems with servers, to improve Products that we offer by tailoring them to your needs, to gather broad demographic information, to analyze trends, to seek compatible advertisers, sponsors, clients and customers, and to track users movements around the Service and elsewhere on the web or across apps and/ devices. Your geographic location Data may specifically be used to show you Content (including advertising and sponsored messaging) based on geographic location.

We may also allow access to your Data by Third Party Providers that provide us with services, such as technical maintenance, market research, community and forums management, auction services, e-commerce, personal/job search and other advertising functionality, but only for the purpose of and to the extent necessary to provide those services. And if you choose to purchase or subscribe to any Product(s), we may forward your Data to Third Party Providers for services such as credit/debit card or other payment processing, order fulfillment, credit pre-authorization, and address verification. There are also times when you provide Data to us in areas of the Service that may be managed or participated in by one or more Third Party Providers. In such cases, the Data may be used by us and by such Third Party Provider(s), each pursuant to its own policies. While we may seek to require Third Party Providers to follow appropriate privacy policies and will not authorize them to use your Data except for the express purpose for which it is provided, we do not bear any responsibility for any actions or policies of third parties.

We may also use your Data to communicate with you about new features, events or Products offered by us, Third Party Providers, our advertisers, and other companies and individuals with which we have a relationship.

We reserve the right to access, use, and share with others your Data for purposes of health, safety and other matters in the public interest. We may also provide access to your Data in order to cooperate with official investigations or legal proceedings brought by or otherwise involving governmental and/or law enforcement officials, as well as private parties, including, for example, in response to subpoenas, search warrants, court orders, or other legal process. We may also provide access to protect our rights and property and those of our agents, customers, and others including to enforce our agreements, policies, and terms of use.

If you provide your PII to us in connection with an employment inquiry, without limiting the applicability of the rest of this Privacy Policy, we will use your PII to evaluate your job application, and for related recruiting, reporting and recordkeeping purposes. We may maintain your PII on file, whether we hire you or not, to administer your relationship with us and/or for job applicant related reporting and recordkeeping for as long as required or permitted by law.

As our business changes, we may buy or sell various assets owned or controlled by us. In the event all or a portion of the assets are sold, assigned, transferred or acquired by another company due to merger, divestiture, restructuring, reorganization, dissolution, financing, acquisition, bankruptcy or otherwise, your Data may be among the transferred assets.

We reserve the right to merge or co-mingle anonymous, non-personally identifiable Data about you, your offline and online behavior, and/or your Device (including its geographic location), with your PII for any lawful business purpose.

We will not sell or rent your credit/debit card number or payment account Data. We may transfer such Data to Third Party Providers who need access to fulfill a transaction.

Unless otherwise specified on the Service, we may sell or share your Data among our parent, subsidiaries, and affiliates and with other third parties who we think may offer or enable you to become aware of Products that may be of interest to you.

If you do not wish to have PII such as your name, email address, postal address or phone number shared with third parties for their marketing purposes, contact our Privacy Policy Coordinator as described at the end of this document. But note that, in order for us to properly administer the Service, we must continue to share your Data with Third Party Providers as described in Section IV(C) above (if you object to such sharing, you should not use the Service). Note also that this option to opt-out applies only to PII, and not Anonymous Data.

If you do not wish to receive future marketing or other commercial messages from us, simply follow the unsubscribe instructions contained within the message you receive. But note that you may continue to receive certain communications from us that are necessary for the Service, such as renewal notifications, invoices, technical notices, updates, security alerts, and support and administrative service bulletins.

If you have registered on any part of the Service, please use the mechanism or contact information on the Service that allows you to change or update your member preferences, if available, to keep all such Data accurate and up-to-date. If no such mechanism or contact information is available on the Service, contact our Privacy Policy Coordinator as described below with your changes.

The Service will at times place and/or store code or other types of information and/or software on your Device or within your browser, such as cookies (including flash cookies), locally shared objects, and HTML5 (collectively, Local Device Storage). We and Third Party Providers may use Local Device Storage in connection with the Service for any lawful business purpose, including without limitation to determine whether you have seen a particular advertisement before on the same or different Device and to otherwise control the display of ads, to track the movements of individual users through the Service and elsewhere on the web or across apps, devices, and geographic locations, to help diagnose problems with servers, to gather broad demographic information, to conduct research, to deliver editorial Content, to record registration and personalization information, and to otherwise administer the Service. For example, if you register on any part of the Service and are given the option to save your user name and password, we may provide this convenience to you via Local Device Storage. Local Device Storage may also collect and store your PII, which may be shared with our parent, subsidiaries, and affiliates and other third parties.

If you do not want Local Device Storage, your Device or browser may include an option that allows you to not accept it. However, if you disable Local Device Storage, some portions of the Service may not function properly.

In addition to Local Device Storage, we may use web beacons, web bugs, internet or pixel tags, clear gifs, digital fingerprinting (aka Machine Identification) and similar technologies (collectively, together with Local Device Storage, the Tracking Technologies) on the Service and in our communications with you, such as within e-mail and text messages and push notifications. We use Tracking Technologies to determine which of our messages have been opened by recipients, and for all or some of the same lawful business purposes we describe above for use of Local Device Storage.

Your browser setting may allow you to automatically transmit a Do Not Track (DNT) signal to websites and online services that you visit. There is no consensus among industry participants as to what DNT means in this context, and some browsers automatically apply DNT signals by default and therefore do not necessarily reflect our visitors choice as to whether they wish to receive advertisements tailored to their interests. As a result, like many websites and online services, we do not alter our practices when the Service receives a DNT signal from a visitors browser. As discussed below, you may opt out of the use of your Data for online behavioral advertising by third parties at any time. To find out more about DNT, please visit

We and our Third Party Providers will at times also use Tracking Technologies for purposes of online behavioral advertising (OBA). OBA allows the serving of advertisements tailored to interests you have shown by browsing on the Service and on other sites, applications, destinations, and services, using the same or a different Device. To enable OBA, we and these Third Party Providers use Tracking Technologies to collect Data including for example the make, model, settings, specifications (e.g., CPU speed, connection speed, browser type, operating system, device identifier) and geographic location of your Device, as well as date/time stamp, IP address, pages visited, time of visits, Content viewed, ads viewed, the site(s), application(s), destination(s), and/or service(s) you arrived from, and other clickstream data. The use of Tracking Technologies by Third Party Providers is subject to their own privacy policies, not this Privacy Policy, and we have no responsibility or liability in connection therewith.

If you do not want OBA, you may be able to opt-out by visiting by clicking the Ad Choices icon that appears in advertising served through OBA. Please note that the option to opt-out applies only to tracking by Third Party Providers across this Service and other sites, applications, destinations, and services, and not tracking among pages within the Service itself.

We are a U.S.-based company and our Service is geared to a U.S. audience. Your Data may be processed, transferred to, and maintained on, servers and databases located within the U.S. and elsewhere where the privacy laws may not be as protective as your jurisdiction. We reserve the right to transfer your Data to and from any state, province, country or other governmental jurisdiction. Your consent to this Privacy Policy followed by your submission or our collection of such Data represents your agreement to any such transfer.

We take commercially reasonable security measures to protect against unauthorized access to, or unauthorized alteration, disclosure or destruction of, PII that you share with us.

Because no data transmission is completely secure, and no system of physical or electronic security is impenetrable, we cannot guarantee the security of the Data that you send to us or the security of servers, networks or databases, and by using the Service you agree to assume all risk in connection with your Data. We are not responsible for any loss of such Data or the consequences thereof.

In the event that we believe the security of your Data in our possession or control may have been compromised, we may seek to notify you. If notification is appropriate, we may notify you by e-mail, push notification, or otherwise.

Californias Shine the Light law, Civil Code Section 1798.83, gives California customers the right to prevent our disclosure of their personal information to third parties for those third parties direct marketing purposes, and requires certain businesses to respond to requests from California customers asking about the business practices related to disclosing personal information to third parties for the third parties direct marketing purposes. Alternately, such businesses may have in place a policy not to disclose personal information of customers to third parties for the third parties direct marketing purposes if the customer has exercised an option to opt-out of such information-sharing. We have such a policy in place. As discussed above in Section V(C), if you wish to opt-out of our sharing of your Data with third parties for the third parties direct marketing purposes or to find out more about your opt-out rights, please contact our Privacy Policy Coordinator as described below.

Californias Online Erasure law, Business and Professions Code Sections 22580-22582, requires operators of certain websites and online services to allow registered users who are under the age of 18 and residents of California to request removal of Content they post. If you fit that description and posted Content on a section of our Service that is directed to minors, you may request removal of the Content by contacting our Privacy Policy Coordinator as described below. In response to your request, we may elect to make the Content invisible to other users and the public (rather than deleting it entirely), in which case the Content may remain on servers we control and/or may be publicly available elsewhere if a third party copied and reposted the Content.

If you have any concerns or questions about any aspect of this policy, please feel free to contact our Privacy Policy Coordinator as follows:

As discussed above in Section V(B) and XI, you may opt-out of having PII such as your name, email address, postal address or phone number shared with third parties for their marketing purposes. If you wish to exercise this right, please contact our Privacy Policy Coordinator and state which of these items you wish to opt-out of sharing with third parties.

Also, as discussed above in Section V(D), if you have registered on any part of the Service and you wish to update or make changes to your PII on file with us, you may contact our Privacy Policy Coordinator.

Make sure to include enough information for us to help you, including for example your name, contact information, and the specific website, mobile site, application, and/or other service youre contacting us about.

Note: Only inquiries about this policy or your PII should be sent to the Privacy Policy Coordinator. No other communications will be accepted or responded to.

For communications on other matters, please contact us through the means described on the Service, if available (for example, in the Contact Us section).

Blackboard Privacy Statement

How We Use Your Information Depends on Your Relationship With Us

Vendors, Partners & Other Types of Disclosures

Client Engagement & Marketing

Childrens Privacy

Security

Data Transfers & Additional Regional & Country Information

Your Rights

Contact Us

Summary

Introduction

How We Use Your Information Depends on Your Relationship With Us

Vendors, Partners & Other Types of Disclosures

Client Engagement & Marketing

Childrens Privacy

Security

Data Transfers & Additional Regional & Country Information

Your Rights

Contact Us

This summary highlights the key points of our Privacy Statement. You can find details for each point by clicking on the links.

We care about your privacy and have a dedicated data privacy program. We do not and will not sell or rent your data unless this is required in the context of a change to our business structure.

Learn more about our approach to data privacy.

This Statement applies to our Blackboard websites as well as to the products and services mentioned in section 3.C. For all other products and services, your institutions privacy statement governs.

Learn more about how we use personal information

We share personal information with vendors that help provide our products and services. We also share personal information with partners and other third parties in certain circumstances.

Learn more about how we share personal information

We conduct marketing to promote our products and services. This marketing is aimed at staff of our current and potential clients and partners. We do not use or disclose student information for behavioral targeting of advertisements to students.

We do not knowingly collect any personal information from children under the age of 13 without consent.

Learn more about how we use childrens personal information

We employ a variety of physical, technological and administrative security safeguards designed to protect personal information.

Learn more about our security safeguards

We may transfer your information to locations outside of your country.

Learn more about data transfers and country-specific privacy information

if you want to exercise your privacy rights, have a complaint, or want to ask a question.

Learn more about your rights and how you can contact us

This Statement was last updated on May 24, 2018. Whats new?

We care about privacy.We believe that privacy is a fundamental right for all individuals. Our clients entrust us with the personal information of their employees and their users, who are often students. We take the obligations that are attached to this information very seriously. We therefore have a dedicated data privacy program with privacy by design at heart. You can learn more about our data privacy program by visiting ourPrivacy Center.

Our business model is different from that of companies that collect your personal information to monetize such data. We collect and use personal information to allow us to provide our products and services to our clients and end users. In most cases, we do this at the direction of our clients. We do not and will not sell or rent your data to third parties unless this is required in the context of changes to our business structure such as a merger or acquisition. SeeVendors, Partners & Other Types of Disclosuresfor more details on how we may disclose personal information in the context of changes to our business structure.

We are EU-U.S. Privacy Shield certified, a proud signatory of the Privacy Pledge, and a member of the Future of Privacy Forum.

Who we are.When we refer to us, we, our, or Blackboard in this Statement, we mean Blackboard Inc. and its affiliates.

This Statement governs all our services that we provide directly to you.Whether you are browsing our websites, receive our newsletters, or use an online trial version of our products, this Statement governs the use of personal information for all our products and services that we provide directly to you as a so-called data controller.

When your institutions privacy statement/policy governs.If you are an end-user of our client and we are providing our products and services to you on our clients (your institutions) behalf, we are considered a data processor. In this case your institutions privacy statement governs the use of personal information. Our Privacy Statement does not supersede the terms of any agreements between us and your institution (or any other client or third party), nor does it affect the terms of any agreement between you and your institution.

Changes to this Statement.From time to time we will need to update this Statement to reflect changes to our products and services, the way we operate, or to meet new legal and regulatory requirements. You will find the latest version of this Statement at. We will explain changes to this Statement on theWhats new?page.

What personal information we collect and how we use it will depend on your relationship with us. Please click on the plus symbol to collapse or expand the relevant section below to learn more. The other sections in our Statement apply to all our activities.

Blackboard has various websites for different services (for example,Blackboard HelpandBlackboard Community) and geographies that are accessible to anyone. You generally can visit our websites without having to log in or otherwise identify yourself. On some of our websites, you may need to log in to benefit from the service or to make use of all the functionalities and be able to communicate with us or other Blackboard users, such as with Blackboard Community and Behind the Blackboard.

Some of our websites require you to sign up for an account. When you do, we ask you for information, such as your name and email address, that we need to set up your account. Often you can also voluntarily provide additional information, such as a photo or biographical information, to make better use of our websites. We also collect information you provide by completing forms or surveys on our websites. If you provide additional content through user forums, for example, when you communicate with others on Blackboard Community, we may link this information with your personal information if you are logged in.

We collect information about the pages you visit and how you access and use our websites using cookies and third-party analytics tools. This information includes information about the device(s) you use to access the websites including unique device identifiers, IP address, operating system, browser, and cookies. Depending on your device settings, we may also collect information about your geographical location. Learn more about our use of cookies in our

We receive information from affiliates in our Blackboard group of companies, our partners, and other third parties that we use to enhance the website experience and promote our products and services. For example, we will receive information from some third parties about how well an online marketing or email campaign performed.

We use this information to provide and improve our website services as follows.

Analytics and marketing.We analyze usage information for sales and marketing purposes and for trends about our visitors and their demographics and how they use our websites. This analysis is necessary to further our legitimate interest in understanding our users and how they interact with us and our websites, improving our websites and communication with you (including for marketing purposes).

Personalization.For some of our websites we also use your information to personalize the pages, which is necessary to provide more contextually relevant information as you browse our websites. For example, if you have indicated your primary industry or your job title, we may present content related to your role or industry as your browse our websites and return to them.

Communication.If you use Behind the Blackboard, Blackboard Community, or other websites with logins, we use the contact details you provided to communicate with you and to let you communicate with us and other Blackboard users. Typically, we use information in this way because it is required to provide this service to you and because it is in our legitimate interests to ensure our services are being offered in a manner that meets our high standards.

We keep website usage information for as long as it is necessary for the purposes described above. This period of time will vary depending on the services and websites you use and how you interact with us. Account information is kept until you delete the account and for a limited period afterwards. Where you provide information in forms, the information is kept only as long as required. For example, we may need to keep a record of the correspondence with you if you have made a complaint for as long as it is necessary to protect us from any legal claim. Similarly, if you unsubscribe from receiving marketing communications from us, will keep a record of this to ensure you do not receive such communications in the future.

Third-party tools.Where we use third-party tools (for example to understand how our websites are used and make sure you see relevant ads and campaigns on other websites), these third parties will have access to some of your personal information. This includes analytics tools such as Google Analytics and advertising tools such as Facebook Business.

Learn more aboutand about our use of cookies in ourCookie Statement.

Partners.We share personal information with resellers of our products and services and other partners, who may use such information for marketing.Learn more about sharing with partners.

Vendors.We also share information with our vendors and service providers and other third parties for legal or business purposes.Learn more about how we ensure your information is protected by our vendors.

Your institution decides how your personal information is used.We provide most of our products and services to end-users of an institution as a so-called data processor on behalf of our clients (for example, school, districts, universities, and corporations). This means that the main responsibility for data privacy compliance lies with your institution as the data controller. It also means thatyour institutions privacy statement governsthe use of your personal information (instead of ours). Your institution determines what information we collect through our products and services and how it is used, and we process your information according to your institutions instructions and the terms of our contracts with your institution.

Read your institutions privacy statement.The following section is mainly for informational purposes and describes how your information is generally used when we provide products and services to you on behalf of a client. How your information is used depends on your institution, so you should read your institutions privacy statement.

For our Web Community Manager product, please read the separateWeb Community Manager Privacy Policy.

Information your institution provides to us.

Typically, our products and services integrate with your institutions systems. As such, your institution will provide us with information about you to set up and maintain your account or for us to be able to provide the product or service. This includes information in the following data categories:

The exact data elements will depend on the product, but often we receive your name, email address, student ID, account credentials, and courses you are enrolled in when we initially set up the products and services for your institution. We will receive regular updated information to keep your account information accurate and up to date.

For some products, such as Connect and ConnectTXT, we also receive your phone number to send you text (SMS) notifications.

Application, enrolment, and financial aid information.

If we provide Student Services, such as enrollment helpdesk or admission and financial aid support, on behalf of your institution, your institution will make this type of information available to us to provide these services. We generally dont store this information but may have access to your institutions systems that store such data.

Depending on the products and services you use, we will collect the following data categories directly from you:

We collect your first and last name, email address, and similar contact data when you provide or update this information in our products. In many products and services, you can choose to provide more information for your account profile, such as your photograph and other biographical content, which may be shared with others through the products and services. In some products, you can choose to provide your phone number to receive notifications via text (SMS). In our Mobile Learn App you can also give us permission to access your contact list on your mobile device. This allows us to match your contacts to users in Learn and display their photo from the users contact list in discussion boards.

Our products and services often integrate with your institutions systems and rely on the credentials your institution uses. Where this is not the case, we will collect passwords, password hints, and similar security information that we use for authentication and account access.

We collect data about your responses to quizzes, your assignments and other course work, and files you submit or upload as well as your activity and actions within our products and services. In some products, you can also provide comments in discussion forums and chats and send messages to your peers and instructors. If you are an instructor, we also collect information about your grading, feedback and assessments, and similar actions within our products.

Some of our products allow you (as a student or instructor) to submit audio and video feedback, and we collect the related information, including metadata.

If we provide financial aid support on behalf of your institution, we will collect financial information that is required to help you with the related applications.

For some of our products and services, such as Cashnet, we collect data necessary to process your payments, including your credit card number and the security code associated with your credit card. We maintain the applicable Payment Card Industry (PCI) compliance levels for such data.

When you or your institution contacts us for support, we may collect limited information about you that you or a representative of your institution provides to us. We use this information only to assist with client support cases on behalf of your institution. When you contact us, your phone conversations or chat sessions with our client support teams may be monitored and recorded for training and quality purposes. Some of our products and services such as the Blackboard App also have feedback functionality that collects limited information about your device, the product, and your institution such as your user ID and school ID when you provide feedback.

We collect information on how you use our products and services. Depending on which product or service you use, this may include the following data categories:

Our Collaborate product allows for virtual classroom sessions to be recorded. There is an indicator if the session is being recorded.

For some of our Campus Enablement products and services, such as access cards and Attendance, we will collect information about which premises, classes, and events you have visited and attended on behalf of your institution, as well as the time and date of such visits. Additionally, we may collect precise geolocation data when you use the mobile apps for some of our Campus Enablement products. You will be asked if you want to enable location data before we collect such information from your device.

Our Mass Notification and Connect products will collect information on how you react to our notifications. For instance, we record if you listened to our phone call, if we left a voice message, or if the phone call was unanswered.

We collect device and usage information when you access and use our products and services, including information that your browser or the mobile app sends when you are using it. This data may include your unique device identifier, Internet Protocol address, your browser type and configuration, the date and time of your use of the product or service, language preferences, and cookie data. Learn more about our use of cookies in our

We may receive information from affiliates in our Blackboard group of companies, our partners, and other third parties. For example, we may receive limited personal information from our other products or from third-party services that integrate or complement our products to ensure a seamless experience.

Information from social media sites.

When you interact with our products and services through social media services, such as when you log in through Facebook, use Cloud/Social Profile, or share Blackboard content on Facebook, Twitter, or LinkedIn, we may receive information from these social media companies. For instance, when you login to a service like CourseSites using a social media account, the social media company will authenticate your identity and provide you the option to share certain personal information from your social media profile with us, which could include your name, email address, age, gender, position, and profile picture. If your institution has enabled Cloud Profiles or Social Profiles, you can also connect your Blackboard profile with your Facebook and Twitter account and use information from those accounts for your Blackboard profile. The data we receive is dependent upon the social media service and your privacy settings with the social media service.

Our Social Media Manager product allows institutions to collect public social media posts and comments with matching keywords and hashtags to give an institution visibility into social conversations taking place about them. Social Media Manager will retain this information for the institution even if the original content was deleted.

On behalf of your institution.We use your information on behalf of and under the instruction of your institution, which is the data controller. We use the information in accordance with our agreement with your institution to operate, maintain, and provide the features and functionality of the products and services. Your institution determines how your information is used.

Analytics.Providing our products and services to your institution may include analytics functionalities. Among other things, such functionalities can indicate your performance compared to that of your peers, project your future performance, and provide this information to instructors and other staff of your institution so they can support you.

Please read your institutions privacy statement for more details on how your institution uses your personal information.

Product enhancements and research.Where the agreement with your institutions gives us the permission, we may also use:

Your personal information to evaluate and improve our products and services and develop new products and services

De-identified information for other purposes such as carrying out research and analyzing trends to better understand how users are using our products services and how we can further improve them

When we use information for these purposes, we will implement appropriate safeguards. This may include removing or hashing direct identifiers (e.g., your name, email address, and device ID) from the data set before carrying out research and analysis.

We share your information in accordance with our agreement with your institution. Generally, this includes the sharing of data within and outside of Blackboard.

Your information will be accessed only by those who have a need to know to provide the products and services to your institution and improve them. For instance, our technical teams and client support teams may have access to your information when we set up the product for your institution or when software or database changes are required for support and maintenance purposes.

Much of the personal information we collect and use about you is shared with your institution that uses our products and services and with other institutional users. What information is shared depends on the product functionality, settings, and instructions of your institution. Please read your institutions privacy statement to learn more.

We use vendors to help us provide our products and services to you on behalf of your institution. For example, IBM, Amazon Web Services, and Microsoft help us host our products and services. Where we use third-party tools (for example to understand how our products and services are used), these third parties will have access to some of your personal information. This includes analytics tools such as Google Analytics (

Your institution may ask us to share such information with additional parties or it may share your information further. Please read your institutions privacy statement.

Learn more about how we share information.

If you are using online trial versions of our products, such as Learn, Collaborate, or Moodlerooms, we are providing these products and services directly to you as the data controller. Similarly, if you are using our Open Education service directly with us (instead of as instructed by your institution), we are considered a data controller. In these instances, we are directly responsible for data privacy compliance andthis Privacy Statement governshow your information is used.

Depending on the products and services you use, we will collect the following data categories directly from you:

We collect your first and last name, email address, and similar contact data when you provide and update this data in our products. In many products and services, you can choose to provide more information for your account profile, such as your photograph and other biographical content, which may be shared with others through the products and services. In some products you can choose to provide your phone number to receive notifications via text (SMS).

We collect passwords, password hints, and similar security information that we use for authentication and account access.

We collect data about your responses to quizzes, your assignments and other course work, and files you submit or upload as well as your activity and actions within our products and services. In some products you also can provide comments in discussion forums and chats and can send messages to your peers and instructors. If you are an instructor, we also collect information about your grading, feedback and assessments, and similar actions within our products.

Some of our products allow you (as a student or instructor) to submit audio and video feedback, and we collect the related information, including metadata.

When you contact us for support, we may collect limited information about you that you provide to us. We use this information only to assist with client support cases. When you contact us, your phone conversations or chat sessions with our client support teams may be monitored and recorded for training and quality purposes.

We collect information on how you use our products and services. Depending on which product or service you use, this may include the following data categories:

Our Collaborate product allows for virtual classroom sessions to be recorded. There is an indicator if the session is being recorded.

We collect device and usage information when you access and use our products and services, including information that your browser or the mobile app sends when you are using it. This data may include your unique device identifier, Internet Protocol address, your browser type and configuration, the date and time of your use of the product or service, language preferences, and cookie data. Learn more about our use of cookies in our

We may receive information from affiliates in our Blackboard group of companies, our partners, and other third parties. For example, we may receive limited personal information from our other products or from third-party services that integrate or complement our products to ensure a seamless experience.

Information from social media sites.

When you interact with our products and services through social media services, such as when you log in through Facebook, or share Blackboard content on Facebook, Twitter, or LinkedIn, we may receive information from these social media companies. For instance, when you log in to a service using a social media account, the social media company will authenticate your identity and provide you the option to share certain personal information from your social media profile with us, which could include your name, email address, age, gender, position, and profile picture. The data we receive is dependent upon the social media service and your privacy settings with the social media service.

To provide features and functionality.We use your information to operate, maintain, and provide to you the features and functionality of our products and services, as well as to communicate directly with you (for example, to send you email messages and push notifications) to allow you to communicate with others in the product and service. Typically, it will be necessary for us to use your information in this way in order to provide you with the service you request or because it is in our legitimate interests to ensure our products and services are being offered in a manner that meets our high standards.

Analytics.Some of our products, such as our Learn trial version, include analytics functionalities. Among other things, such functionalities can indicate your performance compared to that of your peers and project your future performance. Typically, it will be necessary to use your information in this way to provide this functionality or because it is in our legitimate interests to ensure this functionality operates to our high standards.

Improve our products.We use de-identified information to understand and improve our products and services. We carry out research and analyze trends typically because it is in our legitimate interests to better understand how users are using our products services and how we can further improve them. When we use information for these purposes, we will implement appropriate safeguards. This may include removing or hashing direct identifiers (e.g., your name, email address, and device ID) from the data set before carrying out research and analysis.

Marketing.When you use our trial versions, we may use your information for marketing purposes.Learn more about marketing.

We share information to provide the products and services to you and further improve them.

Your information will be accessed only by those who have a need to know to provide the products and services. For instance, our technical teams and client support teams may have access to your information when software or database changes are required for support and maintenance purposes.

We use vendors to help us provide our products and services to you. For example, IBM and Amazon Web Services help us host our products and services. Where we use third-party tools (for example to understand how our products and services are used), these third parties will have access to some of your personal information. This includes analytics tools such as Google Analytics (

). We may also share that you have registered for a trial version with the relevant channels partners in your country or region.

Learn more about how we share personal information.

This section provides more information on how we protect your information when we engage vendors, how we share information with our partners, and in which other scenarios we may share your information with third parties.

We use vendors to help us provide our products and services to our clients and you or to perform work on our behalf. Where this requires access to personal information, we are responsible for the data privacy practices of the vendors. Our vendors must abide by our strict data privacy and security requirements and instructions. They are not allowed to use personal information they access or receive from us for any other purposes than as needed to carry out their work for us.

In some countries and regions, our products and services are offered through channel (or reselling) partners (see the list of our channel partners).We will share information with them that is necessary for them to offer and provide our products and services to our current and prospective clients.

Some of our products allow you to access functionalities or content provided by our content and technology partners. For example, Blackboard Learns integration with Dropbox Education allows institutions and users to store and share content using Dropbox functionalities. With your or your institutions permission, we will share information about you, such as your name, email, or student ID, that is required for you to access these partner functionalities or content from our products and services.

We will also share your information where required in the following circumstances.

W

Mattel Online Privacy Statement

Child-Directed Website Request Form

American Girl Communications Preferences

Child-Directed Website Request Form

American Girl Communications Preferences

Your privacy is important to us at theMattel family of companies. This privacy statement describes theinformationMattel collects from you, through our interactions with you and through ourMattel Services, and how we use that information. It also describes what informationthird partiescollect from you, and how we and they use that information. Key terms are italicized and underlined(like this) and can be found in theDefinitionssection. This Privacy Statement provides examples of data we collect, how we use it, and choices you can exercise; these examples may not be exhaustive or exclusive.

This statement applies toMattel Services, includingMattel Sites, apps, mobile apps, online services, and connected products.Mattel Sitesare also subject to theMATTEL TERMS AND CONDITIONS. Other terms, end-user license agreements, or additional rules may apply. Each time you useMattel Services, you agree to this statement. If you dont agree with all the terms of this privacy statement, please do not useMattel Services.

We want you and your family to have fun using our services and urge you and your family to follow common sense when disclosing personal information, both through our services and anywhere else.

We at Mattel pride ourselves on helping bring delight to children around the world and take our responsibility to children seriously. Please visit theMATTEL CHILDRENS PRIVACY STATEMENTfor specific details on our childrens privacy practices.

Child/children (kid/kids).Individuals who are not of legal age to consent to the collection and processing of their personal information.For most areas of the world, those are individuals under 13. In the European Economic Area (EEA), they are individuals under 16. We adhere to local definitions of children for Mattel Services located in jurisdictions where the age is different.

Information.Data we collect. It includes, in alphabetical order:

Automatically collected information.Informationautomatically collected when you useMattel Services, including information to facilitate your experience and help us understand our visitors, like yourdeviceinformation, information about the network you are using to accessMattel Services(such as preferred language or online sites or services visited before you visit a Mattel Service), and content (including ads) that you see or click on.

Device information.Informationabout the device, browser, or app you are using to access a Mattel Service, such as operating system, browserinformation, Internet Protocol (IP) address, Universal Device Identifiers (UDID), and similar information.

Interest or demographic information.Information about a users favorite games, colors, Mattel characters, and similar preferences; orinformationabout a visitor or user, such as gender, age, education, profession, occupation, or other information.

Location information.Information that allows you to be precisely located, such as through GPS coordinates on a mobile app.

Login information.Information to identify and validate a user to allow access to a Mattel Service. Forchildren, this is usually a user name and password. For adults, this is usually a password plus somepersonal contact information, like an email address.

Order information.Information provided to purchase a product orMattel Service, including details necessary to fulfill the transaction, such as products ordered,payment information, andpersonal contact information.

Payment information.Credit card numbers or other financial institution-issued information provided to complete a transaction, including (as applicable)personalcontact information.

Personal information.Information that identifies (whether directly or indirectly) a particular individual, such as the individuals name, address, email address, device identifier, telephone number, or assigned identifier. When anonymous information is directly or indirectly associated with personal information, this anonymous information also is treated as personal information.

Forchildren,personal informationalso includes photos, video, and audio of thechild.

Personal contact information.Information that allows us to contact you directly, such as your full name, email address, home address, telephone number, mobile number, etc.

Survey information.Answers to surveys or questionnaires voluntarily provided.

Social sign-on information.Login informationand other information (such as friend lists) from a social network that a user chooses to share with Mattel to access aMattel ServiceorMattel Site.

Third-partyprovided information.Data shared with theMattel family of companiesthrough athird party.

User-generated content.Information you post or upload, like reviews, comments, videos or pictures, or social media interactions. Read more atUser-Generated Content.

Interest-based advertising.Targeted ads for products and services that, based on your activities, are likely to be of interest to you.

Mattel family of companies.When we refer to the Mattel family of companies in this statement, we mean:

Mattel Sites.Websites offered by theMattel family of companies. SeeMattel Services.

Mattel Services.All online services offered by theMattel family of companies, including websites (MattelSites), apps, and connected products. Read more atMattel Services.

Third party.A company unrelated to theMattel family of companies, including third-party sites that we link to, or third parties that operate online stores or mobile app stores. Read more atThird-PartyPartnersand Third-Party Technology Partners.

Third-party partner or third-party service provider.Athird partythat Mattel has engaged to help it provideMattel Services, including agents, vendors, service providers, and others.

Third-party technology partners.Third parties whose technologies we use to offer content, understand our users, and deliver advertising.

Mattel Servicesare online services offered by theMattel family of companies, including:

Connected products. Check specific connected productFAQSfor info on features, whos responsible for privacy, and what information is collected.

You may have to interface with athird partyto make a purchase, download an app, or use a connected product.

You may have the opportunity to connect an app or connected product through a wireless service.

We offerMattel Sitesthat feature games, information, shopping, and other interactive and static activities from theMattel family of companies.

SomeMattel Sitesor areas of sites are intended forchildren, and some are intended for adults. Learn more about sites forchildrenand specific practices for them at ourCHILDRENS PRIVACY STATEMENT.

You do not have to share anypersonal contact informationto use mostMattel Sites, but mostMattel Sitesfor adults and teens contain special sections and privileges for members who register.

We offer opportunities to purchase products in our online stores, apps, or through other media or business partners. Online stores are often part of a largerMattel Site.

Customers must be over the age of 18 with a valid payment method to make a purchase.

When a customer places an order online, we will send a confirming email message.

We may also send an occasional email featuring a special promotion or product that may be of interest to customers.

Any customer who prefers not to receive an online order confirmation or promotional email may indicate this preference on the online store order form.

If you do receive marketing or promotional emails from us that you would rather not receive, simply follow the unsubscribe instructions included in each message.

You can also change your communication preferences inMATTEL COMMUNICATIONS PREFERENCES(except for American Girl) or inAMERICAN GIRL COMMUNICATIONS PREFERENCES(for American Girl only).

Please note that a request to unsubscribe from marketing or promotional emails will not affect transactional emails (such as those related to a purchase, paid subscription, or product registration).

EnhancedMattel Servicesmay be available to you or on behalf of yourchildfor a monthly or other fee with someMattel Services.

Only a parent or guardian can registerchildrento participate in enhanced subscriptionMattel Servicesor certain community features atMattel Services.

To register yourchild, we will ask you to provide yourlogin informationin addition to your contact details and credit cardinformation.

We may offer you the option to be billed automatically for subscription service fees.

If you elect to automatically renew a subscription, we or our trustedthird-party partnerswill retain your registrationinformation, including your credit cardinformation, so we can process your request.

We offer a variety of fun and engaging apps featuring our brands. In some cases, apps may be available through a Mattel Online Store, but most often when you download or purchase an app, or make an in-app purchase, you do so through a third-party mobile application online store. VisitLINKS AND THIRD PARTIESfor more information.

Please note:Use of apps may be subject to an End-User License Agreement (EULA) in addition to our standardMATTEL TERMS AND CONDITIONS.

Mattel offers parents andchildrena variety of products that connect to the internet. We sometimes work withthird-party partnersto offer connected products.

Some connected products, like connected baby monitors, are purely for parents use.

Use of connected products typically requires downloading an associated app.

Privacy practices for some connected products are the responsibility of athird party.

We provideFAQSand other information to help you understand specific connected product features (for example, whether they collect voice or visual data), whos responsible for privacy, and whatinformationwe collect.

We may communicate with you on your mobile device. To receiveMattel Servicesthrough a wireless connection, visitors must provide their consent and confirm their understanding that they will be charged by their carrier to send and receive messages according to their applicable service plan. You may be asked to reconfirm such agreement.

Standard messaging rates will apply unless otherwise indicated; if premium rates apply, visitors will be notified before registration.

Mattel is not responsible for wireless service charges, such as messaging fees, associated with accessing or connecting toMattel Services

We collectinformationto allow you to register to use aMattel ServiceLogin informationis often all we need to register you.

We collectpersonal contact information.

We collect otherpersonal informationabout you, such asinterest or demographic information, etc.

We collectuser-generated contentwhere aMattel Servicegives you that option.

We collectdevice informationautomatically collected information, andinformationthat helps you accessMattel Services(such aslogin information, Wi-Fi network name, etc.).

We collectinformationfrom you and about you to provide you withMattel Services. Theinformationwe collect depends on the specificMattel Servicesinvolved.

Automatically collected information.

A ship-to name and address when you make a purchase and ask us to send it to you or to someone else.

The email addresses, user names, or otherinformationabout friends to whom you wish to send an e-card or invite to participate in an offering onMattel Services.

Informationabout yourchild(such as yourchildspersonal informationandpersonal contact information, includinginterest or demographic information).

Informationthat allows us to confirm that you are the parent or legal guardian of yourchild, including your age.

Please visitABOUT COOKIES AND TECHNOLOGIESfor more information on technologies used to collect your information automatically.

We Collect Information That You Share Voluntarily

You can use many of ourMattel Serviceswithout sharing anypersonal contact information. If you choose, you can sharepersonal contact informationpersonal informationlogin informationinterest or demographic information, orsurvey informationabout you or yourchildwith us when you:

Make a purchase at one of our online stores (seeWE COLLECT ORDER INFORMATION).

Sign up to receive information and offers.

Respond to a survey or questionnaire.

Postuser-generated content. Special rules apply; read more atUSER-GENERATED CONTENT.

When a customer puts an item in a shopping cart, places an order or requests a catalogue online, we collectorder informationassociated with the transaction. This may includepersonal informationabout yourchild.

Customers may register when they place orders to conveniently complete an order and place future orders. When registered customers return to the Site to place subsequent orders, they can identify themselves with theirlogin information.

We Collect Information Automatically When You Access a Mattel Service

We collect someautomatically collected information, includingdevice information, to provide you with appropriateMattel ServicesorMattel Sites(for example, in your language) when you use or visit them.

We collectinformationfrom you to serve your needs, manage our content and advertising, operate efficiently, and improveMattel Servicesand products.

We collectinformationto do what you ask us to.

We collectinformationto provide you information onMattel Servicesand products that you or yourchildmay be interested in.

We collectinformationto supportMattel Servicesand operations.

We collectinformationto improveMattel Services.

We collectinformationto improve our products.

We collectinformationto offer you content.

We collectinformationto advertise to you.

We collectinformationto maintain security.

We collectinformationto protect our legal rights and the legal rights of others.

To give you updates about your order status.

To fulfill your free or paid subscriptions.

To notify winners in contests and sweepstakes.

To send you recommendations onMattel Servicesof interest to you or yourchildren.

To send you recommendations on products of interest to you or yourchildren.

To send you marketing communications.

To analyze and measure the effectiveness of our advertising.

To maintain the security, integrity, and quality of our products andMattel Services.

To protect the legal rights of others.

We may work withthird-party partners, includingthird-party technology partners, for some or all of these purposes. You can learn about some of thesethird partiesby visitingABOUT COOKIES AND TECHNOLOGIES.

We may combine allinformationwe have collected to better understand your needs, improveMattel Servicesand operations, manage content and advertising, send you offers and information, and better serve you.

If under the laws of your region we need to get your consent to collect theinformationfor a particular purpose, we will do so at the time we collect theinformation.

We sometimes getthird-partyprovided informationabout you and combine it with otherpersonal informationthat weve collected.

We may collect authenticationinformation.

We Collect Information from Other Sources

We might getthird-partyprovided informationabout you from commercial sources. We may combine thatinformationwith otherpersonal informationabout you that weve collected.

We may also collect authenticationinformation(for example, to verify that you are an authorized credit card holder).

We shareinformationwe obtain within theMattel family of companies,and with ourthird-party partners.

We share somepersonal contact informationwith third parties for marketing purposes with your consent.

As is customary with catalogue businesses, we share mailing addresses (but not email addresses) with other catalogue companies whose products and services may be of interest to you. Where required, we obtain your consent first. We give you the opportunity to opt out.

If you providesocial sign-on information, Mattel sharesinformationwith your social network.

We shareinformationabout usage and interests that we obtain through cookies and technology withthird-party technology partners, and obtain consent if required by applicable law. Find out more aboutYour Choices and Controls.

We share anyinformation(includingpersonal information) we obtain as necessary to satisfy a legal request or subpoena, protect property or personal safety, when a Mattel business is bought or sold, or as otherwise permitted or required by law.

We shareinformationthat we obtain within theMattel family of companies, and with ourthird-party partnersfor them to fulfill their tasks on our behalf.

Except as described in this Privacy Statement, we do not sharepersonal contact informationthat we receive online from or aboutchildrenwith other companies outside theMattel family of companiesfor their direct marketing purposes.

Sharing with Our Third-Party Partners

We may share yourinformationwith a variety ofthird-party partners. They:

Provide database and server maintenance and security.

Help us process and fulfill orders or requests.

They also provide other similar services to theMattel family of companies. We require third-party partners that accessinformationto safeguard theinformation.

Sharing with Third Parties for Marketing Purposes

We share certain names and mailing addresses of catalogue recipients withthird partieswhose catalogues may be of interest to you. Where required, we obtain your consent first. You can opt out at any time.

With your consent, Mattel sharespersonal contact informationwith outside companies that offer products or services that may interest you.

We will remove your name from the list we provide to outside companies if you contact us. Please visitMattel Communications Preferences(except for American Girl) orAmerican Girl Communications Preferences(for American Girl only).

If you providesocial sign-on informationto log in to aMattel ServiceorMattel Siteinformationis shared with your social network, such as the fact that you logged in to a Mattel Service or Mattel Site, or your activity on theMattel ServiceorMattel Site. We may send messages via the social network to communicate with you.

Sharing with Third-Party Technology Partners

We shareinformationabout usage and interests that we obtain through cookies and technology withthird-party technology partners, and obtain consent if required by applicable law. Find out more atYour Choices and Controls.

Sharing to Protect Legal Rights and Fulfill Legal Obligations

If Mattel believes that anyones behavior in anyMattel Servicemay damage us,Mattel Services, or any person or property, we may disclosepersonal informationto prevent such harm. In that case, we might try to identify the wrongdoer, contact them, or bring legal action against them.

We may disclosepersonal informationif we believe that the disclosure is required or permitted by law, or in response to a legal request or subpoena.

Mattel Servicesmay link to or use other content from the internet. We do not control the data collection practices or terms of use of anythird-partysite. Thethird partys privacy policy and terms of use apply to those sites.

Your computer or mobile device settings may allow you to block or partially block other content, but those settings may not be effective in all cases.

You may be able to order or register through athird-partyvendor. Thethird partys privacy policy and terms of service apply to activity conducted with the third-party vendor.

We work withthird-party partnersto offerMattel Services.

Mattel Servicesmay connect with other content from the internet that we do not control.

We may link to social media sites or sites that sell our products.

We may link to otherthird-partysites or services that we think you may find of interest.

We encourage you to carefully review the privacy policy and terms of use of the third-party providers, as they are not covered by this Privacy Statement, and Mattel is not responsible for them.

You may be able to alter settings on your browser, device, or other software to block those third parties. Sometimes those settings may not be effective.

When you place an order or register on aMattel Servicewhere transactions are handled by a third-party vendor (for example, PayPal), those transactions are conducted through the vendors website.

You should be sure to review thethird partys website terms and conditions and privacy policy before submitting anypersonal informationor engaging in any transactions through the third-party site.

Mattel is not responsible for any transactions made with third parties, or for their content, terms and conditions, or privacy policies.

Third-Party Partners and Third-Party Technology Partners

We work withthird-party partnersto offerMattel Services. We ask them to carefully handleinformationthat is entrusted to them.

We also work withthird-party technology partnersto provide content, understand our users, and deliver advertising on ourMattel Sitesand onthird-partysites. Read more atAbout Cookies and Technologies, and find out about tools are available to help you control some of these technologies at theThird-Party Technology Listand the Mobile Third-Party Technology List.

You may be required to register with and log onto athird partymobile app store before you can download or purchase a Mattel app or make in-app purchases using a Mattel app.

When downloading a Mattel app, or using a Mattel app with online features through your mobile platform, the app provider will typically also collect certain device and app-relatedinformation. Mattel does not control the requirements or policies of app stores; you should review the privacy policy and terms of use of the mobile app stores before downloading or using any app and check your device settings for control options.

We respect your choices about receiving promotional offers and updates from us. You can change what communications you get from us inMattel Communications Preferencesor inAmerican Girl Communications Preferences.

You can make choices about yourpersonal informationthat Mattel has in theMattel GDPR Choice Portal(except for American Girl) or theAmerican Girl GDPR Choice Portal(for American Girl only). Parents can access theirchildrenspersonal informationand make choices about it using theParental Access Form.

Your device may allow you to block or manage push notifications,location information, in-app purchases, or ability to access the web.

If you want to stop receiving promotional updates or product information at any time, you can change yourMattel Communications Preferencesor yourAmerican Girl Communications Preferences. Our mailings and email will also include information on how to opt out. Email opt-out requests will be processed in 10 business days. Postal mailing opt-out requests may take longer.

Your Choices and Control About Your Personal Information

If you want to access, update, or delete yourpersonal information; withdraw your consent to our collection or use of yourpersonal information; object to our processing of yourpersonal information; or request a portable copy of yourpersonal information, you can access theMattel GDPR Choice Portal(except for American Girl) or theAmerican Girl GDPR Choice Portal(for American Girl only). You can use these portals to make choices about information that Mattel has about you.

Parents can access their childrens data and make choices about how Mattel uses that data, including updating or deleting the data, using theParental Access Form.

Use your built-in mobile device settings and controls to:

Manage or restrict in-app purchases.

Manage camera, microphone, and photo reel, album, or gallery permissions.

Block navigation to the web by turning off network access on the device or turning off the browser.

Access to or availability of controls may vary depending on your device.

This section summarizes ourChildrens Privacy Statement, which you can review for complete details.

A special note for parents and legal guardians

We take special steps to protectchildrenas defined in this Privacy Statement. Please help us protect yourchildrens privacy by teaching them never to providepersonal informationwithout your permission.

We do not collectpersonal contact informationfromchildrenatMattel Servicesdirected tochildrenwithout the consent of a parent or legal guardian, except in limited circumstances authorized by law.

We collect someinformation(like IP address, mobile device UDID, operating system, etc.) automatically and use technology like cookies to provide functionality and support our operations. We obtain consent where required.

We do not ask for morepersonal informationthan is necessary for achildto participate in an activity.

We take steps to preventchildrenfrom posting or publicly disclosingpersonal information.

We use monitoring and filtering technology in an effort to preventchildrenfrom postingpersonal informationwithout parental consent atMattel Servicesdirected tochildren.

We may require visitors to provide birthdate or geographiclocation informationbefore accessing aMattel Serviceor providingpersonal information.

Parents can access and ask us to update or delete theirchildrensinformationby using theParental Access Form.

For moreinformationonchildrens privacy, please review our completeChildrens Privacy Statement.

You may be able to post or uploaduser-generated contentonMattel Services.

SomeMattel Servicesmay offer you the opportunity to uploaduser-generated content.

Not allMattel Servicesallow you to postuser-generated content.

Social sharing atMattel Servicesdirected tochildrenare structured so that nochildrenspersonal contact informationis shared between visitors unless parental consent is obtained.

We do not access your device, camera, microphone, contact list, photos, videos, or audio files unless you consent.

Some of our connected products will not be fully functional if you do not enable the camera or microphone.

Registration of the user, or of a parent on behalf of achildforchild-directedMattel Services, may be required to activate theMattel Serviceor access all features.

Special rules may apply to social networking activities. Be sure to carefully review any additional posted rules, as well as ourMattel Terms and Conditions.

We strive to maintain the security ofinformationbut cannot guarantee thatinformationsecurity measures are failure proof.

We strive to protect theinformationyou provide to us when you use ourMattel Servicesthrough commercially reasonable means.

We and our agents and affiliates use encryption or other security measures to protectpayment informationduring transmission and adopt internal procedures to safeguard thisinformationin our systems.

We require ourthird-party partnersto follow industry-accepted best practices to safeguardpersonal contact informationand otherinformationthey handle.

Please be aware that while we work hard to protect yourinformation, no method is 100% secure.

We cannot guarantee security procedures of third parties.

We recommend that you learn about and use tools, habits, and practices to protect the security of you and your family. For example, we recommend that you use unique passwords that are hard for others to copy or guess.

Mattel Servicesand servers are governed by U.S. law, which may have different privacy requirements for yourinformationfrom where you live.

Our servers are in the United States and the United Kingdom. We may also use cloud services.

We use Standard Contractual Clauses for transferringpersonal informationfrom the European Economic Area (EEA) or Switzerland to non EEA-countries.

Your use ofMattel Servicesis subject to the collection, transfer, processing, and use of data in accordance with this Privacy Statement.

Do not useMattel Servicesif you do not agree to this Privacy Statement.

Mattel Services, the servers that makeMattel Servicesavailable, and databases where we houseinformationmay be located in countries that may have privacy laws that differ from where you live.

Servers forMattel Servicesare located in the United States and the United Kingdom. We may use cloud services whose servers may be anywhere in the world.

For users whose use ofMattel Servicesresults in the transfer of personalinformationfrom the European Economic Area (EEA) or Switzerland to non-EEA countries, we rely on Standard Contractual Clauses.

By usingMattel Services, the transfer, collection, processing and use of data will occur as specified in this Privacy Statement, ourMattel Terms and Conditions, and any other terms provided at the time of collection.

If you do not consent to the transfer, collection, processing, or use of this data according to these terms, do not use the Services.

We will update this Privacy Statement from time to time by posting it here.

We will not change how we handle previously collectedinformationwithout providing notice. If appl