Privacy and GDPR

1. What's changing with Primalogik's Privacy Policy?

We have released an update to our Privacy Policy which comes into effect on May 25th, 2018. Our new policy is easier to read and understand and addresses new data privacy regulations (including GDPR). These are the most significant changes in the new policy:

• Increased transparency regarding what personal data is collected, why we collect it, and how long it is stored
• Clearer, more straightforward language
• Information on how to remove or correct your personal data.
• Using our products for work. Many users have access to our services through their organizations (e.g., their employers), who control their accounts or use of our services. The updated policy clarifies our relationship with these users and explains the tools available to administrators of these users.
• We updated the Privacy Policy to comply with the new requirements under the EU General Data Protection Regulation (GDPR) coming into effect on May 25, 2018.

2. What is GDPR, and what is Primalogik doing to comply?

GDPR stands for the General Data Protection Regulation and is effective as of May 25th, 2018. GDPR replaces national privacy and security laws that previously existed within the EU with a single, comprehensive EU-wide law that governs the use, sharing, transfer, and processing of personal data that originates from the EU.

Our policy is to respect all laws that apply to our business and this includes GDPR. We also appreciate that our customers have requirements under GDPR that are directly impacted by their use of our services. For those reasons, we are committed to helping our customers comply with GDPR and their local requirements.

As part of our commitment to GDPR compliance, we have updated our Privacy Policy. In addition, here are a few things that Primalogik is committed to doing to ensure our compliance with GDPR and that of our customers:

• Where we are transferring data outside of the EU, Primalogik commits to having the appropriate data transfer mechanisms in place as required by GDPR.
• Primalogik commits to following appropriate security measures and precautions in accordance with GDPR.
• Primalogik will assist with promptly communicating any data breaches to customers and users.
• We will ensure that employees authorized to process personal data have committed to confidentiality and are aware of data regulations such as GDPR.
• We will hold any sub-processors that handle personal data, including our data center partners, to the same data management, security, and privacy practices and standards to which we hold ourselves.
• Where appropriate, we will offer contractual language documenting our commitments to our customers to support their GDPR obligations.
• Primalogik will assist our customers, insofar as possible, to respond to data subject requests our customers may receive under the GDPR.

3. Does Primalogik process personal data?

Yes. We process personal data to provide our services and for other purposes as outlined in our Privacy Policy.

4. Can Primalogik assist my company with responding to an Individual Rights Request (Subject Access Request)?

As a processor of personal data for our customers, we will assist our customers with responding to individual rights requests that they receive under the GDPR. In many cases, customers may be able to address these types of requests by logging into the Primalogik application and using the options available in their accounts. Where this is not possible, please contact us to request assistance with any such individual rights requests.

5. Where does Primalogik store and send my data?

Today, we store data in data centers located in Canada. We may also allow employees and contractors located around the world to access certain data for product promotion and development, and customer and technical support purposes. For more information, please see the "How we transfer information we collect" section of our Privacy Policy.

6. How does Primalogik handle onward transfers of data outside of the EU?

When you use the Primalogik services, Primalogik Software Solutions, Inc. ("we" or "us") is responsible for your personal data. If you use our services from Europe, we store your data in servers located in Canada. To safeguard your data when it leaves the European Economic Area we commit to only access, use, store, or share your personal data in accordance with the principles described in our Privacy Policy.

We need to transfer your personal data to other organizations to help us provide you the service. For example, we use Amazon Web Services data centers to assist us in storing your data. In some instances. Whenever we share your data, we remain accountable to you for how it is used by any of these organizations. We require all service providers to enter into contracts with us that guarantee that your personal data will only be used in accordance with our Privacy Policy.

7. Do you offer your customers a Data Processing Addendum?

Yes. We've included specific GDPR obligations in a Data Processing Addendum (DPA) that's included in our regular terms of service and apply that our customers in the EU, and customers based elsewhere that process data of subjects in the EU. The Primalogik DPA is linked from our Terms of Services and can also be accessed directly here: Data Processing Addendum.

8. Can I opt-out of having my data collected or shared?

You have certain choices available to you when it comes to your information. You can exercise some of the choices by logging into the applicable product and using settings available within the applicable product or your account. Where our products are administered for you by an administrator, you may need to contact your administrator to assist with your requests first. Primalogik's Privacy Policy summarizes those choices, how to exercise them, and any relevant limitations. Please see the section "How to access and control your information" in Primalogik's Privacy Policy for more information.

9. Does Primalogik use sub-processors to further process customer data?

A list of our sub-processors can be found in our Data Processing Addendum.

10. Who can I contact with questions regarding GDPR?

For more information, please see the "Contact Us" section of our Privacy Policy.