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INTRODUCTION

Tagetik Software S.r.l. ("we" or "us") wants to inform you about the ways we process your personal information. In this Privacy & Cookie Notice we explain what personal information we collect, use and disclose. Personal information means any data relating to an individual who can be identified, directly or indirectly, based on that information. This may include information such as names, contact details, (online) identification data, online identifiers, or other characteristics specific to that individual. This Privacy Notice applies when you visit our websites, solutions and other services, including events, that refer or display a link to this notice (“Services”). This Privacy Notice may be supplemented or replaced by additional privacy statements or terms provided to you.




WHO WE ARE

Tagetik Software S.r.l. is the parent company of the Tagetik group, which is, in turn, part of the Wolters Kluwer group. Wolters Kluwer is a global organization consisting of many companies worldwide. Any personal information provided to or collected by us or other Wolters Kluwer affiliates or subsidiaries is controlled by Wolters Kluwer N.V., P.O. Box 1030, 2400 BA, Alphen aan den Rijn, The Netherlands or one of its affiliates or subsidiaries.

We are committed to safeguarding the personal information of our customers, users, employees and other stakeholders, while helping our customers, employees, investors, and society create a deeper impact and make the right decisions.

If you wish to contact us in relation to questions to your personal information we refer you to the ‘HOW YOU CAN CONTACT US’ section below.


WHAT PERSONAL INFORMATION DO WE COLLECT?

The type of personal information we collect depends on your relationship with us and the Services we deliver to you. To that end, we may collect the following personal information about you:

• Name and contact details, such as, first and last name, email address, postal address, telephone number
• Work-related information, such as, job title and other employment or education information
• Account Credentials, such as, passwords and other security information for authentication and access
• Financial Information, such as, bank account, credit and debit card numbers for processing of payments
• Usage information, such as, behavioral information about how you navigate within our Services and which elements of our Services you use the most and information regarding the goods and/or services you wish to order, wish list, preferences, interest, etc. Other information shared by you through our websites, apps, web shops and other products.
• Computer, device and connection information, such as, IP address or domain names of computers used in connecting with this website, the URI (Uniform Resource Identifier) addresses, the time of the request, the method used to forward the request to the server, the size of the file obtained in response, the numeric code indicating the status of the response from the server (success, error, etc.), browser type and version and location, the various temporal connotations of the visit (for example the time spent on each page) and the details relating to the itinerary followed within theServices , with particular reference to the sequence of the pages consulted, to the parameters relating to the operating system and the IT environment.

If you are under 13 years of age, please do not use or access the Services. We do not knowingly collect or maintain personal information (as defined by the United States Children’s Online Privacy Protection Act) from persons under 13 years of age. If we learn that personal information of persons under 13 has been collected on or through the Services, we will take appropriate steps to delete this information.


HOW WE COLLECT PERSONAL INFORMATION

We and our third-party service providers may collect personal information from the following sources:

• Direct Interactions, such as, when you register for our Services or make a purchase
• Data from Third Parties, such as, information on third-party websites or other information you may have made publicly available or information provided by third party sources, including but not limited to government entities and data resellers
• Automated Tracking Technologies, such as, information automatically collected about your interaction with our Services and websites using various technologies such as cookies, web logs and beacons and internet tags


HOW WE USE YOUR PERSONAL INFORMATION

Personal information collected is used for the purposes for which you have provided it and might be further used for statutory or other legitimate purposes only. As an example, if you make use of our service contact form on our website, we will use the information you provided in the first place to respond to your service request. We might further use that information to improve the quality of our customer service process.

Lawfulness of the processing is one of the main principles relating to processing of your personal information - we apply the following legal processing grounds:

• processing is necessary for the performance of a contract or in order to take steps prior to entering into a contract;
• processing is necessary for the purposes of our legitimate interests - for example, to improve the quality of our products and services;
• processing is necessary for compliance with a legal obligation to which we are subject or that is otherwise lawful under applicable data protection laws;
with your given consent.

Unless otherwise specified, all Data required for browsing the website is mandatory. If you refuse to communicate them, it may be impossible for the Services to work. In cases where the Services indicate certain data as optional, you are free to refrain from communicating such data, without this having any consequence on the availability of the Services or on its operation.
If you have doubts about which data is mandatory, are encouraged to contact us.

Depending on how you interact with us and the Service, we may use your personal information for the following purposes:

• Administering our relationship with you and our business, such as providing and managing your access to and use of our Services. This processing is necessary for the performance of a contract;
• Improving our Services and developing new products, such as inviting you to participate in surveys or to personalize your experience with our Services. This processing is necessary for the purposes of our legitimate interests;
• Marketing, such as providing you with marketing or advertising communications that we think you may be interested in. This processing is with your given consent or for our legitimate interests;
• Recruiting, such as assessing job applicants. This processing is in order to take steps prior to entering into a contract or with your given consent;
• Providing online communities, such as making chat rooms, forums, message boards, or news groups available to you. This processing is necessary for the performance of a contract or our legitimate interests. Please remember that any information disclosed in these forums is public. We encourage you to exercise caution when disclosing personal information in these forums, as this information is made available to other users. Do not disclose information in these public forums that might be considered confidential or proprietary or that you do not wish to be publicly available or that you are prohibited from disclosing.
• Other general business support purposes, including but not limited to, procurement, financial and fiscal management, risk and compliance management, and external reporting. This processing is necessary for compliance with a legal obligation to which we are subject or that is otherwise lawful under applicable data protection laws or for our legitimate interests.


SHARING YOUR PERSONAL INFORMATION

To be able to provide you the best possible Services and further our business operations, we may share certain information internally or with selected third parties. There might also be a certain statutory or legal obligation that we believe in good faith requires us to disclose your personal information externally. Parties we might share data with include:

• other Wolters Kluwer affiliates or subsidiaries, e.g. for providing underpinning technology to support the Services we are delivering;
• our service providers, e.g. for managing or hosting services and/or underpinning technology for the Services we are providing;
• our business partners, to the extent you have purchased or expressed interest in, a product or service of such business partner, interacted with them or otherwise authorized the sharing of your personal information with such business partner;
• subscribing, accrediting or professional organizations, e.g. for providing utilization information to organizations that provide you with access to our Services and/or sharing tracking and redeeming credits for professional accreditation;
• organizations involved in business transfers, e.g. to a purchaser or successor entity in the event of a sale or any other corporate transaction involving some or all of our business;
• other parties, e.g. as needed for external audit, compliance, risk management, corporate development and/or corporate governance related matters; or
• governmental authorities and regulators, as required under applicable law.

Whenever we share personal information internally or with third parties in other countries, we have appropriate safeguards in place in accordance with applicable data protection laws including as applicable the EU Model clauses. As required under applicable law, third parties are required to use appropriate safeguards to protect personal information and they can only access personal information that is necessary for performing their specific tasks.


FOR HOW LONG WE KEEP YOUR PERSONAL INFORMATION

Your personal information will be processed in accordance with our data retention policies and applicable data protection laws, therefore it is processed to the extent necessary for the performance of our obligations, and for the time necessary to achieve the purposes for which the information is collected and in any case:

• no more than 2 years from their collection for the purposes of direct and indirect marketing and market research, aimed at the dispatch of informative and advertising material
• no more than 10 years from their collection for the purpose of responding to specific requests and/or for the performance of pre-contractual/contractual negotiations.

In the event of a pending trial, the data will be processed further until its resolution. Furthermore, the Data Controller may be obliged to keep Personal Data for a longer period in compliance with a legal obligation or by order of a supervisory authority.

When we no longer need your personal information, we will take all reasonable steps to remove it from our systems and records or take steps to properly anonymize it so that you can no longer be identified from it.


HOW WE PROTECT YOUR PERSONAL INFORMATION

We have put in place an internal framework of policies and minimum standards across all our businesses to keep your data safe. In addition, we limit access to personal information by our employees, business partners, service providers and third-party service providers to a ‘need-to-know’ basis. More specifically and in accordance with the law, we take appropriate technical and organizational measures (policies and procedures, IT security, and others) to ensure the confidentiality and integrity of your personal information and the way it is processed.


WHAT ARE YOUR RIGHTS

We will honor your rights under applicable laws. To the extent provided under your local data protection laws, including European data protection laws, your rights include the following:

• Right of access (‘an overview of your personal information’): the right to get an overview of your personal information that we process.
• Right to rectification (‘correct your personal information’): if your personal information is inaccurate or incomplete, the right to ask us to rectify or complete your personal information.
• Right to erasure (‘right to be forgotten’): the right to request that we delete your personal information to the extent permitted by applicable law. In certain circumstances, it may not be possible for us to accept your request, for example, when the processing is necessary to comply with a legal obligation, or if processing is necessary for the performance of a contract. In some cases, your personal information is necessary in order to provide the Services and if you do not provide such information to us then you may be precluded from accessing and using the Services or using certain Services features.
• Right to data portability (‘transfer your personal information’): the right to ask us to transfer your personal information directly to you. This applies to certain personal information if processed by automated means and with your consent or based on a contract you have with us. On your request, and where technically feasible, we will transfer your personal information to another party of your choice.
• Right to restrict processing: the right to request that we restrict or stop the processing of your personal information held by us for a certain period of time, or for an indefinite period. In certain circumstances, it may not be possible for us to accept your request, for example, when the processing is necessary to comply with a legal obligation, or if we can demonstrate compelling legitimate grounds otherwise.
• Right to object: the right to object to the processing of your personal information. The reasons for objection should relate to your particular situation, and be related to a processing based on the legitimate interest condition. We will then no longer process the personal information, unless we can demonstrate compelling reasons otherwise. In certain circumstances you have the unconditional right to object; for instance, in the context of direct marketing activities.
• Withdrawal of Consent: the right to withdraw your consent to the processing of your personal information at any time; for instance, after you consented to keeping you informed about our Services, you have the right to withdraw this consent at any time.

To exercise your rights and/or for any other questions about the handling of your personal information, we refer you to the 'HOW YOU CAN CONTACT US' section below.

If you feel we are unresponsive or disagree with our data privacy practices, you can also file a complaint with your national Data Protection Authority.


THE USE OF COOKIES

Information about how cookies are used, how to disable them, and which are our third parties can be found by consulting our cookie policy.


LINKS TO OTHER WEBSITES

Our websites may contain links to other Wolters Kluwer or third-party websites, which may have privacy notices that differ from ours. We are not responsible for the collection, processing or disclosure of personal information collected through other websites.

We are also not responsible for any information or content contained on such websites. Links to other websites are provided solely for convenience. Your usage and browsing on any such website is subject to that website’s own policies. Please review the privacy notices posted on other websites that you may access through our website.

Wolters Kluwer may provide you with additional or different privacy notices in specific instances on how your personal information is collected and used for a specific Service.


HOW YOU CAN CONTACT US

If you have any questions about how we process your personal information or if you want to exercise one of your rights, you can contact us by sending:

• A registered, return receipt letter to Tagetik Software S.r.l. – Registered Offices on Via Roosevelt, No. 103 – 55100 Lucca, Italy;
• An email to the following address: tgk-info@wolterskluwer.com
• A certified email to the following address: grupposerviziholding@pec.tagetik.com using the following form. Download the form.

By clicking here, you can request removal from our mailing lists, and by doing so you will no longer receive commercial information. By clicking here you can request the erasure of all your personal data.

You may also address the Data Protection Officer to have more information and request information regarding your data or report disservices or any problem you may have encountered.
Tagetik Software S.r.l. has appointed AKSILIA S.R.L. as the Data Protection Officer with registered office in Via Fontana 22, Milan, VAT number and C.F. 02249540465 that you may contact at the following addresses:

Telephone: 0583 578787
Email: dpo@consilia.srl
Certified Email: dpo.consilia.srl@pec.it

The reference person to be addressed is Turri Michela, Fiscal Code TRRMHL73A51E715K that can be reached at the contact addresses above and at the following cell phone no.: +39 347 3674033.

If you feel we are unresponsive or disagree with our data privacy practices, you can also file a complaint with your national Data Protection Authority. In response to a request, we might ask you to verify your identity if needed, and to provide information that helps us to understand your request better. If we do not grant your request, whether in whole or in part, we will explain why.


ADDITIONAL INFORMATION FOR CALIFORNIA RESIDENTS

Pursuant to California law, we are providing additional information to California residents.

Under California law, certain organizations need to disclose whether the following categories of “personal information” are collected or disclosed for an organization’s “business purpose” as those terms are defined under California law. Below please find the categories of personal information about California residents that we collect or disclose to third parties or service providers. Note that while a category may be included below that does not necessarily mean that we have or collect information in that category about you. The personal information we collect depends on the nature of our interaction with you and the Services you may use. For example, while we collect credit card numbers for customers who purchase certain solutions, we do not collect or transfer credit card numbers of individuals that submit questions on our website’s “contact us” page. We do not sell personal information.


 

Category of personal information collected

Categories of third parties to whom we disclose personal information for a business purpose

 

 

Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.

• Our affiliates or subsidiaries
• Our service providers
• Product and service fulfillment companies
• Subscribing, accrediting or professional organizations
• Government authorities and regulators

 

 

Financial information such as credit card number, debit card number or bank account number 

• Our affiliates or subsidiaries
• Our service providers
• Payment processors and banks

 

 

Characteristics of protected classifications under California or federal law

• Our affiliates or subsidiaries
• Our service providers
• Government authorities and regulators

 

 

Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

• Our affiliates or subsidiaries
• Our service providers
• Product and service fulfillment companies
• Subscribing, accrediting or professional organizations

 

 

Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an Internet website, application, or advertisement.

• Our affiliates or subsidiaries
• Our service providers
• Product and service fulfillment companies
• Subscribing, accrediting or professional organizations

 

 

Geolocation data

• Our affiliates or subsidiaries
• Our service providers
• Product and service fulfillment companies

 

 

Audio, electronic, visual, thermal, olfactory, or similar information.

• Our affiliates or subsidiaries
• Our service providers
• Product and service fulfillment companies
• Subscribing, accrediting or professional organizations
• Government authorities and regulators

 

 

Professional or employment-related information

• Our affiliates or subsidiaries
• Our service providers
• Product and service fulfillment companies
• Subscribing, accrediting or professional organizations

 

 

Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. section 1232g, 34 C.F.R. Part 99).

• Our affiliates or subsidiaries
• Our service providers
• Product and service fulfillment companies
• Subscribing, accrediting or professional organizations

 

We and our third-party service providers collect personal information from the following sources:

Direct interactions, such as, when you register for our Services or make a purchase
Data from third parties, such as, information on third-party websites or other information you may have made publicly available or information provided by third party sources, including but not limited to government entities and data resellers
Automated tracking technologies, such as, information automatically collected about your interaction with our Services and websites using various technologies such as cookies, web logs and beacons and internet tags

Depending on how you interact with us and our Services, we may use and disclose personal information for the following business purposes:

• Auditing
• Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity,
• Detecting and repairing errors,
• Performing services on behalf of other businesses,
• Processing or fulfilling orders and transactions,
• Processing payments,
• Providing advertising or marketing,
• Conducting internal research for product and service development, and
• Improving, upgrading, and enhancing our services

In addition to sharing personal information for the business purposes identified within the California Consumer Privacy Act, we also share personal information as needed, or required, with the following additional third parties:

organizations involved in business transfers, e.g. to a purchaser or successor entity in the event of a sale or any other corporate transaction involving some or all of our business;
other parties, e.g. as needed for external audit, compliance, risk management, corporate development and/or corporate governance related matters,
business partners as directed by an individual, or as needed to process an individual’s request; and
governmental authorities and regulators, as required under applicable law.




Exercising Rights to Request Access and Request Deletion
Subject to certain exceptions, California residents have the right to request access, deletion and portability of their personal information as further described in the Privacy Notice. If you would like to submit a request or have additional questions about the personal information that we have about you, please contact us at: tgk-info@wolterskluwer.com or 1-877-755-1133.
When you submit your request, we will take steps to attempt to verify your identity. We will seek to match the information in your request to the personal information we maintain about you. As part of our verification process, we may ask you to submit additional information, use identity verification services to assist us, or if you have set up an account on our website, we may ask you to sign in to your account as part of our identity verification process. Please understand that, depending on the type of request you submit, to protect the privacy and security of your personal information, we will only complete your request when we are satisfied that we have verified your identity to a reasonable degree of certainty. We do not discriminate against individuals who exercise their rights under applicable law. If we receive a request from an authorized agent, we have the right to verify with the data subject that the data subject indeed wants to take the action requested by the agent and will do so by contacting the data subject directly.


UPDATES TO THIS NOTICE
From time to time we may update this Privacy Notice or any other specific privacy statement. When making changes to this Privacy Notice, we will add a new date to this Privacy Statement. This version is effective per September 24, 2020.