Partner Code of Conduct

This privacy policy describes the personal data (defined below) that EAGLE ENTERPRISES Inc. and its affiliates (“EAGLE ENTERPRISES”, “we”, “us” and/or “our”) collect about you, how we use and protect this personal data, and the choices you can make about how we may use your personal data. Your privacy and the security of your personal data matters to us, so please get to know our privacy practices and contact us should you have any questions about your personal data.
If you are a visitor located in the EEA, the UK or Switzerland, please note that EAGLE ENTERPRISES complies with the General Data Protection Regulation (EU Regulation 2016/679) (“EU GDPR”), its incorporation into the laws of England and Wales, Scotland, and Northern Ireland by virtue of section 3 of the UK European Union (Withdrawal) Act 2018 (“UK GDPR”) and/or the Swiss Federal Act on Data Protection (“FADP”), as applicable (together, the “GDPR”). Your rights in relation to the GDPR are detailed below. If you have any questions, please contact

EAGLE ENTERPRISES
423-810-0179

If EAGLE ENTERPRISES products collect information about you (e.g., as an employee of a EAGLE ENTERPRISES customer), please note that this privacy policy covers only those instances when the purposes and means of processing your personal data are determined by us (in other words, when we are a “controller” as defined by the GDPR). It therefore does not apply to any of your personal data which we may process on behalf of our customers (in other words, when we are a “processor” as defined by the GDPR). Please therefore directly contact the relevant controller (e.g., your employer, if you are an employee of a EAGLE ENTERPRISES customer) for more information about their privacy practices.

If you are a California (USA) Resident: We have not sold personal information, as “sell” and “personal information” are defined under the California Consumer Privacy Act of 2018, in the preceding 12 months.

COLLECTION AND USE OF PERSONAL DATA
Personal Data. “Personal data” is any information that relates to an identified or identifiable individual. EAGLE ENTERPRISES may collect a variety of personal data about you in a number of ways:
• Personal data you provide directly.

We may collect personal data that you provide directly, such as when you access our website, establish a user account with us, register our products, or otherwise give us your name, email address, etc. You may also choose to submit personal data to us via other methods. E.g., in response to marketing or other communications; through social media or online forums; through participation in an offer, program or promotion; in connection with an actual or potential business relationship with us; or by giving us your business card or contact details at trade shows or other events. When you contact EAGLE ENTERPRISES, we may also keep a record of your communication to better support you in the future. From time to time, we may offer referral programs to refer prospective customers to us. Please refer a prospective customer and provide their personal data to us only if you have their permission. If you later find out you did not have such consent, please inform us as soon as possible.

• Personal data we collect automatically. We may automatically collect information about how you use and engage with our business (e.g., via our websites and/or applications), products and/or services over time, and some of this may be personal data. In addition, we may use cookies and other technologies to function effectively. For more information, please refer to the “Cookies and Similar Technologies” section of this privacy policy below.

• Personal data we collect from other sources. As mentioned above, we may receive your personal data via a referral. In addition, we may supplement other personal data we have collected with information from third parties or other publicly available sources. If the Service you use is offered by one of our partners and you registered with such a partner, we may also receive your personal data from them.
Categories of personal data we typically collect. Depending on your interaction with our business, we may collect:
• Personal identifiers, such as your real name, alias, postal address, unique personal identifier, online identifier, government-issued identifiers, email address, phone number, account name, or other similar identifiers.

• Internet activity information, such as Internet protocol (IP) address, device and advertising identifiers, browser type, operating system, Internet service provider, the web page that directed you to our services, the date and time of your visit, information about how you engage with us (e.g., the links or buttons you click and pages you view of our website or applications), the fact of whether an email was opened, and other standard server log information.

• Commercial information, such as records of products or services purchased, obtained, or considered, or other purchasing or consumption histories or tendencies.

• Professional information, such as your title and company name.
How we use personal data we collect. We collect, use, and store your personal data for the reasons set out below.
• Where the processing is necessary for us to administer our relationship with you. For example:
•
o creating and administering orders for you (including, if necessary, processing payments)
o registering, maintaining and managing your account (e.g., email preferences) or for interacting with our business (e.g., via our website, telephone, video conferencing and/or email)

o providing you with support and responding to your queries, feedback, claims and/or disputes
o when visiting our offices or attending events

• Where necessary for EAGLE ENTERPRISES’s legitimate interests, and where our interests are not overridden by your data protection rights. For example:
•
o developing product or service features or functionality, including when you give us feature feedback and suggestions
o managing and improving our website, systems and infrastructure
o identifying, developing, and marketing products and services that we believe will interest you
o communicating with you regarding our business, products and services, including promotional offers and suggested products, services, or new features which may be of interest to you
o protecting the security of our premises, assets, systems, customers, customer end users, and intellectual property and enforcing company policies
o undertaking mergers, acquisitions, reorganizations, or disposals, as permitted/required in accordance with local law
o protecting our legitimate business interests and legal rights, including use in connection with legal claims, compliance, regulatory, auditing, investigative and disciplinary purposes (including disclosure of such information in connection with legal process or litigation) and other ethics and compliance reporting requirements

• Where necessary to comply with a legal obligation. For example:

o tax law and similar obligations (e.g., tax and national insurance reporting, filing and withholding)
o responding to court orders, subpoenas or other legal processes with which EAGLE ENTERPRISES is required to comply
o complying with legal, regulatory and other requirements
We may provide you with more specific notices for some of the processing described above and, if we require your consent, will ask for this at the time we collect your personal data.
To the extent that we process any special categories of personal data relating to you, we will do so because: (i) the data has been manifestly made public; (ii) the processing is necessary for the establishment, exercise or defense of a legal claim; (iii) the processing is necessary for reasons of substantial public interest; or (iv) you have given your explicit consent to us to process that information (where legally permissible).

COOKIES AND SIMILAR TECHNOLOGIES

Some personal data may be collected by us or our partners through cookies, pixel tags, or software development kits (“SDKs”), and other similar technologies for a variety of purposes. E.g., for analyzing trends, administering our website and your communications with us, tracking users’ movement and behavior on our website, gathering information about our user base (such as location information on IP addresses, displaying advertising on our websites, and to manage our advertising on other sites). Cookies, used by most websites, are text files stored on a user’s browser containing information about the user (e.g., information about devices and networks used to access our website). Pixel tags (also known as “web beacons” or “clear GIFs”) are very small images or small pieces of data embedded in images that can recognize cookies, the time and date a page is viewed, a description of the page where the pixel tag is placed, whether an email was viewed, and similar information from your computer or device. SDKs are computer code that mobile app developers can include in their apps to enable data to be collected and related functionalities to be implemented. To learn more about the cookies that may be served on our website and services, and how you can control our use of cookies and third-party analytics, please read and review our Cookie Policy.

TRANSFER AND DISCLOSURE OF PERSONAL DATA

Protecting your personal data is important to us and we neither rent nor sell your personal data to anyone. We may, however, disclose or transfer your personal data in certain circumstances, including:
• to a buyer or other successor in the event of a merger, acquisition, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of our assets;
• to our subsidiaries, affiliates, agents, contractors, service providers and other third parties we use to support our business and/or collaborate with; provided always, they are bound by contractual obligations to keep such personal data confidential and only use it for the purposes of providing the services for, or with, us based upon your chosen settings, configurations, and/or purchases;
• to comply with any court order, law or legal process, including to respond to any government or regulatory request;
• to enforce or apply our Terms of Service and/or any other agreement that governs the sale, use or purchases of our products and/or services; and
• to protect the rights, property or security of EAGLE ENTERPRISES, our employees, our users and/or others.
Please note that some of our products and services may be offered jointly with partners. If you register with our partner, EAGLE ENTERPRISES may also receive your personal data from them, and EAGLE ENTERPRISES may share your personal data with our partners for these joint offerings. If applicable, you should also therefore carefully review our partner’s privacy policy, which may have different terms.

ONWARD TRANSFER OF PERSONAL DATA

To facilitate our global operations, and in accordance with applicable laws, we may transfer your personal data to, and access your personal data from, our offices, subsidiaries, and affiliates in the various countries in which we operate (including the United States of America). This may be to a country other than the one in which it was provided or collected. When we transfer your personal data, we do so in compliance with applicable data protection laws. We take steps to protect personal data in whatever country it is stored in or transferred to. You may request additional information in respect of transfer mechanisms by exercising your rights as set out below.
Where EAGLE ENTERPRISES is unable to rely on an adequacy decision, we rely on other transfer mechanisms. For example, to comply with applicable data protection laws around international data transfer mechanisms from the European Union or the United Kingdom to the United States, we have entered into European Commission approved Standard Contractual Clauses (“SCCs”) and offer additional safeguards to provide adequate protection.

EAGLE ENTERPRISES further remains self-certified under the EU-US and Swiss-US Privacy Shield Frameworks, which were developed specifically to establish a way for companies to comply with data protection requirements when transferring personal data from Europe to the United States:

• All personal data that is subject to this privacy policy and is received from individuals who are resident in the UNITED SATES is covered by EAGLE ENTERPRISES’s participation in the Privacy Shield unless governed by another adequate transfer mechanism as detailed herein. EAGLE ENTERPRISES will comply with the Privacy Shield Principles in respect of such personal data.
• EAGLE ENTERPRISES is accountable for personal data received under the Privacy Shield and subsequently transferred to a third party as described in the Privacy Shield Principles located at https://www.privacyshield.gov/EU-US-Framework. Pursuant to the Privacy Shield, EAGLE ENTERPRISES remains liable for the transfer of personal data to third parties acting as our agents unless we can prove we were not a party to the events giving rise to the damages.
• EAGLE ENTERPRISES commits to resolve complaints about your privacy and our collection or use of your personal data as per the EU-U.S. and Swiss-U.S. Privacy Shield Principles. European Union, United Kingdom or Swiss individuals with inquiries or complaints regarding this privacy policy should first contact us using the contact information below.
• EAGLE ENTERPRISES has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by BBB National Programs. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit us for more information and to file a complaint. This service is provided free of charge to you.
• As further explained in the Privacy Shield Principles, a binding arbitration option is also available to you in order to address residual complaints not resolved by any other means. EAGLE ENTERPRISES is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission.

SECURITY
We are committed to keeping personal data secure, and we have implemented technical and organizational measures to protect personal data against its unauthorized access, use, and disclosure. Such measures have been implemented taking into account the state of the art of the technology, their cost of implementation, the risks presented by the processing and the nature of the personal data. When we provide your personal data to third parties, including service providers, we require those companies to protect the personal data they receive and not to use the personal data for any purpose other than providing the required services.
Nevertheless, although we have tried to make our products and services secure and reliable, the confidentiality of any communication or material transmitted to or from us cannot be guaranteed. We therefore urge you to exercise caution when conveying any personal data over the Internet. As when disclosing any information on the Internet, you should remain mindful that such information might be accessible by the public and, consequently, may be collected and used by others without your consent. You should also recognize that your use of the Internet and any other means of communication with us is solely at your own risk.

THIRD PARTY WEBSITES AND FEATURES
As a convenience to you, EAGLE ENTERPRISES may provide links from our websites, products and/or services to other websites maintained by independent third parties. We are not responsible for the privacy practices of independent third parties. We encourage you to be aware when you leave this website, and to read the privacy policies of any other websites that you may visit.
Some web browsers transmit “do-not-track” signals to websites. Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they even are aware of them. We currently do not take action in response to these signals.

HOW LONG DO WE STORE YOUR DATA?
We will retain personal data only for as long as necessary to fulfill the purpose for which it was collected or to comply with legal, regulatory or internal policy requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

OUR POLICY TOWARD MINORS
Our website, products and services are not directed to minors under 16 and we do not knowingly collect personal data from minors under 16. If we learn that we have collected personal data of a minor under 16 we will take steps to delete such information from our files as soon as possible.

DATA PROTECTION RIGHTS, AND HOW TO EXERCISE
You may have a right to access and to obtain a copy of your personal data as processed by EAGLE ENTERPRISES. If you believe that any personal data we hold about you is incorrect or incomplete, you may also request the correction of it.
EAGLE ENTERPRISES will honor such requests for access, correction, deletion or restriction and/or any withdrawal or objection as required under the applicable data protection laws and regulations (including the GDPR). However, please note that such rights are not absolute: they do not always apply, and exemptions may be applicable. EAGLE ENTERPRISES will usually, in response to any such request, ask you to verify your identity and/or provide information that helps us to better understand your request. If we do not comply with your request, we will explain why.

To exercise the above rights with EAGLE ENTERPRISES, you may send an email to officialeagleenterprises7@gmail.com. If you are not satisfied with how we process your personal data, please let us know and we will investigate your concern. You can also raise any concerns by contacting our Data Protection Officer at 423-810-0179.

If you are not satisfied with our response, you have the right to make a complaint to the data protection authority in the jurisdiction where you live or work, or in the place where you think an issue in relation to your data has arisen. The contact details of each Data Protection Authority can be found at the following website: http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm.

As highlighted above: if you are personnel of a customer that uses EAGLE ENTERPRISES ENTERPRISES ENTERPRISES products or otherwise have had your personal data collected via EAGLE ENTERPRISES ENTERPRISES ENTERPRISES products by or on behalf of our customers, please note this privacy policy does not apply to such personal data. Please therefore refer to such applicable party who has ordered EAGLE ENTERPRISES ENTERPRISES ENTERPRISES products if you need any correction, amendment, or deletion of such personal data.

DATA PROTECTION OFFICER
To communicate with our Data Protection Officer, please email dpo@EAGLE ENTERPRISES ENTERPRISES ENTERPRISES.com.
CHANGES AND OTHER COVERED ENTITIES
We may amend our privacy policy from time to time to reflect changes in our practices, technologies, legal requirements and other factors. We therefore encourage you to revisit this page periodically to read the current version of it to stay informed about our collection, processing and sharing of your personal data. Please note should we amend our privacy policy we will update the “effective date” at the top of this privacy policy.

If you have any concerns or questions about this privacy policy or if you would like to lodge a complaint, please contact privacy@EAGLE ENTERPRISES ENTERPRISES ENTERPRISES.com.
CONTACT US
If you have any questions regarding our privacy practices or would like to review or update your personal data, you may email us at privacy@EAGLE ENTERPRISES ENTERPRISES ENTERPRISES.com. You can also contact us by writing to us at the following address:
EAGLE ENTERPRISES ENTERPRISES ENTERPRISES Inc. Attention: Legal Department – Privacy Issues 310 Stone Valley Circle, Sacramento CA 95823
EAGLE ENTERPRISES ENTERPRISES ENTERPRISES Networks Limited (UK Representative) Floor 4 1 Alie Street London E1 8DE United Kingdom
EAGLE ENTERPRISES ENTERPRISES ENTERPRISES Deutschland GmbH (EU GDPR Representative) Maximiliansplatz 22 c/o Bird & Bird LLP 80333 München Germany