Summary

Pelorus Methods, Inc. ("Pelorus Methods") wants you to benefit from the information and services we make available when you visit one of our websites, interact with Pelorus Methods through an online community forum we make available, or use our browser-based software or mobile applications (collectively "Pelorus Vision") with the knowledge that we have implemented fair and transparent information policies and practices designed to protect your privacy.

This Privacy Statement describes our practices and policies regarding our collection and use of personal information about users of the Pelorus Vision and sets forth your privacy rights. This Privacy Statement also applies to information we collect through other means about you, including offline and from third parties. If you do not agree with our policies and practices, you have a choice to not use Pelorus Vision.

We will update this Privacy Statement from time to time as we adopt new privacy policies or change our personal information practices. Any updates will be reflected in the current version of the Privacy Statement available on Pelorus Vision.

Who We Are

Pelorus Methods is a national company comprised of a single legal entity. Our corporate headquarters are located in the state of Utah, in the United States. You can find information about our office locations on pelorusmethods.com, and we have also provided contact information at the end of this Privacy Statement.

We are a company dedicated to providing software solutions to our public sector clients to empower them to serve their own governmental and business functions. As such, most of the personal information Pelorus Methods collects and processes is in connection with the software and services we provide to our clients pursuant to our contractual arrangements with them. In these cases, Pelorus Methods is acting as a "data processor" only. Please see details under the heading "End User Personal Information".

In other interactions, such as when you visit the pelorusvision.com website or when you give us a physical card collected at a trade show, you provide us with your contact information. And, in some cases, Pelorus Methods is providing software and services directly to you based on an engagement you have asked us to undertake. In these types of scenarios, Pelorus Methods is the "data controller" because we are making the decisions about what personal information is collected during your visit to our website or trade booth, or your direct use of Pelorus Vision, and how we use that information to fulfill our business purpose(s).

The data privacy measures we undertake, and the rights you have with respect to your personal information, are dependent on whether Pelorus Methods is the data processor or the data controller of that information, as more fully explained below.

We have an in-house team of security and privacy professionals staffed across the United States. If you have questions or concerns regarding Pelorus Methods' data privacy policies or practices, you may contact our privacy team by emailing [email protected] or by calling 1-801-224-3318. Regular mail may be sent to the attention of the Legal Department/Privacy Team using the contact information at the end of this Privacy Statement.

End User Personal Information

When Pelorus Methods makes Pelorus Vision available for use by a client we do so under a contractual arrangement with our client pursuant to which the client, not Pelorus Methods, makes the decisions about what personal information is collected and how it is processed in Pelorus Vision. Personal information collected in this context could include, for example, information required to set up administrator rights for a client's employees in the context of their employment duties, or personal information collected from a client's constituents who are using Pelorus Vision to pay their utility bill. In these interactions, the client's employees or constituents are "End Users".

If you have questions or concerns about our client's decisions regarding the collection and processing of your personal information, you may contact us, or our client. If you contact us, we will coordinate the response with our client as appropriate.

Why We Collect Personal Data

Pelorus Methods collects personal information about users of Pelorus Vision for various reasons:

Online and Website Services: Pelorus Methods collects personal information when users interact with us online and through our websites in order to, for example:

• Provide you with information or services you request, including when you subscribe to our newsletters, blogs and online subscriptions;
• Comply with our legal and security obligations with respect to operating Pelorus Vision;
• Improve our products, services, and operations; and
• Personalize and continually improve user experience on Pelorus Vision.

Responding to Requests Related to Pelorus Vision Offerings: When you have requested access to or use of a Pelorus Software, Pelorus Methods collects and uses personal information to, for example:

• Provide our clients with the products and services which Pelorus Methods is contractually obligated to provide;
• Process your request and complete a transaction (including sending invoices and collecting payments);
• Assist you in implementing the Pelorus Vision you have requested, including setting up user account(s);
• Provide you with support and ongoing services for Pelorus Vision;
• Provide you access to Pelorus Methods’ online knowledge-base system, Pelorus Methods-sponsored online user community forums or other interactive tools designed for users of Pelorus Vision; and
• Register you for an in-person Pelorus Methods event or conference or virtual webinar, provide you with a class schedule and hotel accommodations, if applicable, track your attendance and request that you participate in surveys during and following the event.

Visitors to our Physical Office Location: If you visit our physical office location, we may collect personal information such as your name, employer and form of identification, in order to support our compliance with applicable security practices and procedures or applicable legal requirements.

For Pelorus Methods’ Marketing Purposes: We collect information from you, directly and indirectly (such as through analytics tools we use on pelorusvision.com) for our marketing purposes such as:

• Providing you with advertising and information about Pelorus Methods products or services that match your interests and other criteria you have identified, or that we otherwise believe may be of interest to you based on your activity on Pelorus Vision or activity on third-party sites and applications, such as social media platforms;
• Performing statistical, demographic, and marketing analyses of users of Pelorus Vision and their behavioral patterns.

For Pelorus Methods' Legitimate Business Purposes: Pelorus Methods uses personal information collected and processed by Pelorus Vision for Pelorus Methods’ other business purposes, such as:

• Gathering and analyzing data about client and end-user usage of the software and services offered by Pelorus Vision;
• Managing our security obligations with respect to Pelorus Vision;
• Complying with applicable laws and regulations;
• Conducting internal auditing, finance and insurance operations.

How We Collect Your Information

The information we collect about you comes to us in several different ways —

Information you provide to us:

• When you submit a contact form on Pelorus Vision, or post comments or questions on one of our online forums, you may choose to disclose information about yourself, including your name, physical address, email address, and phone number, along with information regarding your preferences and interests.
• When you make a support call via telephone, participate in a remote support assistance call, or other online support chat service, Pelorus Methods may make a record of such interaction and retain an audit log.
• When you attend a Pelorus Methods in-person event or conference or an online webinar, you will be required to provide personal information necessary to register you for the event or webinar.
• Pelorus Methods regularly records its events and webinars and may take photos at in-person events.
• When you visit us at a trade show booth and provide us with your business card, or when you chose to complete one of our information cards available at our trade show booths.
• When you are an End User of a Pelorus Methods client, you may be required to disclose information about yourself in order to avail yourself of the products and services provided by Pelorus Vision.

Information that is automatically collected: Like many websites and online platforms, we use web analytics tools that rely on cookies, web beacons, and other automated tracking technologies ("Tracking Tools"). Depending on your use of Pelorus Vision, we may use the Tracking Tools to help us analyze how users interact with and use Pelorus Vision, improve Pelorus Vision, personalize your Pelorus Vision experience, provide you with information we believe may be of interest to you, and identify others like you who may be interested in our products and services.

The information we collect automatically includes information about your computer and internet connection (including your IP address, operating system, and browser type) and details regarding your visits to Pelorus Vision (including your browsing actions and patterns and information about any referring website, search engine, social media platform, or link). When you use a Pelorus Methods mobile application, Pelorus Methods may collect and process unique device-specific identifiers which identify your mobile device.

We use Tracking Tools to collect the information described above. Please do note though, that in certain instances, for our legitimate business purposes we correlate the information collected through Tracking Tools to your personally identifiable information you have otherwise provided us.

Third Party Tracking Tools; Google Analytics

The Tracking Tools we use include analytics services we obtain from third parties. The information generated by these analytics services will be transmitted to and stored by the third parties and will be subject to their privacy policies. Please note that if you visit a third-party website, including one we may direct you to, we do not control these third parties' tracking technologies, how they may be used, or the information they may collect, and we are not responsible for these third parties' privacy policies.

The third-party Tracking Tool we use is Google Analytics. The information generated by Google Analytics will be transmitted to and stored by Google and will be subject to Google's privacy policies, which can be viewed here ("Welcome to the Google Privacy Statement"). To learn more about Google's partner services and to learn how to opt out of tracking of analytics by Google, visit ("How Google uses data when you use our partners' sites or apps").

We do not respond to a user's "Do Not Track" (DNT) browser request, given that we cannot control the DNT handling of third parties interacting with our site, such as Google Analytics.

Cookies and Web Beacons

The Tracking Tools we use rely on cookies and web beacons:

• Cookies. A cookie is a small data file that can be placed on your hard drive when you visit certain websites. Cookies are used to collect and store information, such as the type of computer you are using and how often you log on to a site. Pelorus Vision uses both "session cookies," to improve your navigation across Pelorus Vision and to remember you over the course of a single visit, and "persistent cookies," which are stored on your computer until they expire or are deleted and help us provide better service to you over multiple visits to Pelorus Vision. You can always delete or disable cookies through your browser. If you disable cookies, you may not be able to sign in or take advantage of certain features of Pelorus Vision that require cookies.
• Web Beacons. In addition to cookies, we deliver "web beacons" through Pelorus Vision and through emails we send you. Web beacons are small graphic images that may not be visible to Pelorus Vision visitors that collect information about Pelorus Vision usage on an anonymous basis. In some cases, anonymous data may be transmitted to third-party advertising networks. We use web beacons for our own internal analytics, to better understand the ways users interact with Pelorus Vision, and to determine whether an email was received and opened. We also use web beacons in connection with our marketing efforts. For example, web beacons allow third-party advertising networks to detect when a user has visited a Pelorus Methods website, and then serve them ads for Pelorus Methods products and services when they browse to another site.

Information from third parties and other sources: We supplement the information we collect through Pelorus Vision with information from third parties (including our advertising partners, trade show associations which Pelorus Methods sponsors, and other service providers and reputable vendors who contractually represent to us that they are authorized to obtain and share your information with us) and information we collect through other means, such as offline or through other websites. This information includes social media profile information, depending on the settings you have established for your social media accounts.

When and How We Share Personal Data With Others

Except as described in this Privacy Statement, Pelorus Methods will not share your personal information with third parties, rent or sell its mailing list, or share your personal information with third parties for their direct marketing purposes.

To the Pelorus Methods Client: If you are an End-User as described in this Privacy Statement, Pelorus Methods will share your personal information with the Pelorus Methods client who is providing your access to Pelorus Vision (e.g. your employer or our client).

Service Providers: We have service providers that perform functions on our behalf, such as hosting, content management, client relationship management, social media integration, marketing, analytics, billing, payment processing and customer service. These entities may have access to personal information if necessary or useful to perform their contractual functions. If obtaining such access, these third parties will be subject to confidentiality and security/privacy obligations with respect to such information.

Partners: Pelorus Methods may share information about you with our business partners and trade associations in order to provide you with information and services that you have requested or that we believe may be of interest to you.

Law Enforcement / Legal Obligations: Pelorus Methods reserves the right to share information about you where Pelorus Methods believes that such disclosure is necessary to comply with a legal requirement, such as a subpoena or court order, or to protect the rights or property of Pelorus Methods, you, or third parties.

Consent: Pelorus Methods may share your information in any other manner to which you consent. When you use Pelorus Vision to post or upload information that is shared publicly (i.e. via an online community forum or social media account), you are consenting to Pelorus Methods sharing that information.

Protection of Your Information

Pelorus Methods makes reasonable efforts to guard your personal information against accidental loss and from unauthorized access, use, alteration, and disclosure. We update and test our security technologies on an ongoing basis. We restrict access to your personal information to those employees who need to know that information to provide benefits or services to you. In addition, we train our employees about the importance of confidentiality and maintaining the privacy and security of your information. We commit to taking appropriate disciplinary measures to enforce our employees' privacy responsibilities.

Unfortunately, the transmission of information via the internet is not completely secure. Although we take measures to protect your personal information, we cannot guarantee its security. The safety and security of information also depends on your own security practices. If we have provided you with (or you have chosen) a username and password for access to certain parts of Pelorus Vision, you are responsible for keeping such information confidential. Please do not share your username and password with anyone.

Your Choices About Your Personal Data

Pelorus Vision allows you to submit information through Pelorus Vision, including personal information, such as your mailing or email address, or information needed to process a payment.

• If Pelorus Methods is acting as the data controller of your personal information and you have questions about your personal information, or, in accordance with applicable laws, you want to correct, update, or in certain cases, delete the information you can contact us at any time by emailing [email protected]. Additionally, Pelorus Methods provides you choices regarding the way we use the personal information you have provided us. For example, you may sign up to receive newsletters or email notifications regarding Pelorus Methods products or services. You may opt-out of receiving these communications at any time by contacting us at [email protected]. or by selecting the opt-out option provided in the body of the communication.
• If Pelorus Methods is acting as the data processor of your personal information for or on behalf of a Pelorus Methods client (as explained above under End User Personal Information), you may contact either Pelorus Methods or the Pelorus Methods client with your inquiries. If you contact us, we will contact the client and coordinate a response accordingly.

Transferring Personal Data to the United States

Pelorus Methods is headquartered in, and all of its corporate functions occur in, the United States. Please be aware that any information you provide to us may be transferred to and processed in the United States and may be subject to United States law. The privacy and data protection laws in the United States may not be equivalent to the laws in your country of residence.

The United States has not sought nor received a finding of "adequacy" from the European Union under Article 45 of the European Union's General Data Protection Regulation (GDPR). Pelorus Methods relies on derogations for specific situations as set forth in Article 49 of the GDPR. In particular, Pelorus Methods collects and transfers to the U.S. personal information only: with your consent; to perform a contract with you, or a contract with a Pelorus Methods client; or to fulfill a compelling legitimate interest of Pelorus Methods in a manner that does not outweigh your rights and freedoms. Pelorus Methods endeavors to apply suitable safeguards to protect the privacy and security of your personal information and to use it only consistent with your relationship with Pelorus Methods and the practices described in this Privacy Statement.

Children's Privacy

Except as described below, Pelorus Vision is not intended for use by minors. Pelorus Methods does not knowingly collect personal information from minors.

Pelorus Methods provides certain Pelorus Vision products and services to K-12 schools clients. When Pelorus Methods is under contract with its K-12 schools clients, Pelorus Methods:

• Complies with applicable state and federal laws, including but not limited to the Family Educational Rights and Privacy Act (FERPA);
• Does not collect or use student personal information in excess of what Pelorus Methods needs to perform its contractual obligations to the Pelorus Methods client;
• Does not sell student personal information to third parties; and
• Does not use or disclose student personal information for the purpose of targeted advertising to students.

Links

This Privacy Statement applies only to information collected by Pelorus Vision and not to other websites that you may link to from Pelorus Vision. Pelorus Methods is not responsible for the privacy practices of third-party websites. Please be aware that when you leave Pelorus Vision, you should review respective privacy policies for other entities or websites that ask you to provide personal information.

Notification of Changes

Any changes to this Privacy Statement will be reflected in an updated Privacy Statement made available on Pelorus Vision. Any information that we collect from you will be used in accordance with the version of this Privacy Statement in effect at the time the information was collected, unless we receive your consent to change our practices with respect to previously collected information.

For further information or comments on our Privacy Statement, please contact our privacy team at [email protected], or contact Pelorus Methods at the following address:

Pelorus Methods Inc.
195 S Orem Blvd Ste 3
Orem, UT 84058
Phone 1-801-224-3318

EFFECTIVE: January 1, 2020