Overview

SpringCM is serious about protecting your privacy and recognizes that you care how information about you is used and shared. We appreciate that you expect SpringCM to protect your personal information carefully and sensibly. This Data Protection and Privacy Policy notice ("Privacy Policy") describes how we may collect personal information about you whether you are one of our registered users ("Registered User") or as a visitor to the Site. You care what personal information we collect, how we may use it, with whom we may share it, what choices you have regarding it, and how we protect it. This Privacy Policy is incorporated into and is a part of the Terms of Use of this SpringCM web site (www.SpringCM.com, this "Site") and we encourage you to become familiar with the terms and conditions contained herein. SpringCM enters into service agreements with its clients in the European Union which may include the processing of information relating to our clients' customers and employees. In these agreements, the European Union based client agrees and recognizes that it is the "data controller" for the purposes of the European Union data protection legislation. This means that our European Union based clients are responsible for complying with the data protection legislation and policies of the European Union and their individual countries before it sends its customer or employee data to SpringCM for processing. Any data processed by SpringCM is only disclosed to third parties at the request of our client, as required by law or as provided below. By registering with SpringCM and accessing and using this Site, you agree that you have read and understand this Privacy Policy, and that you accept and consent to the privacy practices described in this Privacy Policy.

Changes to Privacy Policy

From time to time, SpringCM may change its privacy practices because of changes in relevant and applicable legal or regulatory requirements, the business or business practices of SpringCM, or in its attempts to better serve your needs. Notice of such changes to our privacy practices will be given and a revised Privacy Policy will be posted at this location.

What Information Do We Collect?

The information collected by SpringCM is not ordinarily acquired in a form or manner that permits the identification of an individual's Personal Information by SpringCM. Notwithstanding the above, Personal Information may be supplied to SpringCM by our clients' employees or representatives and Registered Users. SpringCM collects various types of information from our Registered Users. During the registration process, Registered Users supply us with basic contact information (such as name, address, telephone number, e-mail address and company name), as well as billing information. This information is generally entered into fields in the registration and subscription forms and enables the Registered User to take full advantage of the products and services that we offer. Should you purchase any SpringCM products or services on or through the Site, the information that you supplied during the registration process may be used to track details about those purchases. "Personal Information" means any information or set of information that identifies or could be used by SpringCM, its customers or agents of its customers, to identify an individual. Personal Information does not include information that is encoded or anonymized, or publicly available information that has not been combined with non-public personal information. "Sensitive Personal Information" means personal information that reveals race, ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, or that concerns health or sex life. SpringCM does not require that Registered Users supply Sensitive Personal Information as part of the registration process or in any registration or subscription form. SpringCM will treat as Sensitive Personal Information any information received from a third party where that third party treats and identifies the information as sensitive.

As with many other Web sites, the Web servers used to operate the SpringCM Site collect certain data pertaining to those that access the Site and the equipment and communications method that are used to access the Internet and the Site. Without combining these data with other sources of information, they do not readily identify the individual user. They do reveal such things as the Internet protocol ("IP") address assigned to your computer, pages you accessed on the Site, or immediately prior to visiting the Site, and the length of time you spent at the Site. This information is collected to, among other things; facilitate Site operation and system administration, to generate aggregate, non-identifiable statistical information, and to improve performance of the services made available on the Site.

SpringCM may also retain the content of and metadata regarding any correspondence you may have with SpringCM or its customer service representatives, regardless of the mode of communication by which such correspondence was made. This information helps SpringCM to improve the Site and the materials, products and services offered on the Site, and to more effectively and efficiently respond to both current and future inquiries.

SpringCM uses "cookies" (small text files stored on your computer) to help track and customize your access and use of the Site. Cookies store and retain information that helps us recognize you on subsequent visits to the Site. Cookies may also store any login or ID assigned to you by SpringCM and the associated password, this information is stored in encrypted form. Most popular Internet browser packages allow you to configure the browser so as not to accept cookies. However, setting the browser to reject cookies may prevent you from taking full advantage of the Site and the materials, products and services that SpringCM makes available on the Site.

How Do We Use The Information That We Collect?

In addition to the uses mentioned or described above, SpringCM uses the information that it collects to improve the materials, products and services that SpringCM makes available on the Site, to notify Registered Users of changes made to the Site or new products made available on or through the Site, to evaluate customer needs and customize Site content delivered according to those needs, to facilitate the processing of any purchases made through the Site, to send promotional material from SpringCM, and for other legitimate and lawful business purposes of SpringCM. SpringCM does not share Personal Information collected about its Registered Users with third parties. It is our policy not to sell lists containing Personal Information about Site users, registrants or subscribers.

In the event SpringCM collects Personal Information regarding individuals in the European Union, it will be used solely for the purposes enumerated in this Privacy Policy, the types of non-agent third parties to which SpringCM discloses that information, and the choices and means, if any, SpringCM offers individuals for limiting the use and disclosure of their Personal Information. Notice will be provided in clear and conspicuous language when individuals are first asked to provide Personal Information to SpringCM, or as soon as practicable thereafter, and in any event before SpringCM uses the information for a purpose other than that for which it was originally collected.

EU Safe Harbor Privacy Statement and Commitment

SpringCM is committed to handling Personal Information received from European Union clients in accordance with the Safe Harbor Principles as described on the U.S Department of Commerce's web site at http://www.export.gov/safeharbor/SH_Overview.asp. SpringCM's Safe Harbor Certification can be found at http://web.ita.doc.gov/safeharbor/shlist.nsf/webPages/safe+harbor+list.

What Choices Do You Have?

Where SpringCM collects Personal Information directly from individuals in the European Union, SpringCM will offer individuals the opportunity to choose (opt-out) whether their Personal Information is (a) to be disclosed to a non-agent third party, or (b) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual. For Sensitive Personal Information, SpringCM will give individuals the opportunity to affirmatively and explicitly (opt-in) consent to the disclosure of the information to a non-agent third party or the use of the information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual. SpringCM will provide individuals with reasonable mechanisms to exercise their choices. Registered Users may update at any time the information about the user and user preferences that are stored on the Site or during registration. Registered Users may also ask us at any time to remove the user's name from our list of Site users who wish to receive electronic communications and e-mail advertisements from SpringCM by simply sending such a request to us at the numbers or addresses given below. Once you opt-out, we will honor your choice until you inform us otherwise.

E-mail: support@springcm.com

SpringCM
Attn: Customer Support
350 N. Orleans Street, Suite 900
Chicago, IL 60654
Telephone: (877) 362-7273 or 312-881-3200
Facsimile: (312) 881-2201

How Do We Protect Your Information?

SpringCM places a high value on the corporate data and document data you entrust with us. For this reason, we secure your information at three levels: physical, application, and network layers. The physical layer is protected by need-to-know authorization by only the appropriate operations individuals. Additionally, the servers are caged within a room only accessible through biometric scanning. The application layer is entirely secured with VeriSign's Site Trust 128 bit SSL encryption technology so all communication with the web site is locked. The network layer is protected by industry-leading firewall technology and administered real-time to ensure timely security patching. This layer is also watched by intrusion-detection systems to ward off unauthorized access. These safeguards all are put in place to protect our users' information, prevent unauthorized access, safeguard user data, and ensure the proper and legal use of the Site. SpringCM akes commercially reasonable measures to secure and protect customer-specific information transmitted via or stored on our Site. However, no security system is impenetrable. We cannot guarantee that information user's supply will be totally secure.

Enforcement

SpringCM will conduct compliance audits of its relevant privacy practices to verify adherence to our policies. Any employee that SpringCM determines is in violation of its policies will be subject to disciplinary action up to and including termination of employment.

Dispute Resolution

Any dispute involving the use or retention of Personal Information by SpringCM shall be resolved by appeal to the American Arbitration Association.

Linked Sites

For your convenience, some hyperlinks may be posted on the Site that link to other Web sites not under the control of SpringCM. We are not responsible for and this Privacy Policy does not apply to the privacy practices of those sites. We encourage you to seek out and read the privacy policy of any Web site that you visit. In addition, when you initiate a transaction on a web site that our Site links to, even if you reached that site through our Site, the information that you submit to complete that transaction becomes subject to the privacy practices of the owner of that linked site. You should read their privacy policies to understand how they use and protect personal information that they collect. SpringCM is not responsible for the privacy or information practices of its suppliers or any third party web sites.

Who Can You Contact For More Information?

Please direct any other questions, inquiries or complaints regarding our privacy practices or this Privacy Policy to SpringCM at support@springcm.com or by our customer service line at 877-362-7273 or 312-881-3200.

Acknowledgement

YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTAND AND CONSENT TO THE PRIVACY PRACTICES DESCRIBED IN THIS PRIVACY POLICY AND AGREE TO BE BOUND BY THE TERMS OF USE REFERENCED HEREIN.