This Website Privacy Policy (“Privacy Policy”) covers the web sites (“Web Sites”) operated by Intellum, Inc. (“Intellum” or “we” or “us” or “our”), including but not limited to Intellum.com, Exceedlms.com, Catcat.com, Facebookblueprint.com, Snacker.tv and Tribesocial.com. This Privacy Policy describes the types of information that we collect, what we do with it, how we protect it, and if and when we disclose it to third parties.
This Privacy Policy is a part of and subject to the Intellum Terms of Service (“TOS”). Accordingly, when you enter into the TOS, you agree that you have read, understand, and agree that we can collect, use, and disclose your information in accordance with this Privacy Policy. If you do not agree or are not comfortable with any part of this Privacy Policy, you should not agree to the TOS (including this Privacy Policy) and you may not use the Web Sites.

Additional information about Intellum’s Data Privacy and Data Security practices, including Intellum’s commitments with regard to the General Data Protection Regulation (GDPR), can be found at the bottom of this page.

Information Gathering, Processing and Usage

In connection with operation of the Web Sites and providing our services to you, we may collect the following types of user information (“Information”):

• Personal Information. We collect personal information (“Personal Information”) from you and those individuals to whom you have given Web Site access. This Personal Information is used for billing purposes, account management purposes and for you to utilize the features of the Web Sites to which you have purchased access. Examples of Personal Information we might collect include but are not limited to: first name, last name, email address, mailing address, etc. We also collect Personal Information provided to us via any emails you send to us and via any user information added by you to the Web Sites (including Personal Information for users other than yourself).
• Browsing Information. We collect information about your computer hardware and software and browsing activity.
  
• Training Information. We collect information on learning/training activities within the Learning Management System (“LMS”)
  
• Survey Information. We collect responses to any Intellum-sponsored Web Site surveys.
  

We collect and process this Information for the following general purposes: products and services provisioning, billing, identification and authentication, Web Site improvement, contacts, and research.

Intellum may disclose your Information to third parties under the following circumstances:

• Disclosure to Successors. We may disclose your Information to any actual or potential successor-in-interest of ours, such as a company that is seeking to acquire us or the Web Site(s).
• Third-Party Service Providers. We may use third-party partners to help us operate and maintain our Web Sites and deliver our products and services. We may also share your Information with our service providers and other third parties (“Affiliated Parties”) that provide products or services for or through the Web Sites or for our business (such as website or database hosting companies, CRMs, e-mail service providers, analytics companies, credit card processing companies and other similar service providers that use such information on our behalf or at the direction of your employer). Third-party service providers are contractually restricted from using or disclosing the Information, except as necessary to perform services on our behalf or to comply with legal requirements. Information may be processed in the European Union or the United States depending upon contractual requirements and in accordance with legal jurisdictions for the region(s) to which Intellum is subject.
• Other Disclosure. We may disclose your Information to prevent an emergency, to protect or enforce our rights, to protect or enforce the rights of a third party, or as required or permitted by law (including, without limitation, to comply with a subpoena or court order).

Cookies

To enhance your experience on our Web Sites, many of our web pages use "cookies". Cookies are bits of electronic information that a web site can transfer to a visitor’s hard drive to help tailor and keep records of his or her visit.  Cookies are required to use most Intellum services.  You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access most of Intellum’s services. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Web Sites.  If you proceed with using our Web Sites without deactivating cookies through your browser, you are deemed to have accepted our use of cookies.

Web Beacons

Pages of our services or our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an e-mail and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

Data Storage

Intellum uses third party vendors and hosting partners to provide some of the necessary hardware, software, networking, storage, and related technology required to run the Websites. Although Intellum owns the code, databases, and all rights to the Websites, you retain all rights to your data.

Protecting Personal Information

We understand the importance of safeguarding your Information.  We employ administrative, physical, and electronic measures designed to protect your Information from unauthorized access.  We implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk, taking into account technological reality, cost, the scope, context and purposes of processing weighted against the severity and likelihood that the processing could threaten individual rights and freedom.  Despite our efforts, we cannot guarantee the security of your Information. Accordingly, we assume no liability for any disclosure of data due to errors in transmission, unauthorized third-party access or other acts of third parties, or acts or omissions beyond our reasonable control.

Privacy Shield

Intellum complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of Personal Information transferred from the European Union and the United Kingdom to the United States.  Intellum has certified to the Department of Commerce that it adheres to the Privacy Shield Principles.  If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.  To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/

As such:

• We participate in Privacy Shield.
  
• We collect only Personal Information provided by the individual or the individual’s employer, including but not limited to name, address and email.
  
• Intellum is subject to the Principles of all personal data received from the EU in reliance on the Privacy Shield.
  
• Intellum collects Personal Information for authentication and personalization of the user experience.
  
• Other than to the Third-Party Service Providers referenced above, Intellum does not disclose any Personal Information to third parties.
  
• Intellum's customers can view their personal data in their profile in the application.
  
• All user accounts are password protected, and an individual's Personal Information is only available to that individual when logged in.
  
• Intellum is subject to the investigatory and enforcement powers of the FTC.
  
• Intellum understands the possibility, under certain conditions, for the individual to invoke binding arbitration.
  
• Intellum is required to disclose Personal Information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
  
• Intellum is liable in cases of onward transfers to third parties.
  

In compliance with the Privacy Shield Principles, Intellum commits to resolve complaints about our collection or use of your Personal Information.  EU individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Intellum here.

Intellum has further committed to cooperate with EU data protection authorities (DPAs) with regard to unresolved Privacy Shield complaints concerning human resources data and non-Human Resources data transferred from the EU. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact the EU DPAs for more information or to file a complaint. The services of EU DPAs are provided at no cost to you.

Third Party Websites

This Privacy Policy applies only to our Web Sites.  This Privacy Policy does not apply to any websites managed, maintained, and/or hosted by third parties not directly affiliated with Intellum that you may visit, e.g., via a link provided through the Web Sites or on a website maintained by any third party.  We do not control the privacy policies of other websites to which we may provide hyperlinks.  We cannot be responsible for the privacy practices or the content of such non-Intellum websites, and we do not control the practices of any of the third party websites or service providers to whose sites we link. We encourage you to learn more about the online privacy and data security policies of third party websites directly from such third parties, as their policies may differ from ours.

Children’s Privacy

We are committed to protecting the privacy of children.  Our solutions are not intended for anyone under the age of 13. If you are under 13, do not use or provide any information on or through our solutions. If we learn we have collected or received Personal Data from a child under 13 without verification of parental consent, we will delete that information. If you are a parent or guardian or otherwise believe we might have any information from or about a child under 13, please contact us so that we can delete the child's information. Our services will never knowingly accept, collect, maintain or use any information from a child under the age of 13. If a child whom we know to be under the age of 13 sends Personal Data to us online, we will only use that information to respond directly to that child or notify parents.

Intellum Data Privacy & Data Security Statement

This Data Privacy & Data Security Statement (the “Statement”), is provided by Intellum, Inc. (“Intellum”) to its Clients (each, a “Client”) and to users of Intellum’s Services affiliated with the Clients (“Users”). This Statement describes Intellum’s commitments with regard to data privacy and data security.   Intellum may update this Statement from time to time.  Updated versions will be published on Intellum’s website.

1. Definitions

• “Authorized Persons” means Intellum’s employees, agents, and contractors that have a need to know or otherwise access User Data to enable Intellum to provide the Services.
• “Controller” means a controller as defined under the GDPR.
• “Data Protection Laws” means all international, federal, national and state privacy and data protection laws and regulations to the extent applicable to Intellum and the Services.
• “Data Breach” means any loss or unauthorized access, acquisition, theft, destruction, disclosure or use of User Data that occurs while such User Data is in the possession of or under the control of Intellum.
• “GDPR” means the EU General Data Protection Regulation 2016/679.
• “Personal Data” means information relating to an identified or identifiable natural person.  An identifiable natural person is a natural person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
• “Process” or “Processing” means any operation or set of operations that are performed upon User Data, whether or not by automatic means, such as collection, accessing, processing, use, recording, organization, storage, adaptation or alteration, retrieval, consultation, use, disclosure, dissemination, transmittal, alignment or combination, blocking, erasure, destruction or otherwise used as set out in the applicable Data Protection Laws.
• “Processor” means a processor as defined under the GDPR.
• “Services” means Intellum’s services, solutions and products.
• “Sub-Processor” shall mean an entity engaged by Intellum to assist it in Processing the User Data in fulfillment of its obligations with regard to the Services.
• “Third Party” is any person or entity other than Intellum and Client and Client’s Users.
• “User Data” means all data relating to a User that is (i) provided to Intellum by Client or User or (ii) otherwise obtained, accessed, developed, or produced by Intellum.  User Data may include Personal Data.

2. Data Privacy

• 2.1. Compliance with Laws. Intellum is committed to complying with its obligations under all Data Protection Laws. For purposes of the GDPR, Client is considered the Controller and Intellum is its Processor; if Client is considered a Processor for purposes of the GDPR, then Intellum is considered its Sub-Processor.
• 2.2. Distribution of User Data. Users should provide Intellum only with Personal Data that is requested by Intellum or that is otherwise necessary for Intellum to provide the Services.  Intellum is not responsible for any other Personal Data.  Client will not provide Intellum with Personal Data unless Client has obtained all required consents from Users.
• 2.3. Limitations on Use of Personal Data. Intellum shall not Process User Data other than for the purposes specified by Users. Intellum shall not Process User Data for the benefit of any Third Party. Intellum shall access only the User Data that it needs to perform the Services (i.e., no more than necessary). Intellum will not store User Data longer than necessary to achieve the permitted purposes specified by User. Intellum does share aggregate or anonymous data (including personal data that has been stripped of personally-identifying characteristics) with third parties. Personal Information does not include information that has been aggregated or made anonymous such that it can no longer be reasonably associated with a specific person or directly identify you. This policy in no way restricts or limits our collection and use of aggregate information, and we may share aggregate data about our users with third parties for various purposes.
• 2.4. Restrictions. Except with a User’s prior, written approval, on a case-by-case basis, Intellum will not: (a) use User Data other than as necessary for Intellum to provide the Services, (b) disclose, sell, assign, lease or otherwise provide User Data to Third Parties (other than to its affiliates or Sub-Processors) except to the extent required or permitted by Data Protection Laws, or (c) merge User Data with other data, modify or commercially exploit any User Data.
• 2.5. Sensitive Personal Data. Clients and Users are advised never to provide Intellum with Sensitive Personal Data. “Sensitive Personal Data” means (a) information that reveals a natural person’s racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade-union membership, (b) information or data concerning a natural person’s health or sex life or sexual orientation; or (c) genetic data or biometric data about a natural person.

3. Sub-Processors

• Intellum may engage Sub-Processors in connection with the provision of the Services, provided, however, that Intellum may not provide a Sub-Processor with access to User Data unless the Sub-Processor has: (i) a business need to know / access the relevant User Data, as necessary for the purposes of the Services; (ii) signed a written obligation of confidentiality or are under professional obligations of confidentiality; and (iii) implemented technical, operational, physical, and organization safeguards to protect User Data against accidental or unlawful destruction or alteration and unauthorized disclosure or access.

4. Data Subject Rights; Cooperation

• You may have certain rights relating to your Personal Information, subject to local data protection law. Whenever you use our services, we aim to provide you with choices about how we use your personal data. We also aim to provide you with access to your Personal Information. If that information is wrong, we strive to give you ways to update it quickly or to delete it – unless we have to keep that information for legitimate business or legal purposes. Subject to applicable law, you may obtain a copy of Personal Information we maintain about you or you may update or correct inaccuracies in that information by contacting us. To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to the information. In addition, if you believe that Personal Information we maintain about you is inaccurate, subject to applicable law, you may have the right to request that we correct or amend the information by contacting us as indicated in the How to Contact Us section below.
  
• The European Union’s General Data Protection Regulation (“GDPR”), and corresponding legislation in the United Kingdom and Switzerland, provide European, Switzerland and United Kingdom residents with certain rights in connection with Personal Data you have shared with us. If you are resident in the European Economic Area, you may have the following rights:
  

• The right to be informed. You are entitled to be informed of the use of your Personal Data.  This Privacy Policy provides such information to you.
  
• The right of access. You have the right to request a copy of your Personal Data which we hold about you.
  
• The right of correction: You have the right to request correction or changes of your Personal Data if it is found to be inaccurate or out of date.  
  
• The right to be forgotten: You have the right to request us, at any time, to delete your Personal Data from our servers and to erase your Personal Data when it is no longer necessary for us to retain such data.  Note, however, that deletion of your Personal Data will likely impact your ability to use our services.
  
• The right to object (opt-out): You have the right to opt-out of certain uses of your Personal Data, such as direct marketing, at any time.  
  
• The right to data portability: You have the right to a “portable” copy of your Personal Data that you have submitted to us.  Generally, this means your right to request that we move, copy or transmit your Personal Data stored on our servers / IT environment to another service provider’s servers / IT environment.
  
• The right to refuse to be subjected to automated decision making, including profiling: You have the right not to be subject to a decision and insist on human intervention if the decision is based on automated processing and produces a legal effect or a similarly significant effect on you.
  
• The right to lodge a complaint with a supervisory authority.
  

• You may also have the right to make a GDPR complaint to the relevant Supervisory Authority. A list of Supervisory Authorities is available here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
  

5. Return or Destruction of User Data

• Upon the written request of a User, Intellum will return User Data to the User in a commonly readable format or securely delete User Data as soon as reasonably practicable. If you completely delete all such information, then your account may become deactivated. We may retain an archived copy of your records as required by law, to comply with our legal obligations, to resolve disputes, to enforce our agreements or for other legitimate business purposes.

6. Data Security

• 6.1. Security Program Requirements. Intellum will maintain a security program that contains administrative, technical, and physical safeguards appropriate to the complexity, nature, and scope of its activities. Intellum’s security program shall be designed to protect the security and confidentiality of User Data against unlawful or accidental access to, or unauthorized processing, disclosure, destruction, damage or loss of User Data.  At a minimum, Intellum’s security program shall include: (a) limiting access of User Data to Authorized Persons; (b) implementing network, application, database, and platform security; (c) means for securing information transmission, storage, and disposal within Intellum’s possession or control; (d) means for encrypting User Data stored on media within Intellum’s possession or control by using modern acceptable cyphers and key lengths, including backup media; (e) means for encrypting User Data transmitted by Intellum over public or wireless networks by using modern acceptable cyphers and key lengths; and (f) means for keeping firewalls, routers, servers, personal computers, and all other resources current with appropriate security-specific system patches.
• 6.2. Regular Reviews. Intellum shall ensure that its security measures are regularly reviewed and revised to address evolving threats and vulnerabilities.

7. Data Breach Procedures

• 7.1. Notification. Intellum shall notify Client and any affected User of any Data Breach as soon as practicable and without undue delay after becoming aware of it.  Such notification shall at a minimum: (i) describe the nature of the Data Breach, the categories and numbers of Users concerned, and the categories and numbers of Personal Data records concerned; (ii) communicate the name and contact details of Intellum's data protection officer or other relevant contact from whom more information may be obtained; and (iii) describe the measures taken or proposed to be taken to address the Data Breach.
• 7.2. Remedial Actions. In the event of a Data Breach for which Intellum is responsible, Intellum will use commercially reasonable efforts to: (a) remedy the Data Breach condition, investigate, document, restore the Services, and undertake required response activities; (b) provide regular status reports to Client on Data Breach response activities; (c) assist Client with the coordination of media, law enforcement, or other Data Breach notifications; and (d) assist and cooperate with Client in its Data Breach response efforts.

8. Cross-Border Transfers

• 8.1. Location. Intellum systems and Intellum’s Processing of User Data will occur within the following jurisdictions: United States of America and Ireland (the “Processing Jurisdictions”).  Intellum will not transfer any User Data outside of the Processing Jurisdictions except as directed by or with the consent of Client and/or User.
• 8.2. Sub-Processors. Before providing User Data of a European citizen to Sub-Processors, Intellum will use commercially reasonable efforts to ensure that the Sub-Processors will either be certified under the EU-US Privacy Shield or that the Sub-Processors execute EU-prescribed Standard Contractual Clauses.

Privacy Policy Updates

This Privacy Policy may be updated periodically and without prior notice to reflect changes in our online information practices. We will post a prominent notice on this Web Site to notify you of any significant changes to our Privacy Policy and indicate at the bottom of the policy when it was most recently updated.

Report a Vulnerability

If you believe you have found a security vulnerability on Intellum, please let us know right away. We will investigate all reports and do our best to quickly fix valid issues.
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You can submit your report here and our security team will respond as soon as possible.

How to Contact Us

If you have any specific questions about this Privacy Policy, you can contact us via email or by writing to us at the address below:
Intellum, Inc.
Attn: Privacy Policy Inquiry
3525 Piedmont Road, 7-500
Atlanta, GA 30305