This Privacy Notice (“Privacy Notice”) applies to: (i) https://khoros.com ;(“Site”) and https://community.khoros.com/, owned and operated by Khoros, LLC and its wholly owned subsidiaries (“we,” “us,” or “Khoros”); and (ii) the online communities and social media management products that Khoros provides to its customers (“Customer(s)”) (“Service(s)”).

This Privacy Notice describes how Khoros: (i) collects, uses, shares, and secures your personal information that can be used, directly or indirectly, to identify you or your household (“Personal Data”) on this Site; and (ii) collects, uses, shares, and secures your Personal Data as a data processor on behalf of our Customers through the Services we provide to them.

The use of any information collected through our Services shall be limited to the purpose of providing the Service for which the Customer has engaged Khoros, as agreed in a signed contract between Khoros and Customer.

This Privacy Notice also describes your rights regarding the use of your Personal Data by Khoros, as well as the options available to you regarding how we communicate with you.

Khoros does not send unsolicited emails or sell any Personal Data that users may have submitted to us though our Site. In addition, for lead generation or marketing purposes, we may ask individuals interested in obtaining more information about Khoros products to voluntarily submit their contact information to us. For more information on the Personal Data that we collect, see the “What Personal Data do we collect?” section, below. For more information on how we use your Personal Data, see the “How do we use your Personal Data?” section below. Khoros is controller of your Personal Data as described in this Privacy Notice, unless explicitly stated otherwise.

This Privacy Notice does not apply to the extent that we process Personal Data while acting in the role of processor for our Customers. Such processing is governed by contracts that we have with our Customers.

For detailed information on how we process Personal Data on behalf of our Customers, please ask the applicable Customer directly. Khoros is not responsible for the data privacy or data protection practices of its Customers.

Please note that some Personal Data we receive directly from you is provided to us automatically via technology, such as a cookie placed on your computer when you visit our Site.

Please also note that some parts of our website and services allow you to post or transmit comments, computer files, messages, and other materials. Please be careful about what Personal Data you choose to make public in these areas of our Site and Services.

We collect the following types of Personal Data:

Context	Types of Data	Legal Basis and Primary Purpose for Processing
Marketing Communications	Khoros receives user-submitted Personal Data from users wishing to be sent additional promotional information on Khoros products. Such Personal Data includes information such as name, phone number, company, title, and email address.	Khoros has a legitimate interest in communicating with its customers. In some circumstances, this processing may also be based upon your consent.
Information Posted to our Communities	We collect information, often including Personal Data, that is posted by users to the Khoros Community forum (“Khoros Community,” also called the “Atlas”) located at the Site, including content that is processed and stored within such community (“Community Content”). As part of our Services, we also collect information that users post to our Customers’ online communities hosted by Khoros (“Customer Communities”, each individually a “Customer Community”). When personal data is posted in our Customer Communities, we process that data as a data processor or service provider.	We process Personal Data on the Khoros Community or Atlas based upon your consent.
Account Registration	When you create an account on the Khoros Community or in a Customer Community, we collect Personal Data from you including your name, email address, phone number, and social media account information.	We have a legitimate interest in providing account related functionalities to our users. Accounts can be used for easy checkout and to save your preferences and transaction history.
Office Visits	When you visit our offices, we collect Personal Data including name, phone number, company, title, and email address.	We have a legitimate interest in maintaining records of individuals who visit our office.
Event Attendance	When you register for and/or attend our events, we collect Personal Data including name, phone number, company, title, and email address.	We have a legitimate interest in maintaining records of individuals who attend our events.
Employment Applications	As part of its recruiting activities, Khoros also receives Personal Data from users submitting job application materials to be considered for Khoros employment (“Recruiting Data”). This Recruiting Data includes anything that an individual chooses to include, such as a resume or application, and typically consists of job history, education, personal interests and activities, name, email address, phone number, and residence address. Further, Khoros collects gender, race, and military status from employment candidates to assist Khoros in its equal employment opportunity compliance and related statistical tracking to help our diversity efforts. In connection with job screening activities, Khoros also requests Personal Data sufficient to have background checks conducted prior to hiring.	We also have a legitimate interest in collecting Recruiting Data in order to provide for an efficient workforce and to comply with relevant laws.
Social Media and Single Sign On Information	You can log in to our Site using sign-in services such as Facebook Connect or an Open ID provider. These services will authenticate your identity and provide you the option to share certain Personal Data with us, such as your name and email address, to pre-populate our sign up form. Services like Facebook Connect give you the option to post information about your activities on this Site to your profile page to share with others within your network.	We have a legitimate interest in ensuring users can effectively connect to our websites.
Cookies and other tracking technologies.	We also use cookies and collect some information passively such as the client browser type and IP address information. This information is gathered for all users to our website to track usage and provide a personalized experience. More information on cookies and similar technologies can be found in the section entitled “Use of cookies and other tracking technologies” below.	We have a legitimate interest in ensuring our website operates efficiently.
Third Party Tracking	We partner with a third party ad network to either display advertising on our Site or to manage our advertising on other sites. Our ad network partner uses cookies and Web beacons to collect information about your activities on this and other websites to provide you targeted advertising based upon your interests. If you wish to not have this information used for the purpose of serving you targeted ads, you may opt-out by clicking here, or if you are located in the European Union you may click here. Please note this does not opt you out of being served advertising. You will continue to receive generic ads.	We have a legitimate interest in behavioral based advertising and in capturing website analytics.
Information from Customers	We collect information that our Customers provide us to enable them to log on and use the Services. This data consists of Personal Data of their authorized users, company information and configuration, content, internal communications, and notes.	We have a legitimate interest in ensuring Customers can use our Services effectively.
Partner Information	We also collect information from partners and other websites concerning visitors of our Site and our Customers‘ websites (“Visitors”). For example, we ask or engage third parties to tell us additional information about Visitors, such as how they responded to our communication or promotions.	We have a legitimate interest learning more about how users respond to our communications and promotions.

In addition to the information that we collect from you directly, we may also receive information about you from other sources, including third parties, business partners, our affiliates, or publicly available sources. For example, Khoros collects data about individuals that is made available to Khoros and other third parties by social media sites such as Twitter, Facebook, Instagram, Pinterest, YouTube, Google, and others through APIs or social media monitoring technology (“Third Party Sites”). This data includes names, user IDs, social media handles, gender, and other information that individuals choose to make publicly available on social media sites. Khoros also monitors the public activities of individuals on social media sites, including posts, blogs, tweets, and profile information, including such social media messages directed at our customers (the “brands” that are interested in understanding their consumer customers in order to serve them better).

Note that any direct or indirect use of any social media network or other third party site through our Services is subject to your consent of the legal terms of that site, such as their respective terms of use and privacy policy. For your convenience, we've listed some of the most used sites with links to their main terms below (most terms also have additional policies linked to within the main terms). Note that we endeavor to keep these links updated, but they are subject to change. Regardless, you agree to locate and abide by all the third party terms that apply to you.

Facebook: https://www.facebook.com/polic...

Instagram: https://help.instagram.com/478...

Google: https://policies.google.com/pr...

YouTube: https://www.youtube.com/t/term...

In addition to the normal procedure for deleting stored data under YouTube's Terms of Service, please be aware that users can revoke access to their data via the Google security settings page, located at: https://myaccount.google.com/p...

LinkedIn: https://www.linkedin.com/legal...

Pinterest: https://policy.pinterest.com/e...

Twitter: https://twitter.com/en/tos

Tumblr: https://www.tumblr.com/policy/...

WhatsApp: https://www.whatsapp.com/legal...

Your continued access and/or use of this web site constitute your acceptance of the terms, as applicable, that are contained in the above third party notices.

Additionally, when a Customer provides or accesses information through one of our Services, we may receive information from the Customer’s input of, in response to, or by way of interaction with, content generated by Customer’s use of the Services, such as social media messaging, as well as from the Customer’s website or Third Party Site. This may include information regarding a third party that was published on or provided to the Customer’s website or Third Party Sites.

This Privacy Notice does not govern the collection of content by Third Party Sites that is not published or generated through the Services, except to the extent that we act as a processor with respect to such content. Our Customers are required to abide by the applicable policies and requirements of such Third Party Sites used in connection with the Services and when using information from Third Party Sites.

We collect and process your Personal Data for the following purposes:

• To help us provide, maintain, and improve the Site and the Services, and to assess and enhance user experience on the Site and Services. We conduct this processing on the basis of our legitimate interest in ensuring the optimal functionality of our Site and Services.

Information collected by Khoros from each Customer Community is used solely to provide the Services for that Community, to provide related Services to the customer who manages that Community, and as otherwise agreed in a contract between Khoros and the customer. Other information gathered is solely used to: (i) respond to a user's request for additional information on Khoros Services; (ii) provide, develop, enhance and support related Khoros Services; (iii) fulfill Khoros’s legal obligations and defend Khoros’s legal rights, as needed. We may also use a user's email address to send promotional or marketing materials on related Services, such as updates on the product line, but this is only after the user is a customer, a Service is requested by the user, or Khoros has some other pre-existing business relationship with the user. We use your IP address and browser-type information in the general administration of our website

In addition, we use the information that we gather from other social media sites to:

1. provide context to a brand, such as information about an individual’s past interactions with that brand, and the individual’s public profile information, to improve the quality of the brand’s interactions with that consumer who is reaching out to them over social media,
2. assess each individual’s general topics of interest (but excluding sensitive topics such as political or religious views),
3. measure their influence on social media by assigning a numerical value based on our proprietary algorithm which looks at frequency/ dates of activity, responses of other individuals to that activity, and the occurrence of certain key words and/or brand names, and,
4. allow brands to compare themselves to other brands in their industry by seeing aggregated statistics of the numbers of individuals who promote or detract from each brand based on the individuals’ public social media activity.

Through our social media management services, we provide this information on individuals to the customer support and service representatives of the companies who are Khoros customers, the “brands”, so that those representatives can provide support and service to their consumer customers more effectively, by triaging communications to address more urgent requests in priority order, and by understanding the interests of their consumer customers to provide more targeted support. We also provide aggregated statistic to the brands for competitive analysis purposes.

Khoros Care’s use and transfer of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.

Through our Khoros Community and Khoros JX Community platforms, we make social impact scores available for individuals who participate in the community to create more effective and interesting social interactions within the Community.

In the collection and use of information from other social media sites, we rely on our legitimate interests in providing services to our customers, and assisting them to provide better service to their customers, under applicable data privacy regulations, and balance those interests with the data privacy concerns of individuals. If you would like more information about our legitimate interests analysis, or have concerns that you would like us to address, please contact privacy@khoros.com.

• To ensure the security of our Site and Services. We conduct this processing on the basis or our legitimate interest in promoting the security and safety of the Site and Services, and in protecting our rights and the rights of others.
• To provide the necessary functionality of the Site and Services. We conduct this processing to perform our contract with you for the use of our Site and Services. If we have not entered into a contract with you, we base this processing on our legitimate interest in providing you with the necessary functionality required during your use of our Site and Services.
• To allow social sharing functionality on our Site and Services.
• To manage event registrations and attendance. We conduct this processing based on our legitimate interest in providing our Customers and Users with valuable information on our Site and Services.
• To register visitors to our offices. We conduct this processing on the basis of our legitimate interest in protecting our offices and our confidential information against unauthorized access.
• To identify new Customer opportunities. We process your Personal Data to identify and assess new potential Customer opportunity to the extent that it is in our legitimate interest to ensure that we are meeting the demands of our Customers.
• To manage contests or promotions. If you register for one of our contests or promotions, we process your Personal Data to perform our contract with you. If we have no contract with you, we engage in this processing based on our legitimate interest in running successful contests or promotions for you.
• To send you marketing communications. We process your Personal Data to send you marketing information, product recommendations, and other non-transactional communications (e.g., marketing newsletters, telemarketing calls, SMS, or push notifications) about us and our affiliates and partners, including information about our products, promotions, or events as necessary to further our legitimate interest in conducting direct marketing or to the extent you have provided your prior consent. Please see the "Your rights and options regarding your Personal Data" section, below, to learn about your options regarding the processing of your Personal Data by Khoros for marketing purposes.
• To display personalized advertising and content. We process your Personal Data to conduct marketing research, advertise to you, provide personalized information about us on and off our Site and to provide other personalized content based upon your activities and interests to the extent it is necessary for our legitimate interest in advertising our Site and Services or, where necessary, to the extent you have provided your prior consent. As stated above, please see the "Your rights and options regarding your Personal Data" section, below, to learn about your options regarding the processing of your Personal Data by Khoros for marketing purposes.
• To complete a merger or sale of assets.
• To protect the rights of Khoros and others.
• To evaluate candidates for employment. In regard to candidates for employment, we use your Recruiting Data for purposes of evaluating candidates for potential employment with Khoros. We disclose your Recruiting Data to our private equity sponsor, Vista Equity Partners, and its affiliates, including Vista Consulting Group (collectively, “Vista”), for administration, research, database development and business operation purposes, in line with the terms of this Privacy Notice. Vista processes your personal information on the basis of its legitimate interests in overseeing the recruitment process and, if applicable, your employment relationship with Khoros. If you have consented to us doing so, we also share your personal information with other Vista portfolio companies for the purpose of being considered for other job opportunities in the pooling system, both inside and outside your home country (including inside and outside the EEA). Please find a full list of all Vista portfolio companies at: https://www.vistaequitypartner.... For residents of EEA countries, when this requires us to transfer your personal information outside of the EEA, we comply with applicable EU data privacy rules.
• To comply with legal obligations. We process your Personal Data when cooperating with public and government authorities, courts or regulators in accordance with our legal obligations under applicable laws to the extent this requires the processing or disclosure of Personal Data to protect our rights or is necessary for our legitimate interest in protecting against misuse or abuse of our websites, protecting personal property or safety, pursuing remedies available to us and limiting our damages, complying with judicial proceedings, court orders or legal processes or to respond to lawful requests.
• In accordance with your consent.

In regard to Khoros Services, Khoros collects information under the direction of its Customers, and has no direct relationship with the individuals whose Personal Data it processes. If you are a customer of one of our Customers and would no longer like to be contacted by one of our Customers that use our Services, please contact the Customer that you interact with directly. We may transfer Personal Data to companies that help us provide our Services. Transfers to subsequent third parties are covered by the service agreements with our Customers.

Please note that Khoros may use and disclose data cleansed of all Personal Data so that it no longer can identify the Customer and/or user; and aggregated with similar data from other Khoros Customers (“Aggregated Data”) to determine and report Services usage patterns by Customers and users generally, and for any other legitimate purpose.

Information collected by Khoros from Customers is used solely to provide the Services and as otherwise agreed to in a contract between Khoros and the Customer.

Sometimes, our Customers have specific purposes for which they plan to use an individual user’s Personal Data, and our Customers describe those purposes at the point of collection. For example, a Customer may solicit a user’s feedback in order to improve services and products, respond to a user’s questions or comments, register in connection with a contest, giveaway, or drawing, respond to a request for a brochure, or to otherwise send information to the user. We may be asked to fulfill or assist with the fulfillment of the requirements associated with the point of collection purposes, but the responsibility to obtain any necessary consents remains with our Customers as the data controllers.

As a matter of policy, we do not sell your Personal Data. We may disclose your Personal Data. We will only share your Personal Data in the ways stated below:

• To any third party with your consent
• To companies that provide services on our behalf to help us with business activities. These companies are authorized to use your personal information only as necessary to provide these services to us. These services may include hosting, log file analysis, spam filtering, content delivery network services, video hosting, and/or serving targeted in-media content. For a complete list of our subprocessors (third parties who process or have access to our customers’ personal data through our Services) visit https://khoros.com/khoros-subp....
• In certain situations, Khoros may be required to disclose Personal Data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements, when required by law to comply with a subpoena or other similar legal processes.
• We may share your Personal Data when we believe in good faith that disclosure is necessary to protect our rights, your rights, protect your safety or the safety of others, investigate fraud, or comply with a law enforcement request.
• If Khoros becomes involved in a merger or acquisition, or any form of sale of some or all of its assets, we will provide notice via email and/or a prominent notice on our Site when your Personal Data becomes subject to a different privacy notice, of any change in ownership, uses of your Personal Data, and choices you may have regarding your Personal Data.
• In regard to Personal Data we collect from other social media sites, we disclose this Personal Data to our Khoros Customers as part of our Services to them to help them better serve their customers, as we describe above in the section called “How do we use your Personal Data?”
• We disclose your personal information to our private equity sponsor, Vista Equity Partners, and its affiliates, including Vista Consulting Group (collectively, “Vista”), for administration, research, database development, workforce analytics and business operation purposes, in line with the terms of this Privacy Policy. Vista processes and shares your personal information with its affiliates, including other Vista portfolio companies, on the basis of its legitimate interests in managing, administering and improving its business and overseeing the recruitment process and, if applicable, your employment relationship with Khoros, LLC. If you have consented to us doing so, we also share your personal information with other Vista portfolio companies for the purpose of being considered for other job opportunities in the pooling system, both inside and outside the EEA. Please find a full list of all Vista portfolio companies at: https://www.vistaequitypartner... and Vista’s privacy policy at https://www.vistaequitypartner.... Where this requires us to transfer your personal information outside of the EEA, please refer to Section 5 of the Privacy Policy for further details on cross-border transfers. In connection with the recruitment process, your personal data may be transferred outside of the EEA to iCIMS, Hirebridge, LLC and Criteria Corp., which provide applicant tracking and evaluation services. Hirebridge, LLC and Criteria Corp. have agreed to comply with the EU Standard Contractual Clauses to ensure that your personal information is adequately protected whilst outside of the EEA.
  

For more information on international transfers of your Personal Data by Khoros, please see “International transfers of your Personal Data” below.

As detailed above in the previous section “How do we share your Personal Data?,” we may share your Personal Data with our affiliates and third parties for a variety of reasons. Some of these affiliates or third parties may be located in countries located outside of the European Economic Area (“EEA”) or UK that offer an adequate level of data protection, as determined by the European Commission. More information on those countries can be found here:

https://ec.europa.eu/info/law/...

Some of these third parties may be located in countries whose level of data protection has not been deemed adequate by the European Commission.

In the course of performing its Services, Khoros and its subprocessors may access and/or transfer the Personal Data described in the Section “What Personal Data do we collect?” to (or from) these areas, pursuant to the European Commission Standard Contractual Clauses (“Clauses”). You can find a copy of the Clauses here:

https://eur-lex.europa.eu/lega...

You have a right to request a copy of the executed Clauses from Khoros, which you can exercise at any time by emailing us at privacy@khoros.com.Khoros strictly prohibits the entry of Sensitive Information into Khoros systems, except with the express prior written consent of Khoros in each instance.

You may “opt-out” of having your Personal Data used for certain purposes, such as receiving promotional or other marketing material from us during the registration process, for downloading a whitepaper or signing up for our webcasts. Users who no longer wish to receive our updates or newsletters may opt-out of receiving these communications by following the instructions contained in the mailer or by emailing us at marketing@khoros.com. Please include the term “OPT-OUT” in the subject line immediately followed by your email address.

You may access, correct, or request deletion of your personal information collected via this Site by filling out the web form found here. You may also contact us at 1 (800) 235-0187. We will respond to your request within a reasonable timeframe.

Note that, as required by law, we will require you to prove your identity. We may verify your identity by phone call or email.  Depending on your request, we will ask for information such as your name, email, social media pages that you have posted content to or interacted with, and/or your social media account profile or handle. We may also ask you to provide a signed declaration confirming your identity. Following a request, we will use reasonable efforts to supply, correct or delete personal information about you in our files.

In some circumstances, you may designate an authorized agent to submit requests to exercise certain privacy rights on your behalf. We will require verification that you provided the authorized agent permission to make a request on your behalf. You must provide us with a copy of the signed permission you have given to the authorized agent to submit the request on your behalf and verify your own identity directly with us. If you are an authorized agent submitting a request on behalf of an individual you must attach a copy of the following information to the request:

1. A signed permission from the consumer in writing indicating that you have authorization to act on the consumer’s behalf.
2. If you are a business, proof that you are registered with the Secretary of State to conduct business in California.

If we do not receive both pieces of information, the request will be denied.

Khoros takes information security and privacy of Personal Data very seriously. We fully support and abide by the data privacy principals established in the EU Directive on Data Protection as well as all other applicable local privacy laws and regulations. Our security controls and mechanisms are based on the ISO 27001 global security management standard and we conduct external security audits and independent security testing on an annual basis.

Specifically for Customers:

The Khoros Security Data Sheet provides a summary of the security measures implemented throughout the organization to provide full transparency and a peace of mind for Khoros Customers that their Personal Data and information are in good hands.

For Customers who have a requirement to conduct their own security testing of the Khoros platform, the Khoros Security Scanning Policy provides an overview of the process and any associated restrictions.

If you have any questions about our security practices or security on our website, you can visit our security information page at https://khoros.com/khoros-secu... email us at privacy@khoros.com.

We use cookies to remember users’ settings (e.g. language preference) and for authentication. Users can control the use of cookies at the individual browser level. If you reject cookies, you may still use our Site, but your ability to use some features or areas of our site may be limited.

As is true of most web sites, we gather certain information automatically and store it in log files. This information may include internet protocol (IP) addresses, browser type, referring/exit pages, browser type and operating system, date/time stamp, and/or clickstream data. We do not link this automatically collected data to other information we collect about you. For more information about cookies used by Khoros and a list of Khoros cookies download the Khoros Cookies Datasheet.