U.S., U.K. AND CANADIAN (EXCEPT FOR QUEBEC) PRIVACY POLICY FOR THE SANDLER® ATTENDANCE APP

This Privacy Policy describes Sandler Systems, Inc.'s (“Sandler”, “we” or “us”) practices regarding the collection, use and disclosure of the information we collect from and about you when you use Sandler's web application known as the Sandler Attendance App (the “App”).

By accessing or using the App, you agree that you have read and understand this Privacy Policy and that you accept and consent to the privacy practices and uses or disclosures of information about you that are described herein.

In order to deliver personalized and relevant information to you through the App, we collect certain information from users. Please do not provide any sensitive information or health information. We do not want, nor will we ask for sensitive information. The App is not designed to process sensitive information.

Information We Collect

We collect personal information, such as your name, email address, phone number, company name and location, when you check in using the App. We also collect other information, such as your trainer's name, lessons learned, class ratings and referral names when you use the App. If you provide us with personal data of another individual, you must have permission to do so and are responsible for notifying them of this Privacy Policy and getting any required consent.

Information We Automatically Collect

We do not automatically collect any information about your use of the App through cookies, web beacons, or other technologies. We do not use automated devices or applications, such as Google Analytics, to evaluate usage of the App.

Use of Your Information

We may use the information we collect from you in the following ways:

• To provide our services to you.
• To personalize your experience and to allow us to deliver the type of content and product offerings in which you are most interested.
• To ask for ratings and reviews of our services and products.
• To improve our web site in order to better serve you.
• To provide customer support and to follow up with you after correspondence (live chat, email or phone inquiries).
• To understand the lessons learned.
• To calculate certification credit hours.
• To contact you for marketing purposes, including to send you personalized and relevant information through email in accordance with local law and consent requirements. You may unsubscribe from our mailing lists at any time by using the “unsubscribe” feature in any marketing emails you receive from us.
• To comply with applicable legal obligations, including responding to a subpoena or court order.
• Where we believe it is necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person or violations of this Policy.

Security

We have put in place security measures to safeguard and secure the information we collect through the App. Nonetheless, the transmission of information via the Internet is not completely secure and therefore we cannot guarantee the security of data sent to us electronically in the App, and transmission of such data is therefore entirely at your own risk.

Disclosing Your Information

The information you enter into the App will be shared amongst your Sandler trainers. We may disclose the information we collect from you to third-party vendors, service providers, contractors or agents who perform functions on our behalf. We take appropriate steps to ensure that such third parties treat your personal information with the same consideration that we do. We do not sell, trade, or otherwise transfer to outside parties your personally identifiable information.

Sandler Systems, Inc. is a United States company. In accordance with local laws, we will take steps to ensure that your personal information receives an adequate level of protection as required by applicable law, such as through the use of the EU standard contractual clauses approved by the European Commission, relevant national equivalents outside the EU, or other safeguards as permissible. By providing us with your personal information, you expressly acknowledge that we may transfer your personal information to, or access it in, jurisdictions which may not provide equivalent levels of data protection to your home jurisdiction.

We may also share information in the following circumstances:

• Business Transfers. If we are acquired by or merged with another company, if substantially all of our assets are transferred to another company, or as part of a bankruptcy proceeding, we may transfer the information we have collected from you to the other company.
• In Response to Legal Process. We also may disclose the information we collect from you in order to comply with the law, a judicial proceeding, court order, or other legal process, such as in response to a court order or a subpoena.
• To Protect Us and Others. We also may disclose the information we collect from you where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of this Privacy Policy, or as evidence in litigation in which Sandler is involved.
• Aggregate and De-Identified Information. We may share aggregate or de-identified information about users with third parties for marketing, advertising, research or similar purposes.

Special Information for California Consumers; Your California Privacy Rights

California residents may request a list of all third parties to which we have disclosed certain personal information about you for the third party's own marketing purposes. You may make one request per calendar year. In your request, please attest that you are a California resident and provide a current California address for our response to you. We will respond to you within thirty (30) days. You may request this information in writing by contacting the Privacy Officer identified in section “Contacting Us” below.

Third-Party Web Sites and Interaction

The App does not contain links to third-party web sites or applications.

Users Only of Legal Age of Majority

The App is designed and may only be used by those who have reached the age of majority (18 years of age in most jurisdictions). By using the App, you affirm that you are at least 18 years of age or older. We are not liable for any damages that may result from a user's misrepresentation of age.

Access to Information

If you believe that any information we are holding about you is incorrect or incomplete, or have any complaints about the App, please inform us as soon as possible at the address below. We will respond to your request in accordance with applicable local law.

You can also update certain of your personal information by logging in in to your account. Please note that we may maintain a copy of any personal data that you have updated for a period of time as part of our backups and business records; please see the “Retention of Your Information” section below for an explanation of our retention practices.

EU users have additional rights in respect of your personal information; for example, to access or erase your personal information, object to our use of it, or require it be made available in a portable format. If these rights apply to you, and you would like to exercise them, please contact us using details set out below.

Retention of Your Information

The App applies a general rule of keeping your personal information for only as long as is required to fulfil the purposes for which it was collected. However, in some circumstances we may retain personal information for longer periods of time, for instance where we are required to do so in accordance with legal, tax or accounting obligations, or where we would like to have an accurate record of your dealings with us in the event of any complaint or challenge.

Changes to this Policy

We do update this Privacy Policy from time to time so please review this Privacy Policy regularly. If we materially alter our Privacy Policy, we will notify you of such changes by posting a notice on the App home page. Your continued use of the App will be deemed your agreement that your information may be used in accordance with the new policy. If you do not agree with the changes, then you should stop using the App and you should notify us that you do not want your information used in accordance with the changes.

Contacting Us

We welcome any queries, comments or requests you may have regarding this Privacy Policy. Please do not hesitate to contact us at:

Shannon Howell, Privacy Officer
Sandler Systems, Inc.
300 Red Brook Blvd, Suite 400
Owings Mills, MD  21117
USA
410-653-1993
legal@sandler.com

Effective Date:  June 27, 2017