Privacy Policy

1. Who Is This Policy For And What Does It Cover?

BookingUGC and its subsidiaries (“BookingUGC,” “we” or “us”) take privacy seriously. This Privacy Policy (“Policy”) is for users of our online products and services (collectively our “Services”), including our websites (e.g., www.BookingUGC.com); mobile, desktop and cloud applications (e.g. Revu®, Revu® for iPad, BookingUGC Cloud™); online collaboration services (e.g. Studio™, Drawings™, Studio Prime™) and tools; and technical support and training services (e.g. BookingUGC University). It describes how we collect, use and share your Personal Information. This Policy also explains related rights and choices you may have.

By using our Services, you consent to the collection, use and sharing of your Personal Information as described in this Privacy Policy so please read it carefully and let us know if you have any questions. If you do not agree with the terms of this Privacy Policy, do not access or use our Services.

You may see other privacy notices from us when your Personal Information is collected for certain purposes or in connection with a particular Service. Those notices supplement this Policy.

This Policy also contains important statements specific to residents of certain areas, including California and Virginia, and the European Economic Area, United Kingdom and Switzerland, based on laws in those areas. Those statements supplement the rest of this Policy, but to the extent they differ from other parts of the Policy, the statements govern in their applicable areas.

This Privacy Policy does not cover our processing of Personal Information in our role as a “service provider” or “data processor” to our customers who are businesses or other organizations. That processing is covered by our agreements with those customers and subject to our customers’ privacy policies.

This Privacy Policy does not apply to third party applications or software that integrate with the Services or any other third party products, services or businesses.

2. What is “Personal Information”?

Generally speaking, your “Personal Information” includes your unique identifiers (for example, your full name, phone number, or email address); and information about your characteristics, conditions or behavior that is associated with one of your identifiers or could otherwise reasonably be linked to you.

“Non-Personal Information”, on the other hand, is information that has been anonymized, aggregated or de-identified such that it cannot reasonably be linked to an individual. Your Personal and Non-Personal Information are referred to collectively in this Policy as “Your Information”.

3. Personal Information We Collect

We collect your Personal Information in various ways when you use our Services. You are not required to provide BookingUGC with your Personal Information; however, if you chose not to in some cases we will not be able to provide you with our Services or respond to your inquiries.

We collect and use your Personal Information in three basic ways:

Personal Information You Give Us

We collect, store and use your Personal Information when you provide it to us voluntarily. For example:

Website. As a visitor, you may be asked to provide:

First Name, Last Name, Business Email, Telephone Number, Company Name, Job Level, Functional Role, and Business Address.

Events. If you register to attend a BookingUGC Event, we may require:

First Name, Last Name, Business Email, Telephone Number, Company Name, Emergency Contact, and Billing Information.

Newsletter. You can subscribe to various newsletters on our websites, which we use to inform you about our company’s activities, current information about our Services, special offers, promotions and events. To receive a newsletter BookingUGC may ask you to provide:

First Name, Last Name, Email Address, Mailing Address, and Company Name.

Customer/User Account Creation. BookingUGC will collect business contact information for account management and user account management such as First Name, Last Name, Email, and Company Name as an example.

Communication Facilitation. You may choose to communicate with BookingUGC through a variety of channels including email, contact forms, chat rooms, forums, and telephone. To process your requests, you may be asked to provide:

Your name, Email Address, reason for contact, and telephone number.

Personal Information We Collect From Your Use of Our Services

Online Identifiers, Location, Internet Activity and Usage Information. When you use our Services, we gather some information automatically and store it in log files. For example, we collect, store and use your Internet Protocol (IP) addresses, cookie ID, location, referring websites and/or applications, the number of times you visit an individual website page, date/time stamps, Internet service provider (ISP), information about your device (such as device name, what devices you use, your operating system, memory available, etc.) and your browser type, and clickstream data. Some of this collection may involve the use of Cookies and other technologies. Account and Account Usage Information. When you access password-protected areas for account holders, we collect, store and use your username, computer name, IP address, transaction information, pages and content accessed by you, and preferences. Personal Information We Receive From Third Parties.

You may be asked to provide Your Information to one of our authorized partners (e.g. authorized resellers, event collaborators, and educational service providers). BookingUGC and its partners may share Your Information but only to the extent necessary to carry out the purpose for which you provided Your Information to us or our partner, e.g. to provide you with access to our Services that are supported by BookingUGC’s partner. A person or company may procure our Services for you, as their employee, to use at work. Your employer may give us Your Information in order for you to make use of the Services in connection with a separate agreement we have with your employer (a “Customer Agreement”). You may also be required to establish a user account with us to access the Services. User accounts require that you provide us with an email address. Other Services may require that we receive your name, title, email address, computer name, and IP address. We may receive information about organizations, industries, companies, website visitors, marketing campaigns and other matters related to our business from our parent corporation, affiliates and subsidiaries, our partners, or others that we use to make our own information better or more useful. This data may be combined with other information we collect. If the data, combined or in isolation, constitutes Personal Information we will treat it as such in accordance with this Policy. When available as a service supported by BookingUGC, you will be able to log into certain Services via single sign-on using the same credentials you use to access your employer’s (our customer’s) systems. This will authenticate your identity without the need to use your BookingUGC username or password. 4. Cookies And Online Tracking

What Are Cookies?

A cookie is a small file containing a string of characters that is sent to your device when you use our Services. Cookies may store unique identifiers, user preferences and other information. BookingUGC uses cookies and other technologies such as pixel tags and web beacons to receive and store certain types of information when you interact with our Services. We also use cookies and other technologies to remember you as you use our Services. Our goal is to make your experience with BookingUGC more convenient and personal by recognizing you when you revisit our Services and to provide content and advertising that is relevant to you and your interests. We also use cookies to improve the quality of our Services, including for storing user preferences and tracking user trends (please also review the section below titled “Google Analytics”).

We generally treat information collected by cookies and other technologies as Non-Personal Information. However, to the extent that Internet Protocol (IP) addresses or similar identifiers are considered Personal Information by local law, we also treat these identifiers and associated location, internet activity or usage information as Personal Information in accordance with this Policy.

Types Of Cookies Used On Our Services Our Service uses “first party” Cookies, which are set by our web domain (e.g., BookingUGC.com). Our Service also uses some “third party” Cookies, which are primarily set by other web domains associated with our vendors or partners. This means that, when you visit our website, for example, your browser may automatically connect to our vendor or partner’s web server, as well as ours, and provide them with access to your online identifiers and internet activity, including information about how you use our site.

Click here to learn more about the types of cookies used on our Services.

Your Cookie Choices

You can reset your browser to refuse all cookies or to indicate when a cookie is being sent. However, some website features and some or all of our Services may not function properly without cookies. You may also change your cookie-related consent with respect to our Services here.

Google Analytics

We use Google Analytics and related cookies, and may use other third party analytic tools to collect information about the use of our Services. Google Analytics collects usage information, such as how often users visit a BookingUGC website and what pages they visit when they do so. We only use the information we get from Google Analytics to improve our Services. To the extent that data we receive through Google Analytics includes IP address or other unique device or browser identifiers, we treat it as Personal Information. Although Google Analytics plants a permanent cookie on your device to identify you as a unique user the next time you visit or use our Services, the cookie cannot be used by anyone but Google. Google’s ability to use and share information collected by Google Analytics about your usage of our Services is restricted by the Google Analytics Terms of Use and the Google Privacy Policy.

Advertising and Remarketing

We advertise online in a variety of ways, including displaying ads to you on third party websites and social media platforms. We use Google AdWords, Google Analytics Remarketing, Google DoubleClick, Google Ads and Conversion Tracking, Google AdSense, Microsoft Advertising (formerly Bing Ads), Demandbase, Facebook Pixel and Customer Audiences (without customer list), Hotjar, LinkedIn Ads and Conversion Tracking (Pixel), Marketo, Visual Website Optimizer and other third parties to advertise on third party websites and services to previous visitors and users of BookingUGC’s Services. Remarketing allows us to tailor our marketing to better suit your needs and only display ads that are relevant to you based on your IP address or by placing a cookie, tag or similar technology on your device. The cookie is used to say “This person visited this page on BookingUGC’s website, so show them ads relating to that page.” Information collected by Google, Microsoft (Bing), Demandbase and other third parties through their remarketing services is used by them and is subject to their own policies and practices.

For more information on Google’s terms of use and privacy policy, see links above.

For more information on Microsoft Advertising (formerly Bing Ads) terms of use and privacy policy, please visit https://about.ads.microsoft.com/en-us/policies/home and https://about.ads.microsoft.com/en-us/policies/legal-privacy-and-security.

For more information on Demandbase’s terms of use and privacy policy, please visit https://www.demandbase.com/terms-of-use/ and https://www.demandbase.com/privacy/.

For more information on Facebook Pixel and Customer Audiences’ privacy policy, please visit https://www.facebook.com/about/privacy/.

For more information on Hotjar’s terms of use and privacy policy, please visit https://www.hotjar.com/legal/policies/terms-of-service/ and https://www.hotjar.com/legal/policies/privacy/.

For more information on LinkedIn Ads and Conversion Tracking (Pixel), please visit https://www.linkedin.com/legal/sas-terms.

For more information on Marketo’s handling of personal data, please visit https://www.adobe.com/privacy.html.

For more information on Visual Website Optimizer’s handling of personal data, please visit https://vwo.com/privacy-policy/.

Browser Privacy Signals

If you have configured your browser to send the Global Privacy Control signal, we will interpret that signal as your request to opt-out of analytics and advertising cookies on our website.

Your browser may offer a Do Not Track (DNT) setting. If you turn that setting on, your browser sends a signal to websites indicating that you do not want to be tracked over time or across third party sites. We do not currently respond to these signals because there is not yet a common understanding of how to process them or a consensus on what “tracking” means.

5. How We Use Personal Information

Subject to conditions that may apply under local law, we use your Personal Information to:

Communicate with you – to respond to your email and other inquiries and requests, to send you newsletters and other information you sign up to receive from us, to show you advertisements, including interest-based or online behavioral advertising, to send you information concerning any purchases you have made with us (e.g. receipts, license information, etc.), and to send you updates or notices related to the Services or related Services items that we think may be of interest to you. Some communications are considered part of the Services (e.g. administrative emails concerning changes to the Services and security, privacy or fraud notices) and you may not opt out of them. Some communications are marketing messages that you can opt out of, please see the section below title “Opt-Out”. Provide, improve, update, and maintain our Services – to deliver the Services, to diagnose technical problems, to improve and enhance features and functionality, and to customize your experience with our Services. Protect our Services – to ensure only you and those you authorize have access to your account Investigate and help prevent security issues and abuse of our Services Fulfill our obligations under a Customer Agreement. As may be required by law, legal process or regulation We use Your Information in combination with other user information to:

Understand and analyze trends, including gathering and analyzing demographic information, identifying user preferences and interests; Administer and provide the Services; Learn about user behavior in order to improve our Services; and Market and promote our Services. We may provide Your Information to our Service Providers or other third parties that assist us in these activities, such as helping us fulfill your request for a product, service or information or to tailor advertising that we think may be of interest to you (e.g. to allow third parties to tailor our ads to you on third party services). Please see the section below titled “How We Share Personal Information”.

We may use or share Non-Personal Information for any purpose.

6. How We Share Personal Information

This section describes how BookingUGC shares Your Information with our Service Providers and third parties.

Service Providers Generally

We use Service Providers to perform supporting functions for the various Services we offer, such as payment processing, cloud storage providers, analytics providers, product training and online learning opportunities, job postings and applicant tracking, and customer research and surveys. Our Service Partners are NOT permitted to use Personal Information collected from you for any purpose other than performing support functions for BookingUGC. In addition, we require that all Service Providers use reasonable safeguards to protect the limited set of your Personal Information that they may have access to.

You can see a list of our Service Providers (sub-processors) here.

Authorized Resellers and Distributors

At times we may make certain portions of your Personal Information available to our authorized resellers and distributors to help BookingUGC provide our Services to you or vice versa. For clarity, you consent to transfer of Your Information for these purposes to facilitate provision of Services and to ensure BookingUGC can address your needs through itself and its resellers and distributors. For example, if you initiate a license of a BookingUGC Service through an authorized reseller, you authorize BookingUGC and that reseller to exchange information you provide during the license and registration process. We allow authorized resellers and distributors to access the portion of Your Information that is associated with the licenses that they sold.

Analytics and Advertising Partners

We may share your Personal Information with analytics or advertising partners to measure performance of our Services or marketing efforts, offer enhanced features, or deliver interest-based advertising. This sharing may involve the use of browser cookies and similar technologies placed through our Service by our partners, as explained in this privacy policy. For example, when you visit our Site, our partner’s Cookie may cause your browser to automatically send a request to our partner’s server and provide our partner with your IP address, other online identifiers, device information and internet activity.

Customer Agreements

We will share your Personal Information as may be required by an applicable Customer Agreement.

Corporate Affiliates

We may share your Personal Information with our corporate affiliates, our parent corporation and our subsidiaries pursuant to data processing agreements or other appropriate safeguards where required.

Corporate Changes

We may share your Personal Information if we engage in a merger, acquisition, bankruptcy, dissolution, reorganization, sale of assets or stock, financing, public offering of securities, or similar transactions.

Protection of rights and Compliance with Laws We will release your Personal Information if we believe that such action is necessary to: (1) comply with the law, legal process, litigation requests or requests from governmental authorities (worldwide), (2) enforce our terms and conditions, including any applicable terms of use, user agreements, license agreements or Customer Agreements, and (3) protect the rights, property, or personal safety of BookingUGC, its employees, and other Service users.

7. Control Of Your Personal Information

Access

BookingUGC Account. By signing into your BookingUGC user account, navigating to the Preferences section, and editing Your Information

BookingUGC University Accounts. By signing into your user account, navigating to the My Profile section, and editing Your Information; or by contacting us at training@BookingUGC.com.

Licensing and Purchase Information. You can correct and update licensing information by emailing us at registration@BookingUGC.com.

BookingUGC Developer Network. By signing into your BBDN user account, navigating to the Preferences section, and editing Your Information.

Opt-Out

Marketing Emails: If you no longer wish to receive marketing emails from or on behalf of BookingUGC, you can opt-out of receiving such communications at any time by clicking on the “unsubscribe” link at the bottom of each email we send. Also in the email footer, you will find an option to Manage Subscriptions if you’d like to adjust your subscription preferences.

Product and Service Emails: If you no longer wish to receive emails concerning the products and service you have licensed and/or purchased from us, you can opt-out of receiving such information at any time by contacting us at registration@BookingUGC.com. If one of our Service users invites you to collaborate with them as part of their use of the Services, we cannot prevent you from receiving those user initiated emails. Further, certain transactional emails concerning your purchase, license or use of our Services cannot be unsubscribed.

Regular Mail/Telephone/In-Person: If you no longer wish to be contacted by BookingUGC via regular mail, telephone or in-person sales calls, you can opt-out by emailing us at registration@BookingUGC.com.

Partners: To opt-out of receiving communications from our partners, you must contact the partner directly.

Cookies: You can opt-out or change your cookie preferences online here.

When you opt-out or close your user account, we may retain a copy of Your Information for archival purposes and to avoid identity theft or fraud.

8. Third Party Direct Marketing We do not share Personal Information with third parties for their direct marketing purposes.

9. Links to Third Party Websites, Products and Services Our Services may include links to third party websites, product or services or use or offer products or services from third parties. Information collected by third parties is governed by their privacy policies and practices. We recommend you read and become familiar with the privacy policies of all parties with which you interact.

10. Children’s Privacy Our Services are not directed to children (individuals under the age of 18). We do not knowingly collect, maintain, or process children’s Personal Information unless the child’s parent or guardian consents and provides the information. If we determine that we have received a child’s Personal Information from a source other than the child’s consenting parent/guardian, we will immediately delete the information.

11. Chat Rooms and Forums We may from time to time provide chat sessions and rooms, forums, beta testing feedback services, message boards and/or bulletin boards (a “forum”) for users to exchange information. Please remember that any information disclosed in these areas may be viewed by other users of the forums or the general public depending on how access to the forums are established. If you post in a forum, please use care not to disclose any confidential or personal information. BookingUGC is not responsible or liable for the uses that others may make of any information you post in a forum.

12. Security We use industry standard physical, technical and administrative security measures and safeguards to protect the confidentiality and integrity of Your Information. When Your Information is stored by BookingUGC, we use computer systems with limited access housed in facilities using physical security measures. Cloud data is stored in encrypted form including when we utilize third-party storage. All of our cloud services leverage Transfer Layer Security (TLS) to encrypt and protect information during transit.

It is your responsibility to protect the security of your login information. Please note that e-mails and other communications you send to us are not encrypted. We strongly advise you not to communicate any confidential information through these means.

13. California Residents

This statement makes additional disclosures to California residents (i.e., “consumers”), and describes rights they have, under the California Consumer Privacy Act of 2018, as amended (the “CCPA”). This statement primarily covers users of our Services and other traditional consumers. If you apply for a job with us please see our Privacy Notice to California Job Applicants. If you work for us, please see our Privacy Policy to California Employees.

You can learn more about the CCPA here: https://oag.ca.gov/privacy/ccpa

Collection Of Personal Information

The CCPA requires a description of Personal Information collected using certain categories. The categories of Personal Information we have collected about consumers in the past 12 months are listed below. For each category, we have collected one or more of the examples listed:

Category Examples Identifiers real name, signature, alias, address, telephone number, email address, Internet Protocol address, device identifier, browser cookies, web beacon, pixel tag, mobile ad identifier, other unique personal identifier, online identifier, account name, Social Security number, driver’s license or state ID number, passport number, insurance policy number, physical characteristics or description, or other similar identifiers. Financial Information bank account number, credit card number, debit card number, or any other financial information. Protected Classification Information age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). Commercial Information records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. Internet Activity. browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. Geolocation Data Physical location or movements Sensory Data Audio, electronic, visual, thermal, olfactory, or similar information. Professional or Employment-Related Information Current or past job history or performance evaluations. Inferences Drawn From Other Personal Information Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. Sensitive Personal Information Information that reveals precise geolocation (accurate to within 1,850 feet) Sale Or Disclosure Of Personal Information

Under the CCPA, you can request to opt-out of the “Sale” of your Personal Information – which the CCPA defines very broadly to include some transactions or arrangements that do not involve the exchange of data for money – and “Sharing” of your personal information, which the CCPA defines as sharing with third parties for purposes of cross-site targeted advertising. We do not sell consumers’ Personal Information in any traditional sense, but we do share it with some of our digital partners for cross-site behavioral advertising purposes, and that sharing may be considered a Sale or Sharing of Personal Information under CCPA. You can opt-out of this sharing at any time by selecting the “Do Not Sell My Personal Information” option available here. Within the past 12 months, we Sold or Shared the following categories of Personal Information (to the categories of recipients listed):

Identifiers (to Analytics and Advertising Partners) Internet Activity (to Analytics and Advertising Partners) We do not knowingly Sell or Share the Personal Information of children under the age of 16.

Within the past 12 months, BookingUGC has disclosed the following categories of Personal Information for a business purpose (to the categories of recipients listed):

Identifiers (to Service Providers) Financial Information (to Service Providers) Commercial Information (to Service Providers) Internet Activity (to Service Providers) Your Rights As a Californian

California residents have the right to make the following requests to covered businesses. The requests may be made by a consumer, by a consumer on behalf of the consumer’s minor child, or by a person authorized by the consumer to act on the consumer’s behalf. Right To Request Information About Collection, Disclosure, Sale or Sharing You have the right to request that a business disclose to you: (i) the categories and specific pieces of Personal Information the business has collected about you within the past 12 months, (ii) the categories of sources from which the Personal Information is collected, (iii) the business or commercial purposes for collecting, Selling or Sharing Personal Information, and (iv) the categories of third parties with whom the business shares Personal Information. If a business Sells or Shares Personal Information, or discloses it for a business purpose, you also have the right to request that the business disclose the following with respect to the 12-month period preceding your request: (i) the categories of Personal Information that the business Sold or Shared about you and the categories of third parties to whom the Personal Information was Sold or Shared, and (ii) the categories of Personal Information that the business disclosed about you for a business purpose. This type of request may be referred to as a “Request to Know.” Before we can honor a Request to Know, we need to verify that the person making it is the consumer whose Personal Information we have. Our method for verifying any particular request weighs information we receive as part of the request, the sensitivity of the consumer information at issue, and the risk of harm to the consumer from unauthorized disclosure. Right to Request Deletion You have the right to request that a business delete any Personal Information that the business has collected from you. This type of request may be referred to as a “Request to Delete.” Before we can honor a Request to Delete, we need to verify that the person making the request is the consumer whose Personal Information we have. Our method for verifying any particular request weighs information we receive as part of the request, the sensitivity of the consumer information at issue, and the risk of harm to the consumer from unauthorized deletion. We are not required to delete Personal Information if we still need it in order to complete the transaction for which the information was collected, provide a good or service requested by you (or that we reasonably anticipate based on our relationship with you), perform a contract with you, comply with a legal obligation, or accomplish any other objective recognized as an exception to the right to deletion under applicable law. Right to Request Correction You have the right to request that we correct inaccurate Personal Information about you. This type of request may be referred to as a “Request to Correct”. By visiting your account settings, you can correct and change certain Personal Information associated with your account. Right to Opt-Out You have the right to direct a business that Sells or Shares Personal Information about you to third parties not to Sell or Share your Personal Information. This type of request may be referred to as a “Request to Opt-Out.” Right to Limit Use and Disclosure of Sensitive Personal Information If a business collects Sensitive Personal Information* for the purpose of inferring characteristics about you, you have the right to request that the business limit its use and disclosure of your Sensitive Personal Information to that use and disclosure which is necessary to perform the services or provide the goods reasonably expected by an average consumer who requests such goods and services. (BookingUGC does not collect Sensitive Personal Information for the purpose of inferring characteristics about you within the meaning of the CCPA.) *Under the CCPA, Sensitive Personal Information includes social security number; driver’s license or state identification number; complete account log-in credentials; precise geolocation; racial or ethnic origin, religious or philosophical beliefs, or union membership; the contents of a consumer’s mail, email and text messages (unless the business is the intended recipient of the communication); genetic data; biometric information; health information; and information concerning sex life or sexual orientation. Right to Non-Discrimination You have the right not to receive discriminatory treatment by a business for the exercise of your privacy rights under the CCPA. How to Submit a Request To Know, Delete or Correct You can submit a Request to Know or Delete to privacypolicy@BookingUGC.com, or by phone at 1-866-496-2140. Requests must state “CCPA Request” and include:

your first and last name; an email address at which you can be reached for purposes of the request; the California county in which you reside; for a Request to Know, the disclosure(s) you are requesting; for a Request to Delete, a clear statement that you want us to delete your Personal Information; and the reason(s) you believe we have collected, disclosed or sold your Personal Information, specifically, within the past 12 months (for example, you purchased a product or received a communication from us) If you are submitting a request on behalf of another consumer as their authorized representative, you must include the foregoing information about the consumer and attach a copy of a power of attorney appointing you as a duly authorized representative under California Probate Code sections 4000 to 4465 or written permission from the consumer to make the request.

After confirming receipt of your request, we’ll contact you if we need more information in order to verify it. If we can’t verify a request, we may deny it.

How to Submit a Request To Opt-Out

You may request that we stop Selling or Sharing your Personal Information by clicking “Change your consent” then selecting the “Do Not Sell or Share My Personal Information” option

14. Virginia Residents

Your Rights Under The CDPA

Virginia residents who interact with a business in a consumer context (as opposed to a business-to-business or employment context) have certain rights under Virginia’s Consumer Data Protection Act (“CDPA”), including:

To confirm whether or not a business is processing the consumer’s Personal Information and to access such Personal Information; To correct inaccuracies in the consumer’s Personal Information; To delete Personal Information provided by or obtained about the consumer; To obtain a copy of the consumer’s Personal Information that the consumer previously provided to the business in a portable, and to the extent technically feasible, readily usable format that allows the consumer to transmit the data to another business without hindrance (if the data is processed by automated means) To opt out of the processing Personal Information for purposes of (i) targeted advertising, (ii) the sale of Personal Information, or (iii) profiling in furtherance of decisions that produce legally or similarly significant effects concerning the consumer.

How To Exercise Your Rights Or Appeal A Decision

To exercise one or more rights under CDPA, please submit a request to privacypolicy@BookingUGC.com. The request must state “Virginia Privacy Request” and include:

your first and last name; an email address at which you can be reached for purposes of the request; the Virginia county in which you reside; and A description of the CDPA rights you are exercising. The reason(s) you believe BookingUGC has obtained your Personal Information

After confirming receipt of your request, we’ll contact you if we need more information in order to verify it. If we can’t verify a request, we may deny it.

If we decline to act on your request, you have a right to appeal. To submit an appeal, please contact us at privacypolicy@BookingUGC.com.

How To Opt-Out Of Targeted Ads On Our Services

To opt-out of targeted advertising on our Services, please click here.

The CDPA defines a “sale” of Personal Information as the exchange of Personal Information for monetary consideration. BookingUGC does not exchange Personal Information for monetary consideration.

15. Users in the EEA, United Kingdom or Switzerland

Data Controller and Data Protection Officer

Personal Information that we collect regarding individuals who reside in a member state of the European Economic Area (“EEA”), the United Kingdom or Switzerland is controlled by BookingUGC, a Delaware corporation, which is headquartered in Pasadena, California, U.S.A.

BookingUGC’s Data Protection Officer is:

intersoft consulting services AG Bernhard-Wicki-Straße 7 D-80636 Munich, Germany

Reachable by e-mail via: AWeskamp@intersoft-consulting.de

Lawful bases for processing

We may process your Personal Information for the purposes described above if at least one of the following grounds for processing applies:

Processing is necessary for us to perform a contract with you or to take steps at your request prior to entering into a contract; Processing is necessary to comply with our legal obligations; Processing fulfills our legitimate interests in a manner that does not outweigh your rights and freedoms. Our legitimate interests include: protecting our Services against malicious intrusions and unauthorized use; maintaining and improving our Services; understanding how our Services are used; personalizing our Services; promoting our Services effectively; and complying with legal obligations and protecting our legal rights. Processing is necessary to protect the vital interests of you or another individual You have consented to the processing International transfers

BookingUGC has its headquarters in the United States. The United States has not sought nor received a finding of “adequacy” from the European Commission under Article 45 of the GDPR. To the extent we make transfers of Personal Information to third parties in the United States or other countries that have not received an adequacy finding, we rely on a variety of legal mechanisms including the European Commission-approved Standard Contractual Clauses and the EU-U.S. Data Privacy Framework. To access our standard data processing addendum which includes the Standard Contractual Clauses, click here.

Automated decision making

We do not make any decisions involving the use of algorithms or profiling that significantly affects you.

EU-US Data Privacy Framework Disclosures

BookingUGC complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. BookingUGC has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union and the United Kingdom in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF. BookingUGC has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the DPF, or to review our certification on the DPF list, visit the DPF website.

Enforcement

BookingUGC’s compliance with the DPF is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission. In accordance with the DPF, BookingUGC is also liable for onward transfers to third parties that process personal information in a way that does not follow the DPF unless BookingUGC was not responsible for the event giving rise to any alleged damage.

Questions and disputes

In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, BookingUGC commits to resolve DPF Principles-related complaints about our collection and use of your personal information. EU and UK individuals and Swiss individuals with inquiries or complaints regarding our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF should first contact BookingUGC at privacypolicy@blubeam.com. If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, you can resolve any applicable disputes with us related to our certification free of charge through JAMS, an alternative dispute resolution provider based in the United States. You can contact JAMS to file a DPF complaint through their website. In some situations, the DPF Framework gives you the right to invoke binding arbitration. You can do this to resolve complaints not resolved by other means, as described in Annex I to the DPF Framework.

European users If the respective legal requirements are met, you are entitled to the following rights based on the General Data Protection Regulation with regard to the processing of Your Information.

You can assert the individual rights directly to BookingUGC. For this purpose, a simple and informal contact (for example, by e-mail or mail) is sufficient. See the Contact Us section below.

Right to access, Art. 15 GDPR. You have the right to request confirmation from us as to whether personal data relating to you is being processed. If this is the case, you also have the right to receive information about the data processing and a copy of the processed data. Right to rectification, Art. 16 GDPR. You have the right to request the correction of incorrect data or the completion of incomplete data. Right to erasure, Art. 17 GDPR. Under the conditions of Art. 17 GDPR, you may request the deletion of Your Information. Your right to erasure depends, among other things, on whether the erasure is not subject to any legal or contractual retention periods or other legal rights or obligations for us to continue storing the data. Right to restriction of processing, Art. 18 GDPR. You have the right to request the restriction of data processing. Right to object, Art. 21 GDPR. You have the right to object to the processing of Your Information at any time. This is the case if we base the processing of Your Information on our legitimate interests pursuant to Art. 6 (1) lit. f GDPR as well as in the case of direct marketing to customers. The objection is informal and possible towards the responsible person and/or the data protection officer(s). Right of withdrawal, Art. 7 (3) GDPR. You have the right to revoke consent to the processing of Your at any time. The processing of Your Information until the time of revocation of your consent remains unaffected. The revocation of consent is informal and possible vis-à-vis the data controller and/or the data protection officer(s). Right to data portability, Art. 20 GDPR. You have the right to receive Your Information in a structured, common and machine-readable format and to request the transfer of this data to another controller. Right to lodge a complaint, Art. 77 GDPR. You have the right to lodge a complaint with a European Union supervisory authority if you believe that data processing by us violates your rights and/or infringes the GDPR. The supervisory authority responsible for BookingUGC GmbH is the Bavarian State Office for Data Protection Supervision (BayLDA). Promenade 18

91522 Ansbach

https://www.lda.bayern.de/de/kontakt.html

However, you may also contact any other data protection supervisory authority.

16. Changes To This Policy We may modify or update this Privacy Policy from time to time. When we change this Privacy Policy in a material way, a notice will be posted on our website (www.BookingUGC.com) along with the updated Privacy Policy. If you use our Services after an update has been made to this Privacy Policy, you consent to the changed Policy.

17. Contact Us If you have any questions concerning this policy please send an email to us at privacypolicy@BookingUGC.com