Effective: June 18, 2020

The ShareBase by Hyland Privacy Policy (“Policy”) describes how Hyland Software, Inc. and its affiliates (“Hyland”, “we” or “us”) collect, use, and share the personal information we obtain when you use the ShareBase Web Application, ShareBase Mobile Application, or ShareBase Desktop (collectively referred to as “ShareBase”). This Policy also describes your choices regarding our use of your information, the ways in which we safeguard such information, and how you may contact us regarding our privacy practices. In addition, this Policy includes information about our use of cookies.

This Policy does not apply to your use of other Hyland services, including Hyland websites, web-based products, or other mobile applications. Please refer to the applicable terms of use, privacy policy, or subscription for information regarding the terms and conditions applicable to your use of those products. This policy also does not apply to the content that you upload, store or process using ShareBase (“Customer Content”). Customer Content is processed by Hyland pursuant to the ShareBase by Hyland Terms of Use and Subscription Agreement entered into between Hyland and the company or legal entity that licenses ShareBase (“Customer”).

ShareBase is directed to business users and not to individual consumers seeking products or services for personal or household use. If you are an individual consumer seeking products or services for personal or household use, you are not authorized to use Sharebase.

Hyland Software, Inc. and its affiliate entities are responsible for processing your personal information as described in this Policy. Contact information for each Hyland company is available here.

This policy contains the following sections:

Information We Collect
How We Use Your Information
How We Share Your Information
Security
Your Choice Regarding Your Personal Information
Your Choice Regarding Promotional E-mail
Information Specific to Users Located Outside the United States
Cookies
Children's Privacy
California Privacy Rights
English Language Controls
Changes to this Policy
Contact Us

Information You Provide To Us. We collect information you provided directly to us. For example, we collect information from you when you register, download or sign-in to ShareBase. The types of information we collect may include individually identifiable information (“Personal Information”), such as your name, user name, and password and any other information submitted when you create or modify a user profile.

Information Third Parties Provide About You. Hyland licenses ShareBase to Customers. If you have been authorized by a ShareBase Customer to access or use ShareBase, then that Customer may have provided us with your name, user name, e-mail address or other information necessary for us to create or authenticate an account on your behalf.

Information We Collect Automatically. In addition to the information you submit to us, we and our service providers automatically collect certain information about your use of ShareBase. This information may include Personal Information, such as unique device identifiers, dynamic and static Internet Protocol (“IP”) addresses, as well as other information, such as browser characteristics, language preferences, operating system details, referring URLs, length of visits, and pages viewed. Additionally, in connection with the ShareBase Web Application we may also use cookies, web beacons, embedded scripts, web server logs, or other similar technologies to collect details about the services and devices you use to access ShareBase. Please see the Cookies section below for more information.

Third Party Analytics. ShareBase uses third-party web analytics services, including Google Analytics, to help us analyze how users use ShareBase. These services track information about users, including, IP address, the timing of files uploaded, downloaded, shared, or accessed, and features utilized by you. We use this information to improve our products and services and to customize or enhance your experience when using ShareBase. Where, according to local law, IP addresses and similar identifiers are considered Personal Information, then we treat them as such. To learn more about how Google may use information collected through ShareBase, click here. If you are accessing ShareBase via a mobile device, you can opt out of Google Analytics from an android or iOS device, follow these instructions: (1) open the menu located in the upper left corner of the ShareBase Mobile Application; and (2) move the toggle switch next to “Share Usage Analytics” to “off.” If you are accessing ShareBase via the ShareBase Web Application, you can opt out of Google Analytics by following these instruction: (1) Click the User Menu icon in the menu bar; and (2) Click My Account; and (3) Under Privacy & Security, click Allow usage statistics to be gathered on this device to toggle the setting on or off.

We may link individually identifiable information that you provide voluntarily (e.g., your name and contact information) to the information that ShareBase collect automatically (e.g., data analytics).

Do Not Track Setting. In connection with your use of the ShareBase Web Application, we track your online activities over time and across third party websites or online services. We also track your activities while the ShareBase Web Application. You may implement restrictions on tracking, such as plug-ins or browser settings. In that case, some features of ShareBase, for example, personalization or authentication, may not work as designed.

Your web browser may have settings that allows you to transmit a “Do Not Track” signal when you visit various websites or use online services. Like many websites, the ShareBase Web Application is not designed to respond to “Do Not Track” signals received from browsers. To learn more about “Do Not Track” signals, click here.

The ShareBase Mobile Application is not designed to respond to “Do Not Track” signals. However, the ShareBase Mobile Application does not track users over time or across different websites or online services nor do third parties use the ShareBase Mobile Application track users over time or across different websites or online services.

We may use the information, including Personal Information, we obtain through ShareBase for a number of purposes, including:

1. To improve ShareBase and our other products;
2. To continuously evaluate and improve user experience;
3. To respond to emails or other requests, comments, or questions
4. To provide customer support;
5. To provide you or our Customer with information that we believe may be useful, such as information about products or services we offer;
6. To comply with applicable laws, regulations, or legal process as well as industry standards and our company policies;
7. To prevent fraud or other misuse, including to protect our rights and the rights of affiliated companies or related third parties;
8. To report suspected criminal acts;
9. To maintain records of our transactions and communications; or
10. To monitor and analyze trends, usage, and activities of ShareBase users.

We may use the Personal Information we obtain about you in other ways for which we provide notice at the time of collection. In addition, we may use aggregated information about ShareBase users and information that does not identity an individual ShareBase user in additional ways, without further notice.

We may share aggregated information about our users and information that does not identify any individual user, without restriction. We may also share your Personal Information with:

1. Hyland Affiliates. As an international organization, Personal Information about you may be shared globally throughout Hyland’s international organization. A list of Hyland entities and their contact information is available here. Personal Data may be shared with affiliated companies for any of the purposes set forth in the section above titled "How We Use Your Information."
2. Third Party Service Providers Under Contract with Hyland. For example, data analytics providers, data center providers, website management, law firms, auditors, performance service providers, and other similar providers. We share your Personal Information with these Service Providers so that they can perform certain business functions on Hyland’s behalf.
3. Third Party Solution Providers under contract with Hyland. To allow third parties that resell Hyland products and services (“Solution Provider”) to provide customer support and analyze trends, usage, and activities related to ShareBase users affiliated with that Solution Provider’s customers.
4. Other Unaffiliated Third Parties. We may also share your Personal Information with other unaffiliated third parties for the following purposes:
1. Required Disclosures. To comply with a court proceeding, in response to a court order, subpoena, civil discovery request, other legal process, or as otherwise required by law.
2. Government Agencies. To response to a request by a government agency.
3. Legal Compliance and Protections. To comply with the law or to protect the rights, property, or safety of Hyland, our users, or others. This may include sharing information, including Personal Information, with other companies and organizations for fraud protection and credit risk reduction.
4. Corporate Transactions. To disclose and transfer your data, including your Personal Information, if applicable:
1. To a subsequent owner, co-owner, or operator of ShareBase or successor database.
2. In connection with a corporate merger, consolidation, bankruptcy, the sale of substantially all of our membership interests and/or assets or other corporate change, including to any prospective purchasers.

We do not rent, lease, or sell your Personal Information to third parties.

We maintain appropriate physical, electronic, and administrative safeguards designed to protect the information, including the Personal Information, which we obtain in accordance with this Policy. Although we use reasonable efforts to secure such information, transmission via the Internet is not completely secure, and we cannot guarantee the confidentiality of information transmitted to us over the Internet.

To exercise your right to update, correct, or delete the Personal Information collected through ShareBase that is contained within the Customer Content, you should contact the ShareBase Customer that provided you with access to ShareBase. Hyland will cooperate with its Customers in responding to these requests. To exercise your right to update, correct, delete the Personal Information collected by Hyland as described in this Policy, you may contact privacy@hyland.com.

If you are accessing ShareBase from outside the United States, please see the Information Specific to Users Located Outside the United States section below for additional information on accessing your Personal Information and other legal rights available to you under applicable law.

Your Choice Regarding Promotional email. You may unsubscribe from receiving promotional emails from us by following the instructions provided in those email communications. Please note that even if you opt out of receiving promotional communications from us, we may continue to send you non-promotional emails, such as emails concerning our ongoing business relationship with you.

Your Choices About Certain Other Data Collection Technologies. You have a number of options to control or limit how we and our service providers use cookies and other data collection technologies including for advertising:

1. To prevent your information from being used by Google Analytics:
1. you can install Google’s opt-out browser add-on: https://tools.google.com/dlpage/gaoptout.
2. from your android or iOS device, follow these instructions: (1) open the menu located in the upper left corner of the ShareBase Mobile Application,(2) selected the Settings menu; and (3) toggle switch next to “Share Usage Statistics” to “off.”
2. To opt out of interest-based advertising, you can visit http://optout.networkadvertising.org/#!/ and follow NAI’s on-screen instructions. Note that if you opt out through the NAI, you will still receive advertising, but the advertising will not be tailored to your interests. In addition, if you opt out through NAI and later delete your cookies, use a different browser, or buy a new device, you will need you opt out of interest-based advertising again.
3. Check your mobile device for settings that control ads based on your interactions with the applications on your device. For example, on your iOS device, enable the “Limit Ad Tracking” setting, and on your Android device, enable the “Opt out of Ads Personalization” setting.

ShareBase is operated by Hyland Software, Inc., which is headquartered in the United States at 28500 Clemens Rd. Westlake, Ohio 44145. The Personal Information collected by ShareBase is controlled by the Hyland entity that licensed ShareBase to the ShareBase Customer applicable to you. Contact information for each Hyland affiliated company is available here.

Data Retention. We retain your Personal Information for as long as the ShareBase Customer that provided you with access to ShareBase continues to license ShareBase and for thirty (30) days thereafter, unless a longer period is required by law or otherwise agreed upon between Hyland and the ShareBase Customer. You may request that your Personal Information be deleted as described below.

Users Located in Brazil

The following applies specifically to individuals located in Brazil. If you are located in Brazil, you have the right, subject to applicable law, to obtain the following:

1. Confirmation that Hyland processes your Personal Information;
2. Access to your Personal Information from Hyland;
3. Correction of your Personal Information if incomplete, inaccurate, or out-of-date;
4. Anonymization, blocking or deletion of unnecessary or excessive Personal Information or Personal Information processed in noncompliance with the provisions of Brazil’s data protection law;
5. Portability of your Personal Information to another service or product provider, by means of an express request and subject to commercial and industrial secrecy as long as that Personal Information has not already been anonymized at the time of your request;
6. Deletion of personal data processed with the consent of the data subject
7. Information about public and private entities with which Hyland has shared your Personal Information; and
8. Information about the possibility of denying consent and the consequences of such denial.

You have the right to revoke consent to Hyland’s processing of your Personal Information if Hyland’s processing is based on consent. Where Hyland processes your Personal Information on a basis other than consent, you may oppose the processing if the processing does not comply with Brazilian data protection law. You have the right to petition, regarding your Personal Information, against Hyland before the Brazilian national authority.

You may request to exercise your rights, or a legally constituted representative may request to exercise rights on your behalf, by contacting privacy@hyland.com. To exercise your rights related to the Persona Information collected through ShareBase you should contact the ShareBase Customer that provided you with access to ShareBase. Hyland will cooperate with its Customers in responding to these requests.

Users Located in the European Economic Areas, United Kingdom, or Switzerland (Collectively the “EEA”).

The following applies specifically to individuals located in the EEA.

Obligation to Provide Personal Information and Automated Decision-Making: You are not required by statute or by contract to provide any Personal Information. We will not use your Personal Information submitted via ShareBase for automated decision-making, including for profiling, that produces legal effects or similarly significantly affects you.

Cross-Border Data Transfers: The Personal Information collected via ShareBase may be transferred to, and processed in, countries outside of the country from which you have accessed ShareBase, including the United States, and other countries where Hyland affiliates are located as described above.

Hyland Software, Inc. and all Hyland affiliated companies have agreed to process your Personal Information in accordance with the Standard Contractual Clauses for data controllers approved by the European Commission. You can obtain a copy of the Standard Contractual Clauses by submitting a request to privacy@hyland.com.

Before transferring your Personal Information to a third party recipient located outside the EEA, Hyland will: (a) execute Standard Contractual Clauses, approved by the European Commission, to ensure an adequate level of protection for the transfer of your Personal Information to those entities outside the EU; (b) confirm that the third party has certified to the EU-U.S. Privacy Shield Framework Swiss-U.S. Privacy Shield Framework; or (c) otherwise ensure adequate protection for your Personal Information. You can obtain a copy of the relevant Standard Contractual Clauses or Privacy Shield certification by contacting privacy@hyland.com.

Legal Basis For Processing: Hyland processes your Personal Information with your consent and as required by law. Hyland also processes Personal Information as necessary for its legitimate interests as follows:

1. Business Operations: We use your Personal Information for our legitimate business purposes, including to develop new products and services, to improve existing products and services, and to personalize communications.
2. Investigations: In the event of fraud, a security incident, or a suspected criminal act, we would examine Personal Information that appeared to be linked to the incident as necessary to determine what happened, remediate, report to the authorities, and prevent a recurrence.

Right to Object to Processing for Legitimate Interests: You have the right to object to the processing of your Personal Information for purposes of Hyland’s direct marketing or other legitimate interests by contacting privacy@hyland.com.

Individual Rights: You have the right to access your Personal Information or request that it be updated, corrected, or deleted. You also have the right to restrict certain processing of your Personal Information, as provided by applicable law and the right to data portability concerning your Personal Information. To exercise your rights related to the Personal Information collected through ShareBase you should contact the ShareBase Customer that provided you with access to ShareBase. Hyland will cooperate with its Customers in responding to these requests.

If you believe that your personal data has been processed in violation of applicable data protection law, you have the right to lodge a complaint with the relevant data protection authority in the country where they reside, where they work, or where the alleged violation occurred.

EU Representative: Hyland Software, Inc.’s representative in the European Union for data protection purposes is Hyland Software UK Ltd. You can reach our representative at privacy@hyland.com.

We use cookies, and embedded scripts on the ShareBase Web Application.

Cookies: A cookie is a unique identifier that is placed and stored on a computer when it is used to visit a website. Cookies may be used for various purposes, including to track user preferences or web pages visited while using a website, to identify the number of unique visitors to a website, and to verify whether or not a visitor is a repeat visitor.

Embedded Scripts: An embedded script is programming code designed to collect information about a user’s interactions with a website. Typically, the script is temporarily downloaded onto a computer from the host website’s server (or the server of a third party service provider), and is active only while the visitor is connected to the website, then deleted or deactivated thereafter.

Cookies We Use And Why We Use Them

We may use three types of cookies on our website:

1. Essential Cookies: These are cookies that are strictly necessary for the functioning of the website or for performing services that an individual user has requested. Some examples of functions performed by essential cookies are cookies that remember previous actions (e.g., entered text) when navigating back to a page in the same session.
2. Analytical Cookies: These cookies collect information about how visitors use a website, for instance which pages visitors go to most often, and if they get error messages from web pages. These cookies don’t collect information that identifies a visitor. All information that analytical cookies collect is aggregated and therefore anonymous. These cookies are used only to improve how a website functions.
3. Functional Cookies: These cookies allow the website to remember choices users make and to provide enhanced, personalized features. For example, on our website, these cookies remember users’ language preferences.

Cookies can also be categorized by how long they remain on your device. There are two broad categories of duration:

1. Persistent Cookies: Persistent cookies remain on your device until deleted manually or automatically.
2. Session Cookies: Session cookies remain on your device until you close your browser when they are automatically deleted.

We use both persistent cookies and session cookies on the ShareBase Web Application.

Cookies can be first-party cookies, which means that we place the cookies ourselves, or third party cookies, which means that a third party places them on your device. The ShareBase Web Application use first-party cookies and occasionally use third-party cookies.

Information Collected by our Cookies and Scripts

Our cookies and scripts collect information including:

1. What web pages you visit on the ShareBase Web Application and how long you visit them;
2. Information about how you navigate, use, and interact with the ShareBase Web Application;
3. Your IP address, device identifiers and signatures, and browser type; and
4. The language you’ve chosen to read the website.

Your Right To Refuse Cookies

Many web browsers provide options to allow you to stop accepting new cookies, or to disable existing cookies. You can go to the HELP function of your browser to learn how. You can also go to https://www.cookiesandyou.com for information about how to disable and control cookies on most browsers. Please be aware that if you disable the cookies on your computer you may not be able to use certain features of the ShareBase Web Application or other websites, and disabling cookies may invalidate opt outs that rely on cookies to function. Also, these options may not be effective in all cases, or may be effective with respect to one type of browser or service, but not another.

To opt-out of targeting by many third party advertising companies, please visit the Network Advertising Initiative (NAI) at http://www.networkadvertising.org.

ShareBase is not intended for children, nor is it targeted to children under the age of eighteen (18). We do not knowingly collect Personal Information from children under the age of 18 through ShareBase, and if we learn that we have received information from a user under the age of 18, we will delete such information in accordance with applicable law.

California law permits California residents to request certain details about how their information is shared with third parties and, in some cases, affiliates for direct marketing purposes. California customers may request information about our compliance with this law by contacting us at privacy@hyland.com. Any such inquiry must include “California Privacy Rights Request” in the first line of the description and include your name, street address, city, state, and ZIP code. Please note that we are only required to respond to one request per individual each year.

Any California residents under the age of eighteen (18) who have registered to use ShareBase, and who have posted content or information to ShareBase, can request that such information be removed from ShareBase by contacting us at privacy@hyland.com, stating that they personally posted such content or information and detailing where the content or information is posted. We will make reasonable good faith efforts to remove the post from prospective public view or anonymize it so the minor cannot be individually identified. This removal process cannot ensure complete or comprehensive removal.

This Policy is executed in English and may be translated into other languages. In the event of any conflict or discrepancy between the English language and a translated version, the English language version shall control to the fullest extent permitted by applicable law.

We may change this Policy from time to time. If we make changes, we will notify you by revising the date at the top of this Policy. We encourage you to review this Policy whenever you visit ShareBase to stay informed about our information practices. This Policy was last modified on June 18, 2020. If we materially change this Policy in a way that affects how we use or disclose your Personal Information, we will provide a prominent notice and the effective date of the changes before making them.

To contact us regarding this Policy or with questions about our privacy practices, you may email us at privacy@hyland.com (please include “Privacy Inquiry” in the subject line of your email), call us at 1-877-251-9504, or send postal mail to:

Hyland Software, Inc.
Attn: SHAREBASE PRIVACY INQUIRY
Legal Department
28500 Clemens Road
Westlake OH, 44145
USA