Alia Data Privacy Framework

Alia Software, Inc. complies with the EU-U.S. Data Privacy Framework (“EU-U.S. DPF”), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework as set forth by the U.S. Department of Commerce and as applicable. This Alia Data Privacy Framework statement (“DPF Policy”) and the Privacy Policy describes the privacy practices that we implement for Personal Data received from the EEA, UK and Switzerland in reliance on the DPF.

Alia Software, Inc. 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. Alia Software, Inc. 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. Alia Software, Inc. maintains this certification as part of the Dotdigital Group’s Data Privacy Framework certification, which also covers Dotdigital, Inc., Social Snowball Holdings, Inc., and Fresh Relevance, Inc. 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 Data Privacy Framework (DPF) Program, and to view our certification, please visit: https://www.dataprivacyframework.gov/

Onward Transfers and Liability

We do not currently transfer personal data to third parties. However, in accordance with the Accountability for Onward Transfer Principle under the EU-U.S. Data Privacy Framework (DPF), we acknowledge that if we do transfer personal data to a third party acting as an agent on our behalf in the future, we will remain liable under the DPF Principles if that agent processes such personal data in a manner inconsistent with the DPF Principles, unless we can demonstrate that we are not responsible for the event giving rise to the damage.

Should any such transfers occur, we will ensure that:

• The third party provides at least the same level of privacy protection as required by the DPF Principles.
• Appropriate contractual safeguards are in place.
• Individuals are informed of such transfers in accordance with the Notice and Choice Principles.

We are committed to maintaining transparency and accountability in all data processing activities, including any future onward transfers.

Dispute Resolution

In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, Alia Software Inc 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 Alia Software Inc at: help@alialearn.com

The Federal Trade Commission has jurisdiction over Alia’s compliance 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).

In accordance with the Data Protection Framework (DPF) Principles, Alia are committed to informing you about your rights, including the possibility of invoking binding arbitration under certain circumstances. Binding Arbitration is a dispute resolution process where an impartial arbitrator reviews the case and makes a decision that is legally binding for both parties. This mechanism can be used in situations where you and our organization are unable to resolve a dispute through other means, such as our internal complaint resolution process.

Some conditions under which you may invoke binding arbitration include:

• If you have exhausted all other available dispute resolution mechanisms with our organization.
• If your complaint has not been addressed or resolved within a reasonable time frame.
• If you believe that our organization has not complied with the applicable data protection principles, and this non-compliance has caused you harm or damage.

To initiate the binding arbitration process, please follow the procedure outlined in our privacy policy or contact our designated data protection officer for more information. Please note that certain terms and restrictions may apply, as detailed in our privacy policy.

We encourage you to familiarize yourself with your rights and our dispute resolution procedures, as our organization is dedicated to ensuring the security of your personal data and maintaining a transparent relationship with you.

In compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF, Dotdigital, Alia and Social Snowball commits to refer unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF to JAMS, an alternative dispute resolution provider based in the United States. 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, please visit https://www.jamsadr.com/DPF-Dispute-Resolution for more information or to file a complaint. The services of JAMS are provided at no cost to you.

For HR data

• In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF, Dotdigital, Social Snowball, Alia and Fresh Relevance commits to cooperate and comply respectively with the advice of the panel established by the EU data protection authorities (DPAs) and the UK Information Commissioner’s Office (ICO) with regard to unresolved complaints concerning our handling of human resources data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF in the context of the employment relationship.