Effective Date: January 26, 2023

Last Updated: July 13, 2023

This privacy policy (this “Policy”) describes how Allvue Systems, LLC (“Allvue,” “we,” “us,” “our”) collects, handles, secures, shares and uses the personal information you provide to Allvue offline or through any of Allvue’s website(s) where this Policy is posted (each, a “Website”). It also describes your choices regarding use, access, and correction of your personal information. For purposes of this privacy policy, personal information is information that can be used to identify an individual.

For our California Privacy Notice, please click here.

SCOPE

This Policy does not describe the treatment of data (including personal information) used, processed or collected in connection with the use of Allvue’s software products or services or personal information in connection with employment opportunities with Allvue. This Policy also does not apply to situations where Allvue may process your personal information on behalf of our customers. For more information on our customers’ privacy practices, please review their privacy policies.

This Policy does not address Allvue’s collection, use or disclosure of personal information collected in the employment context.

INFORMATION THAT WE COLLECT

We may collect the following personal information you provide to Allvue offline or through our Websites:

• Identifiers: Including contact information, such as your name, physical address, email address, phone number and cell phone number.
• Professional Information: Information such as employer, title, job function and interests.
• Financial Information: Information you provide to pay for our products and services, including financial account numbers.
• Information You Submit: Information you provide in surveys, use the Website’s chat function, or when you contact us.
• Commercial Information: We may collect personal information that could identify you and relates to the services in which you are interested or have considered.
• Information Allvue collects automatically through our Websites: This may include information about your computer and Internet connection, such as the IP address of your computer and/or Internet service provider, the date and time you access the site, the Internet address of the website from which you link to our Website, the computer technology you are using and your movements and preferences on our site. For more information about cookies and how we use them, please read our cookie page.

By providing us with the above personal information, you consent to your information being collected, used, disclosed, processed and stored by us in accordance with this Policy.

You can opt out of providing personal information by not entering it when asked. If personal information is required in order to allow us to respond to your inquiry, you will receive a notice advising you of this. If you do not provide us with some or all of the requested personal information, we may not be able to provide the requested information or services to you.

HOW WE COLLECT YOUR INFORMATION

We collect your personal information in different ways, including:

• Personal information you provide to us offline. For example, we collect information you may provide to us over the phone, at in-person events or when otherwise communicating with us offline.
• Personal information you provide to us through our Websites. When you request information, a free demo, schedule a consultation, respond to an online survey or otherwise contact us, you are providing us with personal information which we collect.
• Personal information collected through third-party sources. Although not obtained through our Websites, we also obtain personal information about you from third party sources as permitted by applicable law, such as:
  • information collected by our marketing service providers on our behalf, which are a variety of marketing lead generation and content syndication service providers, marketing opt-out lists and/or professional event organizers;
  • information shared with us by our business partners as part of their referral activities; and
  • public databases or other data you may have made publicly available, such as social media posts on professional networks and social media platforms.
• We may collect information when you visit and navigate our Websites on any device. We may also collect information about users over time and across different websites and devices when you use the Websites.
• By Combining Information. For example, we may combine information that we collect offline with information we collect through our Websites. We may also combine information we collect about you from the different devices you use to access our Websites.

HOW WE USE PERSONAL INFORMATION

Allvue will use your personal information for the following purposes:

• To respond to your specific inquiry or request and to provide you with information and access to resources that you have requested from us.
• To administer, protect, operate and maintain our Websites and our systems.
• To improve the navigation and content of our Websites, system administration and security.
• To compile aggregated statistics about the usage of our Websites and to better understand the preferences of visitors to our Websites.
• To help personalize your experience on our Websites (for example, we may use IP addresses to identify your professional organization or approximate your general location such as city and state for purposes such as to provide information on local promotions and events).
• To carry out marketing efforts, such as contacting you to further discuss your interest in our company, the products and services we provide and the ways we can improve them and to provide information on such products and services, promotions and events.
• To send information about your account, technical alerts or updates and other administrative or service-related communications.
• To carry out analytics, research and development activities to improve our services or products.
• To ensure legal compliance, such as responding to a subpoena or court order.
• To carry out other legitimate business purposes, as well as other lawful purposes about which we will notify our users and customers as required by applicable law.
• For other purposes at your request or direction.

DATA TRANSFERS TO THIRD PARTIES

Allvue may share your personal information with third parties as described in this Policy. We rely on service providers to perform a variety of services on our behalf. In so doing, we may need to share your personal information with them.

We may share your business contact information with our business partners with whom we have a strategic partnership, such as resellers or providers of implementation services, or our investors.

Your information may also be transferred to another company in connection with a corporate transaction, such as a divestiture, merger, acquisition, consolidation or asset sale (or the negotiation thereof) of a substantial amount or all of the assets of Allvue, or in the unlikely event of bankruptcy. We may assign or transfer your information as part of the transaction.

We may also share your personal information: (i) as required by law, (ii) in response to lawful requests by public authorities, including to meet national security or law enforcement requirements, or (iii) when we believe that disclosure is necessary to comply with a judicial proceeding, court order or legal process, (iv) to respond to any other government-related request, (v) to protect our rights and interests (including without limitation, for our own safety), (vi) to protect your interests (including without limitation, for your safety), (vii) to protect the interests of others (including without limitation, for their safety) or (viii) to investigate alleged or actual fraud, misrepresentation or other misconduct.

We will also share your personal information as requested or directed by you.

 LINKS TO OTHER SITES AND SOCIAL MEDIA

Our Website includes links to other websites and Social Media whose privacy practices may differ from those of our Website. If you submit personal information to any of those other websites, your information is governed by their specific privacy policies. We encourage you to carefully read the privacy policy of any website that you visit.

 SECURITY

Allvue maintains physical, technical, administrative and organizational security measures designed to protect personal information from loss, misuse and unauthorized access, disclosure, alteration and destruction, including where appropriate:

• the pseudonymisation and encryption of personal information.
• the ability to ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and services.
• the ability to restore the availability and access to personal information in a timely manner in the event of a physical or technical incident.
• a process for regularly testing, assessing and evaluating the effectiveness of technical and organizational measures for ensuring the security of the processing.

All our employees, contractors and data processors who have access to, and are associated with, the processing of your personal information are obligated to keep the information confidential and not use it for any other purpose than to carry out the services they are performing for us.

However, even with these security controls in place, the Internet is not 100% secure. We cannot promise that your use of our Website will be completely safe. We encourage you to use caution when using the Internet.

RETENTION

Allvue will retain your information for so long as we have an ongoing legitimate business interest, including for as long as your account is active, or you have not unsubscribed or otherwise contacted us directly to remove your information from our database, or as necessary for the following purposes:

• If there is a legal obligation (or change to a legal obligation) applicable to Allvue (for example, certain laws require Allvue to keep records of transactions for a certain period before Allvue can delete them); and
• If retention is advisable based on legal opinion (such as, for statutes of limitations, litigation or regulatory investigations).

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

CHOICES REGARDING YOUR PERSONAL INFORMATION

Marketing Communications: If you wish to subscribe to our newsletter(s), we will use your name and the email address provided to send the newsletter to you. If you wish to no longer receive these emails, you can also unsubscribe from our marketing communications by following the unsubscribe mechanism in the applicable e-mail message. Please note that if you do opt out of receiving marketing-related emails from Allvue, we may still send you important administrative messages, and you cannot opt out from receiving account-related or other administrative messages.

Cookies and Other Tracking Technologies: For more information about our use of cookies on the Website, please review our Cookie Statement. Note that some browsers have “do not track” features that allow you to tell a website not to track you. These features are not all uniform. We do not currently respond to those signals.  If you block cookies, certain features on our sites may not work.  If you block or reject cookies, not all of the tracking described here will stop. Your selections are device-, website- and browser-specific and may be deleted when you clear your browser’s cache or when you clear cookies.

CALIFORNIA PRIVACY NOTICE

The California Consumer Privacy Act (“CCPA”), as amended by the California Privacy Rights Act (“CPRA”), requires us to make specific disclosures about how we collect, use and disclose the personal information of California residents who are subject to CCPA (we call this specific personal information “PI” in this section). CCPA also grants California residents certain rights related to their PI. This section describes our PI practices offline and online and contains these required disclosures and instructions for California residents who wish to exercise their rights under CCPA. Please note that, to the extent permitted under CCPA, this California Privacy Notice does not apply to the PI of California residents that we collect for employment-related purposes.

CCPA contains specific definitions for “sharing” PI and “selling” PI. These definitions only apply to this California Privacy Notice, and do not apply to the rest of our Policy. “Share” or “sharing” means, in short, sharing PI for cross-contextual advertising purposes. “Sale” or “selling” is defined very broadly and includes the disclosure of PI for monetary or valuable consideration. You will find an overview of our “sale” or “sharing” practices below. This statement is based on our understanding of how these terms are defined under CCPA.

We are required under CCPA to tell you which categories of PI we collect, and which of these categories we disclose for “business purposes” or “commercial purposes,” or for “sale” or “sharing” purposes as these terms are defined under CCPA.

• For information about our PI retention criteria, please see the “RETENTION” section of the Policy.

California resident rights under CCPA. Subject to certain exclusions included in CCPA, and as relevant to our operations, California residents have the rights listed below. We may take steps to verify your identity, as permitted or required under CCPA, before we process your request. Verification may include asking you to provide information about yourself that we can match it against information already in our possession.

• Notice. This means that you can request that we disclose the categories of personal information we have collected about you; the categories of sources from which such personal information is collected; the categories of personal information we have “sold” or disclosed for a business purpose; the categories of third parties to whom the personal information was “sold” or disclosed for a business purpose; and the specific pieces of personal information we have collected about you in the last 12 months.
• Deletion. This means that you can request that we delete personal information about you which we have collected from you.
• Correction. This means that you can request that we correct inaccurate personal information that we maintain about you.
• Limit the Use or Disclosure of Sensitive Personal Information. The CCPA provides a right for consumers to request that business limit the use or disclosure of their “sensitive” personal information. In our normal course of operations as a “business,” we do not process “sensitive personal information,” as these terms are defined under CCPA. Please do not submit this information to us.
• Opt Out of Sale or Sharing of Personal Information. CCPA provides a right to opt out of the “sale” or “sharing” of personal information, as those terms are defined in CCPA. Please note that, in order to fully opt out of the “sharing” of your personal information, you will need to both send an email request and take steps to set your cookie preferences on your browser. You can find instructions to do so here: allaboutcookies.org/manage-cookies. Your selections are device-, website- and browser-specific and may be deleted when you clear your browser’s cache or when you otherwise clear cookies.
• Equal prices and services. This means that we are prohibited from discriminating against you if you exercise your rights under CCPA.

If you would like to exercise your rights under the CCPA, please contact us at [email protected].

Agents. Agents that you have authorized to act on your behalf may also submit CCPA requests as instructed above. The agents must also provide evidence that they have your written permission to submit a request on your behalf. If we are unable to verify the authenticity of a request, we may ask you for more information or may deny the request.

GENERAL DATA REQUESTS

Allvue acknowledges that you have the right to access your personal information. If your personally identifiable information changes, or if you no longer desire our service, you may choose to correct, update, delete/deactivate or access it by emailing us directly at [email protected]. We will respond to your request within a reasonable timeframe, not to exceed forty-five (45) days or as otherwise required by applicable law.

CHILDREN UNDER 13

The Website where this Policy is located is meant for adults. We do not knowingly collect personally identifiable data from persons under the age of 13, and strive to comply with the provisions of The Children’s Online Privacy Protection Act (COPPA). If you are a parent or legal guardian and think your child under 13 has provided us with information, please contact us at [email protected]. You can also write to us at the address listed at the end of this website Policy. Please mark your inquiries, “COPPA Information Request.”

DISPUTE RESOLUTION

Allvue commits to resolve complaints regarding processing, use and disclosure of Personal Information in accordance with this Policy. Individuals with inquiries or complaints regarding Allvue’s compliance with this Policy should first contact Allvue at [email protected]. Allvue will investigate and attempt to resolve all complaints and disputes.

In certain circumstances, you may have the ability to invoke binding arbitration to address any complaint that Allvue has violated its obligations under this Policy to you and has not been otherwise resolved such violation.

EU PRIVACY RIGHTS
If you are an EU resident, you may be able to assert a legal right regarding our collection, use and disclosure of your personal information under applicable law. Under these applicable laws, you may have a number of rights, including:

• The right not to provide your personal information to us;
• The right to object to, stop or limit the processing of your personal information;
• The right to request the erasure or restriction of processing of your personal information in our possession;
• The right to have your information transferred to another data controller;
• The right to withdraw your consent;
• The right to access to your information and request from us a description, or a copy, of the types of personal information we have stored about you; and
• The right to request an update or rectification of your personal information.

To exercise any of these rights, or to request more information, contact us at [email protected].

Please note that the disclosure of your personal information can be transferred to non-EU member states (for example, the United States and United Kingdom). The laws in those countries may not provide the same level of protection for personal information as the laws in the country where the personal information was originally collected.

You also have the right to lodge a complaint with a supervisory authority, in particular in the state of your habitual residence, place of work or of an alleged infringement of the GDPR.

 HOW TO CONTACT US

If you have any questions regarding this Policy or if you need to request access to or update, change or erase your personal information that Allvue processes on your behalf, you can do so by contacting Allvue’s Systems Privacy Team at:

396 Alhambra Cir | Suite 1100 | Coral Gables | FL 33134

Main: +1.305.901.7060

Email: [email protected]

AMENDMENTS

Allvue reserves the right to change, modify, add or remove portions of this Policy from time to time and in its sole discretion but will update the public that changes have been made by indicating on this Policy the date it was last updated.