Bella Scena™ Privacy Policy

1. Introduction

Wonderly Software Solutions, LLC ("Wonderly", "us", "our" or "we") owns and operates the Bella Scena™ Cloud-based meeting and productivity management platform (hereafter, the Service), hosted in the United States and/or its territories. This Privacy Policy, together with the Bella Scena Terms of Use Agreement, constitute a formal Agreement between users of the Service (collectively, "you" or "your") and us. If you do not agree with the terms and conditions of this Privacy Policy, you should not access or use the Service. We advise that you print or retain a digital copy a copy of this Privacy Policy for future reference.

2. Our Commitment to Your Privacy

We recognize the importance of data privacy. We believe that privacy is amatter of trust, and we are committed to managing data lawfully, fairly, and transparently. We want you to understand the ways we collect, use, and share your Personal Data (as defined below).

This Privacy Policy describes:

• What Personal Data we collect;
• Ways we collect your Personal Data;
• Ways we use your Personal Data;
• Ways we share your Personal Data;
• Ways we retain and safeguard your Personal Data; and
• Your rights and choices about how we collect, use, and share your Personal Data.

3. Policy Scope

This Privacy Policy applies to the Service and our business operations in Minneapolis, Minnesota. This Privacy Policy applies to the Processing ofP ersonal Data about you.

The following definitions apply herein:

"Personal Data" means means information that identifies you as an individual or relates to an identifiable individual.

"Processing" means an operation or set of operations that is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

4. Conformance with Relevant Laws and Regulations

Wonderly makes good faith efforts to conform our business practices to the requirements defined in applicable laws and regulations relating to the protection of Personal Data.

5. Your Consent to Processing Personal Data

By using the Service, you consent to the Processing of your Personal Data for our legitimate business purposes. If you do not consent to such Processing of your Personal Data, you must not use the Service.

Where applicable, Wonderly may seek your explicit consent for certain collection, uses or transfers of your Personal Data.

6. Using Discretion

The Bella Scena platform enables users to add, modify, share, and delete information of all types, including Personal Data. Please be aware that such Personal Data is potentially sensitive for both the creator and the recipient. Wonderly encourages you to use discretion when you add, modify, share, and delete Personal Data. When in doubt about whether certain information is "personal data" about you or another person, we recommend that you avoid using the Service to add or share such information.

7. What Personal Data We Collect and How We Collect It

7.1. Personal Data We Collect

When you register for and use our Service, we may collect different types of personal data about you. This personal data may include, but is not limited to, the following: your name, e-mail address, postal address, phone and fax number, IP address, user IDs, passwords, company name and job title.

We collect only Personal Data that you provide to us voluntarily and with your consent, where applicable. Wonderly takes measures to ensure that we collect Personal Data for specified, explicit and legitimate reasons only; namely, to provide the Service to you and meet our legal obligations. We also take steps to limit the Personal Data we collect to only the minimum necessary to carry out our mission.

Unless identified above or specifically requested by us, we ask that you not send us, and you not disclose, any sensitive personal information (e.g., Social Security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Service or otherwise to us.

7.2 How We Collect Your Personal Data

We may collect your Personal Data when you:

• add, create, use, and share Personal Data via the Bella Scena platform;
• contact us by chat, phone, email, fax, or other online formats;
• request white papers or similar resources;
• sign up for our newsletters or alerts; and/or
• view our educational videos or listen to our podcasts.

7.3. Collection Via Log Files

We may use log files to collect and record data relative to your use of the Service. When you use the Service, we collect detailed information about your interactions with the Bella Scena platform. We use this information to analyze overall trends to help improve the Service.

7.4. Collection Via First-Party Cookies

Our Service uses first-party cookies to implement basic browser functionality and provide a personalized user experience in the Bella Scena platform. We may use cookies to collect information necessary to retrieve your last session or last known state of the Service. In so doing, we automatically save one or more cookies (each a small text file) on your computer. We do not recommend that you remove or block cookies using the settings in your browser, as doing so may impact your ability to use the Service.

7.5. Collection Via Third-Party Cookies and Other Tracking Technologies

Our Service may use third-party cookies to expand functionality in the Bella Scena platform. We do not knowingly use third-party cookies to track or analyze user behavior outside of the Service. Though we may not be able to fully control the functionality of third-party cookies and other tracking technologies, Wonderly seeks contractual assurances from our third-party service providers that they implement appropriate technical and organizational measures in a manner that meets applicable legal and regulatory requirements.

7.6. Collection Via Surveys

We may collect information, including Personal Data, from surveys as part of the core functionality of the Bella Scena platform. Participation in these surveys may be voluntary, depending upon the settings chosen by the user who creates the survey.

7.7. Collection Via Academic Research

We may collect de-identified data, generated by users of the Service, for academic research. See theUse of Data for Academic Research section below for information on how we use this such de-identified data.

7.8. Your Consent to Our Collection of Personal Data

By using the Service, you consent to our collection of your Personal Datafor our legitimate business purposes. If you do not consent to such collection of your Personal Data, you must not use the Service.

8. Ways We Use Your Personal Data

8.1. In General

Wonderly may use your Personal Data for our legitimate business purposes. In particular, we may use your Personal Data to communicate with you and provide you a personalized experience when you use the Service. For example, we may use your Personal Data to:

• Personalize the Bella Scena platform interface;
• Send you newsworthy updates;
• Send you invitations to events;
• Answer questions you submit to us;
• Administer our business processes; and
• Comply with our legal and contractual obligations.

8.2. Use of Data for Academic Research

We may use de-identified data, generated by users of the Service, for academic research. Our aim is to improve meeting planning and execution processes, and productivity for organizations small and large. To achieve this, we may study de-identified data to draw statistical inferences from the data to support the meeting and productivity best practices we publish. As a user of the Service, you consent to our use of de-identified data for academic research.

8.3. Your Consent to Our Use of Personal Data

By using the Service, you consent to our use of your Personal Data for our legitimate business purposes. If you do not consent to such use of your Personal Data, you must not use the Service.

9. Ways We Share Your Personal Data

9.1. In General

We have not and will not sell or lease your Personal Data to third-parties. In the context of the uses of Personal Data mentioned in theWays We Use Your Personal Data section above, we may share your Personal Data with third-party service providers we engage to optimize the value of the Service for you. In such cases, Wonderly seeks contractual assurances that our third-party service providers implement appropriate technical and organizational measures in a manner that meets applicable legal and regulatory requirements. Wonderly’s third-party service providers include, but are not limited to, organizations that provide the following:

• Software development and support;
• Customer relationship management (CRM) platform;
• Payment and fulfillment partners;
• User onboarding and training services;
• Website hosting services;
• Business resilience and disaster recovery services;
• User authentication tools and services;
• Auditing platforms and accounting services;
• Legal services; and where applicable,
• Academic research findings.

9.2. Other Sharing Circumstances

We may also share your Personal Data in other circumstances, such as:

• As required to by law or in response to a subpoena or other government information requests;
• To make you aware of our family of brands;
• If we believe that the disclosure is in the interest of your security or Wonderly’s security (including exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction);
• If we merge with or are acquired by another company, or;
• If we go out of business, enter bankruptcy, or experience some other change of control.

9.3. Sharing Aggregate Information

We may share aggregate information about our users with strategic partners. In these circumstances, we do not share Personal Data that can uniquely identify you.

9.4 Your Consent to Our Sharing and Transferring of Personal Data

By using the Service, you consent to our sharing and transferring of your Personal Data for our legitimate business purposes. If you do not consent to such sharing and transferring of your Personal Data, you must not use the Service.

10. Personal Data Retention

We may retain your Personal Data for as long as you do business with us, as needed to provide you the Service. Wonderly may also retain your Personal Data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

If you cancel the Service and we deactivate your subscription, Wonderly may retain your Personal Data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

11. Special Notice for Individuals in The European Economic Area (EEA) and Switzerland

11.1 Transfer of Data from EEA or Switzerland

If you are in the European Economic Area (EEA) or Switzerland, please be aware that we operate in the United States. As such, we may transfer your Personal Data from the EEA and/or Switzerland to the US to provide you the Service and for our legitimate business purposes. Wonderly takes measures to adequately safeguard your Personal Data when it is transferred to the United States or elsewhere. In doing so, we aim to comply with applicable EU and Swiss data protection laws and regulations.

By using the Service, you acknowledge that we may transfer and/or Process your Personal Data outside the EEA and/or Switzerland, and that we may share your Personal Data, as described in theWays We Share Your Personal Data section above.

11.2 Your Privacy Rights

With respect to the Service, you have certain data privacy rights. These rights include:

Access: You have the right to request that we provide you access to your Personal Data held by Wonderly.

Correction, Amendment, and Removal: You have the right to request a correction or amendment of your Personal Data held by Wonderly. You also have a right to request that Wonderly deletes certain Personal Data about you.

Restriction: You have the right to request that we restrict Processing of your Personal Data held by Wonderly if you contest the accuracy of your Personal Data held by Wonderly, or the lawfulness of our Processing of your Personal Data.

Portability: You have the right to receive your Personal Data held by Wonderly in a structured, commonly-used, and machine-readable format. You also have the right to transmit your Personal Data to another organization without hindrance from Wonderly.

Objection: You have the right to object, on grounds relating to your particular situation, to Wonderly’s Processing of Personal Data about you, unless Wonderly demonstrates compelling legitimate grounds for continuing such Processing. You also have the right to object to automated decision-making (such as user profiling) used by Wonderly.

Complaints: You have the right to lodge a complaint or concern about our data privacy practices with Wonderly directly and/or with an appropriate supervisory authority.

If you wish to exercise any of your rights, as described above, please submit your request to Wonderly by using the information in the How to Contact Us section below. If you are in the EU and wish to lodge a complaint about our data privacy practices with a supervisory authority in your country, you may find details atthis site.

12. Individuals Under the Age of 18

Wonderly does not intend the Service for use by individuals under 18 years of age. Individuals under age 18 should avoid using the Service without verifiable parental consent.

13. Data Security

We constantly strive to align our data security practices with industry standards for Processing your Personal Data. To prevent unauthorized access, maintain data accuracy and the correct use of information, Wonderly implements administrative, physical, and technical measures to safeguard and secure the information we collect on the Service. We utilize industry-accepted encryption technologies and strengths to reduce the risk that others can view information passing between our Service and your browser.

Since the Internet is not a completely secure environment, we cannot ensure or warrant the security of any information you transmit to us. Wonderly offers no guarantees that information cannot or will not be accessed, disclosed, altered, or destroyed by a breach of any of our administrative, physical, or technical measures.

14. Notification in Event of Data Breach

International, federal, and state laws and regulations require Wonderly to notify individuals in the event of a breach of Personal Data. In such an unfortunate event, we will promptly notify data breach victims, in accordance with notification procedures defined in our internal policies, and as required by applicable law.

15. Links

The Service may contain links both hyperlinks or application programming interfaces (APIs) to and from third-party service providers. Please be aware that Wonderly cannot be held responsible for the privacy practices of these third-party service providers, though we make good faith efforts to attain contractual assurances that our third-party service providers implement appropriate technical and organizational measures in a manner that meets applicable legal and regulatory requirements. We encourage you to be aware of the privacy policies of each third-party service provider that collects and uses your Personal Data as part of the Service.

16. How to Contact Us

If you request to opt-out, there may be a 30-day period before such opt-out will take effect.

17. Updates to This Privacy Policy

Wonderly created this Privacy Policy on September 20, 2018. We reserve the right, at our discretion, to change, modify, add, or remove portions of this Privacy Policy at any time. Your continued use of the Service following reasonable notice of such modifications constitutes your acceptance of any changes to this Privacy Policy.