Corporate Privacy Statement

Hypori, Inc. and its subsidiaries (“Hypori”, “we”, “us”, and “our”) places importance on privacy and data protection.

This CORPORATE PRIVACY STATEMENT describes our personal information processing practices, including the types of personal information we obtain, how we may use that personal information, with whom we may share it, and how individual data subjects (“you” and “your”) may exercise your rights regarding our processing of your personal information. This Privacy Statement also describes the

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Summary: Corporate Privacy at a Glance

This summary explains, in simple terms, how Hypori handles personal information.
For full details, please read our full Privacy Statement.

Who We Are

Hypori provides secure access technology for organisations.

• Hypori, Inc. owns the Hypori platform and products
• Hypori Ltd (UK) supports UK operations and is registered with the UK ICO.

What Data We Do Not See

This is important:

• We do not access, read, or store the content of your work, messages, or files
• We do not monitor content inside customer virtual workspaces
• We do not have visibility of access control to customer resources, systems or services
• We do not access personal files, apps, or content on your device

All content inside customer-controlled environments is managed by the customer organisation, not Hypori.

What Personal Information We Do Collect

We only collect personal information needed to run our business and keep systems secure, such as:

• Your name, work email, and business contact details
• Account and login information
• Limited device and security information (for secure access only)
• Website usage information (via cookies, where permitted)
• Information you provide at events, webinars, or when contacting us
• Virtual Workspace security policy violations

Why We Use Personal Information

We use personal information to:

• Provide and secure our websites and services
• Manage accounts, contracts, billing, and customer support
• Communicate with you about products, updates, and events
• Improve our business operations and security
• Meet legal and regulatory obligations

We do not use personal information for automated decision-making that has legal or significant effects on you.

Cookies and Website Tracking

Our websites use cookies to:

• Make the site work properly
• Understand how the site is used
• Improve performance and user experience

We do not use cookies for behavioural advertising inside customer environments. You can manage cookie preferences at any time using the Cookie Preferences link on our website.

Who We Share Information With

We do not sell personal information.

We may share information with:

• Our group companies
• Trusted service providers (e.g. IT, hosting, analytics, events)
• Professional advisers (legal, audit, finance)
• Authorities where required by law

All sharing is subject to appropriate safeguards.

International Transfers

Hypori operates globally, so personal information may be transferred to other countries (including the United States). Data processed by Hypori on the Pando Platform for customers contracted to Hypori Ltd is hosted in the UK.

When we do transfer data, we use approved safeguards such as:

• Standard Contractual Clauses
• UK and EU data transfer agreements
• Other legally recognised protections

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Your Privacy Rights

Depending on where you live, you may have the right to:

• Access your personal information
• Correct inaccurate information
• Request deletion or restriction
• Object to certain uses
• Withdraw consent (where applicable)
• Complain to your data protection regulator if we can’t resolve your issue.
  

If Hypori processes data for a customer, requests should initially be made to that customer.

To contact us about your rights: [email protected]

How We Protect Data

We use appropriate technical and organisational security measures, including:

• Access controls
• Encryption and security monitoring
• Staff training
• Supplier oversight

Children

Our websites and services are not designed for children, and we do not knowingly collect their personal information.

Want the Full Detail?

This summary is designed to be clear, readable and easy to understand.  For full legal detail, international disclosures, and jurisdiction-specific rights, please read our full Privacy Statement.

This full Privacy Statement applies to the personal information we obtain through Hypori properties on which this Privacy Statement is posted, including our websites, that reference this Privacy Statement (“Online Channels”); offline collection, including Hypori events, surveys, questionnaires, customer user research and evaluations (“Offline Channels”); and third-party sources, including business partners, and vendors (collectively, the “Offerings”).

IT IS IMPORTANT TO NOTE THAT HYPORI DOES NOT ACCESS, MONITOR, STORE, OR CONTROL END USER CONTENT, COMMUNICATIONS, OR ACTIVITY THAT OCCURS WITHIN CUSTOMER-CONTROLLED VIRTUAL WORKSPACES. ALL DATA PROCESSED WITHIN A HYPORI VIRTUAL WORKSPACE IS CREATED, MANAGED, AND GOVERNED EXCLUSIVELY BY THE CUSTOMER ORGANIZATION AND IS SUBJECT TO THAT ORGANIZATION’S POLICIES AND AGREEMENTS.

HYPORI’S INTERACTION WITH END USERS’ PERSONAL DEVICES IS LIMITED TO ENABLING SECURE ACCESS TO CUSTOMER-CONTROLLED ENVIRONMENTS AND DOES NOT INCLUDE ACCESS TO PERSONAL FILES, APPLICATIONS, COMMUNICATIONS, OR CONTENT ON THE DEVICE ITSELF.

Except where expressly stated otherwise, Hypori acts as a data controller in respect of its corporate websites, marketing, events, security operations, and business administration activities described in this Privacy Statement.

Where Hypori processes personal information on behalf of enterprise customers in connection with its products and services, Hypori acts as a data processor, and such processing is governed by applicable customer agreements and data processing documentation.

The Online Channels may provide links to third-party websites and features. Unless otherwise disclosed in this Privacy Statement or other supplementary privacy notice provided to you, Hypori does not automatically share your personal information with those third-party websites and is not responsible for their privacy practices. These websites are subject to their respective privacy notices and policies. Hypori may engage vendors and service providers in connection with its corporate operations, subject to appropriate confidentiality and data protection obligations.

References in this Privacy Statement to “Hypori” mean Hypori, Inc., and, where applicable, its operations in the United Kingdom (Hypori Ltd). Hypori, Inc. is the entity that determines the purposes and means of processing personal information and acts as the data controller for such processing in the USA. Hypori Ltd is the data controller in the UK. If you have questions about the data controller or how your personal information is processed, please see the How to Contact Us section below.  If you are a UK Pando user and have downloaded the Pando App without a formal Hypori contract in place, you should refer to the Privacy Notice of Beacon Medical Systems Ltd who is the Data Controller in this instance.

When we use the term “personal information” in this Privacy Statement, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to an individual, or as otherwise defined under applicable privacy and data protection laws.  

This Privacy Statement does not apply to:

• personal information that our employees provide us with in connection with their employment.

• personal information that an individual makes available to us in connection with the recruitment process.

• additional personal information collected by third-party platforms or marketplaces (such as the Apple App Store or Google Play Store) in connection with downloads or updates of Hypori applications, which are subject to those third parties’ own privacy notices.

• personal information processed entirely within customer-controlled virtual workspaces or enterprise environments, which Hypori does not access, and which is governed by the applicable customer’s privacy notices, policies, and agreements.

Personal Information We Collect

The personal information we obtain varies depending on your interactions with Hypori in connection with our corporate activities. We obtain personal information, for example, when you:

• browse our website;
• participate in Hypori events including conferences, webinars, surveys, questionnaires, research or evaluations; or correspond with us or request information from us.

In addition to personal information you directly provide, we collect personal information from the following categories of sources:

• third parties such as your employer, company administrator or business partner, through their use of the Offerings;
• our affiliates;
• social media networks;
• personal information contained in forums, blogs, and testimonials you provide; and
• marketing and business information enrichment sources.

The types of personal information we obtain include the following categories and examples. The categories described below may apply depending on the context of an individual’s interaction with Hypori in connection with our corporate activities. For the avoidance of doubt, this Privacy Statement does not describe personal information processed within customer environments or enterprise products, which is governed by applicable customer agreements. Not all categories apply to every individual or processing activity.

Limited Device Security Information

Hypori does not collect or interact with personal content or applications on end user devices. The only information Hypori may process in connection with device access is limited to security-related and technical metadata necessary to provide secure access, such as:

• device make and model
• operating system version
• security attestation or integrity indicators
• approximate device location, where enabled by the user
• corporate email address used for authentication

This information is used solely for security, access control, and fraud prevention purposes.

The categories below describe personal information processed in connection with Hypori’s corporate activities only (such as marketing, events, website interactions, and business communications). They do not describe data processed within customer virtual workspaces or enterprise environments, over which Hypori has no control or visibility

Please note that providing personal information to us is voluntary on your part. Hypori does not use personal information described in this section for automated profiling or behavioural monitoring in connection with its corporate activities.

How We Use Personal Information

We use the above categories of personal information for the following purposes:

• to process and fulfill business transactions and keep you informed about the status of those transactions;
• to help you complete a transaction or order and provide customer support;
• to respond to inquiries and provide business-related support;
• to bill you for products and services you purchased;
• to operate, evaluate, and improve our business operations, including managing communications and customer relationships and performing accounting, auditing, billing, reconciliation, and collection activities;

to perform internal business analytics, such as financial analysis and operational reporting;

• to communicate with you about your account and orders (including sending emails relating to your registration, account status, order confirmations, renewal or expiration notices, and other important information);
• to conduct advertising, marketing, and sales activities (including sending you promotional materials, generating leads, pursuing marketing prospects, performing market research, determining and managing the effectiveness of our advertising and marketing campaigns, and managing our brand);
• to communicate with you about, and administer your participation in, events, programs, promotions, and surveys;
• to connect customer employees with their enterprise account administrator;
• to protect the health, safety, and security of our employees;
• to comply with and enforce relevant laws, regulations, industry standards, contractual obligations, and our policies;
• to respond to your inquiries.

Depending on the purposes for which personal information is processed, and the context in which the data is obtained, we may rely on one or more of the following legal bases:

• performance of a contract with you or other relevant individual data subject;
• our legitimate business interests;
• compliance with a legal obligation, a court order, or to exercise or defend legal claims; or
• your consent, which you can revoke at any time.
  

Where required by applicable law, we will obtain your consent for the processing of your personal information for direct marketing purposes.

Artificial Intelligence (AI) Technologies

Our processing of personal information for the purposes described in this Privacy Statement may include automated and manual (human) methods of processing in connection with our corporate activities, such as responding to inquiries, managing communications, and improving internal business processes. We do not use automated decision-making that produces legal or similarly significant effects for individuals. Where required under applicable law, we will provide additional transparency regarding our use of AI-assisted tools.

Cookies and Other Similar Technologies

Hypori uses cookies and similar technologies on its Online Channels to operate and manage those websites and to understand how they are used. Cookies are small text files that are placed on your device when you visit a website and are commonly used to make websites function efficiently, improve user experience, and provide information to website operators.

We use cookies and similar technologies to collect information about how our Online Channels are accessed and used, such as browser type, operating system, pages visited, referring or exit pages, access times, and general interaction patterns. This information helps us operate our websites, respond to inquiries, and improve the content and performance of our Online Channels. We do not use cookies on our corporate websites to monitor individuals within customer environments or within Hypori products.

Cookies used on our Online Channels may be either first-party cookies (set directly by Hypori) or third-party cookies (set by service providers that support the operation of our websites, such as analytics providers). Some cookies are session cookies, which expire when you close your browser, while others are persistent cookies, which remain on your device for a limited period unless deleted earlier.

Types of Cookies We Use

Strictly Necessary Cookies

These cookies are required for the operation and security of our Online Channels. They enable core functionality such as page navigation and secure access to website features. Because these cookies are essential to the operation of the website, they do not require consent where permitted by applicable law.

Functional Cookies

Functional cookies support website functionality and user experience, such as remembering preferences or choices you make when interacting with our Online Channels.

Analytics Cookies

Analytics cookies are used to understand how visitors interact with our Online Channels, such as which pages are visited and how users move through the site. This information is used in aggregated form to help us improve website performance and usability. Where required by applicable law, analytics cookies are used only with appropriate consent.

Hypori does not use cookies for cross-context behavioural advertising or interest-based advertising on its corporate websites.

You can manage your cookie preferences at any time through the Cookie Preferences link available at the bottom of Hypori’s website. Your browser settings may also allow you to control or delete cookies. Please note that disabling certain cookies may affect the functionality of our Online Channels.

Our Online Channels may include features provided by third parties, such as social media sharing tools. These third parties may use their own cookies or similar technologies in accordance with their own privacy notices and policies. Hypori does not control these third-party technologies and is not responsible for their data practices.

Where required by applicable law, Hypori obtains consent before placing non-essential cookies on your device.

Why and With Whom We Disclose or Share Personal Information

Hypori does not sell personal information and does not disclose personal information except as described in this Privacy Statement or where otherwise permitted or required by applicable law.

Hypori may disclose personal information for the following purposes:

• to operate, manage, and administer its corporate websites, business operations, and customer and partner relationships;
• to communicate with business contacts regarding corporate matters, including product information, account administration, events, or relationship management;
• to conduct corporate sales, marketing, and business development activities in a business-to-business context;
• within Hypori, including with affiliates and subsidiaries, for internal administrative, operational, and compliance purposes consistent with this Privacy Statement; and
• to connect individuals acting on behalf of an organization with relevant organizational administrators or contacts where appropriate.

Hypori may disclose personal information to the following categories of recipients:

• Hypori affiliates and subsidiaries, where necessary for internal business operations and governance;
• vendors and service providers engaged to perform services on Hypori’s behalf, such as website hosting, customer relationship management, communications platforms, analytics, professional services, and event administration. These service providers are contractually required to process personal information only in accordance with Hypori’s instructions and to implement appropriate safeguards;
• business partners, resellers, or distributors, where necessary to support corporate relationship management, sales engagement, or partner programs, subject to appropriate contractual protections; and
• professional advisers, such as legal, financial, or audit advisers, where necessary for legitimate business purposes.

Hypori may also disclose personal information where required or permitted by law, including:

1. to comply with applicable laws, regulations, legal processes, or enforceable governmental requests;
2. to law enforcement or regulatory authorities where disclosure is required or appropriate to comply with legal obligations;
3. to protect the rights, property, safety, or security of Hypori, its business partners, or others;
4. to establish, exercise, or defend legal claims; and
5. in connection with investigations relating to suspected or actual fraud, security incidents, or unlawful activity.

In addition, Hypori may disclose personal information in connection with a corporate transaction, such as a merger, acquisition, reorganization, sale of assets, or similar transaction, subject to appropriate confidentiality and data protection safeguards.

Where required by applicable law, Hypori will provide notice and obtain consent prior to any disclosure not otherwise described in this Privacy Statement.

International Data Transfers

Hypori is a global organization and may transfer personal information to, or store and process personal information in, countries other than the country in which the information was originally collected. This includes transfers to countries where Hypori or its service providers operate, including the United States.

Where personal information is transferred internationally, Hypori ensures that such transfers are made in accordance with applicable data protection laws and that appropriate safeguards are in place to protect personal information. These safeguards may include, where required:

• entering into data transfer agreements incorporating the European Commission’s Standard Contractual Clauses;
• applying the UK International Data Transfer Addendum or International Data Transfer Agreement (IDTA), as applicable;
• relying on Swiss-recognised transfer mechanisms for transfers subject to the Swiss Federal Act on Data Protection; and
• implementing supplementary technical and organisational measures where appropriate.

Hypori transfers personal information internationally only for the purposes described in this Privacy Statement, such as operating its corporate websites, managing business operations, supporting customer and partner relationships, and complying with legal and regulatory obligations.

Where Hypori processes personal information on behalf of its customers in connection with the provision of its products or services, international transfers of such data are governed by the applicable contractual arrangements between Hypori and the relevant customer, including any data processing addendum or data transfer agreements in place. In those circumstances, the relevant customer remains responsible for determining the lawful basis for the transfer.

Individuals may request additional information about the safeguards applied to international transfers by contacting Hypori using the details provided in the How to Contact Us section of this Privacy Statement.

Your Privacy Rights and Choices

To the extent provided by the law of your jurisdiction, you may have privacy rights to access, correct, update, amend, delete, restrict the processing of your personal information, or object to automated decision-making based on your personal information.  

When Hypori is acting as a “data controller” under applicable law, you may exercise such rights by contacting us via [email protected]. To help protect your privacy and maintain security, we may take steps to verify your identity before granting you access to the information.  Depending on your location, you may have the right to file a complaint with a government regulator if you are not satisfied with our response.

When Hypori is acting as a “data processor” and you wish to exercise your privacy rights of access and request corrections, suppression, or deletion, we will direct you to the data controller under the applicable data protection laws. Alternatively, to exercise any rights relating to personal information processed on behalf of our customers in connection with the use of our products and services, end users may directly contact the relevant customer, not Hypori. If you are a customer account administrator or customer account owner and require assistance with this process, such as if you want to make a request with respect to your own user data, you may contact us as described in the How to Contact Us section below.

European Economic Area (EEA) and United Kingdom Privacy Disclosures

If you are located in the European Economic Area (“EEA”) or the United Kingdom (“UK”), the following additional information applies to you.

Data Controller and Processing Roles

For the purposes of applicable data protection laws, including the EU General Data Protection Regulation (“GDPR”) and the UK GDPR:

• Hypori Inc acts as a data controller in respect of personal information processed in connection with its corporate websites, marketing and communications activities, events, security operations, account administration, and general business operations described in this Privacy Statement.
• Where Hypori Inc processes personal information on behalf of enterprise customers in connection with the provision of its products or services, Hypori acts as a data processor, and such processing is governed by the applicable customer agreements, data processing addenda, and related documentation. In those circumstances, the relevant customer acts as the data controller and determines the purposes and means of processing.

If you are an end user accessing Hypori services through an organization, you should direct privacy-related requests primarily to that organization.

Legal Bases for Processing

We process personal information only where we have a lawful basis under applicable data protection laws. Depending on the context and nature of the processing, these legal bases may include:

• Legitimate interests (Article 6(1)(f) GDPR), such as:
  

• providing, operating, and improving Hypori’s corporate operations, websites, and business activities;
• ensuring network and information security;
• preventing fraud, misuse, and unauthorised access; and
• managing customer relationships and business operations provided that such interests are not overridden by your rights and freedoms.
  

• Compliance with Legal Obligations (Article 6(1)(c) GDPR), including regulatory, tax, and security requirements.
  

• Consent (Article 6(1)(a) GDPR), where required by law, such as for certain cookies, analytics, or marketing communications. You may withdraw your consent at any time.
  

• In business-to-business (B2B) contexts, including where personal information relates to employees or representatives of customers, partners, or vendors, processing is primarily based on Hypori’s legitimate interests in managing corporate relationships and business operations, except where another lawful basis is required by applicable law.

Your Rights

Subject to applicable law, you may have the right to:

• request access to your personal information;
• request correction of inaccurate or incomplete personal information;
• request deletion or restriction of processing in certain circumstances;
• object to processing based on legitimate interests;
• request data portability where applicable; and
• lodge a complaint with a relevant supervisory authority if you consider that we have not satisfactorily resolved your complaint ourselves. In the UK, this is the Information Commissioner’s Office (ICO).
  

If Hypori processes your personal information as a processor on behalf of a customer, requests should be directed to the relevant customer, as they are responsible for responding under applicable data protection laws.

Switzerland Privacy Disclosures

If you are located in Switzerland, the following information applies to you in accordance with the Swiss Federal Act on Data Protection (“FADP”) and its implementing ordinances.

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• Controller
  

Hypori, Inc. is responsible for the processing of personal data described in this Privacy Statement where it determines the purposes and means of processing. Where Hypori processes personal data on behalf of its customers, Hypori acts as a processor, and the relevant customer is responsible as the controller.

• Purposes and Legal Bases
  

Hypori processes personal data for the purposes described in this Privacy Statement. Under Swiss data protection law, processing is lawful where it is justified by the consent of the data subject, required for the performance of a contract, mandated by law, or necessary to protect overriding private or public interests, including the operation, security, and improvement of our services.

• Your Rights under Swiss Law
  

Subject to applicable law and certain limitations, individuals in Switzerland have the right to:

• request information about whether personal data relating to them is being processed;
• request access to their personal data;
• request correction of inaccurate personal data;
• request deletion of personal data where retention is no longer justified;
• object to the processing of personal data in certain circumstances;
• request data portability where applicable.

You may exercise these rights by contacting us using the details provided in the How to Contact Us section of this Privacy Statement. We may take reasonable steps to verify your identity before responding to your request.

• International Transfers
  

Personal data may be transferred to countries outside Switzerland, including the United States. Where such countries do not provide an adequate level of data protection under Swiss law, Hypori implements appropriate safeguards, such as contractual data protection clauses or other legally recognized transfer mechanisms, to protect personal data.

• Complaints
  

If you believe that your personal data has been processed unlawfully, you have the right to lodge a complaint with the Swiss Federal Data Protection and Information Commissioner (FDPIC).

Singapore Privacy Disclosures

If you are located in Singapore, the following information applies to you in accordance with the Singapore Personal Data Protection Act 2012 (“PDPA”).

• Organization Responsible for Processing

Hypori, Inc. is responsible for the processing of personal data described in this Privacy Statement where it determines the purposes and means of processing. Where Hypori processes personal data on behalf of its customers, Hypori acts as a data intermediary and processes such personal data in accordance with the instructions of the relevant customer.

• Purposes for Collection, Use, and Disclosure
  

Hypori collects, uses, and discloses personal data for the purposes described in this Privacy Statement, including to provide, operate, secure, and improve its products and services; manage accounts; provide customer support; ensure information security; and comply with legal and regulatory obligations.

• Consent and Notification
  

Hypori collects, uses, and discloses personal data with your consent or where otherwise permitted or required under the PDPA. Where consent is required, you may withdraw your consent at any time by contacting us using the details in the How to Contact Us section of this Privacy Statement. Withdrawal of consent may affect our ability to provide certain products or services.

• Your Rights under Singapore Law
  

Subject to applicable law and certain exceptions, individuals in Singapore have the right to:

• request access to personal data held by Hypori;
• request correction of personal data that is inaccurate or incomplete.
• Requests may be submitted using the contact details provided in the How to Contact Us section below. Hypori may require reasonable information to verify your identity before responding.

• Retention and Protection
  

Hypori retains personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law, and implements reasonable security arrangements to protect personal data against unauthorized access, disclosure, or misuse.

• Transfers Outside Singapore
  

Personal data may be transferred outside Singapore. Where this occurs, Hypori takes steps to ensure that transferred personal data is protected to a standard comparable to that under the PDPA, including through contractual or other legally recognized safeguards.

• Complaints and Contact
  

If you have concerns about Hypori’s handling of your personal data, you may contact us using the details in the How to Contact Us section of this Privacy Statement. You also have the right to lodge a complaint with the Personal Data Protection Commission of Singapore.

Supplemental U.S. State Privacy Disclosures

This section applies to residents of U.S. states with comprehensive privacy laws, including but not limited to California, Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Montana, Tennessee, Indiana, Iowa, Delaware, and New Jersey (“State Privacy Laws”). This section supplements the Privacy Statement above.

• Categories of Personal Information We Collect
  

• Depending on your interaction with Hypori and as described in this Privacy Statement, we may collect the following categories of personal information: identifiers such as name, email address, IP address, and account identifiers; professional or employment-related information; internet or other electronic network activity information relating to access, usage, and security logging; device and technical information necessary to support secure access and service operation; commercial information limited to subscription, licensing, and transaction metadata (excluding payment card details); and approximate location information derived from IP address for security and compliance purposes.
  

• We do not knowingly collect sensitive personal information except where strictly necessary to provide and secure our services, such as account credentials.
  

• Purposes for Processing
  

We collect and process personal information for the purposes described in this Privacy Statement, including to provide, operate, maintain, and secure our products and services; support account access and administration; protect against, detect, and respond to security incidents and other unlawful or harmful activity; respond to customer inquiries and provide service-related communications; perform limited internal analytics and research to maintain and improve service functionality and reliability (not for cross-context behavioral advertising); and comply with applicable legal and regulatory obligations.

• Sale and Sharing of Personal Information
  

Hypori does not sell personal information as that term is defined under applicable U.S. State Privacy Laws. We also do not share personal information for purposes of cross-context behavioural advertising, except where limited online advertising or analytics technologies may be considered “sharing” under certain state laws. Where required, Hypori provides opt-out mechanisms through cookie controls and recognizes legally required preference signals.

• Your Privacy Rights (U.S. States)
  

• Subject to applicable law and certain exceptions, residents of U.S. states may have the right to confirm whether we process your personal information; access and obtain a copy of your personal information; correct inaccuracies in your personal information; delete personal information; obtain personal information in a portable format; opt out of the sale of personal information, sharing of personal information for targeted advertising, or certain profiling activities; and not be discriminated against for exercising privacy rights.
  

• Some rights may vary by state and may be subject to limitations, including where Hypori acts as a service provider or processor on behalf of a business customer.

• Exercising Your Rights
  

• To submit a privacy rights request, please see the How to Contact Us section below. We will verify your request in accordance with applicable law and respond within the timeframes required by law. Where permitted, we may request additional information to verify your identity.
  

• If Hypori processes your personal information on behalf of a customer, for example where you access Hypori services through your employer or organization, we may direct you to that customer to exercise your rights.

• Appeals
  

If we decline to take action on your request, you may have the right to appeal our decision, depending on your state of residence. Instructions for submitting an appeal will be provided in our response where applicable.

• Authorized Agents
  

Where permitted by law, you may designate an authorized agent to submit a request on your behalf. We may require proof of authorization and verification of your identity before processing the request.

• California Residents (Additional Notice)
  

For California residents, this section is intended to satisfy the notice requirements of the California Consumer Privacy Act, as amended by the California Privacy Rights Act (CCPA/CPRA). Hypori does not sell personal information and does not use or disclose sensitive personal information for purposes other than those permitted by law. California residents may exercise the rights described above by contacting [email protected].

Communication Preferences

We offer choices in connection with the personal information we use to communicate with you, such as via email or telephone. To update your email and telephone communication preferences, limit the communications you receive from us, or submit a related request, please contact us as at [email protected]. You can also unsubscribe from our email marketing by following the “Unsubscribe” link in our marketing emails. Please note that unsubscribing from marketing communications does not affect your receipt of operational communications that are important to your interaction with us or our services, such as communications about the status of your subscription, service changes, support communications, security updates, event registration updates or account management communications.

Internet-Based Advertising Choices

Hypori may use limited advertising and analytics technologies to promote its products and services, such as measuring the effectiveness of campaigns and displaying content that may be relevant to business users. Where required by applicable law, we obtain consent before using cookies or similar technologies for advertising purposes.

You can manage your cookie and advertising preferences at any time using the Cookie Preferences link available at the bottom of Hypori’s website. Opting out of advertising cookies will not prevent you from seeing Hypori communications, but it may mean that such content is less relevant to your interests.

Global Privacy Control (GPC)

Hypori recognizes Global Privacy Control (“GPC”) signals where legally required. GPC is a browser setting that a user can set to send a signal to websites visited regarding the user’s cookie preferences. If your browser or browser extension has GPC enabled, we will recognize that signal and opt you out of non-essential cookies.

Other Online Preferences

When you use our Online Channels, we and certain third parties may collect information about your online activities through cookies and similar technologies, as described in this Privacy Statement. Some web browsers offer settings such as “Do Not Track” signals; however, there is no consistent industry or legal standard for responding to such signals, and our Online Channels do not respond to them.

You can manage your cookie preferences at any time by using the Cookie Preferences link available at the bottom of our website. Where legally required, we also recognize Global Privacy Control (GPC) signals, as described above.

How We Protect Personal Information

Hypori maintains appropriate administrative, technical, and organizational safeguards designed to protect the personal information it processes against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access.

These safeguards are proportionate to the nature of the personal information processed and the purposes for which it is used, and may include:

• access controls and authentication measures appropriate to job role and responsibility;
• policies and procedures governing data handling, confidentiality, and acceptable use;
• security awareness and data protection training for personnel;
• measures to protect physical access to offices and facilities where personal information may be processed; and
• oversight of service providers through contractual obligations requiring appropriate data protection and security measures.

Hypori regularly reviews and updates its safeguards to reflect changes in legal requirements, business practices, and risk environment.

This section describes Hypori’s corporate data protection practices only. Security measures applicable to Hypori’s cloud services, products, or technical platforms are addressed separately in relevant product documentation, security exhibits, or cloud service offering security policies, as applicable.

While Hypori takes reasonable steps to protect personal information, no security measures can guarantee absolute security. Accordingly, Hypori cannot ensure or warrant the security of information transmitted to or stored by Hypori, and individuals provide information at their own risk.

How Long We Retain Personal Information

Hypori retains personal information only for as long as necessary to fulfil the purposes for which it was collected, as described in this Privacy Statement, and in accordance with applicable law.

In determining appropriate retention periods, Hypori takes into account:

• the nature and purpose of the processing;
• the duration of Hypori’s relationship with the relevant organization or business contact;
• applicable legal, regulatory, tax, accounting, or compliance obligations; and
• the need to establish, exercise, or defend legal claims.

Personal information collected for corporate purposes, such as account administration, business communications, sales and marketing activities, event management, and relationship management, is generally retained for the duration of the relevant business relationship and for a reasonable period thereafter, unless a longer retention period is required or permitted by law.

Where personal information is no longer required for the purposes for which it was collected, Hypori will delete, anonymize, or otherwise securely dispose of such information in accordance with its data retention and deletion practices.

Where Hypori processes personal information on behalf of its customers in connection with the provision of products or services, retention of such information is governed by the applicable contractual arrangements with the relevant customer, and Hypori retains such data only in accordance with the customer’s instructions and applicable law.

Individuals may request deletion or restriction of processing of their personal information in accordance with applicable data protection laws, subject to legal and contractual limitations.

Children’s Personal Information

The Online Channels are designed for a general business audience and are not directed to children under the age of 18. We do not knowingly collect or solicit personal information from children under the age of 18 through the Online Channels. If we become aware that we have collected personal information from a child under the age of 18, we will promptly delete the information from our records. If you believe that a child under the age of 18 may have provided us with personal information, please contact us as specified in the How to Contact Us section of this Privacy Statement.

Changes to Our Privacy Statement

Hypori may update this Privacy Statement from time to time to reflect changes in its corporate practices, legal requirements, or regulatory obligations.

The “Effective Date” at the top of this Privacy Statement indicates when it was most recently updated. Where changes are material, Hypori will provide appropriate notice, such as by posting an updated version of this Privacy Statement on its website or by other reasonable means, prior to the changes taking effect.

By continuing to engage with Hypori’s corporate websites, communications, or business activities after an updated Privacy Statement becomes effective, you acknowledge and accept the updated terms.

How to Contact Us

If you have questions, requests, or concerns relating to one of our customers’ handlings of your personal information, please contact the relevant customer. If you have any questions or comments about our privacy practices, this Privacy Statement, or your privacy rights and preferences, you may contact us at:

Hypori, Inc.

Attn: Data Privacy Officer (DPO)

1801 Robert Fulton Drive, Ste 340

Reston, VA 20191

United States

[email protected]

Prior Analytics Ltd (d/b/a PrivacyAid) (EU Representative)

Attn: Hypori DPO

590 Green Lanes

London, N13 5RY

[email protected]