Retail Pro International, LLC, ("RPI") is committed to protecting your personal identifiable Information (the "Personal Information"). This document (the "Privacy Policy") describes the privacy practices of Retail Pro International, LLC., for data that we collect:

• through websites owned, operated or controlled by us from which you are accessing this Privacy Policy (individually, a "Website", and collectively, the "Websites")
• through the software applications made available by us for use on or through computers and mobile devices (collectively, the "Software")
• through our social media pages that we control from which you are accessing this Privacy Policy (collectively, our "Social Media Pages")
• through HTML-formatted email messages that we send you that link to this Privacy Policy
• through your communications with us or through other offline activities and interactions (e.g., customer service inquiries and engagements, user conferences, etc.)

Collectively, we refer to the Websites, the Software, and our Social Media Pages, as the "Online Services" and, together with offline channels, the "Services."

We want you to be familiar with how we collect, use and disclose data. Unless otherwise specified below, this Privacy Policy does not apply to any other products or services or to information collected in any other way (whether online or offline) or for any other purpose. In addition to the above, it also describes your choices regarding use, access and correction of Personal Information.

By using the Services, you agree to the terms and conditions of this Privacy Policy and confirm you have read and understand the entirety of this Privacy Policy as it applies to you and that you may be transferring your data to, and consent to having your data transferred to, and processed in, the United States.

Collection of Your Information

How We Use Personal Information

How We Share Personal Information

Access, Change and Control of Personal Information

Legal Basis for Collecting and Using Personal Information

Security and Retention of Personal Information

Contacting Retail Pro International, LLC.

Changes to this Privacy Policy

Further Questions and How to Make a Complaint About Personal Information

1. Collection of Your Information

In the course of using the Services, we collect both personal and anonymous information. Personal Information in this Privacy Policy refers to information that allows someone to identify or contact you. Examples of Personal Information include your name, address, telephone number, e-mail address, user ID, passwords, billing and transactional information, as well as, any other non-public information about you that is associated with or linked to any of the foregoing information. Information not associated with or inherently linked to Personal Information (the "Anonymous Information") is information that does not enable identification of, or contact with, individual persons.

If you submit any Personal Information about other people to us or our authorized resellers and service providers, you represent that you have the authority to do so and you permit us to use the data in accordance with this Privacy Policy.

Providing Personal Information on our Websites

As a visitor to RPI’s Website(s), you are free to explore any authorized Websites without providing any Personal Information about yourself. If you request more information about the Services, request a demonstration of the Software, register as a user on the Websites, or register for a webinar sponsored by RPI, we may request that you provide Personal Information about yourself as outlined within the section below, "Personal Information Collected Directly from You".

Personal Information Collected Directly from You

RPI may collect, store and process Personal Information directly from you. Certain information that you voluntarily provide to RPI as a course of general business or visitation to the Websites may include Personal Information. Collection of this information will include:

• when you contact us (by email, phone, mail or in person);
• when you become a designated contact and/or an authorized user on one of our Websites and/or when you express an interest in our products and services;
• when you request marketing material, support materials or download our content;
• when you subscribe to our newsletter;
• when you sign up for a product demo, webinar or an RPI sponsored event;
• when you register to obtain access to service offerings, support and training from RPI;
• when you participate in a conversation with our Sales, Account Management and/or Customer Service teams;
• when you purchase products and/or services directly from RPI, one of its authorized resellers or strategic partners.

Automatic Collection of Information

In addition to the information above, we may use other industry standard technologies like tracking pixels to track your use of our Website pages. Tracking pixels are tiny graphic images placed on certain pages on our Websites, or in our emails that allow us to determine whether you have performed a specific action. When you access these pages or open or click an email, the tracking pixels generate a non-personally identifiable notice of that action. Tracking pixels allow us to measure and improve our understanding of visitor traffic and behavior on our Websites, as well as give us a way to measure our promotions and performance.

Automatic collection may also include payment information where such information can directly or indirectly identify an individual. Payment information includes information we collect and process for the purposes of payment via third party PCI-compliant service providers, for RPI products, RPI services and/or RPI event attendance.

Collection of Anonymous Information

When you use our Online Services or receive/view email from RPI, we automatically collect anonymous information from your computer and browser sessions as described below.

Anonymous Information Collected by Our Servers

To make our Websites and Services more useful to you, our servers collect information from you including your browser type, operating system, Internet Protocol ("IP") address (a number that is automatically assigned to your computer when you use the Internet, which may vary from session to session), domain name, and/or a date/time stamp for your visit.

We gather certain information automatically and store it in log files within our servers. This information includes IP addresses, browser type, Internet service provider ("ISP"), referring/exit pages, operating system, date/time stamp, and clickstream data. We use this information to analyze trends, administer the Website, track users’ movements around the Website, gather demographic information about our user base as a whole, and better tailor our Services to our visitors’ needs. For example, some of the information may be collected so that when you visit the Website or the Services again, it will recognize you and the information could then be used to serve information appropriate to your interests. Except as noted in this Privacy Policy, we do not link this automatically-collected data to Personal Information.

Anonymous Information from Cookies

We use cookies to collect information. "Cookies" are small pieces of information that a website sends to your computer’s hard drive while you are viewing the website. We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our Websites. This type of information is collected to make the Websites more useful to you and to tailor the experience with us to meet your special interests and needs.

We use Google Analytics™ to help analyze how our users use the Websites. Google Analytics™ uses Cookies to collect information such as how often users visit the Websites, what pages they visit, and what other sites they used prior to coming to the Websites. We use the information we get from Google Analytics™ only to improve our Websites and Services. Google Analytics™ collects only the IP address assigned to you on the date you visit the Websites, rather than your name or other Personal Information. We do not combine the information generated through the use of Google Analytics™ with Personal Information. Although Google Analytics™ plants a persistent Cookie on your web browser to identify you as a unique user the next time you visit the Websites, the Cookie cannot be used by anyone but Google™. Google’s™ ability to use and share information collected by Google Analytics™ about your visits to the Websites is restricted by the Google Analytics™ Terms of Use and the Google™ Privacy Policy.

Combining Anonymous and Personal Information

We may combine any of the foregoing Anonymous Information with Personal Information, in which case we will consider it to be Personal Information under this Privacy Policy.

Retail Pro® Software Collection of Data

As a software developer, RPI provides software applications for retail management use under the control of customer. The Software is provided as an installable desktop application, as well as a downloadable mobile application for use on mobile hardware. The Software does not collect, or record, or transmit Personal Information. Anonymous hardware details, used for the purpose of licensing a system which has the Software installed, will be sent to Retail Pro International, LLC.; however, this information does not contain any Personal Information.

On occasion, RPI may provide customer service to the customer as requested by and consented to by the customer, and there may be instances where backups of the Software data will need to be sent to RPI for the purpose of troubleshooting and performing root-cause analysis of a customer’s issue when using the Software (a "Service Incident"). In this case, the backup data will only be used and maintained for the sole purpose of resolving the Service Incident and will be destroyed after the Service Incident has been addressed to the customer’s satisfaction. We do not link this Service Incident data to Personal Information.

Personal Information Received from Third Parties

From time to time, we may receive Personal Information about you from third party sources including partners with which we offer co-branded services or engage in joint marketing activities, as well as publicly available sources such as social media websites. In these cases, the Personal Information we receive is bound by the terms of this Privacy Policy.

2. How We Use Personal Information

The Personal Information we collect from you in the course of providing the Services is used only in compliance with this Privacy Policy. We may use the Personal Information collected from you in various ways including (but not limited to):

• improving your browsing experience by personalizing the Websites;
• promoting use of our Services to you and sharing promotional and informational content for the Services with you in accordance with your communication preferences;
• providing service and support to you for the Services;
• accounting for the Services;
• verification of your identity and the Personal Information provided by you;
• carrying out our obligations and enforcing our rights arising from any contracts entered into between you and RPI;
• improving your experiences with the Services offered by RPI;
• communicating with you to complete surveys that we use for marketing or quality assurance purposes;
• sending you promotional information related to the Services;
• combating fraud, crime and as otherwise required or permitted by law;
• sending information to you regarding changes to our Customer Terms of Service, Privacy Policy or other legal agreements; and
• for any other purpose you consent to as provided for in this Privacy Policy.

Other Uses of Personal Information

RPI will also collect, process, use and retain Personal Information for the following additional business reasons:

• to deal with any inquiries you have about how we collect, process, use and store Personal Information;
• requests made by you for a copy of Personal Information that we hold;
• for internal corporate reporting and business administration purposes;
• to establish, exercise or defend our legal rights; and
• to comply with any procedures, laws and/or regulations which apply to RPI.

Customer Testimonials and Comments

We post customer testimonials, quotes and comments on our Websites which may contain Personal Information. We obtain each customer's consent via email prior to posting the customer's name and testimonial.

Social Media Features

Our Websites include social media features, such as the "Share This" or "Like" button(s). These features may collect your IP address, which page you are visiting on our Websites, and may set a cookie to enable the feature to function properly. These social media features are either hosted by a third party or hosted directly on our Websites. This Privacy Policy does not apply to these features. Your interactions with these features are governed by the privacy policy and other policies of the companies providing them.

External Websites

Our Websites provide links to other websites. We do not control, and are not responsible for, the content or practices of these other websites. Our provision of such links does not constitute our endorsement of these other websites, their content, their owners, or their practices. This Privacy Policy does not apply to these other websites, which are subject to any privacy and other policies they may have.

Personal Information on Message Boards, Blogs, and Community Forums

We offer login-controlled access to message boards, blogs, and community forums. Please keep in mind that if you directly disclose any information through message boards, blogs, or forums, this information may be collected and used by others. We will correct or delete any information you have posted on the Websites if you so request, as described in "How You Access, Change and Control Personal Information" below.

How does Retail Pro International Use Credit Card Information?

If you provide RPI credit card information, it is solely used to collect payment for Services or engagements which you have agreed to purchase. RPI uses a PCI-DSS compliant, third-party service provider to manage credit card processing. This service provider is not permitted to store, retain, or use information you provide except for the sole purpose of credit card processing on behalf of RPI.

We Never Sell Personal Information

The Personal Information provided by you or collected as the course of automatic collection processes within the Services is collected, processed, used and stored solely for the purposes of business activity associated with the Services. RPI will never sell Personal Information to any third party.

3. How We Share Personal Information

Sharing Personal Information Across Country Borders

To facilitate our global operations, there may be times RPI is required to share or transfer Personal Information across country borders or allow access to your information from countries in which RPI or its Authorized Resellers and Service Providers have operations. This Privacy Policy shall apply even if we transfer Personal Information to other countries.

In all instances, we have taken appropriate safeguards to ensure that Personal Information will remain protected. We have taken steps to ensure that transfers of Personal Information are in accordance with applicable law and make use of standard contractual data protection clauses, which have been approved by the European Commission, and we rely on the EU-U.S. and Swiss-U.S. Privacy Shield Framework to safeguard the transfer of information we collect from the European Economic Area and Switzerland. In this course, RPI may disclose Personal Information:

• to our authorized resellers, strategic partners and global and regional offices;
• to comply with the law or in response to a subpoena, court order, law enforcement or government request, or other legal process;
• to produce relevant documents or information in connection with litigation, arbitration, mediation, adjudication, government or internal investigations, or other legal or administrative proceedings;
• in connection with any proposed or actual sale or other transfer of some or all assets of RPI, and/or any proposed or actual sale or merger of RPI or any division of RPI;
• to enforce the terms of any agreement with RPI;
• as otherwise required or permitted by law; and/or
• with your consent.

Service Providers

We may employ third-parties to provide services as a course of our marketing and sales actions and may need to share Personal Information with them. Examples could include: removing repetitive information from prospect lists, analyzing data or performing statistical analysis, providing marketing assistance, processing credit card payments, supplementing the information you provide us in order to provide you with better service, and providing customer service or support. In all cases where we share Personal Information with such agents, we explicitly require the agent to acknowledge and adhere to our Privacy Policy and customer data handling policies.

4. Access, Change and Control of Personal Information

What Information Can I Access and What Can I Delete?

You can access Personal Information on the Websites and correct, amend, or delete information in your registration profile. To do this, you may login to your account on the Website and edit your profile or contact us at privacy@retailpro.com and we can help you resolve anything you wish to change for your profile. It is important to note that certain administrative data cannot be removed.

How Do I Unsubscribe from RPI’s Communications?

You may unsubscribe from RPI’s marketing, sales and technical communications by clicking on the "unsubscribe" link located on the bottom of our e-mails, updating your communication preferences at My.RetailPro.com, or by sending us a request using the details in section in section "Contacting Retail Pro International, LLC.", below.

Communications from RPI that are sent in the course of transactional matters as they relate to your account and contractual relationship with RPI cannot be opted out of or unsubscribed from unless your account is closed.

How do I Unsubscribe from RPI’s Authorized Partner’s Communications?

RPI’s Authorized Partners are solely responsible for managing their own communications platforms. RPI cannot facilitate unsubscribing you from their communications. To unsubscribe from RPI’s authorized partner’s communication platforms please contact them directly.

Your Right to Personal Information

You have certain rights in relation to Personal Information. If you would like further information in relation to these or would like to exercise any of them, please contact us via email at privacy@retailpro.com at any time. You have the following rights:

You have a right of access to any Personal Information RPI maintains. You can ask us for a copy of Personal Information; confirmation as to whether Personal Information is being used by us; details about how and why it is being used; and details of the safeguards which are in place if we transfer Personal Information outside of the European Economic Area ("EEA"). Further details are noted below in the section "Your Rights Under EU Law"

• You have a right to request an update to any Personal Information which is out of date or incorrect.
• You have a right to ask us to delete any Personal Information which we are holding about you in certain specific circumstances. If you are entitled to deletion of Personal Information, you can make such a request by contacting via the details in section "Contacting Retail Pro International, LLC.", below.
• You have a right to ask us to restrict the way that we process Personal Information in certain specific circumstances. You can ask us for further information on these specific circumstances by contacting us using the details in section in section "Contacting Retail Pro International, LLC.", below.
• You have a right to ask us to provide Personal Information to a third-party provider of services. This right only applies where we use Personal Information on the basis of your consent or performance of a contract; and where our use of Personal Information is carried out by automated means.
• You have a right to ask us to consider any valid objections which you have to our use of Personal Information where we process Personal Information on the basis of our or another person's legitimate interest.

We will consider all such requests and provide our response within a reasonable period (and in any event within one month of your request unless we inform you we are entitled to a longer period under applicable law). Please note, however, that certain Personal Information may be exempt from such requests in certain circumstances. For example: if we need to keep using the information to comply with our own legal obligations or to establish, exercise or defend legal claims.

If an exception applies, we will tell you this when responding to your request. We may request you provide us with information necessary to confirm your identity before responding to any request you make.

Your Rights Under EU Law

If Personal Information is subject to the protections offered by European Union (EU) law, you may:

• Access, correct, update or request deletion of Personal Information, at any time by contacting us using the contact details provided under the section "Contact RPI" above;
• Object to processing of Personal Information, ask us to restrict processing of Personal Information or request portability of Personal Information;
• Withdraw your consent at any time if we have collected and process Personal Information with your consent;
• Complain to a data protection authority about our collection and use of Personal Information. For more information, please contact your local data protection authority.

To exercise any of these rights you should contact RPI in accordance with the contact details set forth below in Section "Contacting Retail Pro International, LLC." below. Please note that if you are not subject to EU law, these rights do not apply to you.

Notice of Privacy Rights to California Resident

California law requires that we provide you with a summary of your privacy rights under the California Online Privacy Protection Act (the "Act") and the California Business and Professions Code. As required by the Act, we will provide you with the categories of Personal Information that we collect through the Services and the categories of third party persons or entities with whom such Personal Information may be shared for direct marketing purposes at your request.

California law requires us to inform you of, at your request, (1) the categories of Personal Information we collect and what third parties we share that information with; (2) the names and addresses of those third parties; and (3) examples of the products marketed by those companies.

To obtain this information, please send a request by email or standard mail to the address found below. When contacting RPI, please indicate your name, address, email address, and what Personal Information you do not want RPI to share with Authorized Partners. The request should be sent to the attention of our legal department and labeled "California Customer Choice." Please allow 30 days for a response.

Email: privacy@retailpro.com
Standard Mail: Retail Pro International, LLC., Attn: Privacy, 400 Plaza Dr., Suite 200, Folsom, CA 95630, USA

5. Legal basis for processing Personal Information

We consider that the legal bases for collecting and using Personal Information as set out in this Privacy Policy are as follows:

• our use of Personal Information is necessary to perform our obligations under any contract with you;
• you have provided us with your consent to do so. You can control and withdraw your consent at any time for our Services;
• operate, maintain and improve our Services and our marketing optimization efforts;
• understand the way in which our Services are used; and
• for internal group administrative purposes.

In some cases, we may also have a legal obligation to collect Personal Information from you. If we ask you to provide Personal Information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of Personal Information is mandatory or not (as well as of the possible consequences if you do not provide Personal Information). Similarly, if we collect and use Personal Information in reliance on our legitimate interests (or those of any third party), we will make clear to you at the relevant time what those legitimate interests are.

6. Security and Retention of Personal Information

We use reasonable organizational, technical and administrative measures to protect Personal Information. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your account has been compromised), please immediately notify us in accordance with the "Contacting Retail Pro International, LLC." section, below.

Retention of Personal Information

How long the Personal Information we collect is kept depends on the type of information. We retain Personal Information that you provide to us while we have an ongoing legitimate business need to do so and it is needed to comply with our legal obligations or to resolve disputes and enforce our agreement(s) with you. When we have no ongoing legitimate business need to process Personal Information, we will securely delete the information or anonymize it. If this is not possible, then we will securely store Personal Information and isolate it from any further processing until deletion is possible.

If you have consented to receive marketing communications from RPI, we will retain information about your marketing preferences for a reasonable period of time from the date you last expressed interest in the Services. We retain information derived from cookies and other tracking technologies for a reasonable period of time from the date such information was created.

7. Contacting Retail Pro International, LLC

If you have any questions about this Privacy Policy or our treatment of the Personal Information you provide us, please notify us at:

Email: privacy@retailpro.com
Standard Mail: Retail Pro International, LLC., Attn: Privacy, 400 Plaza Dr., Suite 200, Folsom, CA 95630, USA

When contacting RPI as indicated above, we ask that you provide sufficient information to allow us to identify your account and Personal Information within our systems. We will make every effort to resolve your concerns as soon as reasonably possible.

8. Changes to this Privacy Policy

RPI periodically updates its Privacy Policy to reflect the changing landscape of Personal Information. We will post any Privacy Policy changes on this page, and when these changes are significant, we will email you with notice of the updated details within the Privacy Policy. We encourage you to review this Privacy Policy periodically.

9. Further Questions and How to Make a Complaint About Personal Information

If you have any queries or complaints about our collection, use or storage of Personal Information, or if you wish to exercise any of your rights in relation to Personal Information, please contact us via the means noted in the section "Contacting Retail Pro International, LLC." above. We will timely investigate and attempt to resolve any such complaint or dispute regarding the use or disclosure of Personal Information.

When applicable, in accordance with Article 77 of the General Data Protection Regulation, you may also make a complaint to the Information Commissioner's Office, or the data protection regulator in the country where you usually live or work, or where an alleged infringement of the General Data Protection Regulation has taken place.