We at Keystone (Keystone Strategy and our subsidiaries and affiliates) are committed to protecting your privacy. This privacy policy applies to our applications, software, websites, APIs, products, and services including our associated mobile applications ("Mobile Apps"), (each a "Site", "Service", or "Mobile App" or collectively, the "Services"), owned and controlled by Keystone.

This Privacy Policy governs our data collection, processing and usage practices. It also describes your choices regarding use, access and correction of your personal information. If you do not agree with the data practices described in this Privacy Policy, you should not use our Services.

Specifically, this Privacy Policy covers:

Information we collect and how we use it:

We may collect Personal Information, Usage and Device Information (collectively, "information", defined in detail below) about you in connection with your (or your organization’s) use of our Services that link to this Privacy Policy.

We use the information we collect only in compliance with this Privacy Policy. We may use your information to provide services (either directly to you or to those third parties who have engaged us as service providers to process your information on their behalf); respond to inquiries and provide customer support and technical assistance; communicate with you; process transactions; improve, develop, provide content for, operate, deliver and market our Services; implement social networking features; comply with our company policies and procedures and with applicable law; ensure proper and authorized use of the Services; perform Services tracking and analysis; and, as otherwise permitted by applicable law.

Your continued use of the Website following the posting of revised Terms of Use means that you accept and agree to the changes. You are expected to check this page from time to time so you are aware of any changes, as they are binding on you.

Job Applicants and Employees:

This Privacy Policy does not apply to job applicants or employees, which are subject to relevant privacy notices. This Privacy Policy does not apply to the extent that:

• Our products and services set forth an additional or alternative Privacy Policy; or

• Applicable law imposes different processing or privacy requirements on your information.

Links to other websites:

Our Services may contain links to other websites or services that are not owned or controlled by Keystone, including links to websites of our sponsors and partners. This Privacy Policy only applies to information collected by our Services. We have no control over these third-party websites, and your use of third party websites and features are subject to privacy policies posted on those websites. We are not responsible or liable for the privacy or business practices of any third-party websites linked to our Services. Your use of third parties’ websites linked to our Services is at your own risk, so we encourage you to read the privacy policies of any linked third-party websites when you leave one of our Services.

Security of your personal data:

We work hard to keep your data safe. We use a combination of technical, administrative, and physical controls to protect the confidentiality, integrity and availability of your data. This includes using Transport Layer Security ("TLS") to encrypt data transmission and Advanced Encryption Standard ("AES") to encrypt data storage. No method of transmitting or storing data is completely secure, however. If you have a security-related concern, please contact Customer Support or our Security team.

Use of cookies on the site:

We may use “cookies” and similar technologies to help deliver our Services. This technology may involve placing small files/code on your device or browser that serve a number of purposes, such as remembering your preferences and to offer you a more personalized user experience. Read our Cookie Policy to learn more.

Who we share your personal data with:

We may share your information with our business units, affiliates, subsidiaries, business partners, service providers and/or your representatives, in order to provide or improve our Services to you. We do not share information with third parties so that they can independently market their own products or services to you unless we have explicitly given you the option to opt-in such disclosures. We will never sell your Personal Information to any third party.

DEFINITIONS

1. The data controller is the person or company that, together or jointly with others, determines the purposes (why) and means (how) of the processing of personal data.

2. Personal data is any information that relates to an individual who is identified or identifiable, for instance by reference to a name, an identification number or an online identifier.

3. Standard Contractual Clauses are an agreement that can be entered into by companies for transfers of personal data outside of the European Union. They are a mechanism approved by the European Commission to ensure adequate safeguards to personal data when it is transferred outside of the European Union.

4. Anonymizing means transforming data in such a way that it is no longer identifiable, i.e. the data can no longer be linked to an individual, even if combined with other information. Anonymous data is not considered “personal data”.

5. Pseudonymizing means transforming data in such a way that it is no longer identifiable without the use of additional information. Pseudonymous data is still considered “personal data”.

CONTACT

If you have any questions about this Privacy Policy or how Keystone handles your personal data, please contact our Data Protection Officer or Privacy Officer at privacy@keystonestrategy.com.

Email: privacy@keystonestrategy.com

Post: 116 Huntington Avenue, Floor 12, Boston, MA 02116

Telephone: +1-617-224-9100