We've written this privacy policy to tell you what we will and will not do with your information. It covers two different things: The DevResults application, which is the cloud-based software as a service, delivered to paying organizations at a custom domain name (for example, your-program.devresults.com); and the DevResults public website, which is what you're viewing now.

Information Collected Via the DevResults Software Application (And How We Use It)

Your organization's information

The DevResults software application (the "App") is designed to store and maintain information about your organization and its work. We understand that some or all of this information may be sensitive or confidential, and we have implemented a comprehensive security framework so that only registered users and our authorized staff have access to your organization's information and specific webpage within the App (the "Secured Site").

You and your organization have control over what information your organization provides to the App, and our staff will only access your information to support your use of the App. Our support of your use of the App will largely be at your request and authorization, but may include actions we take to ensure the security, integrity, and good working order of the App, Site, and information. In rare cases we may need to allow technical staff from our vendors access to our databases for troubleshooting, maintenance, or support services. These support vendors may only use the information on our databases as necessary to provide these support services to us. Except as stated in this policy or where we are required by law or court order, we will not disclose your organization's information to third parties without your express authorization.

While we own and retain all rights in the software code to the App, the information you store in the App belongs to you. At your request, at any time and for any reason, we will export your information and provide it to you (as long as all subscription fees have been paid). We will retain your organization's information for as long as your account is active, or as needed to provide services to you and/or your organization.

The DevResults application is software as a service, delivered to paying organizations at a custom domain name.

Your Personal Information

We collect Personal Information and Anonymous Information from you when you visit the Public and Secured Sites, use our App services, and/or send us information or communications. "Personal Information" means information that allows someone to identify or contact you, including, for example, your name, address, telephone number, e-mail address, IP Address, and any information about you that is associated with or linked to any of these types of information. "Anonymous Information" means information that is not associated with or linked to your Personal Information. Anonymous Information does not permit the identification of individual persons. We collect and use Personal Information and Anonymous Information as described in this Privacy Policy.

How We Collect Your Personal Information

Personal Information You Voluntarily Provide

Your company or organization will create an account for you with basic information such as your full name, phone number, company or organization name, and email address, creating your user profile. After that account has been created, you can modify your Personal Information at any time and, if you would like, add a photo to your user profile. If you need to delete your account, you must notify your system administrator, who will delete your account for you.

Cookies

To make the App more useful to you, as you access or use the Secured Site we use technological means to collect Personal Information from you, including the Uniform Resource Locator (URL) you just came from, the URL you go to next, your browser type, and your Internet Protocol (IP) address. We may also use cookies to collect Personal Information from you about your use of our Sites.

An "IP Address" is a number that is automatically assigned to your computer when you use the Internet. In some cases your IP address stays the same from browser session to browser session. However, if you use a consumer internet access provider, your IP address probably varies from session to session. We track IP addresses solely in conjunction with session cookies to analyze our web page flow.

In addition to our use of cookies for internal administrative and site-evaluation and optimization purposes, the App uses cookies for important security and user preference purposes, including: to confirm that you're an authorized user; to remember your login credentials; and to remember your preferences and settings. These cookies are essential to the security and performance of the App and cannot be disabled. While you are not required to consent to the use of cookies in conjunction with the App, realize that you will not be allowed to access the Secured Site or use the App unless the cookies are enabled and you consent to their use. Your browser must accept cookies in order for you to use the App.

To enable you to make an informed decision regarding consenting to our use of cookies on the App and Secured Site, we have provided additional information regarding the types of cookies we use:

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These cookies are not shared with other websites, and DevResults will not disclose the information collected with these cookies to third parties, except as described in this policy.

How We Use Your Personal Information

We utilize the information we collect from you, whether voluntarily provided by you or collected via technological means, to perform important administrative and security functions. By monitoring and analyzing such information, we are able to authenticate Secured Site users, improve the function of the App, provide support and security services, and protect the integrity of your organization's data. We will retain your Personal Information for as long as your account is active, or for as long as your Personal Information is needed for legal or security purposes.

Analytics and logs

Our App servers log every request and store these logs in files that are available to us for analysis. We also use analytics technologies that run in the browser to record usage.

We use this data in aggregate to:

• analyze trends
• monitor security threats
• administer the site
• understand typical usage patterns on the site; and
• gather technical information about our user base (for example, what versions of which browsers are in use).

Aggregate customer data

We may run queries across all customer data to produce impressive-sounding aggregate numbers for a number of legitimate and lawful purposes, including for administrative, security, system analytics, and self-promotion. For example, we might say "X people in Y countries around the world are using DevResults to manage $Z worth of development programs." This information is anonymous, and it will only be stored in an aggregate form that is not traceable to a specific person or organization. It will never be presented in a way that can be traced to you, your projects, your organization, or specific individuals within your organization.

We will not perform any automated decision-making processes on the information that we collect.

Disclosure of Your Personal Information

We may share Anonymous Information for any legitimate business purpose allowed under the applicable laws and regulations without notification or consent.

We may share your Personal Information with third parties who perform services for us or on our behalf for any legitimate purpose allowed under the applicable laws and regulations (see section titled "Your Rights Regarding Your Information," below) including for technical support or security purposes. If we disclose your Personal Information in this manner, the third party recipients of your Personal Information will be bound by the terms of this policy.

Additionally, we may share some or all of your Personal Information with "Affiliates" (parent company, subsidiaries, joint ventures, or other companies under common control), in which case we will require our Affiliates to honor this Privacy Policy. If our company or our assets are acquired by another company, that company will possess the Personal Information collected by us and it will assume the rights and obligations regarding your Personal Information as described in this policy.

Some of the third parties or Affiliates to which we might disclose your Personal Information may be international organizations or organizations that were formed in the United States. If we share your Personal Information with such third parties or Affiliates, we will use appropriate methods to transmit your information in accordance with all applicable laws and regulations. Such methods may include the Privacy Shield framework, Standard Contractual Clauses, or binding corporate bylaws.

In all cases where we disclose or transfer your Personal Information to third parties or Affiliates, we are liable for any unlawful use of your Personal Information by such third parties or Affiliates.

We may be required to disclose your Personal Information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Information Collected Via the DevResults Public Website (And How We Use It)

Similar to the Secure Site, we collect certain Personal and Anonymous Information from users of the Public Site in order to enhance our demo product, protect the integrity of the demo, and to maintain the Security of the Public Site. We may collect this information via a mixture of voluntary disclosure and technological tools such as cookies. Generally, we will not disclose Personal Information collected from the Public Site to third parties, excepting disclosure related to security, administrative, or technical support purposes. However, we reserve the right to share your Personal Information for any legitimate purpose allowed under the applicable laws and regulations (see section titled "Your Rights Regarding Your Information," below). If we disclose your Personal Information in this manner, third party recipients of your Personal Information shall be bound by the terms of this policy. Additionally, we may disclose Anonymous or Aggregate Information that is not traceable to you or any specific Public Site user.

Note: DevResults is not responsible for protecting the privacy of Personal Information that you have voluntarily published or shared with the general public (see subsection titled "Information You Enter in the Demo," below). The website you are currently viewing (www.devresults.com), the blog ( blog.devresults.com), and the demo site (demo.devresults.com) are freely available to the general public.

How We Collect Your Personal Information

Demo Sign-Up

When you sign up for access to the DevResults demo website using the form at www.devresults.com/demo, (the "Public Site") you will be asked to provide your name, email address, and the name of your program or organization. In addition, you may choose to optionally provide a note about what you're doing and what you need.

We don't share this information; we use it to better understand who is interested in DevResults. We may also use your email address to politely follow-up with you, or send you updates regarding our services and our App. However, we will not use this information to send you bulk marketing communications, and you may opt-out of receiving updates at any time.

Information you enter in the demo

Please do not enter any sensitive or private information on the Public Site. Anything you upload or type into the Public Site is visible to the public, until the next time the demo is reset with randomly-generated data. DevResults is not responsible for the disclosure or third party use of information you voluntarily enter into the Public Site .

Cookies

The DevResults public website does not use any first-party cookies; it uses third-party cookies as described above. For more information about the types of cookies used on the Public Site, please see the subsection entitled "Cookies," above.

How We Use Your Personal Information

Analytics and logs

Our Public Site servers log every request, and store these logs in files that are available to us for analysis. We also use analytics technologies in the browser to record traffic and usage. We use this data in aggregate to analyze trends in global interest in DevResults.

Email Communications

On occasion, we may send out informational emails — updates on new functionality, tips for using the software, etc. You have the right to opt-out of these communications at any time by following the unsubscribe directions included in such emails.

Information Security

We pride ourselves in a robust information security program that guards the safety and privacy of your data. We implement industry best practices to protect your information from loss, destruction, misuse, unauthorized access or disclosure. Please see our security statement for more information.

Your Rights Regarding Your Information

We respect your rights with respect to your Personal Information and want you to be in control of how your Personal Information is used by DevResults. You can do this by using the process described in the below section called "How to Inquire About or Enforce Your Privacy Rights".

Subject to local law, you can control your personal information in the following ways:

• You can ask us to see and/or obtain a copy of the personal information we hold about you;
• You can inform us of any changes to your personal information, or if you want us to correct any of the personal information we hold about you;
• In certain situations, you can ask us to erase, block, or restrict the personal information we hold about you, or object to the particular ways in which we are using your personal information; and
• In certain situations, you can also ask us to send the personal information you have given us to a third party.

Where we are using your personal information on the basis of your consent, you are entitled to withdraw that consent at any time. Moreover, where we process your personal information based on legitimate interest or the public interest, you have the right to object at any time to that use of your personal information.

We will take all reasonable steps to ensure that your Personal Information is handled with respect for your wishes.

In some circumstances, we may not be able to comply with your requests related to your Personal Information. In those cases, we will explain why our collection and use of your Personal Information is legitimate and allowed under the applicable laws and regulations, and share information with you about how you can object to the relevant Supervisory Authorities if you think our continued use is improper.

There are many legitimate and lawful ways that we may use the Personal Information we collect without your consent. These uses, among others, may include:

1. Complying with legal obligations, for example, tax, employment, and other laws or regulations;
2. Fulfilling our contractual obligations to you;
3. Fulfilling our legitimate business interests and purposes, whether performed by ourselves or a third party, so long as that purpose does not override your fundamental rights and freedoms;
4. Preventing fraud;
5. For internal administrative purposes, whether your data is maintained internally or shared with our subsidiaries and affiliates, franchisees, or third party contractors for this purpose;
6. Ensuring network and information security;
7. Establishing, exercising, or defending against any legal claims; or
8. Using your personal information in accordance with any valid consents you have given.

To request access to, correct, object to our use and retention of your Personal Information, or to exercise any of your rights related to your Personal Information, please submit your request using the process described in the below section called "How to Inquire About or Enforce Your Privacy Rights".

In addition to submitting requests or objections directly to us, depending on where you live or are a citizen, you may also have the right to lodge a complaint with an appropriate Supervisory Authority if you believe we are unlawfully retaining or misusing your Personal Information. Depending on where you live or are a citizen, you also may have the right to a judicial remedy if it is determined that your Personal Information is being used illegally. Under certain conditions, you may also have the right to invoke binding arbitration for complaints regarding Privacy Shield compliance not resolved by any of the other Privacy Shield mechanisms; for additional information, please see: https://www.privacyshield.gov/article?id=ANNEX-I-introduction.

How to Inquire About or Enforce Your Privacy Rights

In compliance with the Privacy Shield Principles, DevResults commits to resolve complaints about our collection or use of your Personal Information. European Union and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact DevResults using the information in the below “Contact Us” section or by email at privacy@devresults.com.

DevResults commits to cooperate with the panel established by the EU Data Protection Authorities (DPA) and the Swiss Federal Data Protection and Information Commissioner and comply with the advice given by the panel and Commissioner with regard to data transferred from the EU and Switzerland.

Privacy Shield Notice

DevResults is committed to subjecting to the Privacy Shield Principles all personal data received from the EU and Switzerland in reliance on the respective Privacy Shield Frameworks.

DevResults complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of Personal Information transferred from the European Union and Switzerland to the United States. DevResults has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.

DevResults is subject to the Federal Trade Commission’s investigatory and enforcement powers with regard to the Privacy Shield.

Currently, DevResults does not maintain any other entities or subsidiaries related to the Secure Site, Public Site, or App. Therefore, there are no other entities or subsidiaries related to DevResults that also adhere to the Principles.

In compliance with the Privacy Shield Principles, DevResults commits to resolve complaints about our collection or use of your personal information. European Union and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact us using the information in the below “Contact Us” section.

DevResults commits to cooperate with the panel established by the EU Data Protection Authorities (DPA) and the Swiss Federal Data Protection and Information Commissioner and comply with the advice given by the panel and Commissioner with regard to data transferred from the EU and Switzerland.

Additionally, under certain circumstances, you may be entitled to invoke binding arbitration for complaints regarding Privacy Shield compliance that has not been resolved by any of the other Privacy Shield mechanisms. For more information, please visit: https://www.privacyshield.gov/article?id=ANNEX-I-introduction.

GDPR Requests

Depending on where you live or are a resident, you may have the right to manage your personal information, including accessing, correcting, or modifying the data we have, as well as requesting that we delete it from our systems. DevResults may not be able to fulfill every request we receive, but we will respond as soon as possible, and certainly within 30 days after receiving your request, and will let you know if and why we are not able to comply.

Regardless of where you live or are a citizen, we take your privacy seriously and will do our best to respond to every request we receive with questions about how your personal information is used.

We rely on you to ensure that your personal information is complete, accurate, and current. Please inform us promptly of any changes to, or inaccuracies of, your personal information by contacting us using the information in the below "Contact Us" section. We will respond to your request as soon as possible but certainly within 30 days.

If you have a concern about our handling of your personal information or your request, please get in contact with us first so we can try to resolve your concerns using the below contact information. We are committed to working with you to obtain a fair resolution to any complaint or concern you may have about our use of your personal information. If, however, you believe that we have not been able to assist with your request, complaint, or concern, you may have the right to lodge a complaint with the data protection authority in your country (if one exists in your country) or supervisory authority. You may also have a right to a judicial remedy if it is determined your personal information is being used illegally.

A Final Note From Our Lawyers

We may update this statement from time to time. You can always find the current version at www.devresults.com/privacy. If you do not accept the terms of this statement, your only remedy is to stop using the Secure Site, the Public Site, and the App. If we make any changes that we determine are material, we will notify our customers in advance either by email or by a notice on the Secure and Public Sites (or both).

We do not intentionally gather Personal Information about visitors who are under the age of 13. Furthermore, we do not intentionally allow visitors under the age of 18 to register for the services. If a child under 13 submits Personal Information to us and we learn that the Personal Information is the information of a child under 13, we will attempt to delete the information as soon as possible. If you believe that we might have any Personal Information from a child under 13, please contact us using the information in the below "Contact Us" section.

By using this site, you represent that you are at least the age of majority in your state or province of residence, or that you are the age of majority in your state or province of residence and you have given us your consent to allow any of your minor dependents to use this site.

Our provision of a link to any other website or location is for your convenience and does not signify our endorsement of such other website or location or its contents. We have no control over, do not review, and cannot be responsible for, these outside websites or their content. Please be aware that the terms of our Privacy Policy do not apply to these outside websites, and these websites maintain their own Terms of Service and Privacy Policy. We are not responsible for the privacy practices of any third party websites linked to our Secure Site, Public Site, or App, and we encourage you to read their terms and privacy statements if you wish to utilize such third party websites.

Contact Us

If you have any general questions about our Privacy Policy or how we collect, use, or share your personal information, or would like to manage your personal information as permitted under the GDPR, please contact our Privacy Officer at the below email or mailing address:

Email: privacy@devresults.com

Attn: Privacy Officer
DevResults
655 New York Avenue NW
6th Floor
Washington, DC 20001

Effective Date: September 28, 2021

Privacy Policy Location: https://www.devresults.com/privacy