ConnectWise, LLC. Privacy Policy

How We Collect, Use, and Share Personal Information

We primarily collect, access, use, and share Personal Information where necessary for us to market and provide Services to our clients and in the ordinary course of running our business, including through the receipt of communications such as emails, website enquiries and telephone calls.

Personal Information Collected through Our Services and ConnectWise Websites

We may collect Personal Information through our Services and ConnectWise Websites in the following ways:

Information That You Provide to Us Voluntarily

General Contact Information. We collect any Personal Information that you voluntarily provide to us when you visit a ConnectWise Website or when you subscribe for or enquire about any of our Services. For example, if you submit a sales enquiry or subscribe for a newsletter via a ConnectWise Website web form or request additional information or contact from ConnectWise via email, you will provide us with certain Personal Information, which may include names, company name, address, and email address.

In addition, if you choose to communicate with us via a web form, email, or by telephone, we will keep a copy of our communication together with your email address or phone number and our responses.

Personal Information That We Collect Automatically

Device-related Information. When you visit any ConnectWise Website or use our Services, we collect Personal Information from your device, including IP address, device type, unique device identification numbers, browser-type, broad geographic location (e.g. country or city-level location), the date and time of use of our Services, the date and time of an event on the client’s IT systems, system logs, and technical attributes about the device or a web browser. In some countries, including countries in the European Union (“EU”), the United Kingdom (“UK”), and Switzerland, this information may be considered Personal Information or "personal data" under applicable data protection laws. This Personal Information enables us to better understand use of our ConnectWise Websites and Services. Some of this Personal Information may be collected using cookies and similar tracking technology, as explained further under the heading “Cookies or Similar Technologies” below.

Cookies or Similar Technologies

ConnectWise Websites use cookies. A "cookie" is a string of alphanumeric characters. There are two types of cookies that may be used at ConnectWise's Websites: persistent cookies or session cookies. A persistent cookie gets entered by your Web browser into the "Cookies" folder on your computer and remains there after you close your Web browser. Persistent cookies may be used by your browser on subsequent visits to the site; however, session cookies are held temporarily in your computer's memory and disappear after you close your browser or shut off your computer.

If you have arrived at any ConnectWise Website by clicking on a banner ad for one of ConnectWise's products or services, a session cookie may be used. This cookie contains an identification number for the advertisement that you clicked on, and it helps ConnectWise determine which of its ads attracts the most visitors. If you choose to request further information from us about ConnectWise's products and services, the Personal Information that you provide in that request will be linked to the Personal Information in the session cookie.

In order to better understand how our sites are used, ConnectWise Websites may also use persistent cookies along with other Personal Information collected in our servers' files (e.g., IP Address, referring URLs, etc.). Each browser is different, so you should check your browser’s “Help” menu to learn how to change your cookie preferences. If you reject or block cookies, ConnectWise Websites may not function as intended.

Personal Information That We Obtain from Third Party Sources

Commercially Available Personal Information. ConnectWise may also collect Personal Information from commercially available sources, but only where we are legally permitted to do so. Such Personal Information may include names, addresses, email addresses, and demographic data. The Personal Information ConnectWise collects from these commercial sources may be combined and cross-referenced with Personal Information we collect through our Services. We use this Personal Information for communication purposes to provide direct marketing materials for our business customers or prospects.

From time to time, we may also ask our partners or clients to voluntarily provide us with the email addresses of contacts of other organizations, so they too can benefit from the various products and services offered by ConnectWise and ConnectWise's trusted affiliates. Where we do, we will confirm that they have the permission to pass on these details to us.

How We Use Personal Information Collected through Our Services and ConnectWise Websites

To Serve Our Clients. We use the Personal Information we collect, to provide our Services to the Clients on whose behalf we are acting. For example, in order to provide technical support, we may contact a user (such as employees or staff members) of ConnectWise's Clients using any contact information provided to us.

To Serve You. We use the Personal Information to respond to any request or query directed to us (for example through web forms or email), to provide you/your organization with our products and Services and to manage our relationship with you. For example, we, address any enquiries or complaints you may have, endeavor to improve the Services we provide, or provide you with information about other products and services we offer that we think you may be interested in.

For Direct Marketing. If we have the right to do so, we will use your Personal Information for the purposes of direct marketing communications to your organization, such as by adding your contact and other details to a marketing database. Where we do, we will provide you with an opportunity to opt out in accordance with section III.

For Internal and Service-Related Purposes. We may use any Personal Information we collect through the Services and/or any ConnectWise Websites for internal and service-related purposes, including providing it to third parties as necessary to allow us to provide the Services, maintain or improve ConnectWise Website security, and/or invoicing for example.

Anonymized and Aggregate Data. From time to time, we will aggregate Personal Information collected through our Services for analytics purposes, product improvement purposes and other service-related purposes.

How We May Disclose Personal Information Collected through Our Services and ConnectWise Websites

We may share Personal Information with the following categories of recipients and/or in the following circumstances:

With Our Group Companies including those listed in Schedule 1, Third-Party Vendors and Service Providers. As appropriate, we may share Personal Information with any of our group companies including those listed in Schedule 1, vendors and/or service providers in connection with the provision or marketing of the Services, ConnectWise Websites. These third parties have access to Personal Information to the extent necessary to permit them to do their jobs, however, they are bound by confidentiality agreements before any Personal Information is provided to them, and they are restricted from using the Personal Information for other purposes.

For Personal Information previously transferred to us from the EU, UK, and Switzerland, under the EU-US DPF, UK Extension to the EU-US DPF, or Swiss-US DPF we will remain liable under the Data Privacy Framework Principles if our agents or service providers process such Personal Information in a manner inconsistent with the Data Privacy Framework Principles, unless we will prove that we are not responsible. A list of service providers and partners that we use with ConnectWise Websites is available on ConnectWise’s Privacy Center.

As Required by Law and Similar Disclosures. We may disclose Personal Information: if we believe it is necessary: to comply with national security or law enforcement requests and legal process, such as a court order or subpoena; to respond to your requests; to prevent or address fraud, security, or technical issues; or to protect our property or other legal rights or the rights or property of others, or to protect the vital interests of others.

Merger, Sale, or Other Asset Transfers. If we are involved in a potential or actual merger, acquisition, financing, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider Personal Information collected through the Services or ConnectWise Websites (or both) may be sold or transferred as part of such a transaction, as permitted by law and/or contract.

Other than as stated in this Privacy Notice, we will not release Personal Information to unaffiliated third parties, and we will not cross-reference Personal Information collected through one Client’s use of our Services with that of any other Client or entity.

How We Use Personal Information Collected for Targeted Advertising.

We share Personal Information with companies involved in targeted (i.e. interest-based) advertising. Targeted advertising is advertising that is targeted to you based on your web browsing and app usage over time through the use of Cookies and other devices. This targeted advertising consists of ConnectWise [and third-party ads] that are personalized and displayed on ConnectWise Websites and through other channels. We share various types of de-identified Personal Information (i.e. Personal Information that does not disclose your name) to enable interest-based advertising.

You have the option to restrict the use of Personal Information for targeted advertising and to opt-out of receiving targeted ads.

You can control whether companies serve you targeted advertising by visiting the Digital Advertising Alliance website and using its opt-out: http://www.aboutads.info/choices/ (U.S.) http://www.youronlinechoices.com/ (EU). The DAA opt-out requires that cookies not be blocked in your browser.

As an alternative to the DAA opt–out, you can also elect to block browser cookies from first parties (such as those from our website) and browser cookies from third parties (such as advertisers) by using the cookie blocking options built into your browser software. If you block browser cookies, some parts of ConnectWise Websites may not function correctly. Also, blocking cookies will not stop third parties from collecting IP address, data stored in "Flash" cookies, and certain other types of technical information that may uniquely identify your browser.

Social Network Widgets. ConnectWise Websites may include social network sharing widgets that provide Personal Information to their associated social networks or third parties about your interactions with ConnectWise Websites that you visit, even if you do not click on or otherwise interact with the plug-in or widget. Personal Information may be transmitted from your browser and may include an identifier assigned by the social network or third party, information about your browser type, operating system, device type, IP address, and the URL of the web page where widget appears. If you use social network tools or visit social networking sites, you should read their privacy disclosures, to learn what information they collect, use, and share.

How do we transfer and store your Personal Information?

ConnectWise Websites Services and systems use servers located in the United States. If you are located outside of the United States, the Personal Data we collect will be processed and stored in the United States, a jurisdiction in which the data protection and privacy laws may not offer the same level of protection as those in the country where you are located.

Access, Integrity, Retention, and Choices

If you wish to request access to, correction, or deletion of Personal Information you have submitted through the ConnectWise Websites, you can log into your account or contact ConnectWise at privacy@connectwise.com. If you are located in the EU, UK, and Switzerland, you may have additional rights which we have set out in Section 6 below.

Data Integrity and Purpose Limitation

ConnectWise will use Personal Information only for the purpose of or in ways compatible with the purposes for which it was collected.

Information Retention

We keep Personal Information we need to provide our Services only for as long as we have a valid business purpose, in accordance with applicable law and our Client agreements. For example, we retain Personal Information for as long as it is needed to provide you with Services you have requested or to comply with applicable legal, tax or accounting requirements.

When we have no ongoing legitimate business need to process your Personal Information, we will delete it. If immediate deletion is not possible (for example, because your Personal Information has been stored in backup archives), then we will securely store your Personal Information and isolate it from any further processing until deletion is possible or unless as otherwise required by law.

User Choices

We include an “unsubscribe” hyperlink in ConnectWise marketing emails for those users who wish to stop receiving email communication from ConnectWise. The hyperlink will connect one to the ConnectWise Websites, which will confirm the email address that has been automatically unsubscribed and will no longer receive emails from ConnectWise.

Security

We take steps to ensure that Personal Information is treated securely and in accordance with this Privacy Notice which include appropriate technical and organizational measures. These measures are designed to provide a level of security appropriate to the risk of processing of your Personal Information. However, neither the Internet nor any form of electronic storage can be guaranteed to be 100% secure, and we cannot ensure or warrant the security of any Personal Information provided to us.

International Data Transfers

ConnectWise is headquartered in the US, but we are a growing corporation with operations in multiple countries. In using ConnectWise Websites, Services and/or otherwise contacting us you acknowledge that your information may be accessed and processed around the world, to us in the United States or to our affiliates, partners, merchants, or service providers elsewhere in the world, including the United Stated, EU, UK, Australia, the Philippines and India. However, we have taken appropriate safeguards to require that your Personal Information remains protected in accordance with the terms of this Privacy Notice and applicable data protection laws. We have entered into standard contractual clauses approved by the European Commission to provide appropriate safeguards for international Personal Data Transfers from the EU, UK, and Switzerland.

For users and/or visitors in the European Union (EU), United Kingdom (UK), and Switzerland

Legal Basis for processing your Personal Information

Our legal basis for collecting and using the Personal Information described above will depend on the Personal Information concerned and the specific context in which we collect it. We normally collect Personal Information from you only where we need the Personal Information to perform our contract for our Services with our Clients, where the processing is in our legitimate interests (provided these interests are not overridden by your data protection interests or fundamental rights and freedoms), or otherwise if we have your consent to do so. In some cases, we may also have a legal obligation to collect Personal Information from you, such as Know Your Customer checks or tax information.

If we ask you to provide Personal Information to comply with a legal requirement or to contact you, we will make this clear at the relevant time and advise you whether the provision of your Personal Information is mandatory or not (as well as of the possible consequences if you do not provide your Personal Information). Similarly, if we collect and use your 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 and before doing so will ensure that we have considered your rights and interests

If you have questions about or need further information concerning the legal basis on which we collect and use your Personal Information, please contact us at privacy@connectwise.com.

Your Rights

You may have the following data protection rights which you may exercise at any time by using the contact details provided under the "Complaints and How to Contact Us" section below:

• You may access, correct, update or request deletion of your Personal Information; You can object to processing of your Personal Information, ask us to restrict processing of your Personal Information or request portability of your Personal Information.
• You have the right to opt-out of marketing communications we send you at any time. In addition to using our contact details below, for email marketing communications you can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you.
• Similarly, if we have collected and process your Personal Information on the basis of your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your Personal Information conducted in reliance on lawful processing grounds other than consent.
• You have the right to complain to a data protection authority about our collection and use of your Personal Information. For more information, please contact your local data protection authority. (Contact details for data protection authorities in the European Union are available here. in the United Kingdom are available here, and in Switzerland are available here.)

We will respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

Please note, if you are an individual whose Personal Information ConnectWise processes as a "data processor", for example to provide services on behalf of its Clients, you must contact the relevant data controller of your Personal Information in order to exercise your rights. This might be one of our Clients or one of our Clients' customers.

Data Privacy Framework Policy

ConnectWise and its U.S. entities & subsidiaries listed in Schedule 1 have certified with the EU- US Data Privacy Framework (“EU-US DPF”), the UK Extension to the EU-US DPF, and the Swiss-US Data Privacy Framework (“Swiss-US DPF”) as set forth by the US Department of Commerce regarding the processing of certain Personal Information from Switzerland and the European Union member countries and from the United Kingdom (and Gibraltar). We have certified that we adhere to the EU-US DPF Principles with regard to the processing of personal data received from the European Union in reliance on the EU-US DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-US DPF. We have certified to the U.S. Department of Commerce that it adheres to the Swiss-US DPF Principles with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-US DPF Principles, and/or the UK Extension to the EU-US DPF and/or the Swiss-US DPF Principles, the Data Privacy Framework Principles shall govern. To learn more about the Data Privacy Framework program, and to view our certification page, please visit https://www.dataprivacyframework.gov.

If you have any inquiries or complaints about our handling of your Personal Information previously transferred to the US under the the EU-US DPF, UK Extension to the EU-US DPF, or Swiss-US DPF, you should first contact us at privacy@connectwise.com and we will respond to your inquiry promptly. If we are unable to satisfactorily resolve your complaint, or we fail to acknowledge your complaint in a timely fashion, we have further committed to cooperate and comply with the panel of European data protection authorities (DPAs) in the resolution of any Data Privacy Framework complaints. If you reside in the EU, UK, and Switzerland, you may also have the opportunity under certain conditions to invoke binding arbitration for complaints regarding the Data Privacy Framework not resolved by the above mechanisms. For more information, please see the "Complaints and How to Contact us" section below.

ConnectWise is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC) and of other relevant US statutory bodies authorized to verify and ensure compliance with the Data Privacy Framework Principles.

For users in Australia

ConnectWise complies with the Australian Privacy Principles as set out in the Privacy Act 1988 (“Privacy Act”) regarding the collection, storage, use and disclosure of Personal Information from Australian users.

In addition to the uses set out in the section titled “How We Use Information Collected through Our Services and ConnectWise Websites”, we may also use your information, including Personal Information, for a secondary purpose that is related to a purpose for which we collected it, where you would reasonably expect us to use your Personal Information for that secondary purpose.

Under the Privacy Act, we have an obligation (the “Obligation”) to take reasonable steps, in the circumstances, before disclosing Personal Information to an overseas recipient to ensure that the overseas recipient does not breach privacy laws in relation to that information. However, should we obtain your consent to disclose your Personal Information to an overseas recipient, the Obligation does not apply. In obtaining your consent, we will not be accountable, and you will not be able to seek redress against us under the Privacy Act if the overseas recipient handles your Personal Information in breach of the Australian Privacy Principles (“APPs”) under the Privacy Act. In providing your consent under this Privacy Notice, you acknowledge and agree to the risks associated with the disclosure of your Personal Information overseas. These risks may include the overseas recipient not being subject to any privacy obligations or privacy principles similar to the APPs and the overseas recipient being subject to foreign law that could compel the disclosure of your Personal Information to a third party, such as an overseas authority.

If you are a user in Australia and wish to access, correct or update your information in accordance with section III, ConnectWise may refuse certain requests but only in circumstances where this is permitted under the Privacy Act.

Children’s Privacy

We do not knowingly collect, store, or use information from children, including those under the age of 13. If you are under the age of 13, you may not submit any information through the ConnectWise Websites or Services. If you have reason to believe that a child under the age of 13 has provided information to us through the ConnectWise Websites or Services, please contact us and we will endeavor to delete that information from our databases.

Do Not Track

The ConnectWise Websites currently do not respond to “Do Not Track” (DNT) signals and operate as described in this Privacy Notice whether or not a DNT signal is received.

Your California Privacy Rights (California Residents Only)

Under Section 1798.83 of the California Civil Code, residents of California have the right to request from a business, with whom the California resident has an established business relationship, certain information with respect to the types of Personal Data the business shares with third parties for those third parties’ direct marketing purposes, and the identities of the third parties with whom the business has shared such data during the immediately preceding calendar year.

To exercise your rights, you may make one request each year by emailing us at privacy@connectwise.com with “Request for California Privacy information” on the subject line and in the body of your message. Be sure to provide in the request sufficient information to properly identify you and/ or the members of your family.

ConnectWise processes certain Personal Information as a business under the California Consumer Privacy Act (“CCPA”). This Personal Information relates to business transactions within the scope of Section 1798.145(n) of the CCPA. California residents have limited rights under the CCPA in connection with this personal data. ConnectWise offers the right to opt out of the sale of this Personal Information on the ConnectWise websites.

Changes to This Privacy Notice

We may update this Privacy Notice to reflect changes to our information practices from time to time. If we decide to change this Privacy Notice, we will post the changes on this page so visitors to the ConnectWise Website and our clients and the users of their IT systems are aware of our practices, and we will change the “Last Updated” date above. If we make a material change to our information practices, such as to how we use Personal Information, we will make reasonable efforts to provide notice on our website and/or through our clients and obtain consent to any such uses as may be required by law.

Complaints and How to Contact Us

DPO: Our Data Protection Officer is currently Fieldfisher LLP. Please continue to use the contact details outlined below to contact the DPO.

If you have any questions, comments, or concerns about this Privacy Notice or our information practices, please email us at privacy@connectwise.com.

If you don’t receive adequate resolution of a privacy-related problem, you may write to our Chief Compliance Officer at:

Chief Compliance Officer
ConnectWise, LLC
PO Box 172100
Tampa, FL 33672 USA

For EU, UK, and Swiss Individuals: If a complaint cannot be resolved by any of the mechanisms described above, you also have a right, under certain conditions, to invoke binding arbitration under the Data Privacy Framework in compliance with the EU-US DPF, UK Extension to the EU-US DPF, or Swiss-US DPF. If you want to initiate this arbitration procedure, you are required to first formally notify us of your intention to do so by writing to privacy@connectwise.com. Please remember to include a summary of the steps you have already taken to resolve your complaint and a description of the alleged violation.

If your complaint cannot be resolved through ConnectWise’s internal process, we have further committed to refer such complaints, under the Data Privacy Framework Principles to utilize JAMS as an alternative dispute resolution provider. Information regarding JAMS and the process for initiating a claim can be found at https://www.jamsadr.com/DPF-Dispute-Resolution. In addition, EU, UK, and Swiss individuals have the right to complain to EU data protection authorities.

ConnectWise's EU, UK, and Swiss representative is DataRep, contact at privacy@connectwise.com.

For Australian individuals: if a complaint cannot be resolved by any of the mechanisms described above or for more information on your privacy rights, you may contact the Office of the Australian Information Commissioner at:

Phone: 1300 363 992. If calling from outside Australia: +61 2 9284 9749
Fax: +61 2 9284 9666
Email: enquiries@oaic.gov.au
Address: GPO Box 5218, Sydney NSW 2001

Schedule 1

ConnectWise’s U.S. entities & subsidiaries certifying to the Data Privacy Framework:

Continuum Managed Services Holdco LLC
Perch Security, Inc.
StratoZen, Inc.