WHISTLEBLOWER POLICY

1. Purpose

The Whistleblower policy is designed to encourage Board members, leadership, staff (paid and volunteer), and others to report suspected or actual occurrences of illegal, unethical, or inappropriate events without fear of retribution. This policy aims to uphold integrity, transparency, and accountability within the organization while ensuring a safe environment for all stakeholders.

2. Scope

Applies to all employees, contractors, vendors, and stakeholders of the organizations.

3. Abbreviations & Definitions:

Investigators:

Individuals or groups authorized or consulted by the Group CISO, which may
include Aithent’s auditors and law enforcement.

Protected Disclosure:

Any report made in good faith by an employee or director revealing
unethical, illegal, or improper behaviour that violates Aithent’s Code of Conduct.

Subject:

The individual against whom a Protected Disclosure has been made.

Whistleblower:

Personnels who makes a report under this Policy.

2. Other Information

Other Information We May Collect

“Other Information” is any information that does not reveal your specific identity or does not directly relate to an individual, such as:

  • Browser information
  • Information collected through cookies, pixel tags and other technologies
  • Demographic information and Other Information provided by you
  • Aggregated information
  • Zip code

How We May Collect Other Information

We and our third-party service providers may collect Other Information in a variety of ways, including:

  • Through your browser: Most Internet browsers transmit certain information to websites that you visit, such as your computer’s type (Windows or Macintosh) and its Media Access Control (MAC) address and screen resolution, and the type and version of your computer’s Operating System and browser. We use this information to ensure that the Sites functions properly.
  • Using cookies: Cookies are text files, containing small amounts of information, which are downloaded to your browsing device (such as a computer or smartphone) when you visit a website. Cookies allow us to recognize your browsing device to assist with your use of the Sites. This can include helping us understand how our Sites are being used, letting you navigate between pages efficiently, remembering your preferences, and generally improving your browsing experience. Cookies can also help ensure marketing you see online is more relevant to you and your interests.
    • If you do not want information to be collected through the use of cookies on your computer, there is a simple procedure in most browsers that allows you to automatically decline the transfer of cookies to your computer, or to be given the choice of declining or accepting a particular cookie (or cookies) from a particular website. If cookies are disabled, however, some features of the Sites may not operate as intended. Information about procedures to disable cookies can be found on your Internet browser provider’s website.
  • Using applications: We may use applications, including mobile applications or widgets, to collect information from you.
  • Using pixel tags and other similar technologies: Pixel tags (also known as web beacons and clear GIFs) may be used in connection with some Sites pages and HTML-formatted email messages to, among other things, track the actions of Sites users and email recipients, measure the success of marketing campaigns and compile statistics about Sites usage and response rates.
  • IP Address: Your “IP Address” is a number that is automatically assigned to the computer that you are using by your Internet Service Provider (“ISP”). An IP Address is identified and logged automatically in our server log files whenever a user visits the Sites, along with the time of the visit and the page(s) that were visited. Collecting IP Addresses is standard practice on the Internet and is done automatically by many websites. We use IP Addresses for purposes such as calculating Sites usage levels, helping diagnose server problems and administering the Sites.
  • From you: We collect information when voluntarily provided by you, such as your company, title, interests and preferred means of communication. Unless combined with Personal Information, such information does not personally identify you or any other user of the Sites.
  • By aggregating information: Aggregated Personal Information does not personally identify you or any other user of the Sites. For example, we may aggregate Personal Information to calculate the percentage of our users who have a particular telephone area code.

How We May Collect Other Information

Please note that we may use and disclose Other Information for any purpose, except where we are required to treat Other Information as Personal Information under applicable law. In those situations, we may use and disclose Other Information for the purposes for which we use and disclose Personal Information, as well as for the uses listed in the “How We May Collect Other Information” section above.

In some instances, we may combine Other Information with Personal Information (such as combining your name with your company and title). If we combine any Other Information with Personal Information, the combined information will be treated by us as Personal Information if it is so combined.

3. Third-Party Sites

This Privacy Policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including any third-party operating any site to which this Sites contains a link. Please read the terms, conditions and policies of such third-party sites before accessing or using such sites. The inclusion of a link on the Sites does not imply any endorsement of the linked site by us or by our affiliates.

4. Security

We use reasonable organizational, technical and administrative measures to protect Personal Information under our control. Unfortunately, no data storage system or method of data transmission over the Internet can be guaranteed to be 100% secure. Please do not send sensitive or confidential information to us by email or by any other means in connection with the Sites. If you have reason to believe that your communications with us have been compromised in any way, please immediately notify us of the problem by contacting us as provided in the “Contacting Us” section below.

5. Choices and Access

Your Choices Regarding Our Use of Your Personal Information for Marketing Purposes

If you no longer wish to receive marketing-related emails from us on a going-forward basis, you may opt-out of receiving these marketing-related emails by following the unsubscribe instructions in any such message, by emailing us at info(at)aithent(dot)com. We aim to comply with such request(s) as soon as reasonably practicable. Please note that if you do opt-out of receiving marketing-related emails from us, we may still send you administrative messages; you cannot opt-out from receiving administrative messages.

How you can Access, Change, or Suppress Your Personal Information

You may request to review, correct, update, suppress or otherwise modify any Personal Information that you have previously provided to us through the Sites, or object to the use of such personally identifiable information by us. You may exercise these rights by writing to us at info(at)aithent(dot)com. Additionally, you may also oppose the processing or transferring of Personal Information to the extent the laws of your country require, if you have a legitimate reason to do so.

In your request, please make clear what information you would like to have changed, and whether you would like to have your Personal Information suppressed from our database or otherwise let us know what limitations you would like to put on our use of your Personal Information. For your protection, we will only implement requests with respect to the Personal Information associated with the email address that you use to send us your request, and we may need to verify your identity before implementing your request. We aim to comply with requests as soon as reasonably practicable.

Please note that we may need to retain certain information for recordkeeping purposes, and there may also be residual information that will remain within our databases and other records. Such information will not be removed. We may, from time to time, re-contact former users of the Sites. Finally, we are not responsible for removing information from the databases of third parties (such as service providers) with whom we have shared your Personal Information.

6. Special Notification for Individual California Users

As noted above, we may disclose Personal Information to affiliates Aithent. Such affiliates may use this information for all purposes outlined in this Privacy Policy. Because separate legal entities are considered “third parties” for purposes of California Civil Code Section 1798.83, and certain communications from our affiliates might be viewed as promoting their services, we are providing the following information for California residents who have provided us with their Personal Information during the creation of or during the course of an established services relationship that is primarily for personal, family, or household purposes (“Individual California Users”). Individual California Users may request information about our disclosures of certain categories of Personal Information to third parties (i.e., our affiliates) for such third parties’ direct marketing purposes. Such requests must be submitted to us by email at info(at)aithent(dot)com.

Within thirty (30) days of receiving such a request, we will provide a list of the categories of Personal Information disclosed to third parties (i.e., our affiliates) for their direct marketing purposes during the immediately preceding calendar year, along with the names and addresses of such third parties. You may make such a request no more than once per calendar year. We reserve our right not to respond to requests submitted other than to the email or mailing addresses specified in this section.

7. Implementation

We have internal arrangements in place to ensure compliance with this Policy, to allow effective exercise of individuals’ rights set out in this Policy and under applicable law, and to deal with any concerns from individuals that Aithent may not have complied with the Policy and/or applicable law. All individuals can leverage these arrangements and/or exercise their rights by contacting us by email at info(at)aithent(dot)com.

8. Retention Period

We will retain your Personal Information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or allowed by law.

9. Use of Site by Minors

The Sites is not directed to individuals under the age of thirteen (13), and we request that these individuals do not provide Personal Information through the Sites.

10. Cross-Border Transfer

Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using our Sites you consent to the transfer of information to countries outside of your country of residence, including the United States, which may have different data protection rules than those in your country.

11. Sensitive Information

We ask that you not send us, and you not disclose, any sensitive Personal Information (e.g., Social Security numbers, credit card or other payment card information, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, criminal background or trade union membership) on or through the Sites or otherwise to us.

12. Contacting Us

If you have any questions about this Privacy Policy, please contact us by email at info(at)aithent(dot)com, or please write to the following postal address: 19 Fulton Street, #408, New York, NY 10038 USA.

Please note that email communications are not secure; accordingly, please do not include credit card information or other sensitive or confidential information in your emails to us.

Last Update on 29 April 2022