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**Effective January 2020**

At Elan, Inc. (together with all successors and assigns, hereinafter **"Elan"**, **"we"**, **"us"** or **"our"**), trust has always been the foundation of our relationship with our customers and partners. This Developer Portal Privacy Policy (the **"Policy"**) applies to all commercial (i.e., non-consumer) customers and partners of Elan and identifiable individuals directly connected with such customers and partners (collectively referred to herein **"Users"**, **"you"** or **"your"**) who access and use the Elan Developer Portal (the **"Developer Portal"**). This Policy only describes and applies to Elan collection and use of information that is provided by Users, or collected about Users, at or through the Developer Portal. This Policy does not apply to any other product or service that may be offered to Users by Elan or any of its affiliates.

## 1. Types of Information We Collect

 We may collect"User Information" from Users of the Developer Portal. "User Information" includes (i) identifying information provided by, or collected about, a User through the Developer Portal that is necessary for Elan to identify the particular User; and (ii) any other information that may be provided by the User to Elan when utilizing the Developer Portal. Examples of such information include (i) any information provided by a User during the registration process in order to gain access to the Developer Portal, such as User name, postal address, email address, telephone number; (ii) other credentialing information (e.g., account number, access code, etc.); (iii) any User contact information; or (iv) any data provided by a User to Elan through the Developer Portal for purposes of developing, testing, or otherwise using in any way any application programming interface ("API") available through the Developer Portal.
For purposes of this Policy, User Information only includes information that is collected, provided, or otherwise obtained through the Developer Portal.

## 2. How We Collect Your Information

We collect User Information when you provide this information directly to Elan through the Developer Portal. In addition, some User Identifying Information may be collected about you by Elan through the use of "cookies," as explained in Section 5, below.

## 3. How We Use Your Information

User Information is used by Elan only for the following limited purposes:
- To respond to requests or inquiries from you;
- To process transactions requested by you through the Developer Portal;
- For billing and other administrative purposes necessary to manage and maintain your Developer Portal account;
- Consistent with local law, to verify your identity and/or location for security, fraud prevention and other risk control purposes;
- To provide choices and controls that may be available to you to personalize content and experiences on the Developer Portal;
- To send you information, via direct mail or electronic mail only, regarding products and services that Elan may make available to you, or about third party products and services that Elan believes may be of interest to you, changes to this Policy, and/or other similar administrative information;
- To detect, investigate and prevent activities that may violate our policies or be illegal; and
- To comply with our legal and regulatory obligations.

## 4. How We Share Your Information

 We do not share User Information with any party, affiliated or otherwise, for any purpose, except as otherwise provided in this Policy. We may share your User Information with third parties for the purpose of providing you with the services and functionality available through the Developer Portal. Elan requires all such third party service providers to maintain the confidentiality of information provided to them by us, and to use such information only to provide the specific product or service intended.
We may also share such information with third parties as follows:
- in response to subpoenas, or during the course of an audit or investigation, issued or initiated by courts, independent auditors, law enforcement agencies, or other governmental authorities, bodies or agencies;
- to prevent fraud; or
- as otherwise required by law.
Elan may share or disclose information about Users that is aggregated, anonymous or that otherwise does not identify any individual User to unaffiliated third-parties.We may share your information with Service Providers of Elan or its parent company that perform functions on our behalf.  For purposes of this Policy, “Service Providers” means agents, subsidiaries, affiliates, partners and other third parties.  The Service Providers, if any, have access to the information needed to perform their functions and are obligated to maintain the confidentiality and security of that information.

## 5. Online Tracking and Advertising

We and certain trusted service providers operating on our behalf collect information about User activity on the Developer Portal using tracking technologies, including:
- Cookies: Cookies are pieces of information that are stored directly on the device that you are using to access the Developer Portal. Cookies allow us to collect information such as the type of browser you are using, the amount of time you spend using the Developer Portal, the websites or applications you visit and the preferences you have set up for your Developer Portal account. We use this information to customize User experience, enhance security, facilitate navigation, display material more efficiently and recognize the device that you are using to access the Developer Portal. The Developer Portal does not use cookies that capture unencrypted User information. You can choose to have your device refuse to accept any cookies, and the majority of devices and browsers offer additional privacy settings for cookies. You do this through your browser settings. Each device and each browser is a little different, so look at your device settings or your browser Help menu to learn the correct way to modify your cookies. If you turn cookies off, you will not have access to many features that make your user experience more efficient and some of the Developer Portal will not function properly. Please note that you will need to manage your cookie settings for each device and browser that you use.
- Pixel tags, web beacons, clear GIF's and other similar technologies: These are typically small pieces of data that may be embedded in images on the Developer Portal or certain e-mail communications. They may involve the transmission of information directly to us, to another party on our behalf or to another party in accordance with its privacy policy. We may use these technologies to bring together information we collect about you.
Information collected through tracking technologies is used for many purposes including, for example, to:
- Provide useful features to simplify your experience when you return to the Developer Portal
- Deliver relevant content based on your preferences, usage patterns and location
- Monitor and evaluate the use and operation of the Developer Portal
- Analyze traffic on the Developer Portal and on websites or mobile applications of third parties
We may associate this tracking data with your registration information, in which case we will treat it as User Information. Service providers that collect tracking data on our behalf may provide an opportunity for you to choose not to be tracked online.
**Do Not Track.** There is no industry standard for how Do Not Track consumer browser settings should work on commercial websites. Due to the lack of such standards our websites do not respond to Do Not Track consumer browser settings.
Occasionally, you may encounter banner advertisements for our products and services on third-party websites and mobile applications. We use third-party advertising service providers to distribute our advertisements on websites and mobile applications where we have paid to advertise. These advertisements may use tracking technologies to capture information such as IP address, browser type and usage information in order to track the effectiveness of our advertising efforts. Our advertising service providers are prohibited from using any information collected except to track advertising effectiveness.
In addition, we use advertising service providers such as Google, Yahoo and Bing to place advertisements for our accounts and services on websites not affiliated with us, and to help us determine which of our advertisements are most likely to be of interest to you using non-personal behavioral information. Advertisements placed by these service providers may use tracking technologies that allow monitoring of your responsiveness to such advertisements. We restrict access and collection of information by advertising service providers for purposes other than assisting us with our advertising efforts.

## 6. Data Security

Your privacy is very important to Elan and we are committed to protecting your User Information from unauthorized access or use. We have implemented physical, technical and administrative security measures that comply with federal law and industry standards, including network firewalls, Secure Sockets Layer (SSL) encryption for online sessions, dedicated security teams and secured files and buildings. The Internet, however, is inherently unsecure, and Elan does not guarantee the security and confidentiality of information you provide through the Developer Portal.
Users have the responsibility to help Elan protect User Information by never revealing such information to unauthorized third parties.

## 7. Preventing User Information Theft

In order to help us protect your User Information, it is important that you always keep your Developer Portal account information safe, including any name, access code, account number, or other credential information used to gain access to the Developer Portal.
Note that Elan will never initiate a request via email or otherwise for your User Information. If you receive an email asking for such information, you should be suspicious of the request and promptly contact us at [devonboarding@elanfs.com](mailto:devonboarding@elanfs.com) to report the suspicious activity.

## 8. Changes to the Policy 

From time to time, we may make changes to this Policy in order to accommodate new technologies, industry practices, regulatory requirements or for other purposes. We encourage you to review this Policy periodically to ensure that you understand how we collect, use and share information through the Developer Portal. If we do make changes to this Policy, we will also update the "Effective Date" posted at the top of the Policy.
Any changes to the Policy will become effective when the revised Policy is posted on the Developer Portal. By continuing to use the Developer Portal following such changes, you are agreeing to accept the terms of the revised Policy.

## 9. Contact Us

If you have any questions or comments about this Policy, or our privacy practices generally, we encourage you to contact our customer service department by emailing us at [devonboarding@elanfs.com](mailto:devonboarding@elanfs.com).

## 10. Cross-Border Transfer 

The Developer Portal is controlled and operated by us from the United States, and are not intended to subject us to the laws or jurisdiction of any country or territory other than that of the United States. We may store and process your personal information in any country where we have facilities or in which we engage service providers, and, by using the Developer Portal, 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 of your country.
