Effective Date: January 1, 2020.

Privacy Statement

Proteus International, Inc. (“Proteus”, “we”, or “us”) understands that your privacy is important to

you. Protecting your personal data is our priority. This Privacy Statement describes how we, as a data

controller, handles and protects the personal data that we collect or use in connection with our business

activities and client services, and on websites, online tools, and communications that post a link to this

Privacy Statement. As used in this Privacy Statement, “personal data” shall be any information that is

capable of identifying you as an individual person.

Summary

How We Collect Your Personal Data

How We Use Your Personal Data

What Legal Basis We Rely Upon to Process Your Personal Data

How We Protect Your Personal Data

How Long We Retain Your Personal Data

How We Share Your Personal Data

How We Transfer Personal Data Across International Borders

Links To Third Party Websites

How We Respect Your Privacy in Marketing

Use of Cookies and Other Tracking Technologies on Our Websites

How To Contact Us

Children

Your California Privacy Rights

Changes To This Privacy Statement

How We Collect Your Personal Data

We collect information about you from the following sources:

Directly from you

From technology when you visit our websites, online tools or other digital properties

From our clients when they hire us to conduct coaching, training, workshops, surveys or

assessments on their behalf

What Personal Data We Collect

Proteus may collect some or all of the following personal data:

Identifiers, such as your name, email address, mailing address, and telephone number

Perceptions and opinions Identifiers and internet or other online network activity information, such as IP address, device

identifier, web browser, and browsing and use information collected through cookies, web

beacons, pixels, clear gifs, and other similar technologies (collectively “Cookies and Other

Tracking Technologies”)

Professional or employment-related information

Inferences drawn from any of the information identified above

You should be aware that whenever you publicly disclose information online, that information could

be collected and used by others. We are not responsible for any action or policies of any third parties

who collect information that users publicly disclose in any such forums on the websites.

How We Use Your Personal Data

We collect and use your personal data to:

manage coaching, consulting and training activities with employees of our clients

provide products and services to our clients

analyze the performance and functioning of our websites, manage our websites and collect

analytics about how our websites are used

If you are a business client, we may use the personal data that we have collected from you to market

to you. If you are an individual who has responded to a survey, an assessment, or participated in any

coaching or training, we do not use that personal data to market to you.

What Legal Basis We Rely Upon to Process Your Personal Data

Our processing of your personal data for the purposes mentioned above is based:

in part, on our legitimate interests in promoting and protecting Proteus, building and

maintaining relationships, and providing our services;

in part, on your consent, for business purposes that support web operations such as

understanding and enhancing the quality of your experience on our websites;

in part, to comply with the law, when certain information is necessary to satisfy our legal or

regulatory obligations.

How We Protect Your Personal Data

We have implemented reasonable security procedures and technical and organizational measures to

protect personal data against accidental or unlawful destruction, loss, disclosure or use. Only

authorized Proteus personnel and third party service providers are provided access to personal data,

and these personnel and service providers are required to treat this information as confidential. Despite

these precautions however, we cannot guarantee that unauthorized persons will not obtain access to

your personal data.

How Long We Retain Your Personal Data

We may retain your personal data for a period of time consistent with the original purpose for

collection. For example, we keep your personal data for no longer than reasonably necessary for useof our services and for a reasonable period of time afterward. We also may retain your personal data

during the period of time needed for us to pursue our legitimate business interests, conduct audits,

comply with our legal obligations, resolve disputes and enforce our agreements.

When personal data is no longer needed for the purpose it was collected or processed or to comply

with a legal obligation, we securely destroy it.

How We Share Your Personal Data

We do not sell, rent or lease our client lists or other personal data to third parties. We do not sell or

otherwise disclose personal data that we collect over our websites or otherwise collect in connection

with our services, except as described herein.

We may disclose information about you to the following categories of third parties or in the following

circumstances:

With third party service providers who perform services and functions on our behalf to support

our interactions with you, such as hosting online assessments, technical infrastructure

environments, email service providers, and providing you with client support.] We also share

personal data with partners and contractors that comprise the Proteus network. Additionally,

personal data collected on our websites may be shared and transferred to our third party service

providers that service or host our websites;

If appropriate, with the client that hired us to conduct the survey or assessment, we share the

information collected in response to our surveys or assessments;

If we are required to do so by law or legal process;

To law enforcement authorities or other government officials;

When we believe disclosure is necessary or appropriate to prevent physical harm or financial

loss or in connection with an investigation of suspected or actual illegal activity;

If disclosure is necessary to protect the vital interests of a person;

To protect our property, services and legal rights;

To prevent fraud against Proteus, our subsidiaries, affiliates and/or business partners;

To support auditing, compliance, and corporate governance functions;

To comply with any and all applicable laws; or

To complete a corporate transaction such as a re-organization, merger, sale, joint venture,

assignment, or other transfer or disposition of all or any portion of our business.How We Transfer Personal Data Across International Borders

Personal data collected in the course of Proteus’s business activities, as well as on the websites, may

be transferred from time to time within Proteus and to our third party service providers, including to

countries other than the one in which you reside, some of which may have local laws that grant you

fewer rights than you have in your own country. Where required by law, we have put in place legal

mechanisms designed to ensure adequate data protection of your personal data that is processed by

Proteus and third party service providers, including the transfer of your personal data to countries other

than the one in which you reside. If you would like more information about these legal mechanisms,

which may include the EU’s Standard Contractual Clauses, please contact us at the address below. By

using any of the websites and providing information on any of them, you voluntarily consent to such

trans-border transfer and hosting of such information.

Proteus will not intentionally disclose or transfer (and will take reasonable steps to prevent the

unauthorized or accidental disclosure of) your personal data to third parties without your consent or

as otherwise permitted by law, whether for such third parties’ own marketing purposes or otherwise,

except as follows.

Link to Third Party Websites

We may provide links to third party websites or information as a service to you. If you use these links,

you will leave our website. Such links do not constitute or imply our endorsement, sponsorship, or

recommendation of the third party, the third party website, or the information contained therein, and

we shall not be responsible or liable for your use thereof. Such use shall be subject to the terms of use

and privacy policies applicable to those sites.

How We Respect Your Privacy in Marketing

We use various means of communication and tools to market our products and services. We use

commercial marketing email as permitted under applicable law. If you prefer not to receive future

communications from us, you may unsubscribe by using the “Unsubscribe” or “Opt-out” link in the

commercial email or by contacting us at privacy@ privacy@proteus-international.com or calling us

at +1 612.926.9627.

Use of Cookies And Other Tracking Technologies On Our Websites

We may collect information, via cookies, web beacons, pixels, tags or other tracking technologies,

such as your Internet Service Provider and IP address, the date and time you access the website, the

pages you have accessed while visiting the website, and the Internet address from which you accessed

the website. We use these technologies to remember user preferences, analyze and maximize the

performance of our website, applications and services, measure the effectiveness of our email

campaigns and to customize online content.

We do not use cookies for advertising purposes.

You may refuse or delete cookies. If you refuse or delete cookies, some of our website functionality

may be impaired. Please refer to your browser’s Help instructions to learn more about how to manage

Cookies and Other Tracking Technologies.Our websites do not track you by collecting personal data about your online activities over time and

across third party websites or online services. Accordingly, we do not alter our data collection and use

practices in response to “do not track” signals transmitted from web browsers.

How To Contact Us

If you have any questions or comments about our Privacy Statement, please contact us at:

Proteus International, Inc.

123 N. 3rd Street, Suite 801

Minneapolis, MN 55401

Attention: Jeff Mitchell

+1 612.926.9627

privacy@proteus-international.com

Children

We do not knowingly collect, use, share or sell personal data from children under the age of 16. If you

believe we have done so in error, please contact us at the address or email above and we will delete

the information.

Your California Privacy Rights

If you are a California resident under the age of 18, and a registered user of any of the websites where

this Privacy Statement is posted, California Business and Professions Code Section 22581 permits you

to request and obtain removal of content or information you have publicly posted. To make such a

request, please send an email with a detailed description of the specific content or information

to privacy@proteus-international.com. Please be aware that such a request does not ensure complete

or comprehensive removal of the content or information you have posted and that there may be

circumstances in which the law does not require or allow removal even if requested.

As required by the California Consumer Privacy Act (CCPA), this Privacy Statement describes the

categories of personal data collected, processed, and disclosed by Proteus, the categories of sources

for that data, and the business or commercial purposes for which that data is collected, processed, and

disclosed.

In addition, under California law, you may have the right (up to two times in any 12-month period) to

request more information about Proteus’s collection, use, disclosure, and sale of personal data about

you including:

The categories of personal data about you that we have collected in the preceding 12 months

and the categories of sources of that information,

The categories of sources from which we have collected that information in the preceding 12

months

The commercial or business reason(s) we have collected, used, disclosed, or sold that

information, and The categories of third parties to whom we have disclosed or sold that information in the

preceding 12 months.

In addition, upon receipt of a verifiable request from you establishing your identity, you may

have the right to know about the specific pieces of personal data that we have collected about

you and/or shared with third parties in the preceding 12 months.

You may also have the right to request deletion of personal data about you that we have collected or

maintain, which we will honor subject to certain limitations set forth in California law.

If you are a California consumer and you or your authorized agent would like to exercise your privacy

rights, please contact us at privacy@proteus-international.com, or call us at +1 612.926.9627. When

we process your request, we require you to provide certain personal data about you in order to verify

your identity in accordance with requirements under CCPA. This may include your first and last name,

email address, physical address, telephone number, and information about your relationship with us or

other information needed to verify your identity. Proteus will not discriminate against you based on

your exercise of any of these rights.

Changes To This Privacy Statement

We reserve the right to make changes to this Privacy Statement from time to time. We will alert you

to any such changes by updating this Privacy Statement. If we make material changes to this Privacy

Statement that increase our rights to use personal data that we have previously collected about you,

we will obtain your consent either through an email to your registered email address or by prominently

posting information about the changes on our website.