This Privacy Statement is effective as of 01 December 2020. The previous version of this Statement is available here. At IBM we recognize the importance of protecting your personal information and are committed to processing it responsibly and in compliance with applicable data protection laws in all countries in which IBM operates. This Privacy Statement describes IBM's general privacy practices that apply to personal information we collect, use and share about our clients, business partners, supplier and other organizations with which IBM has or contemplates a business relationship as well as the individuals working for them. This Privacy Statement does not apply to the extent IBM processes personal information on behalf of clients for their benefit and under their control (as a "processor"), such as Cloud Services or applications ("apps"). It may apply to collection of information related to authorized users of such services to the extent IBM processes this information for its own interests (as "controller"). This Privacy Statement is supplemented by the IBM Online Privacy Statement, which provides more information in the online context, including recruitment. We may provide additional or more specific information on the collection or use of personal information on websites or related to a specific product or service. Why and how we collect and use your personal information We may collect your personal information as an individual for various purposes, such as the following:

• Access and use of websites or other online service (including "apps")
  When entering one of our websites, or using an online service (where references to online services include desktop or mobile applications or "apps"), we will record information necessary to provide you with access, for the operation of the website and for us to comply with security and legal requirements in relation to operating our site, such as passwords, IP address and browser settings. We also collect information about your activities during your visit in order to personalize your website experience, such as recording your preferences and settings, and to collect statistics to help us improve and further develop our websites, products and services.
• Responding to your request for information, order, or support
  When you contact us (online or offline) in connection with a request for information, to order a product or service, to provide you with support, or to participate in a forum or other social computing tool, we collect information necessary to fulfill your request, to grant you access to the product or service, to provide you with support and to be able to contact you. For instance, we collect your name and contact information, details about your request and your agreement with us and the fulfillment, delivery and invoicing of your order and we may include client satisfaction survey information. We retain such information for administrative purposes, defending our rights, and in connection with our relationship with you.
  
  When you provide your name and contact information to register in connection with such a request, the registration may serve to identify you when you visit our websites. For ordering of most services and products we require you to have registered an IBMid. Registration may also allow you to customize and control your privacy settings.
   
• Your use of IBM Cloud services
  We collect information about your use of IBM Cloud services to enable product features to operate, improve your user experience, tailor our interactions with you, inform our clients on the overall use of the services, provide support and improve and develop our products and services. For details regarding the technologies we employ, the personal information we collect, as well as how to control or block tracking or to delete cookies, please refer to the IBM Online Privacy Statement.
• Contacting employees of our clients, prospects, partners and suppliers
  In our relationship with clients or prospects, partners and suppliers, they also provide us with business contact information (such as name, business contact details, position or title of their employees, contractors, advisors and authorized users) for purposes such as contract management, fulfillment, delivery of products and services, provision of support, invoicing and management of the services or the relationship.
• Visitor information
  We register individuals visiting our sites and locations (name, identification and business contact information) and use camera supervision for reasons of security and safety of persons and belongings, as well as for regulatory purposes.
• Marketing
  Most information we collect about you comes from our direct interactions with you. When you register for an event we may collect information (online or offline) in relation to the event organization, and during an event, such as participation in sessions and survey results. We combine the personal information we collect to develop aggregate analysis and business intelligence for conducting our business and for marketing purposes. You can choose to receive information by email, telephone or postal mail about our products and services. When visiting our websites or using our services we may provide you with personalized information. You can always opt out from receiving personalized communication from IBM by setting your marketing communication preferences here. For subscriptions, please follow the unsubscribe instructions provided at the bottom of each email. More information can be found in the IBM Online Privacy Statement.

Where we reference that we use your personal information in connection with a request, order, transaction or agreement (or preparing for the same), or to provide you with services that you requested (such as a website), we do this because it is necessary for the performance of an agreement with you. Where we reference that we use your personal information in relation to marketing, improvement or development of our products or services, for reasons of safety and security, or regulatory requirements other than in connection with your agreement or request, we do this on the basis of our or a third party's legitimate interests, or with your consent. When we collect and use your personal information subject to the EU Privacy Legislation this may have consequences for your rights.

Sharing of Personal Information

As a global organization offering a wide range of products and services, with business processes, management structures and technical systems that cross borders, IBM has implemented global policies, along with standards and procedures, for consistent protection of personal information. As a global company, we may share information about you with our subsidiaries world-wide and transfer it to countries in the world where we do business in accordance with this Privacy Statement.

Between IBM controlled subsidiaries we only grant access to personal information on a need-to-know basis, necessary for the purposes for which such access is granted. In some cases, IBM uses suppliers located in various countries to collect, use, analyze and otherwise process personal information on its behalf.

Where appropriate, IBM may also share your personal information with selected partners to help us provide you, or the company you work for, products or services, or to fulfill your requests, or with your consent. When selecting our suppliers and partners, we take into account their data handling processes.

If IBM decides to sell, buy, merge or otherwise reorganize businesses in some countries, such a transaction may involve the disclosure of personal information to prospective or actual purchasers, or the receipt of such information from sellers. It is IBM's practice to require appropriate protection for personal information in these types of transactions.

Please be aware that in certain circumstances, personal information may be subject to disclosure to government agencies pursuant to judicial proceeding, court order, or legal process. We may also share your personal information to protect the rights or property of IBM, our business partners, suppliers or clients, and others when we have reasonable grounds to believe that such rights or property have been or could be affected. International Transfers

The international footprint of IBM involves a large number of transfers of personal information between different subsidiaries, as well as to third parties located in the countries where we do business. Some countries have implemented transfer restrictions for personal information, in connection with which IBM takes various measures, including:

• Where required, IBM implements Standard Contractual Clauses approved by the EU Commission, or similar contractual clauses in other jurisdictions. This includes transfers to suppliers or other third parties. You can request a copy of the EU Standard Contractual Clauses here.
• IBM complies with the APEC Cross Border Privacy Rules (CBPR) system.

While the EU-U.S. and Swiss-U.S. Privacy Shield Framework may no longer be used or relied upon for transfer of personal information, IBM continues to comply with all EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework obligations. More information can be found here: IBM Privacy Shield Privacy Policy andUS Department of Commerce. Back to top Information Security and Accuracy

We intend to protect your personal information and to maintain its accuracy. IBM implements reasonable physical, administrative and technical safeguards to help us protect your personal information from unauthorized access, use and disclosure. For example, we encrypt certain sensitive personal information such as credit card information when we transmit such information over the Internet. We also require that our suppliers protect such information from unauthorized access, use and disclosure. Retention Period

We will not retain personal information longer than necessary to fulfill the purposes for which it is processed, including the security of our processing complying with legal and regulatory obligations (e.g. audit, accounting and statutory retention terms), handling disputes, and for the establishment, exercise or defense of legal claims in the countries where we do business. Because the circumstances may vary depending on the context and the services, the information provided in Online Privacy Statement or provided in a specific notice may provide more detailed information on applicable retention terms.   How to contact us

If you have a question related to this Privacy Statement, please contact us by using this form. Your message will be forwarded to the appropriate member of IBM's Data Privacy Team, such as Data Protection Officers or members of their teams. Where this is relevant, the controller of your personal information is International Business Machines Corporation (IBM Corp.), 1 North Castle Drive Armonk, New York, United States, unless indicated otherwise. Where IBM Corp. or a subsidiary it controls is required under data protection law to appoint a legal representative in the EEA or the UK, the representative for the EEA will be IBM International Group B.V., Johan Huizingalaan 765, 1066 VH Amsterdam, The Netherlands; and the representative for the UK will be IBM United Kingdom Limited, PO Box 41, North Harbour, Portsmouth, Hampshire, PO6 3AU, United Kingdom. IBM Corp. is not the controller in situations such as:

• Personal information processed in connection with a contractual relationship, or with entering into a contractual relationship with a specific IBM subsidiary. In this case the controller of personal information is the IBM contracting company, which is the legal entity with which you or your employer have, or will have, the contract.
• Personal information collected on the physical site or location of an IBM subsidiary. In this case that subsidiary is the controller of the personal information.

Your Rights You can request to access, update, or correct, and in certain circumstances, to delete your personal information. You also have the right to object to direct marketing. You can access the request process here. You may have additional rights pursuant to your local law applicable to the processing. More information can be found here. Right to Lodge a Complaint

In the event you consider our processing of your personal information not to be compliant with the applicable data protection laws, you can lodge a complaint:

• Directly with IBM by using this form.
• With the competent data protection authority. The name and contact details of the Data Protection Authorities in the European Union can be found here.

Changes to our Privacy Statements

We may update this Privacy Statement from time to time to reflect changes to our data governance practices. The revised Privacy Statement will be posted here with an updated revision date. We encourage you to check back periodically for any changes or updates. If we make a material change to our Privacy Statement, we will post a notice at the top of this page for 30 days. By continuing to use our websites after such revision takes effect we consider that you have read and understand the changes.   Other privacy statements & policies California Supplemental Privacy Statement IBM Privacy Shield Privacy Policy for Certified IBM Cloud Services IBM Controller Binding Corporate Rules Kyndryl Supplementary Privacy Statement