Insight is concerned about privacy issues and wants you to be familiar with how we collect, use and disclose information. This Privacy Policy describes our practices in connection with information that we collect through activities that link to this Privacy Policy including websites and through your interactive business with Insight. By providing information to us, you agree to the terms and conditions of this Privacy Policy. You can find out details of all of Insight’s affiliates by visiting our website here. When we refer to ‘we’ or ‘Insight’ in this policy we are referring to Insight Enterprises, Inc. and its affiliates.

Information We May Collect

Categories of data subjects from whom we may collect data:

· employees and former employees including volunteers, agents, individual contractors, temporary or casual workers;

· applicants who have applied for employment;

· relatives, guardians or associates of employees, former employees or applicants;

· contractors, agents, consultants and suppliers both past and present and their individual employees or representative;

· customers and former customers and their employees or representatives, which may include clients of our customers and former customers;

· individuals and representatives of organizations who have registered with Insight to obtain information on products and/or services offered; and

· individuals and representatives of organizations who have visited the website.

Information may include:

· browser and device information;

· server log file information;

· information collected through cookies and other technologies;

· demographic information and other information provided by you;

· financial details;

· complaints or grievances;

· contact details, being corporate contact details where appropriate, including email, postal address, telephone and facsimile numbers;

· purchasing habits and customers;

· customer preferences;

In addition, with respect to employees, former employees and applicants the additional categories of data may include:

· Personal details

· Family, lifestyle and social circumstances

· Employment details

· Financial details

· Complaints or grievances

· Email and postal addresses

· Telephone and facsimile numbers

· Limited sensitive data such as racial or ethnic origin, physical or mental health or condition, religious observance, issues notified under whistleblower policies, criminal records and disciplinary records, collected in the ordinary course of the employment relationship.

How We May Collect the Information

We may collect information in a variety of ways, including:

· From you directly.

· Through this site: Insight may collect information through the website when you visit.

· Through business interaction: We may collect information through your or your employer’s business interaction with our employees or offices.

· From other sources: We may receive information from other sources, such as public databases; joint marketing partners; social media platforms; or other third parties.

How We May Use Information

· Data storage and administration;

· Data security;

· Customer and user administration, including the processing of orders, enquires and client reporting;

· Employee administration;

· Advertising, marketing and public relations activities;

· Maintenance of accounts and records;

· Analysis of trends and statistical data;

· Crime prevention and prosecution of offenders; and

· Maintenance and development of our website including tailoring for specific visitors.

Insight will always request your consent to send you marketing communications - as per the Information Disclosure section below you may opt-out of this whenever you wish.

Our legal basis for collecting and using the personal data described above and in this Privacy Policy will depend on the personal data concerned and the specific context in which we collect it.

However, we will normally collect personal data from you only (i) where we have your consent to do so, (ii) where we need the personal data to perform a contract with you, or (iii) where the processing is in our legitimate interests and not overridden by your rights.

If we ask you to provide personal information to comply with a legal requirement or to perform a contract with 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 data).

We will process your information for the purposes of operating our website and communicating with you as necessary to provide our services to you and in our legitimate commercial interests, for instance, when responding to your queries, undertaking marketing activities, improving our website and services or for the purposes of detecting or preventing illegal activities.

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 using the contact details provided below.

Cookies

Insight, its service providers or other third parties may set cookies for your web browser when you visit our website, use our products or visit a website where Insight provides ads, content or analytics.

Use of cookies by Insight

Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site. Cookies may be used to store items such as identifiers and user preferences. A website may set a cookie to the browser used if the browser’s preferences allow it.

Generally, we use cookies in order to improve the user experience of this website in particular with customized content, tell us which parts of the websites the users have visited, keep track of your preferences while you are using Insight services, provide enhanced services, remember the location and language settings for individual users, provide general internal and customer analytics, and support security measures.

Operational Cookies

Operational Cookies are required for the proper operation of the Insight website, allowing you to move freely around and use secure areas of our website. These cookies allow our web pages to load faster and improve service performance. Generally, we use the following cookies:

· cookie_banner_closed - This is an operational cookie used by Insight to display a cookie and privacy message at the bottom of our website. When the cookie banner is closed this cookie is set on your browser and the message will not display again, unless you clear your cookie history in your browser, then it will re-appear. Any data collected will not be shared with any 3rd party.

· secure_cookie- This is an operational cookie used by Insight to prevent any ‘hijacks’ while you are using our site, by making the session secure. Any data collected will not be shared with any 3rd party.

· pst_* - This is an operational cookie used by Insight so when you log into our website and close down your browser without logging out, we then keep you persistently logged in, we will prompt you to log back in to re-confirm who you are. Any data collected will not be shared with any 3rd party.

· pref- This is an operational cookie that is used to set your language preference by Insight. The next time you visit our site your language will be set for you. Any data collected will not be shared with any 3rd party.

· sess- This is an operational cookie which allows you as a user to use Insight’s website, it makes our site work. This is called a session cookie and temporary in it use. Once you close your browser the session cookie is no longer used. Any data collected will not be shared with any 3rd party.

· Insight_locale - This is an operational cookie which shows which local Insight website you are accessing. Once you close your browser the cookie is no longer used. Any data collected will not be shared with any 3rd party.

Third Party Cookies

With respect to analytics, we use cookies from third-party service providers. For each third party cookie used, you can find below a description and a link leading you to the privacy policies of these third parties for further inquiries. We use the following third party cookies:

1. This website uses Google Analytics, a web analytics service provided by Google, Inc. ("Google"). Google Analytics uses cookies to help the website analyse how users use the site. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. Google will not associate your IP address with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website. By using this website, you consent to the processing of data about you by Google in the manner and for the purposes set out above.

a. These cookies are called _utma, _utmz, _ga, _gid and attribution_x_

b. For more information on Google’s privacy and cookie policy, please visit Google’s privacy policy http://www.google.com/privacy/privacy-policy.html.

2. This website uses Marketo Munchkin cookies (“Marketo”). Marketo's cookie allows us to track repeated visits to the website, and link each visit to the information voluntarily provided by the visitor. For example, if the visitor is asked to provide us with name, company name and email address, we will know the identity of the visitor when they visit the site at a later date. We also use Munchkin to track email open rates and click through rates, allowing us to manage the email marketing experience. By using this website you are consenting to the above use of your data.

a. These cookies are called _mkto_trk and _mktoLearn

b. For more information on Marketo’s privacy and cookie policy,

please visit Marketo privacy policy: http://www.marketo.com/trust/legal/privacy.

How to change your cookie settings

Cookie settings can be changed in the settings of most web browsers.

You may refuse to accept cookies by modifying the settings on your browser, for example:

· For Internet Explorer ™: http://windows.microsoft.com/fr-fr/internet-explorer/delete-manage-cookies

· For Safari ™: https://support.apple.com/en-gb/HT201265

· For Chrome ™: https://support.google.com/chrome/answer/95647?hl=en-GB&hlrm=en

· For Firefox ™: http://support.mozilla.org/fr/kb/Activer%20et%20d%C3%A9sactiver%20les%20cookies

· For Opera ™: http://help.opera.com/Windows/10.20/en/cookies.html

· To opt out of being tracked by Google Analytics across all websites, visithttp://tools.google.com/dlpage/gaoptout.

Please note, if you choose to block cookies via the browser, you may not be able to access certain parts or functions of this website.

Surveys

The information you provide for surveys will be used to support your relationship with Insight. Insight may use online surveys to ask visitors/customers for contact information (like their email address). We use contact data from our surveys to send the survey taker information about our company and promotional material on behalf of our partners. We may combine survey information with other data we hold about you.

Contests/Giveaways

The information you provide during contests and giveaways will be used to support your customer relationship with Insight. Insight may ask for contact information (like your email address). We use contact data from these events to send users information about our company and promotional material from some of our partners. The contact information is also used to contact the visitor when necessary. We may combine this information with other data we hold about you.

Careers

If you use the website to apply to work with us, the information you provide will be used to evaluate your candidacy for job opportunities with Insight and to monitor recruitment statistics. We provide electronic applications on our site in which we ask job candidates for contact information (like their email address) and information regarding work history and education. We use third parties to help us to do that. We use contact data from our applications to contact those individuals whose backgrounds most closely meet our requirements to schedule a personal interview. As a global business, we may transfer your details outside of your home country and to other Insight affiliated entities. Personal information about unsuccessful candidates will be held after the recruitment exercise has been completed and may be reconsidered should an appropriate position become available. Insight will follow the applicable law as to destruction and deletion of such personal information. We may retain de-personalized statistical information about applicants to help inform our recruitment activities, but individuals should not be identifiable from that data. Once a person has taken up employment with us, we will compile a file relating to their employment. At that stage, we will give more details about how we hold employee data.

Information Disclosure

Insight will not give or sell any information regarding you or your order and the products you purchase to any outside organization for its use in marketing or solicitation without your consent, save for the limited circumstances outlined in this policy. Your information may be shared with group companies, agents, contractors or vendors of Insight who provide data processing services to us or who otherwise process personal data for the purpose of performing services for you or Insight or for the purpose notified to you when we collected your personal data. Insight may release personal data (including personally identifiable information) when required to by law if we have a good-faith belief that such action is necessary to comply with a current judicial proceeding, in response to a lawful request by public authorities, a court order or legal process served on Insight.

Insight may also share your personal data with a potential or actual buyer (and its agents and advisers) in connection with any proposed or actual purchase, merger or acquisition of any part of our business, provided that we inform the buyer it must use your personal data only for the purposes disclosed in this Privacy Policy, as well as any other person with your consent to the disclosure.

We may also disclose your information if we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of the business or assets. If Insight or substantially all of its assets are acquired by a third party, personal data held may be one of the transferred assets. Any third party who acquires assets from us may acquire all or part of our business. They may not be in the same line of business as we are. Similarly, your personal information may be passed on to a successor in interest in the event of a reconstruction, liquidation or administration.

Security

While Insight uses all reasonable efforts to safeguard your personal data, no security program is impenetrable, and criminals have been adept at circumventing widely adopted security safeguards. Accordingly you acknowledge that the use of the internet is not entirely secure and that you provide personal information to Insight at your own risk. Insight cannot therefore guarantee the security or integrity of any personal data that are transferred from you or via the internet. Any user or third party accessing Insight’s website or services is responsible for its own use of the website and the services. Insight is not responsible for any third party’s actions or its security controls with respect to information that third parties may collect or process via the website, services or otherwise.

Insight uses what we consider to be reasonable and appropriate organizational, technical and administrative measures to protect information under our control. This site has security measures in place to protect the loss, misuse and alteration of the information under our control. All account information you use or supply on Insight's website when ordering or tracking products is held on a system which is designed to be secure. We use reputable advanced encryption technology which the aim to protect you from unauthorized use of information supplied on our website. In addition, we may use your IP address to help diagnose problems with our server, and to administer our website. Your IP address is used to help identify you and your shopping cart and to gather broad demographic information.

Social Media Features

This website includes social media features, including Facebook “Like” button and Twitter “Follow” button. These features may collect your IP address, which page you are visiting on this website, and may set a cookie to enable the feature to function properly. Social media features are either hosted by a third party or hosted directly on this website. Your interactions with these features are governed by the privacy policy of the company providing it.

Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site or our online ordering facility, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. Please make sure this password is unique and that you do not use this password for any other purpose. If you use another account (such as a social media account) to log on to a secure part of the Insight website, then please make sure that you keep that password secure as well. If you think that any of your passwords have been compromised, please notify us so that we can look after the security of your details on our website.

Links to Third-Party Websites and Services

This website may contain links to third-party sites. If you click on those links this will take you outside Insight’s service. We cannot control and are not responsible for the privacy practices of those third-party sites. We encourage users to be aware when they leave this website, and to read the privacy statements of each website they visit. This Privacy Policy applies only to this Website.

Retention of Personal Data

We retain personal data we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service 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 data, we will either delete or anonymise it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal data and isolate it from any further processing until deletion is possible.

Choice/Opt-Out/Rights

You have the following data protection rights:

- you have the right to opt-out of receiving marketing communications from us. You can exercise this right by clicking on "unsubscribe" by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you. To opt-out of other forms of marketing (such as postal marketing or telemarketing), then please contact us using the contact details provided below. You may also modify your preferences in respect of such communications here.

- you may also have the following rights (although all of these rights are subject to some conditions and exceptions):

o to access, correct, and request deletion of your personal data;

o to object to processing of your personal data, ask us to restrict said processing, and/or request portability of your personal data;

o to erasure of your personal data.

- if we have collected and process your personal data with 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 data 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 data. For more information, please contact your local data protection authority.

You must be able to provide your name and email address or other information sufficient to allow us to identify you. We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

If you would like to exercise your rights please get in touch with the relevant Insight affiliate. The contact details of each Insight affiliate are detailed on our website at here.

Postal mail should be addressed for the attention of:

· The Global Compliance Officer for North America and APAC regions; or

· The DPO (Legal Department) for EMEA countries.

Email should be sent to:

· Compliance@Insight.com for North America and APAC regions; and

· DPO@Insight.com for EMEA countries.

Privacy Shield and Data Transfer

Insight is a global business. As a result, the data that we may collect from you may be transferred to, and stored at, any of our locations which may be inside or outside the European Economic Area (“EEA”) or Switzerland. Data may also be processed by people around the world who work for use or for one of our suppliers/vendors. These people may be engaged in, among other things, the fulfillment of your information requests, meeting your orders and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing.

Insight has put in place a number of measures designed to protect data which is transferred from Europe/Switzerland to the US, including appropriate security measures to safeguard your personal data. Insight maintains a network of specific agreements to require contracting parties to observe data protection legislation. Insight Enterprises, Inc. and Insight North America, Inc. have additionally signed up to the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework. You can find out more about both Privacy Shield Frameworks and view Insight’s certifications here https://www.privacyshield.gov/Program-Overview. Insight complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the EU and Switzerland to the United States, respectively. Insight has certified to the Department of Commerce that it adheres to the Privacy Shield Principles of notice, choice, onward transfer, security, data integrity and purpose limitation, access, and recourse, enforcement and liability. We are committed to following the Privacy Shield Frameworks. We are also committed to supervising third parties where we have transferred data to them after a Privacy Shield data transfer to us and we accept our liability in cases of onward transfer of data to third parties.

If you believe Insight maintains your personal data within the scope of the Privacy Shield Frameworks, you may direct any of your inquiries or concerns concerning our Privacy Shield compliance to compliance@insight.com. In compliance with the Privacy Shield Principles, Insight commits to resolve complaints about our collection or use of your personal information. Individuals in the European Union (EU) with inquiries or complaints regarding our Privacy Shield policy should first contact compliance@insight.com. Insight will respond within 30 days. In the unlikely event that we fail to respond within 30 days, or if our response does not address your concern, Insight will undertake to refer the concern to our Global Compliance Officer who will investigate the matter and communicate with you within 14 days.

Insight has further committed to refer unresolved Privacy Shield complaints to JAMS, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact or visit https://www.jamsadr.com/eu-us-privacy-shield for more information or to file a complaint. The services of JAMS are provided at no cost to you. You can also follow that link for a description of the range of potential remedies. There are more details on the arbitration requirements of the Privacy Shield Framework at https://www.privacyshield.gov/.

If you do not find the proposed solution satisfactory, Insight will resolve the EU-U.S. Privacy Shield disputes under dispute resolution procedures of the panel established by the EU data protection authorities (DPAs) to resolve disputes pursuant to the Privacy Shield Principles. If your matter involves the Swiss-U.S. Privacy Shield, Insight is committed to resolve the dispute in cooperation with the Swiss Federal Data Protection and Information Commissioner. Insight additionally commits to co-operate with EU/Swiss Authorities and comply with the advice given by such Authorities with regard to human resources data transferred from the EU/Switzerland in the context of the employment relationship. The EU/Switzerland DPAs may be contacted directly via the information provided at http://ec.europa.eu/justice/data-protection/bodies/index_en.htm and www.edoeb.admin.ch, respectively.

Under certain and limited conditions, you may have the possibility to invoke last resort binding arbitration by a “Privacy Shield Panel” composed of at least 20 arbitrators designated by the U.S. Department of Commerce and the European Commission.

Insight is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).

In cases of onward transfer to third parties of data of EU individuals received pursuant to the EU-US Privacy Shield and Swiss-US Privacy Shield, Insight is potentially liable. Insight will continue to adhere to the Privacy Shield Principles for as long as it retains your personal information.

Updates to this Privacy Policy

We may change this Privacy Policy as our business continues to evolve. When we update our Privacy Policy, we will take appropriate measures to inform you in case of significant modifications, consistent with the significance of the changes we make. Please take a look at the “Last Updated” legend at the bottom of this page to see when this Privacy Policy was last revised.

Last Updated May 2018