Municipal Websites Central Privacy Statement

This Privacy Statement describes the processing activities performed by CivicPlus when providing its Municipal Websites Central product (“Product”) pursuant to an executed contract with our Customers. This is not a privacy policy regarding the collection, use, and processing of Personal Data when CivicPlus is acting as a data controller. For information regarding our privacy practices when we are acting as a data controller, please see our Privacy Policy.

Description of the Product: The Web Central CMS product assists municipalities with fostering civic engagement by launching a custom-branded website to promote the community and empower its staff and residents. For more information, please see the Municipal Website Product Page. If you have any questions about this Privacy Statement, please contact us at privacy@civicplus.com.

Processing Overview for the Product

1. Does the Product process Personal Data? Yes

   1. Who’s Personal Data?

      • Our Customers’ Staff or Vendors: Yes

      • Our Customers’ End-Users: Yes

      • Other: No

2. Are there optional modules for the Product that process Personal Data that are turned on by default? Yes

3. Does the Product process Sensitive Data? Yes

4. Does the processing involve profiling of individuals based on personal characteristics? No

5. Is the processing done by Artificial Intelligence? No

6. Does the Product process Biometric Information? No

7. Does the Product process Personal Data using Monitoring Technologies? Yes

8. Does the processing include automated decision making that produces legal consequences or seriously impacts the people whose data the Product processes? No

Detailed Description of the Processing

Technical and Organizational Measures (TOMs)

CivicPlus maintains the following Technical and Organization Measures (TOMs) to ensure the ongoing confidentiality, integrity, availability and resilience of processing systems for the Product. We will provide further information about the below TOMs defined below to facilitate Customer audits and to prove compliance with our processing obligations, upon request.

Audits and Other Certifications

CivicPlus has the following audits or certifications for this Product:

• GovRAMP Ready

Subprocessors

We utilize subprocessors to perform the processing activities set out in this Privacy Statement for the Product. If we engage a new subprocessor or replace an existing one, we will update this Privacy Notice. If you have an objection to a subprocessor, please contact us at privacy@civicplus.com.