China Privacy Policy
November 2023

Introduction
OpenText supports the right to privacy and understands the importance of protecting personal informationand complying with applicable data protection laws. We have appointed a Data Protection Officer forassisting with questions regarding this policy and the processing of your personal information.
This Privacy Policy (‘policy’) applies to Open Text Corporation in China, Micro Focus, Covisint, and GXSInc. (China) (hereinafter referred to as ‘OpenText’, ‘we’, ‘us’, ‘our’) and provides information on thecollection, use and sharing of personal information for the People’s Republic of China market. This
includes personal information collected via our websites and portals (‘Website’), our products, services or
personal information collected from you directly, such as in person, via telephone or email, or indirectly
through third parties during our business.
This policy applies to all Opentext Licensing (Off Cloud), Licensing Support products and Professional
services sold in China.
A current listing of our subsidiaries is available in our Annual Report. This policy applies to our
subsidiaries to the extent they have access to your personal information, and the respective subsidiarythat directly collects and processes your personal information is the personal information processor.
This policy does not apply to the extent we process your personal information in the role of a data trustee
or service provider on behalf of our customers.

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For details on how to contact us, see the Contact Information section below.
This policy describes:
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What data we collect
Why we use it
How we collect your data
How we share your data
How we protect your data
How long we store your dataYour privacy rights
Children’s privacy
How your personal information is transferred globally
Contact information

What data we collect
The personal information we process about you and how we collect it can vary depending on (a) the
product(s) or service(s) you use; (b) how you use the product(s) or service(s); (c) how you haveinteracted with OpenText and (d) the personal information that we have obtained from a customer or froma third party with permission to share such information with us. Refer to the table below for more details
on the categories of information collected and purposes of use.

Categories of information collected

Contact and account registration information
For example: Name, address, email, telephone number,username and password, country, and language(collectively “Account Information”)

Financial and transactional information
For example: Credit card, debit card, banking, orother payment information

Purposes of use(for additional information, please refer toTable 1 under ‘Why we use your data’)•Communicating with you•

Providing services•

Personalizing your experience•

Controlling access to our services and
users

•

User authentication and other legal
purposes•

Providing services•

Processing payments•

Authentication and other legal purposes

Copyright © 2023 Open Text. All rights reserved. Trademarks owned by OpenText.

Categories of information collected

Purposes of use(for additional information, please refer toTable 1 under ‘Why we use your data’)Device information and identifiers
For example: The configuration of any device registeredfor use in connection with the products and services;also, IP address, browser type and language, operating
system, platform type, device type, software andhardware attributes, and unique device and application
identifier•

Providing services•

Controlling access to our services and
users

•

Personalizing your experience•

User authentication

Connection and usage data
For example: Information about files you download,
domain names, landing pages, usage activity,
content viewed and accessed, dates and times ofaccess, pages viewed, forms you complete or partiallycomplete, search terms, uploads or downloads, whether
you open an email and your interaction with email
content, access times, error logs, URL accessed andother similar information•

Providing services•

Personalizing your experience•

Controlling access to our services and
users

•

User authentication and other legal
purposes

Other information
For example: Any other information you choose toprovide to us directly or indirectly in connection with youruse of the products and services or websites.

•

Communicating with you•

Providing services•

Personalizing your experience•

Controlling access to our services and
users

•

User authentication and other legal
purposes

Copyright © 2023 Open Text. All rights reserved. Trademarks owned by OpenText.

Why we use your data
OpenText processes personal information to respond to your requests, to provide you OpenText products
and services, including information, support, delivery, and access to online resources. Some of thespecific purposes of use of your personal information include:
Table 1
PurposeExamplesCommunicating with you•

Account set up and administration.

•

Responding to your requests for information and providing you withmore effective and efficient customer service and technical support•

Monitoring communications for quality and training purposes•

Providing you with transactional updates and information about
products and services (e.g., updates to our products and services,
information about your account or information about transactions thatyou conduct on products and services)•

In accordance with applicable legal requirements, contacting you byemail, postal mail, phone, or other means for marketing purposes.

•

Gathering feedback and opinions about our provided services (e.g.,surveys)•

When you download position papers•

Event registration and participation•

Notification to users of changes to our products and services•

Communicating with you about our events, surveys, contests,
sweepstakes, and other promotions•

Allowing you to participate in discussion boards or other social media
functions on the Website•

Processing and fulfilling your requests using products and services.

•

Meeting our contractual commitments to you•

Engaging in analysis, research and reports to better understand how
you use the products and services, so we can improve them.

•Backing up, restoring, and archiving data•

Understanding and resolving reported problems with services or
products

Providing services

Copyright © 2023 Open Text. All rights reserved. Trademarks owned by OpenText.

Personalizing yourexperience

Protecting our services
and users

Defending our legal rights
and compliance withthe law•

Record keeping and billing•

Customizing user experience and showing customized content•

Internal research and development to enhance our products, services,and user experience.

•

Improving our website to ensure content is presented in an
appropriate manner for you and your computer, as well as to improve
product and service offerings.

•

Administering our website for internal operations, including but notlimited to troubleshooting, data analysis, testing, research, statistical,
and survey purposes•

Measuring or understanding the effectiveness of our advertising toyou, and delivering or allowing our service providers to deliver
relevant advertising to you, including interest-based advertising(otherwise known as “online behavioural advertising”)•

Monitoring, preventing, and detecting fraud, such as through verifying
your identity.

•

Combatting spam or other malware or security risks•

Monitoring, enforcing, and improving the security of our services•

Complying with any applicable procedures, laws, and regulations•

Establishing, exercising, or defending our legal rights (e.g., to enforce
compliance with our Terms of Use, Privacy Policies or to protect ourservices, users or others)•

Fulfilment of obligations outlined in any agreements

Copyright © 2023 Open Text. All rights reserved. Trademarks owned by OpenText.

The legal basis for collecting and using the personal information described above will depend on the
personal information concerned, applicable privacy laws and specific context in which we collect it,such as:•With customer or user consent.

•

Where it is necessary for the conclusion or performance of a contract to which the individual
concerned is a party, or for the implementation of human resources management in accordancewith the labor rules and regulations formulated in accordance with the law and the collective
contract concluded in accordance with the law.

•

Where it is necessary for the performance of statutory duties or statutory obligations.

•

Where it is necessary for the response to a public health emergency or for the protection of thelife, health and property safety of a natural person in an emergency.

•

Where such acts as news reporting and supervision by public opinions are carried out for the
public interest, and the processing of personal information is within a reasonable scope.

•

Where it is necessary to handle the personal information disclosed by the individual concerned orother personal information that has been legally disclosed within a reasonable scope inaccordance with the articles of the Personal Information Protection Law.

•

Where necessary to comply with law and administrative regulations.

How we collect your data
We collect personal information through various means. For example, via our website(s), order forms andthrough provision of products or services, from third-party service providers, customer support activities,
and at meetings, exhibitions and events (both physical or digital). Your employer, as a customer orpartner of OpenText, may provide your contact information as required to provide OpenText products orservices. We also collect personal information where you or your employer is a customer of a business
we may acquire. We may also collect information about you on CCTV when you visit our premises or onother security cameras as part of our security and crime prevention measures. The Website(s) may alsocollect information about your visits to the Website without you actively submitting such information
through cookie technology.
Cookies: OpenText uses cookies to collect information about the use of its website(s), either directly or
through third-party tracking providers. For more information refer to our Cookie Policy.
Do Not Track (DNT): Your browser setting may allow you to automatically transmit a "Do Not Track"(DNT) signal to websites and online services that you visit. There is no consensus among industry
participants as to what DNT means in this context, and some browsers automatically apply DNT signals
by default and therefore do not necessarily reflect our visitors' choice as to whether they wish to receive
advertisements tailored to their interests. As a result, like many websites, we do not respond to a DNT
signal from a visitor's browser. To find out more about DNT, please visit http://allaboutdnt.com. However,
you may elect not to accept cookies by changing the designated settings on your web browser or optingout of the OpenText cookies. Please note that if you do not accept certain cookies, you may not be able
to use all functions and features of our Website(s). Consent for use of cookies varies depending on thejurisdiction, click here for more information about OpenText’s Cookie Policy and options on how tomanage your cookies preferences.

Copyright © 2023 Open Text. All rights reserved. Trademarks owned by OpenText.

Personal information collected from third parties: OpenText obtains personal data from third parties.
For example, OpenText may collect and receive personal information about you from companies that
distribute OpenText products by way of co-branded or private-labeled websites. Companies with which
OpenText partners to market, resell and distribute its products and services, which may include thepayment gateways we work with, also may supply us with personal information in order to help us fulfil
orders and provide services.
How we share your data
OpenText may share personal information with its affiliates, business partners (including those who resell
or distribute our products and services), service providers (including website, software, infrastructure andapplication providers), payment gateways, customer service, event/campaign management, cloud hosting
providers, credit reference agencies, debt agencies, professional advisors, marketing agencies (including
event or promotion partners or sponsors), third-party networks and websites, database providers, backup
and disaster recovery specialists, analytics and email providers, and agents working on our behalf.
We may be required to share personal information with a third party or body where such disclosure isrequired to satisfy applicable law or other legal or regulatory requirement, or to protect the rights orproperty of OpenText or others. This can include in response to lawful requests from a competentauthority or body and to meet national security or law enforcement requirements.
If all or any part of our business is re-organized or sold or there is a joint venture with anotherorganization, we may need to provide your information to that organization. We may also be the recipientof personal information when we acquire another organization or a part of their business or enter into a
joint venture with them.
Where third parties are performing processing on our behalf, OpenText will require these organizations to
adopt adequate technical and organizational security measures to protect personal information and toensure the processing of personal information is only performed as instructed by OpenText and for noother purposes.
Personal information may be processed outside the country of your residence by our affiliates, partners orservice providers and agents working on our behalf. The transfer to other countries by OpenText and its
affiliates shall be in accordance with applicable data protection legislation and standards.
How we protect your data
Protecting your data, both online and offline, is a priority for us. We have implemented appropriatetechnical and organizational measures to protect your personal information and ensure a level of security
appropriate to the risk.
All our employees are subject to confidentiality agreements and undergo annual training on the proper
handling of personal information.
OpenText is committed to protect all personal information and is cognizant of its obligations underapplicable data protection laws. For further details, including information on industry standard
certifications of our products, please refer here.
Links to other websites or locations may be provided for your convenience, but do not signify ourendorsement of such other websites or locations or their contents. When you click on such links, you will
leave the OpenText website and go to another site. When this happens, a third party may collect personal
information from you. Please be aware that the terms of this policy do not apply to such outside websites
or content or to any collection of data after you click on a link to a third-party website or location. If you
Copyright © 2023 Open Text. All rights reserved. Trademarks owned by OpenText.

submit personal information to any of those sites, your information is governed by their privacy
statements. We encourage you to carefully read the privacy notice of any website you visit.
How long we store your data
OpenText will retain personal information for as long as needed to provide the relevant products orservices or to fulfil the purposes for which the personal information was collected or as per the specificcontractual terms. OpenText may also retain and use this information for a longer period as permitted or
required by law, to comply with our legal, tax or regulatory obligations (e.g., audit and accounting
requirements), handle disputes, or to exercise or defend claims and enforce our agreements. We ensurethat personal information we dispose of is de-identified or destroyed in a secure manner.
Your privacy rights
Your local applicable law may provide certain rights regarding the collection, use, and sharing of yourpersonal information. You may request from OpenText access to, correction of, updating of and/or
deletion of your personal information, or object to our use of your personal information in certain
circumstances, in line with applicable data protection law. Your rights may differ according to your placeof residence.
The rights available to you depend on our reason for processing your information:•

Your right to access
You have the right to ask us for copies of your personal information. This right always applies.
There may be exceptions, such as under circumstances where laws or administrative regulations
provide that confidentiality shall be preserved or notification is not necessary.

•Your right to rectification
You have the right to ask us to rectify information you think is inaccurate. You also have the rightto ask us to complete information you think is incomplete. This right always applies.

•

Your right to deletion
You have the right to ask us to delete your personal information except in circumstances where itis necessary for security protective measures or where there is a legal requirement for data to bepreserved.

•

Your right to object to processing of your Personal Information
You have the right to ask us to restrict or object to the processing of your information except incircumstances such as where it is necessary for the fulfillment of statutory duties or obligations.

•Your right to data portability
This only applies to information you have given us. You have the right to ask that we transfer the
information you gave us from one organization to another or give it to you.

•

Choice/opting out of marketing: OpenText offers you the choice of receiving different types ofcommunications and information related to our products and services. You may subscribe to enewsletters or other publications; you may also elect to receive marketing communications andother special offers from us via email. If at any time you would like to change your communicationpreferences, we provide unsubscribe links and an opt-out mechanism in all our marketing
communications or you may contact us.

Note that if you opt out of marketing, you may still receive service-related messages from us (and you
may still receive marketing messages for a short period after opting out while we update our records).
Copyright © 2023 Open Text. All rights reserved. Trademarks owned by OpenText.

To exercise your privacy rights, please fill out the Data Subject Request form.
Please direct any complaints or questions you may have with regard to our privacy practices to OpenText
China Data Protection Officer.
Customer data: If your personal data has been submitted to us by or on behalf of a customer to our
products and services who is the personal information processor of that personal information and we are
the trustee on their behalf, you will need to contact them directly if you wish to exercise any rights you
may have under applicable data protection laws. If you make your request to us, we will need the name ofthat customer who submitted your data to us, and we will refer it on to them.
Children’s privacy
OpenText encourages parents and guardians to take an active role in their children's online activities. Our
Services are not aimed at people under 18 and OpenText does not knowingly collect personal informationfrom children without appropriate parental or guardian consent. If you believe that we may have collected
personal information from someone under the age of 14 (or the applicable age of consent) without proper
consent, please submit your complaint in writing to the address found in the Contact Information section.
How your personal information is transferred globally
In principle, your Personal Information will be collected and stored within the territory of the People's
Republic of China. However, as a global company, we provide products and services with globally
deployed IT sources and servers, in certain scenarios based on business needs, your personal
information may be transferred to our parent companies, subsidiaries and/or affiliates, business partners
and/or service providers including those established outside the territory of the People's Republic ofChina or maybe remotely accessed by them from outside of the People’s Republic of China. At that time,
OpenText will separately obtain your consent, comply with the applicable laws and regulations for crossborder data transfer and make sure that your personal information will get the same level of safeguards
as in the People’s Republic of China.
China DPO Contact information
OpenText’s China Data Protection Officer can be reached at Chinadpo@opentext.com or by mail at:
Opentext
11/F Garden Square, Room 1125
No. 968 West Beijing Road, Jing'an District
Shanghai, China, 200041
If you have any questions or concerns about this policy, or if you wish to exercise any of your privacy
rights, please contact OpenText via the contact information as mentioned above, and we will respond to
your request within 15 working days. If you are not satisfied with our response, you may also have theright to complain to the competent supervisory authority, data protection authorities or file a lawsuit to thecompetent people’s court in the People’s Republic of China.
To access the Global OpenText Privacy policy, click the link here.
Changes to this Privacy Policy
OpenText may update this policy from time to time. If we modify this policy, we will post the revised
version here. You should review this page periodically for updates.

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If we make a change that significantly affects your rights or, to the extent we are permitted to do so,significantly changes how or why we use personal information, we will notify you by way of a prominent
notice or pop-up on our Website. If you disagree with such changes, you may submit your complaint inwriting to the address found in the Contact Information section. Without your express consent, we will not
restrict your rights available under this policy before such changes. If you continue to use our products
and services after the changes take effect, you should be deemed to have agreed to the changes thathave taken effect.
This policy was last updated in November 2023.

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About OpenText
OpenText enables the digital world, creating a better way for organizations to work with information,
on premises or in the cloud. For more information about OpenText (NASDAQ/TSX: OTEX),
visit opentext.com.

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