Altair Privacy Shield Policy for Consumer Data

Altair Engineering, Inc. and its US subsidiaries Altair Product Design Inc., solidThinking Inc., and Illumisys Inc., (“Altair”) are committed to upholding the highest ethical standards in its business practices and strives to collect, use, and disclose personal information consistent with the laws of the countries in which it does business. This Privacy Shield Policy sets forth the privacy principles that Altair follows with respect to your personal consumer information transferred from the European Economic Area (EEA) (which includes the twenty-eight member states of the European Union (EU) plus Iceland, Liechtenstein and Norway) to the United States and from Switzerland to the United States..

The Federal Trade Commission (FTC) has jurisdiction over Altair’s compliance with the Privacy Shield.

Altair has certified that it adheres to the Privacy Shield Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Privacy Shield program, and to view Altair’s certification, please visit https://www.privacyshield.gov.

SCOPE

This Privacy Shield Policy (the "Policy"), effective September 26, 2016, applies to all data information received from consumers by Altair in the United States from the European Economic Area and from Switzerland, in any format including electronic, paper, or verbal.

Altair complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework, each as set forth and administered by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the Member States of the EEA and Switzerland to the United States of America. Altair has certified to the U.S. Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit the U.S. Department of Commerce’s Privacy Shield List atwww.privacyshield.gov.

Altair also collects personal data concerning its employees (Human Resources Data) in connection with administration of its Human Resources programs and functions and for the purpose of communicating with its employees. Altair applies the EU-U.S. Privacy Shield Principles and Swiss-U.S. Privacy Shield Principles to these data. Further information in this regard can be found in Altair’s Human Resources Privacy Policy which is internally available to Altair’s employees.

DEFINITIONS For purposes of this Policy, the following definitions shall apply:

"Agent" means any third party that collects or uses personal data under the instructions of, and solely for, Altair or to which Altair discloses personal data for use on Altair's behalf.

"Altair" means Altair Engineering Inc, its US subsidiaries, divisions, and groups.