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Privacy Policy

Last Updated September 15, 2023

Digital Hands LLC and its affiliate and subsidiary companies (together, “Digital Hands”, “we,” “us,” or “our”) deliver world-class automation to connect all software and hardware in your cybersecurity system.  As a managed security services provider, we take data privacy and security seriously and believe in transparency. 

What is In Scope for this General Privacy Policy 

We believe it is important to inform you about how we will use your Personal Data.  Therefore, we encourage you to carefully read this privacy policy (“General Privacy Policy”), which describes the following: 

What Information We Collect. We want you to be in the know.  We may collect Personal Data from you when you visit or use Digital Hands’ websites (including https://www.digitalhands.com/), applications, platforms, media, solutions, domains under our control (but excluding our career site or HR intranets)(“Websites”), and/or functionalities made available by Digital Hands with a link to this General Privacy Policy; when you attend in-person or virtual events hosted by Digital Hands; or when you request or receive our marketing information (collectively, “our Business Operations”). 

How We Treat the Information We Collect. No surprises.  This Privacy Policy describes how we collect, use, disclose, share or safeguard Personal Data that we collect from individuals who access or interact with Business Operations (“you” or “your”). 

What choices and rights you have in this regard. You can take control.  Please review Sections 7 and 8 of this General Privacy Policy regarding how we use and share your information. 

For California residents, please review Section 14 below. 

What is Out of the Scope for this General Privacy Policy 

PLEASE NOTE: This Policy does not apply to our HR-related data collection practices, where you act as our job applicant, employee, independent contractor, or corporate officer.  A separate HR-related privacy policy will be made available to you in that case.  To the extent we agree to be a data processor or service provider to our customers, we execute a data processing agreement with that customer, which supersede this General Privacy Policy.  

How to Contact Us 

 If you have any questions or concerns regarding this General Privacy Policy or our information collection, storage, and disclosure practices, wish to exercise your rights, or wish to lodge a complaint with us, you may contact us using the information below.  Please note, if your communication is sensitive, you may wish to contact us by postal mail or telephone. 

Via Email: 

Privacy@DigitalHands.com 

Phone: 

1-844-684-9201 

Address: 

Digital Hands LLC 

4211 W. Boy Scout Blvd, Suite 700, Tampa, FL 33607 

 

DISCLAIMERS 

Our Services are housed on servers in the United States.  If you are located outside of the United States, please be aware that information and data we collect may be processed and stored in the United States, where the data protection and privacy laws may not offer the same level of protection as those in your home jurisdiction.  For more details, please refer to Section 12 (International Data Transfers). 

PLEASE READ THIS PRIVACY POLICY CAREFULLY TO UNDERSTAND HOW WE TREAT YOUR PERSONAL DATA. IF YOU DO NOT AGREE WITH THE TERMS OF THIS PRIVACY POLICY, YOU SHOULD NOT ACCESS, USE, OR OTHERWISE INTERACT WITH OUR SERVICES.  BY USING OR ACCESSING OUR WEBSITES, REGISTERING OR SUBMITTING YOUR INFORMATION, OR INTERACTING WITH DIGITAL HANDS, YOU CONSENT TO THIS PRIVACY POLICY AND TO OUR COLLECTION AND SHARING OF YOUR INFORMATION IN ACCORDANCE WITH THE TERMS OF THIS PRIVACY POLICY. 

Table of Contents 

1. INTRODUCTION  2. INFORMATION WE MAY COLLECT 
3. HOW WE MAY USE YOUR INFORMATION  4. HOW WE MAY DISCLOSE YOUR INFORMATION: 
5. DATA RETENTION  6. DATA SECURITY 
7. YOUR CHOICES TO CONTROL YOUR INFORMATION  8. COOKIES AND SIMILAR TECHNOLOGIES 
9. THIRD PARTY WEBSITES OR TECHNOLOGIES  10. CHILDREN’S PRIVACY 
11. UPDATES TO THIS PRIVACY POLICY  12. INTERNATIONAL PERSONAL DATA TRANSFERS 
13. INTERNATIONAL DATA PRIVACY ADDENDUM  14. STATE-SPECIFIC DATA PRIVACY ADDENDUM 

 

1. INTRODUCTION

    1. What is “Personal Data”? “Personal Data” means information that can be used to identify you, directly or indirectly, alone or together with other information.  This includes things such as your full name, contact information, email address, phone number, device IDs, certain cookie and network identifiers, and other categories described below. 

We may de-identify, aggregate and/or anonymize your Personal Data by excluding and removing data components (such as your name, email address, or linkable tracking ID) through obfuscation, or through other means so that the resulting dataset is no longer personally identifiable to you (such resulting dataset is known as “Aggregated Data”).  Our use of Aggregated Data is not subject to this General Privacy Policy. 

  1. Is entry of Personal Data required? The entry of Personal Data is required to access certain portions of Business Operations or otherwise interact with us.  You may choose not to provide us with any Personal Data and may still interact with certain portions of our Business Operations.  However, you may not be able to fully utilize all functionalities and features of our Business Operations if certain categories of Personal Data are required for us to deliver that functionality.  For example, signing up for our whitepaper and newsletter is voluntary, but if you choose not to provide your email, then we are not able to deliver this content to you via email. 
2. INFORMATION WE MAY COLLECT 

We need your Personal Data to provide you a great experience with our Business Operations. 

  1. Information that we may collect. The information we collect depends upon the nature of our relationship, the method you communicate with us, and the purposes of your interaction with us, among others.  We may collect the following information: 
  • Contact Information, such as your first and last name, email addresses, mailing addresses, telephone numbers, professional title and business name. 
  • Account Information, such as your username, email address, and/or password to login to your online account with us. 
  • Communications Data, such as information you provide through our online web forms, when you contact us with questions, feedback, comments, surveys, or otherwise choose to provide when you correspond with us online. 
  • Pictures/Audio/Video Recordings or Similar Information, such as audio recordings of telephone calls with us for quality assurance and training purposes, details and information about your visits to our offices or interactions with our Personnel (such as your headshots taken for creating your name tag(s), where applicable, or images or video captured by surveillance cameras), photographs or videos captured during in-person meetings, video conferences, or events that you attend. 
  • Device Information, such as information that is automatically assigned to your devices used to access the Websites including IP address, unique device identifier (UDID, IDFA or GAID), device type, browser type, location information, and other information about your browser. 
  • Usage Data, such as information (including inference based on such information) about how you access, use and interact with our Business Operations.  This information may include, information you provide to us when you use any interactive features of the Websites, the URL that referred you to the Websites, browsing and click behavior and other activities, cookie ID, cookie content, IP address, domain name, access dates and times, Internet service provider (“ISP”), operating system, language, clickstream data and similar device and usage information.  We also may use pixels in HTML emails to understand if you read the emails that we send you.  For more information, see Section 8 (Cookies and Similar Technologies) below. 
  • Social Media Information, such as name, username, email address, or other profile information in connection with your social media account that we may collect if you connect with us through a third-party social network or other websites, such as LinkedIn (each, a “Social Media Site”). 
  • Marketing Data, such as your preferences for receiving communications about our activities, events, and publications, and details about how you engage with our communications. 
  • Transaction Data, such as information about payments to and from you and other details of your interaction with Digital Hands. 
  • Other information that you voluntarily share with us when you access, use or interact with our Business Operations, which is not specifically listed here.  We will use such data in accordance with this General Privacy Policy, as otherwise disclosed at the time of collection, in accordance with our agreement, or to the extent necessary for performing the services. 
3. Sources of Personal Data We May Collect 

Personal Data You Provide Directly to Us. We may collect your information when you provide it to us directly, through account registration, responding to survey, questionnaires, or other webforms, or otherwise directly interacting with us with questions, feedback, or reports. 

Personal Data We Automatically Collect from You. We may collect Personal Data about you through cookies and other similar tracking technologies.  If you choose to disable such tracking technologies, some areas and features of the Websites may not work properly.  The information we collect from you via the Websites may depend on the settings of your device(s) and/or browsers.  We recommend checking the polices and instructions of your device manufacturer(s) or browser provider(s) to learn what information they provide to us. 

Personal Data We Collect from Third Parties.  We may collect your Personal Data from the following sources: 

  • Public records; 
  • Service Providers, who collect data on our behalf; 
  • Advertising Partners, who assist us with marketing or promotional services related to how you interact with the Websites; 
  • Linked Social Media Platforms, if you choose to connect with us through your social media accounts. 
4. HOW WE MAY USE YOUR INFORMATION 

We may use your Personal Data for various business or commercial purposes, which are outlined below. 

We may use the information we collect and derive for the following purposes: 

  • Verifying Identity. We use your Personal Data to verify your identity and/or to confirm that individuals are authorized to access, use, or share information related to claims or other services. 
  • Providing services such as our Websites. We use your Personal Data to provide you with, maintain, and/or modify the Websites, and/or complete the transaction for which we collected the Personal Data. 
  • Improving our Business Operations. We use your Personal Data to evaluate, analyze, improve, and develop our products and services, including the Websites such as performing security and quality controls of the Websites, develop new products and services, improve, enhance, and facilitate your use of the Websites and other features of our Business Operations, including research and development, offer location customization and personalized help and instructions, and to otherwise understand and analyze how you interacts with our Business Operations and personalize your experiences. 
  • Data Analytics. We use your Personal Data we collect to conduct data analytics, improve our tools, surveys, benchmarking, or other related business purposes, including for the purposes of creating Aggregated Data and developing industry and sector-wide reports or whitepaper. 
  • Personalization and Marketing.  We use your Personal Data to communicate with you about information that we think may interest you, such as newsletter, events, promotions, and campaigns, including promotion of our services via direct marketing and advertisement, or our partners.  We may communicate with you via email, LinkedIn, mail, or other interaction channels, or personalize your experience interacting with us, including suggesting and offering you relevant content and recommendations. 
  • Communication and Customer Care. We use your Personal Data to communicate with you about your interaction with our Business Operations, to respond to your comments and inquiries, provide you with the information and documents you request, and for other customer service purposes. 
  • Legal Requirements. We use your Personal Data to enforce our terms and conditions or protect our business or our Customers, and to comply with our contractual and legal obligations as set forth below in Section 4 (How We May Disclose Your Information). 
  • Security and Fraud Prevention. We use your Personal Data to protect, investigate, mitigate, and deter against fraudulent, malicious, unauthorized, infringing, or illegal activity relating to our Business Operations, assets, or products or monitor and ensure the safety and security of our premises, property, employees and visitors. 
  • Corporate Activities.  We may use your Personal Data in connection with evaluating, conducting or implementing a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by us is among the assets transferred. 
  • Business Operations.  We may use your Personal Data in connection with our regular business operations, such as maintain accounting records, analyze financial results, comply with internal audit requirements; or obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. 

We may use your Personal Data for other purposes that are consistent with, related to and/or ancillary to the purposes and uses described in this General Privacy Policy, for which your Personal Data was provided to us. 

5. HOW WE MAY DISCLOSE YOUR INFORMATION: 

We may share Personal Data for purposes in accordance and consistent with this General Privacy Policy. 

When permitted by applicable privacy laws, including with your consent, legal obligations, or for our legitimate business purposes, or as mandated by Legal Requests (as defined below), we may share or exchange your Personal Data with our affiliates, business partners, service providers, and others, as follows: 

  • Third-Party Vendors: We may share your Personal Data with other parties who perform functions on our behalf such as billing and payment, customer services, information technology, cloud service, web hosting, document management providers, debt collection agencies, and marketing and advertising, other services relating to our Business Operations. 
  • Our Customers:  In performing services to a customer that engages us for managed security services and other offerings, we may collect certain Personal Data for and on behalf of our customer and may share such Personal Data with the customer in accordance with terms of our engagement letter with such customer.  In that case, our use and disclosure of such Personal Data may be subject to our customer’s Privacy Policy, or engagement letter with such customer, who may use it for their own purposes. 
  • Corporate Affiliates: We may share your Personal Data with our subsidiaries or affiliates, so that they may provide and improve our Business Operations or other service offerings, send you information about special offers or products and services that may be of interest to you based on your activities on our website, your interactions with us both virtually or offline, and/or other information that you have given us. 
  • Advertising or Marketing Partners. We may share limited personal data (such as electronic identification data, contact information, approximate locations, and conversion status) with our advertising partners, including social media platforms such as LinkedIn etc., based on how you interact with us or to create list of specific target audiences. 
  • Acquisition and Similar Transactions: If we sell, transfer, or otherwise share some or all of our assets in connection with a merger, reorganization, liquidation, dissolution, bankruptcy, or sale of assets, we may transfer your Personal Data as a part of the assets transferred as a result of the transaction without your consent. 
  • Legal Requests or Legal Claims: We may disclose Personal Data as required by laws, court orders, subpoena, or other legal process or if we reasonably believe such action is necessary to comply with the laws and the reasonable requests of regulators, law enforcement, or other public authorities or quasi-government authorities, including fraud detection agencies (“Legal Requests”).  We may also disclose the information to establish, protect, or exercise our rights; to defend against a legal claim; to detect, investigate, prevent, or take action against illegal activities or potential threats to the rights, property, or safety of any other person; or as otherwise required by law. 
  • Professional Advisors: We may share your Personal Data with our attorneys, accountants, auditors, tax advisors, investment advisors, financial institution or other lenders, insurers, underwriters, actuaries, claims handlers and investigators, surveyors, and/or other fiduciaries and consultants that need access to your information to provide operational or other support on our behalf. 
  • With Your Consent or at Your Direction: We may ask, from time to time, if you would like us to share your information with other unaffiliated third parties who are not described elsewhere in this General Privacy Policy.  We may disclose your information in this context with your permission or upon your direction.  For example, where you submit a request for a referral, or ask us to refer you to or match you with another professionals, we will share the information that you provide us, with such other professionals who may be able to assist with your project. 
6. DATA RETENTION 

Nothing is forever.  We have a few rules on how we retain your information. 

We retain and use your Personal Data for an appropriate period of time as is necessary to fulfill the purposes for which it was collected, to comply with our business requirements and legal obligations, to resolve disputes, to protect our assets, to provide our services, to pursue legitimate business purposes, to enforce our agreements, and other business or commercial purposes to the extent provided in this General Privacy Policy. 

We take reasonable steps to delete the Personal Data we collect when (1) we have a legal obligation to do so, (2) we no longer have a purpose for retaining the information, or (3) if you ask us to delete your Personal Data, unless we determine that doing so would violate our existing, legitimate legal, regulatory, dispute resolution, contractual, or similar obligations.  We may also decide to delete your Personal Data if we believe it is incomplete, inaccurate, or that our continued storage of your Personal Data is contrary to our legal obligations or business objectives.  When we delete your Personal Data, it will be removed from our active servers and databases; however, it may remain in our archives when it is not practical or possible to delete it. 

7. DATA SECURITY 

We do our best to protect your information and ask that you work with us to keep it confidential, safe, and secure. 

We recognize the importance of safeguarding your Personal Data and we endeavor to maintain reasonable and appropriate physical, technical, and organizational safeguards, such as the implementation of reasonable security measures or protocols, designed to protect your Personal Data against accidental loss and unauthorized access, use, alteration, or disclosure, and to detect fraudulent identity verification activity and mitigate risks concerning your Personal Data. 

While we strive to identify and implement appropriate security measures to protect Personal Data in our possession, no security system is perfect, and no data transmission is 100% secure.  As a result, while we strive to protect your information, we cannot guarantee or warrant the security of any information you transmit to or from the Websites or other interactions with our Business Operations.  The safety and security of your Personal Data also depends upon you.  Where you use a password for access to restricted parts of the Websites or other aspect of our Business Operations, you are responsible for keeping your password confidential.  DO NOT SHARE YOUR PASSWORD WITH ANYONE. 

8. YOUR CHOICES TO CONTROL YOUR INFORMATION 

Here are a few ways that you can control how we interact with you. 

You may adjust the settings of your devices accessing the Websites, use the “Contact Us” details listed at the beginning of this General Privacy Policy to exercise certain rights and choices under applicable data privacy laws, or file a complaint with us.  Additional opt-out options for communications are provided below: 

Communication Preferences. If you no longer wish to receive communications from us via email, you may opt-out of certain types of communications (as described below) by clicking the “unsubscribe” link at the bottom of our emails or by contacting us at the “Contact Us” details listed at the beginning of this General Privacy Policy and providing your name and email address so that we may identify you in the opt-out process.  Once we receive your instruction, we will promptly take action. 

  • Marketing Communications.  We will send you email notifications and free newsletters from time to time with offers, suggestions, and other information.  You may “opt-out” from receiving marketing emails from us by following the “Unsubscribe” instructions provided in any such email we send you. 
  • Legal or Security Communications.  We also send out notices that are required for legal or security purposes. For example, certain notifications are sent for your own protection.  In other cases, these notifications involve changes to various legal agreements, such as this General Privacy Policy or other applicable terms posted on the Site or made available to you at the time of data collection. Generally, you may not opt out of such emails. 
  • Account Communications.  If you subscribe to certain account communication, we may send you communications regarding such additional services.  We may also send communications providing customer support or responses to questions regarding the operation of the Websites or other aspect of our Business Operations.  Generally, you may not opt out of such emails. 

Online Tracking Signals. We adhere to the standards set out in this General Privacy Policy and do not currently respond to “Do Not Track” signals on the Websites or on third-party websites or online services where we may collect information. 

Accuracy and Updating Your Personal Data. If any of the Personal Data you have provided to us changes, please update it in your user/account profile, or let us know via the “Contact Us” details listed at the beginning of this General Privacy Policy so that we can continue to communicate with you.  If you become aware of inaccurate Personal Data about you, you may want to update your information.  We are not responsible for any losses arising from any inaccurate, inauthentic, deficient, or incomplete Personal Data that you provide to us. 

Complaints. If you believe that your rights relating to your Personal Data have been violated, you may lodge a complaint with us by contacting us via the “Contact Us” details at the end of this General Privacy Policy. 

8. COOKIES AND SIMILAR TECHNOLOGIES 

Your browsing activities and other use of Services are monitored by Cookies and other tools. 

We (and where applicable, third parties) use cookies, pixel tags, scripts and similar technologies (collectively referred to as "Cookies and Similar Technologies") to automatically collect and record information about your browsing activities, and use of the Websites.  We may combine this “Usage Information” with other Personal Data that we collect about you. 

  1. First and Third-Party Cookies 

A “cookie” is a small file created by a web server that can be stored on your device through the Websites. 

  • Session vs. Persistent Cookies. “Session” cookies are temporarily stored on your hard drive and only last until they expire at the end of your browsing session. “Persistent” or “permanent” cookies remain stored on your hard drive until they expire or are deleted by you. 
  • First-Party vs. Third Party Cookies. “First-party cookies” are set by the website you’re visiting, and they can only be read by that site.  “Third-party cookies” are set by a party other than that website.  You can block and control cookies using the information noted below. If you block all cookies, certain functionalities on the Websites may not work. 
  1. Other Similar Technologies 

In addition, there are other automatic data collection technologies, such as Internet tags, web beacons (clear gifs, pixel tags, and single-pixel gifs), and navigational data collection (log files, server logs, etc.), HTML Local Storage, Social Widgets, or UTM Codes that can be used to collect data as users navigate through and interact with a website or emails.  These similar technologies can be embedded in a web page or in an email to transmit information, which may include Personal Data. 

  1. What Cookies and Similar Technologies Are in Use and Why Do We Use Them? 

Type of Cookies 

Description 

Essential cookies 

Required cookies enable you to navigate the Websites and use its features. 

 

If you have chosen to identify yourself to us, we use cookies containing encrypted information to allow us to uniquely identify you. Each time you log into the Websites, a cookie containing an encrypted, unique identifier that is tied to your account is placed on your browser. These cookies allow us to uniquely identify you when you are logged into our Site and to process your online transactions and requests. 

 

Functionality cookies 

Functionality cookies allow the Websites to remember information you have entered or choices you make (such as your username, language, or your region) and provide enhanced, more personal features. These cookies also enable you to optimize your use of the Websites after logging in. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customize. 

 

We may use local shared objects, also known as Flash cookies, to store your preferences or display content based upon what you view on the Websites to personalize your visit. 

 

Performance cookies 

These cookies collect information about how you use the Websites, including which pages you go to most often and if they receive error messages from certain pages. These cookies do not collect information that individually identifies you. All information these cookies collect is aggregated and anonymous. It is only used to improve how the Websites functions and performs. 

 

From time-to-time, we may engage third parties to track and analyze usage and volume statistical information from individuals who visit the Websites. We may also utilize Flash cookies for these purposes. 

 

Marketing cookies 

Marketing Cookies deliver advertisements (“ads”) that may be more relevant to you and your interests.  They may be 1st Party Cookies or 3rd party Cookies placed by us, by our service providers on our behalf, or by third party business partners with our permission. 

We, our service providers, or our business partners may use targeting or advertising Cookies to track how you visit the Websites, browse pages on the Websites, and click on certain links.  These Cookies help measure the effectiveness of our advertising campaigns.  We may also allow our third-party business partners to use targeting or advertising Cookies on the Websites for similar purposes, including collecting information about your online activities over time and across different websites.  They also perform functions, such as preventing the same ads from continuously reappearing, ensuring that ads are properly displayed, and in some cases selecting ads that are based on your interests. 

 

Google Analytics. Where you have explicitly consented or have not disabled third party advertising cookies (depending on your location), we may use Google Analytics to collect and process statistical data about the number of people using the Websites and to better understand how they find and use the Websites. The data collected includes data related to your device/browser, your IP address, and on-site activities to measure and report statistics about user interactions on the Websites. Any data collected is used in accordance with this General Privacy Policy and Google’s privacy policy. You may learn more about Google Analytics by visiting: 

https://policies.google.com/technologies/partner-sites and; 

https://support.google.com/analytics/answer/6004245. 

You can learn more about Google’s restrictions on data use by visiting the Google privacy policy at: https://policies.google.com/privacy. To opt-out of Google Analytics, visit https://tools.google.com/dlpage/gaoptout and install the opt-out browser add-on feature. For more details, visit the “Google Analytics opt-out browser add-on” page (located at https://support.google.com/analytics/answer/181881?hl=en). 

  1. Choices About Cookies 

Most web browsers are set by default to accept cookies. If you do not wish to receive cookies, you may set your browser to refuse all or some types of cookies or to alert you when cookies are being sent by website tracking technologies and advertising. You may adjust your browser settings to opt out of accepting a “persistent” cookie and to only accept “session” cookies, but you will need to log in each time you want to enjoy the full functionality of the Websites. 

If you decline the use of cookies, you may not have access to the full benefits of the Websites. Further, your opt-out only applies to the web browser you use, so you must opt out of each web browser on each computer you use. Once you opt out, if you delete your browser’s saved cookies, you will need to opt out again. In addition, adjusting the cookie settings on the Websites may not fully delete all of the cookies that have already been created. To delete them, visit your web browser settings after you have changed your cookie settings on the Websites. 

Additional information is provided below about how to disable cookies or manage the cookie settings for some of the leading web browsers (PLEASE NOTE: these third-party links are provided for your convenience, and we may not actively monitor the content of these links): 

Google Chrome 

https://support.google.com/chrome/answer/95647?hl=en 

Firefox 

https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences 

Internet Explorer 

http://windows.microsoft.com/en-GB/windows-vista/Block-or-allow-cookies 

Microsoft Edge 

https://support.microsoft.com/en-us/microsoft-edge/delete-cookies-in-microsoft-edge-63947406-40ac-c3b8-57b9-2a946a29ae09 

Safari; iOS 

https://support.apple.com/guide/safari/manage-cookies-and-website-data-sfri11471/mac and https://support.apple.com/en-us/HT201265 

Adobe Flash Cookie 

https://www.macromedia.com/support/documentation/en/flashplayer/help/help09.html 

 

For more information on how to modify your browser settings to block or filter cookies, visit http://www.aboutcookies.org/ or http://www.cookiecentral.com/faq/. 

9. THIRD PARTY WEBSITES OR TECHNOLOGIES 

This Privacy Policy does not apply to any third-party websites or applications. 

The Services may contain links to websites or mobile applications operated and maintained by third parties and subject to their own privacy policies.  If you follow any links that direct you away from the Websites, including links to social media sites, this General Privacy Policy will not apply to your activities on those external sites you visit.  Because of the dynamic media capabilities of the Websites, it may not be clear to you whether certain sites or applications are linked to the Websites or connected to external, third party websites.  If you click on an embedded third-party link, you will be redirected away from the Websites to the external third-party website.  You can check the URL to confirm if you are no longer accessing the Websites. 

While these third-party websites and applications are selected with care, we are not responsible for the use and collection of your information by these third-party sites, and cannot guarantee the adequacy of these third-party sites’ privacy and security practices.  A link to a third party’s website should not be construed as an endorsement.  For more information, please consult the privacy statement of the third party sites you are visiting (if such such a statement is provided). 

10. CHILDREN’S PRIVACY 

Only individuals over age of 18 may use the Websites or otherwise interact with our Business Operations. 

As a manage security service provider, we deliver services to our corporate customers.  Therefore, no part of our Business Operations is directed to children under the age of 18, and no one under the age of 18 may access, browse, or use the Websites or provide any information to us. Consequently, we do not knowingly collect or directly solicit Personal Data from anyone under the age of 18.  If you are under the age of 18, please do not submit any Personal Data about yourself to us through the Websites or offline.  If we learn that we have collected Personal Data from a child under the age of 18 without a parent’s or legal guardian’s consent, we will take steps to stop collecting that information and delete that information as quickly as possible.  If you are a parent or guardian of a child under 18 years of age and you believe your child has provided us with Personal Data, please contact us by following instructions at the “Contact Us” section above. 

For information about the legal background of children’s privacy regulations, please visit the Federal Trade Commission’s website at: https://www.ftc.gov/enforcement/rules/rulemaking-regulatory-reform-proceedings/childrens-online-privacy-protection-rule. 

11. UPDATES TO THIS PRIVACY POLICY 

We may modify or update this General Privacy Policy from time to time. 

We reserve the right to add to, change, update, or modify this General Privacy Policy at any time to reflect any changes to how we treat your information or in response to changes in law.  In the event of such changes, the modified version of this General Privacy Policy will be re-posted on this page with the date of the modifications as indicated on the top of the page.  If we make material changes to how we treat your information, we may notify you about this with a link to the revised Privacy Policy or through a notice on the homepage of the Websites for a reasonable period of time.  All changes are effective on the date listed at the top of this page and will apply to all information that we have about you. 

You are expected to, and you acknowledge and agree that it is your responsibility to, carefully review this General Privacy Policy prior to interacting with our Business Operations, and from time to time, so that you are aware of any changes.  Your continued use of the Websites or otherwise interact with our Business Operations after the “Last Updated” date indicates your acceptance of the changes and your continued consent to our processing of your Personal Data according to the terms of the then-current Privacy Policy.  If at any point you do not agree to any portion of this General Privacy Policy (other than those information in connection with our HR operations based on our legitimate interests or for business purposes as defined under applicable state laws), then you should immediately stop interacting with our Business Operations.  Because this General Privacy Policy contains legal obligations, we encourage you to review it carefully. 

12. INTERNATIONAL PERSONAL DATA TRANSFERS 

We may transfer your information to a foreign jurisdiction outside of the country you currently reside. 

Please note that we may transfer, or otherwise make available your Personal Data to countries outside of your country of residence (“International Data Transfers”).  Some of these jurisdictions may not offer the same level of protection as the laws in your country of residence or citizenship.  BY VISITING OUR WEBSITE OR OTHERWISE INTERACTING WITH OUR SERVICES FROM A COUNTRY OTHER THAN THE UNITED STATES, YOU UNDERSTAND AND CONSENT TO THE COLLECTION, STORAGE, PROCESSING, AND TRANSFER OF YOUR INFORMATION TO U.S.-BASED FACILITIES OPERATED BY US, OUR SERVICE PROVIDERS, SUPPLIERS, AND/OR OTHER RECIPIENTS AS DESCRIBED IN THIS PRIVACY POLICY. 

If you are located in the European Economic Area (“EEA”), the United Kingdom (“UK”), Switzerland, or countries with cross border transfer restrictions, we rely on recognized data transfer mechanism recognized under the data privacy laws in these jurisdictions, such as the Standard Contractual Clauses or other approved data transfer or certification mechanisms. 

13. INTERNATIONAL DATA PRIVACY ADDENDUM 

This addendum applies if you reside in EEA, UK, or Switzerland. 

This addendum to the General Privacy Policy applies only if you use or interact with our Business Operations from a Member State of the European Union or EEA, UK, or Switzerland, and it supplements the information in the remainder of our General Privacy Policy, above. 

  1. Legal Basis for Data Processing: We may process your Personal Data in connection with any of the purposes and uses set out in this General Privacy Policy based on one or more of the following legal grounds: 
  • Performance of a Contract: As necessary to perform the services you have requested or to comply with your instructions or other contractual obligations between you and us. 
  • Legal Obligations: As necessary to comply with our legal obligations as well as to keep records of our compliance processes (for example, to comply with applicable accounting rules and to make mandatory disclosures to law enforcement). 
  • Legitimate Interest: Because of our legitimate interests, or those of a third-party recipient of your Personal Data, to make the processing necessary, provided those interests are not overridden by your interests or fundamental rights and freedoms, such as to ensure that we provide.  As set forth below, you have the right to object to our processing of your Personal Data based on our legitimate interests and we must stop such processing unless we have a compelling interest in the continued processing that overrides yours. 
  • Vital Interest: As necessary to protect your vital interests; 
  • Public Interest: As necessary in the public interest; 
  • Consent: Because you have expressly given us your consent to process your Personal Data in a particular manner. 
  1. Data Subject Rights: If you are located in the EEA, the UK, Switzerland, you have the following rights under the applicable data privacy laws.  All requests should be sent to the address noted in the “Contact Us” section of this General Privacy Policy, and we will fulfill requests to the extent required by applicable laws. 
  • Right of Access. To the extent required by law, you have the right to (i) receive confirmation as to whether or not Personal Data concerning you are being processed, (ii) where that is the case, access to the Personal Data; and (iii) the following information: the purposes of the processing; the categories of Personal Data concerned; and the recipients or categories of recipient to whom the Personal Data have been or will be disclosed.  We will provide a copy of your Personal Data in compliance with applicable law. 
  • Right of Rectification. Our goal is to keep your Personal Data accurate, current, and complete. Please contact us if you believe your information is not accurate or if it changes. 
  • Right to Erasure. In some cases, you have a legal right to request that we delete your Personal Data when (1) it is no longer necessary for the purposes for which it was collected, (2) consent has been withdrawn in certain instances, (3) you have objected to the processing in certain instances, (4) the Personal Data has been unlawfully processed, (5) the Personal Data have to be erased for compliance with a legal obligation; and (6) the Personal Data were collected in relation to the offer of information society services.  However, the right is not absolute.  When we delete Personal Data, it will be removed from our active servers and databases as well as the Platform; but it may remain in our archives when it is not practical or possible to delete it.  We may also retain your Personal Data as needed to comply with our legal obligations, resolve disputes, or enforce any agreements. 
  • Right to Restrict Processing. You have the right to restrict the processing of your Personal Data when (1) the accuracy of the Personal Data is contested, for a period enabling the controller to verify the accuracy of the Personal Data; (2) the processing is unlawful and you oppose erasure and request a restriction instead; (3) we no longer need the Personal Data, but you need us to keep it for the establishment, exercise, or defense of legal claims; or (4) you have objected to us processing the Personal Data, pending resolution of the objection. 
  • Right to Portability: You have right to request that we made available, in a portable form, your Personal Data in our possession so that you can transfer to a third party. 
  • Right to Object. In certain circumstances, you have the right to object to the processing of your Personal Data where the processing is necessary for performance of a task carried out in the public interest, for our Legitimate Interests, or for the Legitimate Interests of others.  You also have the right to object where Personal Data is processed for direct marketing purposes or for scientific or historical research purposes or statistical purposes. 
  • Right to Withdraw Consent. If you have provided your consent to the collection, processing, and transfer of your Personal Data, you may have the right to fully or partially withdraw your consent. Once we have received notice that you have withdrawn your consent, in whole or in part, we will no longer process your information for the purpose(s) to which you originally consented and have since withdrawn unless there are compelling legitimate grounds for further processing that override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims. Withdrawal of consent to receive marketing communications will not affect the processing of Personal Data for the provision of our Business Operations. 
  1. Data Retention. Please review Section 5 (Data Retention), above. 
  1. Inquiries and Complaints. 

If you have questions or concerns regarding this addendum or would like to exercise your data subject rights regarding your Personal Data, please contact us by following the instructions set forth in “Contact Us”. 

You also have the right to make a complaint to the relevant Supervisory Authority or seek a remedy through the courts. A list of Supervisory Authorities is available in the table below (PLEASE NOTE: these third party links are provided for your convenience, and we may not actively monitor the content of these links): 

Within EEA 

https://edpb.europa.eu/about-edpb/about-edpb/members_en 

United Kingdom 

https://ico.org.uk/make-a-complaint/ 

Switzerland 

https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact.html 

 

 

14. STATE-SPECIFIC DATA PRIVACY ADDENDUM 

Effective Date: September 1, 2023 

This addendum (“U.S. Privacy Addendum”) supplements our General Privacy Policy and provides additional information regarding privacy rights provided under applicable U.S. state laws to the extent applicable, and expressly include the California Privacy Rights Act of 2020 and its implementing regulations as amended from time to time (“California Privacy Laws”).  For the purposes of this U.S. Privacy Addendum, “Personal Information” shall have the same meaning as the term “personal data”, “personal information”, or “personally identifiable information” as defined in the U.S. state privacy laws, as applicable. 

We reserve the right to amend this U.S. Privacy Addendum at our discretion and at any time.  When we make changes to this notice, we will post the updated version on our website and update the Effective Date for the applicable section. 

NOTICE TO CALIFORNIA RESIDENTS 

If you are a California resident (“Consumers” or “California Consumer”) from whom we collect Personal Information as a business (as defined under the California Privacy Laws), you may rely on the General Privacy Policy and the additional information below. 

  1. Personal Information Collected 

Consistent with Section 2 (Information We May Collect) of our General Privacy Policy, the table below describes the categories of Personal Information that we may collect and/or that we have collected within the preceding 12 months: 

  1. Data Category Table 

Category 

Examples 

Collected? 

(Yes/No) 

Identifiers 

Name, postal address, unique personal identifier, IP address, email address, or other similar identifiers. 

 

Yes 

Personal Information as defined in Cal.  Civ. Code § 1798.80(e) 

Name, telephone or cell phone number. 

 

Yes 

Protected Classification 

Characteristics of protected classifications under state or federal law (i.e., age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status. 

No 

Commercial Information 

Products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. 

 

Yes 

Biometric Information 

Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. 

 

No 

Internet or other similar activity 

Browsing history, search history, information on a Consumer's interaction with a website, application, or advertisement, which may include your username, password and other identifiers set to access your network or any password-protected sites, applications, and other services, IP addresses, log files, login information, and software and hardware inventories, browsing history, search history, and information regarding a Consumer’s interaction with an Internet Web site, application, or advertisement. 

 

Yes 

Geolocation Data 

 

Physical location or movements. 

 

No 

Sensory Data 

Audio, electronic, or similar information 

 

  • We collect this category of Personal Information directly from you and your devices through audio recordings of customer service calls; audio/video recordings of in-person and/or virtual meetings, presentations, and events; among others. 

 

Yes 

Professional or employment related information 

Occupation, current or past employment history or performance evaluations 

 

No 

Non-public education information 

Education records directly related to a student maintained by an educational agency/institution, such as, grades, transcripts, class lists, student identification codes, student financial information, or student disciplinary records. 

 

No 

Inferences drawn from other PI 

Inferences drawn from any of the information identified in this list to create a profile about a Consumer reflecting the Consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. 

 

No 

Sensitive Personal Information** 
  • Social Security Number, Driver’s License Number, State ID or Passport Number 
  • Account log-in, financial account, debit/credit card # in combination with security or access code, password, or credentials allowing access to an account. 
  • Racial or ethnic origin, religious or philosophical belief, or union membership 
  • Contents of Consumer’s mail, email, and text messages 
  • Health Data 

 

No 

Personal Information does not include: 

  • Publicly available information from government records or lawfully obtained, truthful information that is a matter of public concern; or 
  • De-identified, anonymized, or aggregated information that cannot be attributed back to an individual (“Aggregated Data”). 
  • Information excluded from the scope of California Privacy Laws including, but not limited to: 
  • An activity involving the collection, maintenance, disclosure, sale, communication, or use of any Personal Information bearing on a Consumer’s credit worthiness, credit standing, credit capacity, character, general reputation, personal characteristics, or mode of living by a consumer reporting agency, a furnisher of information who provides information for use in a consumer report, and by a user of a consumer report provided that the agency, furnisher, or user is subject to regulation under the Fair Credit Reporting Act (“FCRA”). 
  • Medical information governed by the Confidentiality of Medical Information Act or protected health information as governed by the U.S. Department of Health and Human Services pursuant to the Health Insurance Portability and Accountability Act of 1996 (HIPAA). 

For additional details, please refer to Section 2 (Information We May Collect) of our General Privacy Policy. 

  1. Categories of Sources. We collect Personal Information directly and indirectly from the following categories of sources: 
  • Directly from you, and/or your devices. 
  • Indirectly from your activities on your devices, our website and related domains, and/or Services. 
  • From your activities on the customer portal made available to our clients 
  • From our clients and business partners, such as commercial clients, corporate policyholders, insurers, reinsurers, brokers, network partners, and service providers. 
  • From other third parties, such as social media sites, advertising networks, analytics partners, and other third parties that we interface with. 
  • From government authorities. 
  • From publicly available sources. 

For additional details, please refer to Section 2 (Information We May Collect) of our General Privacy Policy. 

  1. Purposes for Which We Use Your Personal Information. 

We use the categories of Personal Information listed above to make available to you our Websites, to operate, manage, and maintain our Business Operations as disclosed in Section 3 (How We May Use Your Information) of our General Privacy Policy, and to accomplish other business purposes, including the following: 

  • Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards. 
  • Helping to ensure security and integrity to the extent the use of your Personal Information is reasonably necessary and proportionate for these purposes. 
  • Debugging to identify and repair errors that impair existing intended functionality. 
  • Short-term, transient use, including, but not limited to, non-personalized advertising shown as part of your current interaction with us. 
  • Performing services on our behalf, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on our behalf. 
  • Providing advertising and marketing services to you, except for cross-context behavioral advertising. 
  • Undertaking internal research for technological development and demonstration. 
  • Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us. 
  • Other purposes as expressly authorized by the implementing regulations of the California Privacy Laws. 
  1. Categories of Personal Information Disclosed for a Business Purpose 

In the preceding 12 months, we have disclosed the following categories of Personal Information for a business purpose: 

  • Categories of Personal Information that we answer “Yest” in the Data Category Table above. 

The categories of third parties to whom we may disclose Personal Information for a business purpose include the third parties set forth in Section 4 (How We May Disclose Your Information) of our General Privacy Policy.  Specifically, within the past 12 months, we may have disclosed Personal information to our service providers associated with our website operations certain identifiers, information about the use of our Websites, including applications and/or account logins described under the category of “Internet and Other Similar Activity” as a result of your interfaces with the Websites. 

  1. Categories of Personal Information Sold or Shared to Third Parties 

California Privacy Laws define “sale” as disclosing or making available Personal Information to a third-party in exchange for monetary or other valuable consideration.  The term “sharing” includes disclosing or making available Personal Information to a third-party for purposes of cross-context behavioral advertising and constitute a form of “sale”.  While no Personal Information is sold for monetary consideration, disclosures of certain identifiers, information about how an individual interacts with a website, and other “Internet and Other Similar Activity” information described above, in certain instances, may constitute a “sharing” of Personal Information for cross-context behavioral advertising as broadly defined under California Privacy Laws.  To the extent such exchanges occur, a California Consumer may exercise his or her rights under the Right to Opt-Out described in Section (B)(iii) of this Notice to California Residents. 

  1. Data Retention 

We keep your Personal Information only as long as necessary to fulfill the purposes for which it was collected and processed, including for the purposes of satisfying any legal, regulatory, accounting or reporting requirements. For additional details, please refer to Section 5 (Data Retention) of our General Privacy Policy. 

  1. Your California Privacy Rights. 

This section describes your rights under California Privacy Laws and explains how to exercise those rights, subject to certain exceptions: 

  1. Right to Know. With respect to the Personal Information, we have collected about you, you have the right to request from us: 

The categories of Personal Information we have collected about you during the past 12 months; 

  • The categories of sources from which the Personal Information was collected; 
  • The business or commercial purpose(s) for which the Personal Information was collected, sold, or shared; 
  • The categories of third parties with whom we disclose that Personal Information for a business purpose; and 
  • The specific pieces of Personal Information we collected about you in a format easily understandable to the average Consumer (also called a “Data Portability Request”). 

In addition, to the extent we sell or share Personal Information, a Consumer shall have the right to request the business to identify, during the past 12 months: 

  • The categories of Personal Information that we sold or shared, and the categories of third party recipients; and 
  • The categories of Personal Information disclosed for a business purpose and the categories of recipients. 
  1. Right to Deletion.  Subject to several exceptions, you have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions and as permitted under the California Privacy Laws. 
  1. Right to Opt-out of “Sale” and Certain “Sharing” Practices. A California Consumer has the right to opt-out of the “sale” and “sharing” of your Personal Information with third parties, as those terms are defined under California Privacy Laws. “Sell” in this case does not mean providing data in exchange for money – we don’t do that.  “Selling” or “sharing” instead means the disclosure or release of Personal Information, including technical device data that does not identify you directly but can be attributed back to identify you, when a third party might use that data for its own purposes, such as for personalized advertising or cross-context behavioral advertising, whether or not for monetary or other valuable consideration.  We do not have actual knowledge that we sell Personal Information of minors under 16 years of age.  While this Consumer right is not applicable to how we collect or use your Personal Information, we provide this information as this is a core part of your rights as a California Consumer.  
  1. Right to Correct. Subject to certain restrictions, you have the right to request that we correct inaccurate Personal Information that we maintain about you.  Our goal is to keep your Personal Information accurate, current, and complete.  If you believe your Personal Information is not accurate (other than the one listed on your account, which you may modify at any time), you may submit a request by using the “How to Exercise Your California Privacy Rights” section of this Notice to California Residents. 
  1. Right to Limit Use and Disclosure of Sensitive Personal Information.  In certain circumstances, a California Consumer has the right to limit the use and disclosure of Sensitive Personal Information.  Our use of your Sensitive Personal Information is reasonably necessary to perform services or provide goods reasonably expected by an average Consumer and not for those purposes for which you may exercise a right to limit the use or disclosure under California Privacy Laws.  While this Consumer right is not applicable to how we collect or use your Sensitive Personal Information, we provide this information as this is a core part of your rights as a California Consumer. 
  1. Right to Non-Discrimination. We will not discriminate against you for exercising any of your rights under California Privacy Laws.  Unless permitted by California Privacy Laws, we will not: 
  • Deny you goods or services; 
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties; 
  • Provide you a different level or quality of goods or services; or 
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services. 
  1. Other California Privacy Rights. California's “Shine the Light” law (Civil Code Section § 1798.83) permits California residents who are users of our websites to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes.  We do not disclose your Personal Information to third parties for their direct marketing purposes. 
  1. How to Exercise Your California Privacy Rights 
  1. Methods to Submit California Consumer Requests 

If you are a California Consumer and would like to exercise your rights under California Privacy Laws described above, you may do so via any of the methods described below: 

  • Calling us at 1-844-684-9201or 

 

  1. Authorized Agent. You may designate an authorized agent to make a request on your behalf.  Authorized agents will be required to provide proof of their authorization.  Individuals operating as an authorized agent on behalf of a California Consumer must provide a written authorization document, signed by the California Consumer, containing the California Consumer’s name, address, telephone number, and valid email address, and expressly authorizing the individual to act on behalf of the California Consumer.  We may also require that you directly verify your identity and the authority of your authorized agent.  We reserve the right to reject authorized agents who have not fulfilled the above requirements or automated requests under California Privacy Law where we have reason to believe the security of the requestor’s Personal Information may be at risk. 
  1. Verification Procedures.  We are required by California Privacy Laws to verify the identity of individuals who submit a Consumer request.  The verifiable Consumer request must provide sufficient information that allows us to reasonably verify your identity and describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.  The information we may need in order to verify your identity differs depending upon the request made and our relationship with you and might include (as applicable) your name, the email address you regularly use to interact with us, your telephone number, your date of birth, etc. We will take steps to verify your request by matching the information provided by you with the information we have in our records.  In some cases, we may request additional information to verify your identity, or where necessary to process your request.  We can only respond to your request or provide you with relevant information if we are able to verify your identity or authority to make the request.  If we are unable to verify your identity after a good faith attempt, we may deny the request and, if so, will explain the basis for the denial. 
  1. Response Timing: 
  • General Response Time: Upon receiving a Request to Know, Request to Delete, or Request to Correct, we will confirm receipt of the request within 10 business days and respond to the request within 45 calendar days from the date we receive your request.  If necessary, we may take an additional 45 calendar days to respond to your request.  If this extension is needed, we will notify you of the extension and explain the reasons that responding to your request will take more than 45 days.  We are only required to respond to Requests to Know and Data Portability Rights twice in a 12-month period. 
  • Opt-Out/Limit Requests (where applicable): To the extent applicable, California Privacy Laws require a business to respond as soon as feasibly possible to verified request by a Consumer, up to a maximum of 15 business days from the date it receives the verified consumer request to exercise the Right to Opt-out of Sale/Sharing or Right to Limit the Use and Disclosure of Sensitive Personal Information. We provide this information as this is a core part of a California Consumer’s rights.