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SECURONIX PRIVACY POLICY

Effective Date: August 15, 2022

This Privacy Policy (“Policy”) describes how Securonix (‘Securonix”, ‘we’, ‘us’
or ‘our’) processes information collected from and about users of our
website www.securonix.com (the “Website”) and our related services, including
the Securonix Cloud (collectively, “Services”). It also describes the choices
available to you regarding our processing of your information.

This Policy contains the following sections:

 * The Information We Collect
 * How We Use Your Information
 * Online Analytics and Advertising
 * How We Share Your Information
 * Your Rights and Choices
 * How We Secure Your Information
 * Data Retention
 * Notice of Policy Changes
 * Privacy Information for International Users
 * Privacy Information for California Residents
 * Privacy Information for Nevada Residents
 * Contact Securonix

The Information We Collect

This section discusses the types of information we collect from and about you as
you use the Services.

Information You Provide to Us

When you use our Services, you may choose to provide certain information
directly to us. For example, we collect information directly from you when you
register for the Services, interact with us through online forms or customer
service, participate in surveys or research, or otherwise interact with us
through the Services. This information includes:

 * First and last name
 * Email address
 * Mailing address
 * Account name
 * Mobile number
 * Company name and job title
 * Payment information (collected by our third-party payment processor) and
   related transaction information

Note regarding sensitive information: the Services are not intended for the
transmission of sensitive information (e.g., information related to racial or
ethnic origin, political opinions, religion or other beliefs, health, criminal
background, or trade union membership) or any protected health information as
defined by the Health Insurance Portability and Accountability Act of 1996
(otherwise known as “HIPAA”) Standards for Privacy of Individually Identifiable
Health Information, as amended. You agree that you will not transmit such
sensitive information through the Services unless otherwise provided in your
written agreements with Securonix.

Information we Automatically Collect as you Use the Services

There is certain information that we collect automatically from your use of the
Services and from your device(s) used to access the Services. This information
includes your IP address, device identifiers, page view statistics, browsing
history, usage and click data (e.g., ingest volume, search concurrency, number
of unique user logins, apps loaded, source type (count), session duration,
diagnostic data) and information about your device (e.g., operating system and
browser type/version). We may collect this information using the types of
technologies discussed in the “Online Analytics and Advertising” section below.

However, please note that we do not collect or access information present in
logs/files that you upload to the Securonix Cloud service.

Information obtained from other sources

We (or third parties acting on our behalf) may collect additional information
about you from public databases, joint marketing partners, social media
platforms, conference hosts, event companies, and other third-parties to
supplement the information we collect directly from you.

Combined Information

For the purposes discussed in this Privacy Policy, we may combine the
information that we collect through the Services with information that we
receive as discussed in this section, and use such combined information in
accordance with this Policy.

De-identified Information

We may de-identify information we collect so the information cannot reasonably
identify you or your device, or we may collect information that is already in
de-identified form. For example, we may share de-identified “best practice”
tips, performance benchmark data, and other de-identified data useful to our
user community. Our use and disclosure of such de-identified information is not
subject to any restrictions under this Policy, and we may use and disclose it to
others for any purpose.

How we Use Your Information

We use your information for the following purposes:

 * To provide the Services and respond to your requests
 * To analyze and improve the Services
 * To communicate with you with transactional information related to the
   Services or about updates to our legal terms
 * In accordance with applicable legal requirements, for advertising and
   marketing purposes, including to provide you with special offers and
   promotions both with respect to our products and services and the products
   and services of third parties that we believe will be of interest to you
 * For our business operations, including maintaining your account, security,
   fraud prevention, legal compliance, and detecting security incidents and
   protecting against malicious, deceptive, fraudulent, or illegal activity
 * For other purposes where we have your consent

The laws in some jurisdictions require companies to explain the legal grounds
they rely on to process your information. Our legal bases for processing your
information as described in this Policy are as follows:

 * Where use of your information is necessary to perform our obligations under a
   contract or commitment to you. For example, to provide the Services you’ve
   requested from us, or to comply with our applicable agreements.
 * Where use of your information furthers our legitimate interests or the
   legitimate interests of others. For example, to provide security for our
   Services, operate our business and our Services, make and receive payments,
   defend our legal rights, and prevent fraud.
 * Where we use your information to comply with applicable legal obligations.
   For example, keeping track of purchases for tax and auditing purposes.
 * Where you have consented to our processing of your information for a
   particular purpose.

Online Analytics and Advertising

Our Services use various technologies such as cookies, beacons, tags and scripts
(collectively referred to herein as “cookies”) for marketing automation, demand
marketing, and web analytics partners. These technologies are used in analyzing
trends, administering the Services, tracking users’ movements around the
Services and in gathering demographic information about our user base as a
whole. We may receive reports based on the use of these technologies by these
companies on an individual as well as aggregated basis.

Please note that you can change your settings to notify you when a cookie is
being set or updated, or to block cookies altogether. Please consult the “Help”
section of your browser for more information (e.g., Internet Explorer; Google
Chrome; Mozilla Firefox; or Apple Safari). Please note that by blocking,
disabling, or managing any or all cookies, you may not have access to certain
features or offerings of the Services.

Online Analytics

We may use third-party web analytics services (such as those of Google
Analytics) on our Services to collect and analyze usage information through
cookies and similar tools; engage in auditing, research, or reporting; assist
with fraud prevention; and provide certain features to you. To prevent Google
Analytics from using your information for analytics, you may install the Google
Analytics Opt-out Browser Add-on by clicking here.

If you receive email from us, we may use certain analytics tools, such as
tracking pixels, to capture data such as when you open our message or click on
any links or banners our email contains. This data allows us to gauge the
effectiveness of our communications and marketing campaigns.

Online Advertising

The Services may allow third-party advertising technologies (e.g., ad networks
and ad servers) to place cookies or other tracking technologies on your
computer, mobile phone, or other device to collect information about you to
assist in the delivery of relevant advertising on the Services, as well as on
other websites you visit and other services you use. These ads may be based on
your current activity or your activity over time and across other websites and
online services and may be tailored to your interests.

We also sometimes provide our customer information (such as email addresses) to
service providers, who may “match” this information in de-identified form to
cookies (or mobile ad identifiers) and other proprietary IDs, in order to
provide you with more relevant ads when you visit other websites and mobile
apps.

We neither have access to, nor does this Privacy Policy govern, the cookies or
other tracking technologies that may be placed on the device you use to access
the Services by such non-affiliated third parties. If you are interested in more
information about tailored browser advertising and how you can generally control
cookies from being put on your computer to deliver tailored advertising, you may
visit the Network Advertising Initiative’s Consumer Opt-Out link, the Digital
Advertising Alliance’s Consumer Opt-Out link, or Your Online Choices to opt out
of receiving tailored advertising from companies that participate in those
programs. Please note that these opt-outs apply per device, so you will have to
opt-out for each device through which you access our Services.

Notice Concerning Do Not Track.

Do Not Track (“DNT”) is a privacy preference that users can set in certain web
browsers. We are committed to providing you with meaningful choices about the
information collected on our website for third-party purposes, which is why we
describe a variety of opt-out mechanisms above. However, we do not currently
recognize or respond to browser-initiated DNT signals. Learn more about Do Not
Track.

How We Share Your Information

We may disclose your information to third parties in the following ways:

 * Affiliates. We may disclose information to our affiliates for the purposes
   outlined in this Policy.
 * Service Providers. We may disclose information to our third-party service
   providers, vendors, or others who provide services for Securonix’s business
   operations and on our behalf. This may include such things as infrastructure,
   data analysis, order fulfillment, IT services, customer service, professional
   services or audit services, among others.
 * Partners and Resellers. We may disclose Information to third-parties,
   including our strategic partners and resellers to permit them to assess your
   interest in the Services, conduct user research and surveys, or send you
   marketing communications, subject to the terms of their privacy policies.
 * Legal and Safety Disclosures. We may disclose Information as necessary or
   appropriate under applicable laws (including laws outside your country of
   residence) to: comply with legal process or requirements, including
   applicable notification obligations; respond in good faith as necessary to
   requests from public and government authorities (including public and
   government authorities outside your country of residence); enforce our terms
   and conditions; and protect our operations or those of any of our affiliates
   and our rights, privacy, safety, or property, and/or that of our affiliates,
   you or others.
 * Business Transactions.We may disclose Information in the event of a proposed
   or actual reorganization, merger, sale, joint venture, assignment, transfer,
   or other disposition of all or any portion of Securonix’s business, assets or
   stock (including in connection with any bankruptcy or similar proceedings).

Your Rights and Choices

Your Rights

We provide you with the ability to exercise certain choices rights regarding our
collection, use, and sharing of your information. Your legal rights to exercise
such controls and choices vary based on the laws of your jurisdiction. Depending
on the laws in your jurisdiction, you may have the ability to request:

 * Access to, or a copy of, your information
 * Correction or amendment of your information
 * Deletion of your information
 * Transfer of your information to a third party, where technologically feasible
 * Restriction or objection to certain uses of your information

We may ask you to provide us with information necessary to reasonably verify
your identity before responding to your request. We will consider all requests
and provide our response within the time period required by applicable law.
Please note, however, that certain information may be exempt from such requests.
To exercise your rights, please contact us using the contact information
provided below.

Your Marketing Choices

You can Opt-Out of email marketing using the Opt-Out link in our email
communications. You may also contact us at the contact information provided
below and request that we no longer use your information for marketing purposes.
We will process such requests in accordance with applicable law. Please note
that even if you opt out of receiving marketing communications from us, you may
still receive transactional communications about the Services or legal
notifications.

How We Secure Your Information

The security of your information is important to us. It is your responsibility
to ensure that the Information you provide to us can be legally collected in the
country of origin, transmitted to us and maintained or used by us. We employ a
variety of technical, organizational, and physical measures to protect the
information submitted to us, both during transmission and once we receive it. No
method of transmission over the internet, or method of electronic storage, is
100% secure, however. Therefore, we cannot guarantee its absolute security. If
you have any questions about the security of the Services, or reason to believe
that your interaction with us is no longer secure (for example, if you feel that
the security of any account you might have with us has been compromised), please
notify us immediately in accordance with the “Contact Securonix” section below.

Data Retention

We will retain your information for the period necessary to fulfill the purposes
outlined in this Policy, unless a longer retention period is required or not
prohibited by applicable law.

Notification of Policy Changes

We may change this Policy from time to time. If we make changes, we will post an
updated Policy on the Services, and it will become effective as of the date of
posting (“Effective Date”). We will also comply with applicable legal
requirements regarding Policy updates and any notice or consent requirements. We
encourage you to periodically review this page for the latest information on our
privacy practices. Your use of the Services following these changes means that
you accept the revised Policy.

Privacy Information for International Users

Please note that information covered by this Policy will be hosted and stored by
us and our service providers in the United States of America and other global
jurisdictions where data protection laws may differ from the laws in your local
jurisdiction. By using the Services, you acknowledge that your information will
be stored and processed in the United States.

EU-U.S. Privacy Shield and Swiss-U.S. Privacy Shield

Securonix does not rely on the Privacy Shield Framework, but continues to keep
the commitments that Securonix made when Securonix certified to the Privacy
Shield Framework.

Securonix (its affiliates, and its subsidiary companies) participates in and has
certified its compliance with the EU-U.S. Privacy Shield Framework and the
Swiss-U.S. Privacy Shield Framework. Securonix is committed to subjecting all
“personal data” (as defined under applicable EU and Swiss law) received from
European Union (EU) member countries and Switzerland, in reliance on the Privacy
Shield Framework, to the Framework’s applicable Principles. To learn more about
the Privacy Shield Framework, and to view our certification, visit the U.S.
Department of Commerce’s Privacy Shield List.

Securonix is responsible for the processing of personal data it receives, under
the Privacy Shield Framework, and subsequently transfers to third parties acting
as service providers on its behalf. Securonix complies with the Privacy Shield
Principles for all onward transfers of personal data from the EU and
Switzerland, including the onward transfer liability provisions.

With respect to personal data received or transferred pursuant to the Privacy
Shield Framework, Securonix is subject to the regulatory enforcement powers of
the U.S. Federal Trade Commission. In certain situations, Securonix may be
required to disclose personal data in response to lawful requests by public
authorities, including to meet national security or law enforcement
requirements.

Privacy Shield Recourse Mechanism

In compliance with the Privacy Shield Principles, we commit to resolve
complaints about our collection or use of Personal Data. Individuals with
inquiries or complaints regarding this Policy should first contact Securonix by
emailing us at privacy@securonix.com. We will respond to any inquiry or
complaint within 45 days of receipt.

There are readily available independent recourse mechanisms to investigate and
expeditiously resolve disputes and complaints if a timely acknowledgment of a
complaint is not received from us, or if we have not resolved a complaint. The
proper independent recourse mechanism to use depends upon the type of personal
data at issue:

With regard to unresolved Privacy Shield Complaints regarding Business Contact
Data, Securonix has committed to refer those to the American Arbitration
Association (AAA)’s International Centre for Dispute Resolution®/AAA Program
(the “ICDR/AAA Program”) at www.icdr.org/privacyshield, an alternative dispute
resolution provider located in the United States. If timely acknowledgment of a
complaint is not received from us, or if we have not resolved a complaint,
please contact or visit http://go.adr.org/privacyshield.html for more
information or to file a complaint.

The services of ICDR/AAA are provided at no cost to you and by reference to the
Principals. Damages may be awarded in accordance with applicable law or
private-sector initiatives.

Individuals have the possibility, under certain conditions, to invoke binding
arbitration for complaints regarding Privacy Shield compliance not resolved by
any other Privacy Shield mechanisms.

Securonix further commits to cooperate with the panel established by the EU data
protection authorities (DPAs) and comply with the advice given by such DPAs with
regard to unresolved Privacy Shield Complaints regarding human resources data
transferred from the EU in the context of the employment relationship.

Privacy Information for California Residents

This section applies only to California residents. It describes how we collect,
use and share “personal information” (as defined under the California Consumer
Privacy Act of 2018 (“CCPA”)) of California residents in operating our business,
and their rights with respect to that Personal Information.

Your California privacy rights. As a California resident, you have the rights
listed below. However, these rights are not absolute and, in certain cases, we
may decline your request as permitted by law. We may also ask you for additional
information to verify your identity before responding to your request:

 * Right to request additional information about our processing of your personal
   information over the past 12 months
 * Access to the specific pieces of personal information we have processed about
   you over the past 12 months
 * Deletion of your personal information

Right to opt-out of the “sale” of your personal information. Like many
companies, we may use services that help deliver interest-based ads to you. In
some instances, California law classifies our use of these services as a “sale”
of your personal information to the companies that provide the services. This is
because we allow them to collect information from our website users (e.g.,
online identifiers and browsing activity) so they can help serve ads more likely
to interest you. You can request to opt-out out of this “sale” of your personal
information here: Do Not Sell My Personal Information.

Non-discrimination. We will not discriminate against you for exercising your
rights under the CCPA. This means that we will not penalize you for exercising
your rights by taking actions such as denying you services; increasing the
price/rate of services; decreasing service quality; or suggesting that we may
penalize you as described above for exercising your rights.

Personal information that we collect, use and share under California law. With
respect to most commercial transactions, our business acts solely as a service
provider/processor, merely processing personal information provided to us by our
customers (i.e. the controllers) and returning the results to them. In those
instances, we will not use or share any personal information provided by our
customers with third parties except as authorized by law and this policy.

However, in some instance, such as where we collect personal information from
business-to-business (B2B) contacts, we may use and share such personal
information in accordance with this Privacy Policy. The chart below summarizes
how we collect, use and share personal information by reference to the statutory
categories specified in the CCPA, and describes our practices during the 12
months preceding the effective date of this Policy. Categories in the chart
refer to the categories described above in the general section of this Policy.
We disclose the following personal information to business transferees:

 

Statutory Category of Personal Information (PI) Source of Personal Information
Purpose of Collection Categories of third parties to whom we “disclose” the PI
for a business purpose Categories of third parties to whom we “sell” PI
Identifiers (i.e., name, alias, postal address, unique personal identifier,
customer number, email address, account name, social security number, driver’s
license number, passport number, or other similar identifiers)  



– B2B contacts

– Public sources

– Customers

– Data Providers

– Operate the Service



– Research & development

– Marketing and promotional communications

– Legal compliance

– Fraud Prevention & Safety

– Create Anonymous, Aggregated or De-identified Data

 

– Affiliates



– Customers

– Service Providers

– Professional Advisors

– Governmental authorities and others

– Third Parties (advertising networks) Commercial information (i.e., records of
personal property, products or services purchased, obtained, or considered,
payment history, complaint history, service requests or other purchasing or
consuming histories or tendencies)  



– B2B contacts

– Customers

– Operate the Service



– Research & development

– Marketing and promotional communications

– Legal compliance

– Fraud Prevention & Safety

– Create Anonymous, Aggregated or De-identified Data

 

– Affiliates



– Customers

– Service Providers

– Professional Advisors

– Governmental authorities and others

– None Financial Information  



– B2B contacts

– Public sources

– Customers

– Data Providers

– Operate the Service



– Research & development

– Marketing and promotional communications

– Legal compliance

– Fraud Prevention & Safety

– Create Anonymous, Aggregated or De-identified Data

 

– Affiliates



– Customers

– Service Providers

– Professional Advisors

– Governmental authorities and others

– None Online Identifiers, Internet or Network Information, and Geolocation Data



 

 



– B2B contacts

– Public sources

– Customers

– Data Providers

– Operate the Service



– Research & development

– Marketing and promotional communications

– Legal compliance

– Fraud Prevention & Safety

– Create Anonymous, Aggregated or De-identified Data

 

– Affiliates



– Customers

– Service Providers

– Professional Advisors

– Governmental authorities and others

– Third Parties (advertising networks) Inferences (i.e. the derivation of
information, data, assumptions, or conclusions from any other category of
Personal Information to create a profile about a person reflecting the person’s
preferences, characteristics, psychological trends, predispositions, behavior,
attitudes, intelligence, abilities and aptitudes)



 

 



– B2B contacts

– Public sources

– Customers

– Data Providers

– Operate the Service



– Research & development

– Marketing and promotional communications

– Legal compliance

– Fraud Prevention & Safety

– Create Anonymous, Aggregated or De-identified Data

 

– Affiliates



– Customers

– Service Providers

– Professional Advisors

– Governmental authorities and others

– None Physical Description  



– Public sources

– Data Providers

– Legal compliance



– Fraud Prevention & Safety

 

– Affiliates



– Service Providers

– Professional Advisors

– Governmental authorities and others

 

– None Sensory Information (ex: audio, electronic, visual, thermal, olfactory,
or similar information)



 

 



– B2B contacts

– Public sources

– Customers

– Data Providers

– Operate the Service



– Research & development

– Marketing and promotional communications

– Legal compliance

– Fraud Prevention & Safety

– Create Anonymous, Aggregated or De-identified Data

 

– Affiliates



– Customers

– Service Providers

– Professional Advisors

– Governmental authorities and others

– None

 


PRIVACY INFORMATION FOR NEVADA RESIDENTS

Under Nevada law, certain Nevada consumers may opt out of the sale of
“personally identifiable information” for “monetary consideration” (as such
terms are defined under Nevada law) to a person for that person to license or
sell such information to others. If you are a Nevada resident who has purchased
goods or services from us, you may submit a request to opt out of any future
sales under Nevada law by contacting us using the “Contact Securonix” section
below. Please note we may take reasonable steps to verify your identity and the
authenticity of the request.

Contact Securonix

If you have any questions or comments about this Policy, the information
practices of the Services, or if you would like to exercise any applicable data
rights, you can contact us at any time:

Securonix, Inc.
Attention: Legal Department-Privacy
5080 Spectrum Drive

Suite 950W
Addison, Texas 75001
privacy@securonix.com

1 (855) 732-6649

Previous Revisions

 * August 20, 2021
 * December 1, 2020
 * August 20, 2019
 * August 9, 2019
 * May 25, 2018 
 * September 28, 2017
 * 2011 – 2017

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