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About CRA

Date of Last Revision: May 25, 2023

CyberRisk Alliance, LLC (“CyberRisk Alliance”, “our”, “us”, or “we”) wants to
help you better understand how we collect, use, protect, and share your Personal
Data. This Privacy Policy is designed to help you understand your privacy
choices when you visit our Website or use our Mobile Apps or any of our
Services. It does not apply to other websites or services that we do not
control, including websites or services of other CyberRisk Alliance users.
Unless otherwise defined herein, capitalized terms shall have the meaning
ascribed them in the Terms of Service.

This Privacy Policy is incorporated into, and forms an integral part of, the
CyberRisk Alliance Terms of Service (“Terms of Service”). Please note that our
services may vary by region.

We encourage you to read this Privacy Policy carefully and take the time to get
to know our privacy practices. By accessing the Websites, Mobile App, and/or the
Services, you are bound by all terms and conditions in the Terms of Service and
this Privacy Policy. If you do not wish to be bound, you may not access the
Websites, Mobile App, and/or the Services.

1. Definitions
1. Information Types.
1. “Account Information” means data about how and when a CyberRisk
Alliance account is accessed and the features used.
2. “Browser Information” means data or information provided by a
browser, including the IP address, the website visited, network
connection, device information, and other data, including Cookies.
3. “Contact Information” means basic personal and business information,
such as first and last name, company name, email address, postal
address, phone number, and may include social media account
information.
4. “Device Information” means information about your device, such as
device ID number, model, and manufacturer, version of your operating
system and geographical region, collected from any devices when
accessing our website, using the Mobile App, or any of our services.
5. “Security Information” means user ID, password and password hints,
and other security information used for authentication and account
access.
6. “Support Information” includes information about your hardware and
software, authentication data, chat session contents, error reports,
performance data, and other communication or technical information
and may, with express permission, include remote access to facilitate
troubleshooting.
7. “Usage Information” means information collected when you interact
with the CyberRisk Alliance website, mobile application or any of our
services, including functionalities accessed, pages visited, and
other interaction data.
2. “Automated Decision Making” means a decision made solely by automated
means without human involvement.
3. “Controller” means an entity that determines the purposes and means of
the Processing of Personal Data.
4. “Cookie” means a small file that resides on your computer’s hard drive
that often contains an anonymous unique identifier that is accessible by
the website that placed it there, but is not accessible by other sites.
5. “Member” means an entity or natural person that registers to become a
member of the Services.
6. “Mobile App” means the CyberRisk Alliance Mobile Application available
through third-party app stores for mobile devices.
7. “Personal Data” or “Personal Information” means information that (i)
relates to an identified or identifiable natural person, or (ii)
identifies, relates to, describes, is capable of being associated with,
or could reasonably be linked, directly or indirectly, with a particular
consumer or household.
8. “Processing” means any operation or set of operations which is performed
upon Personal Data, whether or not by automatic means, including, but
not limited to, alteration, collection, organization, recording,
retrieval, storage, transmission, and use.
9. “Processor” means the entity that processes Personal Data on behalf of
the Controller.
10. “Services” means all CyberRisk Alliance content, memberships, services,
and materials located on or accessible through the Websites and the
Mobile Apps.
11. “Third-Party Products” means any third-party information, website,
product, service, or materials referenced in, accessible through, or
provided in connection with, the Website or Services.
12. “User” means an entity or natural person that downloads, uses, or
interacts with the CyberRisk Alliance Mobile Apps.
13. “Visitor” means an entity or natural person that visits or interacts
with the CyberRisk Alliance Websites.
14. “Website” means the CyberRisk Alliance website located at
https://www.cyberriskalliance.com/ (including all associated internet
country codes).
2. How Do We Collect Information and What Information Do We Collect?
1. When a User or Member interacts with our Websites, CyberRisk Alliance may
collect and control information such as Account Information, Browser
Information, Contact Information, Support Information, Device
Information, Security Information, Usage Information and set a Cookie.
2. When a User or Member interacts with our Mobile Apps, CyberRisk Alliance
may collect and control information such as Account Information, Contact
Information, Device Information, Usage Information and Security
Information.
3. When visitors browse our Websites, or engage in communications with us
online or offline, we may collect and control, as applicable, Browser
Information, Support Information, Contact Information, and Usage
Information submitted or communicated to us.
4. We may collect the following types of information from you or your
device(s):
1. identifiers, such as Browser Information, Device Information, and
Security Information;
2. commercial information, such as Account Information, Contact
Information, and Usage Information;
3. internet or network information, such as Browser Information and
Device Information;
4. geolocation data, such as Browser Information and Device Information;
5. other Personal Information, such as Support Information; and/or
6. information derived from other categories, which could include your
preferences, interests, and other information used to personalize your
experience.
3. How We Use the Information We Collect? We use the information we collect in
our role as a Controller to:
1. provide our Services;
2. confirm identities;
3. to communicate with you, including required communications regarding
your account, security, or updates regarding our Services or polices,
and to send promotional communications;
4. improve and personalize communications, interactions, and our Services,
such as push notifications regarding your activities;
5. provide support such as debugging, troubleshooting, automated decision
making such as the detection of fraudulent account creation when signing
up for our Services;
6. for advertising and marketing, invoicing, to resolve incidents related
to the use of our Websites and Services;
7. to comply with legal requirements,
8. create potential sales contacts (“Leads”);
9. as may be necessary in a business transaction concerning the sale or
transfer of our assets; and/or
10. in other cases where the Visitor has given express consent.
4. How We Share the Information We Collect? We may access, transfer, or
disclose the Personal Data with your consent or if we have a good faith
belief that doing so is necessary to: (i) comply with applicable law or
respond to valid legal process, including from law enforcement or other
government agencies; or (ii) protect the rights or property of CyberRisk
Alliance, including enforcing the terms governing the use of the Services.
We may access certain Personal Data, limited to First Name, Last Name,
Email, Title, Title Level, Functional Area, Phone, Address or Street, City,
Zip Code, State, Country, Company, Company Size, and Industry, in the
creation of our Leads and we may transfer and disclose that certain Personal
Data to the Third Parties that purchase our Leads and third-party data
partners.
5. Cookies.
1. Usage. CyberRisk Alliance and its third-party service providers use
cookies, web beacons, and similar tracking technologies to recognize you
when you visit our Websites, remember your preferences, and give you a
personalized experience. When you visit our Website, we, or an authorized
third party, may place a Cookie on your device that collects information,
including Personal Data, about your online activities over time and
across different sites. Cookies allow us to track use, infer browsing
preferences, and improve and customize your browsing experience.
2. Persistence. We use both session-based and persistent Cookies on our
Websites. Persistent Cookies remain on your computer when you have gone
offline, while session Cookies are deleted as soon as you close your web
browser. A website may set a Cookie if the browser’s preferences allow
it. A browser only permits a website to access the Cookies that it has
set, not those set by other websites.
3. Types.
1. Essential. These Cookies are necessary for our Websites to work as
intended.
2. Functional. These Cookies enable enhanced functionality, like videos
and live chat. Without these Cookies, certain functions may become
unavailable.
3. Analytics. These Cookies provide statistical information on site
usage. For example, these Cookies enable web analytics that allow us
to improve our website over time.
4. Targeting and Advertising. These Cookies are used to personalize
content to enhance your experience.
4. Control. It is possible to disable Cookies through your device or browser
settings, but doing so may affect your ability to use our website. For
instance, we may not be able to recognize your computer or mobile device
and you may need to log in every time you visit our Websites. The method
for disabling Cookies may vary by device and browser, but can usually be
found in preferences or security settings. Please use the following links
for further instructions:
1. Google Chrome
2. Apple Safari
3. Mozilla Firefox
4. Microsoft Internet Explorer
5. Other Resources.To find out more about Cookies, including how to see what
Cookies have been set and how to manage and delete them, visit
allaboutcookies.org, or aboutcookies.org.
6. Third Parties. Third Party application stores, such as Apple’s App Store or
Google’s Google Play, might collect additional information and share them
with us. Please refer to the application store’s Privacy Policy to better
understand how they process any of the personal information they collect and
share with app publishers like ourselves. Third Party applications, such as
Amazon Voice Service, may collect additional information. Please refer to
the respective Third Party’s Privacy Policy to better understand how they
process any of the personal information they collect and the purposes for
collection. While we are dedicated to securing our Websites, Application,
and Services, you are responsible for securing and maintaining the privacy
of your passwords and account information. We are not responsible for
protecting Personal Data shared with a Third Party based on an account
connection that you have authorized.
7. Data Subject’s Rights. Depending on where you reside, you may have data
subject rights as set forth based on location of residency below.
1. UK/UE/EEA Data Subject Rights under the General Data Protection
Regulation (GDPR). If you are a resident of the United Kingdom, European
Union, or European Economic Area (EEA), you may have certain data
protection rights. We aim to take reasonable steps to allow you to
correct, amend, delete, object to the processing, restrict the
processing, request a transfer, or limit the use of your Personal
Information. You can exercise rights over your Personal Data against the
Controller by submitting a request by clicking manage my personal
information form, emailing us at privacy@cyberrisk.com, with the subject
line “GDPR Data Subject Request”, or mail us at the address listed below.
When collection is based on your consent, you have the right to withdraw
consent at any time, without affecting the lawfulness of processing based
on consent before its withdrawal by applicable law. If applicable by
national law, you have the right to lodge a complaint with a supervisory
authority if you believe that the processing of your personal data
relating infringes your rights.
2. California Consumer Privacy Act. If you are a California resident, or
were within the last year or at any point since January 1, 2022, you have
the following rights under applicable California law in relation to your
Personal Information, subject to certain exceptions:
1. Right to Know. You have the right to, up to twice in a 12-month
period, request what Personal Information we collect, use, disclose,
share, and/or sell, as applicable.
2. Right to Delete. You have the right to request the deletion of your
Personal Information that is collected by us.
3. Right to Opt-Out of Sale. You have the right to opt-out of the sale of
your Personal Information by a business. However, as noted above, we
do not currently sell any Personal Information.
4. Right to Non-Discrimination. You have the right not to receive
discriminatory treatment for the exercise of the privacy rights
described above.
5. Right to Correct. You have the right to correct inaccurate Personal
Information that we maintain about you.
6. Right Not to Be Discriminated Against. You have the right not to
receive discriminatory treatment by us for exercising your privacy
rights, including the right not to be retaliated against.

We may sell or share (in the context of cross-behavioral advertising which means
the targeting of advertising to a consumer based on the consumer’s personal
information obtained from the consumer’s activity across businesses including
distinctly-branded websites, applications, or services) Personal Information. If
we do, you will be notified of it prior to or at the point of such collection
for those purposes, and provided a link to opt-out of the selling/sharing of
Personal Information.
These rights are not absolute, and there may be cases when we decline your
request as permitted by law.
Any request you submit to us is subject to an identification and residency
verification process as permitted by the CCPA.
To submit a request pursuant to this Section, please contact us by submitting a
request by clicking manage my personal information form, privacy@cyberrisk.com,
with the subject line “California Data Subject Request” or mail us. In the event
you have an authorized representative submit a request to delete, request to
correct or request to know on your behalf, you will have to provide written
authorization demonstrating this grant of authority, which can include a Power
of Attorney. Authorized representatives may not submit any other types of
requests on your behalf.
For purposes of requests to delete, correct and to know, we will verify your
identity based on information we have collected about you, including your name,
address, and phone number, but will not fulfill your request unless you have
provided sufficient information that enables us to reasonably verify that you
are the consumer about whom we collected the Personal Information. If we are
unable to verify your identity, we may deny your request.
If you are 16 years of age or older, you have the right to direct us not to sell
your Personal Information at any time. We do not and will not sell Personal
Information of consumers we actually know are less than 16 years of age unless
we received affirmative authorization from the consumer who is between 13 and 16
years of age, or the parent or guardian of a consumer less than 13 years of age,
to opt-in to the sale of their Personal Information. Upon the receipt of this
request to opt-in, we will inform the minor of the right to opt-out later and of
the process for doing so. We do not charge a fee to process or respond to your
verifiable consumer request unless it is excessive, repetitive, or manifestly
unfounded. If we determine that the request warrants a fee, we will tell you why
we made that decision and provide you with a cost estimate before completing
your request.

8. Do Not Track. Do Not Track is a privacy preference that users can set in
their web browsers. When a user turns on the Do Not Track signal, the
browser sends a message to websites requesting them not to track the user.
At this time, we do not respond to web browser “do not track” settings or
signals. We deploy Cookies and other technologies on our Services to
collect information about you and your browsing activity, even if you have
turned on the Do Not Track signal.
9. Protecting Your Personal Information. We implement security measures
designed to maintain the security of your Personal Information. These
security measures are implemented both during transmission of Personal
Information and once received. The security of your Personal Information is
important to us. However, no method of safeguarding information is
completely secure. While we use measures designed to protect Personal
Information, we cannot guarantee that our safeguards will be effective or
sufficient. In addition, you should be aware that internet data
transmission is not always secure, and we cannot warrant that information
you transmit utilizing the Services is or will be secure.
10. Transfer of Data. Your Personal Information may be transferred to —and
maintained on—computers located outside of your state, province, country or
other governmental jurisdiction where the data protection laws may differ
from those in your jurisdiction. If you are located outside the United
States, please note that we transfer data, including Personal Information,
to the United States and process it there. By using the Services, you
understand and acknowledge that your Personal Information will be
transferred to and processed in the United States, which may have different
data protection rules than in your country We will take steps reasonably
designed to treat your Personal Information securely and in accordance with
this Privacy Policy, as further described below.
11. Updates. We may update this Privacy Policy from time to time in response to
changing legal, technical or business developments. When we update our
Privacy Policy, we will take appropriate measures to inform you, consistent
with the significance of the changes we make. We will obtain your consent
to any material Privacy Policy changes if and where this is required by
applicable data protection laws. You can see when this Privacy Policy was
last updated by checking the “Date of Last Revision” date displayed at the
top of this Privacy Policy.
12. Contact Us. For more information about our privacy practices, if you have
questions, or if you would like to make a complaint, please contact us by
e-mail or by mail using the details provided below:

CyberRisk Alliance, LLC
400 Madison Ave Ste 6C, New York City, New York, 10017
Attn: Joe Haddock

--------------------------------------------------------------------------------

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