PRIVACY POLICY

Security Services Holdings LLC and its subsidiaries and affiliates (collectively, hereinafter referred to as “Protos” or the “Company”) respect your privacy. This Privacy Policy explains our practices around the information collection, use, storage and disclosure practices, including for our website at www.protossecurity.com/ (the “Website”).

Information Protos Collects About You

Protos may collect both Personally Identifiable Information—information that identifies you or can be used on its own or with other information to identify, locate or contact you—as well as non-personally identifiable information about how you use the Website. Personally Identifiable Information may include name, address, email address, telephone number, payment information, and other similar information that can be used to identify you. Specifically, we may collect the following:

Information You Choose to Provide When You

• Fill in information on our online forms;
• Contact us; and
• Otherwise post or publish on the Website.

Protos uses this information to process your vendor application or other requests, communicate with you about your requests, provide you with information or services you have requested, and evaluate and improve the effectiveness of its Website and the information it contains.

Information We Collect Automatically

Protos may use tools (“Automatic Data Collection Technologies”) to automatically collect certain data about the computer or other device you use to reach our Website, such as:

• Device properties including, but not limited to, unique or other device identifiers;
• Device operating system and software;
• IP address and Internet service provider;
• Mobile phone carrier;
• Geographical data such as country or region; and
• Other similar data.

Protos also may Automatic Data Collection Technologies to gather and analyze information regarding the Website’s usage, such as the number of hits received, the number of unique visitors, the most/least visited pages, errors experienced by users, browsers and platforms used to connect to the Website, the number of times a user or the computers within a given network visited the Website, the date and time you visited the Website, the pages of the Website that you visited and the order in which you accessed such pages, and the websites you visited before or after you visit our Website.

The information Protos collects through the use of Automatic Data Collection technologies may include Personally Identifiable Information or Protos may associate it with Personally Identifiable Information we collect in other ways.

This information may be collected via several technologies, including cookies, web beacons, clear GIFs and other means. You can remove certain cookies by following the directions in your Internet browser’s “help” file. If you disable cookies, your ability to use areas of the Website may be limited.

All of this information belongs to Protos. Protos uses the information for marketing purposes and to improve the effectiveness, content, layout and/or operation of our Website.

Using Your Information

In addition to the uses described above, Protos uses the information it collects about you or that you provide on the Website, including any Personally Identifiable Information:

• To present the Website and its contents to you;
• To provide you with information, products or services that you request from us;
• To fulfil any other purpose for which you provide it;
• To carry out our obligations and enforce our rights arising from any contracts entered into between us and others, including for billing and collection;
• To administer and improve the services or Website, including by monitoring and analyzing the Website traffic and usage patterns;
• To notify you about changes to the Website that may affect your use of it;
• In any other way we may describe when you provide the information; or
• For any other purpose with your consent.

Protos may also use your Personally Identifiable Information to contact you about Protos goods and services that may be of interest to you.  If you do not want Protos to use your Personally Identifiable Information in this way, please contact us using the below contact information.

Sharing Your Information

Protos does not share your Personally Identifiable Information with third-parties for their own marketing purposes. Your Personally Identifiable Information is accessible to certain Protos personnel. In addition, Protos may share your Personally Identifiable Information:

• With contractors, service providers, and other third-parties Protos uses to support the business;
• With sponsors or co-sponsors of webinars, seminars or other events in which Protos is participating;
• To fulfil the purpose for which you provide it;
• For any other purpose disclosed by us when you provide the information;
• With your consent;
• To a buyer or other successor in the event of 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 Personally Identifiable Information held by us about the Services users is among the assets transferred;
• To enforce any agreement, including any applicable terms of service or for billing and collection purposes;
• To establish or exercise our right to defend against legal claims;
• To law enforcement and other government authorities such as legislatures, courts, agencies and litigants if we reasonably believe that such action is necessary to: (a) comply with the law and the reasonable requests of governmental authorities; (b) comply with legal process; (c) respond to requests from public or government authorities, including public or government authorities outside your country of residence; (d) protect the security or integrity of the Website or Protos’ information systems; and/or (e) exercise or protect our rights, privacy, safety or those of affiliates, clients, you or others; and
• If we reasonably believe disclosure is necessary or appropriate to protect the rights, property, or safety of Protos or others.

Protecting Your Information

Protos follows commercially reasonable security practices and procedures designed to protect your Personally Identifiable Information from unauthorized access, use and disclosure. Nevertheless, please be aware that Internet transmissions and information storage systems are never completely private or secure.

Information Storage

Protos stores your information for as long as we believe the information to be necessary in carrying out the business purposes for which it was collected.

Privacy Policies of Third-Party Websites to Which the Website Links

Protos may provide links to third-party websites that it does not control. Protos urges you to review the privacy policies posted on these third-party websites at the time you first visit such sites. Protos undertakes no obligation to review or ensure enforcement or compliance with the privacy policy of any website to which it links.

Children’s Privacy

Protos does not knowingly collect Personally Identifiable Information from any children under age 16. No parts of the Website are directed to or designed to attract anyone under the age of 16.

Data Storage and Processing Conducted in the United States

Regardless of where you are located, Protos collects information and processes and stores that information in databases located in the United States. If you are from a country outside the United States, you should be aware that you may transfer Personally Identifiable Information about yourself to the United States, and that the data protection laws of the United States may not be as comprehensive as those in your own country. By visiting the Website and submitting any Personally Identifiable Information, you consent to the transfer of such Personally Identifiable Information to the United States.

Additional Terms for EU Visitors

The data controller for this Website is Protos. Protos processes Personally Identifiable Information it collects through the Website for Protos’ legitimate business purposes, for example, to fulfill any requests you may make in connection with your submission of Personally Identifiable Information, to monitor and improve the quality of the Website, and to protect and defend our rights, property or safety or that of our clients and other users of the Website. You may have the right to obtain a copy of your Personally Identifiable Information, correct inaccuracies in your Personally Identifiable Information, request the erasure of your Personally Identifiable Information and/or restrict the processing of your Personally Identifiable Information. For more information about how you can rectify and erase your Personally Identifiable Information or make any other requests relating to your Personally Identifiable Information or to contact Protos, please see the Section of this Privacy Policy entitled, “Questions About This Privacy Policy,” below. In addition, you may have the right to lodge a complaint with a supervisory data protection authority.

California Visitors

California law allows California residents to ask companies with whom they have an established business relationship to provide certain information about the companies’ sharing of Personally Identifiable Information with third-parties for direct marketing purposes. We do not share any California consumer Personally Identifiable Information with third-parties for marketing purposes without consent. California customers who wish to request further information about our compliance with this law or have questions or concerns about our privacy practices may contact us using the contact information set forth below.

If you are a California resident, please see our California Resident Privacy Notice, below.

Do Not Track Requests

The Website does not support Do Not Track at this time. Do Not Track (DNT) is a privacy preference you can set in your web browser to indicate that you do not want certain information about your webpage visits collected across websites when you have not interacted with that service on the page. For all the details, including how to turn on Do Not Track, visit www.donottrack.us.

Changes to This Privacy Policy

Protos occasionally may update this Privacy Policy from time to time. All revisions will be posted to Protos’ Website. Protos urges you to review its Privacy Policy frequently.

Questions About This Privacy Policy

Questions or comments about this Privacy Policy should be directed to marketing@protossecurity.com. In addition, if you no longer wish us to maintain data about you, or wish to change the type of information we send you, please let us know by e-mailing marketing@protossecurity.com. Similarly, if you do not receive acknowledgement of your inquiry or your inquiry has not been satisfactorily addressed, you should telephone our Marketing Department at (866) 403-9630.

Last revised: April 1, 2021

 

© 2021 Security Services Holdings LLC, All Rights Reserved.

APPENDIX A

California Resident Privacy Notice

The below privacy notice supplements the information contained in the Privacy Policy and applies solely to California residents or those protected by California law. Protos adopts this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this Notice. Capitalized terms not defined herein have the definition assigned in the Privacy Policy.

Information We Collect:

Protos may collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“Personally Identifiable Information”). Personally Identifiable Information does not include:

• Publicly available information from government records.
• Deidentified or aggregated consumer information.

In particular, Protos may have collected the following categories of Personally Identifiable Information within the last twelve (12) months:

CATEGORY	EXAMPLES	COLLECTED AND HOW	HOW DISCLOSED
A. Identifiers.	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, driver’s license number, passport number, or other similar identifiers.	YES Directly from you. For example, from forms you complete on the Website. Indirectly from you. For example, from observing your actions on the Website.	Disclosed pursuant to the Privacy Policy.
B. Personally Identifiable Information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name, signature, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number. Some Personally Identifiable Information included in this category may overlap with other categories.	YES Directly from you. For example, from forms you complete on the Website. Indirectly from you. For example, from observing your actions on the Website.	Disclosed pursuant to the Privacy Policy.
C. Protected classification characteristics under California or federal law.	Age (40 years or older), race, color, citizenship, physical or mental disability, sex (including gender, gender identity, gender expression).	NO	Not applicable
D. Commercial information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	NO	Not applicable
E. Biometric information.	Activity patterns used to extract a template or other identifier or identifying information, such as keystroke. *We do not utilize facial recognition software.	NO	Not applicable
F. Internet or other similar network activity.	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.	YES Indirectly from you. For example, from observing your actions on the Website.	Disclosed pursuant to the Privacy
G. Geolocation data.	Physical location or movements.	YES Indirectly from you. For example, from observing your actions on the Website.	Disclosed pursuant to the Privacy Policy.
H. Sensory data.	Audio, electronic and visual.	NO	Not applicable
I. Professional or employment-related information.	Current or past job history or performance evaluations.	NO	Not applicable
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as class lists, student identification codes.	NO	Not applicable
K. Inferences drawn from other Personally Identifiable Information.	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	NO	Not applicable

Use of Personally Identifiable Information

Protos may use the Personally Identifiable Information it collects for the purposes described in the Privacy Policy above.

Protos will not collect additional categories of Personally Identifiable Information or use the Personally Identifiable Information collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personally Identifiable Information

Protos may disclose your Personally Identifiable Information to a third-party for a Business Purpose, as described in the Privacy Policy above.

Disclosures of Personally Identifiable Information for a Business Purpose

In the preceding twelve (12) months, Protos has disclosed the following categories of Personally Identifiable Information for a business purpose:

Category A: Identifiers.

Category B: California Customer Records Personally Identifiable Information categories.

Sales of Personally Identifiable Information

In the preceding twelve (12) months, Protos has not sold Personally Identifiable Information.

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their Personally Identifiable Information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that Protos disclose certain information to you about the collection and use of your Personally Identifiable Information over the past twelve (12) months. Once Protos receives and confirms your verifiable consumer request (see Exercising Access, Data Portability, and Deletion), Protos will disclose to you:

• The categories of Personally Identifiable Information collected about you.
• The categories of sources for the Personally Identifiable Information collected about you.
• The business or commercial purpose for collecting or selling that Personally Identifiable Information.
• The categories of third-parties with whom Protos shares that Personally Identifiable Information.
• The specific pieces of Personally Identifiable Information collected about you (also called a data portability request).
• If Protos disclosed your Personally Identifiable Information for a business purpose, two separate lists disclosing:
• the disclosures for a business purpose and identifying the Personally Identifiable Information categories that each category of recipient obtained.

Deletion Request Rights

You have the right to request that Protos delete any of your Personally Identifiable Information that it has collected from you and retained, subject to certain exceptions. Once Protos receives and confirms your verifiable consumer request (see Exercising Access, Data Portability, and Deletion), Protos will delete (and direct our service providers to delete) your Personally Identifiable Information from Protos’ records, unless an exception applies.

Protos may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

1. Complete the transaction for which we collected the Personally Identifiable Information, provide a good or service that you requested, take actions reasonably anticipated within the context of the ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
3. Debug products to identify and repair errors that impair existing intended functionality.
4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
7. Comply with a legal obligation.
8. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to Protos by either:

• Calling us at (866) 403-9630
• Emailing Protos at marketing@protossecurity.com

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your Personally Identifiable Information. You may also make a verifiable consumer request on behalf of your minor child. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows Protos to reasonably verify you are the person about whom Protos collected Personally Identifiable Information or an authorized representative, which may include the user’s first name, last name, email address, exam date and time, and exam ID.
• Describe your request with sufficient detail that allows Protos to properly understand, evaluate, and respond to it.
• Protos cannot respond to your request or provide you with Personally Identifiable Information if we cannot verify your identity or authority to make the request and confirm the Personally Identifiable Information relates to you.

Making a verifiable consumer request does not require you to create an account with Protos. However, Protos does consider requests made through your password-protected account sufficiently verified when the request relates to Personally Identifiable Information associated with that specific account.

Protos will only use Personally Identifiable Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format

Protos endeavors to respond to a verifiable consumer request within forty-five (45) days of its receipt. If Protos requires more time (up to 45 days), we will inform you of the reason and extension period in writing.

If you have an account with Protos, a written response will be delivered to that account. If you do not have an account with Protos, we will deliver our written response by mail or electronically, at your option.

Any disclosures Protos provides will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response Protos provides will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, Protos will select a format to provide your Personally Identifiable Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

Protos does not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If Protos determines that the request warrants a fee, Protos will tell you why it made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination

Protos will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, Protos 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.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
• However, Protos may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your Personally Identifiable Information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.