Effective Date: January 2020
1. COLLECTION AND USE
The categories of Personal Data we collect, which may be collected both on the Site and offline, and our uses of Personal Data depend on the context, as described below:
- Site visitors: We collect the following information from Site visitors, including those who request further information about our services, to the extent they provide it to us: name, title, company, job responsibilities, phone number, mailing address, email address, and contact details (collectively, “Contact Data”), as well as information related to requests from Site visitors, including information or paper or document requests, downloads, and username/passwords used to access our Site (if necessary) (collectively, “Registration Data”). In addition to Personal Data provided by Site visitors, we may also collect the following information about the device used to access our Site: computer Internet Protocol (IP) address, unique device identifier (UDID), cookies and other data linked to a device, and data about usage of our Sites, (collectively, “Device Data”). Note, however, we do not consider Device Data to be Personal Data except where we link it to you as an individual or where applicable law provides otherwise. We use this data to facilitate our Site and its services, make our Sites more intuitive and easy to use, respond to inquiries and requests, provide our services, maintain business operations, maintain our contacts, provide relevant marketing and materials, protect the security of the Site and our systems, address compliance and legal obligations, and interact with Site visitors (collectively, “General Uses”).
- Email. We are committed to keeping your e-mail address confidential. We do not sell, rent, or lease our subscription lists to third parties. We will use your e-mail address solely to provide timely information about our services, as well as for purposes of provision of our services, when appropriate. We will maintain the information you send via e-mail in accordance with applicable federal law.
We do not use automated decision-making without human intervention, including profiling, in a way that produces legal effects concerning individuals or that otherwise significantly affects individuals.
Some jurisdictions require an explanation of the legal basis for the collection and processing of Personal Data. We have several different legal grounds on which we collect and process Personal Data, including: (a) as necessary to perform a transaction (such as when we respond to your requests); (b) as necessary to comply with a legal obligation (such as when we use Personal Data for record keeping to substantiate income, fees and/or or tax liability); (c) consent (where you have provided consent as appropriate under applicable law); and (d) as necessary for legitimate interests (such as when we act to maintain our business generally, providing customer service and making available other items and services to our clients and prospective clients, or to pursue our rights or the rights of our clients).
We may share Personal Data:
- Within the organization. We may share Personal Data within the organization for purposes of performing services on behalf of clients, for administrative purposes and/or for business management.
- With Global Cyber Risk, LLC. We may share Personal Data with Global Cyber Risk, LLC, an affiliated third-party with whom we work to provide consulting services, to enable the provision of services to clients. Global Cyber Risk LLC is not permitted to use Personal Data for its own purposes.
- With Service Providers. We may share Personal Data with unaffiliated third-party service providers to enable such third parties to perform functions on our behalf and under our instruction. The purposes for sharing may be to maintain and provide the Site, or our products and services. For example, we may engage third-party service providers to assist us with mailing services, logistics, website maintenance and fulfillment, etc. These service providers are not permitted to use Personal Data for their own purposes, nor to sell or transfer your Personal Data without your approval.
- As Required by Legal Obligations and Rights. We may share Personal Data in order to comply with any subpoena, court order or other legal process, or other governmental request. We may also share Personal Data to establish or protect our legal rights, property, or safety, or the rights, property, or safety of others, including clients, or to defend against legal claims.
We may also share statistical or other information (not including Personal Data) with third parties, so long as this information does not identify individuals.
We employ reasonable technical and organizational measures designed to protect Personal Data from loss, misuse, alteration or unintentional destruction. We also require that third-party service providers acting on our behalf provide such reasonable security measures. However, no security measure can guarantee against compromise. While we take steps designed to protect Personal Data, you also play a role in protecting your Personal Data, and you should not share any login information, including passwords, with anyone. If you have any reason to believe that your login information or password have been compromised, please contact us as detailed below in the Contact Section.
Email is not a secure medium of communication. For this reason, we request that you do not send personal or sensitive information to us by email without first encrypting it. Doing so is allowed, however, but at your own risk.
Some of the information you may enter on our website may be transmitted securely via a secure medium known as Secure Sockets Layer, or SSL. Credit Card information and other sensitive information should never be transmitted via email.
For site security purposes and to ensure that this service remains available to all users, this site uses software programs to monitor network traffic to identify unauthorized attempts designed to upload or change information, or otherwise cause damage (e.g., Distributed Denial of Service Attacks, bloatware, adware, worms, ransomware and other malware).
4. RETENTION AND STORAGE
We do not knowingly collect Personal Data from children under 16 through operation of the Site. If we have (or receive) actual knowledge that Personal Data about a child under 16 years old has been collected without explicit parental consent, then we will take the appropriate steps to delete such Personal Data.
As permitted by applicable law, you may have the right to obtain confirmation of the existence of certain Personal Data relating to you, to verify its content, origin and accuracy, as well as the right to access, review, port, delete or to block or withdraw consent to the processing of certain Personal Data (without affecting the lawfulness of processing based on consent before its withdrawal), by contacting us as detailed below. Before acting on any such request, we will need to verify your identity. To the extent we do not have sufficient information about you or are unable to verify your identity, we may not be able to honor your request. Please note that we may need to retain certain Personal Data as required or permitted by applicable law.
You have the following choices regarding our use and disclosure of your Personal Data:
- Marketing Communications. If you no longer wish to receive any marketing communications or remain on a mailing list to which you previously subscribed, please follow the unsubscribe link in the relevant communication, or contact us using the information in the Contact section, below.
- Cookies and Similar Technologies. Please review your browser or computer settings for certain cookies and see below to exercise certain choices regarding cookies.
8. COOKIES AND SIMILAR TRACKING TECHNOLOGIES - INTEREST-BASED ADVERTISING
What are cookies?
Cookies are small amounts of data that are stored on your browser, device or the page you are viewing, which often includes an anonymous unique identifier. When you visit a website, that site’s computer asks your computer for permission to store this file in a part of your hard drive specifically designated for cookies. Each website can send its own cookie(s) to your browser if your browsers preferences allow it. Some cookies are deleted once you close your browser, while other cookies are retained even after you close your browser so that you can be recognized when you return to a website. Information gathered through cookies and server logs may include the: date and time of visits, the pages viewed, time spent at our site, and the websites visited just before and just after our own, as well as your IP address.
More information about cookies and how they work is available at www.allaboutcookies.org.
IP addresses are used by your computer every time you are connected to the Internet. Your IP address is a number that is used by computers on the network to identify your computer. IP addresses are automatically collected by our web server as part of demographic and profile data known as “traffic data” so that data (such as the Web pages you request) can be sent to you.
Website Use Statistics
We may collect data and use software programs to understand and track summary statistics, for such purposes as assessing the number of visitors to the different sections of our site, what information is of most and least interest, determining technical design specifications, and identifying system performance or problem areas. The information collected for this purpose does not include Personal Data.
If you choose to correspond with us through email, we may retain the content of your email messages together with your email address and our responses. We provide the same protections for these electronic communications that we employ in the maintenance of information received online, mail and telephone. This also applies when you register for our website, sign up through any of our forms using your email address or make a purchase on this site.
Cookies on our Site are generally used for the following purposes:
Strictly Necessary Cookies: These are required for the operation of our Site. They include, for example, cookies that enable you to log into secure areas. These cookies are session cookies that are erased when you close your browser.
- Analytical/Performance Cookies: These allow us to recognize and count the number of users of our Site and see how such users navigate through our Site. This helps improve how our Site works, for example, by ensuring that users can find what they are looking for easily. These cookies are session cookies, which are erased when you close your browser.
- Functional Cookies: These improve the functional performance of our Site and make it easier for you to use. For example, cookies are used to remember that you have previously visited the Site and asked to remain logged into it. These cookies are session cookies, which are erased when you close your browser.
- Targeting Cookies: These record your visit to our Site, the pages you have visited, and the links you have followed, to recognize you as a previous visitor and to track your activity on the Site and other websites you may visit. These cookies qualify as persistent cookies, because they remain on your device for us to use during the next visit to our Site. You can delete these cookies via your browser settings.
What are your options if you do not want cookies on your computer?
- You can review your Internet browser settings, typically under the sections “Help” or “Internet Options,” to exercise choices you have for certain Cookies. If you disable or delete certain Cookies in your Internet browser settings, you might not be able to access or use important functions or features of this Sites, and you may be required to re-enter your log-in details.
- To learn more about certain cookies used for interest based advertising by third parties, including through cross-device tracking, and to exercise certain choices regarding such cookies, please visit the Digital Advertising Alliance, Network Advertising Initiative, Digital Advertising Alliance-Canada, European Interactive Digital Advertising Alliance or your device settings, if you have the DAA or other mobile app.
Do-Not-Track Signals. We currently do not employ technology that recognizes “do-not-track” signals from your browser.
9. LINKS TO OTHER WEBSITES
- Intellectual Property Rights. All copyrights, trademarks, patents and other intellectual property rights in and on our Site and all content and software located on the Site shall remain the sole property of or its licensors. The use of our trademarks, content and intellectual property is forbidden without our express written consent.
- Restricted Access. We may in the future need to restrict access to parts (or all) of our Site, and reserve full rights to do so. If, at any point, we require use of, and/or assign to you, a username and password for you to access restricted areas of our Site, you must ensure that both your username and password are kept confidential.
- Acceptable Use. You agree to use our Site only for lawful purposes, and in a way that does not infringe our rights, or the rights of, restrict or inhibit anyone else’s use and enjoyment of this Site. Prohibited behavior includes harassing or causing distress or inconvenience to any other user, transmitting obscene or offensive content or disrupting the normal flow of dialogue within our Site.
- When accessing this site, you explicitly agree to NOT to do any of the following without our express written consent:
- Republish material from our Site
- Sell or rent material from our Site
- Reproduce, duplicate, create derivative, copy or otherwise exploit material on our Site for any purpose
- Redistribute any content from our website, including onto another website
- Use our Site to send unsolicited commercial communications
- Use the content on our Site for any marketing related purposes
- Use your access to conduct reconnaissance for, or to commit any type, of attack or other malicious or damaging activity on or against the Site, or to violate a federal, state, local law, regulation or other binding requirement.
11. CAN-SPAM COMPLIANCE
In compliance with the CAN-SPAM Act, all e-mail sent from our organization will clearly state who the e-mail is from and provide clear information on how to contact the sender. In addition, all e-mail messages will also contain concise information on how to remove yourself from our mailing list so that you receive no further e-mail communication from us.
12. USE OF TESTIMONIALS
In accordance with the FTC guidelines concerning the use of endorsements and testimonials in advertising, please be aware of the following:
•Testimonials that appear on this Site (written word, pictures, audio and/or video) are actually received via text, audio or video submission. They are individual experiences, reflecting real life experiences of those who have used our services in some way. They are individual results and results do vary. We do not claim that they are typical results. The testimonials are not necessarily representative of all of those who will use our services.
•The testimonials displayed in any form on this site (text, audio, video or other) are reproduced verbatim, except for correction of grammatical or typing errors. Some may have been shortened. In other words, not the whole message received by the testimonial writer is displayed when it seems too lengthy or not the whole statement seems relevant for the general public.
•We are not responsible for any of the opinions or comments posted on our Site, and while this Site is not a forum for testimonials, we do provide testimonials as a means for customers to share their experiences with one another. To protect against abuse, all testimonials appear after they have been reviewed by management. We make no representations, implicit or explicit, that we share the opinions, views or commentary of any testimonials on this Site, as the opinions and views are strictly those of the testimonial source.
13. DISCLAIMER AND LIMITATION OF LIABILITY
We make no representations, warranties, or assurances as to the accuracy, currency or completeness of the content contained on this Site or any sites linked to this Site.
All the materials on this Site are provided "as is" without any express or implied warranty of any kind, including warranties of merchantability, noninfringement of intellectual property or fitness for any particular purpose. In no event shall this Site or its agents or associates be liable for any damages whatsoever (including, without limitation, damages for loss of profits, business interruption, loss of information, injury or death) arising out of the use of or inability to use the materials, even if we have been advised of the possibility of such loss or damages.
We are committed to conducting our business in accordance with these principles in order to ensure that the confidentiality of personal information is protected and maintained.
This website is owned and operated by: The Schwarz Group, LLC
If you have any questions regarding this policy, or your dealings with our website, please contact us here: Schwarz@globalcyberrisk.com