Last Updated: 2/20/2024

Protegrity Privacy Policy

This Privacy Policy is designed to help you understand how Protegrity USA, Inc. and its affiliates (“Protegrity”, “we”, “us”, and “our”) collect, use, and share your personal information and to help you understand and exercise your privacy rights.

SCOPE
PERSONAL INFORMATION WE COLLECT
HOW WE USE YOUR INFORMATION
HOW WE DISCLOSE YOUR INFORMATION
YOUR PRIVACY CHOICES AND RIGHTS
SECURITY OF YOUR INFORMATION
INTERNATIONAL DATA TRANSFERS
RETENTION OF PERSONAL INFORMATION
SUPPLEMENTAL NOTICE FOR CALIFORNIA RESIDENTS
SUPPLEMENTAL NOTICE FOR NEVADA RESIDENTS
SUPPLEMENTAL NOTICE FOR AUSTRALIA RESIDENTS
SUPPLEMENTAL NOTICE FOR JOB APPLICANTS
CHILDREN’S INFORMATION
OTHER PROVISIONS
CONTACT US

1. SCOPE

This Privacy Policy applies to personal information processed by us, including on our websites and other online or offline offerings. To make this Privacy Policy easier to read, our websites and other offerings are collectively called the “Services.”

An Important Note: This Privacy Policy does not apply to any of the personal information that our customers may collect and process using Protegrity’s Services (“Customer Data”). Our customers’ respective privacy policies govern their collection and use of Customer Data. Our processing of Customer Data is governed by the contracts that we have in place with our customers, not this Privacy Policy. Any questions or requests relating to Customer Data should be directed to our customer.2. PERSONAL INFORMATION WE COLLECT

The categories of personal information we collect depend on how you interact with us, our Services, and the requirements of applicable law. We collect information that you provide to us, information we obtain automatically when you use our Services, and information from other sources such as third-party services and organizations, as described below.

A. Information You Provide to Us Directly

We may collect the following personal information that you provide to us.

Account Creation. We may collect information when you create an account, such as name, email address, and username.
Purchases. We may collect personal information and details associated with your purchases, including payment information. Any payments made via our Services are processed by third-party payment processors. We do not directly collect or store any payment card information entered through our Services, but we may receive information associated with your payment card information (e.g., your billing details).
Your Communications with Us. We may collect personal information, such as email address, phone number, or mailing address when you request information about our Services, register for our newsletter, request customer or technical support, apply for a job, or otherwise communicate with us.
Surveys. We may contact you to participate in surveys. If you decide to participate, you may be asked to provide certain information which may include personal
Interactive Features. We and others who use our Services may collect personal information that you submit or make available through our interactive features (e.g., messaging and chat features, commenting functionalities, forums, blogs, and social media pages). Any information you provide using the public sharing features of the Services will be considered “public,” unless otherwise required by applicable law, and is not subject to the privacy protections referenced herein.
Conferences, Trade Shows, and Other Events. We may collect personal information from individuals when we attend conferences, trade shows, and other
Business Development and Strategic Partnerships. We may collect personal information from individuals and third parties to assess and pursue potential business
Job We may post job openings and opportunities on our Services. You may reply to one of these postings by submitting your application, CV and/or cover letter to us.

B. Information Collected Automatically

We may collect personal information automatically when you use our Services:

Automatic Data Collection. We may collect certain information automatically when you use our Services, such as your Internet protocol (IP) address, user settings, MAC address, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, browser or device information, location information (including approximate location derived from IP address), and Internet service provider. We may also automatically collect information regarding your use of our Services, such as pages that you visit before, during and after using our Services, information about the links you click, the types of content you interact with, the frequency and duration of your activities, and other information about how you use our Services.
Cookies, Pixel Tags/Web Beacons, and Other Technologies. We, as well as third parties that provide content, advertising, or other functionality on our Services, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through your use of our Services.
Cookies. Cookies are small text files placed in device browsers that store preferences and facilitate and enhance your experience.
Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded in our Services that collects information about engagement on our Services. The use of a pixel tag allows us to record, for example, that a user has visited a particular web page or clicked on a particular We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded.

Our uses of these Technologies fall into the following general categories:

Operationally Necessary. This includes Technologies that allow you access to our Services, applications, and tools that are required to identify irregular website behavior, prevent fraudulent activity and improve security or that allow you to make use of our functionality;
Performance-Related. We may use Technologies to assess the performance of our Services, including as part of our analytic practices to help us understand how individuals use our Services (see Analytics below);
Functionality-Related. We may use Technologies that allow us to offer you enhanced functionality when accessing or using our Services. This may include identifying you when you sign into our Services or keeping track of your specified preferences, interests, or past items viewed;
Advertising- or Targeting-Related. We may use first party or third-party Technologies to deliver content, including ads relevant to your interests, on our Services or on third-party websites.

See “Your Privacy Choices and Rights” below to understand your choices regarding these Technologies.

Analytics. We may use Technologies and other third-party tools to process analytics information on our Services. Some of our analytics partners include:
Google Analytics. For more information, please visit Google Analytics’ Privacy Policy. To learn more about how to opt-out of Google Analytics’ use of your information, please click here.
LinkedIn Analytics. For more information, please visit LinkedIn Analytics’ Privacy Policy. To learn more about how to opt-out of LinkedIn’s use of your information, please click here.

C. Information Collected from Other Sources

We may obtain information about you from other sources, including through third-party services and organizations. For example, if you access our Services through a third-party application, such as an app store, a third-party login service, or a social networking site, we may collect information about you from that third-party application that you have made available via your privacy settings.

3. HOW WE USE YOUR INFORMATION

We use your information for a variety of business purposes, including to provide our Services, for administrative purposes, and to market our products and Services, as described below.

A. Provide Our Services

We use your information to fulfil our contract with you and provide you with our Services, such as:

Managing your information and accounts;
Providing access to certain areas, functionalities, and features of our Services;
Answering requests for customer or technical support;
Communicating with you about your account, activities on our Services, and policy changes;
Processing your financial information and other payment methods for products or Services purchased;
Processing applications if you apply for a job we post on our Services; and
Allowing you to register for

B. Administrative Purposes

We use your information for various administrative purposes, such as:

Pursuing our legitimate interests such as direct marketing, research and development (including marketing research), network and information security, and fraud prevention;
Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity;
Measuring interest and engagement in our Services;
Improving, upgrading or enhancing our Services;
Developing new products and Services;
Ensuring internal quality control and safety;
Authenticating and verifying individual identities, including requests to exercise your rights under this policy;
Debugging to identify and repair errors with our Services;
Auditing relating to interactions, transactions and other compliance activities;
Enforcing our agreements and policies; and
Complying with our legal

C. Marketing and Advertising our Products and Services

We may use personal information to tailor and provide you with content and advertisements. We may provide you with these materials as permitted by applicable law.

Some of the ways we market to you include email campaigns, custom audiences advertising, and “interest-based” or “personalized advertising,” including through cross-device tracking.

If you have any questions about our marketing practices, you may contact us at any time as set forth in “Contact Us” below.

D. Other Purposes

We also use your information for other purposes as requested by you or as permitted by applicable law.

Consent. We may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information or with your consent.

De-identified and Aggregated Information. We may use personal information and other information about you to create de-identified and/or aggregated information, such as de-identified demographic information, de-identified location information, information about the device from which you access our Services, or other analyses we create.

4. HOW WE DISCLOSE YOUR INFORMATION

We disclose your information to third parties for a variety of business purposes, including to provide our Services, to protect us or others, or in the event of a major business transaction such as a merger, sale, or asset transfer, as described below.

A. Disclosures to Provide our Services

The categories of third parties with whom we may share your information are described below.

Service Providers. We may share your personal information with our third-party service providers who use that information to help us provide our This includes service providers that provide us with IT support, hosting, payment processing, customer service, and related services.
Our Customers (Authorized Users Only). If you use our Services as an employee or contractor of a company or other legal entity that is our customer (each an “Authorized User”), that customer may access information associated with your use of the Services including usage data and the contents of the communications and files associated with your account. Your personal information may also be subject to the customer’s privacy policy. We are not responsible for the customer’s processing of your personal
Business Partners. We may share your personal information with business partners to provide you with a product or service you have requested. We may also share your personal information to business partners with whom we jointly offer products or
Affiliates. We may share your personal information with our company
Advertising Partners. We may share your personal information with third-party advertising partners. These third-party advertising partners may set Technologies and other tracking tools on our Services to collect information regarding your activities and your device (e.g., your IP address, cookie identifiers, page(s) visited, location, time of day). These advertising partners may use this information (and similar information collected from other services) for purposes of delivering personalized advertisements to you when you visit digital properties within their networks. This practice is commonly referred to as “interest-based advertising” or “personalized advertising.”

B. Disclosures to Protect Us or Others

We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our, or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.

C. Disclosure in the Event of Merger, Sale, or Other Asset Transfers

If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract.

5. YOUR PRIVACY CHOICES AND RIGHTS

Your Privacy Choices. The privacy choices you may have about your personal information are determined by applicable law and are described below.

Email and Telephone Communications. If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. Note that you will continue to receive transaction-related emails regarding products or Services you have requested. We may also send you certain non-promotional communications regarding us and our Services, and you will not be able to opt out of those communications (e.g., communications regarding our Services or updates to our Terms or this Privacy Policy).
Text You may opt out of receiving text messages from us by following the instructions in the text message you have received from us or by otherwise contacting us.
“Do Not Track.” Do Not Track (“DNT”) is a privacy preference that users can set in certain web Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
Cookies and Interest-Based Advertising. You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device However, if you adjust your preferences, our Services may not work properly. Please note that cookie-based opt-outs are not effective on mobile applications. However, you may opt-out of personalized advertisements on some mobile applications by following the instructions for Android, iOS and others.

The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy by visiting the Network Advertising Initiative, the Digital Advertising Alliance, the European Digital Advertising Alliance, and the Digital Advertising Alliance of Canada.

Please note you must separately opt out in each browser and on each device.

Your Privacy Rights. In accordance with applicable law, you may have the right to:

Access Personal Information about you, including: (i) confirming whether we are processing your personal information; (ii) obtaining access to or a copy of your personal information in a structured, commonly used, and machine readable format; and (iii) receiving an electronic copy of personal information that you have provided to us, or asking us to send that information to another company in a structured, commonly used, and machine readable format (the “right of data portability”);
Request Correction of your personal information where it is inaccurate or incomplete. In some cases, we may provide self-service tools that enable you to update your personal information;
Request Deletion of your personal information;
Request Restriction of or Object to our processing of your personal information; and
Withdraw your Consent to our processing of your personal

If you would like to exercise any of these rights, please contact us as set forth in “Contact Us” below. We will process such requests in accordance with applicable laws.

6. SECURITY OF YOUR INFORMATION

We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy. Unfortunately, no system is 100% secure, and we cannot ensure or warrant the security of any information you provide to us. To the fullest extent permitted by applicable law, we do not accept liability for unauthorized disclosure.

By using our Services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of our Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on our Services, by mail or by sending an email to you.

7. INTERNATIONAL DATA TRANSFERS

All information processed by us may be transferred, processed, and stored anywhere in the world, including, but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live. We endeavor to safeguard your information consistent with the requirements of applicable laws.

8. RETENTION OF PERSONAL INFORMATION

We store the personal information we collect as described in this Privacy Policy for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

9. SUPPLEMENTAL NOTICE FOR CALIFORNIA RESIDENTS

This Supplemental California Privacy Notice only applies to our processing of personal information that is subject to the California Consumer Privacy Act of 2018 (“CCPA”). The CCPA provides California residents with the right to know what categories of personal information Protegrity has collected about them and whether Protegrity disclosed that personal information for a business purpose (e.g., to a service provider) in the preceding twelve months. California residents can find this information below:

Category of Personal Information Collected by Protegrity	Categories of Third Parties Personal Information is Disclosed to for a Business Purpose
Identifiers	· Service providers · Protegrity customers (Authorized Users only) · Advertising partners
Personal information categories listed in Cal. Civ. Code § 1798.80(e)	· Service providers · Protegrity customers (Authorized Users only)
Commercial information	· Service providers · Protegrity customers (Authorized Users only)
Internet or other electronic network activity	· Service providers · Protegrity customers (Authorized Users only) · Advertising partners
Professional or employment-related information	· Service providers · Protegrity customers (Authorized Users only)
Inferences drawn from other personal information to create a profile about a consumer	· Service providers · Advertising partners

The categories of sources from which we collect personal information and our business and commercial purposes for using personal information are set forth in “Personal Information We Collect” and “How We Use Your Personal Information” above, respectively.

Additional Privacy Rights for California Residents

“Sales” of Personal Information under the CCPA. For purposes of the CCPA, Protegrity does not “sell” personal information, nor do we have actual knowledge of any “sale” of personal information of minors under 16 years of age.

Non-Discrimination. California residents have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by the CCPA.

Authorized Agent. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. To designate an authorized agent, please contact us as set forth in “Contact Us” below.

Verification. When you make a request, we will ask you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include asking you to verify your email address we have on file.

If you are a California resident and would like to exercise any of your rights under the CCPA, please contact us as set forth in “Contact Us” below. We will process such requests in accordance with applicable laws.

10. SUPPLEMENTAL NOTICE FOR NEVADA RESIDENTS

If you are a resident of Nevada, you have the right to opt-out of the sale of certain personal information to third parties who intend to license or sell that personal information. Please note that we do not currently sell your personal information as sales are defined in Nevada Revised Statutes Chapter 603A. If you have any questions, please contact us as set forth below.

11. SUPPLEMENTAL NOTICE FOR AUSTRALIA RESIDENTS

We do not generally require you to disclose any sensitive information (e.g., details of race, religious belief, sexual orientation or membership of a trade union) to us. If you do provide us with sensitive information for any reason, you consent to us collecting that information and using and disclosing that information for the purpose for which you disclosed it to us and as permitted by the Australian Privacy Act 1988 (Cth) and other relevant laws.

12. SUPPLEMENTAL NOTICE FOR JOB APPLICANTS

This supplemental notice describes Protegrity’s practices with respect to the collection, use, storage and disclosure (“Processing”) of Personal Information (or Personal Data) protected by privacy laws such as the European Union’s General Data Protection Regulation (“GDPR”), the California Consumer Privacy Act (as amended by the California Privacy Rights Act, the “CCPA/CPRA”), and substantially similar laws in other jurisdictions to the extent applicable to Protegrity (the “Privacy Laws”). This supplemental notice is a part of Protegrity’s Privacy Policy. Please refer to the full Privacy Policy for additional information about how we process information about you and your additional rights.

As used in this supplemental notice, “Personal Information” or “Personal Data” mean any information that can be used to identify you, whether directly or indirectly, including by reference to an identifier such as a name, identification number, and also includes information that may be considered “sensitive” such as location data, information specific to your physical, physiological, genetic, mental, economic or social identity, and information you may choose to provide relating to your race or ethnicity.

A. Information We Process About You

When you apply for employment with Protegrity, we Process the following categories of personal information about you during the recruitment process in addition to the information described in the Privacy Policy above applicable to your general use of our websites:

Your name, address, email address, telephone number and other contact information
The information you have provided to us in your CV/resume and cover letter
Any additional information you provide to us in support of an application
Information from interviews and screenings you may have
Details of the type of role you are looking for, current salary (where relevant) and salary expectations, and other terms relating to compensation and benefits packages, or other job preferences
Details of how you heard about the position you are applying for
Reference information and/or information received from background checks, including information provided by third parties
Information relating to any previous recruitment and/or employment history with us
Information relevant to your right to work or being eligible for internship/traineeship, including nationality, or citizenship, for visa purposes
Information about your national origin, where relevant for visa purposes
Medical or health information, where relevant
Information about criminal convictions and offences where required for the role
Security clearances held by you
where needed, information regarding any professional certifications possessed by you
Diversity monitoring related data if you choose to voluntarily disclose it with us and only to the extent allowed under the law.

We have collected the categories of personal information outlined above in preceding (12) twelve months from candidates.

B. How is your personal information collected?

We collect personal information about candidates from the following sources:

You (the candidate)
Our background check provider from whom we collect the following categories of data:
- Employment/Activity History (within the last 7 years)
- Address verification
- Professional qualifications history
- Criminal history (within the last 10 years)
- Government exclusion databases and watchlists
Our recruitment service providers with whom we cooperate
Reference you identify, from whom we collect confirmation of your role and dates of employment
Information about you, including your contact details, your profile and CV (if available) from the following publicly available sources: LinkedIn, No Fluff, Twitter, Facebook, Instagram, Glass Door and from regional job boards and other social media

C. How we process your personal information and our legal basis for processing

We Process Personal Information as generally described above in this Privacy Policy and, more specifically with respect to job applicants: to recruit prospective employees; evaluate applications for employment at Protegrity; evaluate your eligibility for employment; communicate with you about Protegrity and your application; and, if you are offered a position at Protegrity, to manage your acceptance of our offer of employment and begin the process of onboarding you as a new employee. We also use your data for purposes required by law, including complying with application retention requirements, filing reports with applicable government agencies, and for the enforcement of Protegrity policies and applicable laws.

We may combine personal information received from above sources and process it for the purposes described in this Privacy Policy and supplemental notice.

We have the following legal basis for processing the information you provide us in your application or that we collect about you during the application process. We have a legitimate interest in recruiting and hiring qualified applicants, complying with laws and regulations that govern our conduct in the countries where we operate, and managing and operating Protegrity in an efficient, ethical, and appropriate manner. We process all the information we collect from or about you to meet these purposes.

If you fail to provide information when requested, which is necessary for us to consider your application, we may not be able to take you forward in our recruitment process. For example, if we require a reference for this role and you fail to provide us with relevant details, we will not be able to take your candidacy further.

Once you have accepted an offer of employment from us, we may also be required to process your Personal Information to send you an employment offer letter or to complete a contract that you may enter with us, including a contract of employment or an agreement to receive certain other benefits. We may also be required to process your Personal Information to comply with laws applicable to Protegrity and/or applicable in the jurisdiction in which you reside.

In the case of Sensitive Personal Information (which includes (i) information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership; (ii) genetic and biometric data, and (iii) data concerning health, sex life, or sexual orientation), we process information either (i) because we have your consent to do so or (ii) because we are required to process the information to comply with applicable laws. For example, in certain jurisdictions, we are required to collect information about your disability status in order to comply with legal mandates to hire a certain number of disabled employees.

When we process your Sensitive Personal Information on the basis of your consent, you may withdraw that consent at any time by contacting privacy@protegrity.com. If you withdraw your consent, we may still be required to process your Sensitive Personal Information to comply with applicable law, but we will explain to you at the time your consent is withdrawn what processing activities will continue for legal compliance purposes.

D. How we share or disclose your personal information.

Your Personal Information will be received and processed by Protegrity employees and personnel, including third parties who provide services to Protegrity in connection with the purposes of processing described in Section C above, including background-check providers, service providers that support our application software and other programs, and service providers that support our human resources and hiring functions. We share your Personal Information with our service providers only when they have agreed to process your Personal Information only to provide services to us and have agreed to protect your Personal Information from unauthorized use, access, or disclosure. We provide Personal Information to printers and mailing houses, professional organizations, and third-party organizations who assist in verifying your credentials.

We may also disclose your information to government authorities as required by laws that regulate immigration, tax, national security, and criminal activity.

We will disclose (and we have disclosed during the past 12 months for our business purposes) your information as outlined above.

We do not sell and have not sold in past 12 months your personal information to third parties.

E. Data Retention

We will retain the personal information we collect pursuant to this supplemental notice for as long as we are required by law to do so. Depending on applicable law, we may be required us to retain a job applicant’s data for shorter or longer periods to meet local legal requirements or business practices. You can obtain additional information about the retention period applicable to your application information by contacting us.

13. CHILDREN’S INFORMATION

The Services are not directed to children under 13 (or other age as required by local law), and we do not knowingly collect personal information from children.

If you are a parent or guardian and believe your child has uploaded personal information to our Services without your consent, you may contact us as described in “Contact Us” below. If we become aware that a child has provided us with personal information in violation of applicable law, we will delete any personal information we have collected, unless we have a legal obligation to keep it, and terminate the child’s account, if applicable.

14. OTHER PROVISIONS

Third-Party Websites/Applications. The Services may contain links to other websites/applications and other websites/applications may reference or link to our Services. These third-party services are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen or approve, and are not responsible for, the privacy practices or content of such other websites or applications. Providing personal information to third-party websites or applications is at your own risk.

Supervisory Authority. If you are located in Australia, the European Economic Area, Switzerland, or the United Kingdom, you have the right to lodge a complaint with a

supervisory authority if you believe our processing of your personal information violates applicable law.

Changes to our Privacy Policy. We may revise this Privacy Policy from time to time in our sole discretion. If there are any material changes to this Privacy Policy, we will notify you as required by applicable law. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you continue to use our Services after the new Privacy Policy takes effect.

15. CONTACT US

If you have any questions about our privacy practices or this Privacy Policy, or to exercise your rights as detailed in this Privacy Policy, please contact us at:

Protegrity Corp.

333 Ludlow St., South Tower 8th Floor Stamford, CT 06902

privacy@protegrity.com