Effective Date: July 2, 2018.

The Secure Halo™ Team Privacy Notice
Thank you for visiting this website, a digital service provided to you by Secure Halo™. dba SecureHalo (“The Secure Halo™ Team”, “Secure Halo™”, “we”, “us”, or “our”). Your privacy is important to us. Please review this Privacy Policy carefully as you must agree to it in its entirety in order continue to access any websites, software, applications and/or digital services owned, operated or offered by or on behalf of The Secure Halo™ Team through which this Privacy Policy appears or is incorporated (each, a “Service” and together, the “Services”). Persons who use the Services are hereinafter referred to as “Users”, “you” or “your”.

I. What Information We Collect and How We Use It
We collect personal information that you provide directly to us, such as personal information you provide when you visit the Services, and we collect information from you passively or automatically when you visit the Services, such as anonymous information collected from your browser or device. In addition to using information that we collect for the purposes set forth below, we may use information we collect to establish or defend our legal rights, to protect the safety and security of Users of the Services; and as otherwise disclosed in the Terms of Use posted on the applicable Service.

Information You Provide to Us.
Information We Collect When You Request our Services. In order to use our Secure Halo portal and/or subscribe to certain Services, we may ask you to provide certain personal information, such as your first and last name; job title; contact information such as your work address, work phone number, and work email address; information about your preferences; information needed for us to fulfill our Services to you; financial information such as payment-related information; and other information that you voluntarily choose to provide to us. We use this information in order to enable us to provide our Services to you or your company, to communicate with you about our Services and your account, to validate your identity and to fulfill any other legal or regulatory requirements that we may be subject to. We may disclose this information to third parties to the extent that is reasonably necessary to provide the Services (for example, when utilizing services from third-party service providers such as our cloud service provider).

Information We Collect When You Contact Us Though the Services. We may provide you with the ability to contact us through some Services to request information from us, subscribe to our e-newsletter or request other marketing materials. We may ask you to provide certain information, such as your first and last name, phone number and email address. We use this information to respond to your inquiries; to fulfill your requests regarding the Services, including without limitation requests for newsletters, marketing materials and/or notifications; and to communicate with you about other products, programs or services that we believe may be of interest to you.

Information We Collect When You Inquire About Or Respond To Employment Opportunities. We collect information from and about candidates in connection with potential and available employment opportunities. This information may include your resume, identification documents, academic records, work history, information about your employment, references and other information pertinent to the employment opportunity. We may collect personal information directly from you, such as when you contact us through the “Careers” page on certain Services. We may collect information about you from recruitment agencies – for example, when a recruitment agency contacts us to identify you as a potential candidate. We may collect information about you from publicly available sources online – for example, where you have a professional bio posted on your current employer’s website or on a professional networking site like LinkedIn; and by reference or word of mouth – for example, through a referral from a current or former employee/employer or from a reference you have identified. We use this personal information to assess your qualifications with regards to available employment opportunities with The Secure Halo™ Team.

Information That We Passively or Automatically Collect From You
When you visit our Services, we or our third party service providers may automatically collect certain personal information automatically from your device, such as your IP address, device type, unique device identification number, browser-type, broad geographic location (e.g. country or city-level location) and other technical information. We may also collect information about how your device has interacted with our Services, including the pages accessed and links clicked. We and our third party service providers use this information to understand and improve the quality and relevance of our Services and to advertise and market our Services to you.

Some of this information may be collected using cookies and other similar tracking technologies. For more information on how we use cookies and how to set your preferences, please read our Cookie Notice http://www.securehalo.com/privacy-policy/cookies.

II. Who We Share Your Information With
We will not share your information with any third parties for the purposes of direct marketing.
We may disclose your personal information to the following categories of recipients:

• Our third-party services providers who we have contracted with to provide certain services on our behalf, such as website hosting services, cloud services, authentication services, error reporting, email management, technical and operational support services, payment clearance and processing services, business analytics, marketing and advertising services. These third parties are allowed to use your personal information for the purpose of performing such functions and for no other purpose.
• A potential buyer (and its agents and advisers) in connection with a bankruptcy or any proposed purchase, merger or acquisition of all or any part of our business, provided that we inform the buyer that they must use only your personal information for the purposes set forth in this Privacy Notice;
• Any law enforcement agency, regulator, court or other government agency or third party if we reasonably believe such disclosure is necessary as a matter of applicable law or regulation or to exercise, establish or defend our legal rights; and
• To anyone you have given us your consent to disclose your personal information to.

III. Links to Other Websites
Some of our Services may contain links to third party websites. This privacy notice does not cover how those third parties process your personal information. We have no control over information that is submitted to, or collected by, these third party websites. We encourage you to read the privacy notices on the other websites you visit.

IV. How We Respond to Do Not Track Signals
At this time, our Services do not recognize “do not track” settings or signals.

V. How to Control User Preferences
You can choose to enjoy content and features on some of the Services without directly providing us with any information about you; however, as described above, some information may automatically be collected or may be requested so you can take advantage of certain features and services offered on the Services. The Services may contain web pages through which you can edit and update personal information you have provided to us through registration with one or more of the Services and which may allow you to change your marketing preferences. You may also opt-out of receiving marketing communications or other communications by following the instructions contained in any such communication when you receive them. Please note that if you register for a Secure Halo account, we reserve the right to send you certain communications relating to your account such as administrative and service announcements if they relate to your account, and these transactional account messages are not affected if you choose to opt-out from marketing e-mails. When you edit your personal information or change your preferences, information that you remove may persist internally for the Secure Halo™ teams administrative purposes (such as to honor your opt-out).

VI. Children’s Online Privacy Protection Act
The Services are not available to persons under the age of 18. We do not knowingly collect any personal information from or market to individuals younger than the age of eighteen (18). If you are under 18 years of age, do not use the Services or send any information about yourself to Secure Halo™.

VII. Data Protection Rights for Residents in the European Economic Area (EEA)
If you are a resident in the EEA, you have the following data protection rights:

• You have a right to ask us for copies of your personal information. This right always applies. There are some exemptions, which means you may not always receive all the information we process.
• You have the right to ask us to correct information you think is inaccurate and to ask us to complete information you think is incomplete.
• You have the right to ask us to erase your personal information in certain circumstances.
• You have the right to ask us to restrict the processing of your information in certain circumstances.
• You have the right to ask that we transfer information you gave us. The right only applies if we are processing information based on your consent or under, or in talks about entering into a contract and the processing is automated.
• You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you.

You can exercise these rights by following instructions on the Privacy Tools page or by contacting us by email at privacy@securehalo.com. We will respond to requests received from EEA residents wishing to exercise their data protection rights in accordance with applicable data protection laws. If you are not satisfied with our response, you can contact a supervisory authority. Please do not disclose any sensitive Personal Data, national identification numbers, or criminal background information when contacting us.

VIII. Data Transfers
The Secure Halo™ Team is headquartered in the United States. Please be aware that information you provide to us or that we obtain as a result of your use of the Services may be collected in your country and subsequently transferred to the United States or another country in accordance with applicable law. The privacy and data protection laws in another country may not be equivalent to such laws in your country of residence. By using and participating in the Services or providing us with your information, you consent to the collection, international transfer, storage, and processing of your information.

If you are located in the EEA, we will implement appropriate safeguards to protect your personal data as required if we transfer it outside of the EEA.

IX. Data Security
We are committed to protecting your personal information. We have adopted commercially reasonable technical, administrative, and physical procedures designed to help protect your personal information from loss, misuse, and unauthorized alteration. Please note that no data transmission or storage can be guaranteed to be 100% secure. We want you to feel confident using the Services but we cannot ensure or warrant the security of any personal information you transmit to us.

X. Changes to This Privacy Notice
By using the Services, you acknowledge your agreement and consent to the terms of this privacy notice. We may change our privacy notice from time to time. Any modifications to our privacy notice will be reflected by the “Effective Date” or “Last Modified Date” on this privacy notice. Secure Halo™ will use your personal information in a manner consistent with the privacy notice in effect at the time you submitted your personal information, unless you consent to the new or revised privacy notice.

XI. Contact The Secure Halo™ Team
If you have any questions or concerns about our use of your personal information, please contact us at:

Secure Halo™
962 Wayne Ave, Suite 310
Silver Spring, MD 20910
202-629-1960
info@securehalo.com