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Website Privacy

Last updated: June 19, 2023

This website privacy policy demonstrates GreyCastle Security, LLC’s commitment to the privacy of your personally identifiable information (PII). You can visit this web site without telling us who you are or revealing any information about yourself. However, when you register on our site to receive information, register for events or newsletters, apply for an open position, or otherwise interact with GreyCastle Security, LLC, we may collect profile information or PII from you.

Collecting and Using Your Personal Data

Types of Data Collected

Personally Identifiable Data (PII)

In order to fulfill your request for information or to register for events or newsletters, we may ask that you provide:

      • First name
      • Last name
      • E-mail address
      • Phone number
      • Title
      • Company
      • Company location
      • Industry
      • Number of employees

If you are applying for an open position, we will ask that you provide:

      • Full Name
      • Email address
      • Cover letter
      • Resume

Usage Data

We may collect information such as:

      • Your device’s Internet Protocol address (IP address)
      • Browser type
      • Browser version
      • Pages you visited
      • Time and date of your visit
      • Time spent on those pages
      • Unique device identifiers
      • Other diagnostic data

Tracking Technologies and Cookies

We use cookies and similar tracking technologies to track the activity on our webpages and to store certain information. Tracking technologies used are:

      • Cookies or browser cookies—a small file placed on your device
      • Web beacons—small electronic files (also referred to as clear gifs, pixel tags and single-pixel gifs) that permit us, for example, to count webpage visitors

You can set your browser to refuse all cookies or to indicate when a cookie is being sent.

Cookies can be “Persistent” or “Session” cookies. Persistent cookies remain on your device when you go offline, while session cookies are deleted as soon as you close your browser.

Use of Your Personal Data

We may use your personal data for the following purposes:

      • To provide and maintain our website
      • To respond to your inquiries
      • To process orders
      • To contact you regarding account status or customer service
      • To ask for your feedback on our service
      • To provide you with news, special offers and general information about our services unless you have opted to not receive such information
      • To match you with appropriate job opportunities
      • To contact you regarding your open position application

We may share your personal information in the following situations:

      • With service providers: We may share your personal data to monitor and analyze the use of our website.
      • For business transfers: We may share or transfer your personal data in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
      • With your consent: We may disclose your personal data for any other purpose with your consent.

Retention of Your Personal Data

We will retain your personal data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your personal data to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our legal agreements and policies.

We will retain your usage data of internal analysis purposes. Usage data is generally retained for a shorter period of time.

Transfer of Your Personal Data

Your information is processed at our operating offices and in any other places where the parties involved in the processing are located. This means that your personal data 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 than those from your jurisdiction.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

We will take all reasonable steps necessary to ensure that your personal data is treated securely and in accordance with this Privacy Policy and that no transfer of your personal data will take place to an organization or country unless there are adequate controls in place.

Disclosure of Your Personal Data

      • Business transactions: If we are involved in a merger, acquisition or asset sale, your personal data may be transferred. We will provide notice before your personal data is transferred and becomes subject to a different Privacy Policy.
      • Law enforcement: Under certain circumstances, we may be required to disclose your personal data if required to do so by law or in response to valid requests by public authorities.
      • Other legal requirements: We may disclose your personal data in the good faith belief that such action is necessary to:
          1. Comply with a legal obligation
          2. Protect and defend our rights or property
          3. Prevent or investigate possible wrongdoing in connection with our services
          4. Protect the personal safety of users or the public
          5. Protect against legal liability

GDPR Privacy

Legal Basis for Processing Personal Data under GDPR

We may process personal data under the following conditions:

      • Consent: You have given your consent for processing personal data for one or more specific purposes.
      • Performance of a contract: Provision of personal data is necessary for the performance of an agreement with you and/or for any pre-contractual obligations thereof.
      • Legal obligations: Processing personal data is necessary for compliance with a legal obligation to which we are subject.
      • Vital interests: Processing personal data is necessary in order to protect your vital interests or of another natural person.
      • Public interests: Processing personal data is related to a task that is carried out in the public interest or in the exercise of official authority vested in our company.
      • Legitimate interests: Processing personal data is necessary for the purposes of our legitimate interests.

In any case, we will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Your Rights under the GDPR

We respect the confidentiality of your personal data and strive to guarantee that you can exercise your rights.

You have the right under this Privacy Policy, and by law if you are within the EU, to:

      • Request access to your personal data
      • Request correction of the personal data that we hold about you
      • Object to the processing of your personal data
      • Request erasure of your personal data
      • Request the transfer of your personal data
      • Withdraw your consent

Exercising of Your GDPR Data Protection Rights

You may exercise your rights of access, rectification, cancellation and opposition by contacting us. Please note that we may ask you to verify your identity before responding to such requests. If you make a request, we will try our best to respond to you as soon as possible.

You have the right to complain to a Data Protection Authority about our collection and use of your personal data. For more information, if you are in the European Economic Area (EEA), please contact your local data protection authority in the EEA.

CCPA Privacy

This privacy notice section for California residents supplements the information contained in our Privacy Policy, and it applies solely to all visitors, users, and others who reside in the State of California.

Categories of Personal Information Collected

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device. The following is a list of categories of personal information which we may collect or may have been collected from California residents.

Please note that the categories and examples provided in the list below are those defined in the CCPA. This does not mean that all examples of that category of personal information were in fact collected by us but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been collected. For example, certain categories of personal information would only be collected if you provided such personal information directly to us.

Category Content Examples Collected by Us
A Identifiers Real name, alias, postal address, unique personal identifier, online identifier, IP address, email address, account number, driver’s license number, passport number, or similar identifiers Yes
B Personal information categories listed in CA Customer Records statute Name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information Yes
C Protected classification characteristics under CA or federal law Age, race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sec (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information) No
D Commercial information Records and history of products or services purchased or considered No
E Biometric information Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data No
F Internet or other similar network activity Interaction with our website or advertisement Yes
G Geolocation data Approximate physical location No
H Sensory data Audio, electronic, visual, thermal, olfactory, or similar information No
I Professional or employment-related information Current or past job history or performance evaluations Yes
J Non-public education information (per FERPA) Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records No
K Inferences drawn from other personal information Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes No

 

Under CCPA, personal information does not include:

      • Publicly available information from government records
      • Deidentified or aggregated consumer information
      • Information excluded from the CCPA’s scope, such as:
          1. Health or medical information covered by Health Insurance Portability and Accountability Act (HIPAA) and the CA Confidentiality of Medical Information Act (CMIA) or clinical trial data
          2. Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or CA Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act

Sources of Personal Information

We obtain the categories of personal information listed above from the following categories of sources:

      • Directly from you: For example, from the forms you complete or the preferences you express
      • Indirectly from you: For example, from observing your activity on our website
      • Automatically from you: For example, through cookies we or our service providers set on your device as you navigate through our website
      • From service providers: For example, third-party vendors to monitor and analyze the use of our website or third-party vendors that we use to provide information to you

Use of Personal Information for Business Purposes or Commercial Purposes

We may use or disclose personal information we collect for “business purposes” or “commercial purposes” (as defined under the CCPA), which may include the following examples:

      • To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our website.
      • To fulfill or meet the reason you provided the information. For example, if you share your contact information to ask a question, we will use that personal information to respond to your inquiry.
      • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
      • As described to you when collecting your personal information or as otherwise set forth in the CCPA.
      • To detect security incidents and protect against malicious, deceptive, fraudulent or illegal activity, including, when necessary, to prosecute those responsible for such activities.

Please note that the examples provided above are illustrative and not intended to be exhaustive. For more details on how we use this information, please refer to the “Use of Your Personal Data” section.

If we decide to collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes, we will update this Privacy Policy.

Disclosure of Personal Information for Business Purposes or Commercial Purposes

We may use or disclose and may have used or disclosed the following categories of personal information for business or commercial purposes:

      • Category A: Identifiers
      • Category B: Personal information categories listed in the CA Customer Records statute
      • Category F: Internet or other similar network activity
      • Category I: Professional or employment-related information

Please note that the categories listed above are those defined in the CCPA. This does not mean that all examples of that category of personal information were in fact disclosed but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been disclosed.

When we disclose personal information for a business purpose or a commercial purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

Sale of Personal Information

As defined in the CCPA, “sell” and “sale” mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by the business to a third party for valuable consideration. We do not sell your personal information.

Share of Personal Information

We may share your personal information in the above categories with the following categories of third parties:

      • Service providers
      • Our business partners
      • Third party vendors to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you

Sale of Personal Information of Minors Under 18 Years of Age

We do not knowingly collect personal information from minors under the age of 18. We do not sell the personal information of consumers of any age.

If you have reason to believe that a child under the age of 18 has provided us with personal information, please contact us with sufficient detail to enable us to delete that information.

Your Rights under the CCPA

The CCPA provides CA residents with specific rights regarding their personal information. If you are a resident of CA, you have the following rights:

      • The right to notice: You have the right to be notified which categories of personal data are being collected and the purposes for which the personal data is being used.
      • The right to request: Under CCPA, you have the right to request that we disclose information to you about our collection, use, sale, disclosure for business purposes and share of personal information. Once we receive and confirm your request, we will disclose to you:
          1. The categories of personal information we collected about you
          2. The categories of sources for the personal information we collected about you
          3. The categories of sources for the personal information we collected about you
          4. Our business or commercial purpose for collecting or selling that personal information
          5. The categories of third parties with whom we share that personal information
          6. The specific pieces of personal information we collected about you
          7. If we sold your personal information or disclosed your personal information for a business purpose, we will disclose to you:
              • The categories of personal information categories sold
              • The categories of personal information categories disclosed
      • The right to say no to the sale of personal data (opt-out): You have the right to direct us to not sell your personal information.
      • The right to delete personal data: You have the right to request the deletion of your personal data, subject to certain exceptions. Once we receive and confirm your request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. We may deny your deletion request if retaining the information is necessary for us or our service providers to:
          1. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
          2. Debug products to identify and repair errors that impair existing intended functionality.
          3. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
          4. Comply with the CA Electronic Communications Privacy Act.
          5. 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.
          6. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
          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.
      • The right not to be discriminated against: You have the right not to be discriminated against for exercising any of your consumer’s rights, including by:
          1. Denying goods or services to you
          2. Charging different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties
          3. Providing a different level or quality of goods or services to you
          4. Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services

Exercising Your CCPA Data Protection Rights

In order to exercise any of your rights under the CCPA, and if you are a CA resident, you can contact us:

      • By visiting this page on our website: https://greycastlesecurity.com/company/contact-us/

Only you, or a person registered with the CA Secretary of State that you authorize to act on your behalf, may make a verifiable request related to your personal information.

Your request to us must:

      • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative
      • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it

We cannot respond to your request or provide you with the required information if we cannot:

      • Verify your identity or authority to make the request
      • And confirm that the personal information relates to you

We will disclose and deliver the required information free of charge within 45 days of receiving your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonably necessary and with prior notice.

Any disclosures we provide will only cover the 12-month period preceding the verifiable request’s receipt.

For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

Links to Other Websites

Our website may contain links to other websites that are not operated by us. If you click on a third party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, you can contact us:

      • By visiting this page on our website: https://greycastlesecurity.com/contact

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