(a) The Company’s websites (including www.vultsecurity.com) and any other website where this Privacy Policy is posted; and

(b) Company tools, documents, emails, platforms, and applications (including mobile applications), and other services.

applications), and other services. 

By using the Services, you expressly consent to the collection, storage, use, and disclosure of your personal information as described in this Privacy Policy. Commitment to privacy. The Company has a strong commitment to providing information tailored to your individual needs while providing excellent service to all of our visitors and customers, including respecting concerns about privacy. We understand that you may have questions about whether and how we collect and use personal information. This Privacy Policy details the steps we take to respect your privacy concerns. If, after reviewing this Privacy Policy, you have any questions or privacy concerns, please send an email to privacy@vultsecurity.com. 

What personal information do we collect from you and other people that use our Services? 

We may collect and/or combine information from different sources (including, but not limited to, our Services, website(s), offline, etc.). We may combine information from third parties with personal information we already have. Any and all information we collect about you or your use of the Services may be collectively referred to herein as your “information”, and may include, but is not limited to, the following:

Personal Information. 

You may provide us with personal information in a variety of circumstances, e.g., by utilizing the Services, creating an account through the Services (“VULT Account”), updating your VULT Account profile, registering for, or participating in a marketing or transaction event, submitting an employment application, completing online forms, entering into a transaction, forming a relationship with us, or submitting any personal information to us as part of the Services. This information may include, without limitation, information such as your first and last name, e-mail address, mailing address, telephone number, username, password, billing information, financial information, birth date, social security number, and other information exchanged in connection with purchases of products, and related financing transactions. In some cases, this information includes government-issued identification documents, photographs, or related data (such as are standard with driver’s licenses, social security cards, passport books/cards, or birth certificates). Some of the Services require a facial scan. We also may acquire personal information from other sources such as offline records, publicly available information, or from third parties. We use personal information to provide the Services and as discussed in this Privacy Policy. If you choose to provide us with a third party’s information (e.g., the person’s name, phone number, email, etc.) when taking part in our referral program, you represent that you have the third party’s permission to do so. 

Automatically Collected Information. 

We may automatically collect information about the computer or devices (including mobile devices) you use to access the Services. For example, we may collect and store information such as your browser type, IP address, language, operating system, domain name, geographic location of your wireless device (e.g., latitude and longitude), the state or country from which you accessed the Services, unique device identifier (e.g., a UDID or an IDFA on Apple devices like the iPhone, iPad, or iTouch, or the Android Ad ID), the pages you view, the Services you use, the date and time of your visit, the websites you visited immediately before and after visiting our websites, error logs, and other hardware and software information. You may be able to disable our ability to collect some of this information – consult the instructions for your particular device. We may use third party analytics providers and technologies, including cookies and similar tools, to assist in collecting this information. We may use this information to formulate statistical models about use of the Services, enhance the Services for our users, and provide you with tailored content and advertising. In addition, we may combine the information collected by us with information from third parties that may be identifiable to you. We may use this combined information to enhance or market the Services or for other purposes described in this Policy. 

Biometric Information. 

As part of our onboarding process, we may collect biometric information from you, such as facial scans. This information may be used for purposes such as access control and authentication. Please note that under legislation that includes, but is not limited to, the Illinois Biometric Information Privacy Act (BIPA), the Texas Capture or Use of Biometric Identifier Act (CUBI), and the Washington Biometric Privacy Protection Act, we are required to provide you with this notice and obtain your written consent before collecting, using, or disclosing your biometric information. 

VULT Account. 

Registration is required in order to access and utilize some functions provided by the Services. When you register your VULT Account, we will collect personal information that you provide. To register, you will be required to create an account by providing a user name and account password, and you will be required to provide your name, mailing address, telephone number, email address, and possibly other personal information deemed necessary to conduct business. Certain information specified in the preceding paragraph (such as what content you access, view, click on, or search for on the Services, the devices from which you access such content, and the length of time for which you view such content) may be associated with your VULT Account. We may use the information and account details from your VULT Account across all the Services that we offer. Related information may be used as permitted by this Privacy Policy. You are solely responsible for maintaining the confidentiality of your VULT Account and password and for restricting access to your computer, mobile device, and other mediums by which you access the Services, and you agree to accept sole responsibility for all activities that occur under your VULT Account and/or password. Customers are responsible for providing complete and accurate personal information to the organization during collection or in case of any changes. 

Our Use of Cookies. 

The Services use “cookie” technology and similar online tracking tools, such as Flash cookies, tags, application program interfaces, web beacons, and web pixels. “Cookies” are small files that a website stores on a user’s computer or device. The Services use cookies for various purposes, including to keep the information you enter on multiple pages together. Some of the cookies we use are “session” cookies, meaning that they are automatically deleted from your hard drive after you close your browser at the end of your session. Session cookies are used to optimize the performance of the Services and to limit the amount of redundant data that is downloaded during a single session. We also use “persistent” cookies, which remain on your computer or device unless deleted by you (or by your browser settings). We use persistent cookies for various purposes, such as: statistical analysis of performance to ensure the ongoing quality of our Services; to help us remember and process the items in your shopping cart; to help us understand your preferences based on previous or current website, application, and platform activity, which enables us to provide you with improved Services; to provide specific features that can help simplify your experience with the Services when you return to our Services, website(s), and application(s); monitor, evaluate, and optimize the use and operation of our Services; and analyze traffic on the Services. We and third parties also use session and persistent cookies for analytics and advertising purposes, as described below. Most web browsers automatically accept cookies, but you may set your browser to block certain cookies (consult the instructions for your particular browser on how to do this). Please note that if you decide to block cookies, this may interfere with your ability to perform certain transactions, use certain functionality, and access certain content on the Services. By clicking on the “Do Not Sell My Personal Information” hyperlink in the footer of our website(s)/application(s), you can launch a consent tool to adjust your preferences about how certain cookies and certain similar technologies are used in our Services and websites that hyperlink to that same preferences tool from their footer. You should repeat this process with each browser and device you use. This is the best way to control cookies on the sites that offer this option. 

Google Analytics. 

The Company websites may use Google Analytics, a vendor’s service that uses cookies, web beacons, web pixels, and/or similar web and mobile app technology to collect and store information about your browser’s or device’s activity, which may include the sorts of information described above. Google also allows you to install a Google Analytics Opt-out Browser Add-on for each web browser you use to limit their browser-based activities. 

Adobe Analytics. 

The Company websites may use Adobe’s analytics and on-site personalization services, which use cookies, web beacons, web pixels, and/or similar technology to collect and store information about you or your device or browser, which may include the sorts of information described above. You can learn more about how Adobe may handle information collected through our use of its services, and your options for controlling this activity, by visiting Adobe’s website. 

Telephone, Chat, and Video Conferencing Conversations. 

We may record the conversations our agents or employees have with you through any medium, including, without limitation, telephone conversations, online chat services, and/or video technology. By engaging in any telephone, chat, or video conversation with our agents or employees, you consent to our recording and storing such conversation. We do this from time to time to monitor the quality of service and accuracy of information our agents and employees give to you, to ensure that your instructions are followed, and to ensure compliance with the Terms of Use and applicable law. No agent or employee of the Company is authorized to waive this or any other provisions of our Company policies and procedures. 

When do we collect information? 

We collect information from you when you register on our platform, fill out a form, access information on our Services, website(s), and/or application(s), register as a buyer and/or seller on our Services platform. If you choose to provide us with a third party’s information (including, but not limited to, the person’s name, phone number, or email) when taking part in our referral program, you represent that you have the third party’s permission to do so. 

How do we use your information? 

We may use the information we collect from you when you register an VULT Account, make a purchase, sign up for our newsletter, respond to a survey or marketing communication, use the Services, website(s), or application(s), or use certain other site features in the following ways: 

● To personalize your experience and to allow us to deliver the type of content and product offerings in which you are most interested. 

● To improve our Services, website(s), and application(s) in order to better serve you. 

● To allow us to better service you in responding to your customer service requests. ● To administer a contest, promotion, survey, or other Services feature. 

● To quickly process your transactions. 

● To ask for ratings and reviews of services or products. 

● To follow up with customers after correspondence (live chat, email, or phone inquiries). 

● To create and maintain your VULT Account and account profile, registration information, and communication preferences. 

● Enhance the user experience relating to the Services. ● Perform research and analytics. 

● Customize, personalize, and deliver the content and advertising that you see on the Services and elsewhere. 

● Determine your eligibility for certain marketing or transaction events, services, gifts, prizes, and special features of the Services. 

● Call, email, or otherwise contact you: ○ to facilitate marketing or transaction events for which you are registered; 

○ regarding new opportunities relating to marketing or transaction events or our other Services; ○ to send you information about topics that may be of interest to you; ○ to communicate in relation to your VULT Account; 

○ to alert you to the latest developments and features of the Services; and ○ for other marketing, transactional, informational, or research purposes. 

● Administer, register, or enroll you in, or facilitate your participation in recreational, educational, or entertainment activities; surveys or questionnaires; promotions or sweepstakes, or any other services, events, or activities sponsored by us or third parties, or offered in connection with our Services. 

● Send you prizes, coupons, and gifts. 

● Enforce our Terms of Use and other contractual rights. 

● Protect our rights and property and the rights and property of others. 

● Comply with law. 

We process data within the United States at multiple secure data center locations and rely on legally provided mechanisms to lawfully transfer data across state borders, such as contracts incorporating data protection and sharing obligations. 

How do we protect your information? 

We are committed to protecting the security of all the personal information we collect and use. We use a variety of physical, administrative, and technical safeguards designed to help protect it from unauthorized access, use and disclosure. We have implemented standards and controls in compliance with internationally recognized security frameworks. We use encryption technologies to protect data at rest and in transit. No data transmission over the internet or any wireless network can be guaranteed to be 100% secure. As a result, while we employ commercially reasonable security measures to protect data and seek to partner with companies which do the same, we cannot guarantee the security of any information transmitted to or from our Services, website, or application, and are not responsible for the actions of any third parties that may receive any such information. We do not use vulnerability scanning and/or scanning to PCI standards. An external PCI-compliant financial institution or payment gateway handles all banking, credit/debit card, Apple Pay, and Google Pay transactions. We use regular malware scanning. Your personal information is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems and are required to keep the information confidential. In addition, all sensitive/credit information you supply is encrypted via Secure Socket Layer (“SSL”) technology. We implement extensive security measures when a Services user places an order, enters, submits, or accesses their information to maintain the safety of personal information. All transactions are processed securely through a financial institution. Our systems store consumers’ bank routing numbers and account numbers as encrypted data in our secure database. 

Service Providers

We use third parties to help us provide our Services. Various third parties will have access to your information as collected by the Services, website(s), and/or the application(s), as reasonably necessary to perform the contracted tasks on our behalf. We sign contractual agreements to obligate third parties to protect the personal information, only use it to deliver the contracted services to us, prohibit them from selling it, and not disclose it without our knowledge and permission. 

Change in Control 

We may also share your personal information as part of a sale, merger, change in control, or in preparation for any of these events. Any other entity which buys us, or part of our business will have the right to continue to use your personal information but only in the manner set out in this Policy unless you agree otherwise. 

Third Party Marketing 

In addition to the other disclosures described in this section, we may, as allowed by law, provide a copy of your information to other companies who we believe may have products and services of interest to you so that they may market to you. Such information sharing is not a current practice, but we reserve the right to do this in the future, and at such time, we will comply with any applicable legal requirement to (i) provide you with an opportunity to opt-out on the “Preference Center” page located in your VULT Account profile, or by contacting us at privacy@vultsecurity.com or (ii) take additional or alternative steps to provide you with an appropriate opportunity to control whether your data is involved. 

Miscellaneous 

We may share your information with any person or entity where we believe in good faith that such disclosure is necessary or otherwise appropriate to: (a) comply with the law or in response to a subpoena, court order, government request, or other legal process; (b) produce relevant documents or information in connection with litigation, arbitration, mediation, adjudication, government or internal investigations, or other legal or administrative proceedings; (c) protect the interests, rights, safety, or property of the Company or others; (d) enforce the Terms of Use on the Services, website, application, or other contractual obligations; (e) provide users of the Services, website, or application with the services they request; (f) provide you with special offers or promotions from us; (g) allow another company that acquires the Company or some or all of its assets to continue to serve you; or (h) operate the Company’s systems or Services properly.

With Your Consent 

We may share your information with any person or entity when we have your consent. 

Non-Personal Information 

We may use and share non-personal information about you or your use of the Services, including any de-identified or aggregated data, with third parties without limitation. 

Google 

Google’s advertising requirements can be summed up by Google’s Advertising Principles. Google’s advertising requirements are put in place to provide a positive experience for users. We have not enabled Google AdSense on our website, but we may do so in the future. https://support.google.com/adwordspolicy/answer/1316548?hl=en 

California residents 

Under the California Consumer Privacy Act (the “CCPA”), Cal. Civ. Code 1798.100, et seq., residents of the State of California may have additional privacy rights.

Collection and Use of Personal Information in the Last 12 Months (a more detailed list can be found in Section 3 of this Privacy Policy) 

In the last 12 months, we have collected the following categories of personal information from the following sources: 

● Identifiers, such as name, mailing address, email address, zip code, telephone number, or other similar identifiers that were provided to us by customers/users as part of their use of the Services. 

● California Customer Records (Cal. Civ. Code § 1798.80(e)), such as username and password, company name, job title), business email address, and (department) from customers/users who provided the information. 

● Internet/network information, such as browsing history, log and analytics data, information about the device(s) used to access the Services, and information regarding interactions with our Services, websites, applications, or platforms and other usage data automatically collected by proprietary software, cookies usage, and/or third party analytics. 

● Geolocation data, such as information about location (at the country and city level) collected from users’/customers’ IP addresses. 

● Sensory Information, the content, audio, and video recordings of conference calls between customers/users and us that we record where permitted by the customer(s)/user(s) and/or the law. 

● Profession/employment information that customer(s)/user(s) send to us when applying for a position included in a CV and cover letter. 

● Other personal information, such as personal information provided to us in relation to a survey, comment, question, request, article download, or inquiry, and any other information uploaded to our Services. 

● We collect personal information directly from you, from your browser or device when you visit our websites, from third parties that you permit to share your information, or from third parties that share public information about you, as stated above. See the section above, “How We Use Personal Information,” to understand how we use the personal information collected from California consumers, customers, and users.

Disclosure of Personal Information in the Last 12 Months 

In the last 12 months, we have disclosed the following categories of personal information for business purposes: None – not applicable, except as provided in Section 7.

Sale of Personal Information in the Last 12 Months

 In the last 12 months, we sold the following categories of personal information: None – not applicable.

Business/Commercial Purpose(s) of Selling Personal Information 

Not applicable. We have not sold any personal information in the last 12 months.

Your Rights as a California Resident

Right to Disclosure/Access/Know

 You have the right to request disclosure of, and access to, categories of specific pieces of personal information about you that we collect, use, disclose, and sell. You may be able to exercise the following rights in relation to the personal information about you that we have collected (subject to certain limitations at law): ○ The right to know any or all of the following information relating to your personal information that we have collected and disclosed in the last 12 months (upon verification of your identity): ● The specific pieces of personal information we have collected about you. ● The categories of personal information we have collected about you. ● The categories of sources of personal information. ● The categories of personal information that we have disclosed to third parties for a business purpose, and the categories of recipients to whom this information was disclosed. ● The categories of personal information we have sold and the categories of third parties to whom the information was sold. ● The business or commercial purposes for collecting or selling the personal information. 

(ii) Right to Deletion You have the right to request us to delete personal information we have collected from you, subject to certain exceptions (e.g. deletion of personal information would impede us from complying with a legal obligation, etc.). If you would like to exercise your right to request deletion of your personal information, please click here. 

(iii) Right to Opt Out of Sale of Personal Information 

Although we do not engage in the sale of personal information in exchange for monetary VULT SecurityTM – Privacy Policy Page 6

consideration, we do share personal information of our customers/users with third parties for business and/or commercial purposes. You have the right to “opt out” of the sale of your personal information to third parties. 

(iv) Right to Non-Discrimination 

You have the right not to receive discriminatory treatment for exercising your privacy rights under the CCPA.

Object to The Processing of Your Personal Information 

You have the right to object to our processing of your personal information for direct marketing purposes. This means that we will stop using your personal information for these purposes. You may have the right to ask us to limit the way that we use your personal information. You have the right to request that we export to you in a machine-readable format all the personal information we have about you. We do not process personal information using automated means. If you would like to exercise any of the rights described above, please contact us at privacy@vultsecurity.com. You also have the right to lodge a complaint with the local organizations in charge of enforcing the privacy legislation applicable in your territory.

Recipients of Personal Information 

We may share personal information with third parties in accordance with the terms of this Privacy Policy. Please note that if exercising these rights limits our ability to process personal information (such as a deletion request), we may no longer be able to provide you with our products and Services or engage with you in the same manner.

How to Exercise Your California Consumer Rights 

To exercise your right to know, your right to deletion, and/or your right to opt out, please submit a request by contacting us at privacy@vultsecurity.com. We will need to verify your identity before processing your request. In order to verify your identity, we will generally require sufficient information from you so that we can match it to the information we maintain about you in our systems and/or Services. Sometimes we may need additional personal information from you to be able to identify you. We will notify you if we require additional information. We may decline a request to exercise the right to know and/or right to deletion, particularly where we cannot verify your identity or locate your information in our systems or as permitted by law. You may choose to designate an authorized agent to make a request under the CCPA on your behalf. No information will be disclosed until the authorized agent’s authority has been reviewed and verified. Once an authorized agent has submitted a request, we may require additional information (i.e., written authorization from you) to confirm the authorized agent’s authority. If you are an employee/former employee of a VULT Security client that uses our Services, website(s), application(s), and/or other services, please consider directing your requests and/or questions directly to your employer/former employer. If you are a third party (auditor, business associate, etc.), who was given access to the VULT Security application by a VULT Security client, please consider directing your requests and/or questions directly to the VULT Security client that gave you access.

California Online Privacy protection Act (“CalOPPA”) 

According to CalOPPA, we agree to the following: ● Users can visit our website anonymously. ● Once this Privacy Policy is created, we will add a link to it on our home page or as a VULT SecurityTM – Privacy Policy Page 7