GUARDIAN CYBERSECURITY PRIVACY POLICY

Updated as of 09/20/2022

Introduction

This Guardian Cybersecurity Privacy Policy (“Policy”) describes how Sunset Coast Technologies, dba Guardian Cybersecurity, and its wholly owned subsidiaries and affiliates (collectively, “Guardian Cybersecurity,” “Guardian Cybersecurity Group”, ‘we,” or “us”) collect, use, disclose and otherwise process personal information in connection with our websites, including www.GuardianCybersecurity.com, as well as the other websites that we operate and that link to this Policy (our “Sites”). This Policy also describes how we collect, use, disclose and otherwise process personal information to market our software and other products and services (together “Services”) and to maintain and administer our business relationships and subscriptions.

Our processing of any personal information that we collect to provide our Services to our customers (“Subscribers”) or otherwise under the direction of Subscribers is governed by our agreements with our Subscribers and not by this Policy. If you are an individual who interacts with the Services in connection with your relations with a Subscriber (such as an employee of one of our Subscribers), please contact the Subscriber directly for more information, including to understand any rights and choices you may have in relation to your personal information.

Personal Information Collection

We collect the following types of personal information:

• Business contact information, such as your first and last name, professional title, business affiliation and address, email address, and phone number.
• Services account information, such as the Services you use, webinars and other events you sign up for, transactions, and business relationship information.
• Communications with us, including questions or inquiries you may send us, and any information that you create, input, submit, post, upload, transmit, store or display on our Sites.
• Information from cookies and other automated technologies, such as information about the devices you use to engage with our Sites, and online activity data. For more details about the technologies we use, the categories of information we collect, and how we use this information, please review our Cookie Policy.

Third party sources. We obtain personal information from other sources, including:

• Third parties, such as business intelligence services, event co-sponsors, and other data providers.
• Public sources, such as company websites and our pages on social media platforms.

How We Use Personal Information

We use personal information for the following purposes:

• Guardian Cybersecurity Site. When you visit our Sites, we use personal information to interact with you, provide you relevant marketing data and information, contact you about our Services, personalize or customize your experience (based on preferences or geography, for example), conduct research (such as to test the performance and layout of our Sites), and to improve the content and availability of the Sites. If you interact with any publicly accessible blogs, community forums, comments sections, discussion forums, or other interactive features on our Sites, we may display any information that you post and that information might be read, collected, and used by others who access it.
• Administering the Services. If you subscribe or are exploring a subscription to our Services, we use personal information to create and administer your account, manage our business relationship, and communicate with you about the Services, including to send you notifications and keep you informed of any updates to the Services. We also analyze trends in the purchase and use of our Services to understand our Subscribers’ needs and interests, recommend additional Services, forecast business needs, and to improve and develop our Services. We may accept payments on our Sites using a payment service provider. The information provided to the payment service provider in connection with payment and transactions is handled in accordance with the payment service provider’s terms and privacy policies.
• Newsletters, events, marketing and advertising. If you sign up to receive newsletters or other additional information from us, attend a webinar or live event, or participate in any other offering, we use the information you provide, such as your name, company name, email address and phone number, to facilitate your request and to identify business opportunities. Subject to consent where required, we also use personal information to develop and send direct marketing communications, including by email, and to make sales and marketing calls, promoting our Services, events, programs or other services that we believe are of interest to you. You can unsubscribe from our marketing communications as described in the Unsubscribe from marketing communications section below. We also use cookies and similar technologies to engage in interest-based advertising. Please review our Cookie Policy for more information.
• Testimonials. Where you permit us to share your experience with our Services, we may post testimonials on the Sites that may contain Personal Information. We obtain your consent to post your name along with your testimonial. If you wish to update or delete your testimonial, you can contact us at support@GuardianCybersecurity.com.
• Partners. If you partner with us to promote or provide the Services, including by using any online Partner portals we may offer, we use your information to maintain and administer our business relationship and to evaluate the performance of our partnership.
• Compliance and protection. We also use personal information to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities; protect our, your, or others’ rights, privacy, safety, or property (including by making and defending legal claims); audit our internal processes for compliance with legal and contractual requirements and internal policies; enforce the terms and conditions that govern our Services; and prevent, identify, investigate, and deter fraudulent, harmful, unauthorized, unethical, or illegal activity, including cyberattacks and identity theft.

We will only use your personal information as described in this section if we have a valid legal ground for the processing under applicable laws. Our legal grounds for processing include: consent, where you have consented to the use of your personal information (including, where applicable, to receive marketing communications); legitimate interests, such as to promote, develop and improve our Sites and Services, to protect our legal rights, and to establish, exercise, or defend legal claims, provided that such interests are not overridden by your interests or your fundamental rights and freedoms; and legal obligations, including to comply with tax and accounting obligations. We may also process your personal information when necessary to protect your or another individual’s vital interests.

How We Share Personal Information We share personal information with:

• Affiliates. All entities within the Guardian Cybersecurity Group, including our subsidiaries and affiliates, for purposes consistent with this Policy.
• Service providers. Companies and individuals that provide services on our behalf or help us operate our Services (such as hosting, information technology, customer support, email delivery, and website analytics services). The Guardian Cybersecurity Group contractually requires all its third-party business partners with whom it shares personal information to take commercially reasonable steps and implement policies to safeguard your personal information, and to not use your personal information for any purpose other than to assist the Guardian Cybersecurity Group in serving its Subscribers.
• Advertising vendors. Third party advertising companies, including for the interest-based advertising purposes described above, that can collect information on our Sites through cookies and other automated technologies. Please review our Cookie Policy for more information.
• Social media platforms. Our Sites also include social media features that may collect your IP address, which webpage you are visiting on our Sites, and may set a cookie to enable the feature to function properly. Your interactions with these features are governed by the privacy policy of the company providing it.
• Professional advisors. Professional advisors, such as lawyers, auditors, bankers, and insurers, in the course of the professional services that they render to us.
• Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above.
• Business transferees. Acquirers and other relevant participants in business transactions (or negotiations for such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale, or other disposition of all or any portion of the business or assets of, or equity interests in, the Guardian Cybersecurity Group (including in connection with a bankruptcy or similar proceedings). We may assign or transfer this Policy, as well as your account and related information and data, including any personal information, to any person or entity that acquires all or substantially all of our business, stock or assets, or with whom we merge.
• Although we do not sell personal information, like most websites, we use cookies and other online tracking technologies on our websites. You may limit our use of online tracking technologies as described in our Cookie Policy.

Third-Party Links

The Sites may include links to third-party sites, products or services. Please note that your access to and use of these third-party sites, products or services may result in the collection of or sharing of your information, including personal information. These third parties have separate and independent privacy policies, and we are not responsible or liable for your interactions with such third-parties (as further described in our Terms of Service). The option to link to such third-party sites, products or services is not an endorsement or representation regarding any third-party sites, products or services, and we encourage you to review and understand such third-parties privacy policies.

Security

Security is not only important to us, it is our mission. We have adopted a range of administrative, physical and technical security measures designed to protect against unauthorized access, alteration, disclosure or destruction of personal information.

International Transfer of Information Collected

Guardian Cybersecurity is a U.S.-based company which operates globally. When you interact with our Sites, you provide your personal information to us in the United States. We transfer the personal information we receive to our affiliates and third parties as described in the How We Share Personal Information section above. We operate globally and our affiliates and the third parties with which we share information are based in the United States, European Union, and in other countries around the world, some of which may not have laws that provide equivalent protections for personal information as the laws in the countries in which you reside. We implement appropriate safeguards in accordance with applicable law to protect the information we transfer, including by using European Commission approved standard contractual clauses. For more information on how we transfer and safeguard your information, please contact us at support@GuardianCybersecurity.com.

Privacy Choices

Unsubscribe from marketing communications. You can unsubscribe from marketing-related communications by following the instructions at the bottom of the emails you receive from us or by contacting us as provided in the Contact Us section below. If you do so, you will continue to receive service-related and other non-marketing communications until you cease using our Services linked to those service updates.

Privacy rights. Depending on your location, you could be entitled to submit the following requests about your personal information:

• Access. Request that we provide you with information about our processing of your personal information and give you access to your personal information.
• Deletion. Request that we delete the personal information that we maintain about you.
• Correction. Request that we update or correct inaccuracies in your personal information.
• Transfer. Request that we transfer a machine-readable copy of your personal information to you or a third party that you designate.
• Restriction. Request that we restrict the processing (including sharing) of your personal information.
• Objection. Object to our reliance on our legitimate interests as the basis of our processing of your personal information that impacts your rights.

To exercise all other choices described above, please contact us at support@GuardianCybersecurity.com. To avoid security breaches, we will need to authenticate your identity before we respond to the request and to assess whether these rights apply to you. Additionally, applicable law can limit these rights, for example, by prohibiting us from providing certain sensitive information in response to an access request and limiting the circumstances in which we must comply with a deletion request. While we endeavor to satisfy the requests we receive, if you are unsatisfied with our response, you may have the right to complain to a privacy or data protection regulator in your country.

Children’s Personal information

Our services are not intended for use by children. If you have reason to believe that a child has provided personal information to us, please contact us at support@GuardianCybersecurity.com. We will use commercially reasonable efforts to delete such personal information.

Retention

We retain personal information for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of personal information, the purposes for which we process personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

Changes to This Policy

If there are any material changes to this Policy, you will be notified by our posting of a prominent notice on our Sites prior to the change becoming effective or as otherwise required by law. We encourage you to periodically review this page for the latest information on our privacy practices. Your continued use of our Sites constitutes your agreement to be bound by such changes to this Policy.

Contact Us

If you have questions regarding this Policy or about our privacy practices, please contact us by email at support@GuardianCybersecurity.com or at:

Sunset Coast Technologies LLC, dba Guardian Cybersecurity

Attn: Data Protection Officer

P.O. Box 783, Benton Harbor, Michigan, United States

You may also send your questions or concerns regarding our privacy practices to our data protection officer by email at support@GuardianCybersecurity.com.

English Version Controls

Non-English translations of this Policy are provided for convenience only. In the event of any ambiguity or conflict between translations, the English version is authoritative and controls.