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Privacy Policy Statement

Effective Date: January 1, 2024

Paloma Technologies, LLC (“Paloma”) respects our customers’ privacy. This Privacy Policy describes the treatment of information we collect from and about you when you visit our websites or use any of our services which contain a link to this Privacy Policy or otherwise refer to or provide the URL to this Privacy Policy (collectively, the “Services”). Our Privacy Policy also applies to any information we collect or receive by email, text, or other electronic messages between you, and our websites and our company and its affiliates. It also describes other sources we use to obtain information about you; tells you how we use, share and protect your information; and what choices you have about how your information is used, including how you can contact us regarding that information.

BY CONTINUING TO USE THIS WEBSITE , YOU AGREE TO THESE TERMS AND OUR POLICY. FOR THAT REASON, YOU SHOULD CAREFULLY REVIEW THIS POLICY BEFORE PROCEEDING. IF YOU DO NOT AGREE WITH OUR POLICIES AND PRACTICES, YOUR CHOICE IS TO IMMEDIATE CEASE USING OUR WEBSITE. IN ADDITION, BECAUSE OUR POLICY MAY CHANGE FROM TIME TO TIME, YOUR CONTINUED USE OF THIS WEBSITE AFTER THOSE CHANGES WILL BE DEEMED ACCEPTANCE OF THOSE CHANGES, SO CHECK BACK PERIODICALLY FOR UPDATES.

For purposes of this Privacy Policy, “personal information” means information that relates to or can identify a specific person. This can include full name, address, telephone number, IP address, or email address. When other information, such as email newsletter choices, product inquiries, product purchases , consumer product preferences, or website usage, is associated with personal information, this other information will also be treated as personal information under this Privacy Policy.

All of our content, products and services are intended for adult audiences and are NOT directed to children. We do not knowingly permit children under age 18 to register for any content, product or Service, and we do not offer any services or products to person under the age of 18. We do not knowingly collect, use or disclose personal information about users under age 18, except as permitted by law. IF YOU ARE UNDER THE AGE OF 18, PLEASE DO NOT USE OUR WEBSITES, OR PROVIDE ANY INFORMATION TO OUR WEBSITE. If you believe your child has impermissibly provided us with his or her personal information, please contact us, so that we can identify and delete that information.

Collection of Information

Information you provide directly

If you are interested in obtaining information, products or services from Compass, participating in certain activities through the Services, or communicating with us electronically, you may need to provide us or our service providers with information about yourself.

For example:

If you register or log-in our website to obtain information, or request further information about any of our products or services, you may be asked to provide your name, email address, telephone number and other personal information.

If you register to receive a newsletter, or access us through social media, you may be asked for your name, email address, mailing address, phone number and other information.

If you order a product from us or one of our business partners, you may be asked for your name, postal address, email address, telephone number and your credit card number.

If you are ordering a product for another, you may be asked for that person’s name, postal address and phone number in order to enable us to deliver the product to the recipient.

If you send us an email, text message, or otherwise communicate with us electronically, you will have provided us personal information, including but not limited to your name, email address, and other identifying information.

If you apply for or seek information about an employment position, you may provide and we may collect certain personal data.

If you contact us by telephone, we may record certain information, including personal data such as telephone number, name, geographic location, call length, and any follow-up information. Such calls may be recorded, so that any personal data you provide during the call may also be collected.

In addition, we may collect information based on any search queries you may perform on our website, survey responses, and copies of correspondence if you contact us.

From the engineering process to the final customer training, we treat our customers like our partner because that’s the Safe and Sound Security way. When it comes to providing the best security system services for the enterprise sector, no one knows the landscape better than security. We’ve worked with national level enterprises to local businesses and everything in between.

Information we may collect automatically

In addition to information you choose to provide to us, Compass and our service providers also use standard technologies to automatically collect certain additional information. For example:

IP Address and Other Identifiers. When you access and interact with our website and our Services, we and our service providers may collect information about your visits in order to permit you to connect to and obtain the Services and so that we can better understand the frequency with which specific visitors visit various parts of our Services. For example, we may collect your Internet Protocol (“IP”) address, which identifies the computer or service provider that you use to access the Services, or information about your browser type, authentication identifiers, and other software and hardware information. If you access our website or use our the Services through a mobile or other device we may collect your mobile device identifier, geolocation data (including your precise location), or other transactional information for that device. We may combine this information with other information that we have collected to make our Services and our communications to you more targeted to your interests.

Details of Your Visits. As you navigate through and interact with our Website, we may use automatic collection technologies, that can provide us information about the details of your visits, the resources you access, searches that you perform, and information about the computer and internet connection (including IP address) that were used.

Social Media Information and Content. If you access or log into our website or one of our services through a social media service or connect to us by means of a social media service, the information we collect may also include your user ID and/or user name associated with that social media service, any information or content you have permitted the social media service to share with us, such as your profile picture, email address or friends lists, and any information you have made public in connection with that social media service. When you access our website and our Services through social media services or when you connect a Service to social media services, you are authorizing us to collect, store, and use such information and content in accordance with this Privacy Policy.

Cookies. Our Services may also use cookies. Cookies are small text files that are stored on a user’s computer and allow websites to remember information about users. We and our service providers use cookies for a variety of purposes in order to enhance the quality of our sites. We use transient (also called “session ID”) cookies to provide continuity from page to page. A session ID cookie expires when you close your browser. We also use persistent cookies. Persistent cookies allow parts of our site to recognize your browser when you return after your first visit to that part of our site and also track your activity after you have left our site, serving you marketing content on partner and affiliate sites. Cookies allow us to personalize your return visits to our site and to save you time during certain activities. You have the choice to set your browser to accept all cookies, reject all cookies, or notify you when a cookie is set. For more information, please consult the “Help” menu of your Internet browser. It is your decision whether to allow us to send you cookies. If you do not accept cookies from us, however, your ability to use some aspects of our Services may be limited.

Web beacons and other tracking technologies. The Services may use other tracking tools, including so-called “pixel tags,” “web beacons,” “web bugs,” “clear GIFs,” etc. (collectively “Web Beacons”) to collect user activity information about your activities on the Services. These are small electronic images embedded in web content (including online ads) and email messages and are ordinarily not visible to users. Like cookies, Web Beacons enable us to track pages and content accessed and viewed by users. Also, when we send HTML-formatted (as opposed to plain text) emails to you, Web Beacons may be embedded in such emails to allow us to monitor readership levels so that we can identify aggregate trends and individual usage to provide our audiences with more relevant content or offers. Web Beacons in emails may recognize activities such as when an email was opened, how many times an email was forwarded, which links in the email were clicked on, etc. Web Beacons cannot be declined when delivered via a regular web page. Web Beacons can be refused when delivered via email, but if you do not wish to receive Web Beacons via email, you will need to disable HTML images or refuse HTML (select Text only) emails via your email software.

Third-Party Content. Included on our website are links to third-party websites and content providers, including but not limited to YouTube, Facebook, LinkedIn, and others. We do not control and are not responsible for the actions and policies of any third parties, and once you click on a link for any website other than ours’s, you will be subject to the third-parties’ privacy policies, and our Privacy Policy will not apply. In the event that any such third-party websites request information from you, the use of any such information is solely the responsibility of that third-party, and we caution you to carefully review their policies prior to providing any information.

Google Analytics. In order that we may analyze how our visitors use our website, we may use Google Analytics or other similar services. As reflected by Google’s disclosures (policies.google.com/privacy and support.google.com/analytics), Google Analytics uses cookies to collect standard internet log and visitor behavior information, which may include personal information. Google uses that information to compile statistical reports. We use the information to analyze usage trends and preferences of persons who visit our site, and to help us better develop our website and market our products and services.

USE AND DISCLOSURE

Compass and our service providers may use information that we collect from and about you or a variety of business purposes, including to operate, maintain, modify and enhance the features of our website, to provide services and fulfill business obligations, and to further the evaluation and development of our products and services. These uses may include, but not be limited to:

Maintaining and managing your account, delivering content and services that you request, and enhancing your experience on our website;

Keeping track of your access, and of the services or products of interest to you and to others;

Processing and tracking your product or service orders and provide the Services and content you request;

Communicating with you about products, content or services in which you may be interested, and responding to your inquiries or comments;

Offering you branded or co-branded services, products, or features;

Furthering any existing or potential business relationship, whether with you or, as applicable, your employer;

Performing business analyses and other purposes intended to improve the quality of our business, the Services, and the products and services we offer, and to enhance the quality and contents of our website based upon usage trends and visitor preferences;

Pursuing our legitimate business and other interests, including for our own internal administrative purposes, to investigate or report actual or potential crimes, to prevent or investigate fraud, to represent our interests in any proceedings, and to maintain records of contacts and sales;

If applicable, evaluating your candidacy for employment; or in accordance with your consent.

We will use and share your personal information as described in this Privacy Policy, including:

with entities that help us to manage and provide products and the Services, including development of our websites and applications, marketing, product development, research, maintenance and support, personalization, email distribution, measurement and improvement, and fulfillment, to the extent that these entities need the information to perform their services or as required by law;

with our corporate affiliates and subsidiaries;

with identified entities whose products or services you specifically use or request to receive while you use the Services;

with our business partners, such as contractors, sales representatives, service providers and other third parties who support our business and are bound by contractual obligations to keep your information confidential; their use of your personal information will be governed by their own privacy policies;

with other third parties (for example, freight companies who need your contact details to delivery products; or billing or collection services) in the ordinary course of business in order to process your requests, inquiries, to assist with your orders offered through the Services, or to enforce our agreements or to comply with contractual obligations;

in response to legal process and when we believe that doing so is required by law, when necessary to protect any person’s property, rights, or safety, to pursue our legitimate business interests (such as to prevent fraud), to investigate or prevent a potential violation of law, to enforce any terms of use or other legal agreement, or in the event of a corporate transaction, such as a divestiture, merger, consolidation, bankruptcy or asset sale;

in accordance with your consent.

When information we collect is aggregated, anonymized or otherwise does not identify you, we may use that information for any purpose or share it with third parties, to the extent permitted by applicable law.

Except as described in this Privacy Policy, we will not share personal data with a third party unless you consent to the disclosure or the disclosure is required by law. We may use the information we collect from and about you to make inferences and predictions about your potential areas of interest, in order to make our products, content, and Services more interesting and relevant to you and to other visitors. When the information collected from or about you does not identify you as a specific person, we may use that information for any purpose or share it with third parties, to the extent permitted by applicable law.

INFORMATION AND DATA SECURITY

Your data, and this website, are hosted by an independent third-party, Web Propulsion Internet Services, Inc., and we have no control over the processes, equipment, procedures or safeguards used by this third party. You can request their Privacy Policy and General Terms and Conditions by emailing privacy@webpropulsion.com. While we do not host our website or store your data, we take a number of commercially reasonable steps to safeguard information in our possession from loss, theft and unauthorized use, disclosure or modification. Among them, to the extent we have control, we maintain appropriate administrative, physical and technical safeguards against accidental or unlawful destruction, access, or disclosure of data.

Safety and security also depend on you. Where we have given you or you have chosen a password and username to access certain parts of our website or to provide us information or communicate with us, you are responsible to keep this password confidential. You should not share your password with anyone.

It must be recognized that NO METHOD OF TRANSMITTING OR STORING ELECTRONIC DATA IS EVER COMPLETELY SECURE. As a result, we cannot and do not warrant or guarantee that the security of any information you transmit to us, over the Internet or otherwise, nor that information provided to us will never be accessed, used or released in a manner that is inconsistent with this Privacy Policy. YOUR PROVISION TO US OF ANY PERSONAL INFORMATION IS AT YOUR OWN RISK.

Personal information and data collected by us or provided to us may be stored and processed in any country where Compass or our affiliates, subsidiaries or service providers maintain facilities or servers. We also utilize Cloud-based storage and processing, and do not have control over where any data or information may be physically stored in the Cloud. Compass is headquartered in the United States, and as a result, it is expected that data, including personal information, is likely to be maintained in or transferred to the United States. Where information is transferred between countries, such transfer will be subject to a contract which ensures the production of information.

Insofar as you have given your consent for us to collect your personal information and process your data, the respective consent forms the legal basis for the processing covered by the consent. This applies to all data and personal information you provide to us, including but not limited to any consent to telephone or e-mail marketing you may have granted. You may withdraw your consent at any time with effect for the future. It is possible to unsubscribe from any email or other newsletters at any time, by sending a message to info@palomats.com.

If you have given your consent, you may withdraw this at any time with effect for the future. Insofar as we process your data, you can object to such processing. If you lodge a protest, your data will no longer be processed, unless the company responsible can furnish proof of compelling legitimate grounds for processing that outweigh your interests, rights and liberties, or insofar as processing serves the purpose of asserting, exercising or defending legal claims.

DATA RETENTION

We will retain your information and data for the period necessary to fulfill the purposes outlined in this Privacy Policy, unless longer retention is required or allowed by law. We will delete your personal data as soon as it is no longer needed for these purposes. As soon as your personal data is no longer needed for the aforementioned purposes, it will be removed from our databases and no longer be available for further use, and will be deleted at the end of the retention periods stipulated by law, unless you have expressly consented to further utilization of your data. We reserve the right to data utilization after said retention periods in any way permitted by your consent, by law and as described in this Privacy Policy.

USER ACCESS AND CONTROL

You may opt out of having your personal information used or disclosed for certain purposes.

You can opt out of receiving promotional communications from us by contacting us at: info@palomats.com.

If you no longer want to receive marketing-related emails from us on a going-forward basis, you may opt-out of receiving these emails be clicking “Unsubscribe” or “Update my Preferences” at the bottom of any marketing email you receive.

Other than the information outlined above under Collection of Information and Use and Disclosure, we do not share your information with any third-parties. As noted in those sections, you may opt-out of this collection by disabling Cookies, and by changing the privacy settings within your browser.

While you cannot establish an account through our website, you should remember that some information may remain viewable in some circumstances where, for example, you have shared information with social media or other services, or where caching technology preserves information for a period of time. We may also retain backup information related to your use of our website or information you have provided on our servers for some time for fraud detection or to comply with applicable law or our internal security policies. It is not always possible to completely remove or delete all of your information due to technical constraints, contractual, financial or legal requirements.

GENERAL DATA PROTECTION REGULATION (“GDPR”) OF THE EUROPEAN UNION

This section applies only to EU citizens accessing our websites from within the EU.

While we do not have offices, facilities, employees, or storage in the European Union, we are aware that certain visitors to our website and certain customers of Compass may be citizens of the EU accessing from within the EU. Our Privacy Policy as set forth herein provides you with the information which we believe is required by the European Union.

Who is Responsible for Data Processing Operations? As defined by basic EU data protection regulations, Paloma Technologies, LLC is responsible for the processing of your personal data. The contact information for all questions or comments regarding data protection and the use of your data is our Webmaster, who can be reached at contactus@compassmsp.com.

When Do We Acquire and Process Personal Data? As discussed more fully above, we collect information both automatically and by the user’s conduct. Please review our disclosure above for full details. We use the information in the manner disclosed above, and you can learn details by reviewing that section of this policy.

Which Data About You Can Be Collected? As disclosed in more detail above, the data to be collected can include contact data, other personal data (such as IP addresses, browser information, usage information, and others), and how you have used our website. This can include data gathered by means of cookies and other tracking technologies.

What Is The Purpose Of Processing Your Data? As disclosed in more detail above, the use of the data depends in part on what data we receive or obtain, and for what purposes. For instance, it may include providing you services, answering questions, providing customer service and care, quoting on products, sales, complying with our legal obligations, fulfilling our contractual obligations, and pursuing our legitimate interests. We also may use the data for marketing purposes, for market and product development and research, and to enhance our website and the user experience. It may also include use for employment purposes, and if you provide your data as part of a job application, your personal information will be used for the purpose of your application. We may also provide your data to third parties, in accordance with our policies described above.

How Do We Protect Your Personal Data? As disclosed above, we use commercially reasonable steps to protect data and information, including administrative, technical and physical safeguards. We again advise that there is no completely secure method of transmitting information, especially over the Internet, but we, and third parties to whom we transfer data, do our best to protect your personal data using current state of the art practices.

How Long Do We Keep Your Data? In accordance with Article 17 of the basic EU data protection regulations, we will keep your data only so long as necessary for the purposes for which we have collected and processed it, and so long as required by applicable laws and regulations. If there are multiple purposes, your data will be deleted (or stored in a manner that does not allow any use directly relating to a particular person) once the last relevant task is completed.

To Whom Do We Grant International Access To Your Data and How Do We Ensure Protection? Compass is a United States- based company, with headquarters in West Hartford, Connecticut, USA. We do not, at present, have any facilities in the EU. To the extent that you are a citizen of the EU and we receive your data, our processing and use of the data occurs in the United States, unless a third-party service provider with whom we have a contractual relationship does so within the EU at its own discretion. As noted above, we cannot ensure that when you transmit your data to us by means of the Internet, it will be secure, but we use suitable technical and organizational measures, along with contractual arrangements, for the purpose of protecting your data once it is in our possession or when it is transmitted to third-party service providers. If you would like further information about our specific security precautions taken for the transfer of data, please contact us here.

Do You Use Cookies? As discussed above, we use Cookies and other tracking technologies to enhance, monitor, understand and analyze how visitors to our websites interact with us. Cookies serve many useful purposes, including letting you navigate between pages efficiently, remembering your preferences, and improving the user experience. In some cases, they will also help focus relevant content to you, based on your interests. When you first visited our website, you agreed to our use of cookies. If you wish to opt out of the use of cookies (which may result in your no longer being able to access our website or losing some functionality of our website), you can do so by clicking here.

Rights to Information, Correction, Deletion and Objection; Rights of Revocation and to Complain

We reiterate that if you are a citizen of the European Union, you have certain rights under the GDPR, including a right, upon request, to a copy of your personal data, and rights provided under the GDPR, which can be found at https://ec.europa.eu/info/law/law-topic/data-protection/reform/rules-business-and-organisations_en. Further, in accordance with the requirements of the GDPR, we hereby advise you of the following Subject to the applicable legal prerequisites, you have the right of access (Art. 15 GDPR), rectification (Art. 16 GDPR), erasure (Art. 17 GDPR), restriction of processing (Art. 18 GDPR) and data portability (Art. 20 GDPR) with respect to Compass. You also have the right to lodge a complaint with a supervisory authority (Art. 77 GDPR). These rights include a right to a copy of the data (right to access personal data), the right to lodge a complaint with a Data Protection Authority (DPA); the right to withdraw consent (to the extent given) at any time; the right to have corrections made, deletion of, or restrictions on the processing of your data; the right to object to the processing, and to the transfer of data.

With regard to these rights, and if you have any general questions about our privacy policy or our data protection, please contact us at the following email address: info@palomats.com. While we take your reservations and right seriously, if you are of the opinion that we have not adequately dealt with your complaints or communications, you have the right to submit a complaint to the data privacy protection authorities responsible.

OTHER IMPORTANT INFORMATION

Third Party Sites

If you click on or interact with a hyperlink that you find on our websites, you may leave our website or send information to a different website or application. This may include Google, Facebook LinkedIn, MyEmma, and other third-party websites. Our Privacy Policy does not apply to your interactions with third-party websites or mobile apps, even if you find a link to them on or access them through our website. Thus, you should read the privacy policy of the third-party provider to see how your personal information will be treated on its site. We have no control over such third-parties, their Internet sites, or their products or services.

In addition, we use third-party CRM software and services, some of which may be cloud-based. While our CRM is only used internally for the purposes of lead tracking, customer service, and marketing, to the extent that any of your information may be used by such software or services it may be passed on to the website or cloud-based systems of the third-party, over which Compass has no control, and thus we cannot ensure the security of any information which is passed on to such third parties.

Visiting Our Services from Outside the United States

Please be aware that your personally identifiable information may be accessed from, transferred to, processed, and stored in any country where we have facilities or engage service providers. By using our website or providing us with any personal information through the Services, you consent to the transfer, processing and storage of your personal and non-personal information in countries outside your country of residence, including the United States, where the data protection and other laws might be different from those in your country. This includes the use of cookies and other tracking technologies as described above. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in the United States may be entitled to access your personal information. As a result, please read this Privacy Policy with care.

Changes in this Privacy Policy

We may amend this Privacy Policy at any time by posting the most recent version of the Policy on the Services, along with an indication of the date on which the Policy was amended most recently. If we make any material changes in the way we collect, use, and/or share personally identifiable information that we collect about you through the Services, that increase our rights to use personal information that we have previously collected about you, we will notify you either through an email to your registered email address or by prominent posting on our website and, where required by law, we will obtain consent from you either through email or the through our website.

CONTACT US

If you want to access and correct your personal information, or have questions or wish to send us comments about this Privacy Policy, you may do so at:

Paloma Technologies, LLC security@palomats.com