Privacy Policy

Contents

• Privacy Policy Scope
• Consent to Share Personal Information When Using Chat
• Personal Information and Sensitive Personal Information We Collect
• How We Collect Personal Information
• How We Use or Process Personal Information
• With Whom We Share Personal Information
• Notice of Right of California Residents to Opt-Out of the Selling and Sharing of Your Information
• Opt-Out Preference Signals
• Retention of Your Personal Information
• Updating, Correcting or Withdrawing Your Personal Information
• Links to Social Media and Third-Party Websites
• Information Security
• Passwords
• Our Services are Not Directed at and Not Intended to be Used for Minors Under Age 13
• Minors Under Age 16
• International Visitors
• Privacy Rights of California Residents
• Other California Privacy Rights
• Consumers With Disabilities
• Summary of Updates Made

Privacy Policy Scope

We are Alert 360 Opco, Inc. dba Alert 360 (“Alert 360,” the “Company,” or “we”). We provide home security and business security services and products (“our services”). We recognize the importance of your privacy. This Privacy Policy applies to our customers, visitors to our website, job applicants, and independent contractors. This Privacy Policy describes the personal information we collect, use, and disclose about individual consumers, applicants, and contractors who visit or interact with this website, purchase or inquire about any of our products or services, contract with us to provide services, apply for a position of employment, or otherwise interact or do business with us. By continuing to use our services, you are consenting to the practices described in this Privacy Policy. This policy does not apply to our current and former employees and their family members, dependents, and beneficiaries; if you are a California resident who is a current or former employee of the Company or a family member, dependent, or beneficiary of any of our current or former employees, you may request access to our Employee Privacy Policy by sending an email to [email protected].

Consent to Share Personal Information When Using Chat

We utilize a vendor called LiveChat (“Chat Vendor”) to process, analyze, and store the contents and transcript of the chat on our behalf. By using the Chat feature, you consent to our collection and analysis of the personal information provided (first name, last name and email address). The transcripts contained within the chat conversations are recorded. We use the personal and non-personal information we collect to better provide you with our products and services. The Chat feature utilizes a chatbot that analyzes the data and information submitted by you to respond intelligently to meet or identify your needs and answer your questions. We may also connect you with a live representative of the Company to communicate with you in the Chat. LiveChat does not sell or lease your Personal Data to any third party. LiveChat will never share, sell, rent or trade your registration and Personal Information with any marketing or promotional partners without your consent. For more information on how the Chat Vendor may use or disclose your personal information, please review their privacy policy HERE. By using these forms and features, you direct the Company to disclose to and share with the Chat Vendor any personal information you provide.

Personal Information and Sensitive Personal Information We Collect

Personal information is information that identifies, relates to, or could reasonably be linked with you or your household. We may have collected the following categories of personal information within the past twelve (12) months. For each category of information, the categories of third parties to whom we have disclosed the information in the last 12 months are referenced by a letter that coincides with the letter in the list of categories of service providers and third parties that follows soon after this table.

Of the above categories of Personal Information, the following are categories of Sensitive Personal Information the Company may collect from or about consumers, independent contractors, or applicants:

1. Personal Identifiers (social security number, driver’s license or state issued alarm licenses).
2. Account Information (your Company account log-in, in combination with any required security or access code, password, or credentials allowing access to the account).
3. Medical and Health Information (disability, medical and mental condition)
4. Geolocation Data (customers’ precise location).

Personal information does not include:

• Publicly available information from government records.
• Information that a business has a reasonable basis to believe is lawfully made available to the general public by the consumer, independent contractor, or applicant, or from widely distributed media.
• Information made available by a person to whom the consumer, independent contractor, or applicant has disclosed the information if the consumer, independent contractor, or applicant has not restricted the information to a specific audience.
• Deidentified or aggregated information.

For Business Purposes, we may disclose, your personal information to/with the following categories of service providers, contractors, or third parties:

1. Financial institutions
2. Government Agencies
3. Employee tracking and talent management systems
4. Professional employer organizations
5. Social media platforms – photos posted on social media (alert360.com; acssecurity.com, Linked-In, Facebook)
6. IT, cybersecurity, and privacy vendors and consultants
7. Security and risk management vendors
8. Original equipment manufacturers (OEM) (suppliers and makers of the products]
9. Lead providers
10. Product manufacturers/administrators
11. Support vendors for marketing, managing or hosting the website, the Chat function on the website and 3rd party monitoring stations
12. Transaction support vendors (e.g., check guaranty, payment processors)
13. Data analytics vendors

How We Collect Personal Information (Sources)

We collect information directly from you the consumer, independent contractor, or job applicant when you interact with our website and our chat feature. The transcripts contained within the chat conversations are recorded as well as any phone calls with us. We collect information from you when you purchase or inquire about any of our products or services, when you enter into a contract to perform services for us, or when you apply for a position of employment. We also collect information from you when you submit information using a form on the website. We use the personal and non-personal information we collect to better provide you with our products and services. We also collect information when you contact us by telephone and in person.

We collect information from our employees and contractors when you interact with them. We collect information about you from third parties. For example, our business partners or clients may give us information about you.

We collect information about you from other customers and visitors, when you interact with them or when they observe you and provide us with that information.

We collect information about you from lead generators and referral sources, recruiters, social media platforms, company systems, networks, software applications, and databases you log into or use.

We collect information from you passively where permitted. We may collect personal information about users over time and across different websites when you use our services. We may also have third parties that collect personal information this way. We may do this using tracking tools like browser cookies and web beacons and though services providers such as Google Analytics.

Additionally, whenever you communicate, interact, or do business with us online, or whether you are contracted to perform services for us or apply for a position of employment, we will be collecting personal information from you or about you in the course of our interaction or dealings with you.

To learn more about Google Analytics and how to opt out, please visit “How Google Uses Information From Sites or Apps That Use Our Services” at https://policies.google.com/technologies/partner-sites.

a. Cookies and Web Beacons

Cookies are small text files that are downloaded to the browser of a computer, tablet, or smartphone used to visit a website. A web beacon, also known as an internet tag, pixel tag, or clear GIF, is a tiny graphic image that may be used in our websites or emails.

Cookies and web beacons may identify your browser, help you log-in, and improve the navigation of a website. We use these features to help us improve the performance of our services. For example, cookies allow us to review the number of visitors to our website and a visitor’s usage patterns; to track key performance indicators such as pages visited, frequency of visits, downloads, and other statistical information; whether a visitor views the mobile or desktop version of our website; to recognize you if you return to our website; to store information about your past visits, and to remember your preferences.

b. Controlling Cookies and Opt-Out Preference Signals / “Do Not Track” Requests

You can control cookies and other tracking tools. Your browser may give you the ability to control cookies or other tracking tools. How you do so depends on the type of tool. Certain browsers can be set to reject browser cookies. If you block cookies on your browser, certain features of our services may not work. The choices you make are both browser and device specific. If you block or delete cookies, not all the tracking that we have described in this policy will stop.

Opt-out preference signals provide consumers with a simple and easy-to-use method by which to exercise the right to opt-out of the selling and sharing of their information. Global Privacy Controls (GPC) is a user-enabled opt-out preference signal which can communicate a user’s “Do Not Sell or Share” request on behalf of the person or device. We will process opt-out preferences from GPC signals which are in formats commonly used and recognized by businesses, such as an HTTP field header. We will treat a consumer’s use of GPCs as a valid request to opt-out of the selling and sharing of information for that browser. We currently do not connect browser use to particular consumers and, as such, you will need to use GPCs on all browsers in which you access our website and use our opt-out form to opt-out of offline sales.

Do Not Track (DNT) is a privacy preference that users can set if they do not want web services to collect information about their online activity. We do not respond to DNT signals or other mechanisms (with the exception of GPCs) that provide a choice regarding the collection of personal information about activities over time and across different websites or online services. We encourage users who have DNTs to use GPCs.

You can also control cookies and other tracking tools on your mobile devices. For example, you can turn off the GPS locator or push notifications on your phone.

How We Use or Process Personal Information

We may use or process the information that we collect for the following Business Purposes to:

1. Manage our business operations and perform our services.
2. Fulfill or meet the reasons you provided us the information, including to process your requests, transactions or payments, to prevent transactional fraud to provide customer service and to dispatch services to your secured location.
3. Maintain and service customer accounts and verify customer information.
4. To administer a contest, promotion, survey or other site feature.
5. To ask for ratings and reviews of services or products.
6. Send you information about new products and special offers.
7. Help maintain the safety, security, and integrity of our services, website, and other technical assets.
8. Improve, develop, debug, modify or support our services, website, and other similar internal purposes (including using analytics to analyze our website’s traffic and optimize its performance).
9. Respond to your inquiries, including while using Live Chat on the website, process your requests concerning your personal information in our possession, investigate and address your concerns, and to monitor and improve our responses.
10. Respond to lawful requests for information through court orders, subpoenas, warrants and other legal processes, obligations or governmental regulations.
11. JOB APPLICANT PURPOSES:
    1. Consider individuals for employment opportunities.
    2. Fulfill or meet the purpose for which you provided the information. For example, if you share your name and contact information to apply for a job with the Company, we will use that Personal Information in connection with your candidacy for employment.
    3. Comply with local, state, and federal law and regulations requiring employers to maintain certain records.
    4. Evaluate your job application and candidacy for employment.
    5. Obtain and verify background check and references.
    6. Communicate with you regarding your candidacy for employment.
12. INDEPENDENT CONTRACTOR PURPOSES:
    1. Consider individuals for contractor opportunities.
    2. Fulfill or meet the purpose for which you provided the information.
    3. Comply with state and federal law and regulations requiring businesses to maintain certain records (accident or safety records, licenses and or certifications and tax records/1099 forms).
    4. Engage the services of independent contractors and compensate them for services.
    5. Evaluate, make, and communicate decisions regarding an independent contractor, including decisions to hire and/or terminate.
    6. Grant independent contractors’ access to secure Company facilities, systems, networks, computers, and equipment, and maintain information on who accessed such facilities, systems, networks, computers, and equipment, and what they did therein or thereon.
    7. Implement, monitor, and manage electronic security measures on independent contractor devices that are used to access Company networks and systems.
    8. Evaluate, assess, and manage the Company’s business relationship with vendors, service providers, and contractors that provide services to the Company.
    9. Improve user experience on Company computers, networks, devices, software applications or systems, and to debug, identify, and repair errors that impair existing intended functionality of our systems.

We may disclose your personal information for all the above-listed Business Purposes.

We disclose personal information to third parties who perform services on our behalf. We may disclose personal information to service providers who help us operate, test, and improve our services. For example, your personal information may be stored on our behalf on third-party cloud providers including but not limited to Alarm.com, Amazon Web Services, Microsoft Azure, Rapid Response Monitoring Services, Salesforce and WP Engine.

We also disclose personal information to payment processing vendors to fulfill or meet the reasons you provided us the information, including to process your requests, transactions, or payments, to prevent transaction fraud, and to provide customer service. For example, we disclose personal information to Alarm.com, DocuSign, MAS and Sedona to process your transactions and to provide services to you.

We also disclose information if we think we have to in order to comply with a legal investigation or to protect ourselves. For example, we may disclose information to respond to a court order or subpoena. We may share it if a government agency or investigatory body requests. We may share information when we are investigating potential fraud.

We also may disclose information to any successor to all or part of our business. For example, if part of our business was sold, personal information of consumers, contractors and applicants may be one of the business assets transferred as part of the transaction. If substantially all our assets are acquired, personal information of consumers, contractors and applicants may be transferred as part of the acquisition.

We do not sell personal information and do not intend to sell personal information in the future in exchange for monetary consideration.

With Whom We Disclose Personal Information for Business Purposes

We share personal information with third parties for Business Purposes.

First, we use Google Analytics, which is a web analytics service offered by Google (a Service Provider) that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our website. This data may be shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.

Second, we disclose information with business partners. We may share information with third parties to assist in performing services on behalf of the business, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of the business.

Notice of Right of California Residents to Opt-Out of the Selling and Sharing of Your Information

Opt-Out Preference Signals

Opt-out preference signals provide consumers with a simple and easy-to-use method by which to exercise the right to opt-out of the selling and sharing of their information. Global Privacy Controls (GPC) is a user-enabled opt-out preference signal which can communicate a user’s “Do Not Sell or Share” request on behalf of the person or device. We will process opt-out preferences from GPC signals which are in formats commonly used and recognized by businesses, such as an HTTP field header. We will treat a consumer’s use of GPCs as a valid request to opt-out of the selling and sharing of information for that browser. We currently do not connect browser use to particular consumers and, as such, you will need to use GPCs on all browsers in which you access our website and use our opt-out form to opt-out of offline sales.

Do Not Track (DNT) is a privacy preference that users can set if they do not want web services to collect information about their online activity. We do not respond to DNT signals or other mechanisms (with the exception of GPCs) that provide a choice regarding the collection of personal information about activities over time and across different websites or online services. We encourage users who have DNTs to use GPCs.

We do not and will not use or disclose your sensitive personal information for Business Purposes other than the following:

1. To perform the services reasonably expected by an average employee or consumer who requests those services.
2. To detect security incidents that compromise the availability, authenticity, integrity, and confidentiality of stored or transmitted personal information.
3. To resist malicious, deceptive, fraudulent, or illegal actions directed at the business and to prosecute those responsible for those actions.
4. To ensure the physical safety of natural persons.
5. For short-term, transient use.
6. To perform services on behalf of the Company.
7. To verify or maintain the quality or safety of a product, service or device that is owned, manufactured, manufactured for, or controlled by the Company, and to improve, upgrade, or enhance the service or device that is owned, manufactured by, manufactured for, or controlled by the Company.
8. For purposes that do not involve inferring characteristics about the consumers, contractors, and applicants.

Retention of Your Personal Information

We will retain each category of personal information in accordance with our established data retention schedule as indicated above. In deciding how long to retain each category of personal information that we collect, we consider many criteria, including, but not limited to: the Business Purposes for which the Personal Information was collected; relevant federal, state and local recordkeeping laws; applicable statutes of limitations for claims to which the information may be relevant; and legal preservation of evidence obligations.

We apply our data retention procedures on an annual basis to determine if the Business Purposes for collecting the personal information, and legal reasons for retaining the personal information, have both expired. If so, we will purge the information in a secure manner.

Updating, Correcting or Withdrawing Your Personal Information

It is important that the personal information we have about you is accurate. If any of the personal information you provide us should ever change, for instance if you change your email address or phone number, or should you wish to change your preferences, to stop receiving announcements from us, to correct any inaccurate personal information about you, or to delete any personal information that you provided through your use of our services, please let us know by either following this link, or by sending an email to [email protected].

For security reasons, we may need to request specific information from you to help us confirm your identity, before we correct, update or delete any personal information you provide us.

Links to Social Media and Third-Party Websites

Our services may include links to social media, and third-party websites. These third parties have their own privacy policies and terms of use and are not controlled by this Privacy Policy. You should carefully review any terms, conditions, and policies of such third parties before visiting their websites or supplying them with any personal information. If you follow a link to any third-party site, any information you provide that site will be governed by its own terms of use and privacy policy and not this Privacy Policy.

We are not responsible for the privacy or security of any information you provide to a third-party website, or the information practices used by any third parties, including links to any third-party site from our website. We make no representations, express or implied, concerning the accuracy, privacy, safety, security, or the information practices of any third parties. The inclusion of a link to a third-party site on our services does not constitute any type of endorsement of the linked site by us. We are not responsible for any loss or damage you may sustain resulting from your use of any third-party website or any information you share with a third party.

Information Security

We have implemented appropriate physical, administrative, technical, and organizational security measures, including encryption, to protect your personal information from inadvertent or unauthorized access, use, disclosure, alteration, or destruction. No method of data storage or data transmission over the Internet, however, is guaranteed to be completely secure. Your use of our services, and any personal information that you transmit over the Internet to us, is at your own risk.

Passwords

The personal data record created through your registration with our website can only be accessed with the unique password associated with that record. To protect the integrity of the information contained in this record, you should not disclose or otherwise reveal your password to third parties.

Our Services Are Not Directed at and Not Intended to be Used by Minors Under Age 13.

We do not knowingly collect, sell, or share personally identifiable information from children under 13 without permission from a parent or guardian. No visitor to our services who is a minor or under the age of 13 should provide any personal information to us. If you are a minor under the age of 13, do not use our services and do not send any type of personal information about yourself to us.

If you are a parent or legal guardian and think your child under age 13 has given us information, email us at [email protected]. You can also write to us at the address listed at the end of this policy. Please mark your inquiries “COPPA Information Request.”

Because we do not sell personal information, we do not sell the personal information of consumers regardless of whether they are age 15 or 51.

Minors Under Age 16

We do not knowingly sell or share the personal information of consumers under 16 years of age.

International Visitors

We do not target, market to, or offer our products or services to consumers outside of the United States. You agree not to submit your personally identifiable information through the website if you reside outside the United States.

Privacy Rights of California Residents

The California Consumer Privacy Act (“CCPA”) grants residents of the State of California certain privacy rights in their personal information. This section of the Privacy Policy applies only to California residents who are natural persons; it does not apply to any entities (whether business, non-profit or governmental).

If you are a California resident, you have the following rights:

a. Your Right to Access

You have the right to request, up to 2 times in a 12-month period, that we disclose to you, free of charge, the specific pieces of personal information we have collected about you going back to January 1, 2022, unless doing so would be impossible or involve disproportionate effort, or unless you request a specific time period.

b. Your Right to Know

You may request, up to 2 times in a 12-month period, that we disclose to you what personal information we have collected, used, shared, or sold about you, and why we collected, used, shared, or sold that information. Specifically, you may request that we disclose:

• The categories of personal information we have collected about you going back to January 1, 2022, unless doing so would be impossible or involve disproportionate effort, or unless you request a specific time period.
• The categories of sources from which we collected personal information.
• The business or commercial purposes for which we collected, sold, or shared personal information.
• The categories of third parties with whom we share or have shared personal information.
• The categories of personal information that we have sold or shared about you and the categories of third parties to whom the personal information was sold or shared, by category or categories of personal information for each category of third parties to whom the personal information was sold or shared.
• The categories of personal information that we have disclosed about you for a business purpose and the categories of persons to whom it was disclosed for a business purpose.

c. Limitation of Use

You have the right to request that we limit the use of your personal information to that use which is necessary to perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services.

d. Your Right to Delete

You may request that we delete personal information we collected from you and to tell our service providers to do the same. However, there are many exceptions that allow us to keep your personal information. For example, we may deny your request to delete for the following reasons:

• To comply with a legal obligation.
• To complete the transaction for which the information was collected, provide a good or service you requested, perform a contract with you, to fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or take actions reasonably anticipated in the context of our ongoing business relationship with you.
• To detect security incidents, protect against deceptive, malicious, fraudulent, or illegal activity, or to prosecute those responsible for that activity.
• To debug products, services, or applications and to identify and repair errors that impair existing functionality.
• To exercise free speech, to ensure the rights of others to exercise their free speech rights, or to exercise another right provided by law.
• To comply with the California Electronic Communications Privacy Act (Cal. Penal Code 1546 et. seq.).
• To enable solely internal uses that are reasonably aligned with consumer expectations based upon your relationship with us.
• To make other internal and lawful uses of the information that are compatible with the context in which you provided the information.
• If the personal information is certain medical information, consumer credit reporting information, or other types of information are exempt from the CCPA.

e. Your Right to Correct

You have the right to request that we correct inaccurate personal information (to the extent such an inaccuracy exists) that we maintain about you.

f. Your Right to Opt-Out

You have the right to opt-out of the selling or sharing of your personal information to third parties.

g. Authorized Agent

You have the right to designate an authorized agent to submit one of the above requests on your behalf. See below for how you can designate an authorized agent.

h. Non-Discrimination

You have the right to not be discriminated against if you exercise CCPA privacy rights. We will not discriminate against you for exercising any of your CCPA rights. This means, for instance, that we will not deny you services, charge you a different price, including a discount or other benefit or impose a penalty for the exercise of your CCPA rights.

i. How To Exercise Your Privacy Rights

You can exercise these rights in several ways

• You can use this Web Form.
• You can make a request by calling 888-642-4567 toll free
• You can submit a request via email to [email protected].
• You can send a request by mailing it to 2448 81st St. Suite 4300, Tulsa, OK 74137, to the attention of Cheri Fletcher, General Counsel.

You may make the request on your own behalf or on behalf of your minor child. Another person who is legally authorized to act on your behalf may also submit a request for you. Please describe your request in sufficient detail to allow us to understand the nature of the request, evaluate and respond to it. Please provide sufficient information with your request to allow us to verify that you are the person about whom we collected personal information, or an authorized representative of that person.

We will promptly acknowledge receipt of your request and begin our verification process.

j. How We Will Verify and Respond

Before we respond to any request involving personal information, the CCPA requires that we confirm the identity of the person making the request, and if the request is made on behalf of another person, their authority to make the request on the other person’s behalf. We are not obligated to provide or to delete any information pursuant to your request if we are unable to adequately verify your identity or the identity of the person making the request on your behalf.

Accordingly, we reserve the right to deny any request where we are unable to satisfactorily confirm your identity. If you have authorized agent to make a request on your behalf, we reserve the right to deny the request if we are unable to adequately verify the identity of that person or if we are unable to verify that the individual making the request is authorized to act on your behalf.

We will attempt to verify your identity by matching any information provided in your request against the personal information already in our possession. If you have an authorized agent to make a request on your behalf, we will attempt to verify the identity of that person. We will also seek to confirm that you have authorized that person to submit a request on your behalf, which may include requesting a copy of any written authorization or power of attorney for the request. This process does not require that you establish any type of account with us or sign up to receive any of our services.

The amount of information we may require in our verification process will depend on a variety of factors, including the nature of your request, the type, sensitivity, and value of the personal information in our possession, the potential risk of harm that could result from any unauthorized access to or deletion of your personal information, the likelihood that fraudulent or malicious actors would seek your information, and whether the information provided to us in your request is sufficient to protect against fraudulent requests or being fabricated or spoofed. For instance, we will require more points of confirmation if you request that we disclose specific pieces of information rather than categories of information in our possession. Concerning a request to delete information, once we confirm your identity, we will separately confirm that you want the information deleted.

During our verification process, we may request additional information from you. Any information provided to us during our verification process will only be used for purposes of verifying your identity or the identity and/or authority of the person making the request.

We will endeavor to respond within forty-five (45) days of receipt of your request. If, however, we are unable to respond within that time, we will notify you of the reason and the additional time needed to make our response. The CCPA permits us to extend the time of our response by up to an additional forty-five (45) days.

If we deny a request in whole or in part, we will endeavor to explain the reasons for our denial.

l. Responding to Your Request to Opt-Out of the Selling or Sharing of Your Personal Information

We will act upon a verifiable consumer request to opt-out within fifteen (15) days of its receipt. We will notify all third parties to whom we have sold or shared personal information of your request and instruct them to comply with the request within the same time frame. We will notify you when this has been completed by mail or electronically, at your option.

A request to opt-out need not be a verifiable consumer request. However, we may deny a request to opt-out if we have a good faith, reasonable, and documented belief that a request to opt-out is fraudulent. If we deny your request to opt-out, we shall inform you of our decision not to comply and provide an explanation as to why we believe the request is fraudulent.

Other California Privacy Rights

The California Civil Code permits California Residents with whom we have an established business relationship to request that we provide you with a list of certain categories of personal information that we have disclosed to third parties for their direct marketing purposes during the preceding calendar year. To make such a request, please send an email to [email protected], or write to us at the address listed below. Please mention that you are making a “California Shine the Light” inquiry.

Consumers With Disabilities

This policy is in a form that is accessible to consumers with disabilities.

Contact

If you have any questions about this Privacy Policy or want to correct or update your information, please email us at [email protected].

You can also write to us at:

Alert 360
Attention: Cheri Fletcher
2448 E. 81st St. Suite 4300
Tulsa, OK 74137

Updates to Our Privacy Policy

We may amend this Privacy Policy from time to time by posting a revised version and updating the effective date above. Material updates to our Privacy Policy will be posted in the chart below. We may send an email to all known current users of our services when we make material updates to our Privacy Policy.

Summary of Updates Made