Privacy Policy

VALLATION’S PRIVACY AND SECURITY STATEMENT

Vallation Inc. and our subsidiaries (“Vallation,” “our,” “us,” or “we”) deliver our services, in part, by gathering information about our customers (“Personal Data”).

When you use our services and interact with us, you trust us with your Personal Data. We want to keep that trust by being transparent about our privacy practices – including how and why we (“process”) – collect, use, store, manipulate, disclose, transfer and share your personal data. We also want you to understand the choices you have for your Personal Data under various privacy regulations around the world.

We encourage you to contact us (see “How to Contact Us” below) if you have any questions or concerns. If you have a disability and need this policy provided to you in a different format. Please email privacy@vallationsystems.com or call customer support at +1 (833) 247-3747.

1. SCOPE OF THIS PRIVACY POLICY
We respect your privacy and are committed to protecting it through our compliance with this Privacy Notice. This Privacy Notice covers our global privacy and information practices and applies to our websites, services, applications, physical facilities, and related services. Please remember that our Terms of Use may also govern your use of our products or services.

This Privacy Notice does not apply to information collected on any third-party site or application (including advertising) that may link to or be accessible from our websites. We are not responsible for the privacy policies or data collection, use and disclosure practices of those sites. We encourage you to review the privacy policies of each site you visit.

Please read this Privacy Notice carefully to understand our policies and practices regarding your information and how we will treat it. By accessing or using any of our websites or services (including email communications), you agree to this Privacy and Security Statement. This Statement may change from time to time, and these changes may affect how we use the information described below, so please check the Privacy and Security Statement periodically for updates.

2. YOUR RIGHTS AND PREFERENCES

Privacy and data protection laws in different countries and regions around the world give individuals certain rights in relation to their Personal Data. We conduct our privacy practices according to this global Privacy Policy and the relevant laws of the countries or regions in which we interact with you. Vallation encourages you to Contact Us to learn more about your privacy rights and how we collect and use your personal data.

3. TYPES OF INFORMATION WE COLLECT.

We collect several types of information that relates to you and your interactions with Vallation.

A. Personal Data You Provide

- When you interact with us, for example through our website, we may collect Personal Data such as your name, gender, birthdate, government identification number, shipping/billing address, employer, email address, phone number, records and copies of your correspondence with us, device IDs, username and password. For security purposes, we may also collect personal information from you if you visit one of our offices.
- Providing us with some Personal Data may be required in order for you to interact with us or to use our products and services.
- You may be invited to provide additional Personal Data to personalize your interactions with us and your use of our products and services.
- If you work at Vallation, or are applying to work at Vallation, Personal Data will be required in order for you to apply for, be considered for, and maintain employment with Vallation.

B. Mobile Application Data

If you download or use our desktop or mobile application(s), we may collect, either through your mobile device or the application itself, your email address, your username, your mobile device identifier, hardware model, operating system version or mobile network information (as well as any additional registration data you provide to us). We may collect geolocation information and language preferences, which may be used for operational and product or service-related purposes, such as to customize information based on your location. We may also collect data related to your interaction with our mobile applications, crash data, performance data and other diagnostic data.

C. Personal Data from Third Parties

- If you interact with Vallation through a third party, we may receive Personal Data from that third party when you have consented for them to share it with us.
- We may use third party services to supplement, validate, or increase the accuracy of Personal Data that you give to Vallation.
- The Personal Data that you share with third parties is not controlled by Vallation or covered by our privacy practices. We encourage you to review third party policies and privacy settings so that you understand how the Personal Data you share them may be used or shared with others.

D. Automatic Functional Information

We may automatically collect some usage information when you interact with us. For instance, we use cookies and other tracking technologies to automatically collect technical information, such as URL, cookie data, location data, logs and other communication data, IP address, device type, unique device IDs, device attributes, network connection type (e.g., WiFi, 3G, LTE, Bluetooth) and provider, network and device performance, browser type, language, operating system, and products services information.

E. Derived Information

Vallation may use information we have about you to draw inferences and we may then use those inferences to gain a more complete understanding of your preferences. We use preference data in order to offer you potential choices, make recommendations, or to alert you to products or services that may be of interest to you.

F. Children’s information

Vallation’s products and services are intended for and directed to adults, not children. If you are under 16, do not supply any Personal Data to any Vallation website for the purposes of purchasing or using a product or service. If you wish to purchase a Vallation product or use our services, please ask your parent or guardian to handle these transactions for you. If you are aware that we have unintentionally collected information from someone who is underage, please notify us immediately by sending an email to privacy@vallationsystems.com.

G. Email marketing.

As a current or previous customer or user of our products or services, you may periodically receive emails from us containing details about features of the products you use and/or about similar products or services that we offer. Such processing may include the placing of beacons, or pixels, which let us know if you have opened our email and how long the email was open. We do this in order to see which emails are effective and which are not, so that we can improve our content and services. It helps us make sure that you are getting emails from us that you find useful and relevant. In doing so, we will never track your location or device information.

4. HOW WE USE YOUR INFORMATION

Unless we specifically disclose otherwise, you understand that we may use any of your collected Personal Data for any of the purposes described in this Policy (as permitted by applicable law), including:

A. For Account Registration and Servicing

- We may use your Personal Data to create, maintain, supplement, service, change, or delete your customer account with us.
- If you have a customer account with us, we may collect certain Personal Data for security purposes in order to verify your authorized access to your accounts with us.
- We may use your Personal Data to resolve customer service questions you may have about our products and services to follow up with you about your experience.

B. To Communicate with You.

- We may use your Personal Data to communicate with you about our products and services and to share offers for third party products and services that we think you may find useful.

C. To Improve and Develop New Products and Services.

- We may use your Personal Data to personalize your interactions and experiences with us.
- We may use your Personal Data to improve the quality of and to develop new products and services.
- We may use any information you give to us in surveys or other forms of feedback.
- We may combine your information with that from other customers in order to better understand our products and services and how we may improve them.

D. To Provide Our Products and Services and Operate Our Business.

- We may use your information to operate our business, including fulfilling your requests, providing you with technical or customer support, and to help us protect our products and services, including to combat fraud and protect your information.
- We may conduct research using your information alone or in combination with that of other customers. When we share that research outside of Vallation for research, academic, marketing and/or promotional purposes, we do so in an aggregated or de-identified way such that no individual person or household is identifiable.

A. Third Party Service Providers

With your permission or at your direction, we may disclose, share, or sell your Personal Data with third party service providers who we contract with to help us provide our products and services and operate our business. For example, your personal data may be shared when you authorize a third-party application to access your account. We share Personal Data to fulfill your requests, provide you with technical or customer support, and to help us protect our products and services, including to combat fraud and to protect your information.

B. Following the Law and Protecting Vallation

We may share your information with courts, law enforcement or regulatory agencies, or other government bodies when we have a good faith belief we are required or permitted to do so by applicable law, regulation, or legal process. We may also disclose your information if we believe it is appropriate to enforce our Terms of Use.

C. Credit Reporting

We may share information about your creditworthiness with credit bureaus, consumer reporting agencies, and card associations. Late payments, missed payments, or other defaults on your account may be reflected in your credit report and consumer report. We may also share your information with other companies, lawyers, credit bureaus, agents, government agencies, and card associations in connection with issues related to fraud, credit, or debt collection.

D. Sale of Our Business

If we sell, merge, or transfer any part of our business, information about you may be shared, sold or transferred as part of that transaction. We may also share your information with current or future corporate parents, subsidiaries or affiliates.

E. De-Identified or Aggregated Data

We may de-identify or aggregate your information, alone or in combination with other individuals’ information, and share such de-identified or aggregated information freely.

F. With Your Consent

Other than as set out above, we may also share your Personal Data and your information for other purposes with your consent or at your direction.

G. Sale of Information

Other than as set out as above, we do not rent or sell your personal information to anyone.

6. DATA TRANSFERS AND PRIVACY SHIELD

Where permitted by applicable law, we may transfer, process or store your Personal Data in any country or region where we have facilities, business operations, or in which we engage service providers. By using our site or our products and services, you consent to the transfer of your Personal Data to, and the processing and storage of your Personal Data in, countries outside of your country of residence or the point of collection.

Some countries may have data protection laws that are different from the laws of your country. However, Vallation has taken appropriate safeguards to require that your Personal Data remains protected when it is being transferred, processed, and stored.

Please Contact Us to learn more about your rights with respect to data transfers and to request access to, limit the use of, or limit the disclosure of, your Personal Data. If you make a request that involves Personal Data, you will need to provide certain authentication and verification information in order for us to respond to your request.

7. Connecting With Third Parties

In your interactions with us, it may be necessary for us to sync, link, or connect your information with third parties, including providing Personal Data necessary to identify or authenticate your requested interactions. Your consent for these interactions will be required by us, by the third party, or by both. We encourage you to review the privacy practices of any third party that you choose to share your Personal Data with, as we are not responsible for the privacy practices of third parties.

8. MANAGING YOUR DATA AND PRIVACY

A. Managing Marketing Communications From Us.
We will honor your choices when it comes to receiving marketing communications from us. If you have received marketing communications from us that you no longer wish to receive, you may:

- Contact Us to adjust your preferences regarding your Personal Data and your interactions with us.
- Click the “unsubscribe” link in the email or newsletter you received.
- If you are receiving push notifications from us to your mobile device and no longer wish to receive these types of communications, you may turn them off at the device level.
- Remember that even if you choose not to receive marketing communications from us, we may continue to send you mandatory service or transactional communications.
- If you do not have an account, and you wish to adjust your preferences regarding your Personal Data and your interactions with us, you may Contact Us.

B. Updating your Personal Data.
You may access, update, change, correct, or request deletion of your Personal Data by adjusting your account settings, or by contacting Vallation’s customer support.

C. Cookies and Similar Tracking Technologies
We may use and allow others to use cookies, web beacons, pixels, local shared objects, device identifiers, and other similar technologies (“Cookies”) to collect information about you. We use this information to improve your experiences when you interact with us. You have control over some of the data we collect from Cookies and how we use it. For details about these technologies and the information that they collect, use or share, including how you may be able to control or disable these applications, please visit the following websites:

- Criteo
- Digital Advertising Alliance
- Network Advertising Initiative
- Interactive Advertising Bureau (IAB) Europe
- Google Privacy and Terms
- Adobe Privacy

Please note that even if you elect not to enable Cookies or interest-based advertising, you may still receive advertisements, they just won’t be tailored to your interests. Also, if you elect to receive Cookies and later delete your Cookies, use a different browser or buy a new computer, you may need to renew your choices.

D. Do Not Track.
Like most other companies, we are not currently configured to respond to browser “Do Not Track” signals because, at this time, no formal “Do Not Track” standard has been adopted.

9. Data Retention and your access rights

A. Vallation retains and uses your information in accordance with and as permitted by applicable law and regulations:

- We will retain your information as long as necessary to serve you, to maintain your account for as long as your account is active, or as otherwise needed to operate our business.
- When you close your account, we may continue to communicate with you about our products and services, give you important business updates that may affect you, and let you know about products and services that may interest you, unless you have elected to not receive marketing communications from us.
- We may also continue to use some of your information for business purposes and to improve our offerings or in some cases to develop new ones.
- We will retain and use your information as required by applicable regulations and Vallation’s records and information management policies to comply with our legal and reporting obligations, resolve disputes, enforce our agreements, complete any outstanding transactions and for the detection and prevention of fraud.

B. Responses from Vallation
We respond to all requests from individuals regarding the exercise of their data protection rights in accordance with applicable data protection laws. Your data protection rights may vary depending on the country or region in which you are located, but generally include:

- Accessing, correcting, updating, or requesting deletion of your information;
- Objecting to or asking us to restrict the processing of your information;
- Requesting the portability of your information and providing the same in a timely manner and at no charge;
- Electing whether or not to receive marketing communications from us; and
- Withdrawing your consent at any time for us to collect, process, store, or share your information (noting that such withdrawal will not affect the lawfulness of any processing that we conducted prior to your withdrawal, nor will it affect otherwise lawful processing or storage).

C. Data Controller
Vallation is considered to be a “controller” of your information under data privacy regulations. Other entities may also act as controllers of your information, and you should contact them if you have any questions about how they use your information.

10. SECURITY OF YOUR INFORMATION

Keeping your Personal Data safe is important to us. At Vallation we:

- Constantly work to update our security practices to implement accepted best methods to protect your Personal Data and review our security procedures carefully.
- Comply with applicable laws and security standards.
- Securely transmit your sensitive Personal Data.
- Train applicable employees and contractors on data privacy and require them to safeguard your data.
- Transmit, store, protect, and access all cardholder information in compliance with the Payment Card Industry’s Data Security Standards.

11. ADDITIONAL COUNTRY/REGIONAL CONSIDERATIONS

Vallation has adopted a global view on privacy with the intent to provide our customers with strong privacy rights regardless of where they reside. We have attempted to recognize and implement high standards for privacy rights compliance on a global scale and use of terminology in the Privacy Notice should be interpreted to reflect that intent.
You can find additional privacy terms that may be relevant to your specific country or region below.
• United States (US)
• Canada

12. CHANGES TO OUR PRIVACY NOTICE

From time to time, we may change or update this Privacy Notice. We reserve the right to make changes or updates at any time and without prior notice to you.

If we make material changes to the way we process your Personal Data, we will provide you notice by posting the most current version of this Privacy Notice on our websites and we may also advise you of changes via our products and services information, or by other communication channels, such as by email, newsletters, or community post. Please review any changes carefully.

If you object to any changes and no longer wish to use our products and services, you may close your accounts and cease use of our products and services. All changes to our Privacy Notice are effective immediately upon posting and your continued interaction with us or your use of our products and services after a posting of an updated Privacy Notice shall constitute your consent to all changes.

13. HOW TO CONTACT US

If you have questions or comments about this Privacy Notice, you may contact us by email, telephone, or direct mail.

A. Via Email: privacy@vallationsystems.com
B. Via Telephone: +1 (833) 247-3747
C. Via Direct Mail: Vallation, Inc.
412 N. Main St., STE 100
Buffalo, WY 82834
Attn: Legal Department

United States (US) – California Privacy Considerations:
In addition to the terms of our global Privacy Notice, Vallation wants Individuals with whom it interacts that are located in the State of California to understand the following additional privacy and data protection measures which may be applicable (“California Privacy Terms”) and apply to the processing by Vallation of personal information related to identified or identifiable individuals and households located in the State of California.

We include this additional information to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and any terms defined in the CCPA have the same meaning when used in this section. These California Privacy Terms do not apply to personal information that is exempt from the CCPA. The Vallation entity responsible for the processing of your Personal Information will depend on the unique circumstances of your interactions with us.

Collection, Use, and Disclosure of California Personal Information:
During the 12 months leading up to the effective date of this Privacy Notice, we have not “sold” (as the term is defined under the CCPA), what the CCPA calls “Identifiers” (like IP Addresses), “internet or other electronic network activity information” (like an individual’s browsing activity on a webpage), and “commercial information” (website visitation information related to individuals considering purchasing our products) to third parties. To our knowledge, we do not collect and do not “sell” the personal information of individuals under the age of 16.

CCPA Right to Opt-Out of Sale of Personal Information:
We allow you to opt out of sharing and selling your data. We allow you to change these setting in the following ways:

By Contacting Us

CCPA Right to Access or Delete Personal Information:
If you are a California resident, California law may also permit you to request that we:

Provide you with a list of the categories of personal information we have collected or disclosed about you in the last 12 months; the categories of the sources of the personal information; and the categories of the third parties with whom we share that personal information.
Provide access to and/or a copy of personal information that we hold about you
Delete certain personal information that we hold about you, unless Vallation is legally required to retain it.
Correct inaccuracies in your personal data, or complete incomplete data.
To exercise a request regarding your California privacy rights, please Contact Us.
As we will need to verify your identity to fulfill these requests, please either call customer support to verify this information over the phone, or send an email to privacy@vallationsystems.com and we will attempt to verify your identity via encrypted email.
We will respond to properly submitted and verified requests for disclosure, access and deletion within 45 days, but it may take up to 90 days in some cases.
You will receive a confirmation by email of either the completion of your request or a return response with your requested data. If we are unable to verify your identity, we will not be able to process access or deletion requests.

Requests Made by Agents

If you are unable to make a request directly (or in the case of death of the customer) you may legally designate an agent by providing a notarized authorization, power of attorney or other legally binding designation of assignment of rights. Please provide proof of this agency along with your request and we will process your request as quickly as possible.

Contacting Us in the U.S. – California.

Email is the fastest and most preferred way to reach us with your data management or privacy related questions and concerns. You may contact us via email at privacy@vallationsystems.com. You may also contact us via direct mail at:

Vallation Systems Inc.
Attn: Legal – Privacy
412 Main St.
Ste. 100
Buffalo, WY 82834
You may also contact us via telephone at: +1 (833) 247-3747

Canada Privacy Considerations:
In addition to the terms of our global Privacy Notice, Vallation wants individuals with whom it interacts that are located in Canada to understand the following additional privacy and data protection measures which may be applicable (“Canada Privacy Terms”) and apply to the processing by Vallation of personal information related to identified or identifiable individuals and households located in Canada.

We include this additional information to comply with The Personal Information Protection and Electronic Documents Act (PIPEDA) and any terms defined in the PIPEDA have the same meaning when used in this section. These Canada Privacy Terms do not apply to personal information that is exempt from the PIPEDA and other substantially similar Canadian privacy laws.

The Vallation entity responsible for the processing of your personal information will depend on the unique circumstances of your interactions with us.

Your Rights:

If you are a resident of Canada, Canadian law may permit you to request to:

Access and update your information: You have the right to review and amend any personal information stored in our system.

We will provide you with copies of your personal information that is in our possession, subject to certain exceptions, including data that is referenced to another individual’s personal information that we cannot sever, or information subject to solicitor-client privilege, or other legal restrictions that may prevent us from fulfilling your access request.

Request cancellation: You have the right at any time to withdraw your consent to the use of your personal information in the future.

Exercising your Rights: To exercise your rights, please Contact Us.

As we will need to verify your identity to fulfill these requests, please either call customer support to verify this information over the phone, or send an email to privacy@vallationsystems.com and we will attempt to verify your identity via encrypted email.
• We will respond to properly submitted and verified requests for disclosure, access and deletion within 30 days, but it may take longer in some cases.
• You will receive a confirmation by email of either the completion of your request or a return response with your requested data. If we are unable to verify your identity, we will not be able to process access or deletion requests.
Opt-out of internet-based advertising: If you no longer wish to participate in the services offered through these solutions, you can opt-out of this activity by visiting the following websites:
• Network Advertising Initiative at http://www.networkadvertising.org/choices/
• Digital Advertising Association of Canada at http://youradchoices.ca/choices/
If you opt-out, please note you may still receive ads from Vallation, but they are not part of targeted advertising.

Opt-out of promotional communications: In the event you wish to unsubscribe from receiving promotional communications from us you may opt-out by:

If you opt-out of receiving marketing-related emails from us, we may still send you important administrative messages, such as notifications regarding our business relationship with you, important notices regarding our products and services, or as otherwise consistent with applicable law.

Contacting Us in Canada:
If you wish to know what information we have in our files about you, ask a question about the information in your file or request a change to the information in your file, please feel free to contact Vallation via email at: privacy@vallationsystems.com, or contact our Privacy Officer at the following address:

Privacy Officer: Melody Lafond
412 Main St., STE 100
Buffalo, WY 82834
+1 (833) 247-3747