The Privacy Policy below governs CyberGuard360 (“CG360”) and it’s properties, including, but not limited to PIIGuard360, PIIGuard360.com, PIISecured, PIISecured.com, CyberGlass and CyberGlass360.com, et al (collectively “Property” or “Properties”).

A. OVERVIEW

In order to provide certain online services and to reduce the risk of fraud, CG360 must ask you to provide us information about yourself and your company. This Privacy Policy describes the information we collect, how we use that information and how we protect that information from misuse or improper access.

CG360 takes the privacy of your personal information very seriously and will use your information only in accordance with the terms of this Privacy Policy. We will not sell or rent your personally identifiable information or a list of our customers to third parties. However, as described in more detail in Part C below, there are limited circumstances in which some of your information will be shared with third parties, under strict restrictions and in accordance with our Privacy Policy, so it is important for you to review this Privacy Policy. We require, in writing that all third parties conform to, at a minimum, our Privacy Policy. This Privacy Policy applies to all services that are hosted CG360 Properties and extend to all services used, and individuals accessing same, in conjunction with the personal information gathered from those Properties.

So as to leave no doubt, personal data, as defined in myriad law, including but not limited to New York’s Stop Hacks and Improve Electronic Data Security (‘SHIELD’) Act, California Consumer Privacy Act (‘CCPA’), Article 4(1) of the EU General Data Protection Regulation (‘GDPR’), Brazil’s Lei Geral de Proteção de Dados (or LGPD), is:

“(1) “Personal information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Personal information includes, but is not limited to, the following if it identifies, relates to, describes, is reasonably capable of being associated with, or could be reasonably linked, directly or indirectly, with a particular consumer or household:

(A) Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.

(B) Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

(C) Biometric information. “Biometric information” means an individual’s physiological, biological, or behavioral characteristics, including an individual’s deoxyribonucleic acid (DNA), that can be used, singly or in combination with each other or with other identifying data, to establish individual identity. Biometric information includes, but is not limited to, imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which an identifier template, such as a faceprint, a minutiae template, or a voiceprint, can be extracted, and keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information.

(D) Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an internet website, application, or advertisement.

(E) Geolocation data.

(F) Audio, electronic, visual, thermal, olfactory, or similar information.

(G) Professional or employment-related information.

(H) Education information, defined as information that is not publicly available personally identifiable information.

(I) Inferences drawn from any of the information identified in this subdivision to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.”

Where definitions, as outlined by applicable law from an authority of competent jurisdiction, alter this definition, the broadest definition applies.

If you have questions or concerns regarding this Privacy Policy, you should contact CG360’s Principal Privacy Officer by email at ppo@cyberguard360.com. By accepting the Privacy Policy and the Terms and Conditions agreement with your registration and/or your request for information, you expressly consent to our use and disclosure of your personal information in the manner described in this Privacy Policy. This Privacy Policy is incorporated any and all agreements, including, but not limited to the Terms and Conditions, purchase and/or acquisition of services, Terms of Use, Mutual Non-Disclosure, et al. Where consummation of same is needed, such as the payment of a fee,download of a product or service, or any other discourse, this Privacy Policy is fully incorporated therein and agreed by consummation thereof. This Privacy Policy will take effect on January 1, 2014. This Privacy Policy was last updated on May 28, 2020.

Please note that your personal information will be stored and processed on computers in the United States. Should the laws on retaining and/or transmitting personally identifiable data may be less stringent in the United States, CG360 will make every effort to hold and transmit your personal information in a safe, confidential and secure environment, and in a manner that is compliant with the laws of your country. If you object to your personal information, being transferred or used as described in this Privacy Policy, please do not register for, or use CG360 Properties.

As laws and regulations require, or as new features are added to the CG360 Properties, this policy may be revised over time.

Any materially changes to the manner in which we collect, store, use or disseminate personally identifiable information will comport with the broadest interpretation of applicable law as required and, you will have a choice as to whether or not we use or disclose your information in this new manner by opting out of the use of CG360 Properties.

Please check the privacy page of any of the CG360 Properties, including but not limited to www.cyberguard360.com or www.piiguard360.com at any time for the most current version of our Privacy Policy.

Pages on the CG360 Properties may include links to third party Web sites. These sites are governed by their own privacy statements, and CG360 is not responsible for their operations, including but not limited to their information practices. Users submitting information to or through these third party sites should review the privacy statement of these sites before providing them with personally identifiable information.

B. INFORMATION WE COLLECT

Required Information

To open an account on a CG360 Property, you must provide, at a minimum, your name, company name, address, phone number, and/or e-mail address. This required information is necessary for us to establish and manage your account, and to contact you should the need arise during the administration thereof.

Web Site Use and Traffic Information

We use ‘cookies’, small text files used by websites and stored on your devices, with your consent, that remember your registered login, help you resume where your last browsing session left off, display pages correctly, and keep track of your preferences within the website to better service our customers and visitors. Cookies allow us to recognize you as an interested party of CG360, should you return to the any of the CG360 Properties using the same computer and browser. We use session cookies if and when you log in to your CG360 account by entering your user ID< e-mail address and/or password. This allows us to recognize you if you visit multiple pages in our site during the same session, so that you don’t need to re-enter your password multiple times. Once you log out or close your browser, these cookies expire and no longer have any effect. Cookies are also used to display your e-mail address on our sign-in form, so that you don’t have to retype the e-mail address each time when you log in to your CG360 account. Our cookie files are secure so that your information can only be interpreted by CG360.

When you arrive at or leave any of the CG360 Properties, we may receive the URL of the site that you came from (‘referrer’) or are going to (‘referral’). We also collect information on which pages of our Properties you visit while you are on CG360 Properties, your web browser, dates and times you access our Properties, and information related to your movement, behaviors, software and/or tools available when on CG360 Properties. We use this information to better understand our customers’ preferences, to manage the load on our servers, so as to improve our service, product and software offerings, and your experience with CG360. We do not track the sites that you visit before or after you leaving CG360 Properties.

We use this information, as well to analyze trends, administer the site, improve site performance and gather broad demographic information for aggregate use.

A visit to a page on our website may generate the following types of cookies:

Registration cookies – These let us know which account you are signed in with and whether or not you are allowed access to a particular service, and they help us associate any comments you post with your username.

Site performance cookies – This is how we remember your preferences for the tools found on our website so you don’t have to reset them each time you visit our site.

Anonymous analytics cookies – These tell us whether or not someone has visited our site in the past so we can track the number of site users and how often they visit for statistics. Note that these cookies can’t be used to identify any individual.

Advertising cookies – We use these to target our advertisement more accurately by telling us whether or not you have seen our ad and how long it is since you have seen it. These cookies store information about what you are looking at on our site, not your personal information.

How to accept, reject or turn off cookies

You can accept or reject cookies on our website via the pop-up cookies banner on our homepage.

If you would like to turn off cookies from all the websites you visit, you can do so via your browser’s settings. However, the websites you visit will not be able to tell whether you are signed in if cookies are turned off, which means you will not be able to post comments or access certain parts of the website.

Follow the links below to learn about all of your browser’s Cookies settings:

Note: These links are for reference only and may not work as they not controlled by CG360 and may change based on the company who developed the browser.

How to turn off third-party advertising cookies

CG360 partners with industry leaders to develop its suite of product and services. To inform you of our relationships, from time to time we may display our partners’ branding and collateral. We prohibit the use of advertising cookies by our partners, but links to our partner’s sites may take you to a site that includes their cookies. Some of those websites may include advertisement cookies that anonymously track who has viewed their ad.

The Network Advertising Initiative (NAI), a leading self-regulatory association dedicated to responsible data collection and its use for digital advertising, lets you opt out of third-party advertisements.

Note: This link is for reference only and may not work as they not controlled by CG360 and may change based on the company who maintains their site.

Customer Service Correspondence

If you send us correspondence, including e-mails and faxes, we retain such information in the records of your account. We will also retain customer service correspondence and other correspondence from CG360 to you. We retain these records in order to measure and improve our customer service, and to investigate potential fraud and violations of our Agreements. We may, over time, delete these records if permitted by law.

If, at any time you no longer wish to have CG360 use or retain your information, you may withdraw your consent by contacting CG360’s Principal Privacy Officer by email at ppo@cyberguard360.com and we will do so to the extent possible and as required by applicable law.

C. OUR USE AND DISCLOSURE OF INFORMATION

While users of our Properties may, CG360 does not collect or transfer personally identifiable information on individuals for anyone other than the data subject themselves. As such, any law and regulation pertaining to such practices do not apply.

Internal Uses

We collect, store and process your personal information on servers located in the United States. We use the information we collect about you in order 1) to provide our services, 2) to provide customer service, and 3) to improve and/or enhance our products and services. We give access to individually identifiable information about our users only to those employees who require it to fulfill customer service requests.

The use of your personal information comports with the definition and declaration pertaining thereto of applicable law.

Disclosure to Third Parties

CG360 will not sell or rent any of your personally identifiable information to third parties. CG360 will not share any of your personally identifiable information with third parties except in the limited circumstances described below, or with your express permission. These third parties are limited by law or by contract from using the information for secondary purposes beyond the purposes for which the information is shared.

  1. We disclose information that we in good faith believe is appropriate to cooperate in investigations of fraud or other illegal activity, or to conduct investigations of violations of our Agreements.
  2. We disclose information in response to a subpoena, warrant, court order, levy, attachment, order of a court-appointed receiver or other comparable legal process, including subpoenas from private parties in a civil action.
  3. We disclose information to your agent or legal representative (such as the holder of a power of attorney that you grant, or a guardian appointed for you).
  4. We may share aggregated statistical data with our business partners or for public relations. For example, we may disclose that a specific percentage of our users live in New York or California. However, this aggregated information contains no personally identifiable information that can be readily tied to an individual.

For questions about disclosures to third parties, contact CG360’s Principal Privacy Officer by email at ppo@cyberguard360.com or by way of written notice to:

Principal Privacy Officer
c/o CyberGuard360
88 Danbury Road, Suite #1D
Wilton, CT USA 06897

Information Retention and Destruction

Except for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with applicable law and subject to implementation of the appropriate technical and organizational measures required by same in order to safeguard the rights and freedoms of the data subject, personally identifiable information is retained no longer than is necessary for the purposes for which the personal data was processed.

D. INFORMATION SECURITY

Information Security

CG360 is committed to handling your customer information with high standards of information security. We restrict access to your personally identifiable information to employees who need to know that information in order to provide products or services to you. We maintain physical, electronic and procedural safeguards to guard your nonpublic personal information. Such safeguards include, but are not limited to multi-factor authentication, encryption at rest, encryption in transit, and comprehensive audit logging of all credentialed access to CG360 Properties.

The security of your CG360 account also relies on your protection of your password. You may not share your password with anyone. CG360 will never ask you to send your password or other sensitive information to us in an e-mail, though we may ask you to enter this type of information on the CG360 Web site.

Do not share your password with a third party for any reason. If you do they will have access to your account and your personal information, and you will be responsible for actions taken using your password. If you believe someone else has obtained access to your password, change it immediately by logging in to your account at any of the CG360 Properties, such as https://www.piisecured.com and change it in your Profile settings, and also contact us right away as described in Section F below.

E. ACCESSING AND CHANGING YOUR INFORMATION

You can review the personal information you provided us and make any desired changes to such information, or to the settings for your CG360 account, at any time by logging in to your account on the CG360 Property. You may also cancel your account at any time by contacting your account manager at accountmanager@cyberguard360.com. If you cancel your CG360 account, we will mark your account in our database as “Not Active,” but will keep your account information in our records. This is necessary in order to deter fraud, by ensuring that persons who try to commit fraud will not be able to avoid detection simply by closing their account and opening a new account. However, if you cancel your account, your personally identifiable information will not be used by us for any further purposes, nor sold or shared with third parties, except as required by law or as necessary to prevent fraud and assist law enforcement.

F. YOUR RIGHTS

Broadly, by law you have the right to:

  • the right to access;
  • the right to correction;
  • the right to removal;
  • the right to restrict or object to processing;
  • the right to data portability;
  • the right to raise a formal complaint with CG360’s Principal Privacy Officer by contacting them at ppo@cyberguard360.com; and
  • the right to withdraw your use consent.

This list may not be exhaustive; please refer to applicable law for your country or state of origin.

You have the right to confirmation as to whether or not we process your personally identifiable data and, where we do, access to the personally identifiable data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personally identifiable data concerned and the recipients of the personally identifiable data. Providing the rights of others are not infringed upon, we will provide you access to your personally identifiable data to copy and/or export, if available. The will be provided free of charge and during teh time your account is active, but additional access may be subject to a reasonable fee. You may request your personally identifiable data that we store by contacting CG360’s Principal Privacy Officer by email at ppo@cyberguard360.com.

You have the right to have any inaccurate personally identifiable data about you corrected and, taking into account the purposes of the processing, to have any incomplete personally identifiable data about you completed.

In some circumstances, without unreasonable delay you have the right to the removal of your personally identifiable data. These include:

  • the personally identifiable data that are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
  • you withdraw consent to consent-based processing;
  • you object to the processing under certain rules of applicable data protection law;
  • the processing is for direct marketing purposes; and
  • the personally identifiable data have been unlawfully processed.

This list may not be exhaustive; please refer to applicable law for your country or state of origin.

However, there are exclusions of the right of removal where processing is necessary including:

  • for exercising the right of freedom of expression and information;
  • for compliance with a legal obligation; or
  • for legal purposes.

This list may not be exhaustive; please refer to applicable law for your country or state of origin.

In some circumstances you have the right to restrict the processing of your personally identifiable data. These include:

  • contesting the accuracy of the personally identifiable data;
  • processing is unlawful but you oppose removal;
  • CG360 no longer has a need for the personally identifiable data for processing purposes, but you require personally identifiable data for legal purposes; and
  • you have objected to processing, pending the verification of that objection.

This list may not be exhaustive; please refer to applicable law for your country or state of origin.

Where this has restricted processing, we may continue to store your personally identifiable data. However, we will only otherwise process it:

  • with your consent;
  • for legal purposes;
  • for reasons of important public interest; or
  • for the protection of the rights of another person.

This list may not be exhaustive; please refer to applicable law for your country or state of origin.

You have the right to object to our processing of your personally identifiable data, but only to the extent that processing is not for legal purposes and or not necessary for:

  • the performance of a task carried out in the public interest;
  • the performance of a task is in the exercise of any official authority vested in us; or
  • the purposes of the legitimate interests pursued by us or by a third party.

This list may not be exhaustive; please refer to applicable law for your country or state of origin.

If the event you raise such objection, we will cease processing of your personal information unless and until we can demonstrate compelling legitimate grounds for the processing which override your objection, or the processing is for legal purposes.

You have the right to object to our processing of your personally identifiable data for direct marketing, at which time we will cease to process your personally identifiable data for these purposes.

You have the right to object to our processing of your personally identifiable data for scientific, historical research or statistical purposes, unless the processing is for the public interest.

To the extent that the legal basis for CG360’s processing of your personally identifiable data is:

  • consent; or
  • necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract; or
  • require by law or by an enforcement or legal body of competent jurisdiction,

and such processing is carried out in an automated fashion, and to the extent this right does not infringe upon the rights of others, you have the right to access and copy your personally identifiable data from us. Where possible we will make same available in a structured, commonly used and machine-readable format.

If you believe CG360’s use of personally identifiable information infringes on data protection laws, you have a legal right to lodge a complaint with an authority of competent jurisdiction who is responsible for the data protection violation you deem to have allegedly occurred.

You may exercise any of your rights in relation to your personally identifiable data contacting CG360’s Principal Privacy Officer by email at ppo@cyberguard360.com or by way of written notice to:

Principal Privacy Officer
c/o CyberGuard360
88 Danbury Road, Suite #1D
Wilton, CT USA 06897

G. CONTACTING US

If you have any questions about this privacy statement you can contact CG360’s Principal Privacy Officer by email at ppo@cyberguard360.com, or write us at CyberGuard360, 88 Danbury Road, Suite #1D, Wilton, CT USA 06897,