Privacy Notice

ExteNet Systems Privacy Notice

Last Updated: January 1, 2023

ExteNet Systems, Inc. and its subsidiaries and affiliates (collectively, “ExteNet”, “we”, “us”, or “our”) are committed to respecting your privacy. This “Privacy Notice” (or “Notice”) describes the limited ways we collect, use, disclose, store and otherwise process personal information through www.extenetsystems.com and our affiliated websites where this Notice is posted (collectively, “Websites”). As used in this Notice, personal information means any information that relates to an identifiable individual. In addition, this Privacy Notice describes your rights with respect to your personal information that we process. We will not use or share your information with anyone except as described in this Privacy Notice and we do not sell your information.

We urge you to read this Privacy Notice so that you understand our commitment to you and your privacy, and how you can participate in that commitment. By accessing our Websites, you confirm that you have read, understand, and acknowledge the terms of this Privacy Notice.

If you are a California resident, see Section 9 for information provided pursuant to the California Consumer Privacy Act (“CCPA”).

Table of Contents

1. The personal information we collect
2. How we use your personal information
3. How we share your personal information
4. Your rights and choices
5. How we keep your personal information safe
6. This Website May Link to Other Websites
7. Changes to this Privacy Notice
8. Contact Us
9. Information Regarding U.S. Privacy Rights

1. The Personal Data We Collect

We collect personal information about individuals from various sources described below. Where applicable, we indicate whether and why individuals may provide us with personal information.

Information that we collect directly from individuals and the parties with which we do business

We may collect personal information directly from individuals and the parties that interact with us directly (such as individuals who contact us or visit our Websites), (collectively, “clients”), parties that provide services to us (such as vendors) (collectively, “service providers”), and other parties with whom we offer or provide products and services (such as independent sales organizations) (collectively, “partners”).

We may collect information from these parties in a variety of contexts, such as when completing one of our online forms, interacting with us on social media, or corresponding with us directly in another manner. The types of information we obtain in these contexts include:

• Contact information of the business entity and its personnel who interact with us, such as name, job title, address, telephone number, and email address
• Profile information, such as username and password that an individual may establish on one of our Websites, along with any other information that an individual enters into their account profile
• Information about individuals’ affiliation with a legal entity, such as an individual’s role, and whether he or she is a beneficial owner or authorized signatory
• Feedback and correspondence, such as information you provide when you request information from us, receive customer support, or otherwise correspond with us, including by interacting with our pages on social networking sites or services or our Websites

Information that we collect about individuals who do not interact with us directly

We may receive personal information about individuals who do not interact with us directly. For example, our clients, service providers, and partners may provide us with information about individuals other than themselves when using our products or providing services to us. We may also receive information from social media and publicly available sources. The types of information we receive about third parties includes:

• Information about the personnel of our clients, service providers, or partners, such as the business contact information that our clients, service providers, or partners provide to us in the context of our contractual relationships with them
• Information about potential clients or partners such as a service provider providing contact information for real estate representatives

Information collected via automated means

When you access our Websites, we, our service providers and our partners may passively collect information about you through the use of tracking tools like browser cookies and web beacons. A “cookie” is a unique numeric code that we transfer to your computer so that we can keep track of your interests and/or preferences and recognize you as a return visitor to the Websites. Typically, this information includes your computer or mobile device operating system type and version number, manufacturer and model, device identifier (such as the Google Advertising ID or Apple ID for Advertising), browser type, screen resolution, signal strength, IP address, general location information such as city, state or geographic area; and information about your use of and actions on or in our Websites, such as pages or screens you accessed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times, and length of access, what site you came from, or the site you visit when you leave us, and other electronic communications and content from your use of the Websites (such as content entry, mouse movements, screen captures, the date, time, and location of your visit, what search terms or other data you enter, and what content or links you view or click on). This is collected by default and ExteNet does not use the information for any commercial purposes.

Our Websites include social media features and other widgets that run on our Website and may collect your IP address and which page you are visiting on our Website and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our Website. Your interactions with these features are governed by the privacy policy of the organization providing it.

Sensitive personal information

• In limited circumstances and when permitted or required by law, in the context of processing employment applications, we may also request sensitive information, such as racial or ethnic origin or information about disability, Demographic details, such as date of birth, country of citizenship and/or country of residence.
• Government-issued identification numbers (to the extent permitted under applicable law), such as a national identification number (e.g., a Social Security Number, tax identification number, or passport number), state or local identification number (e.g., a Driver’s License or other government-issued identification number), and a copy of your government-issued identification card.

Outside of these contexts or otherwise as we specifically request, we ask that you not provide us with any sensitive personal information (meaning information revealing racial or ethnic origin, political opinions, religion or philosophical beliefs, trade union membership, genetic, health, or biometric information, information about sex life or sexual orientation, or criminal convictions or offenses) through our Websites or otherwise.

Applicant personal information

When you apply for a job with ExteNet, we collect personal information about you from the following sources: 1) you; 2) prior employers, references, recruiters, job-related social media platforms; 3) third-party sources of demographic information; 4) third-party companies, such as background check companies, drug testing facilities; and 5) claim administrators and investigators.

The personal information we collect may include identifiers (such as your name, government-issued identifier, social security number, driver’s license or state identification number, passport number), your contact information (such as your phone number, mailing address, e-mail address), records of your educational and employment history, financial information (such as your bank account number), characteristics of protected classifications (such as age, marital status, gender, sex, race, color, disability, citizenship status, primary language, immigration status, military/veteran status, medical conditions), or inferences drawn from the various data elements listed immediately above.

Combining personal information

We may combine information that we have collected from another party with information that we already have about you. We may also aggregate your information with information about others to understand preferences and trends over time.

Personal information of minors

ExteNet recognizes the importance of protecting the privacy and safety of minors. Our Websites and services are meant for adults and are not directed towards minors under the age of 18. We do not knowingly collect information about minors under the age of 18. If we learn that someone under 18 has provided personal information through one of our Websites, we will use reasonable efforts to remove that information from our databases. Adults who interact with ExteNet should take care not to provide any information about minors under the age of 18. If you are a parent or legal guardian and think your child has given us information, you can contact us using this FORM or call us at 866.892.5327.

2. How We Use Your Personal Information

We use your personal information for the purposes of:

Providing our products and services, which includes:

• Managing our relationship with you or your company
• Carrying out our obligations, and exercising our rights, under our agreement with you or your company
• Administering and protecting our business
• To provide support and to respond to your requests and inquiries
• Marketing purposes – promotions, offers, etc.
• Test, develop, analyze, improve, and provide products/services

Processing job applications

If you are applying for a job, we use your personal information for various purposes related to processing your job application including evaluating your candidacy, scheduling and conducting interviews, conducting background checks and drug tests, and potentially engaging with you on the offer negotiation and hiring process.

Complying with law

We use your personal information as we believe necessary or appropriate to comply with applicable laws, lawful requests and legal process, such as to respond to subpoenas or requests from government authorities.

Compliance, fraud prevention and safety

We use your personal information as we believe necessary or appropriate to (a) enforce the terms and conditions that govern our products and services; (b) protect our rights, privacy, safety or property, and/or that of you or others; and (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity, such as cybersecurity events or fraudulent transactions. For example, we may use personal information to protect our company, clients, partners and their respective personnel.

With your consent

In some jurisdictions, applicable law may require us to request your consent to use your personal information in certain contexts. If you have consented to receive marketing communications from our third-party partners, you may withdraw your consent by contacting those partners directly.

Use for new purposes

We may use your personal data for reasons not described in this Privacy Notice where permitted by law and the reason is compatible with the purpose for which we collected it.

3. How We Disclose Your Personal Information

We do not sell your personal information or share it with third parties for cross-context behavioral advertising!

Companies within ExteNet

We may disclose your personal information to our subsidiaries and corporate affiliates for purposes consistent with this Privacy Notice.

Service providers

We may employ other companies and individuals to administer and provide services on our behalf (such as companies that provide customer support, companies that we engage to host, manage, maintain, and develop our Websites and IT systems). These companies may use your information only as directed by ExteNet and in a manner consistent with this Privacy Notice and are prohibited from using or disclosing your information for any other purpose.  Some additional examples of service providers are:

• Service providers and vendors who provide services such as data analytics, payment processing, order fulfillment, customer service, auditing, marketing services, IT services, and HR and recruiting services
• Security providers to help us prevent and detect fraud, security or technical issues, or illegal activity
• Marketing partners that may help us market our products or services, send email on our behalf, place our advertisements on other platforms, provide analytics and search engine support, or track advertising impressions
• Service providers who assist us with providing our products and services
• Payment processors
• Any other person or entity we reasonably think is customary, necessary or advisable for the business purposes disclosed in our Privacy Notice or to whom we are obliged by applicable law or regulation to make the disclosure
• Any other party where we have obtained your consent or authorization

Professional advisors

We may disclose your personal information to professional advisors, such as lawyers, bankers, accountants, auditors and insurers, where necessary in the course of the professional services that they render to us.

Compliance with Laws and Law Enforcement; Protection and Safety

ExteNet may disclose information about you to government or law enforcement officials (including tax authorities) or private parties as required by law, and disclose and use such information as we believe necessary or appropriate to (a) comply with applicable laws and lawful requests and legal process, such as to respond to subpoenas or requests from government authorities; (b) enforce the terms and conditions that govern our products and services; (c) protect our rights, privacy, safety or property, and/or that of you or others; and (d) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.

Business Transfers

ExteNet may sell or transfer some or all of its business or assets, including your personal information, in connection with a business transaction (or potential business transaction) such as a merger, consolidation, acquisition, reorganization or sale of assets or in the event of bankruptcy, in which case we will make reasonable efforts to require the recipient to honor this Privacy Notice.

4. Your Rights and Choices

In this section, we describe the rights and choices available to all users.

Do Not Track Signals

Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. These features are not all uniform. We currently do not respond to do not track signals. To find out more about “Do Not Track,” please visit allaboutdnt.com.

Choosing not to provide your personal information

Where we request personal information directly from you, you do not have to provide it to us. If you decide not to provide the requested information, in some circumstances we, or our clients, may be unable to provide products or services to you. For example, we may be unable to respond to your question or request.

Opt-out of receiving marketing emails and text messages

To stop receiving our promotional emails, you can follow the instructions in any promotional message you get from us. If you receive promotional text messages from us, you may opt out by replying “STOP”. Even if you opt out of getting marketing messages, we will still send you transactional messages. These include responses to your questions.

Tracking Tools

To control the collection of your precise location on your mobile device, you can adjust the settings on your mobile device, such as by disabling location services and turning off the Bluetooth and Wi-Fi. To learn more about mobile location analytics and certain options with respect to mobile location analytics, visit smart-places.org.

5. How We Keep Your Personal Information Safe

The internet is not 100% secure. We cannot promise that your use of our Websites will be completely safe. We have put in place appropriate security measures to prevent your personal information from being accidentally lost, altered, disclosed, or used or accessed in an unauthorized way. In addition, we limit access to your personal information to those employees, agents, contractors and other parties who have a business need to know. They will only process your personal information on our instructions, and they are subject to a duty of confidentiality. Any transmission of your personal information to our Websites is at your own risk. We encourage you to use caution when using the internet or our Websites.

How long will you use my personal information?

We will use your personal information for as long as necessary based on why we collected it and what we use it for. This may include our need to satisfy a legal, regulatory, accounting, or reporting requirement.

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

In general terms, we will retain your personal information for the duration of your involvement/engagement with us and for as long as reasonably necessary afterwards; however, we may maintain different retention periods for different purposes. There are also certain types of information which are required to be retained for a certain period by law.

6. This Website May Link to Other Websites

We may also link to third-party websites, mobile applications, and other content. ExteNet is not responsible for the privacy practices of any third party, and this Privacy Notice does not apply to such third party’s websites, mobile applications, or other content. ExteNet does not guarantee, approve, or endorse any information, material, services, or products contained on or available through any linked third-party website, mobile application, or other content. ExteNet is not responsible for any content on third-party properties to which we link. ExteNet provides links to third-party properties or content as a convenience, and visiting or using linked third-party properties or content is at your own risk.

7. Changes to This Privacy Notice

ExteNet reserves the right to modify this Privacy Notice at any time. We encourage you to periodically review this page for the latest information on our privacy practices. If we make material changes to this Privacy Notice, we will notify you by updating the date of this Privacy Notice and posting it on our Websites. We may (and, where required by law, will) also provide notification of changes in another way that we believe is reasonably likely to reach you, such as via the e-mail address you have provided us (if you have an account where we have your contact information).

Any modifications to this Privacy Notice will be effective upon our posting of the new terms and/or upon implementation of the new changes (or as otherwise indicated at the time of posting). In all cases, your continued use of our Websites after the posting of any modified Privacy Notice indicates your acceptance of the terms of the modified Privacy Notice.

8. Contact Us

If you have questions about this Privacy Notice or our privacy practices generally, please feel free to contact us using this FORM]. We also maintain a contact number, which is available 24 hours per day from the United States, at 866.892.5327. The contact number is most appropriate for an urgent concern.

9. Information Regarding U.S. Privacy Rights

Your California Privacy Rights

If you reside in California, you have the right to ask us one time each year if we have shared personal information with third parties for their direct marketing purposes. To make a request, please contact us using this FORM or at 866.892.5327. Indicate that you are a California resident making a “Shine the Light” inquiry.

If you reside in California, you also have the rights listed below. However, these rights are not absolute, and we may decline your request as permitted by the CCPA.

• Access. We collect very little personal information and we share personal information only in the very limited ways described above. However, you can request the following information about how we have collected and used your personal information:
  
  • The categories of your personal information that we have collected
  • The categories of sources from which we collected your personal information
  • The business or commercial purpose for collecting, sharing and/or selling your personal information
  • The categories of third parties with whom we disclose personal information
  • The specific pieces of personal information we have collected about you
  • Whether we have disclosed your personal information for a business purpose, and if so, the categories of personal information received by each category of recipient
  • Whether we’ve sold your personal information; and, if so, the categories of personal information received by each category of recipient
  • We do not sell or share your personal information
• Deletion. You can ask us to delete certain personal information that we maintain about you.
• Correction. You have the right to correct personal information that we have about you that is obsolete, incorrect or outdated.
• Limitation of Use/Disclosure of Sensitive Personal Information –You have the right to limit how we use any personal information that we have collected and retained. As noted in the Privacy Notice, we do not use your information for any purposes not explicitly permitted by the law. We collect and use sensitive personal information as outlined in this Privacy Notice. You can request that we limit the use or disclosure of your sensitive personal information, to the extent applicable, subject to certain exceptions.
• Nondiscrimination. You are entitled to exercise the rights described above free from discrimination. This means that we will not penalize you for exercising your rights by taking actions such as by denying you goods or services, increasing the price/rate of goods or services, decreasing the service quality, or suggesting that we may penalize you as described above for exercising your rights.

How to exercise your rights

You may exercise your California privacy rights as follows:

Right to access, deletion, correction and limitation of use
You can request to exercise the foregoing rights by making a request as follows:

• Complete and submit this FORM or
• Contact us via the following toll-free number: 866.892.5327 
• Identify verification. The CCPA requires us to verify the identity of the individual submitting the request before providing a substantive response to the request. A request must be provided with sufficient detail to allow us to understand, evaluate and respond. The requester must provide sufficient information to allow us to reasonably verify that the individual is the person about whom we collected information. We will take reasonable steps to verify your identity prior to responding to your requests. For example, we may utilize a third-party verification provider to assist with verifying your identity. The verifications steps may vary depending on the sensitivity of the personal information and whether you have an account with us. We may request information from you not included in the original request to help us verify your identity.

Authorized agents. California residents can designate an “authorized agent” to submit requests on their behalf. We will require the authorized agent to have a written authorization confirming that authority. When submitting the request, please ensure the authorized agent is identified as an authorized agent. Further, the authorized agent should also submit either proof that you have given them legal power of attorney (as designated under California law) or a signed letter showing that you have given them permission to make the request on your behalf. This letter should be signed by both you and the authorized agent. In some cases, where allowed under the CCPA, we may contact you directly for confirmation that you provided the agent permission to submit the request.

Personal information that we collect, use and share

The chart below summarizes our collection, use and sharing of personal information during the last 12 months before the effective date of this Privacy Notice. We describe the sources through which we collect your personal information in section above titled The Personal Information We Collect, and describe the purposes for which we collect, use, and share this information in section above titled How We Use Your Personal Information and How We Disclose Your Personal Information.