Who and What

We are Protected Trust, LLC and our subsidiaries. You are our clients, guest users, visitors, and business partners.

“Personally Identifiable Information” (“PII”) means information usable to identify a natural person, including identification codes, or physical, physiological, mental, economic, cultural, or social identity factors.

Our core value is that trust and privacy are essential for building meaningful human relationships. Therefore, we are committed to protecting the security and privacy of your PII and other data.

We will not vary from this policy unless: (i) required by law; or (ii) we first notify you via a posted update.

When and Where

Whenever and wherever we collect or use your PII.

Why and How

Because we comply with the seven Safe Harbor Privacy Principles (“Safe Harbor”), as follows:

1. Notice

a. We collect only the PII you willingly provide us, and we will only use it to offer and provide you our software and services. Our premises security includes video recording.

b. We may disclose your PII only when necessary to: (i) enable business partners to assist us in our business operations; (ii) comply with law; (iii) protect human rights, property, or safety; or (iv) facilitate a merger/acquisition.

Send inquiries/complaints to:

PO BOX 111

and/or privacy@protectedtrust.com.

2. Choice

We will not use your PII for any purpose that is incompatible with the purpose for which it was originally collected or subsequently authorized by you, unless we first give you the opportunity to:

a. Opt out regarding non-sensitive PII; and

b. Opt in regarding sensitive PII—including racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, and health or sex life.

3. Onward Transfer

Before we disclose your PII to a third party, we will do one or more of the following:

a. Confirm that the third party: (i) subscribes to Safe Harbor; or (ii) is subject to applicable law (e.g., Directive 95/46/EC) or another adequacy finding; or

b. Enter into a written agreement requiring the third party to provide at least the same level of privacy protection Safe Harbor requires.

4. Access

We will provide you access to your PII to correct, amend, or delete inaccuracies, unless the burden or expense of providing access would be disproportionate to the risks to your privacy in the case in question, or where the rights of another person would be violated.

5. Security

We will take reasonable precautions to protect your PII from loss, misuse and unauthorized access, disclosure, alteration and destruction.

6. Data Integrity

We will take reasonable steps to ensure that data is reliable for its intended use, accurate, complete, and current.

7. Enforcement

To ensure compliance with Safe Harbor, we will:

a. Use JAMS, Inc. for all complaints and disputes;

b. Adhere to governing authorities’ procedures necessary to verify that our commitments have been implemented;

c. Remedy any problems arising out of a failure by us to comply; and

d. Maintain, update, and submit required self-certification letters or online forms to appear in the list of participants and to assure its benefits.

Government Requests for Your PII or Other Data

1. Subpoenas/Warrants

We will only disclose your PII or other data to government officials pursuant to a subpoena or search warrant supported by probable cause and issued in compliance with governing law.

2. Notification

Unless prohibited by a statute or court order, or to protect the safety of another, we will notify you—in advance if reasonably possible—of government requests for your PII or other data.

3. Transparency

To the extent permitted by law, in any year in which we receive government requests for your PII or other data, we will publish a transparency report providing aggregate request data here.

4. Opposition

To the extent of our available resources for such matters, and in compliance with law, we will go to court to oppose overbroad law enforsement requests for your PII or other data.

Mass Surveillance

We support the Reform Government Surveillance Coalition statement that “governments should limit surveillance to specific, known users for lawful purposes, and should not undertake bulk data collection of Internet communications.”

© 2018 Protected Trust / All Rights Reserved