Alterity Solutions Privacy Notice (Portal)

Welcome to the Alterity Solutions Privacy Notice.

Alterity Solutions, Inc. (“Alterity Solutions,” “we,” “us,” “our”) knows that you care about your privacy and protecting your Personal Data (defined below, see “Scope”). Alterity Solutions has developed this Privacy Notice to explain how we process Personal Data when you visit the LegalMind® Personal Learning Portal, found at alteritysolutions.net (together with all sub-domains, and any successor website(s) thereto (“Portal”) and interact with our System, including, without limitation, the OnGuard® Security Awareness Program.

This Privacy Notice is part of our Terms of Use (“Terms”), a link to which appears at the bottom of this page. Any capitalized terms not defined in this Privacy Notice have the meaning set out in our Terms.

We encourage you to read this Privacy Notice fully by reviewing each section below:

Scope

This Privacy Notice applies to Alterity Solutions’ collection, use, sharing, disclosure, retention, and deletion of Personal Data in connection with the System. For purposes of this Privacy Notice, “Personal Data” is any data that could reasonably be used to identify an Authorized User. Generally, we’ll refer to data “processing” when we talk about any operation or set of operations performed on Personal Data, such as the collection, use, sharing, disclosure, retention, and deletion of Personal Data.

Personal Data we process as a service provider

As part of the Contract with our Subscribers, we process Personal Data on their behalf. While we provide transparency into our privacy practices, ultimately, our Subscribers are responsible for notifying you and for obtaining your appropriate consent when they collect Personal Data and transfer it to Alterity Solutions.

Personal data is required to fulfil our obligations under our Contracts with our Subscribers, and such data includes the following categories of Personal Data (but does not include sensitive personal data):

• Identifiers, such as first name and last name.

• Contact Data, such as email address.

• Technical Data, such as internet protocol (IP) address, browser type and version, time, date and type of use of the System and location data, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this Portal.

• System Use Data includes information about how you use the System, and in particular, how you use the Portal and interact with the Material made available through it.

We use different methods to collect Personal Data from and about you, including through:

• Direct interactions with our Subscribers. Our Subscriber sends us your Identifiers and Contact Data so that you may access the System.

• Direct interactions with you. When you log into the Portal, you use your Contact Data as well as a password that you select.

• Automated technologies or interactions. As you interact with the System, the System automatically collects Technical Data about your equipment and actions related to the System.

• Third parties or publicly available sources. If a Subscriber elects to enable analytics, we may receive Personal Data about you from analytics providers such as Google.

Information for California Residents. California Civil Code Sections 1798.115(c), 1798.130(a)(5)(c), 1798.130(c), and 1798.140 indicate that organizations should disclose whether certain categories of personal data are collected, “sold” or transferred for an organization’s “business purpose” (as those terms are defined under California law). As these terms are defined under California law, Alterity Solutions does not “sell” Personal Information; with respect to your access to the Portal, Alterity Solutions is a “service provider;” and our Subscriber — your employer or other entity that has provided you with access to the Portal — is a “business.”

How do we use your Personal Data?

We will only use your Personal Data when and as the law allows us to. Most commonly, we will use your Personal Data for the following purposes:

• To fulfill the purpose(s) for which the Personal Data was collected/provided, such as:

Ex: To provide the System under the Contracts with our Subscribers, at their direction;

Ex: To provide Subscriber service and support;

Ex. To administer our System, including, without limitation, the Portal;

Ex. To perform our contractual obligations; and

Ex. Legitimate purposes including, without limitation, improving and securing our Portal

• To comply with applicable legal or regulatory obligations.

As a processor of your Personal Data, we process such information on the basis of instructions from and under the Contract with the controller, namely our Subscriber. Our Subscriber, who is the controller of your Personal Data, will have a legal basis for providing us with your information to process. It should provide you with details of its legal basis and other information in its privacy notice to you.

Do we share your Personal Data?

Yes, but we do not share your Personal Data with any third-parties for the purposes of direct marketing. Instead, we may share your Personal Data strictly as necessary in order to provide the Portal and/or to fulfill our business and compliance purposes. Further, we share your Personal Data under the following circumstances:

With our Subscribers. Alterity Solutions processes your Personal Data on behalf of our Subscribers. Our Contract requires that we share your Personal Data with that Subscriber. That way, our Subscriber can know whether and how you have used the System that we deliver through our Portal, and in particular, whether (and when) you have completed particular training modules.

With our service provider–eNyota Learning Pvt. Ltd.—who supports our provision of the Portal and helps us carry out the purposes listed above; and

With other third parties for our business purposes or as permitted or required by law: We may share information about you with other parties for our business purposes or as permitted or required by law, in the following cases: (a) to comply with a law, legal process or regulations; (b) responding to or cooperating with law enforcement authorities, other government officials or other third parties pursuant to a subpoena, a court order or other legal process; (c) to protect our System, property, services and legal rights; (d) with a potential buyer and its agents and advisors in case of a sale, merger, consolidation, liquidation, reorganization, or acquisition (in that event, any acquirer will be subject to our obligations under this Privacy Notice); (e) with any other person with your consent; and (f) to support our audit, compliance and governance functions.

How do we protect your Personal Data?

We maintain appropriate administrative, physical, and technical safeguards for protection of the security, confidentiality and integrity of the System, including Personal Data processed in connection with the Portal. These safeguards include limiting access to Personal Data, utilizing encryption, and having procedures for responding to a suspected breach of Personal Data.

However, the transmission of Personal Data over the internet may not be completely secure and any transmission of Personal Data in connection with the Portal is at your own risk.

What are your legal rights?

Some jurisdictions (state, federal, national and international), such as California, Canada, and the European Economic Area (under the General Data Protection Regulation (“GDPR”) for example, provide individuals with certain rights regarding their Personal Data.

PLEASE NOTE: Because Alterity Solutions is processing your Personal Data on behalf of our Subscriber (typically, your employer), you should contact that entity directly to submit an access or correction request, concern, or complaint.

Other Privacy Issues:

Children’s information: Our Portal is not directed at children under the age of eighteen (18) and we do not knowingly collect Personal Data from children under the age of eighteen (18).

Data Retention and Disposal: Personal Data will be retained as long as the information is required to fulfil our legitimate business needs or the purpose for which the information was collected, or for as long as is required by law. Our retention policies will vary depending on the type of data involved. Generally, we will refer to the following criteria to determine retention period:

• Whether the data is still necessary to provide our System; or

• Whether we have a legal or contractual need to store the data.

Disclaimer of linked websites: The Portal may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave the Portal, we encourage you to read the privacy notice of every website you visit.

“Do Not Track” Signals: We do not track our Portal’s visitors over time and across third party websites to provide targeted advertising, and therefore we do not respond to Do Not Track (DNT) signals at this time. However, some third-party sites do keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you. If you are visiting such websites, you can learn more about “Do Not Track” by visiting www.allaboutdnt.com.

Automated decision-making: We do not use automated decision-making without human intervention, including profiling, in connection with the Portal.

Updates to this Privacy Notice

We may update or change this Privacy Notice. The effective date at the top of this page states when this Privacy Notice was last revised. Any change to this Privacy Notice will become effective when we post the revised Privacy Notice on the Portal.

If any change will materially and negatively affect the privacy of your Personal Data, we will use reasonable efforts to notify you in advance and give you a reasonable time to object to any changes.

We encourage you to periodically review this Privacy Notice to stay informed about how we collect, use, and share Personal Data.

How you may contact us

Use the contact information below if you have questions, concerns, or complaints about this Privacy Notice, Terms of Use or our privacy practices.

You may email us at support@alteritysolutions.com, or contact us at:

Chad Johnston
Director of Operations
5345 Towne Square Drive Suite 200
Plano, Texas 75024
cjohnston@travelingcoaches.com

Thank you for reading Alterity Solutions Privacy Notice.