We at Elpha Secure Technology Inc. (“Elpha Secure”, “we”, “us” or “our”) are committed to respecting your (“you” or “your”) privacy and recognize your need for appropriate protection and management of certain information you share with us.  This privacy policy (this “policy” or “Privacy Policy”) describes how Elpha Secure collects, shares, and uses personal information about you and how you can exercise your privacy rights.  This policy applies to the information we collect from you, including through your use of our software, products, and our website (www.ElphaSecure.com) and any other websites that we may control that display or link to this Privacy Policy, and other advertising mediums we may deploy, including, but not limited to, email and newsletters.  This policy in no way applies to the practices of companies that Elpha Secure does not own or control or to people that Elpha Secure does not employ or control.

Information Collected By Elpha Secure

Personal information:  In some cases, we collect information that you may choose to provide to us, and in other cases we may collect personal information automatically.  In other cases, we may collect information about you under the authority and direction of our customers that are corporate entities.

Information collected through our website:  Certain parts of our website may ask you to provide personal information voluntarily.  We may, for example, ask you to provide your contact details (such as your name, email address, and phone number) if you request a demonstration from us, or if you otherwise contact us by email using a contact form on the website.  To access certain features of the website, we may collect login credentials to verify user authorization to access such features.  

Information collected when you communicate with us:  We collect personal information contained within, and associated with, your correspondence with us, including via email, mail, fax, or other means.

Information collected from our customers:  We may collect personal information about you as a representative of our customers, which may be corporate entities, including business contact information such as your name, job title, company name, address, phone number, email address or username, and password, in the course of providing you with the requested services.  We also may acquire personal information in other limited situations, such as for technical support requests or for product improvement purposes.  We process such data strictly in line with the agreements in place with such customers, and such customers determine which information to upload.

Job applicants:  We may also collect your contact details (such as your name, phone number, email address, and address) and employment details if you send us a CV, resume, or other details of your employment history in connection with an Elpha Secure job vacancy or a general enquiry regarding employment opportunities with us.

Office visitors: If you visit our offices, we may ask you to register as a visitor and to provide your name, email address, phone number, company name, and time and date of arrival.  We may ask you to show proof of your identity.  Additionally, to ensure the safety and security of our employees and to protect our confidential information against unauthorized access, our offices may use cameras to record video and audio at our offices’ access points and common-area corridors.

Information We Collect Automatically

We may also use cookies and similar tracking technologies to collect information about you and your device, such as an IP address and other identifiers.  Elpha Secure may collect various types of information from you to better meet your needs and to provide you with a more relevant user experience.  Some of this information is collected automatically through cookies or other Internet tracking technologies.

Cookies are small data files that are placed on your computer or mobile device when you visit a website.  Cookies are widely used by website owners in order to make their websites work, or to work more efficiently, as well as to provide reporting information.  Cookies set by the website owner are called “first-party cookies”.  Cookies set by parties other than the website owner are called “third party cookies”.  Third party cookies enable third party features or functionality to be provided on or through the website (e.g., advertising, interactive content, and analytics).  The parties that set these third party cookies can recognize your computer both when you visit the website in question and also when you visit certain other websites.

We may use first-party and third party cookies for several reasons.  Some cookies are required for technical reasons in order for our website to operate, and we refer to these as “essential” or “strictly necessary” cookies.  Other cookies also enable us to track and target the interests of our users to enhance their experience on our website.  Third parties use cookies through our website for performance and analytics.

Cookies are not the only way to recognize or track visitors to a website.  We may use other, similar technologies from time to time, like web beacons (sometimes called “tracking pixels” or “clear gifs”).  These are tiny graphics files that contain a unique identifier that enables us to recognize when someone has visited our website.  This allows us, for example, to monitor the traffic patterns of users from one page within our website to another, to deliver or communicate with cookies, to understand whether you have come to our website from an online advertisement displayed on a third party website, to improve site performance, and to measure the success of e-mail marketing campaigns.  In many instances, these technologies are reliant on cookies to function properly, and so declining cookies will impair their functioning.

Our website may utilize cookies to collect information about your website activities and to recall the personal information you previously shared with us.  Most browsers allow you to control cookies, including whether to accept them and how to remove them.  You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser. Blocking cookies may result in a lower quality experience for you while you are visiting the website.

Information We Obtain From Third Party Sources

From time to time, we may receive personal information about you from third party sources (including content syndication vendors, data aggregators, and advertisers), but only where we have checked that these third parties either have your consent or are otherwise legally permitted or required to disclose your personal information to us.  The types of information we collect from third parties may include name, company, role, location, and topics of interest, and we may use the information we receive from these third parties to maintain and improve the accuracy of the records we hold about you and to communicate with you about any relevant products or services.

How Collected Information Is Used

The information that Elpha Secure collects automatically through cookies and other similar technologies is used for analytics purposes, marketing, and sales efforts to better target advertisements and other content in an effort to create a more personally relevant experience.  The information is also used to predict responses to advertisements and to help determine which advertisements perform best and which content is most appropriate for different individuals.

The personal information that you voluntarily provide to us or is otherwise provided to us by our customers may be used to offer you requested services, to manage your account and to respond to your inquiries, to provide support to our customers, and to improve and develop our products and services.  Your information may also be used for marketing purposes.  This use may result in follow-up communications from Elpha Secure in accordance with your communications preferences.  In addition, as discussed in the section above, that information may be combined with information collected from other sources to assist with targeting advertisements to your preferences and behaviors and with other Elpha Secure sales and marketing efforts.

Legal Basis For Processing Personal Information (European Economic Area Or The United Kingdom Visitors Only)

If you are a visitor from the European Economic Area or the United Kingdom, our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.  However, we will normally collect personal information from you only where we have your consent to do so, where we need the personal information to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms.

If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).  Similarly, if we collect and use your personal information in reliance on our legitimate interests (or those of any third party), we will make clear to you at the relevant time what those legitimate interests are.

If you have questions about, or need further information concerning, the legal basis on which we collect and use your personal information, please contact us using the contact details provided under the “Contacting Us” heading below.

Sharing Information With Third Parties

We may disclose your personal information to the following categories of recipients:

• To certain third party services providers and partners who may perform certain functions on our behalf and who provide services to us (for example, to fulfill requests for information, to receive and send communications, to update marketing lists, to analyze data, to provide IT and other support services or other similar tasks) or who otherwise process personal information for purposes that are described in this Privacy Policy or notified to you when we collect your personal information.  Types of companies who may provide such services include IT suppliers, service providers, insurance carriers, underwriters, brokers, and other professional advisors.
• To any law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) to comply with applicable law or regulation, (ii) to exercise, establish, or defend our legal rights, or (iii) to protect your vital interests or those of any other person.
• To a potential buyer (and its agents and advisers) in connection with any proposed purchase, merger or acquisition of any part of our business, provided that we inform the buyer it must use your personal information only for the purposes disclosed in this privacy policy.
• To any other person with your consent to the disclosure.

Our Privacy Policy And Outside Links

This Privacy Policy applies only to Elpha Secure’s activities.  Any information you submit to any third party websites is not in our control or governed by this Privacy Policy.  You should be sure that you review the privacy policy of any site to which you link or redirect your browser and should not assume that any such website is operated by Elpha Secure or governed by this Privacy Policy.

Security

Wherever your personal information may be held within Elpha Secure or on its behalf, we intend to take appropriate technical and organizational measures to protect the information you share with us from access or disclosure not in compliance with this Privacy Policy.  We seek to use reasonable organizational, technical, and administrative measures to protect personal information within our organization.  Unfortunately, no transmission or storage system can be guaranteed to be completely secure, and transmission of information via the Internet is not completely secure.  If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please notify us of the problem immediately.

Your Choice And Rights

You have the following data protection choice and rights:

• If you wish to access, correct, update, or request deletion of your personal information, you can do so at any time by contacting us using the contact details provided under the “Contacting Us” heading below and by providing us with the name of the service for which information was supplied, your full name, mailing address, phone number, and email address so that we may identify you.
• In addition, if you are a resident of the European Economic Area or the United Kingdom, you can object to processing of your personal information, ask us to restrict processing of your personal information, or request portability of your personal information.  You can exercise these rights by contacting us using the contact details provided under the “Contacting Us” heading below.
• You have the right to opt out of any marketing communications we might send you at any time.  If you no longer wish to receive any newsletters, surveys, or promotional communications we may send via email, you may opt out of such communications and follow the instructions provided to unsubscribe.  You can also exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you or by contacting us using the contact details provided under the “Contacting Us” heading below. Please be aware that even after you opt out from receiving any such marketing communications, you may continue to receive administrative messages from us – for example, in relation to other services you have requested from us.
• Similarly, if we have collected and processed your personal information with your consent, then you can withdraw your consent at any time.  Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
• You have the right to complain to a data protection authority about our collection and use of your personal information.  For more information, please contact your local data protection authority. 

We will respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

Children’s Privacy

In compliance with the Children’s Online Privacy Protection Act (COPPA) and similar laws applicable to websites directed at people under 16 years of age, Elpha Secure is not structured to attract children.  Pursuant to Elpha Secure’s Terms of Use, you must be at least 18 years of age to use Elpha Secure’s website.  Accordingly, we do not knowingly collect personal information from anyone under 18 years of age.  The website and its content are directed to people who are at least 18 years of age or older.  If you are under the age of 18, you may not use the website unless you have the consent of, and are supervised by, a parent or guardian.

Cross-Border Transfers

Your personal information may be stored and processed in any country where we engage service providers.  Our website servers are located primarily in the United States and may also be located in Canada, but our third party service providers and partners may operate outside of the United States and Canada.  This means that when we collect your personal information, we may process it in countries outside of the United States and Canada.  We have, however, taken appropriate safeguards to require that your personal information will remain protected in accordance with this Privacy Policy.  

Data Retention

We retain personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to fulfill your orders or to comply with applicable legal, tax or accounting requirements).  When we have no ongoing legitimate business need to process your personal information, we will delete it; if this is not possible (for example, because your personal information has been stored in backup archives), then we will store your personal information securely and isolate it from any further processing until deletion is possible.

Your California Privacy Rights

The California Consumer Privacy Act of 2018 (“CCPA”) gives California residents certain rights as described below.  For this section, we use the terms “personal information” and “sale” as those terms are defined in the CCPA.

• You have the right to request a copy of the categories or specific pieces of personal information that Elpha Secure collects, uses, shares, or sells about you.
• You have the right to request that Elpha Secure delete the personal information we have collected from you.
• You have the right to request to opt out from the sale of your personal information.  Because Elpha Secure does not sell your personal information, you do not need to exercise this right.
  

Your rights are subject to certain exceptions under the CCPA – for example, when it is necessary to perform or produce evidence that a transaction or contract complies with a legal obligation or when a consumer’s identity cannot be verified.

Exercising Your CCPA Rights

To make a CCPA request, you can:

• Call us at (845) 248-0955.
• Email us at support@elphasecure.com using “CCPA Request” in the subject line.

Your request must (1) provide sufficient information to allow us to verify that you are the person about whom we have collected personal information, and (2) describe your request in sufficient detail to allow us to understand, evaluate, and respond to it.  We may not respond to requests that do not meet these criteria.  We will only use personal information provided in your request to verify your identity and complete your request.

You may also authorize an agent (an “Authorized Agent”) to exercise your CCPA rights on your behalf.  To do this, you must provide your Authorized Agent with written permission to exercise your rights on your behalf, and we may request a copy of this written permission from your Authorized Agent when they make a request on your behalf.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights, and we will not deny you goods or services, charge you a different price, or provide you with a lesser quality of goods or services if you exercise any of your CCPA rights.

Other California Resident Rights

Under California law, a California resident who has provided Elpha Secure with personal information is entitled to request certain information with respect to the types of personal information that Elpha Secure has shared with third parties for their direct marketing purposes.  In accordance with California law, Elpha Secure will, in response to your written request, provide you with the means to choose not to have your information shared.

Except as otherwise stated in this Privacy Policy (including, but not limited to, sharing information with any third party resellers), we will not share your personal information with third parties for their direct marketing purposes unless you affirmatively agree to such disclosure.  To prevent further disclosure of your personal information from use in direct marketing by a third party, do not opt in to such use when you provide personal information on our website.  If you opt in to receive communication from a third party, your personal information will be subject to the third party’s privacy policy.  If you later decide that you do not want that third party to use your personal information, you must contact that third party directly, as Elpha Secure has no control over a third party’s use of personal information.  You should always review the privacy policy of any party that collects your information to determine how that entity will handle your information.

California residents may request further information about our compliance with this law by emailing support@elphasecure.com.  Please note that we are required to respond to only one request per individual per year and are not required to respond to requests made by means other than through this e-mail address.

Updates To This Policy

We may occasionally update or modify this Privacy Policy and reserve all rights to do so.  When we do so, we will also revise the “last updated” date at the beginning of the Privacy Policy.  The then-current Privacy Policy will apply to all use of information retained by Elpha Secure after the effective date thereof.  If we make any material changes in the way we treat personal information, we will notify you by including a notice in an email sent to the primary email address in your Elpha Secure account or by placing a prominent notice on our Privacy Policy or website.  We encourage you to review this Privacy Policy periodically to stay informed about how we collect, use, and disclose personal information.

Contacting Us

For more information, or if you have questions or concerns regarding Elpha Secure’s Privacy Policy, you may email us at support@elphasecure.com, or you may mail us correspondence at the following address: 580 Fifth Avenue, Suite 820, New York, NY 10036.