Effective as of: February 28, 2020
Telos Identity Management Solutions, LLC and its affiliates and subsidiaries, together referred to as “Telos ID”, “us” or “we”, respects your concerns about privacy. This Privacy Notice (the “Notice”) applies to personal data we collect on this site, online services, electronic mail and related content (collectively “Site” or “Sites”) owned, operated or controlled by us and where personal data is collected. This Notice applies to those Sites where it is posted. “Personal data” refers to information that, by itself or in combination with other information, identifies or can reasonably be used to identify an individual, such as name, email address, IP address, telephone number, address or date of birth. Therefore this Notice does not apply to data from which individual persons cannot be identified. The term “processing” refers to any operation or set of operations which is performed on personal data, whether or not by automated means, such as collection, use, organization, storage, alteration or destruction, disclosure or transfer.
The Notice describes the types of personal data we obtain, how we use the personal data, and with whom we share it. We also describe the rights you may have and how you can contact us about our privacy practices. We are committed to processing personal data in accordance with international legal standards, including the General Data Protection Regulation (GDPR) and other applicable data protection laws. Internal company policies and procedures govern our internal networks and systems and the processing of personal data related to employees and other authorized network users.
Telos ID is the data controller with respect to personal data that we collect through the Sites or that you provide to us. By submitting personal data and other information to the Sites, you consent to the processing of such data in accordance with the terms of this Notice.
- How We Obtain Information About You
We collect personal data that you choose to provide to us through the Sites, including, but not limited to, your first and last name, title and/or rank, organization, physical address, e-mail address, and business and telephone numbers, such as when you:
- Fill out a form on the Sites;
- Sign-up to receive direct marketing communications on the Sites;
- Sign-up to a feature that we offer on the Sites and you provide your personal data in connection with that feature;
- Attend an event that we (or one of our affiliates or partners) have organized;
- Communicate with us (for example, on a social media platform or by sending us an email);
- Communicate with us by telephone for marketing purposes; or
- Communicate with our support or concierge staff.
In addition, when you apply for a job, we collect the following additional information that you choose to provide to us through the Site: employment status, work authorization status, employment history, and education history.
When you visit our Sites, we may also collect certain information by automated means using technologies such as cookies, non-cookie-based tokens, web server logs, and tracking pixels. For further information regarding our use of such technologies, please see sections 2 and 7 of this Notice below.
We may also collect personal data in other contexts and that will be reflected in future Notice updates.
- Information We Obtain
Information That You Provide to Us
Personal data that you provide directly to us will be apparent from the context in which you provide it. Examples include:
- If you fill out a form on our Sites, you generally will provide your name, contact details and any other information requested by the form, such as the reason for your inquiry or your product preferences;
- If you sign up to receive electronic marketing communications from us, you generally will provide your name, email address and other contact information, and your product preferences;
- If you sign up to a feature on one of our Sites, you generally will provide your name and contact information and any other information necessary to access the feature;
- If you register to attend an event, you generally will provide your name and contact information, dietary restrictions or preferences, and any other information necessary to plan and schedule the event;
- If you register for support or concierge services or training, you generally will provide your name, your employer or the entity you represent, account number, email address, phone number, any other business contact information, and any other information necessary to provide support, concierge services, or training.
- If you apply for a job, you generally will provide your resume or CV with information on your experience, work history, educational background, contact information and other information to evaluate your credentials for the open position.
Each form on our Sites varies in the information required and collected. In most cases, an asterisk (*) indicates the required information on a form. You may choose to provide additional information within fields that are not required.
Due to the open nature of the Internet, we request that you do not send us unsolicited proprietary or other confidential information through our Sites.
Information That We Collect Automatically
The technologies we use on our Sites may log information such as your operating system type, browser type, domain, and other system settings, as well as the language your system uses and the country and time zone where your device is located. The logs may also record information such as the address of the web page that referred you to our Site and the IP address of the device you use to connect to the Internet. They may also log information about your interaction with the Sites, such as which pages you visit. Our Sites collect information by automated means by placing tags called “tracking pixels” — small files that link web pages to particular web servers and their cookies (explained in Section 7 below). We use this information in conjunction with data gathered from forms and emails to help us understand and respond to your needs.
Social Media Widgets
The Sites may include social media functions, such as the Blog, Twitter, LinkedIn, and Facebook widgets. These widgets collect information about which pages you visit on the Sites and the IP address of the device you use to connect to the Internet. The widgets may also set a cookie to ensure the features are functioning properly.
Social media functions and widgets are hosted either by a third party or directly on the Sites. Your interactions with the social media functions and widgets located on the Sites are governed by the privacy policies of the companies that provide them. If you use any of the social media functions or widgets on our Sites, we strongly suggest you review the privacy policies of the companies that provide those functions and features.
If you are a LinkedIn member and you visit our Sites from LinkedIn, our Sites may use tracking pixels — transparent graphic images placed on web pages — which, in combination with cookies, collect information contained within your LinkedIn profile as well as your access of and interaction with the web pages that contain the pixels.
Third Party Web Analytics Services
We use third-party web analytics services on our Sites, including Google Analytics and Salesforce Pardot. These service providers help us analyze how users use our Sites. The information collected for this purpose (including IP addresses and other information collected by automated means) will be disclosed to or collected directly by these services. To learn more about these third-party web analytic service provider activities, please go to the relevant sites.
We use a third party service provider to collect information from job applicants. Information collected includes name, address, email address, phone number, and other information to evaluate the applicant’s credentials and authorization to work. As part of their contractual obligations, such third party service providers are not permitted to use the personal data for purposes other than fulfilling those services or to further disclose your personal data.
- How We Use Information That We Obtain
Information That You Provide to Us
We use personal data that you provide to us to respond to your inquiry, for example, to contact you about your request, ask a question, provide announcements about products and future events, conduct surveys, consider your application for employment, and contact you for other reasons related to offering and improving our services. In addition, we use the personal data you provide on our Sites to:
- operate, evaluate, and improve our business;
- develop new products and services;
- perform market research;
- advertise and market our products and services;
- determine the effectiveness of our advertising and marketing;
- analyze our products, services, and websites;
- administer the Sites;
- perform security logging and analysis;
- comply with all legal and regulatory requirements.
We use the personal data for these purposes because we have a legitimate business interest in providing services to our customers and other interested individuals that is not overridden by your interests, rights and freedoms to protect personal data about you. We also use the information to protect against and prevent fraud claims and other liabilities and to comply with or enforce applicable legal requirements, industry standards, and our policies and terms. We use personal data for these purposes when it is necessary to protect, exercise or defend our legal rights, or when we are required to do so by law that applies to us.
Other Uses of Information
In addition to the uses described above, we may use personal data that you provide to us or that we collect for other purposes. Where that is the case, the Notice will be updated to describe those purposes for which we will use the personal data and our legal basis for doing so.
- Information We Share
Any information that you provide will be used for our purposes only. We do not sell or otherwise disclose personal data that you provide to us or that we collect on our Sites, except as described here.
We share personal data you provide to us or that we collect on the Sites among Telos ID and its affiliates and subsidiaries for the purposes described in this Notice.
We share personal data with certain partners when you submit your personal data through website pages that clearly disclose that you are registering for a joint event or other initiative that involves those partners. Those partners identified will only use the information as stated in the notice on the particular website page during the registration process.
We share personal data with service providers that perform services on our behalf such as payment service providers, analytics providers, hosting providers and advisers. All service providers have entered into legally binding agreements requiring them to use or disclose personal data only as necessary to perform services on our behalf and to comply with applicable legal requirements.
In addition, we will disclose personal data about you (a) if we are required or permitted to do so by law or legal process, for example due to a court order or a request from a law enforcement agency, (b) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss, (c) in connection with an investigation of suspected or actual fraudulent or other illegal activity, and (d) in the event we sell or transfer all or a portion of our business or assets (including in the event of a reorganization, dissolution, or liquidation).
When you voluntarily make your personal data available for viewing by third parties online, such as a blog or public message board, your information can be viewed, collected and used by individuals and companies outside of Telos ID. We are not responsible for any unauthorized third-party use of such information that is provided in a public forum.
- Data Transfers
We may transfer the personal data that we collect about you to recipients in countries other than the country in which the personal data originally was collected. Those countries may not have the same data protection laws as the country in which you initially provided the personal data.
If you are located in the European Economic Area (“EEA”), we will comply with applicable legal requirements providing adequate protection for the transfer of personal data to recipients in countries outside of the EEA and Switzerland. In all such cases, we will only transfer your personal data if:
- The country to which the personal data will be transferred has been granted a European Commission adequacy decision;
- The recipient of the personal data is located in the U.S. and has certified to the US-EU Privacy Shield Framework; or
- We have put in place appropriate safeguards in respect of the transfer, for example the EU Model Contracts.
You may request a copy of the safeguards that we have put in place in respect of transfers of personal data by contacting us as described in the How To Contact Us section below.
- How Long We Keep Information
The time period for which we keep personal data depends on the purpose for which we collected it. In all cases we keep it for as long as necessary to fulfill your requests or inquiries, provide services or comply with our legal obligations, resolve disputes and enforce our agreements. We will then delete the personal data, in accordance with our retention policy, unless we are legally required to retain it or if we need to retain it in order to comply with our legal obligations (for example, for tax and accounting purposes).
Subject to any applicable legal requirements, we typically retain personal data you provide to us through our Sites for the duration of our relationship with you and until we do not have any contact with you for an extended period of time.
Certain pages on our Sites contain “tracking pixels” (also known as Internet tags, pixel tags and clear GIFs). These tracking pixels allow third parties to obtain information such as IP address, the URL of the page on which the tracking pixel appears, timestamps, browser type, and the information in cookies set by the third party.
Categories of Cookies and Other Automated Technologies
- Analytics Cookies
These cookies collect information about how visitors interact with our website, such as what pages you visit and if any errors have occurred. The information is used to improve how our websites function. These cookies do not collect information that identifies you but generate statistical data about your use of our Sites. We use Google Analytics. The service registers a unique ID that is used to generate statistical data on how visitors use our Sites. If you want to opt-out of being tracked by Google Analytics on any site, you can find how to do it here.
- Functional Cookies
These cookies allow our Sites to remember choices you make and provide enhanced and more personal features. They capture information such as the pages you have browsed or products you have viewed so that we can improve your browsing experience. They can also be used to remember changes made to parts of our Sites that you can customize.
- Advertising Cookies
Advertising cookies may be used to deliver ads that we believe are relevant to your interests. We may use advertising cookies to customize the advertising and content you receive on the Sites and conduct market research. They can also be used to limit the number of times users see an advertisement as well as help measure the effectiveness of an advertising campaign. They can be placed on a device by us or by a third party with our consent.
You can manage cookies through your web browser. Most browsers will tell you how to stop accepting new cookies, how to be notified when you receive a new cookie, and how to disable existing cookies. You can find out how to do this for your particular browser by clicking “help” on your browser’s menu, going to the security section of your browser website, or by visiting www.allaboutcookies.org. Please note, however, that without cookies you may not be able to take full advantage of all our Site features.
- Your Rights and Choices
European Economic Area (“EEA”) or Switzerland
If you are located in the European Economic Area (“EEA”) or Switzerland, you may have the following rights in relation to personal data that we hold about you:
- To request confirmation of whether we process personal data relating to you, and if so, to request a copy of that personal data;
- To request that we rectify or update your personal data that is inaccurate, incomplete or outdated.
- To request that we erase your personal data in certain circumstances, such as where we collected personal data on the basis of your consent and you withdraw your consent;
- To request that we restrict the use of your personal data in certain circumstances, such as while we consider another request that you have submitted, for example a request that we update your personal data;
- To object to our processing of personal data on grounds relating to your particular situation;
- Where you have given us consent to process your personal data, to withdraw your consent; and
- To request that we provide a copy of your personal data to you in a structured, commonly used and machine readable format in certain circumstances.
You may contact us by email or as described in the “How to Contact Us” section below to exercise your rights described above.
You also have the right to lodge a complaint with the data protection supervisory authority in your country.
Nevada and Other States with Similar Privacy Rights
If you reside in Nevada or another state with similar privacy rights, you have the right to request information from us, as well as the rights outlined above. Under applicable law, you have the right to send us a request to receive the following information:
The categories of information we collected;
The categories of third parties with whom your information may have been shared; and
A disclosure concerning whether a third party may have collected information about your online activities in connection with your use of our Sites.
For users who reside in California, please see our California Privacy Notice.
- Updates to our Online Privacy Notice
This Online Privacy Notice may be updated periodically and without prior notice to you to reflect changes in our personal data practices. We will post the updated version on our Sites and indicate at the top of the notice when it was most recently updated.
- Children’s Online Privacy Protection
We do not knowingly solicit information from children and we do not knowingly market the Site or its services to children. No one under the age of 15 should submit any personal data to us and/or the Sites. If we become aware that a person submitting personal data to us through any part of the Sites is a child, the information will be deleted immediately. Therefore, we do not retain any information about children that can be reviewed or deleted. If a parent discovers that we have inadvertently retained information on his or her child before we have discovered and deleted it, then we will honor any requests that the information be deleted.
- How to Contact Us
If you have any questions or comments about this Notice or any issue relating to how we collect, use, or disclose personal data, or if you would like us to update information we have about you or your preferences, you may contact us:
By e-mail at: firstname.lastname@example.org
By phone at: (703) 724-3756
(800) 283-0105 (Toll Free)
In writing at:
Attention: Privacy Officer
19886 Ashburn Road
Ashburn, VA 20147
CALIFORNIA PRIVACY NOTICE
This California Privacy Notice supplements the information contained in the Privacy Notice of Telos Identity Management Solutions, LLC and its subsidiaries and affiliates (collectively, “Telos ID,” “we,” “us,” or “our”) and applies solely to users or consumers who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws. Any terms defined in the CCPA have the same meaning when used in this notice.
- Information We Collect About You
We collect and use the following personal data that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household or device (“personal data”). In particular, we have collected the following categories of personal data from consumers within the last twelve (12) months:
|Categories of Personal Data||Specific Types of Personal Data Collected||Collected|
|A. Identifiers||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||Yes|
|B. Personal data categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))||A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal data included in this category may overlap with other categories.||Yes|
|C. Protected classification characteristics under California or federal law||Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).||Yes|
|D. Commercial information||Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.||Yes|
|E. Biometric information||Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.||Yes|
|F. Internet or other similar network activity||Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.||Yes|
|G. Geolocation data||Physical location or movements.||Yes|
|H. Sensory data||Audio, electronic, visual, thermal, olfactory, or similar information.||No|
|I. Professional or employment-related information||Current or past job history or performance evaluations.||Yes|
|J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99))||Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.||No|
|K. Inferences drawn from other personal data||Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.||No|
We obtain the categories of personal data listed by the following means:
- Directly from you in person, by telephone, text or email and through our Sites.
- Directly and indirectly from your activity on our Sites, such as from submissions through our Sites or website usage details collected automatically like cookies.
- Directly or indirectly from third-parties that interact with us in connection with the services we perform or with your consent.
- Use of Personal Data
We may use or disclose the personal data we collect for one or more of the following business purposes:
- To fulfill or meet the reason for which the information is provided. For example, if you provide us with personal data in order to register for an event, we will use that information to register you and make appropriate preparations.
- To provide you with information, products or services that you request from us.
- To provide you with email alerts, event registrations and other notices concerning our products or services, or events or news, that may be of interest to you.
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections.
- To carry out our reporting obligations to state and federal regulators.
- To improve our website and present its contents to you.
- To detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and prosecute those responsible for that activity.
- To debug, and identify and repair errors that impair existing intended functionality.
- For testing, research, analysis and product development.
- As necessary or appropriate to protect the rights, property or safety of us, our clients or others.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- As described to you when collecting your personal data or as otherwise set forth in the CCPA.
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal data held by us is among the assets transferred.
We will not collect additional categories of personal data or use the personal data we collected for materially different, unrelated, or incompatible purposes without providing you notice.
- Sharing Personal Data
We may disclose your personal data to a third party for a business purpose. When we disclose personal data for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal data confidential and not use it for any purpose except performing the contract.
In the preceding twelve (12) months, we have disclosed the following categories of personal data for a business purpose:
Category A: Identifiers.
Category B: California Customer Records personal data categories.
Category C: Protected classification characteristics under California or federal law.
Category D: Commercial Information
Category E: Biometric Information
Category F: Internet or other similar network activity
Category G: Geolocation Data
Category I: Professional or employment-related information.
We disclose your personal data for a business purpose to the following categories of third parties:
- Our subsidiaries and affiliates.
- Service providers.
- Third parties to whom you or your agents authorize us to disclose your personal data in connection with products or services we provide to you.
We DO NOT sell any personal data.
- Your Rights and Choices
The CCPA provides consumers (California residents) with specific rights regarding their personal data. This section describes your CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
You have the right to know:
- The categories of personal data we collected about you.
- The categories of sources for the personal data we collected about you.
- Our business or commercial purpose for collecting or selling that personal data.
- The categories of third parties with whom we share that personal data.
- The specific pieces of personal data we collected about you (also called a data portability request).
If we sold or disclosed your personal data for a business purpose, you have the right to know;
- For sales, the categories of personal data and the categories of third parties to whom the personal data was sold; and
- For disclosures for a business purpose, the categories of personal data.
Please note that we are not required to:
- Retain any personal data about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained;
- Re-identify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal data; or
- Provide the personal data to you more than twice in a 12-month period.
Deletion Request Rights
You have the right to request that we delete any of your personal data that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal data from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service providers to do any of the following:
- Complete the transaction for which we collected the personal data, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by phone, mail or email. See “How to Contact Us”.
Only you or a person registered with the California Secretary of State that you authorize to act on your behalf may make a verifiable consumer request related to your personal data. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal data or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal data if we cannot verify your identity or authority to make the request and confirm the personal data relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal data provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the receipt of the verifiable consumer request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal data that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
- Changes to Our Privacy Notice
We reserve the right to amend this privacy notice at our discretion and at any time. We will post the updated version on our Sites and indicate at the top of the notice when it was most recently updated.
- How to Contact Us
If you have any questions or comments about this Privacy Notice, the ways in which we collect and use your personal data, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:
By e-mail at: email@example.com
By phone at: (703) 724-3756
(800) 283-0105 (Toll Free)
In writing at:
Attention: Privacy Officer
19886 Ashburn Road
Ashburn, VA 20147