Effective as of August 29, 2022

Privacy and Cookie Notice

Your privacy is important to Perosphere Technologies Inc. and its affiliates (hereinafter "we" and/or "us" and/or “Perosphere”) and we recognise the responsibility you entrust us with when providing your personal data.

This Privacy and Cookie Notice explains how we handle and treat your personal data when you visit our site: https://perospheretech.com or https://perospheretech.eu or associated sites or pages (hereinafter the ‘Website").  The purpose of this Privacy and Cookie Notice is to provide you with a clear explanation of what personal data we collect, when, why and how we collect, use and share your personal data and an explanation of your statutory rights.

We strongly urge you to read this Privacy and Cookie Notice and make sure you fully understand our practices in relation to personal data before you access or use our Website. If you read and fully understand this Privacy and Cookie Notice, but remain opposed to our practices, you must immediately leave our Website, and avoid or discontinue all use of any of our services. Where you have read this notice but would like further clarification, please contact us at info@perospheretech.com

Our Website is not intended for use by children under 16 years old and we do not knowingly process personal data about children under 16 years old. Parents and guardians should supervise their children's activities at all times. If we learn we have collected or received personal data from a person under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a person under 16, please contact us at info@perospheretech.com

If you are located in the European Economic Area or the United Kingdom, please consult the EEA/UK GDPR supplemental notice below.

1

What personal data do we collect, how do we collect it and how do we use it?

With your permission where it is required by applicable laws, we and/or our business partners may collect, by automated means, information from your browser and device through cookies and other tracking technologies (hereinafter “cookies”).

What are cookies?

Cookies are small data files containing a unique identifier that are placed on your computer or mobile device when you visit a wWebsite. Cookies and similar technologies (which include pixels, tags, web beacons and software development kits (“SDKs”) and local browser storage technologies) (together “cookies”) enable operators of website/apps to recognize your device and collect information from it when you interact with them. The information that may be collected automatically 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, IP address, the website you visited before browsing to our Website, general location information such as city, state or geographic area; and information about your use of and actions on our Website, such as pages or screens you viewed, 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. Our business partners may collect this type of information over time and across third-party websites and mobile applications.

Who places cookies on your device?

When you visit our Website, both first-party cookies and third-party cookies may be placed on your device:

  • First party cookies, served directly by us to your computer or mobile device, which we use to recognize your computer or mobile device when it revisits our Website; and 

  • Third party cookies, which are served by service providers or business partners on our Website, can be used by these parties to recognize your computer or mobile device when it visits other websites. Third party cookies can be used for a variety of purposes, including website analytics, advertising and social media features. We do not control how these third parties use your information, which is subject to their own privacy policies.

What types of cookies and similar tracking technologies are used on the Website and why?

The cookies used on our Website are categorised as follows:

Strictly necessary cookies are necessary for the Website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the Website will not then work.In particular, we use these strictly necessary cookies to remember your privacy choices and for security purposes. If you prevent these cookies, we cannot guarantee how the Website or the security on the Website will perform during your visit.

Purpose

This cookie is set by Google. These cookies help collect data to understand how users interact with the Website.

First/Third Party Cookie

Third Party Cookie

Name

klaro

Lifespan of the cookie

Please note that strictly necessary cookies do not require your consent.

Performance/analytics cookies collect information about how you use our Website (e.g., which pages you visit and if you experience any errors). These cookies are used to help us improve how our Website works, understand what interests our users and measure how effective our content is. Some of our performance/analytics cookies are managed for us by third parties.

Purpose

This cookie is set by Google. These cookies help collect data to understand how users interact with the Website.

First/Third Party Cookie

Third Party Cookie

Name

_ga

_ga_3SELHZSNXG

Lifespan of the cookie

Please note that we request your consent before placing performance/analytics cookies on your device. You can give your consent by clicking on the appropriate button on the banner displayed to you. If you wish to withdraw your consent at any time, you will need to delete and block or disable cookies via your browser settings (please see below for more information on how to do this). Please note that disabling these cookies will affect the functionality of the Website and may prevent you from being able to access certain features on the Website.


Change your cookies settings from your browser

Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. Please note that if you set your browser to disable cookies, the Website may not work properly.


For more information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org. If you do not accept our cookies, you may experience some inconvenience in your use of our Website. For example, we may not be able to recognize your computer or mobile device and you may need to log in every time you visit our Website.

2

With Whom Do We Share your Personal Data?

We share your personal data with third parties only where it is necessary for purposes described in this Privacy and Cookie Notice. We may share your personal data with the following categories of third parties:

  • Affiliates: We may share your personal data with our corporate parent, subsidiaries, and affiliates.

  • Business partners / Services providers: We may transfer your personal data to our business partners / service providers as necessary for them to provide services to us in connection with our fulfilment of the purposes set out above. Our business partners / service providers include, without limitation, Klaro and Google.

  • Government Agencies, Regulators and Professional Advisors: Where permitted or required by applicable law, we may also need to transfer your personal data to government agencies and regulators (e.g., tax authorities, courts, and government authorities) to comply with our legal obligations, and to external professional advisors as necessary to defend our legal interests.

  • Organizations Involved in Business Transfers: In the event of a merger, reorganization, dissolution or similar corporate event, or the sale of all or substantially all of our assets, we expect that the information that we have collected, including personal data, will be transferred to the surviving entity in a merger or the acquiring entity. Such information will be transferred in accordance with applicable law.

3

How Do We Protect Personal data?

We have implemented certain information security policies, rules and technical measures that are designed to protect the personal data that we have under our control from unauthorised access, improper use or disclosure, unauthorised modification and unlawful destruction or accidental loss.  We will notify individuals and any applicable regulator of a breach where we are legally required to do so.

4

How long do we keep your personal data?

We may retain your personal data as long as necessary for the purpose for which it was collected, and beyond such time to the extent legally permitted and based on our legal obligations or legitimate interests (e.g., in retaining data for the purposes of responding to possible disputes or complaints).

5

Your Privacy Rights

Under applicable laws, you may have rights to access, update, rectify, or erase certain personal data that we have about you or restrict or object to certain activities in which we engage with respect to your personal data. If you have such rights and your request complies with the requirements under applicable laws, we will give effect to your rights as required by law.

To exercise any rights you may have under applicable privacy laws, please contact us using the details in the “Contact Us” section below. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

6

Do Not Track

Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit.  We currently do not respond to “Do Not Track” or similar signals.  To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

7

International Data Transfers

Your personal data may be transferred and stored outside your place of residence, that are subject to different standards of data protection. In particular, you should be aware that your personal data may be shared with, and transferred to Perosphere, Perosphere’s affiliates and third-party busines partners / service providers who are located outside the European Economic Area (EEA) or the United Kingdom. We will take appropriate steps to ensure that transfers of personal data are in accordance with applicable laws.

8

Links to Other Websites

Our Website may contain links to other websites, which may have privacy policies or notices that differ from ours. We are not responsible for the collection, processing or disclosure of personal data collected through other websites. We are also not responsible for any information or content contained on such websites. Links to other websites are provided solely for convenience. Your usage and browsing on any such website are subject to that website’s own policies. Please review the privacy policies or notices  posted on other websites that you may access through our Website. We may provide you with additional or different privacy policies or notices in specific instances which describe how your personal data is collected and used for a specific service.


9

Changes to this Privacy and Cookie Notice

We may make changes to this Privacy and Cookie Notice from time to time. To ensure that you are aware of how we use your personal data, we will update this Privacy and Cookie Notice from time to time to reflect any changes to our use of your personal data. We may also make changes as required to comply with changes in applicable law or regulatory requirements. Please regularly check these pages for the latest version of this Privacy and Cookie Notice.

10

Contact us

You may contact us using the following details:

  • Email address: info@perospheretech.com

  • Postal address: Perosphere Technologies Inc., 108 Mill Plain Road, Suite 301 Danbury, CT 06811 Changes to this Privacy and Cookie Notice

EEA/UK GDPR supplemental notice

If you are located in the European Economic Area or the United Kingdom, and access our Website, this EEA/UK GDPR supplemental notice applies to you.

1

Who is the Controller?

Perosphere Technologies Inc., located at 108 Mill Plain Road, Suite 301 Danbury, CT 06811, is the controller of your personal data.

2

What Are Our Legal Bases for Processing Personal Data?

Purposes of processing

To understand what may be of interest to you, deliver relevant website content to you, to measure or understand the effectiveness of the content we serve to you, and to use data analytics to improve our Website.

Legal basis

Your consent

3

Your rights

  1. You have the following rights in relation to the personal data we hold about you:

  • Right of access: you can ask us to provide you with information about our processing of your personal data and give you access to your personal data;

  • Right to rectification: If the personal data we hold about you is inaccurate or incomplete, you are entitled to request to have it rectified;

  • Right to erasure: You can ask us to delete or remove personal data where there is no lawful reason for us to continue to store or process it, where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons that will be notified to you, if applicable, at the time of your request;

  • Right to restrict processing: you can ask us to suspend the processing of your personal data if, (i) you want us to establish the data's accuracy; (ii) where our use of the data is unlawful but you do not want us to erase it; (iii) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (iv) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. 

  • Right to object: Where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation that makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. 

  • Right to data portability: You have the right, in certain circumstances, to ask us to provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you. 

  • Right to withdraw consent at any time: where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. 

Please note that some of these rights may be limited where we have an overriding interest or legal obligation to continue to process the personal data or where certain exemptions apply. 

To exercise any of these rights, please contact us using the contact details provided above.

Although we urge you to contact us first to find a solution for every concern you may have, you always have the right to lodge a complaint with your competent data protection authority.

4

How Do We Protect Personal Data if we transfer it internationally?

We may transfer your personal data outside of the EEA and/or UK. Some of these recipients are located in countries in respect of which either the European Commission and/or UK Government (as and where applicable) has issued adequacy decisions, in which case, the recipient’s country is recognized as providing an adequate level of data protection under UK and/or European data protection laws (as applicable) and the transfer is therefore permitted under Article 45 of the GDPR.


Some recipients of your personal data may be located in countries outside the EEA and/or the UK for which the European Commission or UK Government (as and where applicable) has not issued adequacy decisions in respect of the level of data protection in such countries (“Restricted Countries”). For example, the United States is a Restricted Country. Where we transfer your personal data to a recipient in a Restricted Country, we will either:

  • enter into appropriate data transfer agreements based on so-called Standard Contractual Clauses approved from time-to-time under GDPR Art. 46 by the European Commission, the UK Information Commissioner’s Office or UK Government (as and where applicable); or

  • rely on other appropriate means permitted by the EU/UK GDPR, which establish that such recipients will provide an adequate level of data protection and that appropriate technical and organizational security measures are in place to protect personal data against accidental or unlawful destruction, loss or alteration, unauthorized disclosure or access, and against all other unlawful forms of processing.

You may ask for a copy of such appropriate data transfer agreements by contacting us using the contact details above.