Legal & Compliance

Privacy Policy

CHAINBRIDGE SOLUTIONS

PRIVACY POLICY

Introduction

Chainbridge Solutions Incorporated (“Chainbridge” or “We”) is a Virginia corporation offering workforce security software solutions. Our solutions have been rigorously tested and implemented across numerous government agencies and organizations, incorporating optimal workflows that align with government regulations and industry best practices.

We respect your privacy and are committed to protecting it through our compliance with this policy. This policy describes the types of information we collect from you or that you provide when you visit our website, https://chainbridgesolutions.com and our practices for collecting, storing, using, maintaining, protecting, and disclosing that information.

By using our services and/or making the choices you made when registering with us, you acknowledge that you have read and accepted the terms of this Privacy Policy, and you are consenting to our collection, protection, use, retention, and disclosure, subject to the terms and conditions set-forth below in this Policy, of your personal and business information, as applicable. If you elect to not provide the information we require, we may not be able to provide our service to you.

If you do not agree to the terms of this Privacy Policy, please do not use our website or our service. We may make changes to this Privacy Policy from time to time. Your continued use of our website and service following the posting of any changes to this Privacy Policy will indicate your acceptance to these changes. We will post any Privacy Policy changes on this page. Please check back frequently to see any changes.

Information Collected

When you use the website or utilize our services, we may request, and you may provide your personal information to us. As detailed below, the type of user information collected may vary based on how it was gathered, but may include your name, email address, telephone number, and other information that you voluntarily submit (e.g., when contacting us via the website), as well as information automatically collected about your usage of the website (e.g., the content that you choose to view).

Voluntary Submission

We may collect user information that is voluntarily provided by you or with your permission. For example, we collect certain nonpublic personal information about you from information that you provide when you sign up for our service or when you complete a contact form on our website (such as your name, email address and telephone number). Some of this information is submitted directly by you, while at other times it may be collected automatically.

You can manage and change your preferences as outlined below. If you choose not to provide the information we request, you can still visit the website, but you may be unable to access certain options and services. When you provide information to us in any other manner, you agree to provide only true, accurate, current and complete information.

Third Party Service Providers

We may use a third party service provider, e.g., Stripe, Inc. (“Third Party Service Provider”). For your protection, our Third-Party Service Provider uses various fraud prevention protocols and industry standard verification systems to reduce fraud and you authorize it to verify and authenticate your payment information. You agree to be bound by our Third Party Service Provider’s privacy policy and Terms of Service when you purchase our products and services.

Non-Personal Information from Website Visitors

We may collect the following non-personal information on an aggregate basis when visitors visit our website:

  • Visitors’ Internet Protocol (IP) addresses
  • Geographic location of visitors
  • Web browser visitors are using
  • Operating system used by visitors
  • Keywords or search terms used by visitors to find our website
  • Overall number of visitors viewing the website or specific web pages

Our website uses Google Analytics, a web analytics service provided by Google LLC (“Google”). Google Analytics currently uses “cookies,” which are text files placed on your computer, to help analyze how visitors use our website. We use Google Analytics to collect information about the computer or mobile device you use to access the website, such as the operating system and location information based on your IP address.

Cookie Policy

A cookie is a small data file that is written to your computer’s hard drive by your web browser. A cookie file can contain and/or automatically collect information, such as a user identification code or IP address, that a website will use to track the pages and number of times you have visited. The data read from these cookies may be linked to personally identifying (PII) and non-personally identifying (non-PII) information.

We and our partners use cookies and similar technologies on the website to personalize and optimize your browsing experience and the website by:

  • Safeguarding against spam and malware
  • Analyzing trends, traffic, and user behavior
  • Administering the website
  • Gathering demographic information about our user base as a whole
  • Performing location-related functionalities and analytics
  • Participating in market research (e.g., website ratings)
  • Educating ourselves about how we can continue to improve the Website and its various elements

Essential Cookies: Certain cookies are used for specific purposes that are essential to your secure use and navigation of the website. Without them, we may not be able to provide core website functions and features to you, and the website would not operate as well as you or we would like. These cookies collect and use information such as your server preferences, single-session data and corresponding identifier, web beacons and log files (detailed below), and other credential-related information. For EU individuals, essential cookies also help inform us whether you require, or have already been served, an affirmative consent request in connection with the GDPR. Essential cookies include analytics cookies, which provide us data that allows us to better understand our users and improve the website based on what we have learned from that data.

You can prevent Google from collecting and processing the data generated by the cookie and relating to your use of our website (including your IP address) by downloading and installing the browser plug-in available at the following link. Clicking the link sets an opt-out cookie that prevents future collection of your information when you visit this website: https://tools.google.com/dlpage/gaoptout

For more information on the terms of use and privacy regarding Google Analytics, please visit https://marketingplatform.google.com/about/analytics/terms/us/. Please note that on the website, Google Analytics has been extended by the code “anonymizeIP” in order to guarantee an anonymous registration of IP addresses (sometimes known as “IP masking”).

We encourage you to consider keeping your cookies enabled, as if you choose to disable the receipt of cookies from our website, you may not be able to use or benefit from certain features of the website, particularly the features that are designed to personalize your experience.

Web Beacons

We may use web beacons (invisible images often referred to as pixel tags or clear GIFs) on the website in order to recognize users, assess traffic patterns, identify preferred content and measure site engagement. We may also include web beacons in our e-mail messages in order to count how many e-mail messages have been opened.

We and our partners also use web beacons to collect various data provided by your browser while you are on our website. This data is collected in the aggregate, but may include or be associated with other non-PII or PII that users have voluntarily submitted.

Log Files

The website’s web servers log information about a user’s IP address, browser type and the current URL the user is requesting. This information is always provided by a user’s browser and automatically logged by most websites. These log files are stored in a secure location and used in our internal analysis of traffic patterns within our website.

CHILDREN’S INFORMATION

Our website is intended for use by adults over the age of 18. Chainbridge does not intentionally or knowingly collect, use, or process the personal information of children under the age of 16, and such children are not permitted to use our website or the service. If you are under the age 18, do not attempt to register for or use any of our services and do not provide us personal information about yourself. By signing up for an account or subscription with us or otherwise using our Service, you acknowledge you are an adult over 18 years of age and are permitted to use our Service in accordance with our Privacy Policy. If you are a parent or guardian and you are aware that your child has violated this Privacy Policy and provided us with Personal Information, please contact us and we will take measures to remove that information from our servers.

USE OF YOUR INFORMATION

To Provide Interactive Communications from the Website

To enhance your experience, we provide you with the ability to contact us via our website with any questions you may have. If you choose to contact us, you will be asked to provide your name, email address and telephone number. Once we have that information, it is stored on our servers. We use the information to respond to you as requested and, from time to time, we may provide e-mails highlighting new product offerings or new website content to those users who have expressly provided us with their permission to send such communications as part of their user profile.

Sharing of Information

We restrict access to nonpublic personal information about you to those employees who need to know that information to provide requested or responsive information to you. You may be requested to voluntarily provide certain user information during your use of the website. If you choose to do so, that user information may be shared with us as well as vendors providing hosting and other services for us.

We also use third party administrative support providers, such as e-mail service providers and hosting services on the website. We require these outside firms and agents to protect the confidentiality of your information and not to use it for any purpose.

We do not sell, rent or share your information with third parties for promotional or advertising purposes.

In the Event of Sale or Bankruptcy

The ownership of the website may change at some point in the future. Should that occur, we want this site to be able to maintain a relationship with you. In the event of a sale, merger, public offering, bankruptcy or other change in control of our company, your information may be shared with the person or business that owns or controls this site.

As Required By Law

We may disclose your personal information if required to do so by law such as to comply with a subpoena or in the good faith belief that such action is necessary to conform to the edicts of the law, protect your safety or the safety of others, investigate fraud or comply with a judicial proceeding, court order or legal process served on us or to protect and defend the rights or our property.

SECURITY

We care about the protection of your user information and use industry standard safeguards to do so. That said, no data transmission on the Internet is guaranteed to be 100% secure.

Your information is stored on our servers located in the United States. We use industry standard physical, electronic, and organizational safeguards to protect your user information against loss or theft as well as unauthorized access and disclosure to protect your privacy. We treat data as an asset that must be protected against loss and unauthorized access. We employ many different security techniques to protect such data from unauthorized access by users inside and outside of our company. However, “perfect security” does not exist on the Internet. If you are concerned that your privacy may have been breached, please contact us as provided below.

YOUR PRIVACY RIGHTS

California Privacy Rights

Under the California Consumer Privacy Act (CCPA), California consumers have a right to knowledge, access, and deletion of information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with them or their household. California consumers also have a right to opt out of the sale of this information by a business and a right not to be discriminated against for exercising one of their California privacy rights. Noetic does not sell this information in relation to California consumers and does not discriminate in response to privacy rights requests.

We provide notice of our privacy practices in this Privacy Policy. The Privacy Policy includes what personal information is collected, the source of the information, and the purposes of use, as well as whether we disclose that personal information and if so, the categories of third parties to whom it is disclosed.

California consumers can exercise their privacy rights by contacting us at [email protected]. We will ask you for information which we consider necessary to verify your identity for security and to prevent fraud. This information may include name, contact information, and information related to your relationship with us, but the specific information requested may differ depending on the circumstances of your request for your security and to protect privacy rights. If we delete your personal information, we will both render certain personal information about you permanently unrecoverable and also de-identify certain personal information.

Under the CCPA, a California consumer may use an authorized agent to make a CCPA privacy request on the consumer’s behalf. To make a request on behalf of a Chainbridge Solutions site user, the authorized agent must first provide a copy of a valid power of attorney issued pursuant to California Probate Code sections 4000 to 4465. The authorized agent must email this document to [email protected] and include a phone number where the agent may be reached during regular business hours.

Colorado Privacy Act

To the extent any Colorado data privacy law applies to the collection of your Information, this supplemental section of our Privacy Policy outlines the individual rights guaranteed to Colorado residents and how to exercise those rights and applies solely to Colorado residents.  We provide the supplemental section below to comply with the Colorado Privacy Act (“CPA”) and any terms defined in the CPA have the same meaning when used below.

Your rights under CPA

Subject to certain exceptions, you may be entitled to the following rights:

  • Right to Access & Data Portability: You have the right to request that we disclose certain information to you about our collection and use of your Personal Information at any time.  Once we receive and confirm an authenticated consumer request from you, we will, subject to certain exceptions:
    • Disclose whether we are processing your Personal Information.
    • Provide you with access to your Personal Information where we process it.

Where exercising your right to access, you have the right to request and obtain a copy of your Personal Information that you previously provided to us in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the Information to another data controller without hindrance (“data portability”).

  • Right to Correct Inaccurate Information: To the extent that we may maintain inaccurate Personal Information, you have the right to request that we correct such inaccurate Personal Information taking into account the nature of the Personal Information and the purposes of the processing of the Personal Information.  Once we receive and verify your authenticated consumer request, we will use commercially reasonable efforts to correct your Personal Information.
  • Right to Delete: You have the right to request that we delete certain of your Personal Information provided by or obtained about you.  To the extent that we can delete your Personal Information, once we receive and confirm your authenticated consumer request, we will delete your Personal Information, subject to certain exceptions.
  • Sale of Personal Information, Targeted Advertising, Profiling, and the Right to Opt Out: You have the right to opt out of the processing of your Personal Information for the following purposes:
    • Targeted advertising.
    • Sale of your Information.
    • Profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.

You may make an authenticated consumer request free of charge under the CPA once within a twelve (12) month period.  We reserve the right to charge a reasonable fee for a second or subsequent request within the same twelve (12) month period. To exercise the rights described above, see the Exercising Your Rights section below.

Sensitive Data

We do not process sensitive data including sensitive data inferences.  When we process sensitive data, we do so with your consent.

Authorized Agent

You may use an authorized agent to submit verifiable consumer requests on your behalf.  An authorized agent is a natural person or a business entity that you have authorized to act on your behalf.  If you use an authorized agent, we will require: (1) proof of written permission for the authorized agent to make requests on your behalf, and identity verification from you; or (2) proof of power of attorney pursuant to Colo. Rev. Stat. § 15-14-705.  We may deny a request from an authorized agent that does not submit proper verification proof.

Notice of Financial Incentive

As an incentive for providing us with your Personal Information, you may receive a financial benefit as part of our bona fide loyalty program in the form of an email coupon, discount, rebate, free sample, promotions, or other similar reward that will be sent to you.  This discount may constitute a financial incentive under the Consumer Privacy Act (“Financial Incentive”).  The categories of Personal Information required for us to provide the Financial Incentives include personal identifiers such as full name and contact information including email address as well as personal and demographic information you choose to provide.

To offer these discounts, we may track your Personal Information, such as purchase history and other demographic data.  You have the right to withdraw from the Financial Incentive at any time by submitting a request to [email protected].

Please note that if you request deletion of part or all your Personal Information, that could affect your ability to qualify for the discount.

Cross-border Transfers – General Data Protection Regulation

This Privacy Statement and its enumerated policies are intended to comply with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (the “General Data Protection Regulation” or “GDPR”) and provide appropriate protection and care with respect to the treatment of your user information in accordance with the GDPR.

Your user information may be transferred to other countries in connection with your use of the website. If you access or use the website outside of the United States, your user information will be transferred to our servers in the United States.

Our legal ground for processing: As outlined in this Privacy Statement, We will not process your user information without a lawful basis to do so, as such bases are defined in Article 6 of the GDPR. In general, we will process your user information on the legal bases of consent, contract (if you have entered into an agreement with us and such processing is a necessary part thereof), or legal obligation (as noted above). We may also process certain user information on the basis of the following legitimate interests, provided that such interests are not overridden by your privacy rights and interests: delivering and continuing to develop and improve the website, learning from your behavior on the website (e.g., analyzing traffic) to better serve you and other website users, helping us modify or enhance the website and its content, receiving insight as to what users do (and don’t) like about our website or aspects thereof, and providing a stable, consistent, and secure user experience in connection with the website. Where it is not an obligation to provide the personal data we have explained the possible consequences if you choose not to. We will use standard contractual clauses as a safeguard for transferring your user information to third parties.

Your Rights:

Right to access: You have the right to request information about the personal data we hold on you at any time. You can contact us and we will provide you with your personal data.

Right to portability: Whenever we process your personal data by automated means based on your consent or based on an agreement you have the right to get a copy of your data in a structured, commonly used and machine-readable format transferred to you or to another party. This only includes the personal data you have submitted to us.

Right to rectification: You have the right to request rectification of your personal data if it is incorrect, including the right to have incomplete personal data completed. If you have an account you can edit your personal data under your account and membership pages.

Right to erasure: You have the right to erase any personal data processed by us at any time except for the following situations:

• you have an ongoing matter with Customer Service.

• you have an open order which has not yet been shipped or partially shipped

• you have an unsettled debt with us, regardless of the payment method

• if you are suspected or have misused our services within the last four years

• your debt has been sold to a third party within the last three years or one year for deceased customers

• your credit application has been rejected within the last three months

• if you have made any purchase, we will keep your personal data in connection to your transaction for bookkeeping rules

Your right to object to processing based on legitimate interest: You have the right to object to processing of your personal data that you believe is not based on our legitimate interest. We will suspend processing of the personal data unless we can demonstrate a legitimate ground for the process which overrides your interest and rights or due to legal claims.

Right to restriction: You have the right to request that we restrict the processing of your personal data under the following circumstances:

• if you object to a processing based on our legitimate interest, we shall suspend all processing of such data pending the verification of the legitimate interest.

• if you claim that your personal data is incorrect, we will restrict all processing of such data pending the verification of the accuracy of the personal data.

• if the processing is unlawful you can oppose the erasure of personal data and instead request the restriction of the use of your personal data instead

• if we no longer need the personal data but it is required for you to make of defending legal claims.

How can you exercise your rights?: We have dedicated personnel who handle your requests in relation to your rights stated above. You can reach them at: [email protected]

Right to complain to a Supervisory Authority: In addition to contacting us, if you believe we are processing your personal data in an incorrect way you have the right to complain to a Supervisory Authority.

Your Rights Under Canada’s Personal Information Protection and Electronic Documents Act

We intend to allow Canadian residents to exercise their rights under the Personal Information Protection and Electronic Documents Act (“PIPEDA”), Alberta’s Personal Information Protection Act (Alberta PIPA), British Columbia’s Personal Information Protection Act (BC PIPA), and Québec’s Act respecting personal information in the private sector (Quebec Act) as applicable. Although applicable data protection legislation in relevant jurisdictions may afford similar rights, there may be circumstances where some of these rights do not apply under or are modified by, local law. Chainbridge takes reasonable steps to allow you to correct, amend, and delete your personal information, and exercise other rights available under applicable law. We therefore inform you that, where applicable under relevant law, you may be entitled to the following:

  • Right to Access / Disclosure: The right to have access to your personal data upon simple request – that is, you may receive a copy of such data upon receipt of a verifiable request, along with other information related to the processing.
  • Right to Correction/Rectification: The right to correct your personal data if you find it is inaccurate, incomplete or obsolete.
  • Right to Deletion: The right to obtain the deletion of your personal data in the situations set forth by applicable data protection law.

How to Contact Us

If you have any questions regarding this Privacy Statement or how to remove or modify your user information or related consents, please feel free to contact us by e-mail at [email protected]. If you would like to raise an issue or lodge a complaint directly with Chainbridge, please contact us using the information below:

Chainbridge Solutions

12701 Fair Lakes Circle, Suite 300

Fairfax, VA 22033

How Will I Know if the Privacy Statement Is Changed?

If we make any material changes, we will notify you by means of a notice on our website prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

This Privacy Statement only covers our website and our collection and use of your information. Any links from our website to other websites, such as to any of our partners or providers are not covered by this Privacy Statement, unless explicitly stated to apply. This Privacy Statement does not apply to the activities of any third parties who may collect your user information while accessing or using such third party’s services in connection with your use of our website. We encourage you to read and review the privacy statements of each third party service that you may choose to use in connection with the website.

Note on Translated Version(s): For your convenience, we may make translated versions of this Privacy Statement available on the website. In the event that the terms of any such translated version conflict with the terms of the English version, the terms of the English version of this Privacy Statement will control in all instances.

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