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                                     Statement of Privacy

PHT Security ("we," "us" and/or "our") is committed to protecting the privacy and security of your personal data. We are the data controller in respect to the personal data we process about you in relation to our business development and marketing activities.

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Our office is at:

800 W El Camino Real.

Suite 180

Mountain View, CA 94040

(650) 789-3969

info@phtsecurity.net

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This privacy notice describes how we collect and process your personal data as part of our sales and marketing activities, in accordance with the California Consumer Protection Act (CCPA). We may update this notice at any time and should we do so, this will be updated here. If you become a client, we will provide you with further details via a contract informing you how we will process your data.


This privacy notice will explain:

1) Personal Data.  This is defined in the CCPA and includes any information about a person who can be identified directly or indirectly from it, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or one or more personal factors. Practical examples are your name, address email address or details set out on a business card.

2) Which categories of personal data PHT Security may hold about you.  These are the categories: 

 

Name

Company/Organization

Role

Address

Email Address

Telephone Number


3) ​How your personal data is collected.  We collect personal data for sales and marketing purposes from the following places:

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Directly from you.

​From a publicly available source such as LinkedIn and company websites.

4) How we will use your personal data.  
We will use your personal data for a range of purposes as set out below:

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​To keep you informed of new PHT Security products and services.

To handle internal billing and accounting.

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5) The legal basis for our processing of your personal data.

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Processing is necessary for the purposes of the legitimate interests pursued by PHT Security, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject.

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6) With whom we will share your personal data.

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PHT Security will process your personal data internally and only for the purposes set out above. However, on limited occasions we could share your personal data with partners and suppliers such as those below:

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Partner organizations including software companies, managed service providers and consulting firms

Accounting, auditing, or law enforcement agencies

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7) Where we will store your personal data.

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We store all personal data according to HIPPA, SOX, FIPS, and CCPA guidelines under the adoption of strict organizational and technical measures designed to keep your personal data secure. 

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8) How long we will retain your personal data.

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We will retain your personal data for as long as is necessary to fulfill the purposes for which we collected it.  We would like to retain your personal information on file for up to 1.5 years from the date we last communicated with you, on the basis that we seek to build an ongoing relationship with you to understand how PHT Security and services can help provide solutions to your business.


9) What we have done to keep your personal data secure.

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We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit 
access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data per our instructions, and they are subject to a duty of confidentiality. 
Procedures are in place to deal with any suspected data security breach and we will notify you and any applicable regulator of a suspected breach where we are 
legally required to do so.

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10) What your rights are. 

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You have the rights to:

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Request a copy of your personal data that PHT Security holds about you.
Request that PHT Security correct any personal data if it is found to be inaccurate or out of date. In certain circumstances you have the right to ask us to erase the personal data we PHT Security holds about you. Such circumstances include (a) where we no longer need your personal data for the purposes set out above; (b) if you object to our processing based on our legitimate interest and we have no overriding legitimate grounds to continue processing your personal data; (c) if we process the data unlawfully; or (d) where the personal data has to be erased to comply with legal obligation to which we are subject. We will consider any such request in line with CCPA violatons. Please note this is not an absolute right and there may be circumstances where we choose not to delete all of the personal data we hold about you. More information about your right of erasure can be found at

 

https://oag.ca.gov/privacy/ccpa.
 

Request that PHT Security provide you with your personal data and, where possible, to transmit that data directly to another data controller.  Request a restriction on further processing of your personal data where there is a dispute in relation to the accuracy or processing of your personal data.
Lodge a complaint with the Information Commissioners Office should you be unhappy with how PHT Security is handling your data or managing your rights. The Attorney General can be contacted at:


Attorney General's Office
California Department of Justice
Attn: Public Inquiry Unit
P.O. Box 944255
Sacramento, CA 94244-2550

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To exercise any of these rights, you should in the first instance, contact the PHT Security Data Protection Officer.


11) Your Duty to inform us of changes.

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It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your business relationship with us.

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12) Our cookie policy.

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We use cookies to distinguish you from other users of our website. This helps us to improve your experience and to enhance our website.  A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree to the pop-up notice on your first visit to our website. Our website uses different types of cookies that include the following:

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Strictly necessary cookies -- These are cookies that are required for the operation of our website.

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13) Privacy information for visitors.

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When you visit our premises, we may collect personal data from you for the following purposes:

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To register you as a visitor to our premises.
To ensure your health and safety when on our premises.
To keep our premises secure.
To prevent crime and for employee safety, including the use of CCTV.
To report any incidents on our premises to the relevant authorities.
To allow us to establish or defend a legal claim.

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