ExteNet Systems Privacy Notice

Last Updated: August 1, 2021

 

ExteNet Systems, Inc. and its subsidiaries and affiliates (collectively (collectively, “ExteNet”, “we”, “us”, or “our”) are committed to respecting your privacy. This “Privacy Notice” describes the very limited ways we may collect, use, disclose, store and otherwise process personal information through www.extenetsystems.com and its affiliated websites in the United States. Personal information means any information that relates to an identifiable individual. In addition, this Privacy Notice states how you can control the collection, correction and/or deletion of information. We will not use or share your information with anyone except as described in this Privacy Notice and we do not sell your information.

We urge you to read this Privacy Notice so that you understand our commitment to you and your privacy, and how you can participate in that commitment.

 

Table of Contents
  1. The personal information we collect
  2. How we use your personal information
  3. How we share your personal information
  4. Your rights and choices
  5. How we keep your personal information safe
  6. This Website May Link to Other Websites
  7. Changes to this Privacy Notice
  8. Contact Us
  9. Information for California Residents

 

1. The Personal Data We Collect

We collect personal information about individuals from various sources described below. Where applicable, we indicate whether and why individuals may provide us with personal information.

Information that we collect directly from individuals and the parties with which we do business

We may collect personal information directly from individuals and the parties that interact with us directly (such as individuals who contact us), (collectively, “clients”), parties that provide services to us (such as vendors) (collectively, “service providers”), and other parties with whom we offer or provide products and services (such as independent sales organizations) (collectively, “partners”).

We may collect information from these parties in a variety of contexts, such as when completing one of our online forms, interacting with us on social media, or corresponding with us. The types of information we obtain in these contexts include:

  • Contact information of the business entity and its personnel who interact with us, such as name, job title, address, telephone number, and email address
  • Profile information, such as username and password that an individual may establish on one of our websites, along with any other information that an individual enters into their account profile
  • Information about individuals’ affiliation with a legal entity, such as an individual’s role, and whether he or she is a beneficial owner or authorized signatory
  • Feedback and correspondence, such as information you provide when you request information from us, receive customer support, or otherwise correspond with us, including by interacting with our pages on social networking online sites or services

Our websites include social media features and other widgets that run on our site which may collect your IP address and which page you are visiting on our site and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our site. Your interactions with these features are governed by the privacy policy of the organization providing it.

Information that we collect about individuals who do not interact with us directly

We may receive personal information about individuals who do not interact with us directly. For example, our clients, service providers, and partners may provide us with information about individuals other than themselves when using our products or services. We may also receive information from social media and publicly available sources. The types of information we receive about third parties includes:

  • Information about the personnel of our clients, service providers, or partners, such as the business contact information that our clients, service providers, or partners provide to us in the context of our contractual relationships with them
  • Information about potential clients or partners such as a service provider providing contact information for real estate representatives

 

Information collected via automated means

When you access our websites we, our service providers, and our partners may automatically collect information about you, your computer or mobile device, and activity on our websites, sometimes via the use of cookies. A “cookie” is a unique numeric code that we transfer to your computer so that we can keep track of your interests and/or preferences and recognize you as a return visitor to the websites. Typically, this information 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, general location information such as city, state or geographic area; and information about your use of and actions on or in our websites, such as pages or screens you accessed, 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. Typically, this is collected by default and ExteNet does not use the information for any commercial purposes.

Sensitive personal information
  • In limited circumstances and when permitted or required by law, in the context of processing employment applications, we may also request sensitive information, such as racial or ethnic origin or information about disability, Demographic details, such as date of birth, country of citizenship and/or country of residence
  • Government-issued identification numbers (to the extent permitted under applicable law), such as a national identification number (e.g., a Social Security Number, tax identification number, or passport number), state or local identification number (e.g., a Driver’s License or other government-issued identification number), and a copy of your government-issued identification card.

Outside of these contexts or otherwise as we specifically request, we ask that you not provide us with any sensitive personal information (meaning information revealing racial or ethnic origin, political opinions, religion or philosophical beliefs, trade union membership, genetic, health, or biometric information, information about sex life or sexual orientation, or criminal convictions or offenses) through our websites or otherwise to us.

Personal information of minors

ExteNet recognizes the importance of protecting the privacy and safety of children. Our website and services are directed towards the general audience and are not directed towards children. We do not knowingly collect information about children under the age of eighteen or minors otherwise defined in local law or regulation. If we learn that someone under eighteen has provided personal information through one of our websites, we will use reasonable efforts to remove that information from our databases. Adults who interact with ExteNet should take care not to provide any information about children under the age of eighteen.

 

2. How We Use Your Personal Information

We use your personal information for the purposes of:

Providing our products and services, which includes:
  • Managing our relationship with you or your company
  • Carrying out our obligations, and exercising our rights, under our agreement with you or your company
  • Administering and protecting our business
  • Responding to your requests and inquiries

 

Complying with law

We use your personal information as we believe necessary or appropriate to comply with applicable laws, lawful requests and legal process, such as to respond to subpoenas or requests from government authorities.

Compliance, fraud prevention and safety

We use your personal information as we believe necessary or appropriate to (a) enforce the terms and conditions that govern our products and services; (b) protect our rights, privacy, safety or property, and/or that of you or others; and (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.

With your consent

In some jurisdictions, applicable law may require us to request your consent to use your personal information in certain contexts . If you have consented to receive marketing communications from our third-party partners, you may withdraw your consent by contacting those partners directly.

Use for new purposes

We may use your personal data for reasons not described in this Privacy Notice where permitted by law and the reason is compatible with the purpose for which we collected it.

 

3. How We Share Your Personal Information

We do not sell your personal information!

Companies within the ExteNet

We may disclose your personal information to our subsidiaries and corporate affiliates for purposes consistent with this Privacy Notice.

Service providers

We may employ third party companies and individuals to administer and provide services on our behalf (such as companies that provide customer support, companies that we engage to host, manage, maintain, and develop our website and IT systems). These third parties may use your information only as directed by ExteNet and in a manner consistent with this Privacy Notice and are prohibited from using or disclosing your information for any other purpose.  Some additional examples of service providers are:

  • Service providers and vendors who provide services such as data analytics, payment processing, order fulfillment, customer service, auditing, marketing services, and IT services
  • Third party security providers to help us prevent and detect fraud, security or technical issues, or illegal activity
  • Marketing partners
  • Our trusted third party service providers and affiliates who provide a service to us or assist us with providing our products and services
  • Payment processors
  • Any other person or entity we reasonably think is customary, necessary or advisable for the business purposes disclosed in our Privacy Notice or to whom we are obliged by applicable law or regulation to make the disclosure
  • Any other party where we have obtained your consent or authorization

 

Professional advisors

We may disclose your personal information to professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us.

Compliance with Laws and Law Enforcement; Protection and Safety

ExteNet may disclose information about you to government or law enforcement officials (including tax authorities) or private parties as required by law, and disclose and use such information as we believe necessary or appropriate to (a) comply with applicable laws and lawful requests and legal process, such as to respond to subpoenas or requests from government authorities; (b) enforce the terms and conditions that govern our products and services; (c) protect our rights, privacy, safety or property, and/or that of you or others; and (d) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.

Business Transfers

ExteNet may sell or transfer some or all of its business or assets, including your personal information, in connection with a business transaction (or potential business transaction) such as a merger, consolidation, acquisition, reorganization or sale of assets or in the event of bankruptcy, in which case we will make reasonable efforts to require the recipient to honor this Privacy Notice.

 

4. Your Rights and Choices

In this section, we describe the rights and choices available to all users.

Do Not Track Signals

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 signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

Choosing not to provide your personal information

Where we request personal information directly from you, you do not have to provide it to us. If you decide not to provide the requested information, in some circumstances we, or our clients, may be unable to provide products or services to you. For example, we may be unable to respond to your question or request.

Accessing, modifying or deleting your information

In some jurisdictions, applicable law may provide a right for individuals to access, modify, or delete their personal information. You may contact us directly to request access to, or modify or delete your information. In compliance with applicable laws, we may not be able to provide access to, modify, or delete your information in all circumstances. To contact us, you may fill out and submit This Form or call us at 866 892-5327.

Complaints

If you have a complaint about our handling of your personal information, you may contact us using the contact information belowWe request that a complaint be made in writing. Please provide details about your concern or complaint so that we can investigate it. We will take appropriate action in response to your complaint, which may include conducting internal discussions with relevant business representatives. We may contact you for additional details or clarification about your concern or complaint. We will contact you to inform you of our response to your complaint.

 

5. How We Keep Your Personal Information Safe

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

How long will you use my personal information?

We will use your personal information for as long as necessary based on why we collected it and what we use it for. This may include our need to satisfy a legal, regulatory, accounting, or reporting requirement.

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

In general terms, we will retain your personal information for the duration of your involvement/engagement with us and for as long as reasonably necessary afterwards; however, we may maintain different retention periods for different purposes. There are also certain types of information which are required to be retained for a certain period by law.

 

6. This Website May Link to Other Websites

We may also link to third-party websites, mobile applications, and other content. ExteNet is not responsible for the privacy practices of any third party, and this Privacy Notice does not apply to such third party’s websites, mobile applications, or other content. ExteNet does not guarantee, approve, or endorse any information, material, services, or products contained on or available through any linked third-party website, mobile application, or other content. ExteNet is not responsible for any content on third-party properties to which we link. ExteNet provides links to third-party properties or content as a convenience, and visiting or using linked third-party properties or content is at your own risk.

 

7. Changes to This Privacy Notice

ExteNet regularly reviews this Privacy Notice and ensures that we process your information in a manner that is in compliance with applicable regulations. We reserve the right to modify this Privacy Notice at any time. We encourage you to periodically review this page for the latest information on our privacy practices. If we make material changes to this Privacy Notice, we will notify you by updating the date of this Privacy Notice and posting it on our website. We may (and, where required by law, will) also provide notification of changes in another way that we believe is reasonably likely to reach you, such as via e-mail (if you have an account where we have your contact information) or another manner through our website.

Any modifications to this Privacy Notice will be effective upon our posting of the new terms and/or upon implementation of the new changes (or as otherwise indicated at the time of posting). In all cases, your continued use of our website after the posting of any modified Privacy Notice indicates your acceptance of the terms of the modified Privacy Notice.

 

8. Contact Us

For California resident personal information related inquiries please refer to “How to exercise your rights” below

For all other privacy inquiries related to this Notice, please contact us using This Form.

We also maintain a contact number, which is available 24 hours per day from the United States, at +1 866-892-5327. The contact number is most appropriate for an urgent concern.

 

9. Information for California Residents

We are required by the California Consumer Privacy Act of 2018, as amended (“CCPA”) to provide to California residents an explanation of how we collect, use and share their personal information, and of the rights and choices we offer California residents regarding our handling of the personal information.

Your California privacy rights

As a California resident, you have the rights listed below. However, these rights are not absolute, and we may decline your request as permitted by the CCPA.

  • Information. We collect very little personal information and we share personal information only in the very limited ways described above. However, you can request the following information about how we have collected and used your personal information during the past 12 months:
    • The categories of your personal information that we have collected.
    • The categories of sources from which we collected your personal information.
    • The business or commercial purpose for collecting and/or selling your personal information.
    • The categories of third parties with whom we share personal information.
    • Whether we have disclosed your personal information for a business purpose, and if so, the categories of personal information received by each category of recipient.
    • Whether we’ve sold your personal information; and, if so, the categories of personal information received by each category of recipient. We do not sell your personal information.
  • Access. You may request access to the categories and the specific pieces of your personal information we collect.
  • Deletion. You can ask us to delete certain personal information that we maintain about you.
  • Nondiscrimination. You are entitled to exercise the rights described above free from discrimination. This means that we will not penalize you for exercising your rights by taking actions such as by denying you goods or services, increasing the price/rate of goods or services, decreasing the service quality, or suggesting that we may penalize you as described above for exercising your rights. However, the CCPA allows us to charge you a different price or provide a different service quality if that difference is reasonably related to the value of the personal information we are unable to use.

 

Sale of Personal Information

We do not sell your personal information to third parties as defined in the CCPA.

How to exercise your rights

You may exercise your California privacy rights as follows:

Right to information, access and deletion
You can request to exercise your information, access and deletion rights by making a request at:

  • Complete and submit This Form or
  • +1 866 892-5327
  • Identify verification. The CCPA requires us to verify the identity of the individual submitting the request before providing a substantive response to the request. A request must be provided with sufficient detail to allow us to understand, evaluate and respond. The requester must provide sufficient information to allow us to reasonably verify that the individual is the person about whom we collected information.
  • Authorized agents. California residents can empower an “authorized agent” to submit requests on their behalf. We will require the authorized agent to have a written authorization confirming that authority.

 

Personal information that we collect, use and share

The chart below summarizes our collection, use and sharing of personal information during the last 12 months before the effective date of this Privacy Notice. We describe the sources through which we collect your personal information in section above titled The Personal Information We Collect, and describe the purposes for which we collect, use, and share this information in section above titled How We Use Your Personal Information and How We Share Your Personal Information.

 

Categories of Information We May Collect Do we collect this information? Do we share this information for business purposes?
Identifiers Yes Yes, as described in this Privacy Notice
Online Identifiers Yes Yes, as described in this Privacy Notice
Protected Classification Characteristics Possible Yes, as described in this Privacy Notice
Commercial Information No No
Biometric Information No No
Internet or Network Information Yes Yes, as described in this Privacy Notice
Geolocation Data No No
Professional or Employment Information Possible Yes, as described in this Privacy Notice
Education Information Possible Yes, as described in this Privacy Notice
Inferences No No
Financial Information No No
Medical Information Possible Yes, as described in this Privacy Notice
Sensory Information No No

 

 

Glossary
Categories of Personal Information Date Elements within the Category
Biometric Information An individual’s physiological, biological or behavioral characteristics, including DNA, that can be used, singly or in combination with each other or with other identifying data, to establish an individual’s identity. Biometric information includes, but is not limited to, imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which an identifier template, such as a face print, a minutiae template, or a voiceprint, can be extracted, and keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information.
Transaction History Products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Financial Information Bank account number, debit or credit card numbers, insurance policy number, and other financial information.
Geolocation Data Precise location, e.g., derived from GPS coordinates or telemetry data.
Identifiers Real name, alias, postal address, unique personal identifier, customer number, email address, account name other similar identifiers.
Government-issued ID Social security number, driver’s license, passport, or other government-issued ID, including an ID number or image.
Medical Information Personal information about an individual’s health or healthcare, including health insurance information.
Internet or Network Information Browsing history, search history, and information regarding a consumer’s interaction with an Internet website, application, or advertisement.
Online Identifiers An online identifier or other persistent identifier that can be used to recognize a person, family or device, over time and across different services, including but not limited to, a device identifier; an Internet Protocol address; cookies, beacons, pixel tags, mobile ad identifiers, or similar technology; customer number, unique pseudonym, or user alias; telephone numbers, or other forms of persistent or probabilistic identifiers (i.e., the identification of a person or a device to a degree of certainty of more probable than not) that can be used to identify a particular person or device.
Physical Description An individual’s physical characteristics or description (e.g., hair color, eye color, height, weight).
Professional or Employment Information Information relating to a person’s current, past or prospective employment or professional experience (e.g., job history, performance evaluations), and educational background.
Protected Classification Characteristics 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).
Sensory Information Audio, electronic, visual, thermal, olfactory, or similar information.
Inferences Inferences drawn from any of the information identified in this subdivision to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, preferences, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Commercial Information Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Education information Information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. section 1232g, 34 C.F.R. Part 99).