Last Revised: 2021

Introduction

At Broadstone Technologies (“Prytex”, “We”, “Our”, or “Us” and terms of similar meaning), We respect your (“Your” and “You”) privacy and are committed to protecting it through Our compliance with this privacy policy (the “Privacy Policy”). This means We do not transfer, distribute, disclose, rent or sell any of Your personal information to third parties except as provided for in this Privacy Policy or as specifically consented by You.

By using (the word “use” in this Privacy Policy will mean “access or use”) Our Website located at https://prytex.io (the “Website”), or by using any of Our mobile applications (the “Apps”), or any of the services and functionalities We make available via the Website and Apps, including the Prytex Platform (collectively, with the Website and Apps, the “Services”), or by using any of Our hardware products (“Products”), You expressly consent to Our collection, use and disclosure of Your personal information in accordance with this Privacy Policy. This Privacy Policy is incorporated into and subject to Our Terms and Conditions re: Service, Sales and Products.

Scope

This Privacy Policy applies to all information by which You may be personally identified (“Personal Information”) that is collected, used or disclosed by Prytex. Personal Information is any information in any form that identifies or can identify an individual and includes any information provided to Us by You in using Our Services or Products.

This Privacy Policy also applies to information that is about You, but individually does not identify You, as described below.

Information We Collect

a. Personal Information

Personal Information that We collect includes, but is not limited to:

• Account and profile information, including name, e-mail address, usernames and passwords;
• Your mobile device telephone number;
• Any other Personal Information that You may provide when You set-up an account with Us or when you contact us with questions and/or inquiries;
• Device information, including the type of mobile device to which You have downloaded Our Apps;
• Geo-location information;
• Any other Personal Information that You may enter when You use the Services or Products, such as billing information;
• Technical support records;
• Service requests and inquiries; and
• Any information that Prytex collects from You that is intended to improve and personalize Our Services and Products.

b. Non-Personally Identifiable Information

Personal information does not include information that is aggregated or anonymized in such a manner that it cannot be connected to You or any of its other end-users (“Users”). Such information by itself or together cannot be tracked to a specific individual’s personally identifiable information.

How do We use Personal Information?

Prtyex collects Personal Information for the following purposes:

• to provide Services to You and Users;
• to create and administer Your user account, including to authenticate You on log-in;
• to establish and maintain responsible commercial relations and to communicate with You in order to provide Services and Products. This includes, but is not limited to, communications relating to account verification;
• communicate with You regarding billing and account verification;
• permit our payment processor, to provide payment processing services;
• collect and store limited parts of Your payment information (such as a part of a credit card number, or a part of your billing address) in order to record transactions and to prevent fraud;
• to respond to any correspondence You may direct to Us;
• to understand Our Users’ needs and preferences;
• to enforce Our Terms of Use;
• to provide You with service or administrative messages;
• to meet legal and regulatory requirements; and
• for any other reasonable purposes for which You may have provided Your express consent or in which Your consent can be reasonably implied.

In addition, We may use Personal Information, on a de-identified basis, to remediate network vulnerabilities and for research purposes to improve the Services and Products (e.g. research into new network vulnerabilities and threats).

How do We use Non-Personally Identifiable Information?

In an ongoing effort to better understand and serve the Users of Our Services and Products, We conduct research on Our customer and User demographics and behavior based on Personal Information and other information that we have collected. This research will be compiled and analyzed on an aggregate basis and this aggregate does not identify any individual and therefore is considered and treated as Non-Personally Identifiable Information under this Privacy Policy.

The non-personally identifiable information collected is used to monitor traffic, provide the Services and Products, and conduct internal research on Our Users’ to better understand and serve them, including Users’ size, usage patterns, demographics, interests and behaviors

The Services and Products may automatically receive and store certain types of non-personally identifiable information about Users’ Service and Product usage and their devices, including network information (e.g. network packet headers, vulnerabilities and threats, SSID, Product information (e.g. model, software version)), IP address, and mobile network information. We use different types of technology to collect this information, such as cookies.

We use Google Analytics to track information about visits to the Website, including to compile statistical reports about the activity on the Website. This information is used by Us to improve the Website and the Functionalities. This data may be used to show you advertising on any Google or Google affiliated website.

Privacy Policy - Consent

We respect Your privacy and, unless otherwise required by law, We will not collect, use or disclose Your Personal Information without Your prior consent. Your consent may be expressed or implied. You may expressly give Your consent in writing, verbally or through any electronic means. In certain circumstances, Your consent may be implied by Your actions. For example, providing Us Personal Information to register for Our Services is implied consent to use such information to provide You the associated services.

Where appropriate, Prytex will generally seek consent for the use or disclosure of the information at the time of collection. In certain circumstances, consent with respect to use or disclosure may be sought after the information has been collected but before use (for example, when Prytex wants to use information for a purpose other than those identified above). In obtaining consent, Prytex will use reasonable efforts to ensure that a customer is advised of the identified purposes for which Personal Information collected will be used or disclosed.

The form of consent sought by Prytex may vary, depending upon the circumstances and type of information disclosed. In determining the appropriate form of consent, Prytex shall take into account the sensitivity of the Personal Information and the reasonable expectations of Our Users. Prytex will seek express consent when the information is likely to be considered sensitive. Implied consent will generally be appropriate where the information is less sensitive.

You may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice. In order to withdraw consent, You must provide notice to Prytex in writing.

Limiting Use, Disclosure and Retention

Unless required by law, or in connection with a business transaction, Prytex shall not use or disclose or transfer Personal Information for any purpose other than those described above without first identifying and documenting the new purpose and obtaining Your consent, where such consent may not reasonably be implied.

As noted above, Prytex does not disclose Your Personal Information to third parties. Notwithstanding, Your Personal Information may be transferred to third party suppliers, contractors and agents ( “Affiliates”) who are contracted by Prytex to assist it in providing and developing products and services. Such Affiliates will only use Your Personal Information for the purposes identified in this Privacy Policy. In the event Your Personal Information is disclosed to a third party pursuant to a business transaction, Prytex will ensure that it has entered into an agreement under which the collection, use and disclosure of the information is related to those purposes that relate to the transaction.

Subject to the foregoing, only Prytex’s and Our Affiliates’ employees with a business need to know, or whose duties reasonably so require, are granted access to Personal Information about Our Users. All such employees will be required as a condition of employment to contractually respect the confidentiality of Our Users’ Personal Information.

Prytex will retain Personal Information for only as long as required to fulfill the identified purposes or as required by law. Personal Information that is no longer required to fulfill the identified purposes will be destroyed, erased or made anonymous according to the guidelines and procedures established by Prytex.

Law Enforcement Requests

We will disclose Personal Information without Your knowledge or consent if We receive an order, subpoena, warrant or other legal requirement issued by a court, tribunal, regulator or other person with jurisdiction to compel disclosure of Your Personal Information. If We receive a written request from a police officer or other law enforcement agency with authority to request access to Your Personal Information in the course of an actual or potential investigation into a breach of a law, Our policy is to provide the requested information.

Children and Minors

Our Services and Products are not directed to children under the age of 13 years. We will not knowingly collect Personal Information about a child under the age of 13. We do not allow minors (persons who are under the age of majority in their place of residence) to create accounts, make purchases or enter contests or promotions.

Links to Other Websites

You may be able to access third-party websites through links available on Our Services. Any links are provided for Your convenience. We do not have any control over those third-party websites and We do not provide any guarantee that the privacy policy practices of the hosts of those websites or networks meet Our standards. Your use of such third-party websites is at Your own risk and will be governed by the privacy policies of those websites and not by this Privacy Policy. Do not transmit Personal Information using those websites without reading the privacy policies governing those websites.

How can I Access my Personal Information?

Upon request, Prytex will provide information to You or another User regarding the existence, use and disclosure of his or her Personal Information. Prytex will respond to an application for individual access to Personal Information within a reasonable time and at minimal or no cost to the individual. A User may challenge the accuracy and completeness of the information and have it amended as appropriate.

NOTE: In certain circumstances, Prytex may not be able to provide access to all the Personal Information it holds about a User. Exceptions may include information that is prohibitively costly to provide, information that contains references to other individuals, information that cannot be disclosed for legal, security or commercial proprietary reasons, or information that is subject to solicitor-client or litigation privilege. Prytex will provide the reasons for denying access upon request.

Safeguards

Prytex protects Your Personal Information by security safeguards appropriate to the sensitivity of the information. Prytex will protect Personal Information against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification.

Our methods of protection include:

• Physical measures, such as filing cabinets which are kept locked when not in use and restricted access, both to Prytex's place of business in general and to internal offices as well;
• Organization measures, such as employee vetting procedures and limited access on a need to know basis; and
• Technological measures, such as the use of passwords, firewalls and encryption.

The financial information that You enter to purchase Services is not stored by Us in full, but is retained and stored by our payment processing vendor for the purpose of processing Your credit card payment. We only retain a limited portion of such information.

Your California Privacy Rights

California Civil Code Section 1798.83 permits users of our Website or Apps that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please contact Us using one of the methods identified directly below.

Contact Information

To ask questions or comment about this Privacy Policy and Our privacy practices, contact Us at:

E-mail: [ privacy@prytex.io ]

General

Prytex reserves the right to modify and amend this Privacy Policy from time to time in its sole discretion without prior notice. Any such amendment(s) will be posted on our Website and Apps and will be effective as of the date of posting.