Services Privacy Policy

1. General

We know that your privacy is important to you, and we work hard to earn and keep your trust. Theodosian, Inc. ("Company," "we," "us," and "our"), respects your privacy and is committed to protecting your privacy through our compliance with this Privacy Policy (the "Policy"). The words "you" and "your" refer to you as a user of the Services (defined below), either as a registered customer or employee/agent of a Company customer.

This Policy describes:

• The types of information we collect from you or that you may provide when you use our online platform and services that are owned or operated by, or on behalf of, the Company and where this Policy is linked (collectively, our "Services").
• Our practices for collecting, using, maintaining, protecting, and disclosing that information.

This Policy applies to information we collect on the Services or in emails and other electronic messages between you and the Services, and information gathered when you interact with our advertising on third-party websites if such advertisements include links to this Policy.

This Policy does not apply to information collected by us offline or through any other means, including on any other website operated by the Company where this Policy is not linked or any third party, or information collected by any third party through any application or content (including advertising) that may link to or be accessible from the Services (for further information, see below, "Third-party Websites").

Please read this Policy carefully to understand our practices regarding your information and how we will treat it. If you do not agree with our policies and practices, then please do not use our Services. By using our Services, you agree to the terms of this Policy. This Policy may change from time to time (see below, "Changes to this Policy"). Your continued use of our Services after we make changes is deemed to be acceptance of those changes, so please check the Policy periodically for updates.

2. End User License Agreement

This Policy is incorporated by reference and should be read in conjunction with the Terms of Service and the End User License Agreement.

3. The Information We Collect

Personal Information. To ensure that we provide you with the best possible experience, we will store, use, and disclose personal information about you in accordance with this Policy. Personal information is information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular user, household or device ("Personal Information"). The Personal Information that we may receive and collect depends on what you do when you visit our Services.

Use of Services for CUI and Regulated Information. You may use the Services to store, process, or transmit Controlled Unclassified Information (CUI), proprietary data, or other regulated information. However, due to the nature of our encryption technology, the Company does not have access to any such information. All data is encrypted at the file level. While we can provide guidance and instructions on how you may access or manage your encrypted files, the Company cannot decrypt, view, or otherwise access the contents of your data. This ensures that your sensitive information remains private and secure at all times.

Information of Other Individuals. You may have the opportunity to provide information of other individuals. When providing such information, you are solely responsible for obtaining the necessary consents and authorizations from any individuals in accordance with applicable data security laws and regulations, and the Company shall not be responsible or held liable for your failure to obtain the necessary consents.

Credit Card Information. Please note that for any credit card information provided on the Services, we utilize a trusted third-party PCI-DSS compliant payment processor to process all of your transactions and it collects and maintains the necessary Personal Information needed to necessitate such transactions. We do not collect or store your credit card or other payment information on our systems.

Aggregated and De-Identified Data. We may also collect, use and disclose aggregated and de-identified data such as statistical or demographic data for any purpose. Aggregated and de-identified data could be derived from your Personal Information but is not considered Personal Information under applicable law as this data will not directly or indirectly reveal your identity. However, if we combine or connect aggregated or de-identified data with your Personal Information so that it can directly or indirectly identify you, we treat the combined data as Personal Information which will be used in accordance with this Policy.

Free-Text Boxes. The information that you provide in each case will vary. In some cases, you may be able to provide Personal Information via email or free text boxes, such as contacting the Company to request further information. When providing your Personal Information, please provide only relevant information and do not provide unnecessary sensitive information, such as Social Security numbers, credit card information or other sensitive personal data, unless required for our services.

Username and Password. We may ask you to create a username and password that should only be known to you. When you provide this information to us, you are no longer anonymous.

Recording Use of the Services. We partner with trusted third-party vendors to analyze performance and traffic of our Services. This may include things like buttons you click, mouse movements and other behavior on the Services, date and time of access, pages visited, web beacons, and cookie or pixel tag information. Please see our Automatic Information Collection section below to learn more about cookies, pixels tags, and analytic technologies.

(a) Information We May Collect on the Services

You may have the opportunity to provide Personal Information on our Services, including but not limited to:

We may obtain the Personal Information listed above from the following categories of sources:

• Directly from you. For example, when you:
  • Register yourself with the Services;
  • Adjust settings and controls related to the Services;
  • Access or interact with files that are subject to the Services;
  • Review or comment on one of our products; or
  • Otherwise communicate with us, such as contacting us for more information.
• Indirectly from you. For example, through information we collect from you in the course of providing our services to you.
• Directly and indirectly from activity on our Services. For example, from Services usage details that are collected automatically. For more information on automatic information collection, please review the "Automated Information Collection" section below.
• Third Party Sources. We may collect information about you from third party sources, such as our business partners.

4. User Activity

To deliver and maintain the functionality of our Services, Company collects and processes certain operational data, including:

• User Activity Logs: Records of actions taken within the Services for security and audit purposes.
• Audit Logs: Metadata such as file size, timestamps, and transaction details.
• Device Information: Details about the user's device, operating system, and browser.
• Network Information: IP address and related connection data.

This information is used exclusively to provide, secure, and improve the Services, ensure compliance, and support troubleshooting. We do not access or decrypt the contents of your files, as all data remains encrypted under your control.

5. How We Use Your Information

The information we gather and that you provide is collected to provide you information and the services you request, in addition to various other purposes, including, but not limited to:

• Security, credit or fraud prevention purposes;
• Providing you with effective customer service;
• Providing you with a personalized experience when you use the Services;
• Developing new products and services;
• Contacting you with special offers and other information we believe will be of interest to you (in accordance with any privacy preferences you have expressed to us);
• Contacting you with information and notices related to your use of the Services;
• Inviting you to participate in surveys and providing feedback to us (in accordance with any privacy preferences you have expressed to us);
• Better understanding your needs and interests;
• Improving the content, functionality and usability of the Services;
• Improving our products and services;
• Improving our marketing and promotional efforts; and
• Any other purpose identified at the point of data collection, in an applicable privacy notice, in a click-through agreement or in any other agreement between you and us.

Duration. The length of time Company intends to retain Personal Information, including sensitive personal information, if any, is for as long as reasonably necessary to carry out Company's intended business purpose for such information.

6. How We Disclose Your Information

We do not sell your Personal Information to any third party. We may disclose your Personal Information to a third party for a business purpose, including the following categories of third parties:

• Our Affiliates. We may disclose the information collected through the Services with our affiliates, subsidiaries, or other related entities in order to provide our products, services and effective customer support.
• Your Employer or Business. If you are an employee, contractor or agent of a Company customer, we may disclose your information with your applicable employer or business, such as, but not limited to, when managing all active accounts under your employer's or business' subscription with us. The Company is not responsible or liable for any uses of your information or your content by any applicable employer or business.
• Third-party Service Providers. We disclose Personal Information collected through the Services with third-party Service Providers who act for or on behalf of the Company. These third parties may need information about you to perform their functions. "Service Providers" may include suppliers, dealers, distributors, companies and consultants that provide website hosting, software development, payment processing, website and data analytics, order fulfillment, information technology and related infrastructure support, customer service, email delivery, and auditing.

Except as described in this Policy, we will not disclose your information with third parties without your notice and consent, unless it is under one of the following circumstances:

• Legal Reasons.
  • We believe that disclosure is reasonably necessary to comply with any applicable law, regulation, subpoena, or court order;
  • To respond to duly authorized information requests from law enforcement or other governmental authorities;
  • To enforce our agreements or policies;
  • To investigate and prevent security threats, fraud, or other malicious activity; or
  • To respond to an emergency that we believe in good faith requires us to disclose such information to assist in preventing the death or serious bodily injury of any person or Company employee.
• Sale of Business or Merger. There are circumstances where the Company may decide to buy, sell, or reorganize its business. Under these circumstances, it may be necessary to disclose or receive Personal Information with prospective or actual purchasers, acquisition targets, partners or affiliates. In such circumstances, the Company will ensure your information is used in accordance with this Policy.
• In Aggregate or De-Identified Form. We may aggregate or otherwise anonymize the data we collect for purposes of analytics, research, marketing and other business interests of the Company. Such use shall not include Personal Information or information that can identify you as an individual or reasonably be used to identify you.

7. Your Choices and Selecting Your Privacy Preferences

We want to provide you with relevant information that you have requested. When possible, we will always provide options as to what information we collect and how you can manage any preferences that pertains to such information.

If we provide subscription-based services, such as email newsletters, we will allow you to make choices about what information you provide at the point of information collection or at any time after you have received a communication from us while you are subscribed. Transactional or service-oriented messages, such as delivery confirmation messages, are usually excluded from such preferences, as such messages are required to respond to your requests or to provide goods and services, and are not intended for the purposes of marketing.

From time to time, we may send you email newsletters and marketing emails. You may opt out of them at any time by selecting the "unsubscribe" link at the bottom of each email. Please note that by opting out or unsubscribing you may affect other services you have requested we provide to you, in which email communication is a requirement of the service provided. Even if you opt-out of receiving marketing material, we may still need to contact you with important information about your account or responding to your requests or questions.

8. Accuracy and Access to Your Personal Information

We strive to maintain and process your information accurately. We have processes in place to maintain all of our information in accordance with relevant data governance frameworks and legal requirements. We employ technologies designed to help us maintain information accuracy on input and processing.

Where we can provide you access to your Personal Information in our possession, we will always ask you for a username and password to help protect your privacy and security. We recommend that you keep your password safe, that you change it periodically, and that you do not disclose it to any other person or allow any other person to use it.

To view and change the Personal Information that you have provided to us, you can log in to your account and follow the instructions on that webpage, or contact us directly for assistance.

9. Information of Minors

We do not knowingly collect or use information from individuals under the age of sixteen (16) without parental or guardian consent. We do not target the Services to minors, and would not expect them to be engaging with the Services or our services. We encourage parents and guardians to provide adequate protection measures to prevent minors from providing information unwillingly on the internet. If we are aware of any Personal Information that we have collected about minors, we will take steps to securely remove it from our systems.

10. Feedback

We welcome inquiries or feedback on the services or products you might use or like to use. Any inquiries, feedback, suggestions, or ideas you provide to us (collectively, "Feedback") will be treated as non-proprietary and non-confidential. Your Feedback on or through this Services may be available to others who visit this Services. In addition, we may use your Feedback in advertising campaigns and other promotions. We may or may not use your name in connection with such use, and we may or may not seek your consent before using the Feedback for such purposes. Therefore, you should have no expectation of privacy with respect to your Feedback on or through this Services.

You should not submit any content you do not wish to make available to the general public, and you must take special care to make sure your Feedback comply with our Terms of Use or other applicable agreements. All terms and conditions of our Terms of Use apply to Feedback on or through this Services. In particular, your Feedback must not violate the privacy or other rights of others. You may not use false identifying information or contact information, impersonate any person or entity, or otherwise mislead us as to the origin of any Feedback.

11. Third-Party Websites

This Policy does not apply to websites or other domains that are maintained or operated by third parties or our affiliates. Our Services may link to third-party websites and services. For example, if you click on an advertisement on the Services, you may be taken to another website that we do not control. These links are not endorsements of these websites, and this Policy does not extend to them. Because this Policy is not enforced on these third-party websites, we encourage you to read any posted privacy policy of the third-party website before using the service or website and providing any information.

12. Your Rights Under State Law

Some state laws in the United States provide consumers with additional rights with respect to their personal information (also known as "personal data"), as those terms are defined under those applicable state laws. Such state laws may include, but are not limited to, the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020, the Colorado Privacy Act, the Connecticut Data Privacy Act, the Florida Digital Bill of Rights, the Oregon Consumer Privacy Act, the Texas Data Privacy and Security Act, the Utah Consumer Privacy Act, and the Virginia Consumer Data Protection Act (collectively, the "U.S. State Privacy Laws"). Any Personal Information we collect is collected for the commercial purpose of effectively providing our services to you, as well as enabling you to learn more about, and benefit from, our services.

Company is a "Service Provider" or "Processor" as defined by the U.S. State Privacy Laws where Company processes your information on behalf of its business customers, which may be your employer or business. To the extent U.S. State Privacy Laws allow you to make certain requests, including requests to access, correct, limit or delete personal information or sensitive personal information, or a list of third party disclosures, you must make these requests directly to your employer or business. If you submit a request to the Company regarding your rights under applicable U.S. State Privacy Laws, we may redirect you to your applicable employer or business.

13. Location of Our Website and Services

We do not warrant or represent that this Policy or the Services' use of your Personal Information complies with the laws of every jurisdiction. Furthermore, to provide you with our services, we may store, process, and transmit information in the United States and other locations around the world, including countries that may not have the same privacy and security laws as yours. Regardless of the country in which such information is stored, we will process your Personal Information in accordance with this Policy.

14. For Website Users Outside the United States

Under the (i) General Data Protection Regulation (Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, or "GDPR"), (ii) Data Protection Act 2018, (iii) the GDPR as it forms part of the law of England and Wales, Scotland and Northern Ireland (i.e., "UK GDPR") as provided in the Data Protection Act 2018, and (iv) any other applicable data protection legislation of any country or other jurisdiction (collectively "International Data Protection Laws") individuals have specific rights with respect to their Personal Information, or "personal data" as defined under the International Data Protection Laws. For the purposes of this Policy, the Company operates as a data processor. Any personal data we collect from you is processed in the United States and under the terms of this Policy.

Any personal data we collect from you is processed in the legitimate interest of our business and providing our services to you as the lawful means of such processing. You may always withdraw your consent to our use of your personal data as described below. We will only retain your personal data for the time necessary to provide you the information and services to which you have consented, to comply with the law and in accordance with your rights below.

The Data Processor is:

• Name: Theodosian, Inc.
• Address: 1021 East Lincolnway, Suite #6965, Cheyenne, Wyoming 82001, United States
• Email Address: [email protected]

The Data Controller is your employer or business that has a subscription with us. Company is a "Service Provider" or "Processor" as defined by the International Data Protection Laws. To the extent International Data Protection Laws allow you to make certain requests, including requests to access, correct, erase personal information, or withdraw consent, you must make these requests directly to your employer or business. If you submit a request to the Company regarding your rights under applicable International Data Protection Laws, we may redirect you to your applicable employer or business.

15. Safeguarding the Information We Collect

We use reasonable technical, administrative, and physical safeguards in order to protect your Personal Information against accidental loss and from unauthorized access, use, alteration, and disclosure. However, we can never promise 100% security. You have a responsibility, as well, to safeguard your information through the proper use and security of any online credentials used to access your Personal Information, such as a username and password. If you believe your credentials have been compromised, please change your password. Please also notify us immediately of any actual or suspected unauthorized use of the Services or your information.

16. Changes to This Policy

This Policy describes our current policies and practices with regard to the information we collect through the Services. We are continually improving and adding to the features and functionality of the Services along with the products and services we offer through the Services. If we make any changes to this Policy, a revised Policy will be posted on this webpage and the date of the change will be reported in the "Last Revised" block above. You can get to this page from any of our webpages by clicking on the "Privacy Policy" link (usually at the bottom of the screen).

17. How to Contact Us

We value your opinions and welcome your feedback. To contact us about this Policy or your Personal Information, please contact us by email at [email protected] or by mail at 1021 East Lincolnway, Suite #6965, Cheyenne, Wyoming 82001, United States.