PRIVACY POLICY

INTRODUCTION

Data privacy is very important to Marma Security Inc. (“MSI”). We are passionate about privacy preferences and safeguarding your personal data when you engage with us and our technology. We are committed to putting you in control of your privacy choices and using your personal data for no other purpose than as communicated to you. This Privacy Policy explains how information is collected, used, and disclosed by MSI and applies to information collected when you use our product or access our website (collectively, the “Website”), or when you attend a MSI event or otherwise interact with us.

This policy applies to information we collect:

  Through mobile and desktop applications published by MSI that you download from an application store, which provides dedicated non-browser-based interaction between you and this Website.

 On this Website and collected from a MSI device associated with you or your household.

 In email, text, and other electronic messages between you and this Website.

It does not apply to information collected by:

 Us offline or through any other means, including on any other website operated by Company or any third party (including our affiliates and subsidiaries); or

  Any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or through the Website.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website or MSI device. By accessing or using this Website, you agree to this privacy policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

CHILDREN UNDER THE AGE OF 16

Our Website is not intended for children under 16 years of age. No one under age 16 may provide any personal information to (or on) the Website. We do not knowingly collect personal information from children under 16. If you are under 16, do not use or provide any information on this Website or through any of its features, register on the Website, make any purchases through the Website, use any of the interactive or public comment features of this Website, or provide any information about yourself to us, including your name, address, telephone number, payment information, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at support@marmasec.com.

INFORMATION COLLECTED

The primary objective of collecting your personal information is to allow you to access the MSI website and product/services offered by this online platform, to record your details required by us, and to provide you information about the latest discounts, offers, events, and promotions. In this Privacy Policy we refer to all of this information, collectively, as the "Information."

INFORMATION WE COLLECT ABOUT YOU AND HOW WE COLLECT IT

We collect several types of information from and about users of our App, Products and our Website, including information:

 By which you may be personally identified, such as name, postal address, email address, telephone number, and any other identifier by which you may be contacted online or offline ("personal information").

 About your internet connection, the equipment you use to access our Website, and usage details.

We collect this information:

 Directly from you when you provide it to us.

 Automatically as you use our App or navigate through the site. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.

Information You Provide to Us The information we collect on or through our App or Website may include:

 Information that you provide by filling in forms on our Website. This includes information provided at the time of subscribing to our service and any payment information. We may also ask you for information when you enter a contest or promotion sponsored by us, and when you report a problem with our Website.

 Records and copies of your correspondence (including email addresses), if you contact us.

 Your responses to surveys that we might ask you to complete for research purposes.

 Details of transactions you carry out through our Website and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Website.

You also may provide information to be published or displayed (hereinafter, "posted") on public areas of the Website or transmitted to other users of the Website or third parties (collectively, "User Contributions"). Your User Contributions are posted on and transmitted to others at your own risk. Please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Website with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our products and website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

 Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.

 Information about your computer and internet connection, including yourIP address, operating system, and browser type.

The information we collect automatically does/may/is only statistical data and does not include personal information, but we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:

 Estimate our audience size and usage patterns.

 Store information about your preferences, allowing us to customize our Website according to your individual interests.

 Recognize you when you return to our Website.

The technologies we use for this automatic data collection may include:

 Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.

 Web Beacons. Pages of our Website [and our emails] may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or [opened an email] and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

Other Data: Other data may include:

 Applications and features used, sizes and names of the files or folders uploaded, downloaded, shared, or accessed while using MSI website, log information, including IP address, access times, browser type and language, ISP name, content used, device information, operating system and version, mobile network information (as allowed by the mobile network) or platform information (as allowed by the specific platform type), cookies and other tracking technologies.

 Malicious domains, phishing links, and malicious websites that were accessed and blocked from your household.

 Cyberattacks targeted at your household that were blocked.  MSI device operational status, uptime, and performance information.

Content and Advertising Information:

We may receive personal data about you if you choose to interact with a third-party service in our website. 

USE OF INFORMATION

We may use the Information collected for the limited purpose of:

• Providing MSI products and services described in this Privacy Policy and as permitted by applicable laws;

• Improving MSI products, services, or website; • Processing and completing transactions, and send you related information, including purchase confirmations and invoices;

• Providing customer service by sending notices, updates, security alerts, support, and administrative messages regarding MSI products or website;

• Monitoring cyber-attacks and analyzing trends, usage, and activities in connection with MSI products or website;

• Investigating and preventing fraudulent transactions, unauthorized access to the MSI products or website, or other illegal activities;

• Responding to your comments, questions, and requests, and provide customer service and support;

• Communicating with you regarding ongoing business relations; and,

• Providing promotional information regarding offers, promotions, contests, events, and other news or information regarding MSI and/or our select partners;

• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;

• In any other way we may describe when you provide the information; and,

• To fulfill any other purpose for which you provide it.

Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

 Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.

 Promotional Offers from the Company. If you do not wish to have your email address/contact information used by the Company to promote our own or third parties' products or services, you can opt-out by sending us an email stating your request to support@marmasec.com. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions. This opt out does not apply to information provided to the Company as a result of a product purchase, warranty registration, product service experience or other transactions.

We do not control third parties' collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative ("NAI") on the NAI's website. Residents of certain states, such as California, Nevada, Colorado, Connecticut, Virginia, and Utah may have additional personal information rights and choices. Please see Your State Privacy Rights for more information.

PROCESSING

MSI is a US based company and generally information is processed and stored on US based computers and facilities including third-party services such as web-hosting sites. By accessing or using the MSI products, services, or websites, or otherwise providing information to us, you consent to the processing and transfer of information in and to the U.S. and other countries and territories, which may have different privacy laws from your country of residence.

SHARING AND DISCLOSURE OF INFORMATION

We will not share personal information about you, or your use of MSI products, services, or website, with any third party, except as described in this Privacy Policy. We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

Vendors, Consultants and Other Service Providers

• We may share your information with third-party vendors, consultants, and other service providers who are working on our behalf and require access to your information to carry out that work, such as to process billing, provide customer support, etc. These service providers are authorized to use your personal information only as necessary to provide services to MSI and/or to provide MSI products to you.

• In some cases, we may share your information with third-party vendors to understand which areas and features of the MSI products, services, or website are most popular and/or to improve the overall effectiveness of MSI's products and services.

Third Party Applications 

• If you choose to connect with third-party applications or services, we may share information about you including your username and any content you choose to use in connection with those applications and services, and such third parties may contact you directly as necessary.

• This Privacy Policy does not apply to your use of such third-party applications and services, and we are not responsible for how those third parties collect, use and disclose your information and content.

• We encourage you to review the privacy policies of those third parties before connecting to or using their applications or services to learn more about their information and privacy practices.

Compliance with Laws

We may disclose your information to a third-party if we believe that disclosure is reasonably necessary to comply with any applicable law, regulation, legal process, court order, or governmental request.

Company Policy Compliance

To enforce our agreements, policies, or Terms of Use, including for billing and collection purposes; To protect the security or integrity of MSI products, services, or website;

 To protect MSI, our customers, or the public from harm or illegal activities;

 To respond to an emergency which we believe in the good faith requires us to disclose information to assist in preventing the death or serious bodily injury of any person; or,

 To any other third party with your prior consent.

If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of MSI, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Business Transfers

To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer ofsome or all of MSI’s assets, whether as a going concern or as part of bankruptcy, liquidation, orsimilar proceeding, in which personal information held by MSI about our Website users is among the assets transferred.

Other  To our subsidiaries and affiliates.

 For any other purpose disclosed by us when you provide the information.

 With your consent.

Below are the Categories of Personal Information we disclose to each type of third party. We may share your Personal Information with certain categories of third parties, as described in TABLE A below.

SECURITY

While no product, service or website can offer a guarantee to be completely secure, MSI takes reasonable measures to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. The servers on which personal information is stored are kept in a controlled environment with limited access. While we take reasonable efforts to guard personal information we knowingly collect directly from you, no security system is guaranteed to be impenetrable. In addition, we cannot guarantee that any passively collected personal information you choose to store on our systems is maintained at levels of protection to meet specific needs or obligations you may have relating to that information.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Website like message boards. The information you share in public areas may be viewed by any user of the Website. To protect the confidentiality of personal information, if you create an account on MSI website, you must keep your password confidential and not disclose it to any other person. Please advise us immediately if you believe your password has been misused. In addition, always logout and close your browser when you finish your session. Please note that we will never ask you to disclose your password in an unsolicited phone call or e-mail. Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained in our products or on the Website. If you have any questions about the security of your personal information, you can contact us at support@marmasec.com.

COOKIES

Cookies and Other Technologies. MSI and our third-party service providers may use cookies, clear GIFs, pixel tags, beacons, and other technologies that help us better understand user behavior, personalize preferences, perform research and analytics, track your shopping cart and order history, deliver tailored advertising, and improve the products and services we provide. MSI or our third-party service providers also may use certain of these technologies in e-mails to help us track email response rates, identify when our emails are viewed, and track whether our e-mails are forwarded. Cookies and Pixels. Cookies are files that websites send to your computer or other Internet-connected device to uniquely identify your browser or to store information or settings on your device. We use them to uniquely recognize your browser when you visit our website. Cookies also allow us and third parties to provide you with a better and more personalized shopping experience and to make you aware of our products and promotionsthat may be of interest to you. Our Service may use HTTP cookies, HTML5 cookies and other types of local storage (such as browser-based or plugin-based local storage). Most web browsers automatically accept cookies, but your browser may allow you to modify your browsersettingsto decline certain cookies if you prefer. If you disable cookies, you may not be able to use all of the features and functionality of this Service. To control which Web servers collect Information by automated means, we may place tags on our Web pages called "Web beacons," which are small files that link Web pages to particular Web servers and their cookies. MSI may also send instructions to your device using JavaScript or other computer languages to gather the sorts of Information described above and other details of your interactions with the Service.

DO NOT TRACK

Some browsers offer a “do not track” (“DNT”) option. Because no common industry or legal standard for DNT has been adopted by industry groups, technology companies or regulators, we do not respond to DNT signals. We will make efforts to continue to monitor developments around DNT browser technology and the implementation of a standard.

CHANGES TO THIS POLICY

We may change this Privacy Policy from time to time. If we make any changes, we will notify you by revising the "Last Updated" date at the top of this Privacy Policy and, in some cases, we may provide you with additional notice (such as adding a statement to our homepage or sending you an e-mail notification). We encourage you to review our Privacy Policy whenever you access MSI website to stay informed about our information practices and the ways you can help protect your privacy. If you disagree with any changes to this Privacy Policy and do not wish your information to be subject to the revisions, you will need to stop using MSI website and MSI products. Your use of any of MSI product or website after the posting of such changes shall constitute your consent to such changes.

YOUR STATE PRIVACY RIGHTS

California Residents If you are a California resident, you can make certain requests regarding your personal information under the California Consumer Privacy Act (CCPA). We will fulfill each of these requests to the extent required by law.

1. You can ask us what personal information we have about you, including a list of categories of your personal information that we have sold and a list of categories of your personal information that we have shared with another company for a business purpose.

2. You can ask us to delete your personal information.

3. You can ask that we stop selling your personal information.

California Residents who have an established business relationship with MSI may choose to opt out of MSI’s disclosure of personal information (as above) to third parties for direct marketing purposes. To exercise the California privacy rights for requesting or deleting your personal information you or your authorized agent should contact us at: support@marmasec.com.

In addition, if you created on-line account on MSI website, you may update, correct or delete information about you at any time by logging into your account and modifying your information. 

MSI takesthe privacy of your personal information seriously and wantsto ensure that we provide only you or your authorized agent with your personal information. Please note that we do not share or sell your personal information for money. The CCPA also requires that we verify the identity of each person who makes a request to know what personal information we have about you or to delete the personal information we have about you. To verify your identity, we ask you to provide your:

First name*

Last name*

Middle initial

Email address*

Phone number

Address*

*required field

Other States

Colorado, Connecticut, Virginia, and Utah each provide their state residents with rights to:

 Confirm whether we process their personal information.

 Access and delete certain personal information.

 Data portability.

 Opt-out of personal data processing for targeted advertising and sales.

Colorado, Connecticut, and Virginia also provide their state residents with rights to:

 Correct inaccuracies in their personal information, taking into account the information's nature processing purpose.

 Opt-out of profiling in furtherance of decisions that produce legal or similarly significant effects.

To exercise any of these rights or appeal a decision regarding a consumer rights request, see: (Colo. Rev. Stat. Ann. § 6-1- 1308(1)(a)(III), (b) (effective July 1, 2023); Section 6(c)(3), (d), (e), Connecticut Session Law 22-15 (effective July 1, 2023); Va. Code Ann. § 59.1-578(C)(3), (D), (E)) (effective January 1, 2023); Utah Code § 13-61-302(1)(a)(iii), (b) (effective December 31, 2023)).

Nevada provides its residents with a limited right to opt-out of certain personal information sales. Residents who wish to exercise this sale opt-out rights may submit a request to this designated address: support@marmasec.com. However, please know we do not currently sell data triggering that statute's opt-out requirements.

INFORMATION RETENTION

MSI may retain your information after you request deletion for longer periods for specific purposes to the extent that we are obliged to do so in accordance with applicable laws and regulations and/or as necessary to protect our legal rights or for certain business requirements. For example, when we process your payments, we will retain this data for longer periods of time as required for tax or accounting purposes. See below for specific reasons we would retain some data for longer periods of time:

 Security, fraud & abuse prevention – to protect you, other people, and us from fraud, abuse, and unauthorized access.

 Financial record-keeping – when you make a payment to us we are often required to retain this information for a long period of time for purposes of accounting, dispute resolution and compliance with tax, anti-money laundering, and other financial regulations.

 Complying with legal or regulatory requirements – to meet any applicable law, regulation, legal process, or enforceable governmental request, as required to enforce our terms of service, including investigation of potential violations.

 Direct communications with us – if you have directly communicated with us, through a customer support channel, feedback form, or a bug report, we may retain reasonable records of those communications.

TESTIMONIALS

We may use publicly available testimonials and endorsements, or testimonials and endorsements presented in a public forum, regarding our products or website in MSI promotional materials and websites. We may also provide you with the opportunity to share your reviews, thoughts, or comments regarding your relationship with MSI. Such testimonial information may include your personal experiences with our products or services that you choose to submit through the MSI website or via e-mail. MSI reserves the right to monitor content or information provided by you at its sole discretion, to edit or remove any content that, in MSI's judgment, does not comply with the Privacy Policy, or is otherwise objectionable, inappropriate, or inaccurate. MSI is not responsible for any user-generated content that is posted on our website or for any failure or delay in removing such content. You can also request that we remove your testimonial any time by contacting us at support@marmasec.com.

LINKS TO THIRD PARTY WEBSITES

We may include third-party links in our website. When you click on a link to a third-party website, your activity and use on the linked website is governed by that website’s policies, not by those of MSI. The collection, use, and disclosure of your personal and other information will be subject to the privacy policies of the third party websites or services, and not this Privacy Policy. You should read the privacy and security policies of these third-parties. The inclusion of any link does not imply our endorsement of the external site company, its website or websites, or the products or services it promotes or sells.

TABLE A: