Version Date: February 21, 2025

GENERAL

Latitude (“Company” or “we” or “us” or “our”) respects the privacy of its users (“user” or “you”) that use our website located at www.latitudeinfosec.com, including other media forms, media channels, mobile website or mobile application related or connected thereto (collectively, the “Website”). The following Company privacy policy (“Privacy Policy”) is designed to inform you, as a user of the Website, about the types of information that Company may gather about or collect from you in connection with your use of the Website. It also is intended to explain the conditions under which Company uses and discloses that information, and your rights in relation to that information in compliance with applicable regulatory bodies like the General Data Protection Regulation (GDPR). Changes to this Privacy Policy are discussed at the end of this document. Each time you use the Website, however, the current version of this Privacy Policy will apply. Accordingly, each time you use the Website you should check the date of this Privacy Policy (which appears at the beginning of this document) and review any changes since the last time you used the Website.

The Website is hosted in the United States of America and is subject to U.S. state and federal law. If you are accessing our Website from other jurisdictions, please be advised that you are transferring your personal information to us in the United States, and by using our Website, you consent to that transfer and use of your personal information in accordance with this Privacy Policy. You also agree to abide by the applicable laws of applicable states and U.S. federal law concerning your use of the Website and your agreements with us. Any persons accessing our Website from any jurisdiction with laws or regulations governing the use of the Internet, including personal data collection, use and disclosure, different from those of the jurisdictions mentioned above may only use the Website in a manner lawful in their jurisdiction. If your use of the Website would be unlawful in your jurisdiction, please do not use the Website.

BY USING OR ACCESSING THE WEBSITE, YOU ARE ACCEPTING THE PRACTICES DESCRIBED IN THIS PRIVACY POLICY.

GATHERING, USE, AND DISCLOSURE OF NON-PERSONALLY IDENTIFYING INFORMATION

Users of the Website Generally

“Non-Personally Identifying Information” is information that, without the aid of additional information, cannot be directly associated with a specific person. “Personally Identifying Information,” by contrast, is information such as a name or email address that, without more, can be directly associated with a specific person. Like most website operators, Company gathers from users of the Website Non-Personally Identifying Information of the sort that Web browsers, depending on their settings, may make available. That information includes the user’s Internet Protocol (IP) address, operating system, browser type and the locations of the websites the user views right before arriving at, while navigating and immediately after leaving the Website. Although such information is not Personally Identifying Information, it may be possible for Company to determine from an IP address a user’s Internet service provider and the geographic location of the visitor’s point of connectivity as well as other statistical usage data. Company analyzes Non-Personally Identifying Information gathered from users of the Website to help Company better understand how the Website is being used. By identifying patterns and trends in usage, Company is able to better design the Website to improve users’ experiences, both in terms of content and ease of use. From time to time, Company may also release the Non-Personally Identifying Information gathered from Website users in the aggregate, such as by publishing a report on trends in the usage of the Website.

Web Beacons

A “Web Beacon” is an object that is embedded in a web page or email that is usually invisible to the user and allows website operators to check whether a user has viewed a particular web page or an email. Company may use Web Beacons on the Website and in emails to count users who have visited particular pages, viewed emails and to deliver co-branded services. Web Beacons are not used to access users’ Personally Identifying Information. They are a technique Company may use to compile aggregated statistics about Website usage. Web Beacons collect only a limited set of information, including a Web Cookie number, time and date of a page or email view and a description of the page or email on which the Web Beacon resides. You may not decline Web Beacons. However, they can be rendered ineffective by declining all Web Cookies or modifying your browser setting to notify you each time a Web Cookie is tendered, permitting you to accept or decline Web Cookies on an individual basis.

Aggregated and Non-Personally Identifying Information

We may share aggregated and Non Personally Identifying Information we collect under any of the above circumstances. We may also share it with third parties and our affiliate companies to develop and deliver targeted advertising on the Website and on websites of third parties. We may combine Non-Personally Identifying Information we collect with additional Non Personally Identifying Information collected from other sources. We also may share aggregated information with third parties, including advisors, advertisers and investors, for the purpose of conducting general business analysis. For example, we may tell our advertisers the number of visitors to the Website and the most popular features or services accessed. This information does not contain any Personally Identifying Information and may be used to develop website content and services that we hope you and other users will find of interest and to target content and advertising.

Social Media

We may use hyperlinks on the Website which will redirect you to a social network if you click on the respective link. However, when you click on a social plug-in, such as Facebook’s “Like” button, Twitter’s “tweet” button or the Google+, that particular social network’s plugin will be activated and your browser will directly connect to that provider’s servers. If you do not use these buttons, none of your data will be sent to the respective social network’s plugin provider. So for example, when you click on the Facebook’s “Like” button on the Website, Facebook will receive your IP address, the browser version and screen resolution, and the operating system of the device you have used to access the Website. Settings regarding privacy protection can be found on the websites of these social networks and are not within our control.

COLLECTION, USE AND DISCLOSURE OF PERSONALLY IDENTIFYING INFORMATION

General Use

Company uses the Personally Identifying Information in the data we maintain about you, and other information we obtain from your current and past activities on the Website, to:

(1) deliver the products and services that you have requested,

(2) manage your account and provide you with customer support,

(3) communicate with you by email, postal mail, telephone and/or mobile devices about products or services that may be of interest to you either from us, our affiliate companies or other third parties,

(4) develop and display content and advertising tailored to your interests on the Website and other sites,

(5) resolve disputes and troubleshoot problems,

(6) measure consumer interest in our services,

(7) inform you of updates,

(8) customize your experience,

(9) detect and protect us against error, fraud and other criminal activity,

(10) enforce our Terms of Use, and

(11) do as otherwise described to you at the time of collection.

At times, we may look across multiple users to identify problems. In particular, we may examine your Personally Identifying Information to identify users using multiple user IDs or aliases. We may compare and review your Personally Identifying Information for accuracy and to detect errors and omissions. We may use financial information or payment method to process payment for any purchases made on the Website, enroll you in the discount, rebate, and other programs in which you elect to participate, to protect against or identify possible fraudulent transactions and otherwise as needed to manage our business.

Website Registration

As defined above, Personally Identifying Information is information that can be directly associated with a specific person. Company may collect a range of Personally Identifying Information from and about Website users. Much of the Personally Identifying Information collected by Company about users is information provided by users themselves when

(1) registering for our service,

(2) logging in with social network credentials,

(3) participating in polls, contests, surveys or other features of our service, or responding to offers or advertisements,

(4) communicating with us,

(5) creating a public profile, or

(6) signing up to receive newsletters.

That information may include each user’s name, address, email address and telephone number, and, if you transact business with us, financial information such as your payment method (valid credit card number, type, expiration date or other financial information). We also may request information about your interests and activities, your gender, age, date of birth, username, hometown and other demographic or relevant information as determined by Company from time to time. Users of the Website are under no obligation to provide Company with Personally Identifying Information of any kind, with the caveat that a user’s refusal to do so may prevent the user from using certain Website features.

BY REGISTERING WITH OR USING THE WEBSITE, YOU CONSENT TO THE USE AND DISCLOSURE OF YOUR PERSONALLY IDENTIFYING INFORMATION AS DESCRIBED IN THIS “COLLECTION, USE AND DISCLOSURE OF PERSONALLY IDENTIFYING INFORMATION” SECTION.

Web Cookies

A “Web Cookie” is a string of information which assigns you a unique identification that a website stores on a user’s computer, and that the user’s browser provides to the website each time the user submits a query to the website. We use cookies on the Website to keep track of services you have used, to record registration information regarding your login name and password, to record your user preferences, to keep you logged into the Website and to facilitate purchase procedures. Company also uses Web Cookies to track the pages that users visit during each Website session, both to help Company improve users’ experiences and to help Company understand how the Website is being used. As with other Non-Personally Identifying Information gathered from users of the Website, Company analyzes and discloses in aggregated form information gathered using Web Cookies, so as to help Company, its partners and others better understand how the Website is being used. COMPANY USERS WHO DO NOT WISH TO HAVE WEB COOKIES PLACED ON THEIR COMPUTERS SHOULD SET THEIR BROWSERS TO REFUSE WEB COOKIES BEFORE ACCESSING THE WEBSITE, WITH THE UNDERSTANDING THAT CERTAIN FEATURES OF THE WEBSITE MAY NOT FUNCTION PROPERLY WITHOUT THE AID OF WEB COOKIES. WEBSITE USERS WHO REFUSE WEB COOKIES ASSUME ALL RESPONSIBILITY FOR ANY RESULTING LOSS OF FUNCTIONALITY.

Analytics

We may use third-party vendors, including Google, who use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick cookie) together to inform, optimize and serve ads based on your past activity on the Website, including Google Analytics for Display Advertising. The information collected may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity. If you do not want any information to be collected and used by Google Analytics, you can install an opt-out in your web browser (tools.google.com) and/or opt out from Google Analytics for Display Advertising or the Google Display Network by using Google’s Ads Settings (google.com/settings/ads).

Company Communications

We may occasionally use your name and email address to send you notifications regarding new services offered by the Website that we think you may find valuable. We may also send you service-related announcements from time to time through the general operation of the service. Generally, you may opt out of such emails at the time of registration or through your account settings, though we reserve the right to send you notices about your account, such as service announcements and administrative messages, even if you opt out of all voluntary email notifications.

Company Disclosures

Company will disclose Personally Identifying Information under the following circumstances:

• By Law or to Protect Rights. When we believe disclosure is appropriate, we may disclose Personally Identifying Information in connection with efforts to investigate, prevent or take other action regarding illegal activity, suspected fraud or other wrongdoing; to protect and defend the rights, property or safety of Company, our users, our employees or others; to comply with applicable law or cooperate with law enforcement; to enforce our Terms of Use or other agreements or policies, in response to a subpoena or similar investigative demand, a court order or a request for cooperation from a law enforcement or other government agency; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by law. In such cases, we may raise or waive any legal objection or right available to us.
• Marketing Communications. Unless users opt-out from receiving Company marketing materials upon registration, Company may email users about products and services that Company believes may be of interest to them. If you wish to opt-out of receiving marketing materials from Company, you may do so by following the unsubscribe link in the email communications, by going to your account settings (if applicable) or contacting us using the contact information below.
• Third-Party Service Providers. We may share your Personally Identifying Information, which may include your name and contact information (including email address) with our authorized service providers that perform certain services on our behalf. These services may include fulfilling orders, providing customer service and marketing assistance, performing business and sales analysis, supporting the Website’s functionality and supporting contests, sweepstakes, surveys and other features offered through the Website. We may also share your name, contact information and credit card information with our authorized service providers who process credit card payments. These service providers may have access to personal information needed to perform their functions but are not permitted to share or use such information for any other purpose.
• Business Transfers; Bankruptcy. Company reserves the right to transfer all Personally Identifying Information in its possession to a successor organization in the event of a merger, acquisition, bankruptcy or other sale of all or a portion of Company’s assets. Other than to the extent ordered by a bankruptcy or other court, the use and disclosure of all transferred Personally Identifying Information will be subject to this Privacy Policy, or to a new privacy policy if you are given notice of that new privacy policy and are given an opportunity to affirmatively opt-out of it. Personally Identifying Information submitted or collected after a transfer, however, may be subject to a new privacy policy adopted by the successor organization.

Collection and Use of Information by Third Parties Generally

Company contractually prohibits its contractors, affiliates, vendors and suppliers from disclosing Personally Identifying Information received from Company, other than in accordance with this Privacy Policy. However, third parties are under no obligation to comply with this Privacy Policy with respect to Personally Identifying Information that users provide directly to those third parties, or that those third parties collect for themselves. These third parties include advertisers, providers of games, utilities, widgets and a variety of other third-party applications accessible through the Website. Company neither owns nor controls the third-party websites and applications accessible through the Website. Thus, this Privacy Policy does not apply to information provided to or gathered by the third parties that operate them. Before visiting a third party, or using a third-party application, whether by means of a link on the Website, directly through the Website or otherwise, and before providing any Personally Identifying Information to any such third party, users should inform themselves of the privacy policies and practices (if any) of the third party responsible for that website or application, and should take those steps necessary to, in those users’ discretion, protect their privacy.

DATA SUBJECT RIGHTS

Depending on your location, such as under the GDPR for EU residents or under US state law, you may have certain rights regarding your Personally Identifying Information. If you reside in a jurisdiction that provides these rights, you may be able to exercise the following:

• Right to Access

You can request information about the personal data we hold about you, including details on how and why your data is processed, and obtain a copy of that data.

• Right to Rectification

Should you find any inaccuracies or incomplete information in the personal data we maintain, you have the right to request that we update or correct it.

• Right to Erasure

In certain circumstances, you may request the deletion of your personal data—especially if the data is no longer necessary for the purposes for which it was collected or if you withdraw your consent—subject to any legal obligations that require us to retain the data.

• Right to Restrict Processing

You may ask us to limit the processing of your personal data. This right can apply if you contest the accuracy of your data, if you object to its processing, or if processing is unlawful and you prefer that we restrict it instead of deleting it outright.

• Right to Object

You can object to the processing of your personal data based on our legitimate interests, including for direct marketing purposes. Upon receiving your objection, we will review your request and, where appropriate, cease processing your data unless we can demonstrate compelling legitimate grounds that override your interests.

• Right to Data Portability

Where applicable, you have the right to receive your personal data in a structured, commonly used, and machine-readable format and to have that data transferred directly to another data controller, where technically feasible.

Please contact us using the details provided in the Contact section of this Privacy Policy to exercise your rights. We will process your request promptly in accordance with applicable legal requirements.

SECURITY

We take the security of your Personally Identifying Information seriously and use reasonable electronic, personnel and physical measures to protect it from loss, theft, alteration or misuse. However, please be advised that even the best security measures cannot fully eliminate all risks. We cannot guarantee that only authorized persons will view your information. We are not responsible for third-party circumvention of any privacy settings or security measures.

We are dedicated to protect all information on the Website as is necessary. However, you are responsible for maintaining the confidentiality of your Personally Identifying Information by keeping your password confidential. You should change your password immediately if you believe someone has gained unauthorized access to it or your account. If you lose control of your account, you should notify us immediately.

DATA RETENTION

Company retains your Personally Identifying Information and Non-Personally Identifying Information only for as long as necessary to fulfill the purposes described in this Privacy Policy, including to provide you with our services, maintain and improve the Website, and to satisfy our legal, regulatory, and business requirements. Once the purposes for which the data was collected have been fulfilled, and once any applicable legal, accounting, or reporting obligations have been met, we will either securely delete or anonymize your data, subject to any applicable exceptions provided by law.

In determining the appropriate retention period, we consider the nature and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process the data, and the applicable legal requirements. You may request further information regarding our data retention practices by contacting us at the details provided in the Contact section of this Privacy Policy.

CHILDREN’S PRIVACY

Our Website is not intended for individuals under the age of eighteen (18), and we do not knowingly target or solicit personal information from anyone under eighteen (18). If you are under eighteen (18), please do not attempt to provide any Personally Identifying Information on the Website or to Company. In the event that we inadvertently collect information from a person under the age of eighteen (18), we will promptly take steps to delete such information from our records once we are made aware of such collection. If you believe that we have collected information from a minor in error, please contact us immediately using the details provided in the Contact section of this Privacy Policy.

PRIVACY POLICY CHANGES

Company may, in its sole discretion, change this Privacy Policy from time to time. Any and all changes to Company’s Privacy Policy will be reflected on this page and the date new versions are posted will be stated at the top of this Privacy Policy. Unless stated otherwise, our current Privacy Policy applies to all information that we have about you and your account. Users should regularly check this page for any changes to this Privacy Policy. Company will always post new versions of the Privacy Policy on the Website. However, Company may, as determined in its discretion, decide to notify users of changes made to this Privacy Policy via email or otherwise. Accordingly, it is important that users always maintain and update their contact information.

CALIFORNIA PRIVACY RIGHTS

If you are residing in the State of California (“resident”, “consumer”, or “you”), you have certain rights regarding your personal information under the California Consumer Privacy Act (CCPA) and related regulations, including the California Privacy Rights Act (CPRA), that Latitude (“Company” or “we” or “us” or “our”) will ensure are protected when using our Website.

PERSONALLY IDENTIFIABLE INFORMATION COLLECTED

We may collect information that identifies, relates to, describes, references, or is reasonably capable of being associated with or could reasonably be linked, directly or indirectly, to you or your device (“personal information”), provided by you during your usage of our Website. The categories of personal information we may have collected within the past twelve (12) months include, but are not limited to

(1) First name,

(2) Last name,

(3) Zip code,

(4) Email address,

(5) Telephone number,

(6) Internet Protocol (IP) address,

(7) Operating system,

(8) Browser type,

(9) Cookies, and

(10) Demographic information (e.g., race, age, gender) if voluntarily provided.

We use these categories of personal information for the business and commercial purposes described in this Privacy Policy, including providing requested services, improving your experience, and complying with applicable laws and regulations.

We may share your personal information with third parties for legitimate business and commercial purposes. In such cases, we require that these recipients protect and process your data in full compliance with all applicable laws and regulations.

We retain personal information only for as long as necessary to achieve the purposes described in this Privacy Policy, unless a longer retention period is required by law.

CALIFORNIA CONSUMER RIGHTS

To exercise any of these rights, please submit a request to our Privacy Officer using the contact information provided in the Contact section of this Privacy Policy. We will verify your identity as required and respond to your request in accordance with applicable law.

• Right to Know

You have the right to request that we disclose the categories and specific pieces of personal information we have collected about you, the sources from which that information was collected, the business or commercial purposes for collecting or selling it, and the categories of third parties with whom we share your personal information.

• Right to Delete

You may request that we delete the personal information we have collected about you, subject to certain exceptions required by law. This right applies to personal information that is not necessary for us to retain for legal, security, or business operational purposes.

• Right to Correct

You have the right to request that we correct inaccurate or incomplete personal information that we maintain about you.

• Right to Data Portability

Where applicable, you have the right to receive your personal information in a structured, commonly used, and machine-readable format and, if technically feasible, to request that we transmit that information directly to another entity.

• Right to Opt-Out of the Sale of Personal Information

If applicable, you have the right to direct us not to sell your personal information to third parties. We will provide a clear and accessible “Do Not Sell My Personal Information” link on our Website for you to exercise this right at any time.

• Right to Non-Discrimination

We will not discriminate against you for exercising any of your rights under the CCPA and CPRA. This means you will not receive different levels of service or be subject to different terms or pricing solely because you have exercised your rights.

“SHINE THE LIGHT” LAW

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about the Personally Identifying Information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year. If applicable, this information would include a list of the categories of the Personally Identifying Information that was shared and the names and addresses of all third parties with which we shared Personally Identifying Information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to our Privacy Officer as listed below.

VERIFICATION PROCESS

When you submit a request to exercise your rights under the CCPA, CPRA, or other applicable data protection laws, we may ask you to provide additional information to verify your identity. This verification process is designed to protect your personal information and ensure that only you or someone authorized to act on your behalf can access or modify your data. For example, we may request information such as your full name, email address, account number, or other details that help us confirm your identity. We will handle this information securely and use it solely for the purpose of processing your request in compliance with applicable law. If you have any questions about the verification process or need assistance, please contact our Privacy Officer using the details provided in the Contact section of this Privacy Policy.

DO-NOT-TRACK POLICY

Most web browsers and some mobile operating systems include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. Because there is not yet a common understanding of how to interpret the DNT signal, the Website currently does not respond to DNT browser signals or mechanisms.

CONTACT

If you have any questions regarding our Privacy Policy, please contact our Privacy Officer at:

Elizabeth Orobono
Latitude Information Security
736 Springdale Drive
Exton, PA 19341
[email protected]
(610) 425 – 9932