Privacy Policy | Titan Systems

ASCENTIAL TECHNOLOGIES PRIVACY NOTICE

Effective Date: September 14, 2023

Last Reviewed on: September 14, 2023

Ascential Technologies’s (the “Ascential Technologies” or “we” “us” “our”) Privacy Notice describes the types of Personal information we collect, the purposes for which we collect that Personal information, the other parties with whom we may share it and the measures we take to protect the security of the data. This Notice also explains your rights and choices with respect to your Personal information, and how you can contact us about our privacy practices.

Our privacy practices may vary among the countries in which we operate so we can adhere to local requirements.

INFORMATION WE COLLECT

We collect information through our services and/or website that relates to an identified or identifiable person (“personal information”).

In particular, we collect the following personal information:

name

email address

phone number

location

operating system

browser type

preferences regarding online marketing

IP address

cookie data

We obtain the categories of personal information listed above from the following categories of sources:

Directly from you. For example, from forms you complete or products and services you purchase.

Indirectly from you. For example, from observing your actions on our websites.

USE OF PERSONAL INFORMATION

We may use, or disclose the personal information we collect for one or more of the following purposes:

To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.

To provide, support, personalize, and develop our websites, products, and services.

To establish and maintain your relationship with us.

To process your requests, purchases, transactions, and payments and prevent transactional fraud.

To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.

To personalize and improve your website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our websites, third-party sites, and via email or newsletters.

To help maintain the safety, security, and integrity of our websites, products and services, databases and other technology assets, and business.

For testing, research, analysis, and product development, including to develop and improve our website, products, and services.

To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

To enforce applicable Terms of Service, Terms of Use, or other potential violation of Ascential Technologies contracts or rules, including investigation of potential violations.

To detect, prevent, investigate or otherwise address fraud, security or technical issues.

To protect against harm to the rights, property or safety of Ascential Technologies, our users or the public as required or permitted by law.

As described to you when collecting your personal information or as otherwise set forth under applicable privacy laws.

To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our consumers is among the assets transferred.

Added to sales database and used for email marketing to inform about how our products and services are or may be used.

To report on marketing results.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice. In addition, we will only process your personal information if we have a lawful basis to do so. Most commonly, we will process your personal information in the following circumstances:

Where we need to perform the contract we are about to enter into or have entered into with you.

Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

Where we need to comply with a legal obligation.

Where you have given us clear consent to process your personal information.

SHARING PERSONAL INFORMATION

We may disclose your personal information to certain third parties. Prior to disclosing your information, we enter into a contract with the third party that imposes appropriate data privacy and security safeguards as required by applicable laws. Such agreements restrict the third parties’ use of the information to the processing expressly agreed upon in the contract.

We share your personal information with the following categories of third parties:

Software/IT service providers we use to assist with our website and IT infrastructure and to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.

Third-party software providers, including ‘software as a service’ solution providers, where the provider hosts the relevant personal information on our behalf;

Our advertising and promotional agencies and consultants and those organizations selected by us to carry out marketing campaigns on our behalf; and/or

Providers that help us store, collate and organize information effectively and securely, both electronically and in hard copy format, and for marketing purposes.

CHILDREN’S PRIVACY

Our website and services are not directed to, or intended for children under 16 years of age. 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, 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, or based on another legal basis in accordance with applicable law, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at privacy@ascentialtech.com.

YOUR RIGHTS AND CHOICES

Depending on the privacy laws of the country in which you reside, you may have the right or choice to:

Request access to your personal information. This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.

Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal information to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal information for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal information. This enables you to ask us to suspend the processing of your personal information in the following scenarios:

If you want us to establish the data’s accuracy.

Where our use of the data is unlawful but you do not want us to erase it.

Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.

You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal information to you or to a third party. We will provide to you, or a third party you have chosen, your personal information in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Appeal a decision. You may have the right to appeal a decision we make regarding the exercise of your privacy rights.

Lodge a complaint. You may have the right to lodge a complaint with your national Data Protection Authority or equivalent regulatory body.

Not to be subjected to automated decision-making. Automated decisions are decisions made automatically based on computer determinations (using software algorithms), without human review. You will not be subject to decisions that have a significant impact on you based solely on automated decision-making, unless we have notified you and have a lawful basis for such processing.

This list may not be exhaustive and your local laws may confer additional privacy rights. In addition, your privacy rights may be limited in some circumstances by certain legal requirements under local law.

You, or a party authorized to act on your behalf, may exercise your privacy rights by contacting us via our Contact Us page or write to us at:

Email: privacy@ascentialtech.com

Phone: +1 (616) 855-1480

Or by using the following mail address: 975 Spaulding Ave, Suite C Ada, MI 49301, United States

In certain jurisdictions, you can exercise your choice regarding the use of cookies and similar technologies by clicking on the cookie banner displayed on the landing page of our websites.

In addition, you may opt-out of marketing messages at any time by following the opt-out links on any marketing message sent to you, by contacting us at any time.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month or forty-five (45) days in some jurisdictions. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

DATA TRANSFERS

We may transfer your personal information to the United States and other countries which may not have the same data protection laws as the country in which you initially provided the information, but we will protect your personal information in accordance with this Privacy or as otherwise disclosed to you.

We comply with applicable legal requirements when transferring Personal Information to countries other than the country where you are located. If you are located in the EEA, we will transfer your Personal Information in accordance with adequacy decisions, standard contractual clauses, and other data transfer mechanisms.

The laws of your country may grant you the right to direct us to produce a copy of the safeguards we use to transfer personal information outside of your jurisdiction.

DATA SECURITY

We maintain reasonable administrative, technical and physical safeguards designed to protect the Personal information you provide or we collect against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. We use SSL encryption on a number of our websites from which we transfer certain Personal information. 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 on the website.

We also take measures to delete your personal information or keep it in a form that does not permit identifying you when this information is no longer necessary for the purposes for which we process it, unless we are required by law to keep this information for a longer period. When determining the retention period, we take into account various criteria, such as [Input from client required . . (i.e., the type of products and services requested by or provided to you, mandatory retention periods provided by law and the statute of limitations.)

GOOGLE ANALYTICS

Our websites use Google Analytics, a web analysis service provided by Google Inc. (“Google”). Google Analytics works using cookies. Google Analytics cookies collect your IP address; however, because IP anonymization is used on this website, your IP address will be shortened (and therefore anonymised) as soon as technically possible and before it is stored or otherwise used in connection with Google Analytics. The anonymization process takes place within the European Union or the European Economic Area, except in exceptional cases, where your full IP address may be sent to a Google server in the United States and shortened there. We use the information collected by Google Analytics cookies to find out about how visitors use our websites. Google will not combine the IP address sent by your browser in connection with Google Analytics, with other data. You can prevent Google Analytics cookies from being stored by setting your browser software accordingly. You can also opt-out of Google Analytics by downloading and installing the browser plug-in available at google.com.

CHANGES TO OUR PRIVACY NOTICE

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the websites and update the notice’s effective date. Your continued use of the services or our websites following the posting of changes constitutes your acceptance of such changes.

CONTACT INFORMATION

If you have any questions or comments about this notice, the ways in which the Company collects and uses your information described in this Privacy Policy, your choices and rights regarding such use, or wish to exercise your privacy rights, please do not hesitate to contact us at:

Email: privacy@ascentialtech.com

Phone: +1 (616) 855-1480

Or by using the following mail address: 975 Spaulding Ave, Suite C Ada, MI 49301, United States

CCPA Notice

ASCENTIAL TECHNOLOGIES PRIVACY NOTICE FOR CALIFORNIA RESIDENTS

Effective Date:January 1, 2020

This Privacy Notice for California Residents applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) as amended by the California Privacy Rights Act of 202 (“CPRA”). Any terms defined in the CCPA have the same meaning when used in this Notice.

INFORMATION WE COLLECT

We collect through our services or website 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 consumer, household, or device (“personal information“). Personal information does not include:

Publicly available information from government records.

Deidentified or aggregated consumer information.

Information excluded from the CCPA’s scope, such as:
- health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
- personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:

a) name

b) email address

c) phone number

d) location

e) operating system

f) browser type

g) cookie data (for more information please see our Cookie Notice)

h) preferences regarding online marketing

i) IP address

We obtain the categories of personal information listed above from the following categories of sources:

Directly from you. For example, from forms you complete or products and services you purchase.

Indirectly from you. For example, from observing your actions on our websites.

USE OF PERSONAL INFORMATION

We may use, or disclose the personal information we collect for one or more of the following purposes:

To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.

To provide, support, personalize, and develop our websites, products, and services.

To establish and maintain your relationship with us.

To process your requests, purchases, transactions, and payments and prevent transactional fraud.

To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.

To personalize and improve your website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our websites, third-party sites, and via email or newsletters.

To help maintain the safety, security, and integrity of our websites, products and services, databases and other technology assets, and business.

For testing, research, analysis, and product development, including to develop and improve our website, products, and services.

To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

To enforce applicable Terms of Service, Terms of Use, or other potential violation of Ascential Technologies contracts or rules, including investigation of potential violations.

To detect, prevent, investigate or otherwise address fraud, security or technical issues.

To protect against harm to the rights, property or safety of Ascential Technologies, our users or the public as required or permitted by law.

As described to you when collecting your personal information or as otherwise set forth in the CCPA.

To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our consumers is among the assets transferred.

Added to sales database and used for email marketing to inform about how our products and services are or may be used.

To report on marketing results.

DISCLOSING PERSONAL INFORMATION

We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

We share your personal information with the following categories of third parties:

Software/IT service providers we use to assist with our website and IT infrastructure and to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.

third party software providers, including ‘software as a service’ solution providers, where the provider hosts the relevant personal data on our behalf;

our advertising and promotional agencies and consultants and those organizations selected by us to carry out marketing campaigns on our behalf; and/or

providers that help us store, collate and organize information effectively and securely, both electronically and in hard copy format, and for marketing purposes.

DISCLOSURES OF PERSONAL INFORMATION FOR A BUSINESS PURPOSE

In the preceding twelve (12) months, Company has disclosed the following categories of personal information for a business purpose:

Category A: Identifiers.

Category B: California Customer Records personal information categories.

Category D: Commercial information.

Category F: Internet or other similar network activity.

We disclose your personal information for a business purpose to the following categories of third parties:

Software/IT service providers and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.

COMPANY MERGERS AND TAKEOVERS

We may transfer your personal data to potential purchasers and their advisors, subject to appropriate confidentiality obligations, in the event we decide to dispose of all or parts of our business.

YOUR RIGHTS AND CHOICES

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

ACCESS TO SPECIFIC INFORMATION AND DATA PORTABILITY RIGHTS

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion), we will disclose to you:

The categories of personal information we collected about you.

The categories of sources for the personal information we collected about you.

Our business or commercial purpose for collecting, or selling or sharing that personal information.

The categories of third parties with whom we shareto whom we disclose that personal information.

The specific pieces of personal information we collected about you (also called a data portability request).

DELETION REQUEST RIGHTS

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.

Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

Debug products to identify and repair errors that impair existing intended functionality.

Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.

Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).

Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.

Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.

Comply with a legal obligation.

Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

RIGHT TO CORRECT

You have the right to request that we correct inaccurate personal information that we maintain about you. Upon verifying the validity of the verifiable consumer request, we will use commercially reasonable efforts to correct your personal information as directed, taking in to account the nature of the personal information and the purposes of maintaining the personal information.

RIGHT TO OPT-OUT OF SALE OR SHARING

In the preceding twelve (12) months, the Company has not sold or shared personal information.

RIGHT TO LIMIT USE OR DISCLOSURE OF SENSITIVE PERSONAL INFORMATION

To the extent we use or disclose sensitive personal information, such processing is restricted to the following business purposes:

Perform services or provide goods that an average consumer requesting those goods or services would reasonably expect.

Help ensure security and integrity, as the CCPA defines those terms, if that use is reasonably necessary and proportionate.

Perform short-term, transient uses, including but not limited to non-personalized advertising shown as part of a consumer’s current interaction with the business, if the business does not:
- disclose the sensitive personal information to another third party; or
- use it to build a profile about the consumer or otherwise alter the consumer’s experience outside their current interaction with the business.

Perform services for the business, including:
- maintaining or servicing accounts;
- providing customer service;
- processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing, storage, or providing similar services for the business.

Verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business.

Improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business.

EXERCISING ACCESS, DATA PORTABILITY, CORRECTION AND DELETION RIGHTS

To exercise the access, data portability, correction and deletion rights described above, please submit a verifiable consumer request to us by:

Email: privacy@ascentialtech.com

Phone: +1 (616) 855-1480

U.S. Mail: 975 Spaulding Ave, Suite C Ada, MI 49301, United States

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. To designate an authorized agent, please contact us through the methods noted above.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include:
- [include at least two data points you need to verify a consumer request (i.e., name and email address).

Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

Making a verifiable consumer request does not require you to create an account with us. However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account.

We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

RESPONSE TIMING AND FORMAT

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing. We will confirm receipt of your request within ten (10) business days.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

PERSONAL INFORMATION SALES OPT-OUT AND OPT-IN RIGHTS

We do not currently sell or share the personal information of consumers.

NON-DISCRIMINATION

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

Deny you goods or services.

Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.

Provide you a different level or quality of goods or services.

Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

CHILDREN’S PRIVACY

DATA SECURITY

CHANGES TO OUR PRIVACY NOTICE

CONTACT INFORMATION

If you have any questions or comments about this notice, the ways in which we collect and use your information described in this Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Email: privacy@ascentialtech.com

Phone: +1 (616) 855-1480

Or by using the following mail address: 975 Spaulding Ave, Suite C Ada, MI 49301, United States