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CYBERCECURITY

Privacy Policy

Copyright@ 2021 TurnkeyCyberSecurityandPrivacySolutions, LLC, All rights reserved.
LAST UPDATED ON: April 5, 2021

TurnkeyCyberSecurityandPrivacySolutions, collects your personal information for a variety of reasons. This Privacy Policy applies to personal information we collect from you in the course of our business and the delivery of Services to you, including information which is collected through our website, www.TurnkeyCyberSecurityandPrivacySolutions.com, (the "site").

You should read this Policy before using this Site or otherwise providing us with personal information. If you choose to use the Site or otherwise provide us with information about you, you are telling us you have read and agree to the terms of this Privacy Policy and consent to our actions that are consistent with this Privacy Policy.



SCOPE OF THIS PRIVACY POLICY


TurnkeyCyberSecurityandPrivacySolutions, LLC was formed in March 2016 via a merger of the founder's two previous companies Denver Cyber Security, LLC and Information Risk Strategy Consultants, LLC. The two companies had been officially collaborating on projects for some time previous to the merger until it made sense to combine the two operations.

INFORMATION COLLECTION


We collect information about you. This information may include:

  • Information about you that you provide us, for example, by registering to use the site or ordering products on the Site;
  • Information that you otherwise provide us; and
  • Information we collect by automated means.

INFORMATION USE


We do not sell or lease your Personal Information. We may use this Personal Information for our business purposes, for example:

  • Customer service and marketing to you;
  • Sharing this information with third parties who are working with or for us;
  • Improving our products and services;
  • Communication with you; and
  • Compliance with our legal obligations.

More information on our uses of your Personal Information can be found here.

DATA SECURITY


We are concerned with the security of your Personal Information and take care in implementing appropriate physical, technical and administrative safeguards. Unfortunately, no data transmission over the Internet, nor any data we collect or store, can be guaranteed to be 100% secure. As a result, while we strive to protect your Personal Information, we cannot guarantee the security of any information you transmit to us. Further information on our security procedures and your responsibility for security can be found here.

DATA ACCESS, INTEGRITY & CHOICE


You have choices about whether we use your Personal Information to communicate with you and, if we do communicate with you, what form that communication takes. We will use and share your Personal Information as described in the "Information Use" section of this Privacy Policy. If you wish for us to stop using your Personal Information to communicate with you, you can write us and tell us that you no longer consent to such use (you opt-out). You may also contact us to inquire as to what Personal Information about you we possess. Please do so by contacting us at the address below.

If you opt-out, we will continue to retain and use your personal information for limited purposes. Click here for a fuller explanation.

For more information regarding your options with respect to access, integrity and choice, please click here.

OTHER AGREEMENTS REGARDING CONFIDENTIALITY


We may enter into one or more written agreements directly with you which contain express provisions regarding the confidentiality of information ("Contract Provisions"). With respect to Personal Information we receive which is subject to any such Contract Provisions, those Contract Provisions, and the Agreement(s) of which those Contract Provision(s) are a part, and not this Privacy Policy, control for all purposes.

EFFECTIVE DATE AND UPDATES


We may revise this Privacy Policy at any time. The "Last Updated" date at the top of this Privacy Policy reflects the date of the most recent revisions. You are responsible for regularly reviewing the Privacy Policy. The most current version of the Privacy Policy can be reviewed by clicking on the "Privacy Policy" link located at the bottom of each of our pages associated with the Site.

RESPONSIBILITY FOR DATA CONTROL AND PROCESSING


TurnkeyCyberSecurityandPrivacySolutions, LLC is the entity which is responsible for the control and processing of personal data that we collect from you when you use the Services. If you have any questions or concerns about TurnkeyCyberSecurityandPrivacySolutions, LLC’s use of your personal data, please contact our Data Privacy Team at dataprivacy@TurnkeyCyberSecurityandPrivacySolutions.com.

COUNTRY OF PROCESSING


TurnkeyCyberSecurityandPrivacySolutions, LLC operates the Services from the United States of America (USA) and our data collection and processing activities take place primarily in the USA. Accordingly, data collected from users when using our Services is collected in the USA. We store and otherwise process data (including personal data) through third party cloud service providers and other IT service providers which may be located or which may operate in other countries.

CONTACT INFORMATION


If you have questions, concerns or requests regarding TurnkeyCyberSecurityandPrivacySolutions's Privacy Policy, or TurnkeyCyberSecurityandPrivacySolutions's collection or use of your Personal Information, please contact us:

TurnkeyCyberSecurityandPrivacySolutions
Attn: Managing Partner
P.O. Box 270072
Littleton, CO 80127

SCOPE OF THIS PRIVACY POLICY


This Privacy Policy applies to our collection and use of Personal Information:

  • We collect or use from your visit to the Site; and
  • That you provide to us by other means (for example, as part of an email you send us).

When we use the term "Personal Information" in this Privacy Policy, we mean information that identifies, or can be used by us or on our behalf to identify, an individual. This can be, for example, a name, street address, e-mail address, or telephone number(s). Personal Information does not include encoded information, anonymized information, or information that is publicly available and not combined with non-public Personal Information.

This Policy does not apply to any data in a form which cannot be linked to a living individual (such as anonymized or aggregated data which cannot directly or indirectly be used to identify you or to obtain information about you) ("Anonymized and Aggregated Data"). We may generate or extract Anonymized and Aggregated Data out of any databases containing your personal data and we may make use of any such Anonymized and Aggregated Data for our purposes as we see fit.

CHANGES TO THIS PRIVACY POLICY


Please review the Privacy Policy each time you use the Service. We may update this Policy from time to time, and the updated version of this Policy will be effective upon posting on the NAME Services. Please check this page to review the most up-to-date version of this Policy.

HOW LONG WE KEEP YOUR INFORMATION


We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

CHILDREN'S PRIVACY


The Service is not directed to children and is intended for use by adults only. We do not knowingly collect information from individuals under 16 years of age. If you are under the age of 16, please do not submit any information through the Service.

CALIFORNIA PRIVACY RIGHTS


Under California Civil Code Section 1798.83, if you are a California resident and your business relationship with us is primarily for personal, family or household purposes, you may request certain data regarding our disclosure, if any, of information to third parties for the third parties' direct marketing purposes. To make such a request, please send an email to dataprivacy@TurnkeyCyberSecurityandPrivacySolutions.com with "Request for California Privacy Information" in the subject line. You may make such a request up to twice per calendar year.

If applicable, we will provide to you via email a list of the categories of information disclosed to third parties for their direct marketing purposes during the immediately-preceding calendar year, along with the third parties' names and addresses. Please note that not all personal data sharing is covered by Section 1798.83's requirements. If you are a California resident, you may also have rights under the California Consumer Privacy Act.

In particular, you may have the right to:

  • Know what personal information is being collected about you;
  • Know whether your personal information is sold or shared and if so, to whom;
  • Say no to the sale of your personal information
  • Gain access to your personal information:
  • Enjoy equal service and price even if you exercise your privacy rights:
  • Ask us to delete any and all of any of your personal information that we might have

Please note that these rights are not absolute or applicable in all instances. To exercise thes possible rights, please make a request of us by email to support@TurnkeyCyberSecurityandPrivacySolutions.com (or via mail), with "California Consumer Privacy" in the subject line, and the details of your request. We reserve the right to reasonably authenticate any request you make, and to respond to your request as allowed by applicable law.

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INFORMATION WE COLLECT


We collect Personal Information from you in certain areas of the Site, as well as through your other interactions with us. The following is a description of what Personal Information we may collect:

Personal Information You Voluntarily Provide. If you voluntarily provide us with Personal Information, for example your name, email address, phone or mobile number, or payment information (such as a credit card), we collect this Personal Information. You may voluntarily provide this information to us in a variety of ways, including by filling out a registration form on the Site, providing us with Personal Information in order to initiate or complete a transaction, providing online feedback to us, or by contacting us (by email or otherwise) with questions about the Site or our products and services.

Personal Information We May Automatically Collect. We use cookies and other technologies to collect information about you when you visit the Site or otherwise communicate with us. For example, we may automatically collect information such as:

  • Your browser type and operating system
  • Navigation and click-stream data
  • Search terms you use
  • Web pages you view on our Site
  • Links you click
  • Your IP address
  • Sites you visited before coming to our Site
  • Metadata from your communications with us

IP Addresses. An IP address is a number assigned to your computer when you connect to the Internet. As part of the protocol of the Internet, web servers can identify your computer by its IP address. In addition, web servers may be able to identify the type of browser and/or type of computer you are using. We collect IP addresses and related information for the purposes of system administration, to assess the traffic to the Site, and to maintain and improve the Site. For security purposes, we may link account information you enter when you purchase products on the Site to the originating IP address, but we do not otherwise link IP addresses to your personally identifiable information. We can and will use IP addresses and other information we possess to identify a user when we feel it is necessary to enforce compliance with this Privacy Policy or our Terms of Use, to protect our service, the Site, customers or others, or to comply with applicable laws.

Cookies. Cookies are small bits of information that some websites (including the Site) transfer to an individual's hard drive. We use cookies to improve users' experience on our Site, for example to personalize features of the Site and for you, and to analyze the traffic, such as total visitors and pages viewed on the Site, and make improvements based on the data we collect. We never save passwords or credit card information in cookies. The use of cookies has become a standard in the industry. Most browsers are initially set up to accept cookies. You can usually set your browser to refuse cookies or indicate when a cookie is being sent. If you refuse cookies, you may not be able to use some of the functionality of the Site. Other partners or third parties associated with the Site may also use cookies in connection with the services and websites to which the Site links. We do not control these cookies.

Clear GIFs/Web Beacons. Web beacons (also known as clear GIFs) are small bits of code that communicate with third parties and are embedded in web pages, our ads or in emails. We may use web beacons to deliver or communicate with cookies, to count users who have visited a web page, to understand usage patterns or for other third party functionality. We also may include web beacons in e-mails to learn if messages have been opened, acted on, or forwarded.

Location Data. When you access or use the Service using a mobile device, we may access, collect, monitor and/or remotely store "location data," which may include GPS coordinates (e.g. latitude and/or longitude) or similar information regarding the location of your device. Location data may convey to us information about how you browse and use the Service. Some features of the Service, particularly location-based services, may not function properly if use or availability of location data is impaired or disabled.

Device Identifiers. When you access or use the Service using a mobile device, we may access, collect and/or remotely store one or more "device identifiers," such as a universally unique identifier. Device identifiers are small data files or similar data structures stored on or associated with your device that uniquely identify your device. A device identifier may consist of data stored in connection with the device hardware, operating system or other software, or data sent to the device by us. A device identifier may convey information to us about how you browse and use the Service. A device identifier may remain persistently on your device to enhance your navigation on the Service. Some features of the Service may not function properly if use or availability of device identifiers is impaired or disabled.

Location Data. When you access or use the Service using a mobile device, we may access, collect, monitor and/or remotely store "location data," which may include GPS coordinates (e.g. latitude and/or longitude) or similar information regarding the location of your device. Location data may convey to us information about how you browse and use the Service. Some features of the Service, particularly location-based services, may not function properly if use or availability of location data is impaired or disabled.

Third Party Tracking via the Site. We do not allow third parties to utilize the Site to collect your Personal Information over time or across sites for such third parties' own business purposes. Third parties who are service providers to us (for example, assisting us in analyzing traffic to the Site) may collect such information for our internal business purposes only.

Other Technologies. Examples of other technologies we may use to provide better service to you include:

  • Web Session Variables. Information that is passed from one web URL to another as you browse.
  • Browser plug-ins/add-ons. Additional web components that may need to be installed to enable certain web features on our Site. You have the option not to install these components.

As technologies continue to evolve, we may likewise adapt our methods of collection and processing. To the extent we understand such new technologies to materially alter our collection or use methods as described in this Policy, we will amend this Policy.

The Site may contain links to websites operated by third parties. This Privacy Policy does not apply to any information collected from you through such links or that you may provide on the websites you reach by those links. We are not responsible for any actions, practices or policies of other parties.

Please be advised that if you disclose personally identifiable information or personally sensitive information through public forums or message boards provided by TurnkeyCyberSecurityandPrivacySolutions, this information may be collected and used by others. We do not monitor these public spaces and take no responsibility for the content, security or confidentiality of any information posted.

YOUR CHOICES ABOUT YOUR DATA


(a) Controlling Your Settings. You can limit your browser or mobile device from providing certain information by adjusting the settings in the browser, operating system or device. Please consult the documentation for the applicable browser, operating system or device for the controls available to you. You can also stop receiving promotional emails from us by following the unsubscribe instructions in those emails. Note that unsubscribe is not available for certain emails concerning your relationship or dealings with us.

(b) Do Not Track. At this time, we do not recognize "do not track" signals sent from web browsers. In some cases, your browser may offer a “Do Not Track” option, which allows you to signal to operators of websites, mobile applications, and services (including behavioral advertising services) that you do not wish such operators to track certain of your online activities over time and/or across different websites and mobile applications and services. Disabling tracking mechanisms may disable certain features of the Service. To disable tracking, please consult the documentation for your browser, operating system or mobile device. For some devices, it may not be possible to disable tracking mechanisms. You may also disable tracking by certain third-party services by opting out. For example, you can opt out of Google by going here:

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HOW WE USE AND TRANSFER INFORMATION


Our use of your Personal Information for business purposes. We may use your Personal Information for our business purposes. Such business purposes could include, for example, using the information to provide services to you or complete a transaction with you. We may also use this information for various other business purposes, for example:

  • Analyze and improve the performance of the Site
  • Analyze our business, products and services
  • Perform customer service
  • Communicate with you regarding your account
  • Communicate with you regarding products or services provided to you by us or our business partners
  • Market our products and services to you
  • Contact you on behalf of our subsidiaries or external business partners about a particular offering that may be of interest to you
  • Ask you about your experience with or opinions about our company, the Site, or our products and services
  • Protect against or identify possible fraudulent transactions
  • Determine the effectiveness of our advertising
  • Enforce our Terms and Conditions and otherwise manage our business
  • Such other purposes as we disclose to you, and to which you consent, at the time we collect Personal Information from you
  • Such other purposes as we disclose to you, and to which you consent, prior to our processing your Personal Information in a manner inconsistent with the terms of this Policy

We may also provide your Personal Information to third parties who are service providers to us, for example third parties who provide computer-related, credit card processing, mapping, or debt collection services. These third parties will only use your Personal Information as directed by us for our business purposes.

TurnkeyCyberSecurityandPrivacySolutions also works with third parties to jointly provide you with certain products or services (we call these third parties "external business partners"). We may provide your Personal Information to our external business partners.

We may also share your information if we merge with, or if we or any of our assets are sold to, another company.

We may also share anonymized data derived from your Personal Information with researchers performing studies in areas relevant to our business. When we do so, we take reasonable steps to anonymize your Personal Information such that it can no longer be used to identify you.

We do not sell or lease your Personal Information or Data

Our use of your Personal Information for legal purposes. Sometimes a law, court order or other judicial or administrative process requires us to provide information to a government authority or party to a private lawsuit. We will provide the information that we in good faith believe is required to comply with the law, order, or other process. We may also disclose certain information if:

  • We are required to bring, or defend against, litigation or any regulatory proceeding between, or relating to, you and us,
  • We have reason to believe that disclosing this information is necessary to identify, contact, or bring legal action against someone who may have breached our Site Terms of Use or who may be causing injury to or interference with (either intentionally or unintentionally) our rights or property, other Site users or anyone else who could be harmed by such activities, or
  • We believe in good faith that the law requires it.

Information Transfer. Your Personal Information may be transferred to, stored, and processed in a country other than the one in which it was provided. When we do so, we transfer the information in compliance with applicable data protection laws.

We take steps to protect Personal Information no matter what country it is stored in or transferred to. We have procedures and controls as appropriate to help ensure this.

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DATA SECURITY


We take appropriate steps that we believe are reasonable to protect the security of your Personal Information on our system, both internally and from outsiders, and to ensure the integrity of the data we collect. We use a combination of technological, physical and policy methods to protect this data such as, for example, requiring a password to access our network and employing firewall security.

You are responsible for maintaining the secrecy of your passwords and any account information. Please be aware that we will never ask you for your password in an unsolicited phone call or e-mail. We do not provide your password to third parties.

We cannot guarantee that transmissions of your personal data will be fully secure and that third parties will never be able to defeat our security measures or the security measures of our partners. WE ASSUME NO LIABILITY FOR DISCLOSURE OF YOUR INFORMATION DUE TO TRANSMISSION ERRORS, THIRD-PARTY ACCESS OR CAUSES BEYOND OUR CONTROL.

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ACCESS, INTEGRITY & CHOICE


Access & Integrity. If you believe that the Personal Information you voluntarily provided us is, or has become, inaccurate, incomplete or untimely, contact us and provide additional or corrected information. You may also contact us to inquire as to what Personal Information about you we possess. We reserve the right to charge a reasonable fee to cover our costs in responding to such requests (if such a fee is otherwise allowed by law). We also reserve the right to disregard unreasonable or abusive requests, and we reserve the right, but do not assume any obligation, to verify your identity prior to responding to any such request.

Choice. When you provide Personal Information to us, you consent to our using that information as described in this Privacy Policy.

If you do not want us to use or continue using your Personal Information to communicate with you, you may request that we not do so (opt-out) by following the procedures described below.

  • Opting-Out after Signup: If you wish to discontinue any further promotional communications from us, please email your opt-out request to support@TurnkeyCyberSecurityandPrivacySolutions.com or send your request to our P.O. box address listed above.  You can also use the link on our home page. Place the word "UNSUBSCRIBE" in your request to us.
  • Digital / Electronic Communications: You can also stop receiving promotional email messages from us by following the instructions provided in any such email message you receive.

Continued Use of Your Personal Information Despite Opt-Out. Because it is essential that we have and use personal information about you in order to provide you with products and services you order from us, we will continue to use personal information to facilitate a transaction that you initiate. In addition, even if you opt-out, we will retain your personal information for our internal use, such as internal business analytics and legal compliance. We will also retain your personal information in order to contact you for non-promotional purposes regarding your use of our service.

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