About IPS Privacy To protect your privacy while you use the IPS website and to let you know what types of information we are collecting and how we are using it, we have developed this Privacy Policy. As we update, expand or change our offerings, this Privacy Policy may change from time to time. Effective Date of Current Policy: September 01, 2021 Overview Purpose IPS–Integrated Project Services, LLC. and its operating divisions, subsidiaries, affiliates and branches (collectively, “IPS,” the “Company,” “we” or “us”) are sensitive to privacy issues, and it is important to us to protect the information provided to us by our Clients, Suppliers, and potential, current and former Employees. Accordingly, IPS provides this privacy and information practices policy to inform you about our information practices, the kinds of information we may collect, how we intend to use and share that information, and how you can correct or change such information (“Privacy Policy”). Scope This Privacy Policy applies to Personal Information that is processed by IPS in the course of our business, including on IPS’ website located at www.ipsdb.com (together with any and all future websites operated by or on behalf of IPS, the “Sites”), and any and all future online and offline offerings operated by or on behalf of IPS (the “Services”). All individuals whose responsibilities include the Processing of Personal Information on behalf of IPS are expected to protect that data by adherence to this Privacy Policy. IPS is the controller for the Personal Information we process, unless otherwise stated. For information on how to contact us, please refer to “Redress/Compliance and Accountability” below. This Global Privacy Policy is designed to satisfy global and local compliance requirements; however, IPS may also maintain additional privacy policies and notices to address or provide additional details regarding certain additional local requirements. California Residents The California Consumer Protection Act (“CCPA”) requires specific disclosures to California residents (see Notice for California Residents), and the Nevada Revised Statutes Chapter 603A requires specific disclosures to Nevada residents (see Notice for Nevada Residents). These required disclosures are organized separately for convenience and to reflect terminology used in the CCPA and Nevada Revised Statutes Chapter 603A, however please review this entire Privacy Policy to understand IPS’s Privacy Practices. If you wish to request more information from IPS or inquire on exercising your rights under CCPA or Nevada Revised Statutes Chapter 603A, you can reach out to ISACA by emailing ISP at DPO@ipsdb.com by calling IPS at 1-610-828-4090 Transparence/Notice What Personal Information We Collect and How We Use It The types of Personal Information we may collect (directly from you or from Third-Party sources) and our privacy practices depend on the nature of the relationship you have with IPS and the requirements of applicable law. Some of the ways that IPS may collect Personal Information include: You may provide Personal Information, including your name, email address, or phone number directly to IPS through interacting with the Services, participating in surveys, during events such as sweepstakes and trade shows, and requesting Services or information. As you navigate the Services, certain passive information may also be collected about your visit, including through cookies and similar technologies as described below. The following sections describe who we collect information from and how we use it. Clients IPS collects Personal Information regarding its current, prospective and former clients, customers, visitors and guests (collectively “Clients”). Client data we collect includes information relating to the sale or support of IPS Services, including an individual’s title, name, address, phone number, email address, government identification (driver’s license, passport), as well as financial information related to payments for services or goods. We acquire, hold, use and Process Personal Information about Clients for a variety of business purposes including to: generally manage Client information and accounts; provide IPS International, Inc. Project Management and Construction Claim Services; respond to questions and requests; provide access to certain areas and features of the IPS’ Sites; verify Client identity; communicate about Client account and activities on IPS’ Sites and systems, and, in IPS’ discretion, changes to any IPS policy; tailor content, advertisements, and offers we serve to Clients; process payment for products or services purchased; improve IPS Sites and systems; develop new products, processes and services; Client worker safety and/or performance using location-based technologies, tools and/or devices; process applications and transactions; and for purposes disclosed at the time that Clients provide Personal Information or otherwise with consent. Suppliers IPS collects Personal Information regarding its current, prospective and former suppliers, distributors, subcontractors and strategic partners (collectively “Suppliers”). Supplier information we collect relates to the management of Suppliers and the receipt of their products and services. It may include an individual’s title, name, address, phone number, email address, government identification (driver’s license, passport), as well as financial information related to payment for goods and services. We acquire, hold, use and Process Personal Information about Suppliers for a variety of business purposes including to: generally, manage Supplier information and accounts; provide IPS Project Management and Construction Claim Services; respond to questions and requests; provide access to certain areas and features of our Sites; verify Supplier identity; communicate about Supplier account and activities on our Sites and systems, and, in IPS’ discretion, changes to any IPS policy; tailor content; process payment for products or services purchased by IPS; improve our Sites and systems; develop new products, processes and services; process applications and transactions; and for purposes disclosed at the time Suppliers provide personal data or otherwise with consent. Human Resources Data IPS collects Personal Information from current, prospective and former Employees, their contact points in case of a medical emergency, and beneficiaries under any insurance policy (“Human Resources Data”). The Human Resources Data we collect may include an individual’s title, name, address, phone number, email address, date of birth, passport number, driver’s license number, social security number, financial information related to credit checks, bank details for payroll, information that may be recorded on a CV or application form, contact information of third parties in case of an emergency, and beneficiaries under any insurance policy. Additionally, we may collect location information regarding our Employees, including through GPS tracking technology on Company-owned vehicles, tools or other devices. We may also collect Sensitive Human Resources Data such as details of health and disability, including mental health, medical leave, and maternity leave, as well as information relating to trade union membership. We acquire, hold, use and Process Human Resources-related Personal Information for a variety of business purposes including: workflow management, assigning, managing and administering projects; Human Resources administration and communication; payroll and the provision of benefits; compensation, including bonuses and long-term incentive administration, stock plan administration, compensation analysis, including monitoring overtime and compliance with labor laws, and company recognition programs; job-grading activities; performance and employee development management; organizational development and succession planning; benefits and personnel administration; absence management; helpdesk and IT support services; regulatory compliance; internal and/or external or governmental compliance investigations; internal or external audits; litigation evaluation, prosecution and defense; diversity and inclusion initiatives; shareholder management; restructuring and relocation; emergency contacts and services; Employee safety, including monitoring compliance with safety regulations by confirming Employees are not speeding or otherwise violating traffic laws; compliance with statutory requirements; processing of employee expenses and travel charges; and acquisitions, divestitures and integrations. Additional Types of Information We Collect We endeavor to collect information only relevant for the purposes of Processing. Below are and some of the ways we collect information and how we use it. Social Media and Interest-Based Advertising Generally, online social media resources are interactive tools that enable Data Subjects to collaborate and share information with others. Social media resources include, but are not limited to, social networks, discussion boards, bulletin boards and blogs, wikis, and referral functions to share web site content and tools with a friend or colleague. IPS may collect Personal Information to enable Data Subjects to use online social media resources. We may also enable you to use these social media resources to post or share Personal Information with others. When using social media resources, you should take into careful consideration what Personal Information those Third Parties share with others. IPS will only comply with the terms of this Privacy Policy and the privacy policies applicable to the social media resources it uses. Information from Third-Party Sources IPS may collect information about you from Third-Party sources to supplement information provided by you. This supplemental information allows us to verify information that you have provided to IPS and to enhance our ability to provide you with information about our business, products and services. IPS’ agreements with these Third-Party sources typically limit how IPS may use this supplemental information. Direct Mail, Email and Outbound Telemarketing Clients and Suppliers who provide us with Personal Information, or whose Personal Information we obtain from Third Parties, may receive periodic emails, mailings or phone calls from us with information on our products and services or upcoming special offers/events we believe may be of interest. We offer our Clients and Suppliers the option to decline these communications at no cost to the individual Client or Supplier by following the procedures outlined below. Research/Survey Solicitations From time to time, IPS may perform research (online and offline) via surveys. We may engage Third-Party service providers to conduct such surveys on our behalf. All survey responses are voluntary, and the information collected will be used for research and reporting purposes to help us to better serve Clients and Suppliers by learning more about their needs and the quality of the products and services we provide. The survey responses may be utilized to determine the effectiveness of our Sites, various types of communications, advertising campaigns and/or promotional activities. If a Client or Supplier participates in a survey, the information given will be used along with that of other study participants. We may share anonymous individual and aggregate data for research and analysis purposes. All Internet Users – Cookies, Pixel Tags, Web Beacons and Aggregate Information Cookies Like many other websites, IPS may employ a cookie, or small piece of computer code that enables Web servers to “identify” visitors, each time an individual initiates a session on the Company’s Sites. A cookie is set in order to identify Data Subjects and tailor our Sites to you. Cookies do not store any of the Personal Information that is provided to the IPS Sites; they are simply identifiers. Data Subjects can delete cookie files from their own hard drive at any time. However, individuals should be advised that cookies may be necessary to provide access to much of the content and many of the features of IPS’ Sites. Pixel Tags/Web Beacons IPS may use “pixel tags,” also known as “web beacons,” which are small graphic files that allow us to monitor the use of our Sites. A pixel tag can collect information such as the Internet Protocol (“IP”) address of the computer that downloaded the page on which the tag appears; the URL of the page on which the pixel tag appears; the time the page containing the pixel tag was viewed; the type of browser that fetched the pixel tag; and the identification number of any cookie on the computer previously placed by that server. When corresponding with you via HTML capable email, we may use "format sensing" technology, which allows pixel tags to let us know whether you received and opened our email. Social Media Widgets Our Site includes social media features such as the Facebook “Like” button and LinkedIn (that might include widgets such as the share this button or other interactive mini programs). These features may collect your IP address, which page you are visiting on our Site, and may set a cookie to enable the feature to function properly. These social media features are either hosted by a Third Party or hosted directly on our Site. Your interactions with these features are governed by the privacy policy of the company providing the features. Anonymous and Aggregated Information Anonymized and aggregated information is used for a variety of functions, including the measurement of visitors’ interest in and use of various portions or features of the Sites. Anonymized or aggregated information is not Personal Information, and IPS may use such information in a number of ways, including internal analysis, analytics and research. We may share this information with Third Parties for our or their purposes in an anonymized or aggregated form that is designed to prevent anyone from identifying you. Mobile Computing IPS may provide websites and online resources that are specifically designed to be compatible and used on mobile computing devices. Mobile versions of IPS’ Sites may require that users log in with an account. In such cases, information about use of each mobile version of the website may be associated with user accounts. In addition, IPS may enable individuals to download an application, widget or other tool that can be used on mobile or other computing devices. Some of these tools may store information on mobile or other electronic devices. These tools may transmit Personal Information to IPS to enable Data Subjects to access user accounts and to enable IPS to track use of these tools. Some of these tools may enable users to email reports and other information from the tool. IPS may use personal or non-identifiable information transmitted to the Company to enhance these tools, to develop new tools, for quality improvement and as otherwise described in this Privacy Policy or in other notices IPS provides. Analytics We may also use Google Analytics and Google Analytics Demographics and Interest Reporting to collect information regarding visitor behavior and visitor demographics on some of our Services, and to develop website content. This analytics data is not tied to any Personal Information. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/. You can opt out of Google’s collection and Processing of data generated by your use of the Services by going to http://tools.google.com/dlpage/gaoptout. Choice/Modalities to Opt Out You have the right to object to and opt out of certain uses and disclosures of your Personal Information, as set out in this Privacy Policy. General Where you have consented to IPS’ processing of your Personal Information or Sensitive Personal Information, you may withdraw that consent at any time and opt out by contacting our Data Protection Officer at DPO@ipsdb.com. Even if you opt out, we may still collect and use non-Personal Information regarding your activities on our Sites. Additionally, before we use Personal Information for any new purpose not originally authorized by you, we will provide information regarding the new purpose and give you the opportunity to opt out. Prior to disclosing Sensitive Data to a Third Party or Processing Sensitive Data for a purpose other than its original purpose or the purpose authorized subsequently by the Data Subject, IPS will endeavor to obtain each Data Subject’s explicit consent (opt-in). Where consent of the Data Subject for the Processing of Personal Information is otherwise required by law or contract, IPS will comply with the law or contract. Email and Telephone Communications If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. We will process your request within a reasonable time after receipt. Note that you will continue to receive transaction-related emails regarding products or services you have requested. We may also send you certain non-promotional communications regarding IPS and our Services and you will not be able to opt out of those communications (e.g., communications regarding updates to our Terms or this Privacy Policy). Human Resources Data With regard to Personal Information that IPS receives in connection with the employment relationship, IPS will use such Personal Information only for employment-related purposes (e.g., tax, payroll, benefits), as more fully described in the Transparence/Notice section above. If IPS intends to use this Personal Information for any other purpose, IPS will provide the Data Subject with an opportunity to opt-out of such uses (e.g., charity, health club membership). “Do Not Track” Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers. Cookies As noted above, you may stop or restrict the placement of cookies on your computer or remove them from your browser by adjusting your web browser preferences. These cookie-based opt-outs must be performed on each device and browser that you wish to have opted-out. For example, if you have opted-out on your computer browser, that opt-out will not be effective on your mobile device. You must separately opt-out on each device. Onward Transfer Information We Share IPS does not sell or otherwise disclose Personal Information about you, except as described in this Privacy Policy or as you explicitly consent. IPS may share Personal Information with our service providers, consultants and affiliates for our and our affiliates’ internal business purposes and administrative purposes, including activities such as IT management, for them to provide services to you or support and supplement the Services we provide or to provide you with a product or service that you have requested. Payment information will be used and shared only to effectuate your order and may be stored by a service provider for purposes of future orders. IPS requires our service providers to agree in writing to maintain the confidentiality and security of Personal Information they maintain on our behalf and not to use it for any purpose other than the purpose for which IPS retained them. We may disclose information about you: (i) if we are required to do so by law, court order or legal process; (ii) in response to lawful requests by public authorities, including to meet national security or law enforcement requirements; (iii) under the discovery process in litigation; (iv) to enforce IPS policies or contracts; (v) to collect amounts owed to IPS; (vi) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (vii) in the good faith belief that disclosure is otherwise necessary or advisable. In addition, server logs may be reviewed for security purposes – e.g., to detect unauthorized activity on the Sites. In such cases, server log data containing IP addresses may be shared with law enforcement bodies in order that they may identify users in connection with their investigation of the unauthorized activities. We reserve the right to disclose or transfer any information we have about you in the event of a proposed or actual purchase, any reorganization, sale, lease, merger, joint venture, assignment, amalgamation or any other type of acquisition, disposal or financing of all or any portion of our business or of any of the business assets or shares (including in connection with any bankruptcy or similar proceeding). Should such an event occur, IPS will endeavor to direct the transferee to use Personal Information in a manner that is consistent with this Privacy Policy. International Data Transfers You agree that all Personal Information collected via or by IPS may be transferred, Processed, and stored anywhere in the world, including but not limited to, the United States, the European Union, in the cloud, on our servers, on the servers of our affiliates or the servers of our service providers. Your Personal Information may be accessible to law enforcement or other authorities pursuant to a lawful request. By providing information to IPS, you explicitly consent to the storage of your Personal Information in these locations. We endeavor to safeguard your information consistent with the requirements of applicable laws. Privacy Rights Where permitted by law, you may seek confirmation regarding whether IPS is Processing Personal Information about you, request access to your Personal Information including obtaining a copy of your Personal Information, object to or request the restriction of the Processing of Personal Information, ask that we correct, amend, port or delete Personal Information, request the anonymization or blocking of your Personal Information, withdraw your consent to our Processing of your Personal Information, be informed about third parties with which your Personal Information has been shared, and request the review of decisions taken exclusively based on automated decision-making if that could affect your rights by sending an email to the Data Protection Officer at DPO@ipsdb.com or by using any of the methods set out in this Privacy Policy. Please include your full name, email address associated with your account and a detailed description of your data request. Such requests will be processed in line with local laws. Although IPS makes good faith efforts to provide individuals with access to their Personal Information, there may be circumstances in which IPS is unable to provide access, including but not limited to: where the information contains legal privilege, would compromise others’ privacy or other legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to the individual’s privacy in the case in question or where it is commercially proprietary. If IPS determines that access should be restricted in any particular instance, we will provide you with an explanation of why that determination has been made and a contact point for any further inquiries. To protect your privacy, IPS will take commercially reasonable steps to verify your identity before granting access to or making any changes to your Personal Information. Data Retention IPS retains the Personal Information we receive as described in this Privacy Policy for as long as you use our Sites or as necessary to fulfill the purpose(s) for which it was collected, provide our products and services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements and comply with all applicable laws. Rights of Access, Rectification and Erasure and Restriction Where permitted by law, you may seek confirmation regarding whether IPS is Processing Personal Information about you, request access to or restrict the Processing of Personal Information, and ask that we correct, amend, port or delete Personal Information by sending an email to the Data Protection Officer at DPO@ipsdb.com or by using any of the methods set out in this Privacy Policy. Please include your full name, email address associated with your account and a detailed description of your data request. Such requests will be processed in line with local laws. Although IPS makes good faith efforts to provide individuals with access to their Personal Information, there may be circumstances in which IPS is unable to provide access, including but not limited to: where the information contains legal privilege, would compromise others’ privacy or other legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to the individual’s privacy in the case in question or where it is commercially proprietary. If IPS determines that access should be restricted in any particular instance, we will provide you with an explanation of why that determination has been made and a contact point for any further inquiries. To protect your privacy, IPS will take commercially reasonable steps to verify your identity before granting access to or making any changes to your Personal Information. Data Retention IPS retains the Personal Information we receive as described in this Privacy Policy for as long as you use our Sites or as necessary to fulfill the purpose(s) for which it was collected, provide our products and services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements and comply with all applicable laws. Security of Your Information The security of all Personal Information provided to IPS is important to us, and IPS takes reasonable steps designed to protect your Personal Information. Unfortunately, no data transmission over the Internet or storage of information can be guaranteed to be 100% secure, and we cannot ensure or warrant the security of any information you provide to us. We do not accept liability for unintentional disclosure. By using our Sites or providing Personal Information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Sites. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Sites or sending an email to you. You may have a legal right to receive this notice in writing. Supervisory Authority If you are located in the European Economic Area, Switzerland, the United Kingdom or Brazil, you have the right to lodge a complaint with a supervisory authority if you believe our processing of your personal information violates applicable law. Redress/Compliance and Accountability If after reviewing this Privacy Policy, you would like to submit a request or you have any questions or privacy concerns about our privacy practices, this Privacy Policy, or how to lodge a complaint with the appropriate authority please contact us at: IPS Attn: Data Protection Officer 721 Arbor Way, Suite 100 Blue Bell, PA 19422 USA DPO@ipsdb.com 888-366-7660 610-828-4090 IPS will address your concerns and attempt to resolve any privacy issues in a timely manner. Other Rights and Important Information Information Regarding Children Due to the nature of IPS’ business, services and benefits are not marketed to minors. IPS does not knowingly solicit or collect Personal Information from children under the age of 13. If you learn that your child has provided us with Personal Information without your consent, you may alert us at DPO@ipsdb.com. If we learn that we have collected Personal Information from a child under the age of 13, we will promptly delete that information. Links to Third-Party Websites Please note that our Sites may contain links to other websites for your convenience and information. IPS does not control Third-Party websites or their privacy practices, which may differ from those set out in this Privacy Policy. IPS does not endorse or make any representations about Third-Party websites. Any Personal Information you choose to give to unrelated Third Parties is not covered by this Privacy Policy. IPS encourages you to review the privacy policy of any company or website before submitting your Personal Information. Some Third Parties may choose to share their users’ Personal Information with IPS; that sharing is governed by that company’s privacy policy, not this Privacy Policy. Changes to the Privacy Policy IPS may update this Privacy Policy from time to time as it deems necessary in its sole discretion. If there are any material changes to this Privacy Policy, IPS will notify you by email or as otherwise required by applicable law. IPS encourages you to review this Privacy Policy periodically to be informed regarding how IPS is using and protecting your information and to be aware of any policy changes. Your continued relationship with IPS after the posting or notice of any amended Privacy Policy shall constitute your agreement to be bound by any such changes. Any changes to this Privacy Policy take effect immediately after being posted or otherwise provided by IPS. Compliance This Privacy Policy shall be implemented by IPS and all its operating divisions, subsidiaries and affiliates. Any Employee that violates these privacy principles will be subject to disciplinary procedures. Definitions The following capitalized terms shall have the meanings herein as set forth below. “Agent” means any Third Party that processes Personal Information pursuant to the instructions of, and solely for, IPS or to which IPS discloses Personal Information for use on its behalf. “Data Subject” is an identified or identifiable natural person. “Employee” refers to any current, temporary, permanent, prospective or former employee, director, contractor, consultant, worker or retiree of IPS or its subsidiaries worldwide. “Personal Information” is any information relating to an identified or identifiable natural person (“Data Subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. “Process” or “Processing” means any operation which is performed upon Personal Information, whether or not by automatic means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction. “Sensitive Data” or “Sensitive Personal Information” is a subset of Personal Information which, due to its nature, has been classified by law or by policy as deserving additional privacy and security protections. Sensitive Personal Information includes Personal Information regarding EU-residents that is classified as a “Special Category of Personal Data” under EU law, which consists of the following data elements: (1) race or ethnic origin; (2) political opinions; (3) religious or philosophical beliefs; (4) trade union membership; (5) genetic data; (6) biometric data where Processed to uniquely identify a person; (6) health information; (7) sexual orientation or information about the individual’s sex life; or (8) information relating to the commission of a criminal offense. “Third Party” is any natural or legal person, public authority, agency or body other than the Data Subject, IPS or IPS’ agents. Notice for California Residents This section of the notice applies solely to individuals who reside in the State of California (referred to herein as a “consumer” or “consumers”). We are providing this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws. Any terms defined in the CCPA have the same meaning when used in this notice. The term “personal data” means “personal information” for purposes of the CCPA. Personal Data We Collect Under the CCPA This section of the notice applies solely to individuals who reside in the State of California (referred to herein as a “consumer” or “consumers”). We are providing this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws. Any terms defined in the CCPA have the same meaning when used in this notice. The term “personal data” means “personal information” for purposes of the CCPA. Identifiers. A real name, alias, postal address, unique personal identifier, online identifier, IP address, email address, account name, or other similar identifiers. Protected Classification Characteristics Under California or Federal Law [e.g., Age, race, color, ancestry, national origin, citizenship, marital status, medical condition, physical or mental disability, sex genetic information (including familial genetic information).] Commercial Information. Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. Internet or Other Electronic Network Activity Information. Browsing history, search history, and information regarding a consumer's interaction with a website, application, or advertisement. Geolocation. Physical location or movements. Professional, Education, and Employment-Related Information. Inferences Drawn from Other Personal Data. Inferences drawn from the information identified above to create a profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. Personal data does not include: Publicly available information from government records; De-identified or aggregated consumer information; or Information excluded from the CCPA. We obtain the categories of personal data listed above from the following categories of sources: You and your devices; Your business partners and employees Our business partners or their agents; Our website, applications, devices and services; Consumer data resellers; Public records; From third parties that interact with us in connection with our products and services. Use of Personal Data We may use or disclose the personal data we collect for one or more of the following business purposes: Auditing related to a current interaction with you and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards; Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity; Debugging to identify and repair errors that impair existing intended functionality; Short-term, transient use, including, but not limited to, the contextual customization of ads shown as part of the same interaction; Performing services, including maintaining or servicing accounts, providing customer products or services, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider; Undertaking internal research for technological development and demonstration; Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us; For business related activities such as contact options, planning, and marketing preferences; As described to you when your personal data is collected, as directed by you or as otherwise permitted under the CCPA or applicable law; When you have provided your consent/authorization, to support benefit resolution and prescription fulfillment; and/or 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 data held by us is among the assets transferred. Sharing Personal Data We may disclose your personal data to a third party for a business purpose. When we disclose personal data for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal data confidential and not use it for any purpose except performing the contract. In the past 12 months, IPS may have disclosed the following categories of information about consumers for a business purpose: Name and Other Identifiers such as real name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers. Protected Classification Characteristics Under California or Federal Law. [Age, race, color, ancestry, national origin, citizenship, marital status, medical condition, physical or mental disability, sex genetic information (including familial genetic information)]. Commercial Information. Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. Network Activity Information including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an internet website, application, or advertisement. Geolocation Data. Business or personal location for delivery of products or services. Professional, Education, and Employment-Related Information. Inferences Drawn from any of the information above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. We disclose the relevant categories of your personal data for a business purpose to the following categories of third parties: Our affiliates (Name and other identifiers; Protected Classification Characteristics under California and Federal Law; Commercial Information; Network Activity Information; Geolocation Data; Professional, Education, and Employment-related Information; Inferences Drawn); Advertising networks (Name and Other Identifiers; Commercial Information; Network Activity Information; Geolocation Data; Inferences Drawn); Internet service providers (Name and Other Identifiers; Commercial Information; Network Activity Information; Geolocation Data); Data analytics providers (Name and Other Identifiers; Commercial Information; Network Activity Information; Geolocation Data); Government entities (Name and other identifiers; Protected Classification Characteristics under California and Federal Law; Commercial Information; Network Activity Information; Geolocation Data; Professional, Education, and Employment-related Information; Inferences Drawn); Social networks (Name and Other Identifiers; Commercial Information; Network Activity Information); Service providers such as entities who provide the following: IT and related services; services performed on their operating systems and platforms; information you have requested; customer service activities; and our products and services (Name and other identifiers; Protected Classification Characteristics under California and Federal Law; Commercial Information; Network Activity Information; Geolocation Data; Professional, Education, and Employment-related Information; Inferences Drawn); and/or Third parties to whom you or your agents authorize us to disclose your personal data in connection with products or services we provide to you (Name and other identifiers; Protected Classification Characteristics under California and Federal Law; Commercial Information; Professional, Education, and Employment-related Information). For purposes of the CCPA, IPS does not “sell” personal information, nor do we have actual knowledge of any “sale” of personal information of minors under 16 years of age. Your Right and Choices In accordance with applicable law, you may have the right to: Access to/portability of personal data about you consistent with legal requirements. In addition, you may have the right in some cases to receive or have your electronic personal data transferred to another party. Request correction of your personal data where it is inaccurate or incomplete. In some cases, we may provide self-service tools that enable you to update your personal data or we may refer you to the controller of your personal data who is able to make the correction. Request deletion of your personal data, subject to certain exceptions prescribed by law. Not receive discriminatory treatment by us for the exercise of your rights conferred by the CCPA. Designate an authorized agent to make a verified consumer request on your behalf. 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 as at DPO@ipsdb.com and provide written authorization signed by you and your designated agent. To protect your privacy, we will take steps to verify your identity before fulfilling your request. When you make a request, we will ask you to 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 asking you to answer questions regarding your use of our Services. If you would like to exercise any of these rights, please log into your account, writing to us or emailing us at DPO@ipsdb.com or calling 888-366-7660. We will process such requests in accordance with applicable laws. To protect your privacy, we will take steps to verify your identity before fulfilling your request. Notice for Nevada Residents If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Information to third parties who intend to license or sell that Personal Information. You can exercise this right by contacting us at DPO@ipsdb.com with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account. Please note that we do not currently sell your Personal Information as sales are defined in Nevada Revised Statutes Chapter 603A. If you have any questions, please contact us as at DPO@ipsdb.com. 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