Privacy

At FullON, Inc. (“FullON”), we respect your concerns about privacy. FullON is a Strategy and Go-to-Market engagement company providing consulting & tools (collectively referred to as the “Services”). This Privacy Notice (“Notice”) describes how we process the personal information we collect from visitors to our websites, forums and blogs (“Sites”) and mobile applications (“Apps”) that link to this Notice, subject to the additional information on scope provided below.

For the purpose of this Notice, FullON, “we” and “us” refer to FullON, Inc. and its subsidiaries and affiliates, as the context requires, and include but are not limited to RTI and SICOM. Our privacy practices vary depending on the Services we provide and the country-specific requirements for the countries in which we operate. For some products and Services, where required, we will provide additional privacy notices before collecting your personal information. Please read this Notice carefully. If you have any questions, you may contact us at info@fullonstrategy.com or by the methods provided in the “Contact Us” section below.

Please note that the FullON Sites and Apps collect personal information from our current and prospective Customers, as well as from the end users who engage with our Apps through the Services we provide to our Customers (“Customer End Users”). When FullON processes personal information about Customer End Users, we do so for the sole purpose of providing the Services to our Customers, and in accordance with our agreements with our Customers. Our processing of Customer End User personal information is therefore governed by our Customers’ privacy notices, not this Notice. If you are a Customer End User who has a relationship with one of our Customers, and you have a question about how your personal information is collected, used, or shared, or would like to exercise any rights you may have with respect to your personal information, please contact the Customer directly.

Please be aware that not all of the information in this Notice will be directly applicable to our handling of your personal information. This Notice provides an overview of the possible circumstances in which we may interact with your personal information. If you have any questions about our processing of your personal information, please contact us at privacy@FullONstrategy.com.

Personal Information We Collect

Through our Sites and Apps, subject to your consent if required by law, we may collect the following categories of personal information:

Identifiers (including your name and contact information such as telephone number, email address, or postal address)
Sensitive Personal Information (such as financial account information and username and password)
Commercial Information (such as your access and purchase history, the products and Services we provide to you, or your marketing preferences)
Internet/Electronic Activity (see “Cookies and other tracking technologies” for additional information)
Employment Information (such as your status with the organization with which you are affiliated or information that you provide as a job applicant)
Geolocation Information (to the extent your location can be derived from your Identifiers or from Internet/Electronic Activity information such as your IP address)
Communications Contents and Metadata (such as information you provide in any communication with us or when you participate in any blog, community or forum on our Sites)
• Inferences drawn from the foregoing. such as your preferences, characteristics or predispositions

Data anonymization and aggregation. Subject to your consent if required by law, we may anonymize or aggregate your personal information in such a way as to ensure that you are not identified or identifiable from it, in order to use the anonymized or aggregated data. For example, we may use anonymized or aggregated data for statistical analysis including to analyze trends, for product development, and for risk assessments and cost analysis. We may share anonymized or aggregated data with our parent, subsidiaries, affiliates or with other third parties.

Use of Personal Information

We may use the information that we collect about you for the following purposes:

Providing our Services and related support: including to help fulfill your requests for products and Services; to communicate with you about your use of our Services; to respond to your inquiries; to provide troubleshooting and other technical support; and for other customer service and support purposes.

Protecting the integrity of the Services: including to verify your identity; to detect and prevent fraud and unauthorized activities; to facilitate software; to preserve the integrity of the Services and our systems, and prevent unauthorized access and activities; to enforce our applicable terms; and to protect the rights and safety of others.

Analyzing and improving the Services and our business: including to better understand how users access and use our Services; to evaluate and improve the Services and our business operations; to develop new features, offerings and Services; to conduct surveys and other evaluations; and for other research and analytical purposes.

Personalizing the Services: including to tailor content we send or display on our Sites and Services (e.g., for your geographic area); to offer personalized help and instructions; and to otherwise personalize your experiences with the Services.

Advertising, marketing and promotional purposes: including to send or display targeted marketing; to reach you with more relevant ads and to evaluate, measure and improve the effectiveness of our ad campaigns; to contact you about our Services, and those of our affiliates, as well as other information we think may interest you. Where required by applicable law, we will obtain your consent to use your personal information for marketing and related purposes.

Securing and protecting our business: including to protect and secure our business operations, assets, Services, network and information and technology resources; to investigate, prevent, detect and take action regarding fraud, unauthorized access, situations involving potential threats to the rights or safety of any person or third party, or other unauthorized activities or misconduct.

Defending our legal rights: including to manage and respond to actual and potential legal disputes and claims, and to otherwise establish, defend or protect our rights or interests, including in the context of anticipated or actual litigation with users or third parties.

Auditing, reporting, corporate governance, and internal operations: including relating to financial, tax and accounting audits; audits and assessments of our operations, privacy, security and financial controls, risk, and compliance with legal obligations; our general business, accounting, record keeping and legal functions; to maintain appropriate business records; to enforce company policies and procedures; and related to any actual or contemplated merger, acquisition, asset sale or transfer, financing, bankruptcy or restructuring of all or part of our business.

Complying with legal obligations: including to comply with the law, our legal obligations and legal process, such warrants, subpoenas, court orders, and regulatory or law enforcement requests.

We retain the personal information we collect for different periods of time depending on what it is and how we use it. In some contexts, we will provide additional information about retention as you use the Services. When we collect your personal information, we will retain it only for as long as is necessary to complete the legitimate business or legal purposes for which we collected it. In many cases, the retention time period will correspond to the time period for which you have an account or other type of business relationship with us plus a defined period after that relationship ends which will be defined by our regulatory requirements.

Our Processing of Sensitive Personal Information. Sensitive Personal Information includes personal information defined as sensitive under applicable privacy and data protection laws. When we collect Sensitive Personal Information about you, we will limit our use and disclosure of that information to what is necessary to perform the Services, unless we are required to do otherwise under applicable laws. In addition to processing Sensitive Personal Information as required to perform the Services, we may process Sensitive Personal Information to detect and prevent security incidents or fraud, to ensure the physical safety of natural persons, for short-term transient uses (when consistent with the purpose for which the information was collected), and to verify or maintain the quality or safety of any Services we perform. Under some privacy and data protection laws, you may have the right to limit the processing of your Sensitive Personal Information. You can find more information about your rights in other sections of this Notice, including any applicable section directed at residents of the state or country in which you reside.

Sources of Personal Information

We collect personal information from several sources that we use to provide our Services to you, to analyze and improve our Services, and to communicate with you. Those sources include:

Information that you provide to us: We collect personal information that you provide to us when you set up an account with us, use our Services, or communicate with us. For example, if you register for an online account with us, we may request your name, contact information and payment information. Providing us with personal information about yourself is voluntary, and you can always choose not to provide certain information, but then you may not be able to take advantage of or participate in some of the Services' features.

Information collected from third parties: We may collect information about you from third parties in the course of providing our Services to you. For example, we may collect personal information like your name and contact information from our Customer if you are a Customer End User in order to provide the Services to you.

Information collected through technology: When you visit our Sites or Apps (or when you use any of our Services) we may collect certain information about your location, usage, or device through technology such as cookies (see “Cookies and Other Tracking Technologies” for more information). We may collect geolocation in the Apps for the purpose of enabling location-based Services.

Sharing of Personal Information

For each category of personal information we collect, we may share such information in the manner and for the purposes described below:

With FullON affiliates where such disclosure is necessary to provide you with our Services or to manage our business.
With third-party service providers whose systems, applications, products or Services help us to provide the Services. For example, we share personal information with IT service providers who help manage our back office systems or administer our Sites and Apps. These service providers have agreed to confidentiality restrictions and have agreed to use any personal information we share with them, or which they collect on our behalf, solely for the purpose of providing the contracted service to us.
With our Customer with whom you are also engaging when you use the Services. For example, you may be using a FullON Site to log into your account with our Customer. FullON will share the personal information you provide in order to fulfill your request. You may also receive communications from the Customer. Each such Customer operates independently from FullON and their collection and use of your personal information is not subject to this Notice but to their own privacy notices.
With other third parties including third parties that provide advertising, campaign measurement, online and mobile analytics, and related Services. These third parties may receive or access as browsing and other data about your use of the Services, in order to help us better reach individuals with relevant ads and measure our ad campaigns, or to better understand how individuals interact with our Site and online Services overtime and across devices.
With promotional partners if you choose to enter a contest, sweepstakes or promotion. Personal information shared in connection with a promotion may include information needed to enable posting your entry with attribution or otherwise as permitted in the official rules for the promotion in question, fulfilling your prize or including your name on a winners list. Also, by entering a promotion, we may require you to consent to the use of your personal information or other information, such as name, voice or likeness, in advertising, promotional and marketing materials. In addition, we may offer certain promotional content, such as a sweepstakes, sponsored by or co-branded with a third party, who may obtain the personal information that you submit.
With social media sites such as Facebook, Instagram and Twitter, through an application programming interface (API) or other software. By allowing the Site to connect with your accounts on such third party sites, you consent to our accessing the information in those accounts, which information may include personal information. When you access the Sites via your social media account, activity you engage in through the Site may be published on the third party site. It is your choice whether to use any such third party sites.

FullON may also disclose personal information about you if it believes such disclosure is necessary to comply with laws or respond to lawful requests and legal process, to enforce our agreements, policies and terms of use and to protect or defend the rights, safety or property of FullON, users of the Services or any person.

In addition, subject to applicable legal requirements, we may share personal information in connection with or during negotiation of any merger, financing, acquisition, bankruptcy, dissolution, transaction or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business assets to another company.

Unless otherwise disclosed in a specific notice, and subject to your consent where required by applicable law, we do not sell your personal information to third parties for monetary compensation, and we do not share your personal information with third parties for cross-context behavioral advertising.

Cookies and Other Tracking Technologies

A “cookie” is a text file that is stored to your browser when you visit a website. Unique device identifiers like IP address or UDID recognize a visitor’s computer or other device used to access the internet. Unique device identifiers are used alone and in conjunction with cookies and other tracking technologies for the purpose of “remembering” computers or other devices used to access the Sites and Apps.

Cookies can be classified by duration and by source:

Duration. The Sites use both “session” and “persistent” cookies. Session cookies are temporary - they terminate when you close your browser or otherwise end your “active” browsing session. Persistent cookies remember you on subsequent visits. Persistent cookies are not deleted when you close your browser, and they will remain on your computer or other device unless you choose to delete them (see below for “How to Delete or Block Cookies”).

Source. Cookies can be “first-party” or “third-party” cookies, which means that they are either issued by or on behalf of FullON or by a third-party operator of another website. For an example of a third-party cookie, our Sites may contain features like videos hosted by other companies, which would set a cookie that can be read by the host. Our Sites may use both first-party and third-party cookies.

The cookies that we may use on the Sites fall into the following categories:

Strictly Necessary Cookies. These cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions taken by you such as logging in or filling in forms. You can set your browser to block or alert you about these cookies, but blocking them may impede the functionality of the Sites.

Performance Cookies. These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site. They help us to know which pages are the most and least popular and see how visitors move around the site. All information these cookies collect is aggregated. If you do not allow these cookies we will not know when you have visited our site, and will not be able to monitor its performance.

Functionality Cookies. These cookies enable the Sites to provide enhanced functionality and personalization. They may be set by us or by third-party providers whose Services we have added to our pages. If you do not allow these cookies then some of these Services may not function properly.

Targeting Cookies. These cookies may be set by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant advertisements on other sites. They are based on uniquely identifying your browser and internet device. If you do not allow these cookies, you will experience less targeted advertising.

How to Delete or Block Cookies

On some Sites, when technically feasible, we will enable tools to help you make choices about cookies. You may also delete or block cookies at any time by changing your browser settings. You can click “Help” in the toolbar of your browser for instruction or review the cookie management guide produced by the Interactive Advertising Bureau available at www.allaboutcookies.org. If you delete or block cookies, some features of the Sites may not function properly.

Our Site does not recognize browser "Do Not Track" signals but several of our service providers who utilize these cookies or beacons on our web sites enable you to opt out of this behavioral advertising. To learn more about how to opt out of the behavioral advertising conducted by these providers you can visit www.networkadvertising.org.

External Links

FullON may provide links on our Sites to other websites that are not under our control. We do not endorse or make any warranty of any type regarding the content contained on such websites or products and Services offered on those websites. We make no representation regarding your use of such websites. Please be aware that we are not responsible for the privacy practices of the operators of other websites. We encourage our users to be aware when they leave our Sites and to read the privacy statements of each and every website that collects personal information. This Notice applies solely to information collected by us. You should read any other applicable privacy and cookies notices carefully before accessing and using such other websites.

Consent to Processing

By using our Site, participating in any of our Services and/or providing us with your personal information, you consent and agree to the collection, transfer, storage and processing of your information to and in the United States.

Your Legal Rights

Depending on how you interact with our Sites, Apps, or Services, you may have the right to:

Know whether we process your personal information;
Know how your personal information is used;
Access, request and receive the personal information we have collected in a portable manner;
Object to having your personal information sold or shared; and
Request that we delete your personal data.
You may contact us using the information in the Contact Us section of this Notice for additional information about how to exercise your rights.The following sections include information for residents of specific jurisdictions.

Information for Residents of the European Economic Area

EU Resident Rights

What does this mean?

Right to be informed

You have the right to be provided with clear and easy-to-understand information about how we use your personal information. This is why we are providing you this Notice and we may provide other forms of notice, as appropriate or required by law, in the Services.

Right to access personal information

You have the right to access and receive a copy of personal information we hold about you.

Right to data portability

In some circumstances, you have the right to receive the personal information you request from us in a format that is user-friendly and enables you to transfer it to another provider.

Right to rectification

You have the right to correct or update your personal information if it is outdated, incorrect or incomplete.

Right of erasure ("right to be forgotten")

In some circumstances, you have the right to have your personal information erased or deleted.

Right to restrict/suspend processing of personal information

You may object to processing of personal information that is based on legitimate interest. You may withdraw consent for processing that is based on consent (this includes the right to opt out of direct marketing).

Right to information about information transfers

You have the right to obtain a copy of documents related to the safeguards under which your personal information is transferred outside the EU.

Right to complain to a supervisory authority

You have the right to contact the data protection authority in your country to complain about our data protection and privacy practices.

Information for California Residents:

If you are a California resident, this section applies to you, in addition to the rest of the Notice.

California Shine the LightIf you are a resident of California, you may request information concerning the categories of personal information (if any) we share with third parties or affiliates for their direct marketing purposes. If you would like more information, please submit a written request to us using the information provided in the “Contact Us” section of this Notice.Categories of Personal Information We Collect and Our Purposes for Collection and UseYou can find a list of the categories of personal information that we collect, as well as a description of how we use it, in the section titled, “Personal Information We Collect and How We Use It,” above.

Categories of Personal Information Disclosed and Categories of Recipients

We disclose the following categories of personal information for business or commercial purposes to the categories of recipients listed below:

We disclose Identifiers to service providers, affiliates, and third-party partners.
We disclose Sensitive Personal Information to service providers, affiliates, and third-party partners.
We disclose Commercial Information to service providers, affiliates, and third-party partners.
We disclose Internet/Electronic Activity to service providers, affiliates, and third-party partners.
We disclose Employment Information to service providers, affiliates, and third-party partners.
We disclose Geolocation Information to service providers, affiliates, and third-party partners.
We disclose Communication Contents and Metadata to service providers, affiliates, and third-party partners.
We disclose Inferences to service providers, affiliates, and third-party partners.
For more information on how your information is shared, please see the “How We Share Personal Information" section, which provides more detail.As a California resident, you have specific rights with regard to your personal information. When we act as a business for the purpose of processing your personal data you can contact us using the information provide in the “Contact Us” section of this Notice with regard to the following rights:

CA Resident Rights

What does this mean?

Right to know about personal information collected, disclosed, and sold

You have the right to request, twice in a 12-month period, the following information about the personal information we have collected about you during the past 12 months:

the categories and specific pieces of personal information we have collected about you;
the categories of sources from which we collected the personal information;
the business or commercial purpose for which we collected or sold the personal information;
the categories of third parties with whom we shared the personal information; and
the categories of personal information about you that we sold or disclosed for a business purpose, and the categories of third parties to whom we sold or disclosed that information for a business purpose.

Right to opt-out of the sale of personal information

You may request that we do not sell your personal information to third parties. You may also request that we do not share your personal information for cross-context behavioral advertising.

Right to request deletion

In some circumstances, you have the right to have your personal information erased or deleted.

Right to equal service and prices ("non-discrimination")

Your choice to exercise your privacy rights will not be used as a basis to discriminate against you in services offered or pricing.

Right to request correction

You have the right to request that we correct any inaccuracies in your personal information.

Right to limit the use and disclosure of sensitive personal information

In some circumstances, you may request that we limit the use and disclosure of your sensitive personal information.

Managing Your Preferences

Subject to your consent if required by applicable law, we may use your personal information to provide you with direct marketing information about our products and Services as well as those of our global affiliates and third parties. Our direct marketing may be by email, telephone, post or SMS or such other method(s) as may become relevant. In addition, we may provide direct marketing information and permit others to do that as allowed by our customers’ respective contracts.We will take steps to seek to ensure that any direct marketing from us and which is sent by electronic means will provide a simple means for you to stop further communications, in accordance with applicable law. For example, in emails, we may provide you with an “unsubscribe” link, or an email address to which you can send an opt-out request. In addition, if we need your consent for direct marketing communications under applicable law, and if you provide your consent, you will be able to change your mind at any time.

Changes and Updates to this Notice

We reserve the right, in our sole discretion, to modify, update, add to, discontinue, remove or otherwise change any portion of this Notice, in whole or in part, at any time. When we amend this Notice, we will revise the “last updated” date located at the top of the document. We will also take reasonable steps to ensure you are made aware of any material updates including providing you direct communication about such changes or providing a notification through the Services, as appropriate. If you provide personal information to us or access or use our Sites and Apps after this Notice has been changed, you will be deemed to have unconditionally consented and agreed to such changes.

The most current version of this Notice will be available on the Sites and Apps and will supersede all previous versions of this Notice.

Children

The Sites, Apps, and Services are not intended for use by children. We do not solicit or knowingly accept any personal information from persons under the age of 16 and we do not sell or share personal information of consumers under age 16. Please do not use the Sites, Apps, or Services if you are under the age of 16.

Choice of Law

This Notice, including all revisions and amendments thereto, is governed by the internal laws of the United States, State of Georgia, without regard to its conflict or choice of law principles which would require application of the laws of another jurisdiction.

Arbitration

By using the Sites or Apps in any way, you unconditionally consent and agree that: (1) any claim, dispute, or controversy (whether in contract, tort, or otherwise) you may have against FullON and/or its parent, subsidiaries, affiliates and each of their respective members, officers, directors and employees (all such individuals and entities collectively referred to herein as the "FullON Entities") arising out of, relating to, or connected in any way with the Sites or Apps or the determination of the scope or applicability of this agreement to arbitrate, will be resolved exclusively by final and binding arbitration administered by JAMS and conducted before a sole arbitrator in accordance with the rules of JAMS; (2) this arbitration agreement is made pursuant to a transaction involving interstate commerce, and shall be governed by the Federal Arbitration Act ("FAA"), 9 U.S.C. §§ 1-16; (3) the arbitration shall be held in Atlanta, Georgia; (4) the arbitrator’s decision shall be controlled by the terms and conditions of this Notice and any of the other agreements referenced herein that the applicable user may have entered into in connection with the Site; (5) the arbitrator shall apply Georgia law consistent with the FAA and applicable statutes of limitations, and shall honor claims of privilege recognized at law; (6) there shall be no authority for any claims to be arbitrated on a class or representative basis, arbitration can decide only your and/or the applicable FullON Entity’s individual claims; the arbitrator may not consolidate or join the claims of other persons or parties who may be similarly situated; (7) the arbitrator shall not have the power to award punitive damages against you or any FullON Entity; (8) in the event that the administrative fees and deposits that must be paid to initiate arbitration against any FullON Entity exceed $125 USD, and you are unable (or not required under the rules of JAMS) to pay any fees and deposits that exceed this amount, FullON agrees to pay them and/or forward them on your behalf, subject to ultimate allocation by the arbitrator. In addition, if you are able to demonstrate that the costs of arbitration will be prohibitive as compared to the costs of litigation, FullON will pay as much of your filing and hearing fees in connection with the arbitration as the arbitrator deems necessary to prevent the arbitration from being cost-prohibitive; and (9) with the exception of subpart (6) above, if any part of this arbitration provision is deemed to be invalid, unenforceable or illegal, or otherwise conflicts with the rules of JAMS, then the balance of this arbitration provision shall remain in effect and shall be construed in accordance with its terms as if the invalid, unenforceable, illegal or conflicting provision were not contained herein. If, however, subpart (6) is found to be invalid, unenforceable or illegal, then the entirety of this Arbitration Provision shall be null and void, and neither you nor FullON shall be entitled to arbitrate their dispute. For more information on JAMS and/or the rules of JAMS, visit their website at https://www.jamsadr.com/.

Contact Us

If you are a Customer End User who has a relationship with one of our Customers, and you have a question about how your personal information is collected, used, or shared, or would like to exercise any rights you may have with respect to your personal information, please contact the Customer directly.

If you have other questions about this Notice, or if you want to exercise your rights as described in this Notice, email info@fullonstrategy.com or may contact us as follows:FullON Inc.Nashville, TN

In order to honor any access or deletion request, we will require you to provide enough information for us to verify your identity. For example, we may ask you for information associated with your account, including your contact information or other identifying information. If you designate an authorized agent to make a rights request on your behalf, we may require proper proof of that authorization as well as direct verification of your identity from you.

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FullON Privacy Notice