Privacy Policy

1. INTRODUCTION

Gulo Solutions, LLC (hereafter may be referred to as “Fullsecure”, “we,” “us,” or “our”) is committed to safeguarding the privacy of our website visitors and customers. The purpose of this Privacy Policy is to inform you of our practices with regard to personal data we collect from or about you in connection with our website (the “Site”) or through the provision of our services (the “Services”).

By using our website and agreeing to this policy, you consent to our collection, use, and disclosure of information and use of cookies in accordance with the terms of this policy.

All staff members and FullSecure affiliates who have access to data or personal information collected by FullSecure are expected to uphold the FullSecure privacy policy.

2. INFORMATION WE COLLECT

Data that FullSecure collects is used to further the mission, programs, operations and services of FullSecure , and to provide the best experience for customers and website visitors.

There are two different types of data that can be collected: Personal Identifiable Information (PII) and Non- Personal Identifiable Information (Non-PII). PII is any information that can be used to distinguish or trace an individual’s identity, such as name, address, email, place of employment or other information that is linked or linkable to an individual. Non–PII data is anonymous to FullSecure and cannot be used by FullSecure to distinguish or trace an individual’s identity, such as: device IDs, cookies and IP addresses.

Information we collect:

Web Server Logs – This information may include Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring or exit pages, the files viewed on the Site (e.g., HTML pages, graphics, etc.), operating system, date/time stamp, and clickstream data to analyze trends in the aggregate and administer the site. We use analytical software (Google Analytics, WordPress, WP Engine) to help us understand this information. This software sends information to its licensor. Other sites and companies may also use this software but will not have access to your data.

Correspondence Data – Data may include: the communication content and metadata associated with the communication. Correspondence data may be processed for the purposes of communicating with you and record-keeping.

Contact Data – Contact data may include your name, email address, employer and job title. The source of the account data may be you, your employer or affiliated institution who submits via a form on the website. All contact data is encrypted and stored in ProsperWorks.

Inquiry Data – Information contained in any inquiry users submit to FullSecure regarding goods and/or services.

Service Data – Any data that is provided by you when using or participating in any of FullSecure services or programs.

Notification Data – Information provided for the purpose of subscribing to our email notifications, program updates and/or newsletters.

We may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another person. Please do not supply any other person’s personal data to us, unless we prompt you to do so under the basis of providing goods, services or programs.

FullSecure users can add, correct or update their personal information by contacting info@fullsecure or (762) 233-7032.

3. PROVIDING YOUR PERSONAL DATA TO OTHERS

We may disclose your personal data to any member of our company insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.

We may disclose your personal data to suppliers or subcontractors insofar as reasonably necessary for the basis of providing goods, services or programs.

We may disclose your inquiry data to one or more of those selected third party suppliers of goods and services identified on our website for the purpose of enabling them to contact you so that they can offer, market and sell to you relevant goods and/or services. Each such third party will act as a data controller in relation to the inquiry data that we supply to it; and upon contacting you, each such third party will supply to you a copy of its own privacy policy, which will govern that third party’s use of your personal data.

In addition to the specific disclosures of personal data set out in this Section 3, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interest of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

4. INTERNATIONAL TRANSFERS OF YOUR PERSONAL DATA

Fullsecure sole headquarters office is located in Washington, DC, United States. No data is transferred to any other headquarters or facilities outside of the United States.

The hosting facility for our website is WP Engine and is situated within North America.

Personal data may be hosted by suppliers or subcontractors for the basis of providing goods, services, or programs. Suppliers and vendors are situated within the United States.

You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.

5. RETAINING AND DELETING PERSONAL DATA

This section sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data. Personal data that we process for any purpose shall not be kept for longer than is necessary for that purpose. Notwithstanding the other provisions of this section, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or to protect your vital interests or the vital interests of another person.

6. POLICY CHANGES

We may update this policy from time to time by publishing a new version on our website. Check this page occasionally to ensure you accept any changes to this policy. We may notify you of changes to this policy by email or via website announcement on www.fullsecure.net.

7. YOUR RIGHTS

In this section, we have summarized the rights that citizens of the European Union have under data protection law. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

Your principal data protection rights are:

• The right to access
• The right to rectification
• The right to erasure
• The right to restrict processing
• The right to object to processing
• The right to data portability
• The right to complain to a supervisory authority
• The right to withdraw consent

You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. You can access and request a copy of your personal data by emailing info@fullsecure.net.

You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.

In some circumstances, you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defense of legal claims.

In some circumstances, you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defense of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defense of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.

You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defense of legal claims.

You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.

You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation unless the processing is necessary for the performance of a task carried out for reasons of public interest.

To the extent that the legal basis for our processing of your personal data is:

Consent

That the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.

If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.

To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

You may exercise any of your rights in relation to your personal data by written notice to us by emailing info@fullsecure.net or call (762) 233-7032

8. ABOUT COOKIES

Cookies are files created by a website that are stored in the user’s computer either temporarily for that session only (session cookie) or permanently on the hard disk (persistent cookie). Cookies provide a way for Full Secure to recognize you and keep track of your preferences.

Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies. Ultimately, the user has control of if and how cookies are stored through their web browser.

9. COOKIES THAT WE USE

We use cookies for the following purposes:

Authentication – We use cookies to identify you when you visit our website and as you navigate our website.

Status – We use cookies to help us to determine if you have filled out a form on our website.

Personalization – We use cookies to store information about your preferences and to personalize the website for you.

Security – We use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally.

Analysis – We use cookies to help us to analyze the use and performance of our website and services.

• User identification and authentication
• User preference storage
• A/B performance testing
• Usage pattern assessment and traffic analysis
• Advertisement performance assessment

10. COOKIES USED BY OUR SERVICE PROVIDERS

Our service providers use cookies that may be stored on your computer when you visit our website.

We use Google Analytics to analyze the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use and performance of our website. Please see Google’s privacy policy for more information.

We use Google AdWords to share relevant content with you via digital advertising. Google AdWords gathers information about website use by means of cookies. Please see Google’s privacy policy for more information.

We use Google Optimize to analyze use of our website. Google Optimize monitors site usage, user preference and trends by means of cookies. Please see Google Optimize’s privacy policy for more information.

11. MANAGING COOKIES

Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can obtain up-to-date information about blocking and deleting cookies via these links:

Chrome – Google Chrome Cookie Policy

Edge – Microsoft Edge Cookie Policy

Firefox – Firefox Cookie Policy

Internet Explorer – Internet Explorer Cookie Policy

Opera – Opera Cookie Policy

Safari – Apple Safari Cookie Policy

Blocking all cookies will have a negative impact upon the usability of Full Secure. If you block cookies, you will not be able to use all the features on our website.

12. OUR DETAILS

This website is owned and operated by Full Secure, LLC. Contact us at:

Full Secure
4256 N Ravenswood Ave, Suite 110
Chicago, IL 60613
United States

By telephone: (762) 233-7032

By email: info@fullsecure.net

13. DATA PROTECTION POINT OF CONTACT

For any issues related to data protection or privacy, please email info@fullsecure.net  or call (762) 233-7032.