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Netquall Privacy Shield Policy

This Privacy Shield Policy (Policy) describes how NetQuall Technologies and its subsidiaries and affiliates in the United States (US) (NetQuall Technologies, Company, We, or Us) collect, use, and disclose certain personally identifiable information that we receive in the US from the European Union member countries (EU) and Switzerland (Personal Data). This Policy applies to the following US affiliated entities: Citadel Ground Control, Ground Alliance. This Policy supplements our Website Privacy Policy located at http://www.netquall.com/privacy-policy, and unless specifically defined in this Policy, the terms in this Policy have the same meaning as the website privacy policy. If there is any conflict between the policies in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.

Privacy Shield Certification

NetQuall Technologies is a current, active participant in the EU-U.S. and the Swiss-U.S. Privacy Shield Frameworks. Information about NetQuall Technologies certification under the frameworks may be found here: https://www.privacyshield.gov/participant?id=a2zt00000008SMDAA2.

NetQuall Technologies complies with the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information transferred from European Union and Switzerland to the United States, respectively. NetQuall Technologies has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov.

For purposes of enforcing compliance with the Privacy Shield, NetQuall Technologies is subject to the investigatory and enforcement authority of the US Federal Trade Commission. For more information about the Privacy Shield, see the US Department of Commerce’s Privacy Shield website located at: https://www.privacyshield.gov

In compliance with the Privacy Shield Principles, NetQuall Technologies commits to resolve complaints about our collection or use of your personal information. EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact NetQuall Technologies at: privacy@netquall.com

NetQuall Technologies has further committed to cooperate with the panel established by the EU data protection authorities (DPA) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved Privacy Shield complaints concerning data transferred from the EU and Switzerland.

The Information We Collect

This privacy policy applies to all information collected or submitted on the NetQuall Technologies website and its platform. On some pages, make requests, and register to receive materials. The types of personal information collected at these pages are:

• Name
• Address
• Email address
• Phone number
• Company Name
• Title
• Payment Information (billing name, address, and credit card information platform only)

Purpose of Collection and Use of Personal Data

NetQuall Technologies collects certain Personal Data such as name, email address, postal address and telephone number. We do not collect sensitive Personal Data of consumers, customers or suppliers, such as information about medical or health conditions, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership or other sensitive information as defined by the Privacy Shield framework.

We use Personal Data of consumers, customers, suppliers and others (i) to respond to their requests, (ii) to evaluate the quality of our products and services, (iii) to communicate with them about our products, services and related issues, (iv) to notify them of and administer offers, contests, sweepstakes and other promotions, and (v) for internal administrative and analytics purposes, and (vi) to comply with our legal obligations, policies and procedures.

How you can access or correct your information

Upon request, NetQuall Technologies will provide you with information about whether we hold, or process on behalf of a third party, any of your personal information. To request this information please contact us at privacy@netquall.com

You can update, delete or correct factual errors in your personal information by sending us a request that credibly shows error. If you no longer desire our service, contact us directly through the contact information listed below. We will respond to your request to access a reasonable timeframe.

To protect your privacy and security, we will also take reasonable steps to verify your identity before granting access or making corrections.

We will retain your information for as long as your account is active or as needed to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Right of individuals to access their personal data

Individuals can opt-out of their personal information by sending request to support team for:

• Disclosed to a third party (other than to a service provider or pursuant to lawful request as set forth below), or
• Used for a purpose materially different from the purpose for which it was originally collected. You also have the ability to opt out at any time from the use of your personal information for direct marketing purposes.

Under certain conditions, if an individual were to invoke binding arbitration:

Section C of Annex I to the Privacy Shield Principles (included below for reference) explains in detail when an individual can invoke binding arbitration. Rather than include this level of detail in a privacy policy, organizations may provide notice that an individual has the possibility, under certain conditions, to invoke binding arbitration for complaints regarding Privacy Shield compliance not resolved by any of the other Privacy Shield mechanisms and then link to Annex I for additional information: https://www.privacyshield.gov/article?id=ANNEX-I-introduction

Annex I: Section C

An individual who decides to invoke this arbitration option must take the following steps prior to initiating an arbitration claim: (1) raise the claimed violation directly with the organization and afford the organization an opportunity to resolve the issue within the timeframe set forth in Section III.11(d)(i) of the Principles; (2) make use of the independent recourse mechanism under the Principles, which is at no cost to the individual; and (3) raise the issue through their Data Protection Authority to the Department of Commerce and afford the Department of Commerce an opportunity to use best efforts to resolve the issue within the timeframes set forth in the Letter from the International Trade Administration of the Department of Commerce, at no cost to the individual. This arbitration option may not be invoked if the individual’s same claimed violation of the Principles (1) has previously been subject to binding arbitration; (2) was the subject of a final judgment entered in a court action to which the individual was a party; or (3) was previously settled by the parties.

In addition, this option may not be invoked if [an EU Data Protection Authority or the Commissioner] (1) has authority under Sections III.5 or III.9 of the Principles; or (2) has the authority to resolve the claimed violation directly with the organization. [A DPA’s/the Commissioner’s] authority to resolve the same claim against [an EU or a Swiss] data controller does not alone preclude invocation of this arbitration option against a different legal entity not bound by the [DPA’s/Commissioner’s] authority.

If you have further questions related to the above, you can also contact us at info@netquall.com

Enforcement and required disclosure

Our commitments under the Privacy Shields are subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission. We may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. Under such circumstances, we may be prohibited by law, court order or other legal process from providing notice of disclosure.

Third parties who may receive personal data

We may use a limited number of third party service providers to assist us in providing services to our customers or to meet internal business needs.

Currently we are using two third-party tools:

• SendGrid
• Twilio

Sendgrid used for sending emails and Twilio used for sending SMS through the application. These third parties may access, process, or store personal data in the course of providing their services. We maintain contracts with these third parties to restrict their access, use, and disclosure of personal data in compliance with our Privacy Shield obligations, and we may be liable for such parties if they fail to meet these obligations.

How do we share and disclose information to third parties?

We do not rent or sell your Personal Information to anyone. We may share and disclose information (including Personal Information) about our customers in the following limited circumstances:

Vendors, consultants, and other service providers:

We may share your information with third party vendors, consultants, and other service providers who we employ to perform tasks on our behalf. These companies include (for example) our payment processing providers, website analytics companies (e.g., Google Analytics), product feedback or help desk software providers, CRM service providers (e.g., Salesforce), email service providers, and others.

If NetQuall Technologies has received your Personal Information in the United States and subsequently transfers that information to a third party agent or service provider for processing, NetQuall Technologies shall remain responsible for ensuring that such third party agent or service provider processes your Personal Information to the standard required by our Privacy Shield commitments. Unless we tell you differently and you consent, our agents do not have any right to use the Personal Information we share with them beyond what is necessary to assist us.

Protection of NetQuall Technologies and Others:

We reserve the right to access, read, preserve, and disclose any information as necessary to comply with law or court order; enforce or apply our agreements with you and other agreements; or protect the rights, property, or safety of NetQuall Technologies, our employees, our users, or others.

Disclosures for National Security or Law Enforcement:

Under certain circumstances, we may be required to disclose your Personal Information in response to valid requests by public authorities, including to meet national security or law enforcement requirements

Security for Personal Data:

NetQuall Technologies is committed to safeguarding the Personal Data that it receives individuals. While NetQuall Technologies cannot guarantee the security of Personal Data, the Company takes reasonable precautions to protect Personal Data in the Company’s possession from loss, misappropriation and unauthorized access, disclosure and destruction.

Few security measures that we are taking are:

• Our database is encrypted with KMS AWS. It is secure from external attacks and any kind of hacking.
• Credit cards information stored by using KMS(key management system with cryptography algorithm). So these are the best practices to store credit card data in database in binary format.
• All passwords are encrypted with SHA-2 algorithm.
• Files are placed in private servers AWS
• Penetration testing.

NetQuall Technologies utilizes a combination of online and offline security technologies, procedures and organizational measures to help safeguard Personal Data. For example, facility security is designed to prevent unauthorized access to Company computers. Electronic security measures including, for example, network access controls, passwords and access logging — provide reasonable protection from hacking and other unauthorized access. NetQuall Technologies also protects Personal Data through the use of firewalls, role-based restrictions and, where deemed appropriate by NetQuall Technologies, encryption technology. NetQuall Technologies limits access to Personal Data to employees, subcontractors, and third-party agents that have a specific business reason for accessing such Personal Data. Individuals who have been granted access to Personal Data will be made aware of their responsibilities to protect such information and will be provided training and instruction on how to do so.

Inquiries And Complaints:

If you believe that we maintain copies of your personal data within the scope of the Privacy Shields, you may direct any inquiries to privacy@netquall.com or via mail to: NetQuall Technologies Pvt. Ltd, 1345 avenue of the Americas, FL 33, New York, NY 10105, United States. We will respond to your inquiry within 45 days of receipt and verification of your identity.

Contact NetQuall Technologies and Recourse

If you have any questions about this Statement or the information that we collect from you in reliance on Privacy Shield, please contact us at privacy@netquall.com or write to:

Via electronic mail:

privacy@netquall.com

Via post:

Privacy Officer

NetQuall Technologies Pvt. Ltd

1345 avenue of the Americas, FL 33, New York, NY 10105, United States