Privacy Policy

Last Updated May 8, 2022

Thank you for choosing to be part of our community at The Cyber Dawn, LLC (“Company,” “we,” “us,” or “our“). We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about this privacy policy or our practices with regard to your personal information, please contact us at info@thecyberdawn.com.

This privacy policy describes how we might use your information if you:

■ Visit our website at https://thecyberdawn.com/

■ Engage with us in other related ways ― including any sales, marketing, or events

In this privacy policy, if we refer to:

■ “Website,” we are referring to any website of ours that references or links to this

policy

■ “Services,” we are referring to our Website, and other related services, including any sales, marketing, or events

The purpose of this privacy policy is to explain to you in the clearest way possible what information we collect, how we use it, and what rights you have in relation to it. If there are any terms in this privacy policy that you do not agree with, please discontinue use of our Services immediately.

Please read this privacy policy carefully, as it will help you understand what we do with the information that we collect.

TABLE OF CONTENTS

1. WHAT INFORMATION DO WE COLLECT?

2. HOW DO WE USE YOUR INFORMATION?

3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?

4. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

5. HOW LONG DO WE KEEP YOUR INFORMATION?

6. HOW DO WE KEEP YOUR INFORMATION SAFE?

7. DO WE COLLECT INFORMATION FROM MINORS?

8. WHAT ARE YOUR PRIVACY RIGHTS?

9. CONTROLS FOR DO-NOT-TRACK FEATURES

10. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

11. DO WE MAKE UPDATES TO THIS NOTICE?

12. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

13. HOW CAN YOU REVIEW, UPDATE OR DELETE THE DATA WE COLLECT FROM YOU?

1. WHAT INFORMATION DO WE COLLECT?

The personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you express an interest in obtaining information about us or our products and services when you

participate in activities on the Website, or otherwise when you contact us.

The personal information that we collect depends on the context of your interactions with us and the Website, the choices you make, and the products and features you use. The personal information we collect may include the following:

Personal Information Provided by You. We collect email addresses; names; and other

similar information.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

2. HOW DO WE USE YOUR INFORMATION?

In Short: We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, and/or your consent.

We use personal information collected via our Website for a variety of business purposes

described below. We process your personal information for these purposes in reliance on

our legitimate business interests, in order to enter into or perform a contract with you, with

your consent, and/or for compliance with our legal obligations. We indicate the specific

processing grounds we rely on next to each purpose listed below.

We use the information we collect or receive:

To send you marketing and promotional communications. We may use the personal

information you send to us for our marketing purposes if this is in accordance with

your marketing preferences. For example, when expressing an interest in obtaining

information about us or our Website, subscribing to marketing, or otherwise

contacting us, we will collect personal information from you. You can opt-out of our

marketing emails at any time (see the “WHAT ARE YOUR PRIVACY RIGHTS?” below).

3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?

In Short: We only share information with your consent, to comply with laws, to provide you

with services, to protect your rights, or fulfill business obligations.

We may process or share your data that we hold based on the following legal basis:

Consent: We may process your data if you have given us specific consent to use

your personal information for a specific purpose.

Legitimate Interests: We may process your data when it is reasonably necessary to

achieve our legitimate business interests.

Performance of a Contract: Where we have entered into a contract with you, we may

process your personal information to fulfill the terms of our contract.

Legal Obligations: We may disclose your information where we are legally required

to do so in order to comply with applicable law, governmental requests, a judicial

proceeding, court order, or legal processes, such as in response to a court order or a

subpoena (including in response to public authorities to meet national security or

law enforcement requirements).

Vital Interests: We may disclose your information where we believe it is necessary to

investigate, prevent, or take action regarding potential violations of our policies,

suspected fraud, situations involving potential threats to the safety of any person

and illegal activities, or as evidence in litigation in which we are involved.

More specifically, we may need to process your data or share your personal information in

the following situations:

Business Transfers. We may share or transfer your information in connection with,

or during negotiations of, any merger, sale of company assets, financing, or

acquisition of all or a portion of our business to another company.

4. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: We may use cookies and other tracking technologies to collect and store your

information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to

access or store information for the operation of the website and for setting related to your

viewing preferences. We do not sell or share your data with third parties for marketing or

sales purposes.

5. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy policy unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes

set out in this privacy policy unless a longer retention period is required or permitted by law

(such as tax, accounting, or other legal requirements). No purpose in this notice will require

us to keep your personal information for longer than 1 year.

When we have no ongoing legitimate business need to process your personal information,

we will either delete or anonymize such information or, if this is not possible (for example,

because your personal information has been stored in backup archives), then we will

securely store your personal information and isolate it from any further processing until

deletion is possible.

6. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security, and improperly collect, access, steal, or modify your information. Although we will do what is appropriate to protect your personal information, the transmission of personal information to and from our Website is at your own risk. You should only access the Website within a secure environment.

7. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly solicit data from or market to children under 18 years of age. By using

the Website, you represent that you are at least 18 or that you are the parent or guardian of

such a minor and consent to such minor dependent’s use of the Website.

8. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: In some regions, such as the European Economic Area (EEA) and the United

Kingdom (UK), you have rights that allow you greater access to and control over your personal information.

In some regions (like the EEA and UK), you have certain rights under applicable data

protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. To make such a request, please use the email address provided below. We will consider and act upon any request in accordance with applicable data protection laws.

If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent. If you are a resident in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority.

You can find their contact details here:

If you are a resident in Switzerland, the contact details for the data protection authorities are

available here: https://www.edoeb.admin.ch/edoeb/en/home.html.

9. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy policy.

10. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: Yes, if you are a resident of California, you are granted specific rights regarding

access to your personal information.

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

CCPA privacy policy

The California Code of Regulations defines a “resident” as:

(1) every individual who is in the State of California for other than a temporary or

transitory purpose and

(2) every individual who is domiciled in the State of California who is outside the State of

California for a temporary or transitory purpose

All other individuals are defined as “non-residents.”

If this definition of “resident” applies to you, we must adhere to certain rights and

obligations regarding your personal information.

What categories of personal information do we collect?

We have collected the following categories of personal information in the past twelve (12) months:

Category Examples Collected

A. Identifiers Contact details, such as real name, alias,

postal address, telephone or mobile contact

number, unique personal identifier, online

identifier, Internet Protocol address, email

address and account name

YES

B. Personal information

categories listed in the

California Customer Records

statute

Name, contact information, education,

employment, employment history and

financial information

YES

C. Protected classification

characteristics under

California or federal law

Gender and date of birth

NO

D. Commercial information Transaction information, purchase history,

financial details, and payment information NO

E. Biometric information Fingerprints and voiceprints

NO

F. Internet or other similar

network activity

Browsing history, search history, online

behavior, interest data, and interactions with

our and other websites, applications,

systems and advertisements

NO

G. Geolocation data Device location

NO

H. Audio, electronic, visual,

thermal, olfactory, or similar

information

Images and audio, video or call recordings

created in connection with our business

activities

NO

I. Professional or

employment-related

information

Business contact details in order to provide

you our services at a business level, job title

as well as work history and professional

qualifications if you apply for a job with us

NO

J. Education Information Student records and directory information

NO

K. Inferences drawn from

other personal information

Inferences drawn from any of the collected

personal information listed above to create

a profile or summary about, for example, an

individual’s preferences and characteristics

NO

We may also collect other personal information outside of these categories instances

where you interact with us in-person, online, or by phone or mail in the context of:

■ Receiving help through our customer support channels

■ Participation in customer surveys or contests and

■ Facilitation in the delivery of our Services and to respond to your inquiries

How do we use and share your personal information?

More information about our data collection and sharing practices can be found in this privacy policy.

You may contact us by email at info@thecyberdawn.com.

If you are using an authorized agent to exercise your right to opt-out, we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.

Will your information be shared with anyone else?

We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Each service provider is an entity that processes the information on our behalf.

We may use your personal information for our own business purposes, such as for

undertaking internal research for technological development and demonstration. This is not considered to be “selling” of your personal data.

The Cyber Dawn, LLC has not disclosed or sold any personal information to third parties for a business or commercial purpose in the preceding 12 months.

The Cyber Dawn, LLC will not sell personal information in the future belonging to website visitors, users, and other consumers.

Your rights with respect to your personal data

Right to request deletion of the data – Request to delete

You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation or any processing that may be required to protect against illegal activities.

Right to be informed – Request to know

Depending on the circumstances, you have a right to know:

■ whether we collect and use your personal information

■ the categories of personal information that we collect

■ the purposes for which the collected personal information is used

■ whether we sell your personal information to third parties

■ the categories of personal information that we sold or disclosed for a business

purpose

■ the categories of third parties to whom the personal information was sold or

disclosed for a business purpose and

■ the business or commercial purpose for collecting or selling personal information

In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.

Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights

We will not discriminate against you if you exercise your privacy rights.

Verification process

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with the information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g., phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.

We will only use the personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. If, however, we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity, and for security or fraud prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.

Other privacy rights

■ you may object to the processing of your personal data.

■ you may request correction of your personal data if it is incorrect or no longer

relevant, or ask to restrict the processing of the data.

■ you can designate an authorized agent to make a request under the CCPA on your

behalf. We may deny a request from an authorized agent that does not submit proof

that they have been validly authorized to act on your behalf in accordance with the

CCPA.

■ you may request to opt-out from future selling of your personal information to third

parties. Upon receiving a request to opt-out, we will act upon the request as soon as

feasibly possible, but no later than 15 days from the request submission date.

To exercise these rights, you can contact us by email at info@thecyberdawn.com. If you have a complaint about how we handle your data, we would like to hear from you.

11. DO WE MAKE UPDATES TO THIS POLICY?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this privacy policy from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy policy frequently to be informed of how we are protecting your information.

12. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may contact us by email at info@thecyberdawn.com.

13. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the applicable laws of your state or country, you may have the right to request access to the personal information we collect from you, change that information, or delete it in some circumstances.

To request to review, update, or delete your personal information, please submit a request form via email at info@thecyberdawn.com.