Privacy Policy

Kroll Information Assurance, LLC. (referenced further as “Kroll,” “we,” “us” and “our”) respects individual privacy and values the confidence of our subscribers. This Privacy Notice sets out the privacy principles that we follow with respect to processing personal information in the course of providing our products and services via this web portal (“Portal”) referred to herein as the “Platform.”. We will only collect, use and disclose personal information in a manner consistent with applicable law. Your continued use of this Platform constitutes your agreement with this Privacy Notice and any subsequent updates. This Privacy Notice is subject to the Portal Terms of Use (“TOU”) and the Subscriber Terms and Conditions (“Terms and Conditions”) available on the Platform.

By using this Platform, you consent to the data practices described in this Privacy Notice.

Subsidiary, Affiliate, Partner and Third-Party Websites

This Privacy Notice applies to all personal information provided to Kroll from subscribers applying to use and using our services via this Platform. To the extent that this Platform permits you to link to or otherwise access the websites of Kroll’s subsidiaries, affiliates, partners, or other third-parties, separate privacy policies may apply to those linked websites. Those separate privacy policies may contain terms different than those contained in this Privacy Notice, and your access to and use of such linked websites are not governed by this Privacy Notice. Kroll expressly disclaims any and all responsibility for your access to and use of such linked websites, as well as for any use of the information that you may provide, or any information that may be collected about you at such linked websites.

Information Collected from You

a.Personal Information Which May Be Collected by Us or Our Agents

During enrollment, or in order to provide a product or service, we or our agents may collect personal information from which you or your minor child (as applicable) can be identified, such as:

·name, address, phone number, and e-mail address;

·date of birth, driver’s license number, social security number, passport number, and other similar information;

·copies of government-issued photo identification, Social Security card and/or utility bill(s), where applicable;

·credit card number and other financial account data, including your consumer credit file(s), as applicable;

·your responses to security questions; the information you provide in customer service correspondence; and general feedback.

b.Non-Personal Information Which May Be Collected

This Platform, online services, applications, email messages, and advertisements, if any, may use “cookies” and other technologies such as pixel tags and web beacons to collect information about you and your activity (pixel tags and web beacons are also known as clear GIFs, action tags or web tags), such as your IP address, , geographic location, browser type, and service provider, and website session statistics.

Purpose of Collection of Personal and Non-Personal Information

We and our agents will use the personal information provided by you to provide our identity protection service and for the prevention and detection of fraud.

We and our agents will also use the personal and non-personal information you provide us for the purpose of providing you with the products and services you have requested and for administering our relationship with you, internal business purposes, our product or service development and/or statistical analysis. This includes verification of your identity and address as well as charging of agreed-upon fees for our services.

When you close your account, we will continue to store and may share the collected personal and non-personal information in accordance with our legal and regulatory requirements.

Disclosure of Personal Information to Third Parties

a.Disclosure and Sharing of Personal Information

Kroll will not share personal information collected from you with third parties for purposes other than those in support of Kroll’s operations and as necessary to facilitate the purpose for which you provided it.

In order for us to provide you with our identity protection service and for the prevention and detection of fraud, Kroll and/or its agents may share your personal information with its affiliated companies, with third party service providers retained by Kroll to provide services on its behalf, or with others, such as credit bureaus (for instance, in order to provide you with your credit reporting history). These affiliated companies or third party service providers will use your personal information only to accomplish the purposes for which the information was collected.

Your personal information may also be shared under the following circumstances: (i) if Kroll is required to do so pursuant to a subpoena or similar legal process or by law enforcement authorities or government agencies; and (ii) in connection with investigations, or other efforts to prevent illegal activities or pertaining to public safety.

In addition, in the event of a merger, acquisition, or any form of sale of some or all of our assets to a third party, we may also disclose your personal information to the third parties concerned or their professional advisors. In the event of such a transaction, the personal information held by Kroll will be among the assets transferred to the buyer.

For E.U. and Swiss Customers only: Any onward transfer of your personal information is pursuant to the U.S.-EU and/or U.S.-Swiss Safe Harbor Frameworks.

b.Disclosure and Sharing of Non-Personal Information

We may share aggregate, non-personal and/or de-identified information (i.e., information about you and other customers collectively, but not specifically identifiable to you) and other non-personal, de-identified or anonymous information we collect with third parties, to the extent permitted by law. Because non-personal information does not personally identify you, we may use such information and disclose it to other third parties, for any purpose.

Protection of Your Personal Information

We will use reasonable physical, administrative, technical and organizational measures to help protect your personal information when provided to Kroll and/or its agents. When you enter information (such as a credit card or social security number) into the Platform, that information is encrypted using secure socket layer technology (SSL). However, you are solely responsible for maintaining the security of your computer or mobile device from unauthorized access.

Access to Personal Information

a.If your personal information changes, or if you no longer desire our services, you may correct, update, or amend it by making the change on our subscriber profile page or by contacting us through mail or telephone.

b.You may request a copy of the personal information we hold about you so you can correct or amend personal information that may be inaccurate or incomplete by writing to the contact listed below. In addition, we will ask you to provide sufficient evidence of your identity for your own protection so we can ensure that information is being released to the correct person.

Information Collected from Cookies and Other Technologies

When you visit this Platform, your computer may be assigned one or more "cookies.” Cookies are text files containing a small amount of data, usually a unique string of letters and numbers. They are commonly used throughout the Internet and are stored on and accessed from your device when you visit a website (including the Sites).

You can find more information at www.allaboutcookies.org.

Both session ID cookies and persistent cookies are used. Specifically, session-based cookies are used in order to store language and other country specific preferences such as support contact information. Cookies may also be used in order to track internal metrics of site usage. A session ID cookie expires when you close your browser.

A persistent cookie remains on your hard drive for an extended period of time. Persistent cookies also enable tracking and targeting the interests of our users to enhance the experience on this site. You can remove persistent cookies by following directions provided in your Internet browser’s “help” file.

The use of cookies by our partners and tracking utility service providers is not covered by our Privacy Notice. We do not have access or control over these cookies. Our partners and tracking utility service providers may use persistent cookies to help with site optimization.

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you wish to block the cookies from the Platform, please visit the “settings” features of your mobile device, or browser and follow the instructions. However, this may prevent you from taking full advantage of the Platform.

Some of your web and email content may also contain small, invisible images sometimes called web bugs or web beacons. When you access the web and emails that contain web beacons, communication is made to a server(s) in order to request the small image. This allows counting of visitors who have viewed these pages or emails. Web beacons collect limited information which may include a cookie number, time and date of the page that was viewed and a page description.

Changes to this Privacy Notice and Notification to You

Kroll reserves the right, in its sole discretion, to make changes to this Privacy Notice. Changes to the Privacy Notice become effective upon posting. Kroll encourages you to periodically review the Privacy Notice to be informed of any changes.

European Union and Swiss Users:

If there is an unresolved dispute for European and Swiss users as to the collection, use, transmission or retention of your personal information, we have designated the American Arbitration Association (AAA) www.adr.org as our independent resource mechanism to resolve these disputes. You may contact the American Arbitration Association by one of the following means:

Mail: 1633 Broadway, 10th Floor, New York, New York 10019

Phone: 1-800-778-7879 (Toll-Free)/ or 1-212-716-5800

Fax: 1-212-716-5905

Children

Kroll does not knowingly collect personal information directly from children under the age of 13 and does not target the Platform to children under the age of 13.

Contact

If you have questions, comments, and/or complaints regarding this Privacy Notice or how we collect, transmit, and process data please contact us via a general inquiry through the Platform, by email and/or by mail at:

Kroll Associates, LLC.

600 Third Avenue

New York, NY 10016

Attn: Compliance Department

KFSClientServices@kroll.com