Privacy Policy

Effective Date: April 2, 2026

Data Collection

We collect or obtain data relating to you in a variety of ways, as described below. Such data may include personal data, i.e., information that alone or in combination with other information identifies you as an individual or can be reasonably linked to your identity.

Data You Provide: When you request information or support from Project Safeguard, we may ask you for your name, postal address, telephone number, and email address so we can respond, provide access or follow up. We may also ask you to provide other data relevant to your experience, question, request, or feedback, such as your geographical location and preferred contact method.

You may also make requests to exercise your individual rights under applicable privacy laws. We will collect and maintain data related to such requests to respond to you and for our audit and legal compliance purposes.

We generally do not seek data that may be considered "special" or "sensitive" personal data (e.g., government-issued identification numbers or information related to an individual's racial or ethnic origin, political opinions, religious or other beliefs, health, criminal background, or trade union membership), and we ask that you do not provide such data. If we specifically require "special" or "sensitive" personal data in connection with one or more of the uses described below, we will request your consent to use the data in accordance with this Privacy Statement and/or in the ways described at the point where you were asked to disclose the data. If you voluntarily share with us or post/upload any "special" or "sensitive" personal data for any other reason, you consent that we may use such data in accordance with applicable law and this Privacy Statement.

Data Use

We use data about you for the purpose(s) for which it was collected or provided to us (as stated at the point of collection) or as otherwise obvious from the context of collection. We may also use data to:

• Process your request for information, or otherwise complete a transaction or service you request or authorize;
• Carry out our internal business purposes, such as corporate transactions, audits, and data analysis; conduct research and analytics about your use of this Site and interaction with us; develop new products; improve this Site and our existing products and services; identify usage trends; assess the performance of our advertisements; optimize our advertising campaigns; and determine the effectiveness of our communications;
• Protect the rights, safety, property, or operations of Project Safeguard, you, or others;
• Comply with applicable law and/or respond to requests and communications from law enforcement authorities or other government officials.

Note that you may unsubscribe from Project Safeguard mailing list or service at any time by clicking on the 'unsubscribe' link in any of our marketing communications to you or by the services themselves. After you unsubscribe, Project Safeguard will not send you further marketing communications, but may continue to contact you to the extent necessary for the purposes of any services you have requested or are still utilizing.

We will never use your personal data to advertise, promote, or market third-party goods or services to you. Additionally, we will not license or publish any of your personal data. We do not and will not sell any personal data to third parties for their own commercial use.

Basis for Processing Personal Data

Applicable law in certain countries requires us to set out in this Privacy Statement the legal basis upon which we rely to process personal data.

Consent: We may rely on the consent that you provide us at the point of data collection or disclosure to us to process such data for the purposes outlined herein.

Legitimate interests: We may rely on our legitimate interests to process your personal data, provided that our interests are not overridden by your interests, fundamental rights, or freedoms. We may process your personal data in reliance on a legitimate interest in the effective and lawful operation of this Site and our businesses, as well as the effective delivery of information and services to you. We may have other legitimate interests and, if so, we will make clear what those interests are at the relevant point in time.

Compliance with legal obligations: We may process your personal data if necessary, for us to comply with a legal obligation arising under an applicable law to which we are subject.

To the extent that we process any "special" or "sensitive" categories of personal data relating to you, we will do so because either: (i) you have given us your explicit consent to carry out such processing; (ii) the processing is necessary for the establishment, exercise, or defense of legal claims; or (iii) you have made the data manifestly public.

If you have questions or concerns about the legal basis upon which Project Safeguard collects and uses your personal data, please contact us.

Disclosures of Personal Data

In connection with one or more of the purposes outlined in the Data Use section above, we may disclose your data to:

• Other entities within Project Safeguard;
• Third parties that provide services to us, such as system hosting, management, and support; data analysis; facilitation of advertisements; data backup; and data security and storage services;
• Relevant third parties as part of a corporate transaction, such as a reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with a bankruptcy or similar proceeding);
• Competent governmental and public authorities, in each case to comply with legal or regulatory obligations or requests; and,
• Other third parties as we believe necessary or appropriate: (a) under applicable law; (b) to comply with legal process; (c) to enforce our terms and conditions; (d) to protect our operations and those of any of our affiliates; (e) to protect our rights, privacy, safety, or property, and/or those of our affiliates, you, or others; and (f) to allow us to pursue available remedies or limit damages that we may sustain.

Data Security

We use reasonable organizational, technical, and administrative measures to protect data under our control. Unfortunately, no data transmission over the internet or data storage system can be guaranteed to be 100% secure. If you feel that the security of any data that we hold concerning you has been compromised, please immediately contact us in accordance with the Contact Us section below.

All parties enrolling, subscribing, or participating in Project Safeguard acknowledge that users have read the Privacy Policy and hereby agree to its terms and consent to the use of user identifiable information as provided therein. Users shall indemnify, defend, and hold harmless Project Safeguard and its affiliates and subsidiaries and their respective officers, directors, employees, members, representatives, and agents from and against any and all claims, losses, liability, damages, costs, and expenses (including reasonable out-of-pocket expenses and attorneys' fees) arising out of or relating to (i) Customer's breach of the foregoing representations and warranties and/or (ii) Customers use of the Software.

Exercising Your Rights

You have choices about how your personal data is handled, and we are committed to providing you with reasonable access to your personal data and the ability to review and limit the use of such data in accordance with applicable law.

If you no longer wish to receive electronic newsletters or correspondence you signed up to receive or other marketing communications from Project Safeguard, click on the 'unsubscribe' link at the bottom of such communications.

Depending on your country (or U.S. state) of residence, you may also have the right to:

• Request confirmation that we are processing your personal data;
• Request a copy of the personal data we hold about you;
• Request that we update the personal data we hold about you or correct such data that is inaccurate or incomplete;
• Restrict the way in which we use your personal data (e.g., if we have no legal right to keep using it) or limit our use of your personal data (e.g., if your personal data is inaccurate or unlawfully held);
• Object to our processing of your personal data;
• Withdraw the consent that you have given us to process your personal data (where we process your personal data on the basis of your consent);
• Request that we delete the personal data we hold about you; and,
• Lodge a complaint with the data protection or privacy authority in your country of residence regarding our processing of your personal data.

If you are interested in exercising one or more of the rights described above, please contact us. Note that we may require proof of your identity before we can give effect to these rights. We will not discriminate against you if you decide to exercise your rights under applicable law.

Only you or an Authorized Agent permitted to act on your behalf may submit a request. An Authorized Agent is a natural person or a business entity you have authorized to act on your behalf by providing your written permission. Please note, we may deny a request from an Authorized Agent if they do not submit proof that they have been authorized by you to act on your behalf.

Your request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal data or an Authorized Agent; and,
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal data if we cannot verify your identity or authority to make the request and confirm the personal data that we maintain relates to you. To verify your identity, we will seek to match any personal data you provide when you (or an Authorized Agent) submit your request to any personal data we already maintain. If we are unable to verify your identity based on the data we maintain, we will let you know.

Additional Information for EU/EEA Residents

If you have any questions or concerns about our collection or use of your personal data, you can contact our Data Protection Officer at contact us.

If you are unsatisfied with the way in which we have handled your personal data or any privacy query or request that you have raised to us, you have a right to complain to the appropriate National Data Protection Authority ("DPA"). For contact details of the DPA in your country of residence, please visit ec.europa.eu.

Special Notice to California Residents

If you are a resident of the state of California, you are entitled to request information regarding the disclosure of your personal data to third parties for direct marketing purposes. Please note that we do not share your personal data with non-affiliated third parties for such purposes.

Data Retention

We will retain your personal data only for those periods necessary to fulfill the various purposes outlined in this Privacy Statement unless a longer retention period is required or allowed by law.

Updates to this Privacy Statement

We may make changes to this Privacy Statement as required. The Effective Date at the top of this page indicates the most previous revision of this Privacy Statement.

Contact Us

If you have any comments or questions regarding this Privacy Statement or our data handling practices, or wish to contact our Data Protection Officer, please contact us.

External Links Policy

All external links are being provided for informational purposes only; they do not constitute an endorsement or an approval by Project Safeguard ("we," or "us") of any of the products, services or opinions of any corporation, organization or individual. Project Safeguard bears no responsibility for the accuracy, legality or content of external sites or for that of subsequent links. Contact the external site for answers to questions regarding its content. References to third parties contained on this website do not constitute endorsement or recommendation by these third parties unless explicitly stated.