This Privacy Statement is effective on January 01, 2018.

Canfield Consulting Group, LLC, a Maryland limited liability company (“CCG,” “we,” “our,” or “us”) is driven by our mission to build high-performance artificial intelligent cybersecurity-centric solutions for the most demanding businesses and governments on Earth. CCG and its subsidiaries around the world understand that when our clients, partners and other individuals provide personal data to CCG, they place their trust in us. We take this trust seriously and are committed to respecting each individual’s privacy and protecting the personal data we handle.

This Privacy Statement describes our privacy practices to help you understand what personal data we collect, use, share and transfer and to inform you about the choices you can make regarding your personal data.

This Privacy Statement applies to CCG websites, domains, or applications that link to this Privacy Statement (this “Statement”), including those of our subsidiaries. We may supplement this Statement with a privacy statement for a specific product, services or website. When we do, the more specific statement is applicable. As an example only, for information describing how we treat personal data you provide for recruiting and hiring purposes will be subject to additional terms for verifying the information for the purpose of recruiting or hiring.

Summary

How We Collect and Use Personal Data

We collect and use personal data that you provide in order to operate our business, provide our products and services, send marketing and other communications, and comply with applicable laws and regulations. In addition to the data you provide to us directly, we may also process personal data about you that we receive from our clients or third parties.

The types of personal data we process will depend on the purpose, including:

  • Provide products and services – contact details (such as name, email, address, company name, phone number, IP address, OS, device details, and other necessary information) to provide services to our clients and our client’s customers, including providing warranty and repair services and product support updates;
  • Improve our products and services – contact details to conduct quality controls and evaluate the performance of our products and services, including conducting customer satisfaction surveys;
  • Conduct due diligence – contact details and publicly available information about the financial or reputational status of a client or third party supplier/partner;
  • Generate sales and marketing leads – contact details, marketing preferences, publically available social media information to maintain a client relationship management database and send relevant newsletters, solution updates, event notifications, and other marketing communications;
  • Customize your website experience – contact details and information obtained through the use of digital collection tools such as cookies (for more information about the way we use cookies);
  • Manage relationships with our clients, suppliers, and partners – contact details and payment information in order to execute contracts, generate invoices and make payments;
  • Respond to inquiries or requests for information – contact details for electronic communication; and
  • Secure our premises and networks – contact details for authentication to use guest networks, collaboration tools and visit our offices; images captured through our encrypted systems set up for security purposes in our offices.

When we receive personal data about you from our clients in order to provide our services, CCG processes the personal data as instructed by our clients and in accordance with our contractual obligations. Our clients are responsible for complying with regulations or laws regarding notice, disclosure, and/or obtaining consent prior to transferring the personal data to CCG for processing.

How We Protect Your Personal Data

We use reasonable security procedures and technical and organizational measures to protect against accidental or unlawful destruction, loss, disclosure or use of personal data we handle. Our network and systems used to provide services are governed by CCG’s limited Small Business liability Information Security policies, which are based upon standards, including the International Organization for Standardization (ISO) 9001:2015 and National Institute of Standards and Technology (NIST).

We limit access to and use of your personal data to authorized persons and trusted third parties who have a reasonable need to know the information in order to perform our services and business operations and who are bound by confidentiality obligations.

How Long We Retain Personal Data

We retain your personal data for as long as is necessary to fulfill the purpose for which the data was collected from you and in consideration of and compliance with applicable legal or regulatory requirements to maintain the data for legitimate purposes. For example, where required by law for audits or accounting requirements, to enforce our agreements or handle disputes.

When personal data is no longer needed for the purpose it was collected or processed or to comply with a legal obligation, we securely destroy it.

How We Share Your Personal Data

We do not sell or otherwise disclose personal data about our website visitors or others that interact with CCG or our products or services, except as described herein.

We may share your personal data with authorized CCG’s personnel in our subsidiaries with a need to know the information in order to process the personal data for the purpose we collected it. We also share personal data with third parties who are acting on our behalf in order to provide the products or services you request or to support our relationship with you. These third parties are not authorized by us to use or disclose the information except as necessary to perform services on our behalf pursuant to a contractual obligation or to comply with legal requirements. CCG requires such third parties to comply with applicable data protection and privacy laws and agree to implement and maintain appropriate technical and organizational security measures to safeguard the personal data.

Our sharing may include:

  • With any of our CCG’s subsidiaries and trusted third party suppliers/partners in order to perform our services or business operations;
  • With our professional advisors and insurers to run our business;
  • With competent legal authorities when required by applicable laws or regulations;
  • With law enforcement authorities or other government officials when we are required to do so by law or pursuant to legal process (including for national security purposes); when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual fraud or illegal activity; or when we believe that disclosure is necessary to protect our rights, protect your safety or the safety of others;
  • With appropriate third parties in connection with the sale, transfer or financing of all or part of a CCG’s business or its assets, including any such activities associated with a bankruptcy proceeding.

How We Transfer Personal Data Across International Borders

CCG is a global enterprise based in the United States with operations in countries around the world. Authorized CCG’s personnel and third parties acting on our behalf may access, use and process personal data collected from you in a country that is different from the country where you entered the personal data, which may have less stringent data protection laws.

As an IT and security services company, CCG has implemented global privacy practices for processing personal data protected under various data protection laws. CCG transfers personal data between the countries in which we operate in accordance with the standards and conditions of applicable data privacy laws, including standards and conditions related to security and processing and acceptable transfer mechanisms.

How We Respect Your Privacy in Marketing

CCG’s uses various means of communication and tools to market its products and services. We provide commercial marketing email to persons who consent or where we have a legitimate interest and it is otherwise permissible under applicable law. You may opt-out of our commercial marketing emails by using the “Unsubscribe” or “Opt-out” link in the commercial email or by contacting us at https://www.phen-ai.com/contact-us/.

We strive to make your CCG experience the best it can be by using various tools that provide us with information about how you and other visitors interact with our website so that we can tailor your CCG experience and improve our web properties. These tools include Cookies and other automatic data collection tools. For information on these tools, please click https://www.phen-ai.com/contact-us/.

How To Request Access To Your Personal Data

We rely on you to provide accurate, complete and current personal data to us.

If you need to correct or update the personal data you provided to us, in many cases, you can edit your data from the location where you provided the personal data to us. If you are not able to access it yourself, we will respond in a timely manner to all reasonable requests to access, correct or delete your personal data. Requests and questions can be submitted to https://www.phen-ai.com/contact-us/.

Your California Privacy Rights

CCG and its subsidiaries are Data Processors/Service Providers for our clients where we process personal data in order to provide our solutions to our clients. When we are a Data Processor/Service Provider, we process the personal data in accordance with the instructions of the Data Controller/Business.

If you are a California consumer seeking to exercise your rights under the California Consumer Privacy Act with respect to the information we hold on behalf of our clients, you should reach out directly to the client responsible for determining the purposes and means of processing your personal information.

For information that CCG holds as a business under CCPA regarding our business contacts, we share information gathered through cookies and other technologies for our own and third-party marketing purposes (a potential “sale” under the CCPA). California consumers have the right to request to opt-out of the sale of personal information. If you would like to opt-out of cookie/tracking technologies, please click https://www.phen-ai.com/contact-us/.

Under California’s “Shine the Light” law, Civil Code Section 1798.83, California residents who provide personal information in obtaining products or services for personal, family or household use are entitled to request and obtain once a calendar year information about the customer information shared, if any, with other businesses for their own direct marketing uses. Please contact us at the addresses below for more information.

How To Contact Us

If you have any questions or comments regarding this statement or our privacy practices, or any concerns regarding a possible violation of this statement, our practices or any applicable privacy law, or a concern or complaint about our practices related to the Privacy Shield, please contact the https://www.phen-ai.com/contact-us/ and we will promptly respond.

Our mailing addresses are:

4104 Alfalfa Terrace

Olney, Maryland, 20832

United States

Links To Other Websites

As a convenience to our website visitors, we sometimes provide links to other websites. These linked sites are not under the control of CCG and we are not responsible for their content. You should review the privacy statements of any linked website to understand their privacy practices before using the site.

Children

It is not our intent to collect personal data from children under the age of consent in their country of residence. Our websites are not designed to attract children and we request that children under the age of consent not submit personal data to us through our websites.

Updates To Our Privacy Statement

We may update this Privacy Statement from time to time. When we update this statement, we will also update the date at the top. Only the current statement is effective, so please review it periodically. If we make any material changes, we may also notify you by contacting you directly or posting a notice on our website. You may request a copy of our prior Privacy Statement by contacting us at https://www.phen-ai.com/contact-us/