Marketing

​

We strive to give you control over how we use your personal data for marketing. We may use your Identity, Contact, Technical, Usage, and Profile Data to form a view on what products or services we think you may want or need, or what may interest you. This is how we decide which offers might be relevant for you – we call this marketing. For example, if you have shown interest in a specific type of security solution, we may send you information on related products.

​

• Promotional offers from us

You will receive marketing communications from us if you have requested information from us or purchased our products/services and you have not opted out of receiving such marketing. We may also send you marketing if you gave us your details when entering a contest or registering for a promotion and you have not opted out.

​

• Third-party marketing

We will get your express opt-in consent before we share your personal data with any company outside the SureView group for their own direct marketing purposes.

​

• Opting out

You can ask us (or third parties, if applicable) to stop sending you marketing messages at any time. To opt out, just contact us (for example, via the DPO email above or by following any “unsubscribe” instructions in the message). Please note that even if you opt out of marketing messages, we may still send you service-related communications when necessary (for instance, notifications about your account, subscription, or important notices about a product you use), as these are not promotional.

Cookies and Automated Technologies

We and our partners use cookies and similar tracking technologies on our Site to provide and improve your browsing experience. Cookies help us remember your preferences and understand how you use our Site. You can set your browser to refuse some or all cookies, or to alert you when cookies are being used. If you disable or refuse certain cookies, some parts of our Site might become inaccessible or not function properly (for instance, features that rely on remembering your preferences). For more information, please see our separate Cookies Policy (if available) or contact us.

​

Legal Compliance for Cookies: We comply with applicable laws regarding cookies and tracking. In jurisdictions where consent is required for non-essential cookies (e.g., analytics or advertising cookies), we will obtain your consent before those cookies are set on your device. In the United States, if you wish to opt out of certain types of online tracking, you may set your browser or use tools like the Global Privacy Control (GPC). We honor such opt-out or “Do Not Sell/Share” signals as required by law (see California Privacy Rights below for more information on how we handle “sale” and “sharing” of data).

​

Change of purpose

We will only use your personal data for the purposes that we have described in this Policy, unless we reasonably consider that we need to use it for another reason that is compatible with the original purpose. If we need to use your personal data for a new purpose and we believe it is compatible with what we originally collected it for, we will explain our reasoning in an update to this Policy or at the time of that further processing. If we need to use your personal data for an unrelated and new purpose, we will notify you and explain the legal basis that allows us to do so (or seek your consent when required by law).

​

Please note that, in accordance with applicable law, we may process your personal data without your knowledge or consent where this is required or permitted by law (for example, if required by a valid legal order or in an emergency).

​

Disclosures of your personal data

We may need to share your personal data with third parties for the purposes described above. We will only share the minimum necessary personal data with third parties and only in accordance with applicable privacy laws. Categories of third-party recipients may include:

• Internal Parties: Other companies within the SureView group (e.g., subsidiaries, affiliates) who may be involved in providing our services, performing support functions, or making business decisions. These entities may act as joint controllers or processors, and all adhere to our internal data protection policies.

• Service Providers (“Processors”): Trusted third-party companies who process data on our behalf and per our instructions to support our operations. Examples include providers of IT and system administration services, cloud hosting, analytics, customer support, payment processing, marketing, or other business support services. These service providers are bound by contracts requiring them to keep personal data confidential and to use it only for the services they perform for us and in line with applicable law.

• Professional Advisers: This includes our lawyers, bankers, auditors, insurers, and similar outside professional advisors, who may need access to certain personal data to provide services to us. They are typically independent controllers of the data but are subject to confidentiality obligations.

• Authorities and Legal Compliance: Government authorities, regulators, law enforcement, or other third parties (including external legal counsel) where disclosure is required by law or necessary to protect rights. For example, we may disclose information in response to valid legal processes (subpoenas, court orders) or to enforce our agreements or protect SureView’s rights or the rights, property, or safety of our customers or others.

• Business Transfers: Third parties as part of a business transaction (or potential transaction) involving SureView, such as a merger, acquisition, or reorganization. In such cases, personal data held by us may be among the assets transferred to the merged entity, under the same conditions of confidentiality and continued protection as outlined in this Policy.

​

International transfers

SureView is a U.S.-based company, and the personal data we collect may be transferred to or accessed by our team or service providers in countries outside of your own. In particular, if you are in the European Economic Area (EEA) or United Kingdom (UK), this means your personal data may be transferred to and processed in countries outside the EEA/UK, including the United States. These countries may have data protection laws that differ from those in your jurisdiction.

​

Whenever we transfer your personal data out of the EEA or UK, we ensure that appropriate safeguards are in place to protect it, as required by GDPR and UK law. This typically includes entering into Standard Contractual Clauses (SCCs) approved by the European Commission (and, where relevant for UK transfers, the UK International Data Transfer Agreement or Addendum), or transferring data to a country that has officially adequate data protection according to the European Commission or UK authorities. Our intra-group data transfers (among SureView affiliated companies) are similarly governed by contractual agreements or internal policies designed to ensure all personal data receives an adequate level of protection, no matter where it is processed.

​

Please contact us if you would like more information about the specific mechanism(s) we rely on for international data transfers or if you have any questions about these safeguards.

​

Data security

We have implemented appropriate technical and organizational security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered, or disclosed. For example, we use access controls to ensure only authorized personnel who have a business need-to-know can access your information, and we employ encryption and other security protocols where appropriate to protect data.

Despite our efforts, no method of transmission over the Internet or method of electronic storage is 100% secure. Therefore, while we strive to protect your personal data, we cannot guarantee its absolute security. If we become aware of a data breach involving your personal data, we will act without undue delay to mitigate the impact and will notify you and any applicable regulatory authorities as required by applicable law.

​

Data Retention

We will retain your personal data only for as long as necessary to fulfill the purposes we collected it for (as described in this Policy), including for satisfying any legal, accounting, or reporting requirements.

​

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the data; the potential risk of harm from unauthorized use or disclosure; the purposes for which we process the data and whether we can achieve those purposes through other means; and applicable legal requirements (such as statutes of limitation and regulatory obligations). In general, this means we will keep your personal data for as long as you have an account or ongoing business relationship with us, plus a reasonable period (for example, to comply with legal obligations or to resolve disputes). Specific retention periods may vary by data category and context. We maintain a detailed internal data retention policy; you may contact us if you want more information about how long we keep particular types of data.

When we no longer have a legitimate need to retain your personal data, we will either securely delete or anonymize it. If deletion or anonymization is not feasible (for example, because your personal data is stored in secure backups), then we will isolate and protect it from further use until deletion is possible.

Your rights under data protection laws

Depending on your jurisdiction and the applicable law, you have a number of rights regarding your personal data. Below, we outline rights available under the EU and UK data protection laws, followed by additional rights for California residents under the CCPA/CPRA.

​

Rights for individuals in the EEA/UK

If you are in the European Economic Area or United Kingdom, your rights under GDPR (and UK data protection law) include:

• Right of Access: You can request access to the personal data we hold about you (commonly known as a “data subject access request”). This allows you to receive a copy of your personal data and certain other information about our processing, to verify we are lawfully processing it.

• Right to Rectification: You can ask us to correct any inaccurate or incomplete personal data we hold about you. We may need to verify the new data you provide to ensure its accuracy.

• Right to Erasure: You can request that we delete or remove your personal data when there is no good reason for us to continue processing it. This right, sometimes called the “right to be forgotten,” applies, for example, if your data is no longer needed for the original purpose or if you withdraw consent (where applicable). Note that we may not always be able to comply – for instance, we might need to retain certain data to comply with a legal obligation or in the exercise or defense of legal claims. If so, we will inform you of the specific reasons at the time of your request.

• Right to Object: You can object to our processing of your personal data where we are relying on a legitimate interest (or those of a third party) and you believe our processing impacts your fundamental rights and freedoms. You also have the absolute right to object at any time to direct marketing uses of your personal data. In some cases, we may demonstrate that we have compelling legitimate grounds to continue processing your data that override your objection (except for objections to direct marketing, which we will always honor).

• Right to Restrict Processing: You can ask us to suspend or restrict the processing of your personal data in certain scenarios: for example, if you want us to verify the data’s accuracy; if our use is unlawful but you do not want us to erase it; if you need us to keep the data in connection with a legal claim; or if you have objected to our use of your data but we need to verify overriding grounds. While processing is restricted, we can still store your data but not use it further except in limited circumstances.

• Right to Data Portability: You can request that we transfer your personal data to you or to a third party in a structured, commonly used, machine-readable format, where technically feasible. This right applies only to information you initially provided to us, which we process by automated means and rely on consent or a contract as the lawful basis.

• Right to Withdraw Consent: Where we rely on your consent to process personal data, you have the right to withdraw that consent at any time. If you withdraw consent, it will not affect the lawfulness of any processing carried out before you withdrew it. However, if we rely on consent and you withdraw it, we may not be able to provide certain services to you (for example, sending you a newsletter). We will advise you if this is the case when you withdraw consent.

To exercise any of these rights, please contact us (see contact details at the top of this Policy). We may need to verify your identity (for example, by asking you to provide information we have on file) as a security measure before fulfilling your request. We will respond to valid requests within one month, or inform you if we require more time (e.g., if your request is complex or you have made multiple requests).

​

You also have the right to make a complaint at any time to your local data protection supervisory authority, as mentioned above. We hope to resolve any issues directly with you first.

​

Additional information for California residents​

If you are a California resident, you have certain privacy rights under the CCPA/CPRA with respect to your personal information. These rights are in addition to those set forth above (there may be overlap). This section describes your California privacy rights and how to exercise them, and provides the disclosures required by California law.

​

Categories of Personal Information Collected: In the preceding 12 months, SureView has collected (from the sources and for the purposes described in this Privacy Policy) the following categories of personal information (as defined by California law):

• Identifiers: Such as real name, contact details (e.g., email, phone number, address), unique personal identifiers, IP address, and other similar identifiers.

• Customer Records Information: Such as account credentials, payment and transaction information, and any other personal information described above that relates to you or your account (for example, Identity, Contact, and Financial Data).

• Commercial Information: Such as records of products or services purchased or considered, or other purchasing or consuming histories (e.g., information about your subscriptions or usage of our products).

• Internet or Other Electronic Network Activity Information: Such as Technical and Usage Data related to browsing history, search history, and interactions with our Site, products, or advertisements (e.g., information collected via cookies and similar technologies, usage logs, etc.).

• Professional or Employment-Related Information: If you interact with us in a business capacity or as an employee of one of our customers, we may collect professional information such as your job title, employer (company name), and business contact information.

• Inferences: We may derive preferences or interests from other data (for instance, inferring which products or services may interest you based on your interactions)

​

SureView software (not our website) does collect precise geolocation data when mobile users choose to provide their precise location to the system as part of the key functionality of the mobile feature. This data is not sold or shared by SureView and is subject to the same retention limits as your other data.

​

We do not knowingly collect other categories of data defined by California law, such as Biometric Information, Sensory data (audio, visual) recordings (except for routine call recordings with notice, if any), Sensitive Personal Information (as specifically defined under CPRA) unless you voluntarily provide such information (e.g., if you submit a government-issued ID for identity verification, which may include a driver’s license number or similar). Additionally, we do not intentionally collect Protected Classification characteristics (like race, ethnicity, religious beliefs, or health data) beyond limited information such as date of birth or gender if you provide them; we do not use such characteristics to unlawfully discriminate in any way.

​

Sale or Sharing of Personal Information: SureView does not and will not “sell” your personal information for money, and we do not share your personal information for cross-context behavioral advertising (as those terms are defined under CCPA/CPRA). In other words, we do not disclose your personal information to third parties for monetary consideration or to allow third parties to target you with ads based on your personal information. Since we do not engage in selling or sharing personal information in this manner, we do not provide a “Do Not Sell or Share My Personal Information” link on our website. If this changes in the future, we will update our practices and Policy accordingly and provide the required opt-out mechanisms.

​

Disclosure of Personal Information for Business Purposes: In the past 12 months, we may have disclosed the above-listed categories of personal information to third parties for our business purposes, as described in “Disclosure of Your Personal Data” above. For example, we share data with service providers (e.g., cloud hosting providers, payment processors, analytics services, etc.), which are considered “service providers” or “processors” under California law, for the purposes of operating our business. When we disclose personal information to service providers or contractors for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

​

California Consumer Privacy Rights: As a California resident, you have the following rights regarding your personal information, subject to certain exceptions and limitations:

• Right to Know/Access: You can request to know what personal information we have collected about you and how we have used and disclosed it over the past 12 months. This includes the specific pieces of personal information we collected, the categories of sources of that information, the business or commercial purposes for collecting it, the categories of third parties to whom we disclosed it, and the categories of information (if any) that we sold or shared.

• Right to Delete: You can request that we delete personal information we collected from you and retained, subject to certain exceptions (for example, we may retain information as required by law or to complete a transaction you requested).

• Right to Correct: You have the right to request that we correct inaccurate personal information we maintain about you. Upon verification of your identity and the accuracy of the new information provided, we will correct any confirmed inaccuracies.

• Right to Opt Out of Sale or Sharing: As noted above, while we do not sell or share personal information in the manner defined by CPRA, you have the right to direct a business that does so to stop selling or sharing your personal information. If in the future we consider selling or sharing personal information, we will provide a clear opt-out mechanism consistent with California requirements.

• Right to Limit Use of Sensitive Personal Information: If we ever collect Sensitive Personal Information (as defined by CPRA) and use or disclose it for reasons other than the limited purposes allowed by law, you would have the right to limit our use or disclosure of such sensitive information. We do not currently use sensitive personal information for any purposes that trigger this right under CPRA.

• Right of No Retaliation (Non-Discrimination): You have the right not to receive discriminatory treatment from us for exercising any of your California privacy rights. We will not deny goods or services, charge different prices, or provide a different level of quality of service just because you exercised your rights (as per CCPA/CPRA’s non-discrimination requirement).

Exercising California Rights: To exercise any of the above California rights, you (or an authorized agent acting on your behalf) may submit a request to us by contacting our DPO at privacy@sureviewsystems.com or via any designated method on our website. Please indicate that you are a California resident making a “CCPA/CPRA request” and specify which right you seek to exercise. We will need to verify your identity to process certain requests, which may involve asking you to provide additional information so we can match it with our records. We will respond to verifiable requests within the time frame required by law (generally within 45 days, with the possibility of a 45-day extension in certain circumstances). If we need an extension or cannot comply with a portion of your request, we will explain the reasons.

​

Changes to this privacy policy

We keep our Privacy Policy under regular review to ensure it remains accurate and compliant with applicable laws. We may update this Policy from time to time (for example, in response to evolving legal requirements, our business practices, or technology changes). If we make material changes, we will notify users as required – for instance, by posting a prominent notice on our Site or, for significant changes, contacting you directly (e.g., via email or in-product notification). The Effective Date at the top of this Policy indicates when the latest changes became applicable. We encourage you to periodically review this page for the latest information on our privacy practices. [sureviewsystems.com]

​

Contact Information: If you have any questions, concerns, or comments about this Privacy Policy or our data practices, please contact our Data Protection Officer at privacy@sureviewsystems.com. You may also write to us at: SureView Systems, Inc., Attn: Data Protection Officer, 400 North Tampa St, STE 2250 Tampa, FL 33602  (please include “Privacy Request” in your correspondence).

​

We are committed to working with you to obtain a fair resolution of any privacy concern. Thank you for reading our Privacy Policy. SureView is dedicated to protecting your personal data and privacy rights.