Effective Date: November 1, 2020

1.0 PURPOSE

Inter-Con Security Systems, Inc. (“Inter-Con”) respects your privacy and is committed to collecting, maintaining, and using personal information about you transparently. This Privacy Policy (the “Policy”) applies to your use of www.icsecurity.com and other services offered through the icsecurity.com domain (the “Site”) and to information we may collect about you when you visit our offices.

BY USING THE SITE OR VISITING OUR OFFICES, YOU AGREE TO THIS PRIVACY POLICY. PLEASE READ IT CAREFULLY.

Please read this Policy carefully before you use our Site, communicate with us through the Site, or visit our offices. The practices described in this Policy are subject to applicable laws in the places in which we operate. By accessing the Site, communicating with us through the Site, or visiting our offices, you are accepting the terms of this Policy, which may be updated and amended from time to time.

2.0 WHAT INFORMATION DO WE COLLECT?

Depending on how you interact with us, we may collect several types of information about you, including:

• Like many websites, our server logs collect information regarding your operating system, browser software, IP (Internet Protocol) address, and the full Uniform Resource Locator (URL) clickstream to, through, and from our website, including date and time.

• We also use the services of other entities, such as Google Analytics, to help us log and analyze Site traffic, and that may result in our collecting and/or the service provider collecting information about you. When you use the Site, Google Analytics may make use of cookies and unique identifiers, such as mobile device identifiers, and Google may receive information about you, such as the URL of the page you are visiting and your IP address. You can learn more about Google Analytics’ privacy policy here: https://policies.google.com/technologies/partner-sites.

• You may choose to email us through the email links provided on the “Contact Us” page on the Site. If you do so, the information you share will include your email address and the information you choose to include in your email.

• You may opt to apply for a position through our Site. We use the services of other entities, such as Paycom Software, Inc. (“Paycom”), to facilitate such applications. If you choose to use these services, Inter-Con and the relevant service provider will collect information about you, which may include your name and contact information, a cover letter, a resume, transcripts, a personal statement, references, employment and education history, and other standard applicant information. Please review the privacy policy or privacy notice of these service providers for information about their privacy practices. Paycom’s privacy policy is available here: https://paycom.com/privacy/.

• When you visit our offices, we may collect your name, the date and times you visited, and who you were here to see. We may also use security technologies, such as security cameras, to enhance the physical security of our offices. If you use our guest wireless network, we may also log information about your use of that service for network administration, analysis, troubleshooting, and other operational purposes.

3.0 HOW DO WE USE YOUR INFORMATION?

Inter-Con may use the information described above for multiple purposes, including:

• Operating the Site, including for Site logging, Site administration, Site improvement, internal operations, troubleshooting, data analysis, testing, and research;

• Responding to your requests for information;

• Reviewing applications for positions with Inter-Con;

• Complying with applicable laws, regulations, and other legal requirements;

• Enforcing this Policy and our other policies and procedures and to protect our rights;

• Protecting our Site and operations against fraud, unauthorized access attempts, identity theft, or other unlawful activities;

• Maintaining the physical security of our offices;

• Protecting the rights, privacy, safety or property of you and others.

4.0 HOW DO WE SHARE YOUR INFORMATION?

Inter-Con may share your information in several ways, including:

• With service providers and other entities. As discussed above, we may share your information with service providers or other entities who assist us with online applications, website traffic monitoring and analysis, or other operations. It is possible that these entities may use information collected through your use of the Site, or through services that the Site links to, in combination with information those entities collect over time and across different web sites. We suggest you review these other entities’ privacy policies or notices at the links provided above. Additionally, if you plan to visit our offices, we may share your name and planned date and time of visit with building security to facilitate your visit.

• In a business transfer. We may share your information as part of a business transaction, such a provision of services rendered by or involving Inter-Con.

• For legal process and protection. We may share your information to satisfy any law, regulation, legal process, governmental request, or where we have a good faith belief that access, use, preservation, or disclosure of such information is reasonably necessary to:
  • Enforce or apply agreements, or initiate, render, bill, and collect for our services;
  • Protect our rights or interests, property or safety or that of others;
  • In connection with claims, disputes, or litigation—in court or elsewhere;
  • Protect users of our Site and others from fraudulent, abusive, or unlawful use of such services;
  • Use the information in case of an emergency.

5.0 LINKS TO THIRD PARTY SITES

Our Site may contain links to other entities’ websites and services. Please note that these links are provided for your convenience and information and to assist us in collecting information related, for example, to job applications. The websites and services may operate independently from us and have their own privacy policies or notices, which we suggest you review.

6.0 DO NOT TRACK

When you use our Site, third parties may collect information about your online activities, over time and across different internet websites, online or cloud computing services, online applications, or mobile applications. Some browsers support a “Do Not Track” feature, which is intended to be a signal to websites that you do not wish to be tracked across different websites you visit. Our Site is not currently set up to respond to “Do Not Track” signals and does not currently change the way it operates based upon detection of a “Do Not Track” or similar signal.

7.0 CONTACTING YOU

We may contact you as described in this Policy or applicable contract between us and you or your organization, including as necessary in connection with our Site, products, and services you use. Unless you tell us otherwise by “opting out,” we may also contact you regarding other products and services that may be of interest to you.

8.0 CHANGES TO OUR PRIVACY POLICY

Inter-Con reserves the right to amend this Policy at our discretion and at any time. When we make changes to this Policy, we will post the updated Policy on the Site and update the Policy’s effective date. Your continued use of our Site following the posting of changes constitutes your acceptance of such changes.

9.0 CONTACT INFORMATION

If you have any questions or comments about this Policy, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

• Toll-Free Phone: +1 (800) 439-5550

• Website: https://www.icsecurity.com/contact-us/

• Email: privacy@icsecurity.com

• Address: 210 South De Lacey Avenue, Pasadena, California 91105

10.0 PRIVACY NOTICE FOR CALIFORNIA RESIDENTS

Effective Date: November 1, 2020

10.1 Scope

This Privacy Notice for California Residents supplements the information contained in Inter-Con’s Privacy Policy and applies to California residents who use the Site. Any terms defined in the California Consumer Privacy Act of 2018 (“CCPA”) have the same meaning when used in this supplemental notice. Any capitalized terms not defined in this supplemental or in the CCPA have the meaning provided in Inter-Con’s Privacy Policy.

10.2 Information We Collect

Personal Information Collected (By Categories Set Forth In CCPA). During the preceding 12 months, we have collected the following categories of personal information about California Consumers (including, but not limited to, customers, job applicants and/or employees) through the Site or another source:

• Identifiers (including, for example, names, email addresses, postal addresses, and IP addresses);

• “Personal Information” as defined in California Civil Code section 1798.80, subsection (e) (such as names, address, and telephone numbers);

• Characteristics of protected classifications under California or federal law;

• Commercial information (such as records of services provided);

• Biometric information, defined in the CCPA to include an individual’s biological characteristics that can be used singly or in combination with other identifying data, to establish individual identity (for example, images recorded on security video);

• Internet or other electronic network activity information (such as website usage details, IP addresses, or the equipment used to access our network);

• Geolocation data (for example, the office in which an employee works or that a client visited);

• Audio, electronic, visual, thermal, olfactory, or similar information (such as images recorded on security video);

• Education information (for example, if you choose to apply for employment with us);

• Professional or employment-related information (for example, if you choose to apply for employment with us or are employed by Inter-Con);

• Inferences drawn from any of the information identified above to create a profile about a consumer reflecting, for example, the consumer’s preferences, characteristics, or predispositions (for example, a client’s billing preferences).

10.3 Personal Information Disclosed For A Business Purpose

Inter-Con may disclose your personal information to a third party for a business purpose. During the preceding 12 months, we have disclosed the following categories of personal information about California Consumers (including, but not limited to, customers, job applicants and/or employees) for a business purpose (such as to perform services on our or a service provider’s behalf or to detect or protect against illegal or fraudulent activity):

• Identifiers (including, for example, names, email addresses, postal addresses, and IP addresses);

• “Personal Information” as defined in California Civil Code section 1798.80, subsection (e) (such as names, address, and telephone numbers);

• Characteristics of protected classifications under California or federal law;

• Commercial information (such as records of services provided);

• Biometric information, defined in the CCPA to include an individual’s biological characteristics that can be used singly or in combination with other identifying data, to establish individual identity (for example, images recorded on security video);

• Internet or other electronic network activity information (such as website usage details, IP addresses, or the equipment used to access our network);

• Geolocation data (for example, the office in which an employee works or that a client has visited);

• Audio, electronic, visual, thermal, olfactory, or similar information (such as images recorded on security video);

• Education information (for example, if you choose to apply for employment with us);

• Professional or employment-related information (for example, if you choose to apply for employment with us or are employed by Inter-Con);

• Inferences drawn from any of the information identified above to create a profile about a consumer reflecting, for example, the consumer’s preferences, characteristics, or predispositions (for example, a client’s billing preferences).

10.4 Your Rights and Choices

The CCPA provides California Consumers with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

10.4.1 Access to Specific Information and Data Portability Rights

You have the right to request that Inter-Con disclose certain information to you about our collection and use of your personal information over the past 12 months:

• The categories of personal information we collected about you.

• The categories of sources for the personal information we collected about you.

• Our business or commercial purpose for collecting or selling that personal information.

• The categories of third parties with whom we share that personal information.

• The specific pieces of personal information we collected about you (also called a data portability request).

• If we sold your Personal Information, the categories of Personal Information that each category of recipient purchased; and

• If we disclosed your Personal Information for a business purpose, the categories of Personal Information that each category of recipient obtained.

To make such a request, you may call toll-free at +1 (800) 439-5550, email privacy@icsecurity.com, or submit a Verifiable Consumer Request from our Site. Please note that your request is subject to verification, and that we are not obligated to provide personal information in response to such a request if a consumer makes more than two requests in a 12-month period.

10.4.2 Deletion Request Rights

You have the right to request that Inter-Con delete any of your personal information that we collected from you and retained, subject to certain exceptions. To make such a request, you may call toll-free at +1 (800) 439-5550, email privacy@icsecurity.com, or submit a Verifiable Consumer Request from our Site. Please note that your request is subject to verification.

We also reserve the right to deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

• Complete the transaction for which the Personal Information was collected;

• Provide a service requested by you;

• Continue the ongoing business relationship with you within the reasonably anticipated context of that relationship;

• Perform a contract between you and Inter-Con;

• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for that activity;

• Debug to identify and repair errors that impair existing intended functionality;

• Exercise free speech, ensure the right of another California resident to exercise his or her right of free speech, or exercise another right provided for by law;

• Comply with the California Electronic Communications Privacy Act;

• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws;

• To enable solely internal uses that are reasonably aligned with the expectations of you based on your relationship with us;

• Comply with legal obligations;

• Otherwise to be used internally in a lawful manner that is compatible with the context in which you provided the Personal Information; or

• Provide employment and related benefits.

10.4.3 Response Timing and Format

We endeavor to confirm receipt of a Verifiable Consumer Request within 10 days of its receipt and respond to a Verifiable Consumer Request within 45 days of its receipt. If we require more time (up to 90 days from receipt), we will inform you of the reason and extension period in writing.

We will deliver our written responses by mail or electronically at your option. Any disclosures we provide will only cover the 12-month period preceding receipt of the Verifiable Consumer Request. The response we provide will also explain the reasons we cannot comply with a request, if applicable.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

10.5 Right to Opt In or Opt Out

If you are a California consumer, you have the right to opt out of having your personal information sold to third parties. If you are a California consumer under the age of 16 but at least 13, you have the right to only have your information sold if you opt in and affirmatively authorize the sale of your personal information; if a California-resident child is less than 13, then the child’s parent or guardian must opt in and affirmatively authorize the sale of personal information. Our current practice is to not sell your Personal Information for monetary or other valuable consideration, and we have not done so in the preceding 12 months. As described above in this notice, we may share your personal information with other entities, such as when we pay a service provider to assist us with processing your Personal Information and receive that service in return.

10.6 Right of Non-Discrimination

You have a right to exercise your rights under the CCPA without being subject to discrimination, including, but not limited to, by:

• Denying you goods or services.

• Charging you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.

• Providing you a different level or quality of goods or services.

• Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

This right does not prohibit a business from charging a consumer a different price or rate, or from providing a different level or quality of goods or services, if that difference is reasonably related to the value provided to the business by the consumer’s data. In certain instances, we may need your information. For example, when you apply for a position with us, we may need the information provided on your resume to evaluate your application for employment. If you request that we delete this information, we may not be able to consider your application.