Privacy Policy

Maclear Global, Inc Global Privacy Notice
Version 1.3
Effective Date: November 6, 2024

Maclear Global, Inc, a global governance, risk and compliance leader, has redefined modern
security with the world's most advanced cloud-native platform in enterprise risk. Powered by the
Maclear Global, Inc ® KaizenEVO Platform and artificial intelligence (AI), the Maclear Global, Inc
platform leverages real-time risk and compliance activities. For more information about Maclear
Global, Inc, please see the “About” section of our website
at https://www.maclearglobal.com/about

This Global Privacy Notice (“Notice”) describes the manner in which Maclear Global, Inc, Inc.
and related companies (collectively, “Maclear Global, Inc”) may use, maintain and disclose
information that we collect from you when you visit or interact with Maclear Global, Inc's social
media platforms, our websites (e.g., maclearglobal.com, Maclear’s support portal collectively,
“Websites”), sign up to attend or participate in an event or webinar, download a white paper or
other materials, and inquire about our “Offerings,” which include Maclear Global, Inc.'s cloud-
based software, technical support, training and professional services like incident response,
investigations, tabletop exercises, forensics and next-generation penetration tests related to
cybersecurity. For purposes of this Notice, the terms “user,” “you” and “your” are meant to refer
to the individuals about whom we may collect personal information, and at times, these terms
may be used within this Notice interchangeably. You can see a list of related companies below.

If you have any questions or concerns about our use of your personal information, then please
contact us using the contact details provided at the bottom of this Notice. At any time, you can
manage your privacy preferences by visiting our Preference Center. If you are a job applicant,
please refer to our Candidate Privacy Notice. Our websites include links to other websites
whose privacy practices may differ from those of Maclear Global, Inc. If you submit personal
information to any of those sites or services, your information is governed by their privacy
notices. We encourage you to carefully read the privacy notice of any website you visit.

Maclear Global, Inc.'s Websites and Offerings are not directed at children, and Maclear Global,
Inc does not knowingly collect or sell personal information from individuals under the age of 16.

This Notice does not apply to the information our customers upload or provide to us when they
use our Offerings. This Notice also does not apply when a responsible third party, such as a
Maclear Global, Inc partner, collects and uses your personal information. We encourage you to
carefully review the privacy notice of such third parties.
We recommend that you read this Notice in its entirety to ensure you are fully informed.

1. What Types of Personal Information Do We Collect?

These are the categories of personal information we may collect from you:

1. Business Contact Personal Information: Your first name, last name, job title,
employer name, work address, work email and work telephone number. If you or a
partner choose to provide us with other information, like your personal email address,
telephone number or mailing address, then Maclear Global, Inc will collect this
information, too.

2. Technical and Device Information: Your Internet Protocol (IP) address, browser
information, device ID, type of computer and technical information about how you
connect to our Websites and social media platforms, such as the operating system and
the internet service provider utilized. If you are required to log in to gain access to a
particular Website feature or portal, we collect usernames, passwords and other login
credentials to authenticate access.

3. Financial and Subscription Information: If you make a purchase, then Maclear
Global, Inc will collect credit/debit card numbers or data about other types of payment
used.

4. Audio and Visual Data: If you attend or give a presentation during a Maclear Global,
Inc-hosted in-person or virtual event, participate in a webinar or agree to be recorded
during a telephone conversation or virtual meeting, we may record and store your voice
and image and collect other personal information you provide to us, like your
professional biography. If you choose to personalize your account with a photo or social
media profile, then Maclear Global, Inc will collect this information, too. We may
document events in other ways, too, such as by taking photographs, conducting
interviews and recording participation in a live question-and-answer session.

5. Cookies and Analytics Data: Maclear Global, Inc and our third-party service providers
use cookies, local storage (HTML5), scripts and similar technologies with all our
Websites and some social media platforms so they function properly. We use such
technologies to continuously improve our Websites and to customize your experience
when you visit them. To some extent, cookies and analytics technologies help us provide

you with custom, personalized content (including targeted advertising), identify you
across multiple devices and monitor aggregate metrics such as total number of visitors,
traffic, usage and demographic patterns.

6. Feedback Data: Through our Websites and social media platforms, Maclear Global, Inc
makes available various online community forums and blogs. You may choose to
participate with these resources by interacting with us, interacting with other users or
adding your own posts. Maclear Global, Inc may invite you to participate in studies or
otherwise provide feedback about your experience. If you do so, then Maclear Global,
Inc considers your participation and your posts to be freely given, and we may collect
and use your feedback without compensation or attribution to you. However, we're under
no obligation to publish, maintain or retain any of your posts.

7. Personal Information About California Consumers Subject to the California
Consumer Protection Act (“CCPA”): In the preceding 12 months, Maclear Global, Inc
has collected the following categories of personal information about California
consumers. We may collect this personal information directly from you, from third parties
and from your interactions with our Websites and social media platforms. As defined by
the CCPA, the personal information categories are:

Business contact information, including identifiers such as name, email address, address and phone number
Commercial information, such as records of Offerings purchased and other transactional data
Internet or other network or device activity details, such as technical data about your use of our Websites or social media platforms
Geolocation data, such as your approximate location based on IP address
Audio, electronic or visual data, such as part of a photo or recording for a Maclear Global, Inc in-person or virtual event

2. When Do We Collect Your Personal Information?

Business Contact Personal Data: Maclear Global, Inc collects your business contact
information when you:
o Sign up to attend or participate in an in-person event or webinar
o Sign up for a contest or promotion
o Sign up for alerts or notifications related to our Offerings
o Download a white paper or other materials
o Agree to be recorded during a telephone conversation or virtual meeting
o Log in to a Website feature or portal
o Visit a Maclear Global, Inc office

Technical and Device Information: Maclear Global, Inc collects your technical and device
information when you:
o Visit our Websites and social media platforms
o Log in to a Website feature or portal
o Sign up for and use a free product trial
Financial and Subscription Information: Maclear Global, Inc collects your financial and
product subscription information when you:
o Purchase Offerings
o Sign up to attend or participate in a live event or webinar for which Maclear Global, Inc
charges a fee

Audio and Visual Data: Maclear Global, Inc collects your audio and visual data when you:
o Attend a Maclear Global, Inc-hosted in-person or virtual event
o Attend a partner-hosted in-person or virtual event
o Participate in a recorded telephone or conference call conversation
o Choose to personalize your account with additional information, such as a photo or
social media profile

Cookies and Analytics Technologies: Maclear Global, Inc uses cookies and analytics
technologies when you:
o Visit our Websites and social media platforms
o Log in to a Website feature or portal
o Sign up for and use a free product trial
If you would prefer not to be tracked, most browsers will allow you to (i) change your browser
settings to notify you when you receive a cookie, which lets you choose whether to accept it; (ii)
disable existing cookies; or (iii) set your browser to automatically reject cookies — however,
doing so may affect how our Websites work. For further information regarding Maclear Global,
Inc.'s use of cookies and how to set your cookie preferences, please refer to the Maclear Global,
Inc Cookie Notice.

Feedback Data: Maclear Global, Inc will collect your feedback when you:
o Participate in our online community forums and blogs
o Respond to Maclear Global, Inc polls and questionnaires

If you interact with Maclear Global, Inc, interact with other users or add your own posts, then
Maclear Global, Inc considers your participation and your posts to be freely given, and we may
use your feedback without compensation or attribution to you. Maclear Global, Inc is under no
obligation to publish, maintain or retain any of your posts.

3. How Do We Use Your Personal Information?

Maclear Global, Inc may use your personal information to:
o Provide you with information about our Offerings and send you reports, white papers and
other resources that you specifically requested to receive from us
o Manage accounts that you create with us
o Send you information about Maclear Global, Inc Offerings that we believe you may be
interested in when you have not opted out of receiving such marketing materials
o Analyze your feedback through surveys or research
o Contact you when a partner or other third party makes a referral to us and we
reasonably believe that they have your consent or another lawful basis for providing your
personal information to Maclear Global, Inc. A partner is a separate organization that
collaborates with Maclear Global, Inc to deliver cybersecurity solutions, services or
Offerings to customers. You can learn more about our partners at Maclear Global, Inc
Partners
o Monitor and keep secure our equipment, intellectual property, physical office locations,
Offerings, Websites, accounts on social media platforms and technology assets
o Diagnose and fix problems related to our Offerings
o Maintain endpoint and network security
o Prevent, investigate or provide notice of fraud or unlawful or criminal activity
o Comply with contractual, legal and regulatory obligations
o Enforce the terms and conditions that we agree to with our customers and those who
decide to try out our Offerings before purchasing them via evaluations and free
trials. Maclear Global, Inc Terms and Conditions
o Carry out a corporate transaction, such as a merger or sale of assets of all or part of our
company
o Comply with a subpoena or similar legal process or request
o Protect your safety or the safety of others
o Interact with our professional advisors (such as auditors, insurance companies, financial
service providers and attorneys) as needed for us to run our business
o Inform third parties (including partners and resellers of our Offerings) to the extent that
you consent to such sharing (where required by applicable law) or expressly direct us to
interact with such third parties

In the preceding 12 months and where applicable, we have disclosed each of these categories
to our service providers, affiliates, partners, resellers and event sponsors, in line with the
applicable purpose(s) described above.

4. What Sources Provide Us with Personal Information?

As described above, Maclear Global, Inc collects personal information from you when you
interact with us online or in person. We also collect your personal information from other
sources when we reasonably believe that they have your consent or another lawful basis for
providing your personal information to Maclear Global, Inc.
Other sources of personal information include:
o Partners and resellers that market and sell our Offerings
o Maclear Global, Inc-related companies
o Social media platforms
o Data brokers
o Providers that make user-generated content available to others, such as local business
reviews or public social media posts
o Communication services, including email providers and social networks, when you give
us permission to seek personal information from these sources
o Referrers, who may share a contact's name and email address with us using a referral
option

5. Does Maclear Global, Inc Share Your Personal Information?

When we collect and use your personal information as described in this Notice, Maclear Global,
Inc may share it with those listed below:
o Maclear Global, Inc-related companies
o Service providers as necessary to provide our Offerings
o Service providers as necessary to fulfill a request made by you
o Maclear Global, Inc professional advisors, such as auditors, insurance providers,
financial service providers and attorneys
o Public authorities, as required by law to comply with a subpoena or similar legal process
or to protect Maclear Global, Inc or its customers
o Customers as necessary to prevent or investigate alleged fraud or other unlawful
criminal activity
o Online content technology providers

o Advertisers. You may opt out by visiting Digital Advertising Alliance's self-regulatory opt-
out page here. If you are in the European Economic Area, click here. Please note this
does not opt you out of being served ads; you will continue to receive generic ads
o Event sponsors. In addition to this Notice, your personal information is subject to
sponsors' privacy practices
o Contest and promotion sponsors
o Partners and resellers that sell our Offerings
o Your employer/organization

In the preceding 12 months, we have disclosed certain categories of personal information
described above to third-party advertising partners, such as in connection with our use of
tracking technologies for cross-context behavioral advertising or by providing lists of email
addresses for potential customers so that we can reach you across the internet with
advertisements for our Offerings. This may be considered “sharing” or a “sale” under the CCPA.

6. What Is Maclear Global, Inc.'s Legal Basis for Processing Personal Data?

If the law requires us to have a legal reason for collecting and using your personal information,
such as the European Union or United Kingdom General Data Protection Regulation (either the
“GDPR”), then the reason will depend on the type of information we collect and why we collect
it. When you interact with Maclear Global, Inc as a representative of a customer or sign up for a
free trial, we use your personal information either because you gave us permission (where
required by law) or because we need it to fulfill an agreement, we have with you or your
company.

When you fill out a form to ask about Maclear Global, Inc or one of our Offerings, we use your
personal information either with your permission (where required by law) or because it's in our
legitimate interest to respond to your request, communicate with you and send you information
about our Offerings (like via marketing calls or emails, depending on your preferences).
If you sign up for newsletters or events, request a demo, download resources or take part in
surveys, we use your consent to send you more information about our Offerings that we think
might interest you. You can opt out of these communications at any time.
We also rely on your consent when it comes to using cookies on our websites. You agree to this
when using our sites, although cookie rules can vary based on where you are located.
If we need to use your personal information based on our legitimate interests, we will tell you
this when collecting the data. Our legitimate interests include things like running our websites,
communicating with you when you ask for information and marketing our Offerings.
Sometimes, we also need to process your information to meet legal requirements, like keeping
business records or complying with tax laws.

7. Security Safeguards

We adopt data collection, storage and processing practices and security measures to protect
against unauthorized access, alteration, disclosure or destruction of your personal information,
and we follow generally accepted practices to protect such data.
For your own safety, please note that the security of data transmitted through the internet can
never be guaranteed. You are responsible for maintaining the security of your password or other
form of authentication involved in accessing password-protected or secured areas of any
Maclear Global, Inc portal. Access to and use of password-protected and/or secure areas of any
Maclear Global, Inc portal is restricted to authorized users only.

For more information on security measures, please contact the Vice President, Privacy, Maclear
Global, Inc (see Section 10 below).

8. Retention of Personal Data

Subject to the conditions and restrictions set out under applicable laws or privacy frameworks
(see Section 9 below), we will retain your personal information for as long as needed to fulfill the
purpose for which we collected it and for a reasonable period thereafter to comply with audit,
contractual or legal requirements or where we have a legitimate interest in doing so. We may
retain aggregated or de-identified data indefinitely or to the extent allowed by applicable law. We
may retain personal information in computer backup or archival copies generated in the ordinary
course of our business.

9. Adherence to Privacy Frameworks

As a global organization, Maclear Global, Inc may need to transfer your personal information
outside your home jurisdiction to Maclear Global, Inc affiliates, including our headquarters in the
United States, and other countries where our service providers operate. These countries may
have data protection laws that are different from the laws of your region. We will only transfer
your personal information to another country in accordance with applicable data protection laws
and provided there is adequate protection in place for the data (e.g., through an adequate
mechanism for the international transfer of personal information). These mechanisms include
written data processing agreements or other appropriate safeguards, as established in the
GDPR or voluntary privacy frameworks made to improve general data privacy and safeguard
the cross-border transfer of personal information (“Privacy Frameworks”).

EU-U.S., U.K. and Swiss Data Privacy Frameworks

Maclear Global, Inc complies with the EU-U.S. Data Privacy Framework (“EU-U.S. DPF”), the
United Kingdom (“U.K.”) Extension to the EU-U.S. DPF and the Swiss-U.S. Data Privacy
Framework (“Swiss-U.S. DPF”; collectively, “DPF Frameworks”) as set forth by the U.S.
Department of Commerce. Maclear Global, Inc has certified that it adheres to the EU-U.S. DPF
Principles and the Swiss-U.S. DPF Principles. If there is any conflict between the terms in this
Notice and the DPF Frameworks, then the DPF Frameworks shall govern. To learn more about
the DPF program, and to view our certifications, please
visit https://www.dataprivacyframework.gov/.

The Federal Trade Commission has jurisdiction over Maclear Global, Inc's compliance with the
DPF Frameworks. In compliance with the DPF Frameworks, Maclear Global, Inc commits to
refer unresolved complaints concerning our processing of your personal information to TRUSTe,
an alternative dispute resolution provider based in the United States. If you do not receive timely
acknowledgment of your DPF Frameworks-related complaint from us, or if we have not
addressed your DPF Frameworks-related complaint to your satisfaction, please visit File a
Report with TRUSTe. These dispute resolution services are provided at no cost to you.

For complaints regarding DPF Framework compliance not resolved by any of the other DPF
Framework mechanisms, you have the possibility, under certain conditions, to invoke binding
arbitration. Additional details are available at the official DPF Website.

Asia-Pacific Economic Cooperation (APEC) Privacy Framework
Maclear Global, Inc.'s privacy practices, described in this Notice, comply with the APEC Cross-
Border Privacy Rules (“CBPR”) System. The APEC system provides a framework for
organizations to ensure protection of personal information transferred among participating
APEC economies. Additional details about the APEC framework can be found here.

10. Individual Privacy Rights

Subject to the conditions and restrictions set out under applicable law and/or Privacy
Frameworks, you may have the following rights:

o You may request access to, and correction or deletion of, your personal information
o You may object to the processing of your personal information, ask us to restrict its
processing and request that we provide your personal information to certain third parties
o You may have the right to complain to Maclear Global, Inc and/or a data protection
authority about Maclear Global, Inc's collection and use of your personal information

If you have consented to Maclear Global, Inc's collection and use of your personal information,
you can withdraw your consent at any time. Withdrawing your consent will not affect the
lawfulness of any processing we conducted prior to your withdrawal, nor will it affect the
processing of your personal information conducted in reliance on another lawful basis.
If your employer is a Maclear Global, Inc customer, then please contact them directly if you wish
to exercise your privacy rights concerning your personal information, which they provide to
Maclear Global, Inc to process for them. Under applicable law and the agreements we have in
place with our customers, Maclear Global, Inc cannot respond directly to your request in this
event.

If you are a California resident, then the CCPA applies to you, and you may have the right to:
o Know what kind of personal information we collect about you and how we use, disclose,
share and sell it
o Request that we correct inaccurate personal information
o Instruct us to delete your personal information
o Opt out of the sale or sharing of your personal information. Maclear Global, Inc shares
personal information as described above in Section 5, which may be considered a “sale”
of personal information under the CCPA
o Limit the use or disclosure of your sensitive personal data. Maclear Global, Inc does not
collect, share or sell sensitive personal data
o Not receive discriminatory treatment from Maclear Global, Inc for exercising your privacy
rights under the CCPA
o Designate an authorized agent to make a request on your behalf when exercising your
privacy rights under the CCPA

You may exercise your privacy rights by completing our Individual Privacy Right Request
Form or by emailing your request to privacy@Maclear Global, Inc.com . When you do so, please
provide your complete name and your email address, which we'll use to communicate with you.
Maclear Global, Inc will use this information only to verify you and process your request. If you
are an authorized agent, then we reserve the right to request you demonstrate evidence of your
authorization, either by providing us with a signed permission form or a copy of your power of
attorney granting you such authority.

If you're a California resident, then you can opt out of the sale/share of your personal
information by submitting a request via our Opt-Out Form, by emailing your request to
privacy@Maclear Global, Inc.com or by clicking the Your Privacy Choices link at the bottom of
www.Maclear Global, Inc.com and following the directions provided on that page. You may also
opt out by using an opt-out preference signal, such as the Global Privacy Control (“GPC”).
Please note that unless you have previously provided your personal information to Maclear
Global, Inc, your request to opt out via GPC will be linked to your browser identifier only
because Maclear Global, Inc does not have any of your personal information with which to
associate your GPC opt-out directive.

From the period of January 1, 2023, to January 1, 2024, Maclear Global, Inc received five
verifiable requests from California consumers.
If you have any questions about this Notice, please contact us at:

Vice President, Privacy
Maclear Global, Inc
1513 Coloma Court
Wheaton, IL 60189
contact@maclear-grc.com

11. Updates to This Notice

We may update this Notice and its effective date at any time to reflect changes to our practices.
We encourage you to periodically review this Notice for the latest about our privacy practices.