Privacy Policy

Celerium Inc. Privacy Policy

Effective Date: September 17, 2021

OVERVIEW

This Privacy Policy ("Policy") describes how Celerium Inc. and our subsidiaries and affiliates including The ESP Group, Inc., and NC4 Soltra LLC (collectively, "Celerium" "we" or "us") collect, use and share personal information about you when you access or use our websites or other online services or applications ("Services"), attend our online events, or otherwise interact with us. It describes the types of personal information we receive in the course of doing business, how we use that information, third parties with whom we may share the information, as well as your choices in modifying or removing the information. For purposes of this policy, personal information includes "personal data" and similar terms as defined under applicable privacy laws.

Celerium owns and operates the following web properties, to which this Policy applies: https://celerium.com, https://celerium.net, https://cmmc.academy, https://lux.celerium.net, https://trial.cdngrids.net, https://*.cdngrid.net, and any webapp purposely built for a customer (each a “Website” and collectively the “Websites”).

For personal information collected through the Websites, we will only collect and use personal information from you as described in this Policy. We will not sell your personal information to any third parties; however, we may allow third parties to access and use certain information as necessary to conduct business and provide our services.

Information collected or shared by you regarding your company through one or more of our tools, questionnaires or services is not covered by this Policy (for example, company information uploaded or shared using one of our self-assessment tools). Please refer to the terms of use corresponding to the particular questionnaire, tool or service.

WHERE YOUR DATA GOES

Depending on the Celerium Service or webpages you are accessing and/or using, your personal information may be stored on our servers in the U.S. at our secure data center, or on a U.S. located server owned and secured by our third-party service providers. We use state of the art technologies to safeguard your personal information stored on our servers and have carefully chosen our third-party providers for many reasons, including their robust security systems. When you interact with our Websites certain data is collected as discussed below.

INFORMATION WE COLLECT; PURPOSE OF COLLECTING IT

Our privacy practices will vary depending on the circumstances under which we collected your personal information. Celerium collects personal information in the following circumstances:

Personal Information collected from our customers.

Personal Information collected through our Websites, Services, online events (e.g., webinars), surveys or questionnaires.

A. Information Collected from Customers

Celerium provides various of our Services under contract with our customers. If you have access to our Services as an employee, agent or contractor of such customer, your name and basic contact information (such as email, work telephone, work address) may have been provided to us by the customer or entered on our Services or Websites by a company-appointed administrator. In such cases, we have no direct relationship with the individuals whose personal information we process from customers.

B. Information Collected Through Our Websites

As is true of most websites, we gather certain information automatically and store it in log files. Even if you are only a visitor to one of our Websites, your computer or device automatically sends technical information to our web servers that we store in log files, including the following "Site Usage Data":

We collect Site Usage Data to allow you to browse and read pages on the Website and to ensure its functionality. We also collect Site Usage Data to perform analyses of the performance of the Website, to continuously improve the Website and correct errors, operation of our systems, as well as to prevent or uncover abuse. We further collect this data in aggregated or pseudonymized form to analyze trends, administer the Websites, track users’ movements around the Websites, and to gather demographic information about our user base as a whole or to improve marketing (including serving you personalized, interest-based ads) as well as the user experience on our Site. To collect Site Usage Data, we use cookies and similar technologies. This information includes:

• • • Date and time of your visit and the duration of your use of the Website;
    • Internet Protocol (IP) address of your device and internet service provider (ISP) – please note this information could be used to identify you if you live in a remote area where there are no other Internet users at a particular location;
    • Referring/exit pages;
    • The visited pages of the Website;
    • Information about the path you take though our Website; and
    • Information about your device including: type of device (telephone, computer etc.), browser type and version, settings, installed plug-ins, or operating system.

Celerium does not attempt to collect any sensitive information, such as personal financial information, social security or driver’s license numbers, or personal health information on our Websites.

Our Celerium.com Website includes social media features, such as Facebook or Twitter buttons and widgets that allow you to share the content. These features may collect your IP address, which page you are visiting on our Website, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third-party website or hosted directly on our website. Your interactions with these features are governed by the privacy policy of the company providing these features.

C. Information You Provide to Us

When you visit and use our Websites and/or Services, we may collect, retain and use information you provide to us. The information you may submit includes:

• • • Information that you provide when filling out online forms to register for events, marketing, webinars; to request information about our solutions; to report a problem with our Websites; or when you otherwise communicate with us. This information includes such personal information as your name, email address and phone number. You are not required to provide your personal information; however, without it, we may not be able to assist you or provide you with the information or services you have requested.
    • Account/Member Data: On some of our Websites you, or a customer administrator, if applicable, can register for an account or to be a member. Depending on the Service, you may be asked to create a profile which may include certain personal information such as first and last name, address, telephone and email. You may also be prompted to create a password. You may also be able to create a “User ID” that is different from your real name or your email address if you so choose. It is your responsibility to only enter information which you are comfortable having stored by us.
    • Chat, Forums, Community Sharing: Some of our Websites and/or Services offer chat, forums, sharing or commenting capabilities. Any information you provide in these areas may be read, collected, and used by others who access them with a registered account.
    • Webinars, Events: You may choose to register for one of our webinars or events, in which case you may be asked to provide certain personal information to register for the webinar/event, such as name, address, telephone and email.
    • Transaction Data: In relation to any possible purchases you may make online, you are directed to a third-party processor where your contact and billing information, (your name, address, and credit card information) is collected, verified and stored. You can view the exact information required in the form provided at point of purchase. This information is used to complete your order and for billing purposes. Additionally, the non-personal data about the items or services purchased may be used and/or returned to us by our third-party processor so we may make decisions about what products and services to offer and for internal accounting.
    • Customer Support Data: You can communicate with us through the different web-forms on our Websites and our customer support sites. For example, you can use the contact forms to ask questions about our products or services, request a demo, request technical assistance, to request to be put on one of our mailing lists, or otherwise reach out to our customer support team. In order to respond to your request, we will collect your contact information, contents of your request and may collect your IP address.
    • Survey/Questionnaire/Testing/Feedback Data: From time to time, we may provide you the opportunity to participate in surveys, questionnaires, testing and/or provide feedback with respect to our products or services. Participation is completely voluntary. However, if you choose to participate, you may provide us with personal information about yourself. Unless you otherwise consent, we will only use this information to determine the types of products or services that may be of interest to you and to operate, enhance or improve our offerings.
    • Email/Direct Mail Campaign Data: We offer informational emails and/or newsletters. Also, from time to time, we may contact our customers directly by email to inform you about new services, promotions, or special offers from us and from other companies, that you told us you were interested in receiving. If you respond to one of our emails, you may have the option to provide us with additional personal information, which we or our marketing partners will use for the purpose indicated. You may opt out of these emails at any time using the unsubscribe link at provided in the emails.
    • Testimonials: We may display personal testimonials of satisfied customers and/or users on our Websites in addition to other endorsements. With your consent we may post your testimonial on a Website along with your name.
    • Additional information we may collect from you:
      • • Information about your business, such as organization and industry.
        • Information collected through automated data collection techniques.

HOW WE USE THE INFORMATION WE COLLECT

We use the information we collect to provide, maintain, and improve our Services and other interactions we have with you or our customer. For example, we use the information we collect to:

• • • administer and manage your account/membership and communicate with you about your account/membership;
    • provide, deliver, enhance and improve our products and services, process transactions, and send you related information, including confirmations, receipts, invoices, surveys, questionnaires, webinar and/or event notices;
    • host forums, chats and other interactive areas of our Services, provide technical support (including to debug and troubleshoot), and send you technical notices, updates, security alerts, and support and administrative messages;
    • detect, investigate and prevent fraudulent transactions and other illegal activities and protect the rights and property of Celerium and others;
    • respond to your comments and questions and provide customer service;
    • communicate with you about Celerium and products, services, offers, promotions, surveys, questionnaires, testing, research, news, events, and other information we think will be of interest to you;
    • comply with our legal and financial obligations;
    • monitor and analyze trends, usage and activities;
    • provide advertising and marketing targeted toward your interests;
    • carry out any other purpose conveyed to you at the time the information was collected; and
    • if you are a defense supplier and affiliated with a defense prime contractor, depending on the Services chosen and/or your contractual arrangement with such prime contractor, and are a supplier affiliated with a prime, depending on the contractual arrangement, the Prime may be able to monitor your activity on a particular Service.

THIRD-PARTIES WITH WHOM WE MAY SHARE YOUR INFORMATION

In order to provide our Services, it may be necessary that we share our customer data with third parties. Such third-parties are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which it is disclosed to them. We do not sell, trade or rent customer data or a user’s personal information to others.

We may disclose certain personal information about you as described in this Policy, including:

To our third-party service providers as necessary to conduct our business, provide our services, operate our websites, provide webinars and events to which you subscribe, etc.

To our subsidiaries and affiliates to provide support to us and to you in connection with our Services or Websites.

To enforce contractual obligations or our Terms of Use.

As required by law, such as to comply with any subpoena, court order, or other legal process or to respond to law enforcement, government authority or regulatory requests.

On a good faith determination that disclosure is necessary or appropriate to protect the rights, property or safety of Celerium, our empoyees, our customers, or others, or to investigate fraud.

In the event of a sale, merger, acquisition, assignment or other transfer of all or part of the business.

To any other person with your consent.

WEBSITES LINKED TO CELERIUM WEBSITES

Except as otherwise set forth herein, this Policy only addresses the use and disclosure of information we collect from you. Third-party websites linked to, or from, Celerium sites are not under Celerium’s control and, therefore, we are not responsible for those websites. Such third-party websites accessible through our Websites or Services have their own privacy policies and related practices. Please consult such third-party’s privacy policy before linking to their site.

DATA RETENTION

We store the information we collect about you for as long as is necessary for the purpose(s) for which we collected it or for other legitimate business purposes, including to meet our legal, regulatory, or other compliance obligations.

DATA SECURITY

The security of our customer’s and user’s information is important to us. Celerium has implemented security measures designed to protect your personal information from accidental loss and from unauthorized access, use, alteration and disclosure. We expect you to take measures to protect your information as well by not sharing passwords or other credentials.

CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION

If you are accessing a Celerium Service as an employee, contractor or agent of one of our customers, you will need to reqeust changes to your information through the authorized administrator for that customer. In most cases, the authorized administrator will make the changes. However, if the customer requests Celerium to make changes to your information, we will do so within a reasonable period of time.

If you receive emails or promotional materials or offers from Celerium about our products, services or events, you can opt-out by using the opt-out link in the emails we send to you. You may also make your request by emailing privacy@celerium.com.

CALIFORNIA USERS

If you are a California, USA, resident and you provided your email address to Celerium, then, once each calendar year, you may submit a written request for information regarding any other companies with which we have shared your information for their use in direct marketing. To submit your written request, please send an email to privacy@celerium.com with “Request for California Privacy” in the subject line.

Upon request, Celerium will make a reasonable effort to inform you regarding whether we hold any of your personal information. Within 30 days of receiving your request, we will send you a list of the names and addresses of these other companies during the immediately preceding calendar year. We reserve the right to not respond to requests sent more than once in a calendar year, or requests submitted to an address other than the one posted in this Privacy Policy. Our disclosure only includes information covered by the law.

If you have signed up to receive marketing emails from Celerium, you can opt-out of receiving future marketing emails at any time by using the unsubscribe links at the bottom of the messages received from Celerium.

INDIVIDUALS IN THE EUROPEAN ECONOMIC AREA (“EEA”)

The following section applies to individuals in the EEA.

A. General Information

The owner of our Websites is Celerium Inc., 21515 Hawthorne Blvd, Suite 520, Torrance, CA 90503 USA. Privacy-related questions can be directed to: privacy@celerium.com.

You are not legally required to provide Celerium with your personal information described in this Privacy Policy. However, you might not be able to use our Websites or Services to their full extent if you do not provide us with certain data or if you object to our use of the data. Also, your data may be provided to us in the role of data processor by one of our customers, your employer. In such case, we take our instructions and directions from the customer (your employer).

B. Purpose for Collecting Data; Legal Basis for Processing your Personal Information.

We have provided the reasons why we collect your personal information above. Our legal basis for processing your personal information depends on the particular personal information and the context in which it was collected.

Typically, Celerium will collect personal information from you only where we have your consent to do so, where we need the personal information in order to perform our obligations under a contract with you or your employer, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms.

If we collect and use your personal information in reliance on our legitimate interests (or those of any third party), such interests will typically be for our legitimate commercial interests, to operate our Websites and/or Services, or to communicate with you as necessary to provide our products and services to you. These legitimate interests include improving our products, services and Websites; responding to your inquiries; performing marketing activities; and detecting or preventing illegal activities. There may be other legitimate interests that pertain to us and, if appropriate, we will provide those to you at the relevant time.

C. Transferring Your Data Outside of the EU or the EEA

Celerium’s principal place of business is in the United States of America. The EU generally considers that non-member countries do not afford the same level of protection that you enjoy in the EU, but Celerium still provides an adequate level of protection for your personal data, and as a California, USA based company, we have done so for a long time.

For Celerium customers that transfer personal data from the EU/EEA to the US as part of the Services, Celerium will incorporate the European Commission approved Standard Contractual Clauses (commonly referred to as the Model Contracts) into its agreements with those customers. The Standard Contractual Clauses are a set of contract terms that have been approved by the European Commission as ensuring adequate protection for personal data transferred from the EU/EEA to non-EU/EEA countries, including the US.

D. Data Subject Requests.

Individuals located in the EEA have the right to access personal information we hold about you and to ask that your personal information be corrected, erased, or transferred. You may also have the right to object to, or request that we restrict, certain processing. If you would like to exercise any of these rights, please send an email message to privacy@celerium.com or our customer support representatives at https://support.celerium.com.

E. Dispute Resolution

Any questions, concerns, or complaints regarding Celerium's use or disclosure of personal information shall be directed to the Celerium address below. Any Celerium employee who receives a question, concern, or complaint regarding the use or disclosure of Personal Information will direct that information to Celerium's legal department. Celerium will investigate and attempt to resolve complaints and disputes regarding use and disclosure of Personal Information in accordance with the principles contained in this Policy.

For complaints that cannot be resolved between Celerium and the complainant, Celerium has agreed to participate in the dispute resolution procedures of the International Centre for Dispute Resolution of the American Arbitration Association. By utilizing Celerium's Service, you also agree to subject any unresolved complaints to these dispute resolution procedures. For more information regarding The International Centre for Dispute Resolution, please consult its website at www.icdr.org or call 800.778.7879.

LIMITATION ON APPLICATION

Adherence by Celerium to the provisions set forth in this Policy may be limited (a) to the extent required for Celerium to respond to a legal or ethical obligation; (b) to the extent necessary to meet national security, public interest, or law enforcement requirements; (c) to the extent a disclosure or other action is permitted or required by an applicable law, rule, regulation, or legal process; (d) to enforce our policies or to protect our rights, property or safety, or those of another; and/or (e) to prevent illegal or improper uses of Celerium's Services or to defend Celerium against claim.

AMENDMENTS TO POLICY

Celerium may update this Policy from time to time to reflect changes in Celerium's products and services, or to remain consistent with the requirements of various privacy principles. Celerium will post its current privacy policy on the Celerium website at www.celerium.com.

CONTACT INFORMATION

Questions, comments, or complaints pertaining to this Privacy Policy or Celerium's collection or retention of personal information should be submitted to Celerium via the following means:

Celerium Inc.
Attn: Legal Department
21515 Hawthorne Blvd., Suite 520
Torrance, CA 90503
Email: privacy@celerium.com
Phone: 310.606.4425