Effective date: March 1, 2021

This Privacy Policy (“Policy”) lets you know how FireLab LLC (“FireLab,” “We, “Us”) collects and uses your Personal Information, how you can control its use, and describes our practices regarding information collected from our website, computer or software applications, and social media pages and HTML-formatted e-mail messages (collectively, the “Services”).

Before you submit any information on or through the FireLab Site or account portal or use FireLab products of services, please carefully review this policy. You acknowledge and understand that, by using any part of the FireLab Site or service, your continued use of the FireLab Site, and/or continued provision of information to us will be subject to the terms of the then-current Privacy Policy.

This policy applies to information we collect:

• On this Website.
• In e-mail, text and other electronic messages between you and this Website.
• Through our Software which includes both a web based application.
• When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy.

Information for California consumers can be found in section 10 “California Consumer Privacy Act.”

We use cookies to collect data automatically about your use of our website or for advertising.

We can share the data we collect from you with those outside of FireLab if they are a service provider for FireLab (and have to follow our requirements) or if we’re legally required to share it with those outside of FireLab.

This Policy does not apply to information collected by:

• us offline or through any other means, including on any other website operated by Us or any third party (including our affiliates and subsidiaries); or
• any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or on the Website.

We do not participate in the E.U. – U.S. and Swiss – U.S. Privacy Shield Frameworks and do not comply with the Privacy Shield Principles.

We at FireLab know you care about how your personal information is used and shared, and we take your privacy seriously. Please read the following to learn more about our Privacy Policy. By using or accessing the Services in any manner, you acknowledge that you accept the practices and policies outlined in this Privacy Policy, and you hereby authorize FireLab to collect, use, and share your information for the purposes identified herein and on the Site.

Remember that your use of FireLab’s Services is at all times subject to the Terms of Use, which incorporates this Privacy Policy. Any terms we use in this Policy without defining them have the definitions given to them in the Terms of Use.

The Services may provide links to or the ability to connect with non-FireLab websites, services, social networks or applications. Clicking on those links or enabling those connections might allow the third party to collect or share information about you. Those third-party websites or services are beyond FireLab’s control. FireLab advises you to check the privacy policies and terms of use of any non-FireLab websites or services before providing any of your Personal Information to them.

As noted in the Terms of Use, we do not knowingly collect or solicit personal information from anyone under the age of 18. If you are under 18, please do not attempt to register for the Services or send any personal information about yourself to us. If we learn that we have collected personal information from anyone under age 18, we will delete that information as quickly as possible. If you believe that anyone under the age of 18 may have provided us personal information, please contact us at: hello@firelabinc.com .

1 Will FireLab ever change this Privacy Policy?

We’re constantly trying to improve our Services, so we may need to change this Privacy Policy from time to time as well, but we will alert you to changes by placing a notice in the app, by sending you an email, and/or by some other means. Please note that if you’ve opted not to receive legal notice emails from us (or you haven’t provided us with your email address), those legal notices will still govern your use of the Services, and you are still responsible for reading and understanding them. If you use the Services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes.

2 What Does FireLab Do With Your Information?

We want to be very clear about the type of information we collect and how we use it to deliver our Services to you and operate our business. We do not sell or share your Personal Information with third parties for their own commercial uses without your consent.

a) Types of Information We Collect.

In connection with using our website or accessing our Services, we may collect information from you which can be used to identify you or your clients such as your name, postal address, email address, phone, username and password and ANY OTHER INFORMATION THE WEBSITE COLLECTS THAT IS DEFINED AS PERSONAL OR PERSONALLY IDENTIFIABLE INFORMATION UNDER AN APPLICABLE LAW (“Personal Information” or “Data” as defined in our Customer Subscription Agreement), Our website might also collect personal information that is about you but individually does not identify you, and/or about your internet connection, the equipment you use to access our Website and usage details.

We collect information when you register or open an account, sign in, pay a bill, purchase a Service, call us for support, or give us any type of feedback. We may also get information from other companies or third parties, or when we may use service providers to supplement the Personal Information you give us such as validating your mailing address to help us maintain the accuracy of your data and provide you with better service. We might also collect content or other information that you may provide or create when you interact with our Services, including your user name, comments, likes, interests, status, pictures and references to your online presence. We make this information available to others, as you request.

To create and open an account through the Services, We may require you to provide personal information to identify yourself such as name, email address, password or phone number.

When purchasing certain Services, you will also be required to provide a credit card number, billing address, phone number or other payment information. No information of this type will be collected unless you have registered for aspects of the Service that require it. Be advised that if we collect payment from you of any kind that we will utilize the services of a third party payment processor to facilitate your payment by credit card.

We may also automatically collect certain usage information when you access our Services (“Usage Data”), such as Internet Protocol address (“IP address”) and information derived from your IP address such as your geographic location, log files, unique device identifiers, pages viewed, browser type, any links you click on to leave or interact with our Services, and other usage information collected from cookies, pixels, tags, beacons, scripts or other technology tracking technologies. We collect IP addresses to track and aggregate non-personal information, such as using IP addresses to monitor the regions from which users navigate to our Services. We also collect IP addresses from users when they log into the Services as part of our log-in and security features. We may also, when you enable location-based Services, collect Global Positioning System (GPS) location data and/or motion data. We may also collect Past transactional behavior conducted by You on the Services, Information about your company such as the name, size and location of your company and your role within the company, and Behavioral or demographic attributes, when tied to personal identifiers.

FireLab may also collect additional information through your dealings with and use of the Services and non-FireLab websites, which does not disclose your specific identity or does not directly relate to an individual. Additional information may include, but is not limited to:

Internet Protocol address (“IP address”) and information derived from your IP address such as your geographic location; Geographic location showing where You are using the Services;

Information about your devices such as information contained in HTTP Headers (defined below) or other internet transfer protocol signals, browser or device type and version; operating system, user-agent strings and information about or from the presence or use of “apps” on your mobile devices, screen resolution, and your preferred language;

Unique IDs such as a cookie placed on your computer, mobile or device IDs;

Behavioral data and information about your usage of the Services, including webpages clicked, websites and content areas visited, date and time of activities;

The web search you undertook to locate and navigate to the Services.

We might also put together additional information with Personal Information, such as gathering geographical location from your IP address and combining all of this with behavioral data about your usage of the Services with your name. If we combine additional information with personal Information, we will treat the combined information as Personal Information.

We might also collect personal information from you if you log into our Services using a Third Party Social Network such as Facebook, Instagram or Snapchat

Our Services may change over time and we may introduce new features that may collect new or different types of information.

2a(i). Confidential Information: Confidential information means any information disclosed by and between FireLab and its customers, either directly or indirectly, in writing, orally or by inspection of tangible or intangible objects, including without limitation documents, business plans, source code, software, documentation, financial analysis, marketing plans, customer names, customer list and customer data (hereinafter the “Confidential Information”.) Confidential Information may also include information disclosed to a party by third parties at the direction of a Disclosing Party. Confidential Information shall not, however, include any information which the Receiving party can establish (i) was publicly known and generally available in the public domain prior to the time of disclosure; (ii) becomes publicly known and made generally available after disclosure through no action or inaction of Receiving Party; or (iii) is in the possession of Receiving Party, without confidentiality restrictions, at the time of disclosure by the Disclosing Party as shown by Receiving Party’s files and records immediately prior to the time of disclosure. The party disclosing the Confidential Information shall be referred to as the “Disclosing Party” in the Agreement and the party receiving the Confidential Information shall be referred to as “Receiving Party” in the Agreement.

2a(ii). Non-use and Non-disclosure: FireLab agrees to prohibit disclosure of Customer’s Confidential Information related to its use of FireLab’s life safety software platform. FireLab agrees not to disclose any Confidential Information to third parties or to its employees, except to: (1) those employees who are required to have the information in order to provide technical support in the use of its software platform on behalf of Customer; and (2) third party agents and companies acting on FireLab’s behalf who perform functions to enable FireLab to provide its Services. This means we may share information about you that can identify you personally with service providers or agents in order to have them perform on our behalf any of the activities we are permitted to conduct under this Privacy Policy and our Terms of Use including but not limited to website design, sending email communications, fraud detection and prevention, customer care, removing repetitive information from customer lists, analyzing data, providing marketing assistance, providing search results and links (including paid listings and links), processing credit card payments, providing customer service or performing analytics. These third parties are acting on our behalf so while they may have access to your information they’re required to follow our instructions and meet the standards explained in our Privacy Policy when handling information about you that we provide them. FireLab shall not disseminate Customer’s Confidential Information unless otherwise stated hereunder.

Maintenance of Confidentiality Information: FireLab agrees that it shall take all reasonable measures to protect the secrecy of and avoid disclosure and unauthorized use of the Confidential Information. Without limiting the foregoing, FireLab shall take at least those measures that FireLab takes to protect its own most highly confidential information and shall have its employees, if any, who have access to Confidential Information sign a non-use and non-disclosure agreement in content substantially similar to the provisions hereof, prior to any disclosure of Confidential Information to such employees. FireLab shall not make any copies of Confidential Information unless the same are previously approved in writing by Customer. FireLab shall reproduce Customer’s proprietary rights notices on any such approved copies, in the same manner in which such notices were set forth in or on the original. FireLab shall immediately notify Customer in the event of any unauthorized use or disclosure of the Confidential Information.

b) How FireLab Uses Your Information.

FireLab may use your Personal Information it collects (unless otherwise prohibited by applicable law), for the following purposes:

(i) Information that you provide by filling in forms on our Website. This includes information provided at the time of registering to use our Website, subscribing to use our paid services, posting material or requesting further services. We may also ask you for information when you report a problem with our Website.

(ii) Account Registration. We may use your name, address, phone number, and email address to register your FireLab Account for certain Services we provide and to communicate important information to you. We may obtain additional Personal Information about you, such as address change information, from commercially available sources, to keep our records current. If you set up an administrator account that may be accessed by people other than you, please note that they may see and have the ability to change or delete your Personal Information.

(iii) Records and copies of your correspondence (including e-mail addresses), if you contact us.

(iv) Your responses to surveys that we might ask you to complete for research purposes.

(v) Details of transactions you carry out through our Website and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Website.

(vi) Your search queries on the Website

(vii) To bill and collect money owed to us by our Customers. This includes sending you emails, invoices, receipts, notices of delinquency, and alerting you if we need a different credit card number. We use third parties for secure credit card transaction processing, and we send billing information to those third parties to process your orders and credit card payments.

(viii) To send you System Alert messages. For example, we may inform you of temporary or permanent changes to our Services, such as scheduled outages, new features, version updates, releases, abuse warnings, and changes to our Privacy Policy.

(ix) To enforce compliance with our Terms and Conditions and applicable law. This may include developing tools and algorithms that help us prevent violations.

(x) To protect the rights and safety of our Employees, Customers and third parties, as well as our own.

(xi) To meet legal requirements, including complying with court orders, valid discovery requests, valid subpoenas, and other appropriate legal mechanisms which includes responding to lawful requests by public authorities, including to meet national security or law enforcement requirements.

(xii) To communicate with our Customers in response to questions and concerns, about their account and provide customer support.

(xiii) To Let You Know About Other Services. We may use your information to communicate with you about our Services and to give you offers for third party products and services that may be of use to you.

(xiv) To Improve Services and Develop New Services. We may use your information or your clients’ information to personalize or customize your experience to develop new features or services, and to improve the overall quality of FireLab’s Services. We may use your information or your clients’ information to personalize or customize your experience to develop new features or Products, and to improve the overall quality.. We may (i) compile statistical and other information related to the performance, operation and use of the Products, and (ii) use data from the Products in aggregated form for security and operations management, to create statistical analyses, and for research and development purposes (clauses i and ii are collectively referred to as “Product Analyses”). We may make Product Analyses publicly available; however, Product Analyses will not incorporate Yours or your clients’ Content, Personal Data or Confidential Information in a form that could serve to identify You, your client or any individual. We retain all intellectual property rights in Product Analyses.

(xv) Feedback. We may use any information you volunteer to provide to us in surveys you answer and combine them with answers from other customers in order for us to better understand our Services and how we may improve them. Of course, answering any survey is optional.

(xvi) To Provide Our Services and Operate Our Business. We may use your information to operate our business, including providing any Services that you have requested, provide you with support related to our Services, and to help us protect our Services, which includes taking action against fraud and protecting your information.

(xvii) Customer Service and Technical Support. We may use your name, address, phone number, email address, how you interact with our Services, and information about your computer configuration to deal with and resolve questions you may have about our Services and to follow up with you about your experience.

(xviii) Publishing or Sharing Combined Information from Many Users In a Manner that Would Not Allow You, your clients or Any Other Person to be Identified Personally. We may prepare and share information about our customers with third parties, such as advertisers or partners, for research, marketing and/or promotional purposes but only in a way that would not allow you, your clients or any other person to be identified. For example, we may share demographic data that describes the percentage of our customers who use one of our services or who use a specific operating system. We or our third party partners may publicly report the aggregated findings of the research or analysis, but only in a way that would not allow you, your clients or any other person to be identified.

(xix) Selling, Publishing, Disclosing or Sharing Combined Information from Many Users with our partners in order to help our partners market and sell our Offerings pursuant to written agreements with confidentiality, privacy and security obligations. All such information includes data derived from personal information in aggregated, anonymous form and does not identify You, your clients or any individuals.

(xx) To provide information to representatives and advisors, including attorneys and accountants, to help us comply with legal, accounting, or security requirements.

(xxi) To prosecute and defend a court, arbitration, or similar legal proceeding.

(xxiii) To provide suggestions to you. This includes adding features that compare Customers’ content or communications, using data to suggest products or services that you may be interested in or that may be relevant to you.

(xxiii) To transfer your information in the case of a sale, merger, consolidation, liquidation, reorganization, or acquisition. In that event, any acquirer will be subject to our obligations under this Privacy Policy, including your rights to access and choice. We will notify you of the change either by sending you an email or posting a notice on our Website.

(xxiv) Customer Testimonials. We might at some point upload Customers testimonials on our Services that may contain Personal Information. Before doing so, we will obtain your consent to use your name and testimonial. If you ever desire to delete a testimonial, please contact us at hello@FireLab.com.

(xxv) Respond to Your Requests. FireLab may also use Personal Information in order to respond directly to your information requests

(xxvi) Third Party Social Networks. FireLab may use your Personal Information to connect with you on third party social networks. FireLab ‘s interactions with you on any third party social network would be subject to that network’s privacy policies and terms of use.

(xxvii) We may use the information we have collected from you to enable us to display advertisements to our advertisers’ target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

You also may provide information to be published or displayed (hereinafter, “posted”) on public areas of the Website, or transmitted to other users of the Website or third parties (collectively, “User Contributions”). Your User Contributions are posted on and transmitted to others at your own risk. Although we limit access to certain pages/you may set certain privacy settings for such information by logging into your account profile, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Website with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

(xxvii) Co-Branded Partners. Co-Branded Partners are companies with whom a FireLab Service jointly offers a service or feature. You can tell when you are accessing a service or feature offered by a Co-Branded Partner because the Co-Branded Partner’s name will be featured prominently. You may be asked to provide information about yourself to register for a service offered with a Co-Branded Partner. In doing so, you may be providing your information to both us and the Co-Branded Partner. Please note that the Co-Branded Partner’s privacy policy may also apply to its use of your information.

(xxviii) Other Persons or Entities. With appropriate consent when required, certain FireLab Services may share your contact information with third party marketing partners, and they may contact you by email, telephone, postal mail or other common communication methods with marketing and promotional messages about their products or services. Sometimes we will give you the option to receive further communications from one of our advertising partners, for example when we run a competition with that advertiser. When you provide consent to receive communications from that third party advertiser, your personal information will be managed by that third party’s own privacy policy.

(xxix) In order to provide the Services effectively and in accordance with applicable law and the Agreement, FireLab may monitor and record a user’s use of the Services and User authorizes FireLab to collect, store and use all such information in accordance with privacy provisions of this Agreement.

c) How Does FireLab Share Your Personal Information.

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose personal information that we collect or you provide as described in this privacy policy:

(i) Third Party Service Providers. We do not share your personal information with unaffiliated third parties except agents or companies acting on FireLab’s behalf who perform functions to enable FireLab to provide its Services. This means we may share information about you that can identify you personally with service providers or agents in order to have them perform on our behalf any of the activities we are permitted to conduct under this Privacy Policy and our Terms of Use including but not limited to website design, sending email communications, fraud detection and prevention, customer care, removing repetitive information from customer lists, analyzing data, providing marketing assistance, providing search results and links (including paid listings and links), processing credit card payments, providing customer service or performing analytics. These third parties are acting on our behalf so while they may have access to your information they’re required to follow our instructions and meet the standards explained in our Privacy Policy when handling information about you that we provide them.

(ii) Selling, Publishing, Disclosing or Sharing Combined Information from Many Users to our partners i n order to help our partners market and sell our Offerings pursuant to written agreements with confidentiality, privacy and security obligations. We will create statistical, aggregated data related to our Customers, Users, Customers’ Clients and the Offerings for analytical purposes. Aggregated data includes data derived from personal information in aggregated, anonymous form and does not identify any individuals or customer or user names (such data is referred to as “Aggregate Information”). Subject to applicable laws and regulations we use aggregate information to understand our Customers, Users, Customers’ Clients and the Offerings and to develop, market and/or improve our Offerings. We may provide Aggregate Information to third parties. For example, we may share demographic data that describes the percentage of our customers who use one of our Offerings to analyze usage trends, such as by industry or sector, or to identify KPIs, metrics and benchmark data or other such aggregated information useful to our partners . We or our third party partners may publicly report the aggregated findings of the research or analysis, but only in a way that would not allow you or any other person or company to be identified.

(iii) We do not sell or rent Personal Information to unaffiliated third parties for their advertising or marketing lists;

(iv) Professional Advisors: We may share your personal information with professional advisors acting as service providers, processors, or controllers – including our lawyers, bankers, auditors and insurers;

(v) Partners and Value Added Resellers: if you choose to interact with or use our partners or value added resellers we may share your personal information with them and they may contact you regarding their products or services;

(vi) Customers with whom you are affiliated: if you use our products, services and offerings as an authorized user of one of our customers, we may share your personal information with your affiliated customer responsible for your access to the products, services and offerings, to the extent necessary for providing our products, services and offerings;

(vii) To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of the Company’s assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by the Company about our Website users is among the assets transferred.

(viii) To third parties to market their products or services to you if you have consented to these disclosures. We contractually require these third parties to keep personal information confidential and use it only for the purposes for which we disclose it to them.

(ix) To fulfill the purpose for which you provide it.

(x) For any other purpose disclosed by us when you provide the information.

(xi) With your consent.

(xii) Response to Subpoenas and Other Legal Requests. We may share your information with courts, law enforcement agencies, or other government bodies when we have a good faith belief that we are required or permitted to do so by law, including to meet national security or law enforcement requirements, to protect our company, or to respond to a court order, subpoena, search warrant, or other law enforcement request.

(xiii) Protection of FireLab and Others. We may share account information, Personal Information and Usage Data when we believe it is appropriate to enforce or apply our products’ Terms of Use and other agreements; or protect the rights, property, or safety of FireLab, our Offerings, our users, or others. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction. This does not include selling, renting, sharing, or otherwise disclosing Personal Information of our customers for commercial purposes in violation of the commitments set forth in this Privacy Statement. 

(xiv) Reporting to Credit Bureaus. We may share your information with credit bureaus, consumer reporting agencies, and card associations. Late payments, missed payments, or other defaults on your account may be reflected in your credit report and consumer report. We may also share your information with other companies, lawyers, credit bureaus, agents, government agencies, and card associations in connection with issues related to fraud, credit, or debt collection.

(xv) Sale of Our Business. If we sell, merge, or transfer any part of our business, we may be required to share your information. If so, you will be asked if you’d like to stop receiving promotional information following any change of control.

(xvi) With your Consent. Other than as set out above, we will provide you with notice and the opportunity to choose when your Personal Information may be shared with other third parties.

3 WHAT CHOICES DO I HAVE ABOUT MANAGING MY PRIVACY?

You can always opt not to disclose information to us, but keep in mind some information may be needed to register with us or to take advantage of some of our features.

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

• Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.

• We may partner with third-party ad networks to either display advertising on our Website or to manage our advertising on other sites. Our ad network partner uses cookies and Web beacons to collect non-personal information about your activities on this and other Websites to provide you targeted advertising based upon your interests. If you wish to not have this information used for the purpose of serving you targeted ads, you may opt-out by clicking here: http://optout.networkadvertising.org/ or here: http://www.youronlinechoices.com . Please note this does not opt you out of being served advertising. You will continue to receive generic ads. Opting out will prevent us from identifying you as a user to whom we have previously delivered certain advertising. Additionally, after you exercise choice, we may continue to collect data for analytics, research, reporting and other similar purposes. If you delete your cookies or otherwise reset your identifier you may need to make your choices again.

If you have privacy concerns regarding access to or the correction of your Personal Information, please contact us at: hello@firelabinc.com .

4 Public Information and Third Party Websites

(a) Blog. Any information you include in a comment on our blog may be read, collected, and used by anyone. If your Personal Information appears on our blogs and you want it removed, contact us. If we are unable to remove your information, we will tell you why.

(b) Social media platforms and widgets. Our Websites may include social media features, such as the Facebook Like button. These features may collect information about your IP address and which page you are visiting on our Website, and they may set a cookie to make sure the feature functions properly. Social media features and widgets are either hosted by a third party or hosted directly on our Website. We might also maintain presences on social media platforms including Facebook, Twitter, and Instagram. Any information, communications, or materials you submit to us via a social media platform is done at your own risk without any expectation of privacy. We cannot control the actions of other users of these platforms or the actions of the platforms themselves. Your interactions with those features and platforms are governed by the privacy policies of the companies that provide them and we encourage you to read them.

(c) Links to third-party websites. Our Websites may include links to other websites, whose privacy practices may be different from FireLab . If you submit Personal Information to any of those sites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any Website you visit.

(d) Cookies and Similar Tracking Technologies. We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). The information we collect automatically is statistical data and does not include personal information, but we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:

• Estimate our audience size and usage patterns.
• Store information about your preferences, allowing us to customize our Website according to your individual interests.

• Speed up your searches.

• Recognize you when you return to our Website.

The technologies we use for this automatic data collection may include:

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.

• Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies.

• Web Beacons. Pages on our Website may contain small electronic files known as web beacons (also referred to as clear gifs. pixel tags and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an e-mail and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

(e) Third-party Use of Cookies and Other Tracking Technologies.

Some content or applications, including advertisements, on the Website are served by third-parties, including advertisers, ad networks and servers, Content providers and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking Technologies to collect information about you when you use our website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with internet-based (behavioral) advertising or other targeted content.

We do not control these third parties’ tracking Technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

(f) Do Not Track Disclosure

Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services (including behavioral advertising services) that you do not wish such operators to track certain of your online activities over time and across different websites. Our Services do not support Do Not Track requests at this time. 

Security of Your Information

The security of your Personal Information is extremely important to FireLab . We use physical, electronic, and administrative safeguards that are designed to protect your Personal Information from loss, misuse and unauthorized access, disclosure, alteration and destruction.

We provide reasonable and appropriate security measures in connection with securing Personal Information we collect. For example, we:

• Constantly work to update our security practices to implement accepted best methods to protect your Personal Information, and review our security procedures carefully.

• Comply with applicable laws and security standards.

• Securely transmit your sensitive Personal Information.

• Train our staff and require them to safeguard your data.

• We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration and disclosure

• The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

• Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the website.

6. Notice of Breach of Security

If a security breach causes an unauthorized intrusion into our system that materially affects you, then FireLab will notify you as soon as possible and later report the action we took in response.

7. Safeguarding Your Information

We take reasonable and appropriate measures to protect Personal Information from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the risks involved in the processing and the nature of the Personal Information.

FireLab accounts require a username and password to log in. You must keep your username and password secure, and never disclose it to a third party. Account passwords are encrypted, which means we cannot see your passwords. We cannot resend forgotten passwords either. We will only reset them.

8 Data Retention and Your Access Rights

 a) Data Retention.

In accordance with and as permitted by applicable laws and regulations, we will retain your information as long as necessary to provide our Services to you, to maintain your account for as long as your account is active, or as otherwise needed to operate our business. When you close your account, we may continue to communicate with you about our Services, give you important business updates that may affect you, and let you know about products and services that may interest you, unless you have opted out of receiving marketing communications. We may also continue to use some of your information for business purposes and to improve our offerings or in some cases to develop new ones. We will retain and use your information as required by applicable regulations and FireLab ’s records and information management policies to comply with our legal and reporting obligations, resolve disputes, enforce our agreements, complete any outstanding transactions and for the detection and prevention of fraud.

b) Accessing and Correcting Your Information

You may send us an e-mail at hello@firelabinc.com to request access to, correct or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

If you delete your User Contributions from the Website, copies of your User Contributions may remain viewable in cached and archived pages, or might have been copied or stored by other Website users. Proper access and use of information provided on the Website, including User Contributions, is governed by our terms of use.

9. California Consumer Privacy Act – Information for California Consumers

California Consumer Privacy Act

We collect certain categories of personal information when you visit our site, and we use that information for business and commercial purposes. Please refer to the California Consumer Privacy Act tab below to view the categories and purposes for which we may collect personal information  

If you wish to have FireLab not sell your personal information to a third party, please email us at: hello@firelabinc.com.

You may have other rights in addition to the right to opt out of the sale of personal information to third parties. Please scroll down to view the California Consumer Privacy Act tab for an explanation of those rights. 

California Consumer Privacy Act

Financial institutions collect personal information necessary to offer and provide financial products and services, as well as permitted by federal, state, and local law. The purposes for which FireLab and its affiliates collect personal information include, but are not limited to:

• Operational Purposes. Includes offering and providing financial products and services, processing and fulfilling payments and other transactions, and to service existing or prospective accounts, products and service offerings.
• Security and Fraud Detection. Includes verifying consumer’s identities, detection of security incidents, protecting against malicious, deceptive, fraudulent or illegal activity and support prosecution of such activity.
• Marketing and Data Analytics. This includes advertising and marketing initiatives and services, data analytics and quality assurance reviews.
• Internet and Web Interaction. Please see above for a detailed explanation on the data collected when you interact with one of our targeted ads or view any of our electronic communications.
• Legal and Regulatory Obligations. Includes collection, disclosure, and storage of data necessary to comply with statutory or regulatory requirements.
• Employment Purposes. Includes collection, disclosure, and storage of personal information necessary for job application and recruitment processes, employment, termination, and benefits related activities.
• Other notified purposes. For any other purposes disclosed to you at the time we collect your information or pursuant to your conse

The categories of personal information that FireLab may collect include:

• Personally Identifiable Information. This includes, but is not limited to, personal identifiers such as name, alias, address, e-mail address, Internet Protocol address and other online identifiers, and other similar identifiers.
• Commercial Information. Includes records of real or personal property, products or services purchased, obtained, or considered and other consuming histories and tendencies.
•  Biometric Information. Biometric data that can be used to establish identity; includes voice, finger, eye and facial prints or recognition.
• Internet or Other Web or Network Activity. Includes browsing and search history, and interactions with websites, advertisements, and applications.
• Geolocation Data.
• Audio, Electronic, Visual, or Similar Information.
• Professional or Employment Information.
• Education Information.
• Insights that we use to build a profile about you; includes profiles, preferences, and behaviors drawn from collection and analytics of any of the other categories of personal information collected.

The business or commercial purpose for which FireLab may disclose your personal information, include but are not limited to:

• For all of the stated purposes above for which FireLab may collect personal information.
• Auditing Purposes. Related to our interaction with you and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with those specifications and other standards.
• Debugging/Repair Activity. Debugging to identify and repair errors that impair, or may impair, existing system and application functionality
• Short-term transient use for our purposes.
• For services performed on our behalf by a service provider, or performing services on behalf of a business for which FireLab is a service provider. Includes, but is not limited to, maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, advertising, marketing, or analytic services, or providing such similar services on behalf of a business or service provider.

FireLab has not sold personal information in the preceding 12 months. FireLab may choose to sell the above categories of personal information for any of the business or commercial purposes listed above in the future. If you would like to opt out of the sale of your personal information in the event FireLab does sell personal information in the future, you can submit an opt-out request by sending an email to: hello@firelabinc.com. Personal information does not include publicly available information made available from federal, state or local records.

Your CCPA Rights

The California Consumer Privacy Act (CCPA) provides California residents rights regarding the collection and use of their personal information, subject to certain exceptions. An authorized party may submit requests on your behalf. The authorized party must provide a valid power of attorney, or proof of registration with the California Secretary of State as an authorized agent on your behalf.

Generally, California residents have the following rights: 

• To request a disclosure of the personal information that has been collected; the categories of sources from which the information was collected; the business or commercial purpose for collecting or selling the personal information; the categories of third parties with which the personal information may be shared; and access to the specific personal information in a portable format.
• To request that a business delete any personal information about the consumer, subject to certain exceptions.
• To opt out of the sale of personal information to third parties at any time please send us an email at: hello@firelabinc.com
• To not be denied a product or service, charged a different price or rate, or denied a discount or other benefit because the consumer exercised any of his/her rights under the CCPA. 

Who does CCPA apply to?

CCPA applies to California residents only. For purposes of CCPA, a California resident is a person who currently lives in California, or is domiciled in California but is outside of the state for a temporary or transitory purpose. The rights described above do not apply to residents of other U.S. states or persons who reside outside of the United States. 

There are certain activities, information, and circumstances involving the collection, use, processing, sale, or disclosure of personal information that are exempt or excluded from CCPA. CCPA exemptions and exclusions include, but are not limited to:

  Personal information collected or sold if every aspect of the commercial transaction takes place wholly outside of California.

  Deidentified or aggregate consumer information.

  GLBA:The CCPA does not apply to personal information collected, processed, sold or disclosed pursuant to Gramm-Leach-Bliley Act and its implementing regulations (GLBA). GLBA is the federal law that regulates the collection, disclosure, and safeguarding of individuals’ nonpublic personal information who obtain financial products or services primarily for personal, family, or household purposes from a financial institution. For example, if you are a California resident and you have a personal financial product with us, such as a personal credit card, the CCPA rights do not apply to the personal information associated with that account. There are other types of personal information that are not covered by the rights and limitations in the CCPA.  

Fair Credit Reporting Act: CCPA does not apply to any activity involving the collection, maintenance, disclosure, sale, communication, or use of any personal information bearing on an individual’s credit worthiness, credit standing, credit capacity, character, general reputation, personal characteristics, or mode of living by a consumer reporting agency, user or furnisher of consumer reports as defined under the Fair Credit Reporting Act.  

Business-to-Business Relationships: Until January 1, 2021, CCPA access and deletion requests do not apply to personal information that (1) reflects written or verbal communications or transactions between FireLab and you, and (2) was collected while you were acting in the capacity of an employee, owner, officer, director, or contractor of a company, in the context of FireLab’s business relationship with that company. For these purposes, a company includes sole proprietors, partnerships, non-profits, and government entities.  

Employment Related Activity: Until January 1, 2021, CCPA access, opt out, and deletion requests do not apply to personal information that is (1) collected about you in the course of acting as a former or current job applicant, employee, owner, director, officer, or contractor of FireLab, and (2) used solely in the context of that role. This exemption also applies to personal information of others collected in the course of your acting in one of these roles, if it is your emergency contact information or necessary to administer your benefits.  

What can I expect if I exercise any of my rights?

Opt Out 

You will not receive a confirmation to a request to opt-out. Consistent with applicable law, we will opt you out of sales at your request.

Access 

You will receive a response to your verified request within 45 days of submission, unless we notify you prior to the 45 days that the delivery date of response will be extended by an additional 45 days. Along with the response to the verified request, you will receive a copy of certain information FireLab has collected on you during the 12 months immediately preceding the date of your verified request. This will include any information provided in your verified consumer request form. FireLab is not obligated to provide a response more than twice in a 12-month period; this period begins upon your submission of the verified consumer request.  

Deletion 

Consistent with applicable law, we will delete your personal information in response to your request.  

Do-Not-Sell. California consumers have the right to opt-out of our sale of their personal information. Opt-out rights can be exercised by emailing us at: hello@firelabinc.com.

Other third-party businesses may collect information when you interact with our digital property, including IP addresses, digital identifiers, information about your web browsing and app usage, and how you interact with our properties and ads in order to provide you with relevant ads across the Internet and for other analytics purposes, and may sell that information to other businesses for advertising and other purposes. By visiting here www.privacyrights.info or optout.privacyrights.info, you can opt out from sales of this type of personal information by businesses that participate in the opt out tool. To make opt-out requests related to mobile apps on your device for businesses participating in the DAA’s CCPA App-based Opt-Out Tool, you can download the appropriate app at www.youradchoices.com/appchoices.

Verifiable Requests for Copy, Deletion, and Right to Know. Subject to certain exceptions, California consumers have the right to make the following requests, at no charge, up to twice every 12 months:

Deletion: the right to request deletion of their personal information that we have collected about you, subject to certain exemptions, and to have such personal information deleted.

Right to Know: the right to request that we disclose certain information about how we have handled your personal information in the prior 12 months, including the:

• categories of personal information collected
• categories of sources of personal information collected
• business and/or commercial purposes for collecting and selling your personal information
• categories of third parties with whom we have disclosed or shared your personal information
• categories of personal information that we have disclosed or shared with a third party for a business purpose
• categories of third parties to whom the consumer’s personal information has been sold
• categories of personal information that we have sold (if any)
• The specific pieces of personal information we collect from you

Submitting Requests. You can submit a deletion or right-to-know request by emailing us at: hello@firelabinc.com; we will respond to verifiable requests received from California consumers as required by law. Account holders may also submit requests in their account by going to the Contact page and using any of our customer support channels. We also ask you for additional information necessary to verify or process your request. We may also carry out checks, including with third party identity verification services, to verify your identity before taking any action with your personal information. We will respond substantively to your verifiable requests within 45 days, unless additional time (up to 45 additional days) is needed, in which case we will let you know.

Incentives and Discrimination. The CCPA prohibits discrimination against California consumers for exercising their rights under the CCPA and imposes requirements on any financial incentives offered to California consumers related to their personal information. Businesses may offer different prices, rates, or quality of goods or services if the difference is reasonably related to the value of the consumer’s data.

10. CAN SPAM Act

The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations.

We collect your email address in order to:

●     Send information, respond to inquiries, and/or other requests or questions.

●     Market to our mailing list or continue to send emails to our clients after the original transaction has occurred

To be in compliance with CANSPAM we agree to the following:

●     NOT use false, or misleading subjects or email addresses

●     Identify the message as an advertisement in some reasonable way

●     Monitor third party email marketing services for compliance, if one is used.

●     Honor opt-out/unsubscribe requests quickly

●     Allow users to unsubscribe by using the link at the bottom of each email

If at any time you would like to unsubscribe from receiving future emails, you can Follow the instructions at the bottom of each email and we will promptly remove you from all correspondence.

11 What if I have questions about this policy?
If you have any questions or concerns regarding our privacy policies, please contact Us at:

hello@firelabinc.com and we will try to resolve your concerns.

12 Special Rules For Children.

Because of federal law, we are not permitted to knowingly collect any personal information from a child under the age of thirteen without the consent of that child’s parent or guardian. The statements in this Privacy Policy about our collection and use of personal information also apply to our treatment of personal information from children under the age of thirteen. Some elements of our Services such as signing up for our Services require the submission of a payment card number along with personal information in connection with a purchase; other elements of our Services require the submission of personal information to access or use the Services. Except in certain cases where limited contact information may be collected and not retained, these elements of our Services are not available to children under the age of thirteen. If a child who we know to be under the age of thirteen and for whom we have not received parental consent attempts to utilize a service on our Services which is not available to children, he/she will not be able to access it and may receive a message which relays that he/she is not eligible for such feature.

13 Dispute Resolution

If you have any complaints regarding our compliance with this policy, you should first contact FireLab. We will investigate and attempt to resolve complaints and disputes regarding use and disclosure of your personal information in accordance with this policy.

14 Additional information for EU residents

The following information is provided for the benefit of FireLab website users resident in the European Union.

Lawful basis for processing. We will only collect, use and share your personal information where we are satisfied that we have an appropriate legal basis to do this. This will be because:

• you have provided consent to us using the personal information, for example you have opted-in to receiving marketing communications from us;

• our use of your personal information is in our legitimate interest as a commercial organization (for example communicating with you to resolve a complaint or query, or tracking your use of the FireLab Site using cookies in order to improve and tailor your browsing experience) – in these cases we will look after your information at all times in a way that is proportionate and respects your privacy rights and you have a right to object to this processing as explained below;

• our use of your personal information is necessary to comply with a relevant legal or regulatory obligation that we have, for example where we are required to disclose data to a government body, law enforcement agency or regulator.

Your EU rights.

In addition to the erasure, access and correction rights referred to in section 12 above, you also have a right to object to direct marketing, and to any use of your personal information which is based on a ‘legitimate interest’ justification.

You also have a right to obtain a copy of personal information safeguards used for transfers outside your jurisdiction, and to lodge a complaint with your local supervisory authority.

To exercise any EU specific right, email us at: hello@firelabinc.com.

International Transfers.

FireLab is based in the United States of America, and you understand that by browsing the FireLab Site your information will be stored on servers in that country, which has different standards of data protection.

In addition, we use service providers located around the world. We will take appropriate steps to ensure that transfers of personal information are in accordance with applicable law to protect your privacy rights and interests. Where we receive requests for information from law enforcement or regulators, we carefully validate these requests before any personal information is disclosed.

15 Corporate Headquarters

If you have any questions about this Privacy Policy please contact us at: FireLab 276 5th Avenue, Ste 704-1720 New York, NY 10001.

Last Updated: March 1, 2021