Overview

This document sets forth NGA 911 LLC's ("we" or "us") privacy notice. It describes the types of personal information that we receive in the course of doing business, how we use that information, third parties with whom we may share the information, and your choices in modifying or removing the information.

We value the trust you place in NGA 911 LLC services and our privacy practices. We are committed to providing our customers and users with a secure environment, unparalleled customer service, and state of the art technologies to safeguard your personal information. NGA 911 LLC will adhere to the policies and practices described in this privacy notice, as well as any applicable customer agreement as it pertains to personal information.

What Information does NGA 911 LLC Collect?

Our privacy practices will vary depending on the circumstances under which we collected your personal information. NGA 911 LLC collects personal information in the following circumstances:

• Personal information collected from customers.
• Personal information collected through our Websites and surveys.
• Personal information collected through our mobile applications.

Information Collected from Customers

NGA 911 LLC provides a critical event management platform that empowers our customers to better manage both emergency and non-emergency situations. Part of this capability involves NGA 911 LLC's software enabling our customers to broadcast notifications to targeted individuals. To broadcast a notification, the customer will have uploaded into the NGA 911 LLC system the individual's name and basic contact information (such as mobile number, work telephone, and e-mail address), and then the customer will use the NGA 911 LLC system to send out the notification.

NGA 911 LLC has no direct relationship with the individuals whose personal information it processes from customers. Our customers are typically the individual's employer, or a local or state government agency with jurisdiction over the area where the individual resides.

Information collected through our Websites

When you visit and use our Websites, we may collect, retain and use the following kinds of information:

• Information you provide to us, which may include:
  • Information that you provide by filling in forms on our website when registering for white papers, marketing, events or webinars, requesting further information about our solutions, when you report a problem with our Websites or when you otherwise communicate with us. This includes personal information such as name, email address and phone number. The personal information that you are asked to provide, and the reasons why you are asked to provide it, will be made clear to you at the point we ask you to provide your personal information. You are not required to provide your personal information but if you choose not to, then we may not be able to provide you with the relevant service, information or communication.
  • Records and copies of your correspondence if you contact us.
  • Your responses to surveys that we might ask you to complete for research purposes.
  • Your search queries on the Website
  • Information you provide through CPaaS.
  • Information you provide when signing up for NGA 911 LLC services, such as your cell phone number.
• Information we may collect from you:
  • Information about your business, such as organization and industry.
  • Demographic information, such as geographic location.
  • Information collected through automatic data collection technologies.

As is true of most websites, we gather certain information automatically and store it in log files. This information includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data. We may link this data with other information we collect about you. We do this to improve our offered services, marketing, analytics, and site functionality. However, we anonymize the data we link so that you won't be identified.

Please note that NGA 911 LLC 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.

Some of our pages utilize framing techniques to serve content to and from our partners while preserving the look and feel of our Websites. Please be aware that you may be providing your personal information to these third parties, not to us, so the privacy practices of those third parties govern the information they receive from you.

Our website also includes social media features, such as LinkedIn, Facebook and Twitter buttons and widgets, and the "Share This" button. These features may collect your IP address, which page you are visiting on our site, 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 notice of the company providing the features.

Surveys

We display personal testimonials of satisfied customers on our site in addition to other endorsements. With your consent we may post your testimonial on a Website along with your name. If you wish to update or delete your testimonial, you can contact us at support@nga911.com.

Information Collected through our Mobile Applications

NGA 911 LLC offers a number of mobile applications. Please note that when you download and use an NGA 911 LLC mobile app, you do so voluntarily. Our mobile apps may collect the following types of information:

• Usage Details. Certain details of your access to and use of the mobile app, including traffic data, logs and other communication data, and the resources that you access and use on or through the mobile app. We use mobile analytics software to allow us to better understand the functionality of our mobile app on your phone. This software may record information such as: how often you use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from. We do not link the information we store within the analytics software to any personal information you submit within the mobile app.
• Device Information. We may collect information about your mobile device and Internet connection, including the device's unique device identifier, IP address, operating system, browser type, mobile network information and the device's telephone number.
• Digital Media. Only after you have downloaded a mobile app and only after you have affirmatively consented, a mobile app may access metadata as well as content that you choose to upload from your device. This content may include photographs that you upload, contact information provided when you ask the mobile app to access your address book to send invites, or the number of residents in your neighbourhood using the mobile app (but not their identity or contact information).
• Location Information. We may ask you for your location when you use our mobile app, or when you opt-in to NGA 911 LLC services in connection with sending or receiving messages from our customers. You will have the option to include your location which will only be used to assist our customers with whom you are affiliated via that location (for example, a local fire department) to provide better communication in the event of an emergency or other incident. You may opt-out of location based services at any time by editing the setting at the device level.

We use this information to monitor, analyse and improve our mobile apps.

How Does NGA 911 LLC Use Information We Collect?

• Customer Data. We use customer data only as necessary to deliver the NGA 911 LLC services that a customer has agreed to use, which include, but are not limited to, the provision of our notification services, customer support, and notification of new features and services. We may also use customer data to contact you regarding administrative notices, to resolve disputes, troubleshoot problems and enforce the customer services agreement. NGA 911 LLC will retain personal information (including geo-location data) provided by our customers for as long as is needed to provide services to our customers and in accordance with the customer's services agreement. In addition to this privacy notice, usage of customer data is subject to and covered by the applicable customer services agreement.
• CPaaS. The CPaaS service will allow you to collaborate with your team during an incident or situation. In connection with an SMS, NGA 911 LLC will store your number according to your authenticated profile to allow for two-way communication. NGA 911 LLC uses industry standard encryption and other safeguards to provide security and anonymity of the information being submitted. Although such encryption and safeguards are utilized, due to the nature of Internet and mobile SMS delivery networks, we cannot and do not guarantee 100% security, or timely delivery or receipt of the information you submit. Neither NGA 911 LLC nor any third party makes any representation as to if, how, or when any information you submit may be acted upon by law enforcement agencies or public safety officials.
• Disclosure of Your Information for Third-Party Advertising. We do not share your personal information with unaffiliated or non-agent third parties for promotional purposes, except for customers sending business or promotional notifications to which you have specifically consented, including through opt-in.

In general, we will use any of the personal information we collect from you only for the purposes described in this privacy notice or for purposes that we explain to you at the time we ask to collect such information. However, we may also use your personal information for other purposes that are not incompatible with the purposes we have disclosed to you (such as statistical purposes on an anonymized basis) if and where this is permitted by applicable data protection laws.

Other Websites Linked to the NGA 911 LLC Websites?

• Except as otherwise discussed in this privacy notice, this document only addresses the use and disclosure of information we collect from you. We are not responsible for the practices employed by websites linked to, or from, NGA 911 LLC websites, nor the information or content contained therein. Other sites accessible through our websites have their own privacy policies and data collection, use and disclosure practices. Please consult each website's privacy notice rules before proceeding.

Third-Parties with Whom We May Share Your Information

• It may be necessary to share our customer data with third parties in order for NGA 911 LLC to provide the services requested by our customers. For example, we will need to transmit an individual's cell-phone number to a telecommunications provider in order to deliver a customer-initiated notification designated for that individual and others. Under such circumstances we will only transmit the information needed to fulfil the obligations described in our customer's service contract. These third parties are also bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them. Transfers to these third parties are covered by the provisions in this privacy notice regarding notice and choice, as well as applicable contractual agreements.We may disclose personal information about you as described in this privacy notice, including:
  • To the extent required to enable you to receive notifications from any group, institution or entity of which you are a member, such as your employer, local or state government agency with jurisdiction over the area where you reside, or educational institution at which you are a student.
  • To our third party service providers on a need to know basis to assist us e.g. operating our website, conducting our business, or providing services to you.
  • To our subsidiaries and affiliates to provide support to you in connection with our websites or NGA 911 LLC services.
  • To fulfil the purpose for which you provide it. For example, if you give us an e-mail address to use the "e-mail a friend" feature of our website, we will transmit the contents of that e-mail and your e-mail address to the recipients. Or if you opt-in to text-based notifications, we will use your mobile number to send those notifications to you.
  • As required by law, such as to comply with any court order, subpoena, or similar legal process, including responding to any government or regulatory request, as well as lawfully binding requests by public authorities to meet law enforcement requirements.
  • To enforce or apply our Acceptable Use Policy or our customer services agreement (as applicable) and other agreements.
  • If we believe in good faith that disclosure is necessary or appropriate to protect the rights, property, or safety of NGA 911 LLC, our customers or others, or to investigate fraud. However, all such disclosure shall comply with any applicable data protection law.
  • In the context of a sale, assignment or other transfer of all or part of the business.
  • To any other person with your consent.

  We do not sell, trade, or rent customer data or a user's personal information to others.

Legal Basis for Processing your Personal Information

• (EEA Individuals Only)

  If you are a visitor from the European Economic Area (EEA), our legal basis for processing your personal information will depend on the personal information concerned and the specific context in which we collect it.

  However, we will normally collect personal information from you only where we have your consent to do so, where we need the personal information to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to process personal information about you to protect your vital interests or those of another person.

  If we collect and use your personal information in reliance on our legitimate interests (or those of any third party), this interest will normally be to operate our website and communicate with you as necessary to provide our products and services to you and for our legitimate commercial interest. These legitimate interests include, for example, responding to your queries, improving our platform, undertaking marketing, or detecting or preventing illegal activities. We may have other legitimate interests and if appropriate we will make clear to you at the relevant time what those legitimate interests are.

  If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided under the "Contacting Us" heading below.

Cookies

• We use cookies and similar tracking technology (collectively, "Cookies") to collect and use personal information about you. For further information about the types of Cookies we use, why we use Cookies, and how you can control Cookies, please see our Cookie Notice.

Data Transfers and Privacy Shield

• Your personal information may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection laws that are different from the laws of your country (and, in some cases, may not be as protective).We have taken appropriate safeguards to require that your personal information will remain protected in accordance with this privacy notice. NGA 911 LLC complies with the EU-U.S. Privacy Shield Framework and the Swiss – U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union (EU), United Kingdom (UK) and Switzerland to the United States, respectively. NGA 911 LLC has certified to the Department of Commerce that it adheres to the Privacy Shield Principles, and commits to comply with the Privacy Shield Principles as they apply to the personal data of EU, UK and Swiss residents. If there is any conflict between the terms in this privacy notice and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.

Resolution of Disputes and Complaint Mechanism

• NGA 911 LLC commits to resolve complaints about our collection or use of your personal information in accordance with the Privacy Shield Principles. Individuals in the EU, UK or Switzerland may submit queries related to the processing of personal information under the Privacy Shield framework by contacting us directly at privacy@nga911.com, or by writing to us at: NGA 911 LLC, 8383 Wilshire Boulevard, Suite 800, Beverly Hills, CA 90211, Attn: General Counsel.NGA 911 LLC has further committed to cooperate with the European data protection authorities (the "DPAs") and/or the UK Information Commissioners Office (the "ICO") and/or the Swiss Federal Data Protection and Information Commissioner (the "Commissioner"), as applicable. If we have not been able to successfully resolve your query or complaint and you are based in the EEA, UK or Switzerland, you may raise your query or complaint directly to the DPA, ICO or Commissioner, respectively. The services of the DPAs, ICO and Commissioner are provided at no cost to you. You can find details of the relevant DPA at http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm. NGA 911 LLC will comply with any advice given by the DPAs and/or ICO and/or Commissioner, and take necessary actions to remediate any non-compliance with the Privacy Shield Principles.If your inquiry still has not been satisfactorily resolved, you may have other recourse mechanisms such as invoking binding arbitration by the Privacy Shield Panel.

Enforcement

• NGA 911 LLC privacy practices are subject to the jurisdiction of the United States Federal Trade Commission (FTC), and as such NGA 911 LLC is subject to the investigatory and enforcement powers of the FTC and other applicable authorities in the jurisdictions where we provide services.

Onward Transfer

• If NGA 911 LLC is going to transfer personal data to a third party that is acting as an agent, it will enter into a written agreement with such third party requiring that the third party provide at least the same level of privacy protection as is required by the Privacy Shield Principles. In the context of such onward transfer to third parties of data of EU or Swiss individuals received pursuant to Privacy Shield, NGA 911 LLC is potentially liable if we process such personal information in a manner inconsistent with the Privacy Shield Principles.

Data Security

• We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration and disclosure. The security of your personal information and our customers' information is extremely important to us. When you enter sensitive information and/or geo-location data, we encrypt the transmission of that information using up-to-date security technology (e.g. TLS). 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. We urge you to be careful about giving out information in public areas of the website.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. If you have any questions about security on our website, you may contact us at privacy@nga911.com.

Choices About How We Use and Disclose Your Information

• We strive to provide you with choices regarding your personal information. We have created mechanisms to provide you with the following control over your information:
  • Customer Data. If you are accessing NGA 911 LLC services as an employee, resident or other designee of one of our customers, and you wish to make any changes to your contact information, you will need to do so through that customer. If you would no longer like to receive communications from the customer, please contact the customer that you interact with directly. If the customer requests NGA 911 LLC to remove the data, we will respond to their request promptly, within a reasonable period of time.
  • Promotional Offers from Us. If you do not wish to receive information about our products or services, you can opt-out by clicking on the "unsubscribe" or "opt-out" link in the promotional e-mails we send you. You may also e-mail your request to marketing@nga911.com. If we have sent you a promotional e-mail, you may send us a return e-mail asking to be omitted from future e-mail distributions.
  • Push Notifications. We may occasionally send you push notifications through our mobile apps to send you updates and other service related notifications that may be of importance to you. You may opt-out from receiving these types of communications, at any time, by contacting our support team at privacy@nga911.com.

Rights of Individuals in the EEA

• If you are a resident of the EEA, you also have the right to:
  • Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law.
  • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms.
    • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
    • If you want us to establish the data's accuracy.
    • Where our use of the data is unlawful, but you do not want us to erase it.
    • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
    • You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
  • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.

  If you wish to exercise any of the rights set out above, you can do so at any time by contacting us using the contact details provided under the "Contacting Us" heading below.

  You will not have to pay a fee to access your personal data or to exercise any of the other rights described above, however, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

  We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

  We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. Also, for general users on our website, you can fill out a new form to access, update or request deletion of your information, or email us at marketing@nga911.com.

Changes to Privacy Notice

• We may update this privacy notice to reflect changes to our information practices. We encourage you to periodically review this page for the latest information on our privacy practices.