Privacy Policy

Last Updated: January 16, 2024

Watchtower Security LLC and its affiliates (collectively “Watchtower”, “we”, “us”, “our”) respect the privacy of its online visitors and users of its websites, apps, products, and services, including communication services (collectively “Services”). We recognize the importance of protecting information collected from our users and have adopted this Privacy Policy to inform you about how we gather, use, store, disclose, and otherwise process your information, including personal information (also known as personal data), in conjunction with your access and use of our Services. Please read this Privacy Policy carefully to understand our views and practices regarding your personal information and how we will treat it.

1. Types of Information We Collect and How We Collect It

We collect two types of information – “personal information” and “anonymous information” – which we may use to create a third type of information (“aggregate information”). “Personal Information”, also often referred to as “Personal Data”, means information that identifies (whether directly or indirectly) a particular individual, household, or device, such as the individual’s first and last name, postal address, e-mail address, telephone number, username, images, and/or other information that can be used to distinguish or trace an individual’s identity. “Anonymous Information” means information that does not directly or indirectly identify, and cannot reasonably be used to identify, an individual, household, or device. “Aggregate Information” means information about groups or categories of individuals which does not identify, and cannot reasonably be used, to identify an individual, household, or device. We may share Aggregate and Anonymous Information with other parties without restriction. Information You Provide We collect the information which you provide us which may include:

• Registration or Account Information. Information you provide when you register to use our Services or create an account such as: your first name and last name, country of residence, date of birth, e-mail address, username, and password.

Not all information will be mandatory to create the account or register to use the Services. For example, we do not ask you to provide sensitive information or special category data (such as that regarding your race, ethnicity, religious beliefs or sexual orientation). However, if you opt to provide more information, please note that this may become publicly available depending on its nature and why it was provided.

• Purchase and Transaction Information. When you purchase a Service from us, we will collect certain information which may include identification information, your postal and/or residential address, telephone number, and payment information. If the Services you use allow you to conduct transactions, we may collect and retain some or all of the information related to these transactions, including transaction amount(s), parties involved, time and manner of exchange, and other transaction circumstances, such as payment method and names or emails of external third-party accounts.
• Information You Provide when Using our Services. Please note that our Services may offer chat functions (either one-to-one or within a limited group) or other forms of communication services (such as real time voice communication either one-to-one or within a limited group), forums, community environments (including multiplayer gameplay), or other tools that are either restricted to other account holders or Services users or that do not have a restricted audience and can be accessible by anyone. Any information, content or communications, including personal information, you provide when you use any of these features will be available to the recipients (dependent on the nature of the tool) and may be recorded and otherwise disclosed without limitation as to its use by us or by a third party.

While we always endeavor to protect the privacy of our users and to ensure no harm is caused through our Services, given the nature of the tools, we have no obligation to keep private any information you made available to other users or the public using these functions.

• Marketing Preferences. We like to keep in touch with our users and future users through different communications such as emails. To ensure you find these communications useful, we ask you for your marketing preferences, which may include your personal information.
• Surveys. As part of our Services, we sometimes offer or ask you to take part in surveys. Depending on the nature of the survey, we may ask you, or you may volunteer, to provide certain personal information, such as your name, address, or opinion.
• When you do Business with us. If you are a vendor, service provider, or business partner (or a prospective vendor, service provider or business partner) of us, we may collect information about you and the services you provide, including your or your employees’ business contact information and other information you or your employees provide to us as part of the services you may provide and our agreement with you.
• We collect information you provide when you contact us, for example regarding customer support inquiries or other inquiries related to your account, or to provide us with feedback on the Services.

Information We Collect Automatically When using our Services, in addition to the information you provide to us, there is also some information we may collect automatically that identifies you or the device you are using to access the Service, such as your computer or mobile device. Generally, this information relates to your use of the Services and your preferences, such as the types of Services you view or engage with, the features you use, the actions you take, the people or accounts you interact with, and the time, frequency, and duration of your activities. In addition, we may also collect location information when you use the Services, including geolocation information or your internet protocol (IP) address. Information We Receive from Third Parties We generally do not receive any information from third parties that specifically identifies you. However, we may receive limited information from a business partner or service provider if you became a user of our Services through the use of third-party sites. For example, if you learn of our Services through a joint campaign with a business partner, the business partner may inform us of this connection. Sensitive or Special Category Data We generally do not actively seek any sensitive or special category data from you, but we may be exposed to it pursuant to your use of the Services. For example, if when using our chat functions or other communication services, you choose to discuss your political views, sexual orientation or other sensitive or special category data, this will be collected by us as with any other information in the communications. If you would not like this information to be accessible by us, we encourage you not to disclose it while using the Services or otherwise.

2. Use of Your Information by Watchtower

Watchtower may use your personal information, subject to and pursuant to applicable laws and your choices and controls, for the following purposes:

• To provide you with the Services you request, including to create and manage your account, process payments, and provide you with customized Services and experiences based on your preferences.

• Service Communications. Communicate with you about your account or transactions with us, or other Service-related announcements such as regarding features on our Services and applications or changes to our policies or terms.

• Marketing Communications. Send you offers and promotions for our Services or, as permitted, third-party products and services, via email, text, mobile, or browser push notifications.

• Provide you or serve you with advertising or information based on your activity on our Services and on third-party sites and applications.

• Other Communications. If you submit a question, inquiry, or concern to us, we will use your personal information to respond to you.

• If we conduct a survey, we will need to process certain personal information to do so. This will vary depending on the nature of the survey.

• Improve Our Services. Develop and test our Services and operations to optimize and improve our Services and operations.

• Violations or Illegal Acts. Detect, investigate, and prevent activities on our Services that may violate our policies (including any applicable terms of service or terms of use) or may be illegal or harmful in any way to us, our Services users, our property, or any other third-party.

• Verification and Monitoring. Verify accounts and monitor activities within our Services to promote safety and security of our Services, our users, and our properties.

• Comply with applicable laws and regulations and any lawful requests from regulators, governmental entities, or other authorities.

3. Sharing Your Information With Third parties

We will not share your personal information with any third-party except in limited circumstances and when permitted by applicable law, including:

• When you consent to us to sharing your personal information with another company. Please note that once we share your personal information with another company, the information received by the other company becomes subject to the other company’s privacy policy and practices and such company is responsible for your personal information;

• When companies perform services on our behalf, including those who help us provide the best services to you and others (such as hosting/storage, anti-fraud functions, billing, collections, registration, customer support, e-mail delivery, or other operations). These companies are prohibited from using your personal information for purposes other than those requested by us or required by law;

• With our business partners who we perform joint campaigns with;

• With our business partners who may include partners of our ad network;

• In connection with the sale of any of our Services, assets and/or businesses, or when the ownership or control of all or part of our Services changes;

• To enforce our Terms of Service or other rules or policies, to ensure the safety and security of our users and third parties, to respond to requests from law enforcement, officials, regulatory agencies and other lawful requests or legal processes, or to comply with a legal obligation to which we are subject, or other legal process or in other cases if we believe in good faith that disclosure is required by law; and

• To effectively perform our Services, we may share your personal information with our affiliates.

4. Additional Information for Individuals Located in the U.S.

  CCPA If you are a California resident in accordance with the California Consumer Privacy Act (CCPA), the following information applies to you. Personal Information We May Collect During the past twelve (12) months, we may have collected the following categories of personal information about you:

Categories or Personal Information	Examples
Personal Identifiers	Full name, IP address, device identifier, and Services account name.
Personal Information under CA Code §1798.80(e)	Contact details (name, address, email address, telephone number, any information you may provide to us about yourself).
Characteristics of Protected Classes or Groups Under State or Federal Law	Age, gender, national origin, race, colour, ancestry, national origin, citizenship, religion or creed, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, marital status, age, medical condition, physical or mental disability, genetic information (including familial genetic information), veteran or military status.
Financial Information (as described in CA Code §1798.80)	Services obtained, transaction histories, purchasing or consuming histories.
Biometric Information	N/A
Internet or Network Activity	Internet protocol (IP) address, device ID, and device settings (e.g., language preference, time zone), login information, browser type and version, browser plug-in types and versions, operating system and platform, and information about your visit on our website.
Geolocation Data	Device location, geographic location from which your transaction originates.
Inferences drawn from any of the above categories	We may verify your identity against third-party databases; potential fraudulent activity or behaviour.
Education Information	N/A
Professional and employment information	Business, job title.
Audio, electronic, visual, thermal, olfactory, or similar information	If you utilize our communication services, such as online chat functions or real-time voice communications, we will collect personal information pursuant to such usage.

Why We Collect Personal Information and How We Use It The purposes for which we collect and use your personal information (described in detail above) depends on how you engage with us and our Services. The table below lists the purposes for which we may collect and use your personal information:

Purposes for Collection and Use	Examples
To collect, process, and retain your personal information where required by law.	To fulfill our obligations under federal and state laws.
To provide you with the information, products, and services that you request from us.	To provide Forensic Review services and video footage.
To provide, maintain, personalize, optimize, and improve the Services, including research and analytics regarding use of the Services, or to remember you when you leave and return to the Services.	To provide you with the same preferred settings each time you use our Services.
Provide you with more relevant content in marketing, promotional, or other communications to which you may be subscribed.	To inform you about events and news we think you’ll be interested in.
Detect, investigate, and prevent activities that may violate our policies or may be fraudulent or illegal.	To confirm users’ identities and locations.

Sources of Personal Information We collect or receive your personal information from the following sources:

• From you and your use of our Services.

• Third-party sources, as described above in Privacy Policy.

We may also combine your personal information from the Services with the categories of sources listed above. Disclosure of Personal Information The categories of third parties to whom we disclose personal information about you depend on, among other things, our relationship or interaction with you. During the past twelve (12) months, we have disclosed your personal information for our business purposes described above to the following categories of third parties:

• Service providers that assist us in providing the Services, including in relation to hosting/storage, anti-fraud functions, billing, registration, customer support, e-mail delivery, or other operations;

• Third parties authorized by you;

• Advertising platforms (for further information, see our Cookies Policy below); and

• Analytics and search engine providers.

Your Rights under the CCPA The CCPA grants certain rights to California residents, including but not limited to:

• Right to Access. A California resident has the right to request a report showing the personal information collected, shared, and sold about them in the past twelve (12) months.

• Right to Deletion. A California resident has the right to request we delete any personal information collected about them.

• Right to Opt-Out of Sale of Personal Information. A California resident has the right to opt-out of the sale of their personal information to third parties (see further below).

• Right to Non-Discrimination. A California resident also has the right to not be discriminated against by us if they choose to exercise any of the above rights.

If you wish to exercise any of these rights, please see contact information below. Sale of Personal Information We do not sell personal information. Other U.S. State Privacy Laws and Requirements

• “Shine the Light” and “Eraser” Laws: Residents of the State of California may request a list of all third parties to which we have disclosed certain information during the preceding year for those third parties’ direct marketing purposes. If you are a California resident under the age of 18, and a registered user of the website where this policy is posted, you may request removal of content or information you have publicly posted. Please be aware that such a request does not ensure complete removal from the Internet of the content or information you posted, and there may be circumstances in which the law does not require or allow removal. If you wish to exercise these rights, please contact us as indicated below.

• Do Not Track Signals: We currently do not respond to Do Not Track signals or similar signals. Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked. You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.

• Vermont Residents: We will not share your information with companies outside of Watchtower, except for our everyday business purposes, for marketing our products and services to you, or with your consent. We will not disclose credit information about you within or outside Watchtower except as required or permitted by law and as permitted by the Terms and Conditions of the applicable Contract.

5. Additional Information for Individuals Located in the EU or the UK

In addition to the information provided throughout this Privacy Policy, there are certain other pieces of information we are required by law in the EU and UK to provide you. Controller The controller of your personal information is Watchtower Security LLC of 145 Weldon Parkway, Maryland Heights, Missouri 63043. Your Rights For information on the rights exercisable by EU or UK individuals, and details on how to exercise them, please see section “Your Controls, Rights and Choices”. In addition to those listed below, EU and UK individuals also have the right, at any time, to submit a complaint to a data protection authority.   We would however appreciate the opportunity to resolve your issue before you do this. International Transfers We do not transfer information outside of the United States. However, whenever your personal information is transferred, stored or processed by us, we will take reasonable steps to safeguard the privacy of your personal information in accordance with applicable law. In particular, when transferring personal information from the EU or UK, we will either only transfer your personal information to a country which has been deemed by the European Commission or the UK data protection authority, the Information Commissioner’s Office, to be adequate or we will ensure the following appropriate measures are in place so your personal information is treated by the recipients in a way that is equivalent to, and which respects, the EU and UK laws on data protection and your rights as an EU or UK data subject. These include:

• The European Commission Implementing Decision (EU) 2021/914 of 4 June 2021 on standard contractual clauses for the transfer of personal data to third countries pursuant to the GDPR, as may be amended or replaced from time to time (the “EU Clauses”); and

• Standard data protection clauses specified in regulations made by the Secretary of State under section 17C(b) of the 2018 Data Protection Act and for the time being in force in the United Kingdom (the “UK Clauses”).

Where necessary, we may also further supplement the EU Clauses and/or UK Clauses with additional measures specific to a relevant transfer, such as increased security. If you require further information about either the EU Clauses or the UK Clauses, or the other protective measures in place, please contact us as indicated below. Lawful Basis for Processing We will only collect, use, process, and store your personal information where we have a valid lawful basis. Our lawful bases include:

• With consent;

• Performance of a contract (our processing is necessary for the performance of a contract we have with you or to take specific steps before entering into a contract with you. This may be, for example, a contract to receive Services from us);

• Legal obligation (processing is necessary for us to comply with applicable laws, regulations and regulatory authorities, court orders or law enforcement requests); and

• Legitimate interests (processing is necessary for ours, or a third party’s, legitimate interests. The legitimate interests pursued by us are improving our business or customer relationships, marketing and advertising, resolving disputes, preventing fraud and abuse, analyzing and improving safety and security of our Services, enforcing our Terms and Conditions. You have the right to object to processing based on legitimate interests).

Retention We will only retain your personal information for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. For example, we retain your personal information while each of your accounts is in existence or as needed to provide you with Services. To determine the appropriate retention period for personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

6. Additional Information for Individuals Located Outside the U.S., the EU, or the UK

In certain jurisdictions, we will need your explicit consent to obtain, process and share your personal information. All such processing will be carried out in line with this Privacy Policy. To the extent required, your use of the Services will be deemed your explicit consent to obtain, process and share your personal information. If you do not wish to provide us such consent, you should cease using the Services immediately and contact us using the contact details provided below. If you are located in a country outside of the U.S., the EU or the UK and have any questions about how we process your personal information, or regarding whether you have any rights with regards to your information, please contact us using the contact details provided below.

7. Your Controls, Rights, and Choices

Right to Access and Control your Personal Information In certain circumstances, you may have the right to:

• Correct or Update. You may correct or update your account registration or your personal information or you may also ask us to change or update your information in certain cases, particularly if it is inaccurate;

• You may delete your account or ask us to erase or delete all or some of your personal information (for example, if it is no longer necessary to provide Services to you);

• Object to processing. You may object to the processing of your personal information where we are relying on a legitimate interest (or that 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. You also have the right to object where we are processing your personal information for direct marketing purposes;

• Limit or Restrict use of Personal Information. You may ask us to stop or suspend using all or some your personal information in certain scenarios (for example if we have no legal right to keep using it) or to limit our use of it (for example, if your personal information is inaccurate or unlawfully held);

• Withdraw Consent. You may withdraw consent at any time where we are relying on consent to process your personal data and you may change your choices for subscriptions, newsletters, and alerts (for example, you may choose whether to receive offers and promotions, or other marketing, from us for our products and services, or products and services that we think may be of interest to you);

• Right to Access Your Information. You may request access to the personal information we hold about you; access includes details about your personal information and how it is being processed and a copy of such personal information (commonly known as a “data subject access request”);

• Right to Move Your Personal Information. You may request a copy of your personal information in machine-readable form, and you may have the right to transmit such data to another controller, without hindrance from us.

To exercise one of the above rights, please contact us at the postal address below or by emailing privacy@watchtower-security.com. Watchtower Security LLC Attention: Privacy 145 Weldon Parkway Maryland Heights, MO 63043 You can submit a request on your own behalf or on behalf of someone else. If you are acting on someone else’s behalf, we will need to verify your authority to do so. We will consider your request in accordance with applicable laws. We may need to request specific information from you to help us confirm your identity and ensure your right to exercise the right. This is a security measure to ensure that personal information 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 try to respond to all legitimate requests within the timeframe required by applicable law. Occasionally, it may take us longer than this if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. Account Closure You may close your MyPortal account by contacting your Customer Service Relations representative. If you choose to close your MyPortal account, we may retain information for a limited period for the purposes set out in this Privacy Policy, at all times to the extent permitted at law. Advertising Choices   We participate in ad and/or affiliate networks operated by various third-party companies. We and these third-party companies may collect and use certain information about you and your visits to our Services to help serve advertising that is relevant to your interests. If you would like to learn more about these specialized advertising technologies, the Network Advertising Initiative offers useful information about Internet advertising companies, including information about how to opt-out of certain information collection. For more information on how to opt-out of receiving internet-based advertising, please visit:

• Digital Advertising Alliance (US) https://www.aboutads.info/choices/

• Digital Advertising Alliance (Canada) https://youradchoices.ca/en/tools

• Digital Advertising Alliance (EU) https://www.youronlinechoices.com/

• Network Advertising Initiative https://optout.networkadvertising.org/?c=1

On many mobile devices, you can control interest-based advertising through your device’s settings. These options can include resetting your device’s advertising ID or selecting “Limit Ad Tracking” (for iOS devices) or “Opt out of Ads Personalization” (for Android devices) in your device settings. Ad choices settings and options will vary depending on your browser and device settings, and this is not an exhaustive list. Please note that your opt-out choices will only apply to the specific browser or device from which you opt out. We encourage you to explore your device and browser settings to better understand your choices. Push Notifications When you use any of our Services that send push notifications or offers to your mobile device, you can change your preferences at any time through the settings on your mobile device. Precise Location You can withdraw consent for our collection, use, and transfer of precise location information by adjusting the location settings on your device.

8. Security

  We implement technical, physical, and organizational security safeguards designed to protect your personal information from loss, misuse, and unauthorized access and disclosure. In addition, we limit access to your personal information to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal information on our instructions, and they are subject to a duty of confidentiality. We regularly monitor our systems for possible vulnerabilities and attacks. However, given the nature of electronic communications and information processing technologies, we cannot guarantee the security or safety of any information that is sent to us, transmitted through the Internet, or stored on our systems. There is no guarantee that information may not be accessed, disclosed, altered, or destroyed by breach by others of any of our physical, technical, or organizational safeguards.

9. Third-Party Links

Our Services may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Services, we encourage you to read the privacy policy of every website you visit.

10. Changes to this Privacy Policy

We keep our Privacy Policy and practices under review and this Policy was last updated on the date given above. From time to time, we may change this Privacy Policy to accommodate new technologies, industry practices, regulatory requirements, or for other purposes. Any changes to this Policy will be posted online and we will provide notice to you through MyPortal if these changes are material and, where required by applicable law, we will obtain your consent. If you object to any changes, you may close your account.

11. Cookies, Web Beacons, and Other Technologies

Watchtower uses cookies, web beacons, and other similar technologies on our website to, among other things, fulfill user requests (such as enable users to login to our website), provide enhanced functionality for our users (such as user accounts and saved preferences), and enhance web content (so that web content and design are relevant to you and your interests). If you continue to use this site, you agree that we can place these types of cookies on your device. Watchtower also uses cookies, web beacons, and other similar technologies from third-party partners, such as Google, for product improvement, measurement analytics, targeted advertisements, marketing pruposes, and other services. This takes place when you visit our website and when you download or install a Watchtower app. These cookies, web beacons, and other similar technologies allow us to display our promotional materials to you on other sites you visit across the internet. Our third-party partners may also use these technologies to identify your browsing interests over time and across different websites to deliver targeted advertisements and other content that has been customized for you. Watchtower may also share information about your behavior on its website or app with third parties (including operators of third-party websites) in order to show you targeted advertisements and other content that has been customized for you. We also use the cookies, web beacons, and other similar technologies, including from third-party partners, to determine which advertisements our users have seen, how many times users have seen a particular advertisement, and on which sites a particular advertisement appeared. For further information regarding the privacy practices of our advertisement provider, please visit https://policies.google.com/privacy. Users may opt out of Google’s use of cookies by visiting the Google advertising opt-out page at https://adssettings.google.com/authenticated or installing the Google Analytics Opt-Out Browser Add-On at https://tools.google.com/dlpage/gaoptout/.

12. Comments and Questions

If you have a comment or question about this Privacy Policy or our privacy practices, please send an e-mail to privacy@watchtower-security.com or write to us at:

Watchtower Security LLC
Attention: Privacy
145 Weldon Parkway
Maryland Heights, MO 63043