Privacy Policy

Our Privacy Commitment

Our mission is to provide excellent products and services to all customers, small to large, all over the world. Metron Adaptive will endeavor to make sure that your information is kept confidential and secure as detailed in this Privacy Policy as well as our Terms of Service.

Privacy Policy Overview

To make our Privacy Policy clear and simple, we provide a summary below, followed by sections with more detail. For questions or concerns, contact us at privacy@metronadaptive.com.

• Types of information we collect and how we use personal data
• Steps we take to ensure your personal data are handled appropriately
• Safeguards and measures we use to protect your personal data
• Rights you have to your personal data and how you can manage your personal data that we handle

In summary:

• Use of Cookies: Currently we do not use cookies. In the future, Metron Adaptive, may use cookies to help us run our website and apps, evaluate site technical performance and working conditions, manage communications with you, and provide our services.
• We handle personal data: If we do handle your personal data (such as name, email address, IP address, locational data, payment details, site or application usage data, Metron Adaptive Services), we ensure such processing is in accordance with the General Data Protection Regulation (GDPR), and other applicable regulations.
• We use different methods of obtaining personal data from and about you, including:
• Direct interactions (e.g., you fill in forms or contact us)
• Usage and marketing interactions (e.g., you use our site or apps)
• Publicly available sources
• Processing means doing anything with your personal data (collecting, manipulating, storing, disclosing, erasing, etc.).
• We may use anonymized info about your website/service use to improve our services.
• If you subscribe to our mailing list or contact us, your contact information will only be used to communicate with you for those purposes.
• Some of our services are automated processes without human involvement. These decisions do not have legal or similarly significant effects.

More about personal data handling below.

About Metron Adaptive's Privacy Program

We may transfer personal data to other companies (third parties) such as data hosting providers, cloud service applications, and payment processors. If we do, sharing is lawful (with your consent, by contract, or based on legitimate interests). Third parties are prohibited from using your personal data for their own purposes outside of our agreement. We use data processing agreements in our contracts and maintain a supplier risk and compliance program. We may transfer personal data internationally to countries inside and outside the European Economic Area (EEA), using recognized safeguards.

• You have rights: You can make requests regarding your personal data, including access, correction, restriction, erasure, or data portability.
• You can file a complaint with a supervisory authority if you feel we have not handled your data properly.
• Our Privacy contact is privacy@metronadaptive.com.

Detailed Privacy Policy

1. Introduction: In this privacy policy, "Metron Adaptive", "we", "us" and "our" refer to Metron Adaptive, a Delaware registered company.
2. Our Commitment: We are committed to safeguarding the privacy and personal data of our website visitors, clients, partners, associates, and others. Our privacy program is governed, in part, by the EU General Data Protection Regulation (GDPR), the Data Protection Act of 2018, and other regulations.
3. Personal Data Definition: Personal data means any information that relates to a living, identifiable person, including but not limited to names, addresses, emails, internet identifiers, phone numbers, and other information relating to that person.
4. Processing Definition: Process or Processing means the activities we perform on personal data, such as collection, transmitting, computing, storage, and disposal.
5. When This Policy Applies: This policy applies when we are a data controller, joint controller, or processor as defined in the GDPR.
6. Our Principles for Personal Data:
• We process personal data lawfully and transparently.
• We collect and process only what is necessary.
• Optional data (e.g., marketing) is processed only with your consent.
• We are clear about why and how we process personal data.
• We ensure data accuracy and provide means to correct inaccuracies.
• We safeguard personal data for integrity and confidentiality.

How We Use Your Personal Data

Here we describe:

• the general categories of personal data that we may process.
• the source and specific categories of that data, in case we did not obtain it directly from you.
• the purposes for which we may process personal data; and
• the legal reasons (known as lawful bases) for processing personal data.

We collect, store, process and transfer different personal data types. We group personal data, collection source, purpose and lawful bases into the following categories:

Direct Interactions:

We process personal data you provide directly to us through our website, apps and services. This could happen when you:

• correspond with us or make an enquiry such as a request for information about our services, knowledge portal guidance, professional opportunities, sponsored programs or contribution to a regulatory agency's call for comments.
• sign up for our free or paid services, under a contract.
• verify your identity when accessing our services.
• support our public outreach and education by contributing to our blogs or social media postings.
• applynfor a job or to volunteer as an intern
• visit any of our premises which may employ CCTV surveillance (images on film) for security and safety purposes.
• opt into communications and/or marketing services by providing consent (which can be withdrawn).
• participate in any of our events, webinars or other projects, including opting in, by providing consent (which can be withdrawn), to be filmed, photographed, or recorded during an event or project; or
• contact us or become involved with us in any other way not listed above.

We process this information to provide the service or information you have requested. Our lawful basis for processing is legitimate interests (unless it is consent or contract as noted above).

Usage Data:

We may process data about your use of our website, apps and services. The usage data may include:

• IP address.
• geographical location.
• browser type and version.
• operating system.
• referral source.
• length of visit.
• page views.
• website navigation paths; or
• information about the timing, frequency and pattern of your service use.

The source of the anonymized usage data is our website or services. We process this information for service performance monitoring and security purposes, and to improve our website and services. Our lawful basis for processing is legitimate interests.

Account and Profile Data:

When you provide personal data, such as details to purchase a service, sign up for a free or trial service, or apply to open jobs or inquire about investment in our company, we may process personal data:

• name.
• address.
• telephone number.
• email address.
• payment details.
• social media account ID.
• electronic communications ID.
• employment or candidate information; or
• prospective investor self-certification information.

We use account and profile data to:

• operate our website, apps and services.
• provide our services, products or information you have requested.
• ensure the security of our website, apps and services.
• maintain back-ups or restore instances of your data.
• process your job applications.
• respond to your inquiries and complaints; or
• generally, communicate with you about your account and profile.

Depending upon the nature of the processing, the lawful basis for this processing is either our legitimate interests or contract performance.

Special Category Data:

We may request or receive, with your explicit consent or by contract or legal requirement, then process personal data designated as special category data under the GDPR, relating to your:

• biometrics
• union affiliation; or
• health information.

Special category biometrics data may be processed for identification (such as use of fingerprint for systems access), if you supply it directly to us as an optional means to govern access to our apps and services.

Before collecting and processing any special category data about you, we will make it clear what information we are collecting, why we need it, whether it requires explicit consent or is part of by contract or legal requirement. We take additional measures to safeguard special category data, such as encryption and technical access controls. The lawful basis for this processing is either consent or contract performance.

Children's Data:

We do not actively collect or process information from or about children (under 16s). If a special situation arises where we need to handle children's data, we will always ask for consent from a parent or guardian prior to collection about children under the age of majority or age described in regulations in a jurisdiction where data is being sought. Our services and products are not knowingly directed at, nor do we knowingly collect any information from people under the age of thirteen (13). If you are under 13 years old, please do not use this website or its applications. If you learn that your child has provided us with personal data without your consent, please contact us at privacy@metronadaptive.com.

Additionally, we may process your personal data identified in this policy where necessary for:

• the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The lawful basis for this processing is legitimate interests (protection and assertion of our legal rights, your legal rights or the legal rights of others); or
• the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The lawful basis for this processing is legitimate interests (proper protection of our business against risks).
• compliance with a legal obligation to which we are subject, or to protect your vital interests or the vital interests of another natural person.

How We Share Your Personal Data

We do not sell your personal data. We may share details with trusted, contracted service providers authorized to process on our behalf.

• Service companies may handle emails, text messages, payments, mail, and trend analysis.
• Third-party processors act on our instruction and contract.
• Payment services providers only receive what is necessary for transactions.
• We do not disclose your data for third-party marketing without your explicit opt-in.
• Disclosure may occur for compliance with legal obligations or the establishment/defense of legal claims.

Data Sharing and Third Parties

Metron Adaptive is a Delaware registered company operating and processing data in the USA and other countries, with third-party processors:

Company	Processing Location
Microsoft	United States
Cloudflare	Global

International transfers comply with the GDPR, including technical and organizational safeguards.

• Canada, Japan, Switzerland, and USA are recognized by the European Commission as offering adequate protection.
• Other countries: Standard contractual clauses are used.

For more information, contact privacy@metronadaptive.com.

Retaining, Updating and Deleting Your Personal Data

• Client data: duration of contract
• Financial data: up to seven years for reporting
• Marketing data: one year, unless renewed
• Employee/contractor data: as long as employed, then as per local law
• Candidate data: up to one year after search
• Some retention periods cannot be specified in advance.
• Data may be retained for legal compliance or vital interests.
• We may use public or professional sources to keep records up to date.
• Data is deleted at end of retention period or sooner, except where legal obligations prevent.

Your Rights

• Access your personal data
• Rectification correct inaccurate data
• Erasure have your data deleted (with some exceptions)
• Restrict processing in certain circumstances
• Object to processing for legitimate interests or marketing
• Data portability receive your data in a machine-readable format
• Complain to a supervisory authority

The first copy of your data is free; additional copies may incur a reasonable fee.

Rights may be withheld to the extent permitted by law or if requests are vexatious/excessive.

Contact us at privacy@metronadaptive.com to exercise your rights.

How We Use Cookies

What is a cookie? Cookies are small text files used to recognize your device and preferences. See allaboutcookies.org and youronlinechoices.eu.

Currently, we do not use cookies on our site or services but may in the future.

Managing cookies:

• Chrome instructions
• Firefox instructions
• Opera instructions
• Internet Explorer instructions
• Safari instructions
• Edge instructions

Blocking cookies may affect some features or access to services.

Changes to This Policy

1. We may update this policy from time to time by publishing a new version on our website.
2. We may notify you of changes via email or through our website, apps, or services.