Privacy Policy

Effective date: April 4, 2018

© COPYRIGHT 2018 FAIRCHILD CONSULTING SERVICES, LLC. ALL RIGHTS RESERVED

Every effort has been made to ensure the accuracy of this document. However, Fairchild Resiliency Systems makes no warranties with respect to this document and disclaims any implied warranties of merchantability and fitness for a particular purpose. Fairchild Resiliency Systems shall not be liable for any error or for incidental or consequential damages in connection with the furnishing, performance, or use of this document or examples herein. The information in this document is subject to change without notice.

TRADEMARKS

Fairchild Resiliency Systems and the Fairchild Resiliency Systems logo are trademarks of Fairchild Consulting Services, LLC in the United States and certain other jurisdictions. Fairchild Resiliency Systems also uses numerous other unregistered trademarks to identify its goods and services worldwide. All other marks used herein are the trademarks of their respective owners and no ownership in such marks is claimed by Fairchild Consulting Services, LLC

1 Purpose of Policy

Fairchild Consulting Services, LLC, a Massachusetts limited liability company, including its subsidiaries and affiliates, d/b/a “Fairchild Resiliency Systems” (“Fairchild Resiliency Systems”, “we” or “us”) respects the privacy of its employees, customers, business partners and visitors to its Website (as defined below).  The Fairchild Resiliency Systems Privacy Policy (the “Policy”) describes the information that we collect, how we obtain the information, and how we may use or disclose that information. This Policy also describes the measures we take to protect the security of the information and how individuals can contact us about our privacy practices and Policy.

2 Scope of Policy

This Policy only covers our privacy practices with respect to the collection, use, and disclosure of information obtained: (i) from Fairchild Resiliency Systems Employees and Job Applicants; (ii) through the Fairchild Resiliency Systems websites at www.FairchildRS.com, www.Fairchildconsult.com, www.Fairchildapp.com,  (collectively, our “Website”); (iii) in connection with the use of applications downloaded to a User’s mobile device (“Mobile Applications”); and (iv) in connection with the use of our hosted software applications (the “Subscription Service”) and related support services (“Support Services”), as well as expert services, including professional services, training and certification (the “Expert Services”) that we provide to Customers. In this Policy, the Subscription Service, Support Services and the Expert Services are collectively referred to as the “Service.”

For the purposes of this Policy,

Customer” means any entity that purchases the Service.

Customer Data” means the electronic data uploaded into the Subscription Service by or for

Customer or its Users.

Visitor” means a visitor of the Website.

User” means an individual authorized by Customer to access and use the Subscription Service.

3 Website

3.1 How we Obtain Information

As further described below, we collect several types of information from and about our Visitors.

Information you provide to us

Information from third parties

Fairchild Resiliency Systems may collect and use information we receive from third parties in connection with your use of the Website.  For instance, Fairchild Resiliency Systems may use a third party for reporting and analytics to measure the effectiveness of our Website and marketing efforts, and to identify areas for improvement.

Information we collect as you navigate through the Website

As you navigate through the Website, we may also collect details about your visits to our Website including, but not limited to, your IP address, usage patterns, traffic data, location data, logs and other communication data and the resources that you access, as well as information about your computer and internet connection, including your operating system and browser type.

Cookies and Other Forms of Automated Collection:

We use “cookies” to help us improve our Website. A cookie is a small file stored on the hard drive of your computer. We may use cookies to obtain information about your general Internet usage and to:

Fairchild Resiliency Systems’ third parties may use JavaScript to collect IP addresses from our Visitors and our hosting provider may also collects server logs. Information gathered through these automated means may be associated with the personal information you previously submitted on our Website.

3.2 How We Use Information Collected

We may use information that we collect about Visitors for the following purposes:

If you ask us to contact you about goods and services that may be of interest to you, we may use your personal information or permit selected third parties to use your personal information to provide you with such services. Visitors may withdraw consent at a later time by clicking on the “unsubscribe” link located in the emails sent by Fairchild Resiliency Systems. For more information, see Communication Preferences and Choices below.

3.3 How we Share Information Collected

We may disclose personal information that you provide to us via this Website to the following third parties:

Area and Switzerland).

We may also disclose your personal information to third parties to:

We do not sell, rent or trade information collected through the Website with third parties for their promotional purposes.

3.4 Public Forms and Blogs

Your User Contributions are posted on and transmitted to other Visitors of the Website at your own risk. Please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other Visitors 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. We are not responsible for circumvention of any privacy settings or security measures contained on the Website. You understand and acknowledge that, even after removal, copies of your User Contributions may remain viewable in cached and archived pages, or might have been copied or stored by other Visitors. Proper access and use of information provided on the Website, including User Contributions, is governed by our Website Terms of Use and known or suspected violations should be reported to our Privacy Officer via e-mail at privacy@FairchildRS.com.

3.5 International Transfer of Data

Fairchild Resiliency Systems may store and process any information collected in connection with the

Website in any country where we have facilities or in which we engage service providers. Fairchild Resiliency Systems’ global headquarters office is located in Andover, MA, USA.  By using our Website,

you consent to the collection, storage, transfer and processing of information outside of your country of residence, including in the United States.

3.6 Communication Preferences and Choices

We provide certain choices regarding the information Visitors provide to us. We have created mechanisms to provide you with the following control over your information when using our Website. If you do not wish to have your e-mail address used for promotional purposes by Fairchild Resiliency Systems, you may withdraw consent at a later time by clicking on the “unsubscribe” link located in the emails sent by Fairchild Resiliency Systems.

Cookies

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. You may refuse to accept cookies by activating the appropriate setting on your browser. You may also set your browser to alert you when cookies are being sent. However, if you do so, please note that some parts of our Website may then be inaccessible or function improperly.

Do Not Track

While Fairchild Resiliency Systems attempts to honor do not track (“DNT”) instructions we receive from a Visitor’s browser, we cannot guarantee that Fairchild Resiliency Systems will always respond to such signals, in part, because of the lack of common industry standard for DNT technology. We continue to monitor developments in DNT technology and stay apprised of DNT industry standards as they evolve.

Choice

You should review this Policy carefully, because if you do not agree with our practices, your ultimate choice is not to use the Website. Remember, by using any part of our Website, you accept and agree to our privacy practices.

3.7 Accessing and Correcting Your Personal Information

You may send us an e-mail at privacy@FairchildRS.com to request access to, correct or delete any personal information that you have provided to us in connection with the Website. We will use reasonable efforts to respond to such requests for correction or updates to personal information.

4 Service

4.1 How We Obtain Information

As described below, we collect several types of information from our Customers and Users, including:

Expert Services or other requests related to our Service.

Cookies:

When providing the Subscription Service, we use cookies to:

Cookies must be enabled in order to use the Subscription Service. A User may however, refuse to accept the “remember me” cookie, which will then require the User to provide their username and password to log into the Subscription Service.

4.2 How We Share Information Collected

We may disclose personal information that Customers and Users provide to our Service, to the following third parties:

Area and Switzerland).

business partners who provide services on behalf of our Customers.

We may also disclose your personal information to third parties to:

Resiliency Systems pursuant to which the Customer purchased access to the Subscription

Service (the “Customer Agreement”).

others.

We do not share, sell, rent or trade information collected through the Service with third parties for their promotional purposes.

4.3 Customer Data

We may use Customer Data to provide the Service, including updating, enhancing, securing and maintaining the Subscription Service and providing Support and Expert Services. Notwithstanding anything else to the contrary in this Policy, we will not use, disclose, review, share, distribute, transfer or reference any Customer Data except as permitted in the Customer Agreement or as required by law.

4.4 Communication Preferences and Choices and Accessing and Correcting Your Personal

Data

Since each Customer is in control of what information, including any personal information, it collects from its Users, how that information is used and disclosed, and how that information can be changed, Users of the Subscription Service must contact the applicable Customer administrator with any inquiries about how the Customer uses and discloses personal information and how to access or correct personal information contained in Customer Data.

To access or correct any personal information Customer has provided as part of the General

Information, the Customer should contact their account representative.

4.5 Mobile Applications

Without limiting the generality of this Policy, in addition to the information collected through the Website and the Service, Fairchild Resiliency Systems may obtain additional information through Mobile Applications that Customer or their Users download to their mobile devices (“Devices”). Mobile Applications provided by Fairchild Resiliency Systems may obtain or collect information from Users’ Devices in connection with the Service and are designed to interoperate with the Subscription Service; for instance, to provide a User with access to information within the Subscription Service or to provide information from a User’s Device to the Subscription Service.

Mobile Applications may access the geographic location of a User’s Device. Mobile Applications may also provide Fairchild Resiliency Systems with information related to Users’ use of the Mobile Applications, including information regarding Users’ Devices and OS identification, login credentials, language and time zone. Mobile Applications may also collect information regarding Users’ interaction with Mobile Applications, which Fairchild Resiliency Systems may use to provide and improve the Mobile Application services.

Information accessed or obtained by the Mobile Application on a User’s Device may be accessible to the Customer and its organization, depending on the intended functionality of the Mobile Application. Customer and its Users may configure Mobile Applications affecting the information collected or accessed on a User’s Device.

In addition to Mobile Applications provided by Fairchild Resiliency Systems, third party Mobile Applications may be made available for download to Users’ Devices. The collection and use of information through third-party Mobile Applications (if any) is governed by the applicable privacy notices of such third parties.

Contractual terms related to a particular Mobile Application may be found in the End User License

Agreement or relevant terms of service for that application.

4.6 Transfer of Personal Data

Fairchild Resiliency Systems 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 Economic Area and Switzerland to the United States. You can view a description of how we comply with the Privacy Shield Principles in our Privacy Shield Policy.  To learn more about the Privacy Shield Framework and the scope of Fairchild Resiliency Systems’ participation, please visit the Department of Commerce’s website, located at: https://www.privacyshield.gov/welcome.

6 General

6.1 Security Statement

Fairchild Resiliency Systems maintains reasonable and appropriate measures to protect the personal information obtained through the Website and in connection with the Service and Mobile Applications from loss, misuse and unauthorized access, disclosure, alteration and destruction.

6.2 Third Party Websites and Applications

The Website may link to websites that are not owned or controlled by Fairchild Resiliency Systems. As such, this Policy does not apply to information collected on any third-party site or by any third-party application that may link to or be accessible from the Website. In addition, Customers and other third parties, including our business partners and consultants, may develop applications (including Mobile Applications) or provide services to you or other third parties using our Service. This Policy does not apply to information collected by Customers, our business partners and other third parties or third-party applications (including Mobile Applications) or services, even if this information is collected using our Website or Service. This Policy also does not cover the use or disclosure of any information stored in the Subscription Service when hosted by the Customer.

6.3 Changes to Our Privacy Policy

Fairchild Resiliency Systems reserves the right to update or change this Privacy Statement from time to time. If we make material changes to this Privacy Statement, we will notify you through an appropriate online notice (and obtain your consent where required by applicable law). Your continued use of the Website or Service is deemed to be acceptance of any updates or changes we make to this Privacy Statement and as such, we ask that you review the Privacy Statement periodically for any updates or changes that we may have made.

6.4 Contact Information

To ask questions or comment about this Policy and our privacy practices or if you need to update, change or remove your information, contact us at: privacy@FairchildRS.com.

or

Fairchild Resiliency Systems

Attn: Privacy – Thomas W. Tavenner, Jr., Esq.

c/o Dalton & Finegold, LLP

34 Essex St,

Andover, MA 01810

ttavenner@dfllp.com

END OF DOCUMENT/POLICY