INTOTO PRIVACY POLICY

What is Personal Information

"Personal information" is any information that can be used to identify an individual and may include name, address, email address, phone number, login information (account number, password), social media account information, or payment card number.

It may also include device identifiers, data, and telemetry (such as IP or MAC address) when such data is linked or tied to a specific person’s device.

If we link other data with your personal information, we will treat that linked data as personal information.

Collection of Your Personal Information

We may collect data, including personal information, about you as you use our website and Solutions and interact with us. We also acquire personal information from trusted third-party sources and engage third parties to collect personal information on our behalf.

We collect personal information for a variety of business reasons, such as:

• Processing your order, including payment transactions.


• Providing you with a newsletter subscription.


• Sending and managing marketing communications and preferences.


• Creating an account.


• Provisioning websites and Solutions and enabling the use of certain features.


• Personalizing, improving, and enhancing user experience and Solutions.


• Providing customer service.


• Managing a job application.


• Administering online education, testing, and certifications.

We and the third parties may combine the information collected across our websites and Solutions from you over time with information obtained from other sources. This helps us improve accuracy and completeness and allows us to better tailor our interactions with you.

If you choose to provide Intoto with a third party's personal information (such as name, email, and phone number), you represent that you have the third party's permission to do so. Examples include forwarding reference or marketing material to a friend or sending job referrals. Third parties may unsubscribe from any future communication following the link provided in the initial message. In some instances, Intoto and the third parties we engage may automatically collect data through cookies, weblogs, web beacons, and other similar applications. This information is used to better understand and improve the usability, performance, and effectiveness of the website or Solution and to help personalize features, content, or offers for you. Please read the "Cookies and Other Web Technologies" section below for more information.

Uses of Your Personal Information

We may use your personal information for the purposes of operating and helping to ensure the security of our business, delivering, improving, and customizing our website and Solutions, sending notices, marketing and other communications, and for other legitimate purposes permitted by applicable law. Some of the ways we may use personal information include:

• Delivering a Solution you have requested.


• Analyzing, supporting, and improving our website and Solutions and user experience.


• Personalizing websites and Solutions, newsletters, and other communications.


• Managing your relationship and interactions with Intoto.


• Sending communications to you, including for marketing or customer satisfaction purposes, either directly from Intoto or from our partners.

You can modify your communication preferences at any time. See Your Choices and Selecting Your Communication Preferences below.

Access to and Accuracy of Your Personal Information

We need your help to keep your personal information accurate and up to date. We provide options to access, correct, suppress, or delete your personal information:

• You can view or edit your Intoto account personal information and preferences online by using the Intoto cloud-based platform or the Intoto mobile app.


• Some Intoto entities may act as or be considered "data controllers." When an Intoto entity is acting as a data controller, you can exercise your rights of access and request corrections, suppression, or deactivations under applicable data protection laws directly with that Intoto entity as described in the specific Solution documentation.


• If you need additional assistance or help with accessing, correcting, suppressing,or deleting your personal information, please feel free to contact us directly. We make good faith efforts to honor reasonable requests to access, delete, update, suppress, or correct your data. We will respond to your request within 30 days. If we are unable to honor your request or need more time, we will provide you with an explanation.


• In certain circumstances, some Intoto entities may act as or be considered "dataprocessors". When an Intoto entity is acting as a data processor and you wish to exercise your rights of access and request corrections, suppression, or deactivations, Intoto will direct you to the data controller under the applicable data protection laws.

Your Choices and Selecting Your Communication Preferences

We give you the choice of receiving a variety of information related to our business, programs, website, and Solutions. You can manage your communication preferences through the following methods:

• By following the instructions included in each promotional email from us to unsubscribe from that mailing.


• By contacting us via mail at Intoto, 1 Wrigley, Irvine, CA 92618, USA. Please be sure to include your name, email address, and specific, relevant information about the material you no longer wish to receive.

These choices do not apply to service notifications or other required communications that are considered part of certain programs, websites, and Solutions, which you may receive periodically unless you stop using or cancel the use of the program, website, or Solution in accordance with its terms and conditions. With your permission, we may also share your personal information with Intoto business partners or vendors, so they may send you information about websites, programs, products or services that may be of interest to you.

By using our website, Solutions, or otherwise engaging or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use. For example, if we learn of a security system's breach, we may attempt to notify you electronically by posting a notice on our website, sending an email, or otherwise contacting you.

Sharing Your Personal Information

We may share your personal information with third parties for the purposes of operating our business, delivering, improving, securing, and customizing our website and Solutions, sending marketing and other communications related to our business, and for other legitimate purposes permitted by applicable law or otherwise with your consent.

We may share personal information in the following ways:

• Within Intoto and any of our worldwide subsidiaries for the purposes of data processing, such as marketing, business operations, security, website or Solution functionality, or storage.


• With Intoto business partners or vendors, so that they may share information with you about their products or services.


• With business partners, service vendors, authorized third-party agents, or contractors to provide a requested website, Solution, service or transaction. Examples include, but are not limited to: processing of orders and credit card transactions, hosting websites, hosting seminar registration, assisting with sales-related efforts or post-sales support, and providing customer support.


• In connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or to another company.


• In response to a request for information by a competent authority or third party if we believe disclosure is in accordance with or is otherwise required by, any applicable law, regulation or legal process.


• With law enforcement officials, government authorities, or other third parties as necessary to comply with legal process or meet national security requirements; protect the rights, property, or safety of Intoto, its business partners, you, or others; or as otherwise required by applicable law.


• In aggregated, anonymized, and/or de-identified form that cannot reasonably be used to identify you.


• If we otherwise notify you and you consent to the sharing.

Security of Your Personal Information

We intend to protect the personal information entrusted to us and treat it securely inaccordance with this Privacy Statement. Intoto implements physical, administrative, and technical safeguards designed to protect your personal information from accidental or unlawful destruction, loss, alteration, unauthorized disclosure or access. We also contractually require that our suppliers protect such information from accidental or unlawful destruction, loss, alteration, unauthorized disclosure or access. The Internet, however, cannot be guaranteed to be 100% secure, and we cannot ensure or warrant the security of any personal information you provide.

Retention of Personal Information

We will retain your personal information as needed to fulfill the purposes for which itwas collected. We will retain and use your personal information as necessary to comply with our business requirements, legal obligations, resolve disputes, protect our assets, and enforce our rights and agreements.

Use of Cookies and other Web Technologies

Like many websites and web-based Solutions, Intoto uses automatic data collection tools, such as cookies, embedded web links, and web beacons. These tools collect certain standard information that your browser sends to us (e.g., Internet Protocol (IP) address, MAC address, clickstream behavior, and telemetry).

These tools help make your visit to our website and Solutions easier, more efficient, and personalized. We also use the information to improve our website and Solutions and provide greater service and value.

We partner with third parties to display advertising on our website and to manage our advertising on other sites. Our third-party partners may use cookies or similar technologies in order to provide you with advertising based on your browsing activities and interests. You may opt out of this advertising; however, generic, non-personalized ads will continue to be displayed.

Linked Websites

We may provide links to other third-party websites and services that are outside our control and not covered by this Privacy Statement. We encourage you to review the privacy statements posted on the websites you visit.

Forums and Chat Rooms

If you participate in a discussion forum, local communities, or chat room on the Intoto website, you should be aware that the information you provide there (i.e. your public profile) will be made broadly available to others and could be used to contact you, send you unsolicited messages, or for purposes neither Intoto nor you have control over. Also, please recognize that individual forums and chat rooms may have additional rules and conditions. Intoto is not responsible for the personal information or any other information you choose to submit in these forums.

Children's Privacy

Intoto encourages parents and guardians to take an active role in their children's online activities. Intoto does not knowingly collect personal information from children without appropriate parental or guardian consent. If you believe that we may have collected personal information from someone under the applicable age of consent in your country without proper consent, please let us know using the methods described in the Contact Us section and we will take appropriate measures to investigate and address the issue promptly.

International Transfer, Processing and Storage of Personal Information

As Intoto is a global organization, we may transfer your personal information to Intoto inthe United States of America, to any Intoto subsidiary worldwide, or to third parties and business partners as described above that are located in various countries around the world. By using our websites and Solutions or providing any personal information to us, where applicable law permits, you acknowledge and accept the transfer, processing, and storage of such information outside of your country of residence where data protection standards may be different.

Intoto safeguards and enables the global transfer of personal information.

Complaint Resolution

If you have an unresolved privacy concern related to personal data processed or transferred by Intoto pursuant to the CBPRs, PRP and/or Privacy Shield or this statement that Intoto has not addressed satisfactorily, please contact (free of charge) our U.S.-based third party dispute resolution provider. Alternatively, you can contact the data protection supervisory authority in your jurisdiction for assistance

Under certain conditions more fully described on the Privacy Shield website, you maybe entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted. Under certain conditions more fully described on the Privacy Shield website, you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.

Your California Privacy Rights

California Consumer Privacy Act (CCPA)

In the last twelve months, Intoto may have collected, used, and shared, for business purposes, personal information about you as described in this Privacy Statement. Each category of data may be used by Intoto or shared with third parties also as described in this Privacy Statement. Residents of California have the right to request access to and deletion of the information Intoto holds about them. Such requests may be submitted by sending us an email at info@intotoware.com or by mail to Intoto, 1 Wrigley Irvine, CA92618. Intoto will not sell your personal information without your consent.

Intoto will not discriminate against you for exercising your rights under CCPA. Specifically, we will not:

• Deny access to our Solutions;


• Charge a different rate for the use of our Solutions; or


• Provide a different quality of service.

California Shine the Light

Residents of the State of California, under California Civil Code § 1798.83, have the right to request from companies conducting business in California a list of all third parties to which the company has disclosed personal information during the preceding year for direct marketing purposes. Alternatively, the law provides that if the company has a privacy policy that gives either an opt-out or opt-in choice for use of your personal information by third parties (such as advertisers) for marketing purposes, the company may instead provide you with information on how to exercise your disclosure choice options.

Intoto qualifies for the alternative option. We have a comprehensive privacy statement, and provide you with details on how you may either opt-out or opt-in to the use of your personal information by third parties for direct marketing purposes. Therefore, we are not required to maintain or disclose a list of the third parties that received your personal information for marketing purposes during the preceding year.

How to Contact Us

We value your opinions. Should you have questions or comments related to this Privacy Statement, contact us at 949-591-8639 or e-mail us at info@intotoware.com.