Privacy Notice

This Privacy Statement explains how GuideOn Consulting, LLC (GuideOn) collects and uses Personal Data

and describes the rights you have with respect to your Personal Data. In this Statement, “GuideOn,”

“we” or “us” refers to GuideOn Consulting, LLC and any affiliated entities.

GuideOn may process Personal Data for a variety of purposes. We collect Personal Data directly from

you, such as when you submit a form or contact information on our website asking for information or

when you register for a GuideOn sponsored event. We may also automatically collect Personal Data

when you engage with our websites.

This Privacy Statement covers the described methods in which GuideOn collects Personal Data. This

statement provides additional details regarding the information GuideOn collects and the purposes of

the collection.

Scope

“Personal Data”; is any data that can be used to identify an individual, either alone or when combined

with other information that is linked or linkable to a specific individual. Personal Data can directly

identify an individual, such as a name, email address, or identification number. Personal Data can also

indirectly identify an individual, such as when combined data elements specify a unique individual, such

as race, gender, and job role within a work environment. Another example is when data elements

specify the physical, behavioral, mental, genetic, economic, cultural, or social identity or activities of a

unique individual.

 “Sensitive Personal Data” includes the following special categories of personal data:

 Government identification card or number

 Financial account numbers and access codes

 Precise geolocation

 Biometric or genetic data when used to identify an individual

 Medical information

 Criminal records

 Racial or ethnic origin

 Religious or philosophical beliefs

 Union membership

 Sex life or sexual orientation

 Content of communications if obtained by someone who is not the intended recipient

Your Rights in Relation to the Personal Data We Collect and Process

You have the following rights related to your Personal Data that GuideOn collects and processes:

 Right to request access to your Personal Data maintained by GuideOn

 Right to request amendment or correction of your Personal Data

 Right to request deletion of your Personal Data

 Right to request data portability or the right to receive a copy of your Personal Data in a

structured, commonly used and machine-readable format to transfer to another company

 Right to opt-out of marketing communications at any time

 Right to request restriction or to object to the processing of your Personal Data

 Right to withdraw consent, if you have voluntarily provided, or have consented to provide your

Personal Data

 Right to complain to a data protection authority

If you want to assert any of the above rights, you may contact us at info@guideonconsulting.com. We

will respond to your request consistent with applicable law. In your request, please include the

following:

 The nature of the request (the type of right you are asserting)

 What Personal Data you seek to access, amend, delete, restrict, transmit to another company,

or withdraw consent to process

For your protection, we may only respond to requests with respect to the Personal Data associated with

the email address that you use to send us your request, and we may need to verify your identity before

implementing your request. We will try to comply with your request as soon as reasonably practicable

and within the requirements of any applicable law.

Please note that we may need to retain certain information for recordkeeping purposes, to comply with

legal obligations, and/or to complete any transactions that you began prior to requesting a change or

deletion. There may also be residual information that will remain within our databases and other

records or in backups which will not be removed until the retention period ends.

Minors

GuideOn does not intend this Site to be directed to individuals under the age of eighteen (18), and we

do not knowingly collect, process, disclose, or share the Personal Data of minors from this Site. If you

are a minor and believe that you have provided Personal Data, please ask your parent(s) or legal

guardian(s) to notify us, and we will delete your Personal Data.

Purpose Specification and Use Limitation

GuideOn limits the collection, use, retention, and disclosure of Personal Data to what is reasonably

necessary and proportionate to achieve the purposes for which the Personal Data was collected or

processed. GuideOn also limits secondary use or disclosure to that which is compatible with the original

purpose of the Personal Data collection, or we will get consent to process the Personal Data, unless the

processing is permitted or required by law.

Personal Data We Collect and For What Purpose

Information that individuals provide

We collect information that you provide voluntarily through our site when you provide an online form,

register for an event, subscribe to a white paper or newsletter, and reach out with contact information

to receive marketing communications. We do not intend to collect Sensitive Personal Data unless you

provide it to us. We encourage you not to provide Sensitive Personal Data in free text boxes or

communications, but if you do, you acknowledge that you consent to the collection and processing of

the Sensitive Personal Data.

If you submit any Personal Data relating to other people to us or to our service providers in connection

with the website, you represent that you have the authority to do so and to permit us to use the

information in accordance with this Privacy Statement.

If you elect to opt-out of receiving GuideOn publications or marketing communications, your basic

contact details will remain on our opt-out list.

Purposes for Which GuideOn Processes the Personal Data of Visitors to the Website

GuideOn may collect and process the Personal Data of Visitors to our website for the following

purposes:

 To administer and manage our site

 To personalize and improve your browsing experience by displaying content and advertising that

may be of particular interest to you

 To provide news or information that may interest you through other plug-ins on the site

 To analyze the data of visitors to our website and website traffic information

 To determine your employer or organization with which you associate

 To develop our business and services

 To provide marketing communications and materials

 To monitor and enforce compliance with applicable terms of use

 To conduct quality and risk management reviews

 To maintain security

 To allow for event and webinar registration, management, and coordination

 To allow content download

 Any other purpose for which you provide information to GuideOn

Legal Basis for Processing Personal Data

 Explicit consent of the visitor

 GuideOn’s legitimate interest in:

o Effectively delivering information and services to you

o Developing and improving our site and user experience

o Marketing, growing, and protecting our business and services

Individuals who engage on social media sites, plug-ins, and tools

Social Media Sites

GuideOn may utilize various social media platforms, such as Twitter or LinkedIn, for recruitment or

marketing purposes. We use social media to provide easy access to relevant information about job

opportunities and events and to promote our services and brand.

GuideOn is responsible for the content it publishes using social media platforms, but does not have

control over the social media platforms and the way they are administered. When using these social

media platforms, you must adhere to the terms of use and privacy policies imposed by the platform

providers. If you would like to access this data or invoke your rights to the data, such as the right to

correct or object to the processing of the data, you should contact the social media platform provider.

Some social media platforms provide GuideOn with data relevant to your pages that is aggregated or

combined with similar data from other visitors to our social media sites, such as the number of “likes”

triggered by our content or the amounts of posts, visitors to the sites, and information downloaded or

links clicked.

Social Media Plug-Ins

We use some social media plug-ins on our site that allow you to share information with your social

network, view content, and provide you with relevant information. When you interact with these

features your internet browser will directly connect you to the relevant social network server to

complete the action. The social media provider will know that the page with the plug-in on our site has

been visited.

GuideOn or our service providers may also provide the social media provider with advertisements or

marketing materials that they can deliver to individuals who viewed related content on our websites.

The social media sites may also use the Personal Data collected in ways consistent with that provider’s

notices and terms of use.

We have no control over the data collected by the social media providers through the use of the

buttons. GuideOn does not know the type of data collected or how it is used.

Individuals who engage GuideOn through email correspondence

GuideOn may utilize tools to protect the security of our information technology (IT) assets, including our

email transmissions. Examples may include:

 Systems that scan incoming emails for suspicious attachments and universal resource locators

(URLs) to prevent malware attacks

 End-point threat detection tools to detect malicious attacks

 Tools that block certain content or websites.

If you send emails to GuideOn, your emails may be scanned by these tools to maintain GuideOn’s IT

infrastructure security, which means that GuideOn personnel other than the intended recipient may

read your email content.

Retention

GuideOn retains PII only as long as needed for the stated processing purpose. GuideOn’s record

retention schedule provides the required retention periods for GuideOn records based on business and

legal requirements, including the need to exercise and defend legal rights. GuideOn also maintains

records for archiving and historical purposes in compliance with retention periods. If Personal Data is

not in a record subject to GuideOn’s retention schedule, GuideOn requires that the Personal Data be

deleted when no longer necessary for the stated processing purpose.

Security of Personal Data

GuideOn uses reasonable organizational, technical, and administrative measures to protect the

confidentiality, integrity, and availability of the Personal Data that GuideOn collects, maintains, and

processes. GuideOn limits access to information to those with a need to know to process the Personal

Data. If you have reason to believe that your Personal Data is no longer secure, please immediately

notify us at info@guideonconsulting.com. Because email communications are not always secure, please

do not include sensitive information in your emails to us.

Service Providers

GuideOn may engage service providers to support our internal operations, including client contracts. We

may disclose, and in some cases, transfer Personal Data we collect to our service providers and their

affiliates and sub-processors. In other cases, service providers may collect and transfer Personal Data on

our behalf. For example, service providers may provide:

 Information technology functions, such as information security, data storage, data analytics,

business applications, and voicemail

 General operational support, such as enterprise management software, customer relationship

management software, archiving, and event management

 Accounting, finance, and billing support

 Compliance risk reviews and assessments, legal hold services, and legal case management

 Subcontractor services when we are engaged by a client

In engaging third parties, GuideOn ensures that our service providers contractually agree to comply with

any applicable privacy law requirements, including those related to the collection and transfer of

Personal Data outside the jurisdiction in which it was collected. GuideOn also requires service providers

to confirm that they maintain appropriate security safeguards and meet confidentiality requirements

related to Personal Data. If you would like to know more about the third parties GuideOn engages,

please contact GuideOn at info@guideonconsulting.com.

Additional Disclosures of Personal Data

GuideOn discloses Personal Data for the following purposes:

 As directed by you or at your consent

 Where the disclosure is necessary and appropriate for the purposes described in this policy,

including within the GuideOn entities

 If required by applicable law, including laws outside the country where the Personal Data was

collected

 In connection with a reorganization, merger, sale, joint venture, assignment, transfer or other

disposition of all or any portion of our business assets or stock (including in connection with any

bankruptcy or similar proceeding)

 To protect, exercise, and defend GuideOn’s legal claims, safety, or property

 To comply with a regulatory or government inquiry, court order, or other legal obligation,

including those outside the country where the Personal Data was collected

 To cooperate with law enforcement as necessary

GuideOn is obligated to report certain activities or suspected criminal activity to relevant regulatory

authorities and law enforcement. The law sometimes prohibits GuideOn from informing the individual

about the disclosure prior to the disclosure, or at all. Third-party recipients of the Personal Data may

include:

 Law firms, tax advisors, or auditors

 Insurers

 Audit regulators

 Tax and customs, and excise authorities

 Regulatory bodies

 Credit reference agencies

 Courts, police, and law enforcement agencies

 Government departments and agencies

 Service providers

 Complaints

If you want to report an alleged violation or breach of a privacy law or any other regulation, you should

contact us at info@guideonconsulting.com.

You also have the right to complain to the data protection authority in your country or refer the matter

to a court of competent jurisdiction or as specified in any applicable engagement agreement with

GuideOn.

If you are located in the EEA, you may lodge a complaint with a data protection authority for your

country or region, or where an alleged infringement of applicable data protection law occurs.

Revisions to the Privacy Statement

We may change this Privacy Statement to reflect changes in our practices and services. The “Last

Updated” legend at the top of this page indicates when this Privacy Statement was last revised. Any

changes will become effective when we post the revised notice on this website. We recommend

checking this Statement from time to time to inform yourself of any changes based on the last updated

date.

U.S. States Privacy Policy Last Updated Date: January 1, 2023

This U.S. States Privacy Policy should be considered an addendum to the GuideOn Privacy Statement

that applies to California and Virginia residents. This policy explains the Personal Data that we collect

from these residents and how we collect and use the Personal Data pursuant to the California Consumer

Privacy Act (CCPA) and its regulations and the Virginia Consumer Data Protection Act (VCDPA) and its

regulations. This U.S. States Privacy Policy provides additional details regarding the categories of

Personal Data about California and Virginia residents that we have collected or disclosed within the

preceding 12 months. This policy also provides details about the rights that California and Virginia

residents have related to the collection of their Personal Data under their states’ privacy laws. This

policy should be read in conjunction with the GuideOn Privacy Statement, and in any case of conflict,

this policy regarding Personal Data subject to your state’s law will prevail. For purposes of this notice,

“Personal Data” includes all “Personal Information” or “Personal Data” as that term is defined in the

CCPA or VCDPA. “Sensitive Personal Data” includes all “Sensitive Personal Information” or “Sensitive

Data” as that term is defined in the applicable state laws (California or Virginia). Targeted advertising

and cross-context behavioral advertising are interchangeable.

Sources of, purposes for collecting, and categories of personal data collected and disclosed

GuideOn’s Privacy Statement provides a detailed description of the specific elements and categories of

Personal Data and Sensitive Personal Data that we collect, the categories of sources from which we

collect the Personal Data and Sensitive Personal Data, and the categories of third parties with whom we

share or may share Personal Data or Sensitive Personal Data.

Categories of Personal Data

In the preceding twelve (12) months we collected the following categories of Personal Data and

Sensitive Personal Data from California and Virginia residents. The following list represents categories of

Personal Data and Sensitive Personal Data across all residents and may not represent what we have

collected specifically about you. Please Note: Your state law may not require the disclosure of data that

is publicly available or that has been aggregated or de-identified.

• Identifiers, including name, postal address, email address, account name, IP address, driver’s license

number and similar identifiers

Sensitive Personal Data

Some of the above listed Personal Data may be considered Sensitive Personal Data under your state

privacy laws, such as protected classifications, biometric data when used to identify you, sexual

orientation, national origin, citizenship/immigration status, religion, medical or health information, and

precise geolocation. California also considers social security number, passport number, trade union

membership, and driver’s license number sensitive Personal Data.

Purposes of Collection and Processing

In the preceding 12 months, GuideOn may have collected and processed Personal Data and Sensitive

Personal Data for various business purposes, including:

• Employment purposes

• Auditing purposes

• Detecting and mitigating security incidents

• Protecting against potential threats to GuideOn

• Protecting against fraudulent or illegal activity

• Debugging to identify and repair errors that impair existing intended functionality

• Short-term, transient uses where the Personal Data is not disclosed to another third party and is not

used to build a profile about a consumer or otherwise alter an individual consumer’s experience

• Performing services for or on behalf of our clients, including, but not limited to, maintaining accounts,

providing customer service, processing payments, providing analytics

• Providing advertising and marketing services other than cross-context behavioral advertising or

targeted advertising

• Undertaking internal research for development of commercial products or demonstrations where the

Personal Data is not used in an identifiable manner in the commercial product

• Undertaking activities to verify or maintain the quality or safety of our services and to improve,

upgrade, or enhance our services

• Exercise and defend legal claims

Disclosure of Personal Data or Sensitive Personal Data

In the preceding 12 months, GuideOn may have disclosed to third parties for a business purpose the

categories of Personal Data and Sensitive Personal Data listed above. GuideOn may have disclosed this

Personal Data and Sensitive Personal Data to the following categories of third parties:

• Other GuideOn affiliates and subsidiaries for GuideOn’s operational purposes

• Vendors, suppliers, and subcontractors who provide services on our behalf or on behalf of a client

• Professional service organizations, such as auditors, law firms, consultants, and accountants to receive

services from these organizations

• Insurers or financial firms to receive services from these organizations

• Joint marketing partners and ad networks to marketing purposes both online and offline (see Sharing

with Third Parties for Cross-Context Behavioral Advertising)

• Business partners for business development and growth

• Government and commercial clients to perform services for our clients

• Information service providers, such as internet service providers, data analytics providers, operating

systems and platforms providers, as necessary to receive services

• Identity and credit verification services as well as employment, criminal and civil, and education

verification services to conduct due diligence and manage GuideOn’s responsibilities related to

employees and hiring of candidate

• Regulatory, professional bodies, government authorities, and any other oversight entity to comply

with legal or other compliance requirements Sale and

Sharing of Personal Data

GuideOn has not “sold” Personal Data for monetary consideration. Depending on your state’s privacy

law, sharing browsing information with certain third parties using cookies, pixels, or other online tools

may be considered a “sale” or “sharing” of Personal Data for targeted advertising or cross-context

behavioral advertising and profiling. GuideOn does not collect Personal Data on its websites for profiling

that produces legal or similarly significant effects, such as denial of employment opportunities. GuideOn

allows third parties to collect your browsing activity and certain other Personal Data through automated

technologies on our website. These third parties may collect your Personal Data when you are on our

websites and may use your Personal Data for purposes of advertising. We may share the following

Personal Data with third parties through the use of cookies, pixels, and other online tools for the

purpose of providing you a more personalized browsing experience and to improve our own advertising

efforts by identifying your interests and information you might want to receive.

• Broad geographic location (e.g. country, city-level or zip location)

• Company name

• Internet Protocol (IP) address

• Pixel ID

• Device type

• Browser Type

• How your device interacts with our site, including pages viewed, time you visited, current URL, and

links clicked You can and optout of their use by contacting GuideOn at info@guideonconsulting.com.

Please note that to the extent you access GuideOn across multiple devices or platforms or if you clear

your browser settings, you may have to opt-out again.

Opt-Out Preference Signal or Do Not Track Global Privacy Control

If we detect that you have enabled the Do Not Track setting in your browser or another technology

(Opt-Out Preference Signal or sometimes called the Global Privacy Control), we will automatically

disable advertising cookies. GuideOn will not charge a fee or change your experience with the products

or services offered if you choose to enable an Opt-Out Preference Signal or Global Privacy Control. You

may learn how to set the Global Privacy Control at https://globalprivacycontrol.org/.

Minors

GuideOn does not knowingly collect, sell, or share Personal Data of minors under 16 years of age.

Data Retention

GuideOn retains PII only as long as needed for the stated processing purpose. GuideOn may also

maintain records for archiving and historical purposes in compliance with retention periods. If Personal

Data is not in a record subject to GuideOn’s retention schedule, GuideOn policy requires that the

Personal Data be deleted when no longer necessary for the stated processing purpose.

Legal Rights

Depending on your states’ consumer privacy law, you may have legal rights related to your Personal

Data, as indicated below.

California You can exercise any of the listed rights using the methods described in Exercising Your Rights

below. Right of access and data portability: You may request that GuideOn disclose to you information

about our collection and use of your Personal Data and Sensitive Personal Data in the preceding 12

months, including:

• Categories and specific pieces of Personal Data and Sensitive Personal Data that we collected about a

California resident

• Categories of sources from which we collect Personal Data or Sensitive Personal Data

• Business or commercial purpose for which we collect Personal Data or Sensitive Personal Data

• Categories of Personal Data or Sensitive Personal Data that we Share and the categories of third

parties with whom we Share the Personal Data or Sensitive Personal Data

• Business or commercial purpose for which we Share Personal Data or Sensitive Personal Data

• Categories of Personal Data or Sensitive Personal Data that we have disclosed for a business purpose

• Length of time, or criteria for determining the length of time, that GuideOn intends to retain each

category of Personal Data and Sensitive Personal Data

Right to request deletion of Personal Data

You may request that GuideOn delete your Personal Data or Sensitive Personal Data. This request is

subject to GuideOn’s right to maintain Personal Data and Sensitive Personal Data for purposes

permitted under applicable law. If we cannot comply with your request, we will notify you. Right to

request correction of your Personal Data and Sensitive Personal Data: You may request that GuideOn

correct inaccurate Personal Data. Right to opt-out of a Sale or Sharing of Personal Data for behavioral

advertising purposes: You may request that your Personal Data not be sold or shared for behavioral

advertising purposes as indicated above. Right to limit the use and disclosure of Sensitive Personal Data:

You may request to direct GuideOn to limit the use of your Sensitive Personal Data to that which is

necessary to perform the services or provide the goods as reasonably expected and to perform certain

services permitted by the CCPA. At this time, GuideOn only uses Sensitive Personal Data for purposes

permitted by the CCPA. If this changes, GuideOn will notify you of the right to limit the use and

disclosure of Sensitive Personal Data. Right to non-discrimination: You have the right to exercise any of

your rights listed above and any other rights under the CCPA without discrimination by GuideOn. This

includes the right of employees, applicants, and independent contractors not to be retaliated against for

the exercise of their CCPA rights.

Virginia You can exercise any of the listed rights using the methods described in Exercising Your Rights

below.

Right of access: You may request to confirm whether GuideOn is processing your Personal Data and to

access your Personal Data.

Right of data portability: You may request that we provide you a copy of the Personal Data that you

previously provided to GuideOn.

Right to correction: You may request that we correct inaccuracies in the Personal Data that we have

collected about you. This request is subject to GuideOn’s right to maintain Personal Data for purposes

permitted under applicable law. If we cannot comply with your request, we will notify you.

Right to opt-out: You may request that your Personal Data not be sold to third parties or used for

targeted advertising or that your Personal not be used for profiling in furtherance of decisions that

produce legal or similarly significant effects concerning you.

Right to Deletion: You may request deletion of certain Personal Data that we have collected about you.

This request is subject to GuideOn’s right to maintain Personal Data for purposes permitted under

applicable law. If we cannot comply with your request, we will notify you.

Appeal: You may appeal GuideOn’s denial of any of the above-listed rights. You may do so by following

the procedures below on Exercising Your Rights and responding to the message that GuideOn sends to

you denying your request by indicating that you want to appeal.

Exercising Your Rights To exercise any of your rights listed above, please contact GuideOn by:

• Contacting us at info@guideonconsulting.com

• Opt-out of sharing your Personal Data by enabling the Preference Signal Opt-Out. We will not require

you to verify your right to opt-out of the sharing of Personal Data. To exercise your other rights, we will

require you to provide certain personal data to verify your identity for your protection and as required

by California law. This information includes:

• Name

• Email address

• Description of relationship with GuideOn, the Personal Data for which you are exercising your rights,

and additional information as necessary, such as the rights you intend to exercise

You may authorize another person or agent to make the request on your behalf. This person will have to

provide the above listed information for both you and the agent. After verifying your identity and

validity of your request, GuideOn takes the following action free of charge:

• If you request disclosure of the specific information related to you collected, disclosed, or shared,

provide you notice of the information directly or indirectly collected by category of information, the

categories of sources from which the Personal Data was collected, the business purpose for collecting or

sharing the Personal Data, and the categories of third parties to whom the business disclosed the

Personal Data

• If you request access, provide you access to any required Personal Data for the twelve (12) month

period preceding your request, including providing you an electronic copy to easily transmit your

Personal Data to another company (right to data portability), when technically feasible and as required

by your state’s law

• If you request deletion, delete your Personal Data, subject to the right to maintain data as permitted

under law

• If you request correction, correct your Personal Data, subject to the right to disagree as permitted

under law

• Respond to your request within forty-five (45) days unless we notify you that we reasonably need to

extend that period Contact to Report Concerns or Ask Questions GuideOn provides employees, clients,

and external third parties various means to ask questions or to report unethical or illegal behaviors that

violate the law, regulations, or GuideOn policy. Questions or reports can be made directly to

info@guideonconsulting.com.