Last update: October 20, 2023

Please read this privacy policy (the “Policy”) carefully to understand how Supremely Technologies Inc. and its product 911Cyber (“911Cyber”, “we”) uses personal information. By accessing or using www.911cyber.app, the 911Cyber mobile app, or any other related sites, applications, services and goods, or any other website operated by 911Cyber that links to this policy (each, the “Site”), you acknowledge that you have read and understood this Policy. This Policy may change from time to time; any changes we make to this Policy will be posted on this Site, we will also take any other steps, to the extent required by applicable law, including notifying you about material changes. Changes to this Policy are effective as of the stated “Last Updated” date. We recommend that you check the Policy periodically for any updates or changes.

Information We Collect – You directly provide us with most of the information we collect: when you register to the Site, use it, complete forms, or register to any of our programs. We also collect information about your communications with 911Cyber as well as any of your posts on our website or forums and your communication with other users of 911Cyber. In addition, we automatically collect information while you access, browse, view or otherwise use the Site and receive information from third party vendors or other available sources.

Information You Provide. When you register to the Site, use it, complete forms, participate in skills tests or surveys, or use the Site as expert/customer, and/or register to our affiliate or influencer or similar program, we ask you to provide certain personal information, including a valid email address, LinkedIn, Facebook or Google account login details and username. We will also ask you to provide or otherwise collect additional information, such as, your name, profile details, physical address or billing information, telephone number or

other contact details, transactional information, payment information (for example, in certain cases we process your payment method and credit card number), taxpayer information and forms, details about other social networks linked accounts, details about your listed services, projects, purchases, education, profession and expertise, information and files uploaded by you to the Site, and additional authentication information (such as copies of your government issued ID, passport, or driving license, as permitted by applicable laws and as detailed in our Help Center at “Verifying Your Identity”). We also collect information about or contained in your communications with 911Cyber as well as any of your posts on our blogs or forums and your communication with other users of 911Cyber.

Information We Collect Automatically. We collect information while you access, browse, view or otherwise use the Site. In other words, when you access the Site we collect personal information on your usage of the Site, including transactions and communications with other users through the Site, your searches, the pages you visited, as well as other actions on Site. We also collect, use and process the information relating to such usage, including geo-location information, IP address, device and connection information, browser information and web-log information, and the URLs of the web pages you’ve viewed or engaged with before or after using the Site. We also collect and process information relating to the use of cookies and similar technologies, as detailed below. We use that information to provide you our services, enhance user experience, personalize your browsing experience as well as monitor the Site for preventing fraud and inappropriate content or behavior.

Additionally, in order to improve your online experience at 911Cyber, we have implemented impression reporting. While you view our ads, we gather user Global Unique Identifier, HTTP request data like, user agent, IP, host, URL, country/continent from which request made, browser info, device/operating system/operating system version.

Information We Receive from Third Parties. We receive information from third party vendors and/or other commercially available sources, such as:

• Third party vendors who provide us data to supplement the information we collect about you, in accordance with applicable laws. For example, we receive fraud warnings from service providers for our fraud prevention and risk assessment efforts. We also receive information from enrichment service providers to enhance and personalize your experience as well as from advertising and marketing partners in order to manage and measure our campaigns.
• If you link, connect, or login to your account with a third-party service (e.g. Google, Facebook, LinkedIn), we receive certain information, such as your registration and profile information from that service. This information varies and is controlled by that service or as authorized by you via your privacy settings at that service.
• If you choose to invite contacts from your G-suite directory, we will have the ability to view details of contacts, subject to your G-suite permission. We will use this data to allow you to invite your contacts to your 911Cyber account. We will also use aggregated anonymised information for our internal purposes.
• If you integrate into your account information from third parties or otherwise integrate your account with third party systems, tools or products, we will receive certain information about you according to your permissions at such third parties.
• We also receive certain information about you, if you are invited to 911Cyber by another user (for example, as part of our collaboration tools and referral program), in such case we will receive limited information, such as your email address or other contact information, and we will use it for the same purpose it was provided and in accordance with the terms of this Privacy Policy.

We combine your personal information with information we collect automatically or obtain from other companies and use it for the purposes detailed in this Policy.

Our Legal Basis for Using Your Personal Information – Where relevant under applicable laws, all processing of your personal information will be justified by a “lawful ground” for processing. In the majority of cases, processing will be justified on the basis that:

• you have provided your consent for us to use your personal information for a specific purpose;
• our use of your personal information is necessary to perform a contract or take steps to enter into a contract with you (e.g. to provide you with services which you have purchased);
• the processing is necessary to comply with a relevant legal obligation or regulatory obligation that we have (e.g. fraud prevention); or
• the processing is necessary to support our legitimate interests as a business (e.g. to improve our services to you), subject to your interests and fundamental rights and provided it is conducted at all times in a way that is proportionate.

How Do We Use the Information Collected? – We use personal information to provide you with quality service and security, to operate the Site, understand how people use the Site, and to perform our obligations to you; to ensure marketplace integrity and security; to prevent fraud; to contact you and send you direct marketing communications; to promote and advertise the Site, our services and the 911Cyber platform; to comply with lawful requests by public authorities and to comply with applicable laws and regulations.

• to ensure marketplace integrity, prevent fraud and maintain a safe and secure marketplace and services. For example, we use personal information to monitor, track and prevent fraudulent activities and other inappropriate activities, monitor content integrity, conduct security investigations and risk assessments, verify or authenticate information provided by you, enforce our Terms of Service and comply with applicable laws. We conduct certain behavioral analytics to achieve the above objectives and in limited cases, if we detect activity that we think poses a risk to the 911Cyber platform, other users, our community, or third parties, automated processes may restrict or limit your ability to use 911Cyber. If you would like to challenge any such decision, please contact us at privacy(at)911cyber.app
• We use your personal information to send you direct marketing communications about our products, services or promotions from 911Cyber that may be of interest to you or our related services. This may be via email, post, SMS, telephone or targeted online advertisements.

• We take steps to limit direct marketing to a reasonable and proportionate level, and to send you communications which we believe may be of interest or relevance to you, based on the information we have about you.

How Long Do We Keep Personal Information – We will keep personal information only for as long as is required to fulfill the purpose for which it was collected. However, in some cases we will retain personal information for longer periods of time.

Children – This Site is offered and available to users who are at least 18 years of age and of legal age to form a binding contract. Minors under 18 and at least 13 years of age, are only permitted to use the Site through an account owned by a parent or legal guardian with their appropriate permission. Minors under 13 are not permitted to use the Site or the 911Cyber services. We do not knowingly collect personal information from children under 13. If you believe we might have any information from or about a child under 13, please contact us at privacy(at)911cyber.app – Subject: Data Collection Under 13 years-old.

Sharing Personal Information with Third Parties – We share personal information with third parties in order to operate the Site, provide our services to you, fulfill obligations imposed on us by applicable laws and regulations, and prevent fraud, infringements and illegal activities.

We share your personal information with third parties as detailed below:

• With other users and Site visitors. Once you register, your username, country, and additional information regarding your activity is made public and is visible to all users of the Site. This information includes photos you upload, your published portfolio, services/projects information, ratings, and additional information you may choose to add to your profile. Please be aware that certain information, such as your user name and profile, together with the content uploaded by you, will be publicly displayed when you use such features. Your information will also be shared with other users when you message or otherwise communicate with such users. When you publish your information and/or share your data with other 911Cyber users, you do so at your own risk. If you choose to share personal information with other users, including Experts (service providers) providing you a service via 911Cyber, such personal information is shared with other users as separate controllers. While 911Cyber Terms of Service require Experts to keep the information shared with them confidential, 911Cyber cannot ensure that all users will do so and it is your responsibility to ensure that other users will comply with your standards.
• With Service Providers. We share personal information for business purposes with service providers that provide us with services for the purpose of operating the Site, opening and operating your account as well as providing ancillary services and solutions. These include, among others, hosting services, billing and payment processors and vendors, CRM systems, forum hosting, community management services, data and cybersecurity services, web analytics and performance tools, translation tools, IT SaaS services, session recording, communication systems, mailing systems, data optimization and marketing services, data enrichment services, legal and financial advisors or technical consultants. Consistent with applicable legal requirements, we take appropriate technical and organizational measures to require third parties to adequately safeguard your personal information and only process it in accordance with our instructions;
• For legal reasons. We share personal information with law enforcement agencies, public authorities or other parties in order to respond to a subpoena or court order, judicial process or to regulatory authorities, if we believe we are required to do so by law, or that doing so is reasonably necessary to comply with legal processes; when we believe it necessary or appropriate to disclose personal information to law enforcement authorities, such as to investigate actual or suspected fraud or violations of law, breaches of security, or breaches of this Policy; to respond to claims against us; and to protect the rights, property, or personal safety of 911Cyber, our customers, or the public;
• For payments and fraud detection. We share personal information with payment processors, fraud detection agencies and similar third parties for the purpose of facilitating payments done via the Site and securing the Site and protecting it against fraud, unauthorized transactions (such as money laundering), claims or other liabilities;
• With social media partners. Our Site includes certain social media features, including single sign on features. We also share limited personal information with such social media platforms and marketing partners, such as LinkedIn, Facebook and Google, to promote our services or the 911Cyber platform. Such features and third party services collect certain information about you and may set a cookie to enable their functionality. Such third parties’ features are governed by their policies.
• With users with whom you interact. We share personal information to help facilitate interactions between users. For example, if you are a Buyer (Customer) we may share certain limited information about you (such as the fact it is your first purchase on 911Cyber) with the Expert to ensure the services you receive from the Expert will fit your needs; such sharing of information is limited in scope, and is only intended to improve the services provided by the Expert and your user experience;
• In the context of a corporate transaction. Personal information will also be disclosed if we go through a business transition such as a merger, sale, transfer of all or a portion of 911Cyber’s assets, acquisition, bankruptcy or similar event. In the event that we sell any business or assets, we will disclose your data to the prospective customer. If we or substantially all of our assets are acquired by a third party, information held by us about our users will be one of the transferred assets.

This Site is also protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply with respect to data collected by reCAPTCHA. The use of Google reCAPTCHA is required in order to prevent fraud and misuse of the Site by use of automated machines. To learn more, please see Google’s privacy policy.

Where We Store Personal Information – Some of the personal information you provide to us will be stored or processed on our behalf by third party suppliers and data processors and may be located in other jurisdictions, such as the United States.

Cookies – We use cookies and similar technologies (such as web beacons, pixels, tags, and scripts) to improve and personalize your experience, provide our services, analyze website performance and for marketing purposes.

Do Not Track (DNT) – Our Site does not respond to Do Not Track (DNT) signals.

External Links – The Site contains links to third party sites and if you link to a third party site from the Site, any data you provide to that site and any use of that data by the third party are not under the control of 911Cyber and are not subject to this Policy.

Security – We implement technical and organizational measures to maintain the security of the Site and your personal information and in preventing unauthorized access, loss, misuse, alteration, destruction or damage to it through industry standard technologies and internal procedures. Users who have registered to the Site agree to keep their password in strict confidence and not disclose such password to any third party. Further information about our data security practices can be provided on request.

Rights of EU, EEA and UK Users – Where we process personal data related to EU, EEA and UK user, further terms apply to our processing in relation to your rights as a data subject under EU data protection laws, as detailed below:

This section of the Policy applies to you if you are in the EU, the European Economic Area (EEA) or UK.

The Controller (within the meaning of the EU and UK General Data Protection Regulation (“GDPR”)) for the processing of personal data as described in this Privacy policy is: Supremely Technologies, New York, USA.

Under applicable EU regulation, you have the following rights in respect of your personal information:

• to obtain information about how and on what basis your personal information is processed and to obtain a copy;
• to rectify inaccurate personal information;
• to erase your personal information in limited circumstances where (a) you believe that it is no longer necessary for us to hold your personal information; (b) we are processing your personal information on the basis of legitimate interests and you object to such processing, and we cannot demonstrate an overriding legitimate ground for the processing; (c) where you have provided your personal information to us with your consent and you wish to withdraw your consent and there is no other ground under which we can process your personal information; and (d) where you believe the personal information we hold about you is being unlawfully processed by us;
• to restrict processing of your personal information where: (a) the accuracy of the personal information is contested; (b) the processing is unlawful but you object to the erasure of the personal information; (c) we no longer require the personal information for the purposes for which it was collected, but it is required for the establishment, exercise or defense of a legal claim or (d) you have objected to us processing your personal information based on our legitimate interests and we are considering your objection;
• to object to decisions which are based solely on automated processing or profiling;
• where you have provided your personal information to us with your consent, to ask us for a copy of this data in a structured, machine-readable format and to ask us to share (port) this data to another data controller; or
• to obtain a copy of or access to safeguards under which your personal information is transferred outside of the EEA.

Under certain circumstances, you may have the right to object, on grounds relating to your particular situation, to the processing of your personal data by us and we may be required to no longer process your personal data. Moreover, if your personal data is processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing. In this case your personal data will no longer be processed for such purposes by us.

We will ask you for additional data to confirm your identity and for security purposes, before disclosing data requested by you. We reserve the right to charge a fee where permitted by law. We will decline to process requests that jeopardize the privacy of others, are extremely impractical, or would cause us to take any action that is not permissible under applicable laws. Additionally, as permitted by applicable laws, we will retain where necessary certain personal information for a limited period of time for record-keeping, accounting and fraud prevention purposes.

Specific Provisions for California Residents– If you are a California resident, you are entitled to specific privacy rights as detailed below.

To make such requests, we kindly ask that you to contact us at privacy(at)911cyber.app

We will verify your request using the information associated with your account, including email address. Government identification may also be required.

A request for access can be made by you only twice within a 12-months period. Any disclosures that we provide will only cover the 12-months period preceding receipt of your request. We do not charge a fee to process or respond to your verifiable User request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will inform you of the reasons for such decision and provide you with a cost estimate before processing further your request.

Updating Personal Information – We take steps to ensure that the personal information we collect is accurate and up to date, and we provide you with the opportunity to update your information through your account profile settings. In the event that you believe your information is in any way incorrect or inaccurate, please let us know immediately.

Contact Us – You can exercise your rights over your personal information, by contacting us at privacy(at)911cyber.app