Last updated: June 5, 2021

Fretwork Security Advisors (hereafter “Fretwork”) is sensitive to the privacy concerns of our clients and the public writ large. This statement discloses the privacy practices for Fretwork. This Online Privacy Statement applies to data collected by Fretwork through the majority of its website, as well as its offline support services.

Our privacy mailing address:
Fretwork Security Advisors
Attention: Privacy
2033 6th Ave, Ste 600
Seattle, WA 98121

Our privacy e-mail address:
privacy-at-fretworksec.com

Collection of Your Personal Information
On our website, or during other interactions with Fretwork, we may ask you to provide personal information such as your e-mail address, name, home or work address, or telephone number. We may collect information about your visit, including the pages you view, the links you click and other actions you take in connection with Fretwork’s website and services. We also collect certain standard information that your browser sends to every website you visit, such as your IP address, browser type, language, access times, and referring website addresses.

Our site is not intentionally designed for or directed at children under the age of 13 years. It is not our policy to knowingly collect or maintain information about anyone under the age of 13.

Information We Collect
We collect information about you in two ways. First, we collect personal information provided to us directly by you, such as when you:

• Submit a request to be contacted about our services
• Submit a request to be contacted about a job
• E-mail us
• Request information from us

Second, we automatically receive information from your browser, including but not limited to, your internet protocol (IP) address; information about your browser, cookie, web beacon, or web bug information.

Cookies
Cookies enable us to track and target the interests of our users to enhance their experience on our website. You can set your browser to reject a cookie. If you do so, you will still be able to use the website, but you may be limited in some areas of the website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you log on to our website. For more information about cookies and how to turn them off, please visit the Interactive Advertising Bureau’s website at http://www.allaboutcookies.org.

Use of Your Personal Information
Fretwork collects and uses your personal information to deliver the services or carry out the transactions you have requested. If you send us a resume or curriculum vitae to apply online for a position with Fretwork we will use the information provided to match you with available opportunities.

Fretwork may also use information you provide to more effectively operate and improve its website. These uses may include:

• Providing you with more effective customer service
• Making the website or services easier to access
• Performing research and analysis aimed at improving our products, services, and technologies
• Displaying content that is customized to your interests and preferences

We also use your personal information to communicate with you. We may send certain mandatory service communications such as welcome letters, billing reminders, information on technical service issues, and security announcements. We may also occasionally send you product surveys or promotional mailings to inform you of other products or services available from Fretwork and its affiliates, though these are rare and we try to keep these to a minimum.

Personal information collected on Fretwork sites and services may be stored and processed in the United States or any other country in which Fretwork or its subsidiaries or agents maintain facilities. By using a Fretwork site or service, you consent to any such transfer of information outside of your country.

Sharing of Your Personal Information
Except as described in this statement, we will not disclose your personal information outside of Fretwork and its controlled subsidiaries and agents without your consent.

We occasionally hire other companies to provide limited services on our behalf, such as:

• Handling the processing and delivery of mailings
• Providing customer support
• Design and hosting of our websites
• Processing transactions
• Performing statistical analysis of our services

Those companies will be permitted to obtain only the personal information they need to deliver the service. They are required to maintain the confidentiality of the information and are prohibited from using it for any other purpose.

We may access and/or disclose your personal information if we believe such action is necessary to:

1) Comply with the law or legal process served on Fretwork.

2) Protect and defend the rights or property of Fretwork (including the enforcement of our agreements).

3) Act in urgent circumstances to protect the personal safety of users of Fretwork services or members of the public.

Accessing Your Personal Information
If you wish to change or view the information kept by Fretwork about you or your organization, please contact your Fretwork at the above mailing address or e-mail address.

Communication Preferences
If you do not want Fretwork to contact you or your company for marketing purposes by e-mail, postal mail, fax and/or phone, you may opt out by contacting our customer service representatives via e-mail, or by writing to us at the above addresses.

Your Choice
You may choose to stop receiving communications from us at any time. To request removal from our mailing list, to access your personal information or to ask us to remove your personal information from our database, please send a message with your request to the Privacy Policy Manager at privacy-at-fretworksec.com.

Security of Your Personal Information
Fretwork is committed to protecting the security of your personal information. We use a variety of security technologies and procedures to help protect your personal information from unauthorized access, use, or disclosure. For example, we store the personal information you provide on computer systems with limited access, which are located in controlled facilities. Our personnel who have access to the data have been trained to maintain the confidentiality of such information. When we transmit highly confidential information over the Internet, we protect it through the use of encryption. Note that on our Contact page, we publish our company’s PGP encryption key, which can be used to send us confidential communication.

Internatonal Compliance
In years past, Fretwork self-certified compliance with EU-U.S. Safe Harbor Privacy Principles. In late 2015, however, the European Court of Justice declared that the existing rules for protecting data transferred between the United States and Europe, and were no longer valid. According to the ECJ’s final determination, Safe Harbor was virtually unenforceable since there was no longer any clear way for a company to really guarantee security and integrity.

This gave way to a follow-on program called Privacy Shield that ran from 2016 to 2020. On July 16, 2020, the ECJ issued a judgment declaring as “invalid” the protection provided by the EU-U.S. Privacy Shield. As a result of that decision, the EU-U.S. Privacy Shield Framework is no longer a valid mechanism to comply with EU data protection requirements when transferring personal data from the European Union to the United States. That said, the U.S. Department of Commerce will continue to administer the Privacy Shield program, including processing submissions for self-certification and re-certification to the Privacy Shield Frameworks and maintaining the Privacy Shield List.

Fretwork has tentatively self-certified with Privacy Shield:

Changes to This Privacy Statement
We will occasionally update this privacy statement to reflect changes in our services and customer feedback. When we post changes to this Statement, we will revise the “last updated” date at the top of this statement. If there are material changes to this statement or in how Fretwork will use your personal information, we will notify you either by prominently posting a notice of such changes prior to implementing the change or by directly sending you a notification. We encourage you to periodically review this statement to be informed of how Fretwork is protecting your information.