Privacy Policy - Netswitch Technology Management

Effective Date: March 23, 2025 | Last Updated: March 23, 2025

This Privacy Policy describes how Netswitch Technology Management, Inc. (“Netswitch”, “we”, “us” or “our”) collects, uses, discloses, and safeguards personal information when you visit our website at www.netswitch.net, use our services, or interact with us in any capacity. Please read this policy carefully. By accessing our website or services, you acknowledge the practices described here.

If you have questions or concerns about our privacy practices, see Section 12 (Contact Us) at the end of this Policy.

1. Information We Collect

1.1 Information You Provide Directly

When you contact us, request a demonstration, subscribe to our communications, or engage with our services, you may provide:

Name and job title
Company name and industry
Business email address and phone number
Mailing or billing address
Information submitted through contact or inquiry forms
Communications you send us by email or other channels

1.2 Information Collected Automatically

When you visit our website, we and our service providers may automatically collect certain technical and usage information, including:

IP address and approximate geographic location
Browser type, version, and operating system
Pages visited, time on page, and referring URLs
Device identifiers and diagnostic data
Cookie and tracking technology data (see Section 4)

1.3 Information from Third Parties

We may receive information about you from third parties such as business partners, event organizers, or professional networks where you have made your information available for business purposes.

2. How We Use Your Information

We use personal information for the following purposes:

To provide and manage our services: Fulfilling service agreements, managing accounts, and delivering assessments, reports, and platform access.
To communicate with you: Responding to inquiries, sending service-related updates, security notifications, and information about products or events you have expressed interest in.
To improve our website and services: Analyzing usage patterns, diagnosing technical issues, and evaluating the effectiveness of our communications.
To meet legal obligations: Complying with applicable laws, regulations, and court orders; responding to lawful requests from public authorities.
For business continuity and transfers: Evaluating or completing mergers, acquisitions, or other business transactions in which your data may be among the transferred assets.
With your consent: For any purpose where you have provided express consent.

3. How We Share Your Information

We do not sell your personal information. We may share it in the following limited circumstances:

Service providers: We work with vendors who process data on our behalf under contractual obligations to protect your information (e.g., hosting, analytics, email delivery, security tools).
Affiliates: We may share information with subsidiaries or affiliated entities under common control with Netswitch, who are bound by this policy.
Business partners: With your consent, or in connection with joint service offerings.
Legal compliance: When required by law, subpoena, court order, or government authority, or to protect the rights, property, or safety of Netswitch, our clients, or others.
Business transactions: In connection with a merger, acquisition, financing, or sale of business assets. We will notify you before your personal data is subject to a materially different privacy policy.

4. Cookies and Tracking Technologies

4.1 Types of Cookies We Use

Our website uses cookies and similar technologies. We do not use Flash Cookies or other deprecated tracking mechanisms. Current technologies include:

Necessary / Essential Cookies (Session): Required for core website functionality. Cannot be disabled without impairing the service.
Functionality Cookies (Persistent): Remember your preferences (e.g., language settings) to improve your experience.
Analytics Cookies (Persistent): Help us understand how visitors interact with the website so we can improve it. Data is aggregated and anonymized where possible.

4.2 Managing Cookies

You can instruct your browser to refuse all cookies or to alert you when cookies are being sent. However, disabling certain cookies may limit your ability to use parts of our website. To manage cookies, consult your browser settings. For more information about online advertising and optout tools, visit optout.aboutads.info or www.youronlinechoices.eu.

5. Data Retention

We retain personal data only as long as necessary to fulfill the purposes described in this policy, or as required by law. Factors we consider include:

The nature of the data and our relationship with you
Legal, regulatory, or contractual retention requirements
Whether data is needed to resolve disputes or enforce agreements

When personal data is no longer required, we securely delete or anonymize it.

6. Data Security

We implement administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, alteration, disclosure, or destruction. As a cybersecurity company, security is central to how we operate.

However, no method of transmission over the internet or electronic storage is 100% secure. We cannot guarantee absolute security. In the event of a data breach affecting your personal information, we will notify affected individuals and relevant authorities as required under applicable law, including California law (Cal. Civ. Code § 1798.82) and any other applicable breach notification statutes.

7. International Data Transfers

Netswitch is headquartered in South San Francisco, California, United States, and operates internationally including through its Asia Pacific office in Hong Kong. Your personal information may be processed in the United States or other jurisdictions where our service providers operate.

When we transfer personal data across borders, we take steps to ensure appropriate safeguards are in place consistent with applicable law, including the requirements of the EU General Data Protection Regulation (GDPR) for transfers from the European Economic Area, and the requirements of Hong Kong’s Personal Data (Privacy) Ordinance (PDPO) for data relating to Hong Kong residents.

8. Your Privacy Rights

8.1 All Users

Regardless of your location, you may:

Request access to the personal information we hold about you
Request correction of inaccurate or incomplete information
Opt out of marketing communications at any time by following unsubscribe instructions or contacting us directly
Request deletion of your personal information, subject to legal retention requirements

8.2 California Residents (CCPA / CPRA)

If you are a California resident, the California Consumer Privacy Act (CCPA) and the California
Privacy Rights Act (CPRA) grant you the following rights:

Right to Know: You may request disclosure of the categories and specific pieces of personal information we have collected about you, the categories of sources, the business or commercial purposes for collection, and the categories of third parties with whom we share it.
Right to Delete: You may request that we delete personal information we have collected from you, subject to certain exceptions.
Right to Correct: You may request that we correct inaccurate personal information we maintain about you.
Right to Opt Out of Sale or Sharing: We do not sell your personal information and do not share it for cross-context behavioral advertising purposes.
Right to Limit Use of Sensitive Personal Information: We do not collect or use sensitive personal information beyond what is permitted under the CPRA without your consent.
Right to Non-Discrimination: We will not discriminate against you for exercising any of your CCPA/CPRA rights.

To exercise your rights, contact us as described in Section 12. We will verify your identity before processing your request. You may designate an authorized agent to make a request on your behalf.

California residents may also review our practices under the California “Shine the Light” law (Cal. Civ. Code § 1798.83) regarding sharing of personal data with third parties for their direct marketing purposes. We do not share your personal data with third parties for their own direct marketing without your consent.

8.3 European Economic Area and UK Residents (GDPR / UK GDPR)

If you are located in the EEA or the United Kingdom, you have rights under the General Data Protection Regulation (GDPR) or UK GDPR, including:

Right of access to your personal data
Right to rectification of inaccurate data
Right to erasure (“right to be forgotten”) in certain circumstances
Right to restriction of processing
Right to data portability
Right to object to processing based on legitimate interests or for direct marketing
Right to withdraw consent at any time (where processing is based on consent)

Our lawful basis for processing your personal information is typically: performance of a contract (where you are a client or prospective client), compliance with legal obligations, or our legitimate business interests (e.g., improving our services, security operations), balanced against your rights. You may lodge a complaint with your local data protection authority. In the EU, a list of authorities is available at edpb.europa.eu.

8.4 Hong Kong Residents (PDPO)

If you are located in Hong Kong, Netswitch’s collection and use of your personal data is subject to the Personal Data (Privacy) Ordinance (Cap. 590) (PDPO). You have the right to request access to, and correction of your personal data as held by us. To make such a request, please contact us using the information in Section 12.

9. Children’s Privacy

Our website and services are not directed to individuals under the age of 18. We do not knowingly collect personal information from minors. If we become aware that we have collectedpersonal data from a person under 18 without appropriate consent, we will take prompt steps to delete that information. If you believe a minor has submitted personal information to us, please contact us immediately.

10. Links to Third-Party Websites

Our website may contain links to third-party websites not operated by us. This Privacy Policy applies only to Netswitch’s website and services. We have no control over, and assume no responsibility for, the content or privacy practices of third-party sites. We encourage you to review the privacy policy of any site you visit.

Changes to This Privacy Policy

We may update this Privacy Policy periodically to reflect changes in our practices, technology, legal requirements, or for other operational reasons. When we make material changes, we will update the “Last Updated” date at the top of this document and, where appropriate, notify you by email or by a prominent notice on our website.

We encourage you to review this policy periodically. Continued use of our website or services after any changes constitutes your acknowledgment of the updated policy.

Contact Us

If you have questions about this Privacy Policy, wish to exercise your privacy rights, or have a complaint about our data practices, please contact us:

Netswitch Technology Management, Inc.

611 Gateway Blvd., Suite 120
South San Francisco, CA 94080
United States

For requests under CCPA, GDPR, or PDPO, please indicate your jurisdiction and the specific right you wish to exercise so we can respond appropriately and within the required timeframe.