Privacy Policy | Beryllium InfoSec Collaborative

Privacy Policy Effective date: 01 January 2020

Beryllium, LLC., dba Beryllium InfoSec Collaborative is a cyber security consultancy providing information security risk assessment services with a focus on assisting smaller businesses in the defense industrial base to better secure their data from exfiltration by agents of adversarial nation states. Our flagship product is CUICK TRAC™ a secure virtual environment to lock down proprietary and sensitive data.

This Privacy Policy sets out our policies regarding the collection, use and disclosure of personal data when you engage with us via our website or during the period you retain us for our operational services, as well as any choices you may have communicated to us with regard that data.

We may your data to provide and improve the user experience on this website. By using the website, you agree to the collection and use of information in accordance with this policy.

Definitions

Website: is the https://www.berylliuminfosec.com website operated by Beryllium
Personal Data Personal Data means one or more data points about a living individual who can be identified from those data points (or from additional data points or other information either in our possession or likely to come into our possession).
Usage Data: Usage Data is data collected automatically either generated by the use of the website or from the intrinsic website infrastructure itself (for example, for example the downloading of a case study, or the dwell time on a specific webpage ).
Cookies: Cookies are small files stored on your device (computer or mobile device).
Data Controller: Data Controller is a term developed under the General Data Protection Regulation and means the natural or legal person (a company is a legal person) who either alone, jointly or in concert with additional persons) determines the purposes for which and the manner in which any personal information are, or are to be, processed. For the purpose of this Privacy Policy, Beryllium may be, in certain circumstances, is a Data Controller of your Personal Data.
Data Processors (or Service Providers): Data Processor (or Service Provider) means any natural or legal person who processes the data on behalf of the Data Controller. It is possible that upon occasion, Beryllium may use the services of various Service Providers in order to process your data more effectively.
Data Subject (or User) A Data Subject/User is any living individual who is using our website or has retained us for an engagement; and is the subject of Personal Data.

Information Collection and Use

We collect several different types of information for various purposes to provide and improve our website and professional services to you.

Types of Data Collected

Personal Data

While using our website, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). Personally identifiable information may include, but is not limited to:

Email address
First name and last name
Phone number
Cookies and Usage Data

We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or the instructions provided in any email we send.

Usage Data

We may also collect information on how the website is accessed and used (“Usage Data”). This Usage Data may include information such as your computer’s Internet Protocol address ( IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers including mobile devices, and other diagnostic data.

Tracking & Cookies Data

We use cookies and similar tracking technologies to track the activity on our website and we may hold certain information that derives from the use of those technologies.

Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies are also used such as beacons, tags and scripts to collect and track information and to determine how we can improve our website and user experience.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to fully use some portions of our website

Examples of Cookies we use:

Session Cookies:We use Session Cookies to operate our website.
Preference Cookies:We use Preference Cookies to remember your preferences and various settings.
Security Cookies:We use Security Cookies for security purposes.

Use of Data

Beryllium uses the collected data for various purposes, which may include:

To provide and maintain our website.
To notify you about changes to our website.
To allow you to participate in any interactive features of our website when you choose to engage with those features.
To provide customer support.
To gather diagnostic information so that we can improve our website.
To monitor the usage of our website.
To detect, prevent and remedy technical issues.
To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information.

Legal Basis for Processing Personal Data under the General Data Protection Regulation (GDPR)

At the effective date of this Privacy Policy, Beryllium does not actively market our services in the EuroZone. However, the nature of our services are such that our clients can be located around the globe. Therefore, if you reside within the European Economic Area (EEA), our legal basis for collecting and using the personal information described in this Privacy Policy depends on the types of Personal Data we collect and the specific context in which we collect it.

For example:

Beryllium may process your Personal Data because:

We need to perform a contract or engagement with you.
You have given us permission to do so.
The processing is in our legitimate interests and it is not overridden by your rights.
To comply with the provisions and requirement of the GDPR.

Retention of Data

Beryllium will retain your Personal Data only for as long as is necessary for the purposes set forth in this Privacy Policy. We will retain and use your Personal Data only to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes and enforce our legal agreements and policies.

Beryllium will also retain Usage Data for the purpose of internal analysis. Usage Data is generally retained for a shorter length of time, except when this data is used to strengthen the security or to improve the functionality of our website, or we are legally obligated to retain this data for longer periods.

Transfer of Data

Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.

If you are located outside the United States and choose to provide information to us, please note that we may transfer the data, including Personal Data, to United States and process it there.

Your consent to this Privacy Policy, as amended from time to time, and followed by your submission of such information is deemed to represent your agreement to that transfer.

Beryllium will take all the steps reasonably necessary to ensure that your data is treated securely while your Personal Data is under Beryllium control. Additionally, and in accordance with this Privacy Policy any transfer of control of your Personal Data will be only be sent to an organization or a country if that organization or country represents and warrants that there are adequate controls in place to assure the security of your data and other personal information.

Disclosure of Data

Business Transaction

If Beryllium is involved in a merger, acquisition or asset sale, your Personal Data could be transferred to a successor entity. We will provide you notice before your Personal Data is transferred and becomes subject to a different Privacy Policy.

Disclosure for Law Enforcement

Under certain circumstances, Beryllium may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency with appropriate legal jurisdiction.)

Legal Requirements

Beryllium may disclose your Personal Data in the good faith belief that such action is necessary to:

To comply with a legal obligation
To protect and defend the rights or property of Beryllium
To prevent or investigate possible wrongdoing in connection with our website
To protect the personal safety of users of our website or the public
To protect against legal liability

Security of Data

The security of your data is important to us but remember that no method of transmission over the Internet or method of electronic storage can be guaranteed to be 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

Our Policy on “Do Not Track” Signals under the California Online Protection Act (CalOPPA)

Our website does not implement Do Not Track (“DNT”) for you. Do Not Track is a preference you can set in your web browser to inform websites that you do not wish to be tracked.

You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.

Your Data Protection Rights under the General Data Protection Regulation (GDPR)

If you are a resident of the European Economic Area (EEA), you have certain data protection rights. Beryllium aims to take reasonable steps to allow you to correct, amend, delete or limit the use of your Personal Data.

If you wish to be informed about what Personal Data we hold about you and if you want it to be removed from our systems, please contact us. Our Data Protection Officer is David Confeld, Vice President of Tech Ops., privacy@berylliumfosec.com

In certain circumstances, you have the following data protection rights:

The right to access, update or delete the information we have on you.Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.
The right of rectification.You have the right to have your information rectified if that information is inaccurate or incomplete.
The right to object.You have the right to object to our processing of your Personal Data.
The right of restriction.You have the right to request that we restrict the processing of your personal information.
The right to data portability.You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
The right to withdraw consent.You also have the right to withdraw your consent at any time where Beryllium relied on your consent to process your personal information.

Please note that we may ask you to verify your identity before responding to such requests.

You also have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).

Service Providers

We may employ third party companies and individuals to optimize the user experience of our website (“Service Providers”), or to provide the website delivery on our behalf, perform website connected services or assist us in analyzing how our website is being used.

These third parties have access to your Personal Data only to perform the above mentioned tasks on our behalf and are obligated not to disclose or use your data for any other purpose.

Analytics

We may use third-party Service Providers to monitor and analyze the use of our website.

Google Analytics (or successor services from Google.) Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our website. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network. You can opt-out of allowing your activity on the website to be available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js and dc.js) from sharing information with Google Analytics about visits activity. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page.

Links to Other Sites

Our website may contain links to other sites that are not operated by us. If you click a third-party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

Children’s Privacy

Our website is not intended for the use of anyone under the age of 18 (“Children”).

We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Child has provided us with Personal Data, please contact our Data Protection Officer. If we become aware that we have collected Personal Data from children without verification of parental consent, we will promptly take the necessary steps to remove that information from our servers.

Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

We will let you know via email and/or a prominent notice on our website, prior to the change becoming effective and update the “effective date” at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, please contact us:

By email: privacy@berylliuminfosec.com

PRIVACY STATEMENT-CALIFORNIA

This PRIVACY NOTICE FOR CALIFORNIA RESIDENTS supplements the information contained in the Privacy Statement of BERYLLIUM LLC (collectively, “we,” “us,” or “our”) and applies solely to visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws. Any terms defined in the CCPA have the same meaning when used in this notice.

Information We Collect

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:

‍

Category	Examples	Collected
A. Identifiers.	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.	YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.	YES
C. Protected classification characteristics under California or federal law.	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).	YES
D. Commercial information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	NO
E. Biometric information.	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	NO
F. Internet or other similar network activity.	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.	NO
G. Geolocation data.	Physical location or movements.	NO
H. Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information.	NO
I. Professional or employment-related information.	Current or past job history or performance evaluations.	YES
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	NO
K. Inferences drawn from other personal information.	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	NO

‍

Personal information does not include:

Publicly available information from government records.
De-identified or aggregated consumer information.
Information excluded from the CCPA’s scope, like:
health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

We obtain the categories of personal information listed above from the following categories of sources:

Directly from our clients or their agents. For example, from documents that our clients provide to us related to the services for which they engage us.
Indirectly from our clients or their agents. For example, through information we collect from our clients in the course of providing services to them.
Directly and indirectly from activity on our website (www.hornellp.com). For example, from submissions through our website portal or website usage details collected automatically.
From third-parties that interact with us in connection with the services we perform. For example, from government agencies when we prepare readiness assessments for projects that receive government funding.

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following business purposes:

To fulfill or meet the reason for which the information is provided. For example, if you provide us with personal information in order for us to prepare a tax return, we will use that information to prepare the return and submit it to the applicable taxing authorities.
To provide you with information, products or services that you request from us.
To provide you with email alerts, event registrations and other notices concerning our products or services, or events or news, that may be of interest to you.
To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections.
To improve our website and present its contents to you.
For testing, research, analysis and product development.
As necessary or appropriate to protect the rights, property or safety of us, our clients or others.
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
As described to you when collecting your personal information or as otherwise set forth in the CCPA.
To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:

Category A: Identifiers.
Category B: California Customer Records personal information categories.
Category C: Protected classification characteristics under California or federal law.
Category I: Professional or employment-related information.

We disclose your personal information for a business purpose to the following categories of third parties:

Our affiliates.
Service providers.
Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.

In the preceding twelve (12) months, we have not sold any personal information.

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

The categories of personal information we collected about you.
The categories of sources for the personal information we collected about you.
Our business or commercial purpose for collecting or selling that personal information.
The categories of third parties with whom we share that personal information.
The specific pieces of personal information we collected about you (also called a data portability request).
If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
sales, identifying the personal information categories that each category of recipient purchased; and
disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service providers to:

Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
Debug products to identify and repair errors that impair existing intended functionality.
Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
Comply with a legal obligation.
Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

Calling us at 763-546-8354
Visiting www.berylliuminfosec.com

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

Deny you goods or services.
Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
Provide you a different level or quality of goods or services.
Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Changes to Our Privacy Notice

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will notify you by email or through a notice on our website homepage.

Contact Information

If you have any questions or comments about this notice, our Privacy Statement, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

David Confeld (Data Protection Officer & Vice President of Tech Ops.)
715 Florida Ave S Ste 210
Minneapolis, MN 55426
763-546-8354
privacy@berylliumfosec.com