This is the Privacy Notice for Tutis Group Inc. dba Illuno and our affiliates and subsidiaries (collectively, “Illuno,” “us,” or “we”). It explains how we collect and use information via illuno.com and other websites and digital channels we own or operate (the “Site”), our world class platform for administering their officer programs (the “Platform”), and other services, solutions, and products we offer (altogether with the Site and Platform, the “Services”). Please read this Privacy Notice carefully to understand our privacy practices.

This Privacy Notice is governed by and part of our Terms of Use. Your use of our Services is subject to this Privacy Notice and our Terms of Use, including its applicable limitations on damages and the provisions regarding resolution of disputes. Capitalized terms not defined in this Privacy Notice have the meanings given to them in the Terms of Use. Any additional notices we may provide you about our privacy practices will be considered to form part of this Privacy Notice.

If you have questions about our privacy practices or would like to make a complaint, please contact us at privacy@illuno.com.

CONSENT

By using or accessing our Services in any manner, you acknowledge and accept this Privacy Notice, and you consent to Illuno’s collection, use, and disclosure of your information as described below. If you do not agree with this Privacy Notice, do not use our Services.

PERSONAL INFORMATION

As used in this Privacy Notice, “Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household, such as:

• Identifiers (e.g., name, address, username, IP address, email address);

• Protected Information (e.g., race, citizenship, marital status, sex);

• Biometric information (e.g., DNA, face/voice prints, health data) and audio, electronic, visual, thermal, olfactory, or similar information;

• Commercial information (e.g., products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies);

• Employment-related information (e.g., current or past employment);

• Non-public educational information, including information protected under the Family Educational Rights and Privacy Act (20 U.S.C. § 1232g, 34 C.F.R. Part 99);

• Internet activity (e.g., interactions with a website, content, or advertisement);

• Sensitive information (e.g., social security or government ID number; precise geolocation; racial or ethnic origin; biometrics; health information; union membership; contents of messages when we are not the recipient); and

• Inferences drawn from Personal Information to create a profile about preferences, characteristics, trends, predispositions, behavior, attitudes, and aptitudes.

Please note that information collected or processed in connection with your employment, publicly available information, aggregated information (data about a group or category of services or users from which individual identities and other Personal Information has been removed), and deidentified information that cannot reasonably be linked back or used to infer information about an individual are data types often excluded from privacy law protections includes.

MINIMUM AGE AND CHILDREN’S PRIVACY

You must be at least 18 years old to register with Illuno. We do not knowingly collect Personal Information from individuals under 18, and we reserve the right to delete account information if we discover an individual under 18 has registered with Illuno. In no case do we knowingly collect information from children. If we discover that a child has provided us with Personal Information, we will delete such information from our systems. If you believe we might have any information collected online from a child, or if you become aware of any unauthorized submission of information to us, please contact us at privacy@illuno.com.

INFORMATION WE COLLECT AND HOW WE USE IT

The types of Personal Information we collect about you and the manner of collection depend on how you interact with us, whether as an officer registered with Illuno (“Officer”), a registered Illuno client (“Client”), a law enforcement agency (“Agency”) or private security company (“Security Company”), or other user of the Services. We only collect, use, retain, and disclose Personal Information as is adequate and relevant to the specific, express purposes described below or as reasonably necessary and proportionate to provide the Services or for other purposes that we disclose to you and are compatible with the context of how we collected your Personal Information.

Categories of Personal Information

During the preceding 12 months, we have collected identifiers, employment-related information, sensitive information, and internet and similar activity. We collect Personal Information about you directly from you, from your Agency, and indirectly from your use of the Services, as follows:

• Officers: If you register with Illuno as an Officer, we collect your identifiers (e.g., name, mailing address, phone, and email), employment-related information (e.g., title, Agency), sensitive personal information (e.g., date of birth, social security number or tax ID) and other Personal Information necessary to facilitate our Clients’ ability to hire and pay you via the Services. We collect this information directly from you with your consent. If your Agency uses Illuno to facilitate their officer programs, we may receive some or all this information from your Agency administrator in our role as a service provider to your Agency. Once registered and approved by Illuno, Officers can use Illuno to accept Jobs, clock in/clock out, submit timesheets, and manage their Personal Information on the Platform.

• Agency or Security Company: If you use the Services on behalf of an Agency or Security Company, Illuno will collect your identifiers and employment-related information like your name, email, and title to register you as the account admin. Once registered as an admin, you can use the dashboard to approve requests, staff Officers, manage contracts, receive payments for Officer services, and access real time data for Officer staffing and scheduling. If you use the messaging feature, Illuno will have access to and process any Personal Information you choose to include in your messages. We collect and use this information with your consent and in our role as a service provider to the Agency or Security Company. Illuno uses this information to facilitate your use of the Platform dashboard on behalf of your Agency or Security Company and to communicate with you about the Services.

• Clients: If you register as the point of contact for a Client using Illuno to hire Officers, we will collect your identifiers and employment-related information like your name, email, and title. As a registered Client point of contact you can request Officers, manage Events, and facilitate payments. If you use the messaging feature, Illuno will have access to and process any Personal Information you choose to include in your messages. We collect this information directly from you with your consent in our role as a service provider to the Client. We use this information to facilitate the Client’s use of the Services, including your use of the Platform, Client dashboard and communications with you as the Client point of contact.

• Our mobile applications: The original Illuno mobile application does not collect any Personal Information or tracking data, but we may release subsequent mobile applications that request privacy permissions to collect Personal Information and other data from your device camera, microphone, GPS, or other functionalities. Any Personal Information that may be collected via our mobile applications is collected with your consent and is used to facilitate your use of the mobile application or other aspects of our Services.

• Inquiries: If you contact us via the Site or by email, phone, or other means to request information or support, we will collect your name, contact information, and employment-related information as needed to respond to your inquiry. We collect this information with your consent, and we use it for the purposes stated at the time of collection.

• Technical Information: When you visit the Site or use the Platform, we automatically collect technical information that may include some Personal Information. More specifically, we collect your device data (e.g., IP address, device ID, mobile network information) and usage details (e.g., session active time, referring URL, content viewed, functions completed). We collect this information to achieve our legitimate interest of providing and improving our Services.

We will not collect additional categories of Personal Information or use already collected Personal Information for purposes that are materially different, unrelated, or not reasonably necessary or compatible with the original purpose without notice and consent to you as required by law. We will update this Privacy Notice or otherwise notify you before we collect additional categories of Personal Information or use your Personal Information for purposes that are incompatible with the purpose stated at the time of collection.

Other Uses

Illuno might also use your Personal Information for any purpose with your consent or to send you support messages, monitor your compliance with our agreements, prevent or investigate fraud or illegal activity, protect your privacy or ours, bring legal action as we deem necessary, or to comply with the law or a court order.

Payroll and Payment Processing

Illuno is not a payment processor. All debits and credits made through the Services are processed by a PCI-compliant payment processor. If you are an Officer using Illuno through your Agency, please direct questions about payments or payroll to your Agency administrator.

RETENTION OF PERSONAL INFORMATION

Illuno retains all categories of Personal Information we collect only as long as your Illuno account remains active or as necessary to provide you with the Services you request. We may also retain and use Personal Information to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. We regularly review and deidentify unnecessary Personal Information and other data and we periodically deidentify unused accounts.

DISCLOSING PERSONAL INFORMATION

• Your Agency: If you are an Officer using Illuno through your Agency, your Agency will have access to certain information from your use of Illuno such as the Jobs you accept, your schedule, and information related to your receipt of payment for those Jobs. Your Agency uses this information for scheduling, payroll, and other purposes according to the Agency’s own policies and practices. Your Agency may integrate this information into its on-duty staffing software.

• Clients: If you are a Client and post a Job on the platform, we may disclose Personal Information like your contact information, email address, schedule, credentials, and Agency contact information as needed for the Officers to work the Job. A Client may receive the name and/or a phone number for the Officer(s) assigned to the Job posted by the Client. Illuno will only disclose Personal Information as needed to staff the Job, for Officers to work the Job, to facilitate Officer payment, and to communicate with Officers and Agencies as part of the Services.

• Service Providers: Illuno uses a variety of service providers such as data hosting companies, analytics services, email hosting services, and payment processors. The type of information that we share with a service provider will depend on the service that they provide to us. Our service providers are subject to contractual agreements that protect your Personal Information, and we require all service providers to maintain confidentiality standards that are commercially reasonable to ensure the security of your Personal Information. However, the use of your Personal Information by our service providers is ultimately governed by their privacy notices and is not within our direct control.

• Government Agencies: Occasionally Illuno may be required by law enforcement or judicial authorities to provide Personal Information to governmental authorities. We fully cooperate with law enforcement agencies in identifying those who use our Services for illegal activities. Illuno reserves the right to disclose Personal Information to law enforcement and other governmental agencies, at our sole discretion in connection with an investigation of any matter that is illegal or that could expose Illuno or our affiliates to liability.

• Affiliates and Third Parties: We may disclose the Personal Information we collect about you to our affiliates like a parent company or subsidiaries. For example, we share Personal Information for Client support purposes, marketing, or technical operations. Under specific circumstances, we may disclose Personal Information to certain third parties as permitted by applicable law, for example: if we go through a business transition (e.g., merger, acquisition, or asset sale); to comply with a legal requirement or a court order; when we believe it is appropriate to take action regarding illegal activities or prevent fraud or harm to any person; to exercise or defend our legal claims; or for any other reason with your consent.

• Aggregated and Deidentified Information: We reserve the right to disclose aggregated, anonymized, or deidentified information about any individuals with affiliated or nonaffiliated entities for marketing, advertising, research, or other purposes, without restriction. For example, we may share reports showing trends about the general use of our Services without identifying an individual.

YOUR CONTROLS

Illuno believes you should have the ability to control the Personal Information we collect and hold about you on your own. You can use the methods described below to control how we collect and use your Personal Information.

• Your Account: You can change or delete the Personal Information in your account at any time by signing into the Platform and editing your information or changing your settings. Illuno may offer instructions to guide you in making additional changes. You can delete all of your Personal Information on Illuno by closing your account. Closing your account may not free up your email address, or username for reuse on a new account. Note that you may not be able to change or delete all types of information. For example, you cannot delete records of your Jobs and payments because we need this data for our business purposes or legal obligations.

• Email Communications: Illuno will send you service announcements or administrative communications by email. You receive these emails as part of your use of the Services, and you will not be able to opt out. Illuno may also send Officers emails about Job openings or new programs or opportunities made available through Illuno. Depending on your communication preferences, we may also send you marketing emails. If you do not wish to receive marketing emails from us, you may change your preferences via the Unsubscribe link in the email or by sending an opt-out request to privacy@illuno.com. Note that if you opt out of marketing emails, Illuno will continue to send you non-promotional emails, such as those about your account, platform specific notifications or our ongoing business relations.

• Texting Consent: If you provide us with your wireless phone number, you consent to Illuno sending you informational or service text messages. However, we will only send you marketing text messages if you opt-in to receive these notifications from us. For all Illuno text messages, the number of texts you receive will depend on the Services you use and the information you request from us. You can unsubscribe from Illuno text messages by changing your texting preference from within the platform or by replying STOP or UNSUBSCRIBE to any of these text messages. Messaging and data charges may apply to any text message you receive or send. Please contact your wireless carrier if you have questions about messaging or data charges.

• Do Not Track: Do Not Track signals are signals sent through a browser informing us that you do not want to be tracked. Currently, our systems do not recognize browser “do-not-track” requests. If this changes in the future, we will update this Privacy Notice.

• Privacy Requests: If you wish to exercise your privacy rights beyond the methods available through the Platform, or if you want to express concerns, lodge a complaint, or request information, please submit a verifiable Privacy Request by sending an email to privacy@illuno.com.

  Illuno can only fulfill a Privacy Request when we have sufficient information to verify that the requester is the person or an authorized representative of the person about whom we have collected Personal Information, and to properly understand, evaluate, and respond to the request. We do not charge a fee to process or respond to a verifiable request unless we have legal grounds to do so. 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.

  We endeavor to respond to Privacy Requests in accordance with the requirements of the law applicable to your jurisdiction. Depending on the circumstances and the nature of your request, we may be unable to fulfill your request in part or in whole, for example, if your request falls within a statutory exception or if fulfilling your request would prevent us from complying with a statutory or contractual obligation. If we do not fulfill your request within the legally required timeline, you can appeal our response by contacting privacy@illuno.com.

YOUR PRIVACY RIGHTS

Depending on where you live, you may be entitled to exercise certain rights over your Personal Information. In the United States, consumer privacy is governed by federal privacy laws covering specific industries or data uses and state privacy laws providing with general consumer privacy rights. This section provides informational notices for state privacy governing California, Colorado, Connecticut, Iowa, Nevada, Oregon, Tennessee, Texas, Utah, Virginia, and a growing list of additional states require companies to inform consumers about their privacy rights and provide a method to exercise those rights. Residents of states offering privacy protections (each a “Consumer”) can exercise their privacy rights as applicable to our Services by submitting a Privacy Request.

• Right to Know: Illuno provides the required information for a consumer’s right to know in this Privacy Notice. We may provide you with additional notices about other ways we process your Personal Information, such as by sending you a notice via email or posting information on the Services.

• Right to Reasonable Expectations: You can expect Illuno to collect, use, or disclose your Personal Information responsibly and not for any other purpose other than as stated at the time of collection or described in this Privacy Notice. If we collect or use your Personal Information based on your consent, we will also notify you of any changes and will request your further consent as required by law. You may withdraw your consent at any time with reasonable notice by contacting privacy@illuno.com.

• Right to Accuracy, and the Right to Correct. You can correct or update your Personal Information held by Illuno by contacting privacy@illuno.com.We will update our records to reflect your accurate information.

• Right to Access. Illuno will provide you with a copy of your Personal Information held by us upon your request and where required by law, along with details about the types of Personal Information we process, why we process it, and any third parties we work with to collect Personal Information on our behalf. Certain laws may limit the scope or frequency of requests we must fulfill.  

• Right to Deletion. Upon your request and when required by law, we will delete your Personal Information from our systems. This right is not absolute, and we may be entitled to retain and process your Personal Information despite your request. If you make this request, we balance certain legal, contractual, and business interests against your right to request the deletion of your Personal Information.

• Right to Data Portability. In some cases, we are required to provide your Personal Information to another organization at your request and in a structured, commonly used machine-readable format, so that the other organization can read and use it.

• No Sale or Sharing of Personal Information. Some jurisdictions entitle consumers to opt out of the sale of their Personal Information or sharing of Personal Information for cross-contextual behavioral advertising purposes. Illuno does not sell your Personal Information or share your Personal Information with third parties for cross-contextual advertising purposes.

• Limited Use and Disclosure of Sensitive Personal Information. In no case will Illuno use or disclose any sensitive Personal Information for the purpose of inferring characteristics about you.

• Right to Non-Discrimination. If you reside in a jurisdiction that extends a right to non-discrimination related to the exercise of privacy rights, we will not (i) deny you goods or services, (ii) charge you different prices or rates for goods or services, (iii) provide you a different level or quality of goods or services, (iv) retaliate against you as an employee, applicant for employment, or independent contractor; or (v) suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services, because you exercised your statutory right unless permitted by law.

• Right to Disclosure. You may have a right to request information about how we collect and use your Personal Information, such as (i) the categories of Personal Information we have collected about you; (ii) the categories of sources for the Personal Information we have collected about you; (iii) our business purpose for collecting, using, disclosing, or selling that Personal Information, as applicable; and (iv) the categories of third parties with whom we disclose that Personal Information. Illuno does not sell or share your Personal Information, but if we did you could request two separate lists stating: (a) sales, identifying the Personal Information categories that each category of recipient purchased; and (b) sharing for a business purpose, identifying the Personal Information categories that each category of recipient obtained. Certain laws may limit the number or frequency of requests we must fulfill.   

• No Automated Decision-Making or Profiling. Illuno does not use automated decision-making or any form of automated processing of Personal Information to evaluate, analyze, or predict your performance, preferences, choices, or behavior. We may use automation tools to evaluate user registrations or Jobs for approval. If we do, we make human oversight available to analyze or reconsider decisions made via automated processes.

• Right to Restrict Processing. You may have the right to request that we restrict the processing of your Personal Information if (i) the data is inaccurate, (ii) the processing is unlawful, (iii) we no longer need the Personal Information, or (iv) you exercise your right to object. Your right to restrict may be limited to Personal Information that is sensitive in nature, or that is sold or shared for certain purposes.

• Right to Object. You may have the right to request, under certain circumstances and where we are required to do so by law, that we limit our processing of your Personal Information as you request.

• Right to Disclosure of Marketing Information. If you are a resident of the State of California, California’s Shine the Light Act (Civil Code sections 1798.83-1798.84) entitles California consumers to request certain disclosures regarding Personal Information sharing with affiliates and/or third parties for marketing purposes.

• Health Data Rights. Illuno does not collect any health data. Some laws entitle consumers to certain details about health data collected about them, including (i) confirmation of whether the entity collects, shares, or sells the consumer’s health data and access that data, including a list of all third parties and affiliates with whom the entity has shared or sold the health data and a method to contact those third parties, (ii) a method to withdraw consent related to use of health data, and (iii) the right to have their health data be deleted.

Consumers may exercise these rights by submitting a Privacy Request to privacy@illuno.com. Only you or someone legally authorized to act on your behalf may make a verifiable Privacy Request related to your Personal Information. You may also make a verifiable Privacy Request on behalf of your minor child. You may designate a third party to exercise your rights – an authorized agent – however we will require written proof of the authorization and potentially proof of your identity.

COOKIES

Illuno may use cookies and other tracking technologies on the Services to track engagement, manage, and improve the Services. Cookies are small text files downloaded and stored on your device when you visit a website or other platform. Cookies are generally used for functionality, security, analytics, or advertising. Some cookies are strictly necessary to the function of the website or other platform, while others enable certain features.

Illuno uses the following functionality cookies on the Services:

• Intercom cookies intercom-session-ou98qnue, intercom-id-ou98qnue, and intercom-device-id-ou98qnue to identify unique browser sessions and devices for session tracking.

• Amazon Web Services cookies AWSALBCORS and AWSALB support data processing and load balancing.

None of the cookies used on our Services are essential. This means you can set your browser or device to refuse all or some cookies or to alert you when cookies are being sent. You can also install third-party plugins to control cookie behavior. If you disable or refuse cookies or block the use of other tracking technologies, some parts of the Services may then be inaccessible or not function properly. If you get a new device, install a new browser, or erase or otherwise alter your device’s cookie file or privacy settings, your privacy preferences may not be saved. If you disable or refuse cookies or block the use of other tracking technologies, you will be able to use certain features, but some or all features may not function properly.

Illuno does not link data automatically collected by cookies and similar technologies to your Personal Information. Third parties may also set cookies on the Services to collect information about you when you use the Services. We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the advertiser directly.

DATA SECURITY

Illuno implements reasonable and appropriate security procedures and practices to help protect your Personal Information from unauthorized or illegal access, destruction, use, modification, or disclosure. Illuno follows the Open Web Application Security Project (OWASP) best practice security standards with regards to platform security. We encrypt all data at rest as well as in transit to prevent unauthorized parties from viewing the data, including your Personal Information, when it is transmitted to us. All data is stored on secure servers and is only accessible to our personnel and contractors via encrypted password and on an as needed basis. We ensure that Illuno employees, contractors, and agents responsible for handling your inquiries are informed of applicable privacy law requirements and we restrict access to those who need that information to process it. Our security measures are appropriate to the volume, scope, and nature of the Personal Information processed and designed to meet our duty of care with respect to your Personal Information.

Please note, however, that no transmission of data over the Internet is 100% secure. We cannot guarantee that unauthorized third parties will not defeat our security measures, use your Personal Information for improper purposes. We also have no control over the security measures or practices of the Agencies and Clients that use our Services, and we make no representations or guarantees that your Personal Information is secure once transmitted or stored on their systems.

It is your responsibility to keep your Illuno account secure from unauthorized access. If you have an account with Illuno, we encourage you to take steps to protect against unauthorized access to your account. These steps include, without limitation, choosing a robust password that nobody else knows or can easily guess, keeping your password private, and signing off after using a shared computer or other device. Illuno is not responsible for any lost, stolen, or compromised passwords, or any unauthorized activity on your account.

CONSENT TO DATA TRANSFERS

Illuno is owned and operated in the United States and is intended for use by users living in the United States or Canada. We do not warrant that Illuno is appropriate or authorized for use in any other jurisdictions. If you use Illuno from outside of the United States, Personal Information we collect about you will be transferred to our servers in the United States and maintained there indefinitely. This may require the transfer of your Personal Information out of your country of origin with laws governing data collection and use that may differ from or be more restrictive than U.S. law, or may result in governments, courts, law enforcement or agencies having access to or obtaining disclosure of your Personal Information pursuant to the laws of the applicable foreign jurisdiction. You are responsible for determining whether this Privacy Notice and Illuno comply with the laws that apply to you. By allowing us to collect Personal Information about you, you consent to the transfer and processing of your Personal Information as described in this paragraph.

THIRD PARTY WEBSITES

The Services may contain links to websites owned or operated by third parties. We have no ability to control, and we are not responsible for, the privacy and data collection, use, and disclosure practices of third-party websites. We encourage you to read the privacy statements of each website that collects your Personal Information.

CONSENT TO DATA TRANSFERS

We may periodically update this Privacy Notice. If we make any material changes, we will notify you by updating this posting or by posting notice in the Services. The date that this Privacy Notice was last revised is identified at the top of the page. Your continued use of the Services after the effective date will be subject to the new Privacy Notice. You are responsible for periodically checking this Privacy Notice for changes.