CONCENTRIC SILICON

Concentric Advisors, Inc. (“Concentric,” “Company,” “we,” “us,” or “our”) respects your privacy and is committed to protecting the personal data you share with us. As a global security and risk advisory firm, we understand the critical importance of data protection and handle all personal information in accordance with applicable laws, including the EU General Data Protection Regulation (“GDPR”), the California Consumer Privacy Act (“CCPA”), and other relevant privacy frameworks. We maintain technical and organizational measures consistent with ISO 27001 and ISO 27701 standards to protect the confidentiality, integrity, and availability of personal data.

This Privacy Policy (“Policy”) describes the types of information we may collect from you or that you may provide when you visit concentric.io or any of our other websites, applications, or digital services (each a “Site,” collectively the “Sites”), and our practices for collecting, using, maintaining, protecting, and disclosing that information.

Concentric is a trusted risk management firm providing security services, risk advisory, staffing solutions, global assistance, and medical support to high-net-worth families, corporations, and organizations worldwide. For more information about our services, please visit our Capabilities page.

Please read this Policy carefully. By accessing or using our Sites, you acknowledge that you have read, understood, and agree to the practices described herein. If you do not agree with our practices, your choice is not to use our Sites. This Policy may change from time to time, and your continued use of the Sites after we post changes constitutes acceptance of those changes.

Our Sites are intended for business use, and we do not knowingly collect any personal data from children under the age of eighteen (18). If we learn that we have collected personal information from a child under 18 without verification of parental consent, we will delete that information promptly. If you believe we may have collected information from or about a child under 18, please contact us at dpo@concentric.io.

We collect several types of information from and about users of our Sites, including:

Personal Data — Information by which you may be personally identified, such as your name, postal address, email address, telephone number, job title, company name, or any other identifier by which you may be contacted online or offline.

Usage Information — Information about your internet connection, the equipment you use to access our Sites, and usage details, including traffic data, location data, logs, referring URLs, and other communication data.

Technical Data — Information collected automatically as you navigate our Sites, which may include your IP address (shortened where applicable), browser type, operating system, device type, date and time of visit, and pages viewed.

We collect personal data through several means:

Directly from you — When you fill in forms on our Sites, submit inquiries through our contact page, request information about our services, apply for employment, subscribe to communications, or correspond with us via email, phone, or other channels.

Automatically — As you navigate our Sites, we may use cookies, web beacons, and other automatic data collection technologies to gather information about your equipment, browsing actions, and patterns.

From third parties — We may receive information about you from our business partners, affiliates, or other third-party sources in connection with the services we provide.

We process your personal data in accordance with applicable data protection laws, including Article 6 of the GDPR, on the following legal bases:

Legitimate interests — When processing is necessary for our legitimate business interests, provided those interests are not overridden by your rights and freedoms. This includes operating and improving our Sites, conducting analytics, and ensuring network security.

Consent — When you have given us clear consent to process your personal data for a specific purpose, such as submitting an inquiry through our contact form, subscribing to our communications, or accepting cookies.

Contractual necessity — When processing is necessary to perform a contract with you or to take steps at your request before entering into a contract. Legal obligation — When processing is necessary to comply with a legal obligation to which Concentric is subject.

We use the information we collect about you for the following purposes:

To present our Sites and their contents to you and to ensure they function properly. To provide you with information, products, or services that you request from us. To communicate with you regarding inquiries, service requests, and prospective business relationships. To process employment applications submitted through our Sites or affiliated platforms. To fulfill any other purpose for which you provide the information. To compile analytics and statistics to improve our Sites and services. To ensure the security and stability of our systems. To carry out our obligations and enforce our rights arising from any contracts entered into between you and us. To comply with applicable legal, regulatory, and compliance requirements. To notify you about changes to our Sites or any services we offer or provide through them.

We share your personal data with third parties outside of Concentric only insofar as this is legally permitted or required, and we limit the transfer of your personal data to what is necessary for the respective purpose.

Within the Concentric Group — We may share your personal data between and among Concentric Advisors, Inc. and its affiliates and subsidiaries for internal business and operational purposes, as well as for purposes consistent with the purpose for which the information was originally collected.

With service providers — We may share your personal data with third-party vendors and service providers who perform services on our behalf, such as hosting, analytics, and marketing. These providers are contractually required to use the information exclusively for the services rendered on our behalf and to comply with applicable data protection regulations.

For legal purposes — We may disclose your personal data to comply with any court order, law, or legal process, including responding to any government or regulatory request; to enforce our Terms of Use and other agreements; or if we believe disclosure is necessary to protect the rights, property, or safety of Concentric, our clients, or others.

We do not sell your personal data.

Concentric operates globally, with offices in the United States, Mexico, United Kingdom, Ireland, and Singapore. Where a data transfer across borders may be necessary, we take appropriate steps to ensure that your personal data receives the level of protection required by the GDPR and other applicable laws. For transfers to entities located outside the European Economic Area, we implement appropriate safeguards, including standard contractual clauses or other approved mechanisms.

We store your personal data on secure servers and with trusted service providers, including external data centers. All storage and processing is conducted in accordance with our ISO 27001 and ISO 27701 certified information security management systems.

We retain personal data for as long as necessary to achieve the purposes described in this Policy, or as required by applicable law. We will delete or anonymize personal data once it is no longer necessary, subject to any applicable legal or regulatory requirements for longer retention, or as needed to establish, assert, exercise, or defend legal claims.

We use cookies and similar tracking technologies to enhance your experience on our Sites. Cookies are small text files placed on your device that help us analyze web traffic and customize your browsing experience.

Types of cookies we use:

Strictly necessary cookies — Essential for the Sites to function properly and cannot be switched off. They are usually set in response to actions you take, such as setting your privacy preferences or filling in forms.

Preference cookies — Enable the Sites to remember choices you make and provide enhanced, personalized features.

Analytics cookies — Allow us to count visits and traffic sources so we can measure and improve the performance of our Sites. We use services such as Google Analytics for this purpose.

Marketing cookies — May be set through our Sites by advertising partners to build a profile of your interests and show you relevant content on other sites.

You can manage your cookie preferences through your browser settings or through the cookie consent mechanism on our Sites. Declining certain cookies may affect your ability to use some features of our Sites.

Depending on your jurisdiction, you may have certain rights regarding your personal data. These may include the right to:

Access — Request access to, and receive a copy of, the personal data we hold about you.

Rectification — Request correction of any inaccurate or incomplete personal data.

Erasure — Request deletion of your personal data, subject to applicable retention requirements.

Restriction — Request restriction of the processing of your personal data under certain circumstances.

Objection — Object to the processing of your personal data, including processing for direct marketing purposes.

Data portability — Receive your personal data in a structured, commonly used, and machine-readable format.

Withdraw consent — Where processing is based on your consent, you have the right to withdraw that consent at any time.

To exercise any of these rights, please contact us at dpo@concentric.io or call 1 (866) 828-5855.

California residents— Under the California Consumer Privacy Act (CCPA) and California's “Shine the Light” law, you may have additional rights regarding your personal information, including the right to know what personal information we collect, the right to request deletion, and the right to opt out of the sale of personal information. We do not sell personal information. To make a request, please contact us at dpo@concentric.io.

Colorado, Connecticut, Virginia, and Utah residents — You may have the right to confirm whether we process your personal data, access and delete certain personal information, request data portability, and opt out of personal data processing for targeted advertising and sales. Colorado, Connecticut, and Virginia residents may also correct inaccuracies and opt out of profiling.

Texas residents — Under the Texas Data Privacy and Security Act, you may have the right to confirm processing, access, correct, delete, and obtain a portable copy of your personal data, as well as to opt out of targeted advertising, the sale of personal data, or profiling.

Nevada residents— You may have a limited right to opt out of certain personal information sales. We do not currently sell data triggering Nevada's opt-out requirements.

To exercise any of these rights, please submit your request to dpo@concentric.io with the subject line referencing your applicable state privacy law. To appeal a decision regarding a consumer rights request, you may email us at the same address, and we will respond within the timeframe required by your applicable state law.

If you are a resident of the European Union or the United Kingdom, applicable laws provide you with additional rights regarding our use of your personal data, as outlined in the Your Privacy Rights section above. If you object to the processing of your personal data, we will no longer process it unless we have compelling legitimate grounds which override your interests, rights, and freedoms, or for the establishment, exercise, or defense of legal claims.

You also have the right to file a complaint with the relevant data protection supervisory authority if you believe your personal data has been processed in violation of applicable law.

You can exercise your rights free of charge by contacting us at dpo@concentric.io.

Residents of Mexico may exercise their rights under applicable Mexican data protection law by emailing dpo@concentric.io with the subject line “Mexican Privacy Rights Request.” Your request must contain your address or other means of responding, documentation to verify your identity, and a clear description of the personal information relating to your request. Complaints may be directed to the Instituto Nacional de Transparencia, Acceso a la Información y Protección de Datos Personales (INAI).

We have implemented robust technical and organizational measures designed to protect your personal data from accidental loss and from unauthorized access, use, alteration, and disclosure. These measures are consistent with ISO 27001 and ISO 27701 standards and include encryption, access controls, network security monitoring, regular security assessments, and employee training.

The safety and security of your information also depends on you. Where we have given you a password for access to certain parts of our Sites, you are responsible for keeping this password confidential. Please do not share your credentials with anyone.

Unfortunately, no method of transmission over the internet or method of electronic storage is completely secure. While we strive to protect your personal data, we cannot guarantee absolute security. Any transmission of personal information is at your own risk.

Our Sites may contain links to third-party websites, services, or applications that are not operated by Concentric. This Policy does not apply to those third-party sites. We encourage you to review the privacy policies of any third-party site you visit. Concentric is not responsible for the privacy practices or content of third-party websites.

We reserve the right to update this Policy periodically. Any changes will be posted on this page with an updated “Last Updated” date. If we make material changes to how we treat personal data, we will notify you through a notice on our Sites. We recommend checking this page from time to time to stay informed about how we protect your information.

If you have any questions, comments, or requests regarding this Privacy Policy or our data practices, please contact us:

Concentric Advisors, Inc. Data Protection Officer
Email: dpo@concentric.io
Phone: 1 (866) 828-5855
Web: concentric.io/contact-us