Portable Solutions Group (PSG - Parent Company to DropBox Inc. & Modular Security Systems Inc.)

PRIVACY POLICY

Effective May 25, 2018

At PSG we take privacy very seriously and have taken all reasonable measures to safeguard any information that you provide us.

WHEN YOU ACCESS OUR WEBSITE, YOU AGREE TO THIS PRIVACY POLICY.  IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, YOU SHOULD DISCONTINUE ACCESSING OUR WEBSITE AND USING OUR SERVICES.

We agree that:

  • We will safeguard, according to strict standards of security, any information you share with us.
  • Except as may be required by law, we will not share information you provide us without your permission.
  • You can unsubscribe from our update notifications at any time.

Introduction

PSG,  through its operating companies, is a leader in container modification providing both standardized containerized product and custom build for shipment worldwide.  In order to better provide you with timely update notices to the hardware, software, firmware and/or the services for which you have either engaged PSG, we may, directly or through someone acting on our behalf, such as a representative and/or a distributor, need to contact you from time to time.  By using PSG’s Websites you may be providing it with information relating to your identity, your business, your processes and procedures. PSG is committed to protecting your privacy and to ensuring that you are in control of the information that we maintain about you. This PSG privacy policy (“Privacy Policy”) explains what we will and will not do with your Personal Data. For purposes of this Privacy Policy, “Personal Data” has the meaning set forth below.

Personal Data

Personal Data is a legal term that describes information that identifies a particular person and has special meaning under European Union law.  For purposes of the EU’s General Data Protection Regulation (GDPR) personal data is any information that can identify you, either directly or indirectly, such as a name, an identification number, your IP address, data about your location, or information about your physical, physiological, genetic, mental, economic, cultural or social identity.

Information We Collect

It is not necessary for you to supply any Personal Data when you visit our Website.  However, when you register with our Website, we typically collect information that you voluntarily provide that personally identifies you or others (“Personal Data”) such as your name, home address, email address and any other information you provide to us.  Additionally, when you visit our Website we automatically collect information that does not personally identify you or others (“non-personally identifiable information”).

  • From employment applicants, we or our service provider will collect contact and identification information, such as name, address, telephone number, e-mail address, date and place of birth, and driver’s license number and employment and income information;
  • From our customers, we or our service provider will collect information on products and services that you purchase, your credit and financial information such as billing and credit history or payment history; and
  • Customer relationship information, such as customer service requests.

We do not automatically collect your Personal Data unless and until you have shared it with us.  This Policy does not apply to information about our business customers that are not natural persons.

Non-Personally Identifiable and Technical Information

Whenever you use a website, mobile application, or other internet service, certain information is created and retained by the website or application.  This happens with our Website as well.  We collect technical information that does not personally identify you when you use our Website, or information that has been made anonymous, such as:

  • Log data: Our servers automatically record information when you use our Website, such as your IP address, the type of browser you are using and its settings, the third party website you visited immediately prior to accessing our Website, the operating system you are using, the domain name of your Internet service provider, the search terms you use on our Website, the specific Website pages you visit, type of product selected, the brand, order, and product identifications, and the duration of your visits.
  • Cookie data: Like many websites, we may/may not use “cookies” to obtain certain types of information when your web browser accesses our Website.  “Cookies” are small text files that we transfer to your computer’s hard drive or your Web browser memory to enable our systems to recognize your browser and to provide convenience and other features to you, such as recognizing you as a frequent user of our Website.  Some of the cookies we use are associated with your account with us (including Personal Data about you) if you have one, and other cookies are not.

We may use “session cookies” (cookies that last until you close your browser) or “persistent cookies” (cookies that last until you or your browser delete them).  Examples of the information we collect and analyze form cookies include your activity on our Website, including the URL you come from and go to next (whether this URL is on our site or not).  Remember that the cookies that we use do not contain and are not tied to Personal Data.

If you are concerned about the storage and use of cookies, you may be able to direct your internet browser to notify you and seek approval whenever a cookie is being set to your Web browser or hard drive.  You may also delete a cookie manually from your hard drive through your internet browser or other programs.  Please note, however, that some parts of our Site will not function properly or be available to you if you refuse to accept a cookie or choose to disable the acceptance of cookies.  We may also collect information pertinent to the marketing of our products and services.  This information may include marketing channels, User Market IDs, Site brands and product names, contract terms, financial information and other information.

Use Limitation

PSG treats your Personal Data as confidential and does not disclose it or use it except as permitted by you, as described in this Privacy Policy, or as required by law, subpoena, court order, legal process or warrant. If we are served with a civil subpoena seeking personal information about you, we will use reasonable efforts to notify you of the request prior to disclosure of such personal information, so as to allow you the opportunity to oppose the subpoena.

PSG will not provide your e-mail address, name, or other personal identifiers to third parties without your explicit, advance permission. PSG may engage third parties to perform analysis or data processing of our databases that could involve access to your personal information. If PSG does so, we will ensure that such parties are contractually required to keep the information confidential and not to use it in any way other than as is necessary to perform their work for PSG.

Unsubscribe Procedures

As a registered user of PSG products, services or as a participant in the PSG Websites, you have control over the data that PSG maintains about you and whether you want us to use that information for the purposes stated in this Privacy Policy.  All registered users of PSG products and services may at any time opt-out of receiving upgrade notices by clicking on the opt-out link we include in the email we send you or by contacting us by email to mduncil@dropboxinc.com or directly via U.S. Mail. If you decide that you do not wish to participate in our upgrade notice service you can unsubscribe by clicking on the link provided in the update request e-mail messages PSG sends you and following the directions provided.

Security Safeguards

At PSG we employ security techniques and well-defined employee practices to ensure that data is protected from unauthorized access and use. We hold our employees, sales representatives, distributors and business partners accountable for maintaining the privacy and integrity of our users’ information.

PSG works to reduce the likelihood of accidental disclosures and unintended access and modification of account information, but it is impossible to eliminate this possibility completely. To maintain the highest level of security for your PSG account, you should not provide others with access to your e-mail address box.

We monitor the effectiveness of our compliance with our Privacy Policy.  If you feel that you have experienced a violation of these Privacy Policies, you should contact us immediately at:

Portable Solutions Group

Attention: Privacy

PO BOX 402

Worthington, KY 41183

Fax: 740.237.4691

E-mail: sales@dropboxinc.com

Openness

PSG has a general policy of openness about developments, practices and policies with respect to personal data. PSG states in detail what personal data it collects and why it collects it. PSG’s Web server may log key information about any visitor to the PSG Websites (both users and non-users), including the following elements:

  • The URL of the page requested;
  • The time and date of the request;
  • The make and version of the web browser being used,
  • The version and type of your operating system);
  • The “Referrer” (the URL where you clicked on a link to get to PSG’s sites); and
  • The IP address where a copy of the page you requested is to be sent for display by your browser.

PSG summarizes each element it tracks, such as browser make and Referrer, the number of visits from higher-level domains, and so on. The individual records are destroyed, thus cutting the link between a particular IP address and the other server elements listed above. Although an IP address does not usually identify the visitor personally, it does suggest an individual association in some cases.  We may use this information in aggregate to get a better picture of where our visitors come from and how to plan for our future needs.

 

The web server logs may also be used in the course of a fraud investigation or as provided by law.

Collection Limitation

PSG collects personal data about you only in ways that are fair and lawful. PSG collects only the personal data it has said it collects and only in the ways it has said it collects it.  This information is collected to allow us to use multiple means of contacting you and to help prevent fraud. Under no circumstances will we use this information for anything else not described in the privacy notice. Users can have access to review their information at any time by requesting it from us by email. You can correct factual errors in your personally identifiable information by notifying us. To protect your privacy and security, we will take reasonable steps to verify your identity before granting access or making corrections.

As a registered PSG user, you give us permission to use the information we have told you we use, for the purposes stated here, according to the options you indicate via the PSG software and Website, according to the terms of this Privacy Policy.

Data Quality

PSG does not collect Personal Data from you that is not relevant to the purposes stated in its Privacy Policy. PSG strives to keep all personal information accurate, complete, and up-to-date. After a reasonable period of time (consistent with business requirements such as accounting), the personal information associated with terminated accounts may be destroyed, compressed or removed. From time to time, PSG reduces the amount of data associated with active members by converting older data into summary statistics or destroying it.

Your Consent

By using our products and services, you consent to our sharing your Personal Data with our partners and affiliates as necessary to fulfill your order or to perform the services you have requested we perform.

For certain types of Personal Data, we may use the data for certain described purposes at the time you provided it.  You may withdraw your consent at any time.  When you give us your consent, you are giving us permission to process your Personal Data specifically for the purposes identified.  Where we ask you for additional Personal Data, we will always tell you why and how the information will be used.  You may withdraw consent at any time by sending an email to sales@dropboxinc.com or by sending a letter to:

Privacy Officer

PSG Group

Miles Duncil II

PO Box 402

Worthington, KY 41183

 

Accessing Your Personal Data

If you want to know what Personal Data PSG holds about you or wish to change Personal Data that is inaccurate or out of date, or to withdraw your consent to the use of your Personal Data, please contact us at the address above.  It may not always be possible to completely remove or modify information in our databases, although we will make reasonable efforts to do so upon your request.  We do not control how our partners retain, store and destroy data they have accessed in connection with assisting with providing our services.  You should check their websites for more information on their practices.

Accountability

PSG always has a person designated as its privacy ombudsman, who is accountable for ensuring that PSG protects its users’ privacy. Questions, concerns, issues or complaints may be sent to mduncil@dropboxinc.com.  If you have any questions regarding our Privacy Policy, please contact us at:

Portable Solutions Group

Attention: Privacy

Miles Duncil II

PO Box 402

Worthington, KY 41183

Phone: 740.532.7822

E-mail: mduncil@dropboxinc.com

Policy Regarding Children’s Use of Our Site

PSG complies with the Children’s Online Privacy Protection Act. PSG does not knowingly collect information from children under the age of 13.

Business Transfers or Bankruptcy

As we continue to develop our business, we may sell or buy companies or assets. In such transactions, customer information generally is one of the transferred business assets. Also, in the event that PSG or substantially all of its assets are acquired, customer information will of course be one of the transferred assets. You may opt-out of any such transfer by notifying PSG in writing.

Notification of Changes

The foregoing policy is effective as of May 25, 2018. PSG reserves the right to change this policy at any time. Please check our Website periodically for changes. Your continued use of PSG’s products and services following the posting of changes to these terms will mean you accept those changes. In the event that PSG changes this policy, PSG will post a message on the home page of its Website that states that the Privacy Policy has been changed, and will provide a link to the Privacy Policy.

If we are going to use your personally identifiable information in a manner different from that stated at the time of collection we will notify you via e-mail. You will have a choice as to whether or not we use your information in this different manner.

MAS/SKA/01987123.1

 
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