Updated: March 18, 2021
We are committed to processing personal data in accordance with U.S. states and international legal standards, including the General Data Protection Regulation (GDPR), and other applicable data protection laws. Internal company policies and procedures govern our internal networks and systems and the processing of personal data related to employees and other authorized network users.
Telos is the data controller with respect to personal data that we collect or that you provide to us. By submitting personal data and other information, you consent to the processing of such data in accordance with the terms of this Policy.
1. How We Obtain Information About You
We collect personal data that you choose to provide to us, such as when you:
- Visit and use the Sites and company portals;
- Sign-up to receive direct marketing communications;
- Sign-up to a feature or request information that we offer;
- Attend an event hosted by us (or one of our affiliates or partners);
- Communicate with us (for example, on a social media platform or by sending us an email);
- Communicate with our support or concierge staff;
- Enter into agreements with us; or
- Make employment inquiries or apply for an open position.
We may also collect personal data in other contexts and that will be reflected in future Policy updates.
2. Information We Obtain
“Personal data” refers to information that, by itself or in combination with other information, identifies or can reasonably be used to identify an individual. Therefore this Policy does not apply to data from which individual persons cannot be identified. The term “processing” refers to any operation or set of operations which is performed on personal data, whether or not by automated means, such as collection, use, organization, storage, alteration or destruction, disclosure or transfer.
The type of Personal Data collected may include:
- Email address
- Date of birth
- Job title
- Telephone number
- Business name and/or Employer
- IP address
Due to the open nature of the Internet, we request that you do not send us unsolicited proprietary or other confidential information through our Sites.
3. Why and How We Use Information That We Obtain
Personal data is processed under one or more of the following legal bases:
- Consent: you have given your consent to the process of personal data, which can be withdrawn at any time
- Contractual: processing of personal data is necessary for the performance of a contract to which you are a party, or for us to take pre-contractual steps at your request
- Legal obligation: processing of personal data is necessary for compliance with a legal obligation
- Legitimate interest: processing of personal data is necessary for our legitimate interest or that of a third party, unless those interests are overridden by your interest or fundamental rights
Personal data is collected to provide legitimate business services, which include:
- For marketing purposes;
- Review and respond to inquiries;
- Operate, evaluate, and improve our business and product and service offerings;
- Administer and analyze our websites and effectiveness;
- Perform security logging and analysis;
- Handle and communicate orders, billing and payment, delivery of products and services;
- Consider applications for employment; and
- Comply with all legal and regulatory requirements.
Personal data may be used to:
- Process orders, request for further information, maintain records and to provide pre- and after-sales service.
- Pass to another organization to supply/deliver products or services you have purchased;
- Pass onto our partners in order to follow-up on any webinars and events to which you have registered or attended;
- Perform obligations arising from any contracts entered into by you and us;
- Perform security checks of information you provided to protect us from credit risk and both you and us from fraudulent transactions;
- Comply with legal and regulatory requirements;
- Assist third parties to perform certain activities, such as processing and sorting data, monitoring how customers use our site and issuing our emails for us;
- Seek your views or comments on the services we provide;
- Notify you of changes to our services;
- Send you communications which you have requested and that may be of interest to you, including information about product updates, newsletters, events, webinars;
- Inform you of various promotions, goods and services that may be of interest to you, either by post, email, telephone, or such other means with marketing communications we deem relevant to you in the legitimate interests of Telos. (Each marketing communication sent to you will provide you with the option to unsubscribe and manage your data profile and communication preferences at any time); and
- Process a job application.
We use the personal data for these purposes because we have a legitimate business interest in providing services to our customers and other interested individuals that is not overridden by your interests, rights and freedoms to protect personal data about you. We also use the information to protect against and prevent fraud claims and other liabilities and to comply with or enforce applicable legal requirements, industry standards, and our policies and terms. We use personal data for these purposes when it is necessary to protect, exercise or defend our legal rights, or when we are required to do so by law that applies to us.
4. Information We Share
Any information that you provide will be used for our purposes only. We do not sell or otherwise disclose personal data that you provide to us or that we collect, except as described here.
We share personal data you provide to us or that we collect among Telos and its subsidiaries for the purposes described in this Policy. Personnel receive regular training on our security and privacy practices. They are reminded of the importance placed on privacy and the protection of personal data. Also access to personal data is limited to those with a need-to-know to perform specific tasks.
We share personal data with certain partners when you submit your personal data through website pages that clearly disclose that you are registering for a joint event or other initiative that involves those partners. Those partners identified will only use the information as stated in the notice on the particular website page during the registration process.
We share personal data with service providers that perform services on our behalf such as payment service providers, analytics providers, hosting providers and advisers. All service providers have entered into legally binding agreements requiring them to use or disclose personal data only as necessary to perform services on our behalf and to comply with applicable legal requirements.
In addition, we will disclose personal data about you (a) if we are required or permitted to do so by law or legal process, for example due to a court order or a request from a law enforcement agency, (b) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss, (c) in connection with an investigation of suspected or actual fraudulent or other illegal activity, and (d) in the event we sell or transfer all or a portion of our business or assets (including in the event of a reorganization, dissolution, or liquidation).
When you voluntarily make your personal data available for viewing by third parties online, such as a blog or public message board, your information can be viewed, collected and used by individuals and companies outside of Telos. We are not responsible for any unauthorized third-party use of such information that is provided in a public forum.
5. How We Secure Your Information
Telos takes reasonable technical and organizational measures to safeguard personal data against loss, theft and unauthorized access, disclosure, alteration, misuse, or destruction. Unfortunately, no data transmission, software, or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please notify us immediately. If Telos learns of a breach of its systems, you may be notified in accordance with applicable law and/or as part of our contractual obligation. Telos may communicate with you electronically regarding privacy and security issues affecting the information collected through your interactions with us.
6. Data Transfers
We may transfer the personal data that we collect about you to recipients in countries other than the country in which the personal data originally was collected. Those countries may not have the same data protection laws as the country in which you initially provided the personal data.
If you are located in the European Economic Area (“EEA”), we will comply with applicable legal requirements providing adequate protection for the transfer of personal data to recipients in countries outside of the EEA and Switzerland. In all such cases, we will only transfer your personal data if appropriate safeguards with respect to the transfer are in place, for example the EU Model Contracts.
7. How Long We Keep Information
The time period for which we keep personal data depends on the purpose for which we collected it. In all cases we keep it for as long as necessary to fulfill your requests or inquiries, provide services or comply with our legal obligations, resolve disputes and enforce our agreements. We will then delete the personal data, in accordance with our retention policy, unless we are legally required to retain it or if we need to retain it in order to comply with our legal obligations (for example, for tax and accounting purposes).
Subject to any applicable legal requirements, we typically retain personal data you provide to us for the duration of our relationship with you and until we do not have any contact with you for an extended period of time.
8. Your Rights
Different rules apply depending on the type of process being undertaken or your country or state of residence. The following rights may apply to you:
- To request confirmation of whether we process personal data relating to you, and if so, to request a copy of that personal data;
- To request that we rectify or update your personal data that is inaccurate, incomplete or outdated.
- To request that we erase your personal data in certain circumstances, such as where we collected personal data on the basis of your consent and you withdraw your consent;
- To request that we restrict the use of your personal data in certain circumstances, such as while we consider another request that you have submitted, for example a request that we update your personal data;
- To object to our processing of personal data on grounds relating to your particular situation;
- Where you have given us consent to process your personal data, to withdraw your consent; and
- To request that we provide a copy of your personal data to you in a structured, commonly used and machine readable format in certain circumstances.
You may contact us by email or as described in the “How to Contact Us” section below to exercise your rights described above. We will comply as soon as reasonably practicable consistent with applicable law. Please describe the nature of your request and the personal data at issue. We will verify your identity before we comply with your request, and therefore, ask for your cooperation with our identity verification process.
You also have the right to lodge a complaint with the data protection supervisory authority in your country or state.
For users who reside in California, please see Special Notice for California Residents.
9. Updates to our Policy
This Policy may be updated periodically and without prior notice to you to reflect changes in our data privacy practices. We will post the updated version on our sites and indicate at the top of the notice when it was most recently updated.
10. Children’s Online Privacy Protection
We do not knowingly solicit information from children and we do not knowingly market the site or its services to children. No one age 16 or under should submit any personal data to us and/or the sites. If we become aware that a person submitting personal data to us through any part of the sites is a child, the information will be deleted immediately. Therefore, we do not retain any information about children that can be reviewed or deleted. If a parent discovers that we have inadvertently retained information on his or her child before we have discovered and deleted it, then we will honor any requests that the information be deleted.
11. How to Contact Us
If you have any questions or comments about this Policy or any issue relating to how we collect, use, or disclose personal data, or if you would like us to update information we have about you or your preferences, you may contact us:
By e-mail at: firstname.lastname@example.org
By phone at: (703) 724-3756
(800) 283-0105 (Toll Free)
In writing at:
Attention: Privacy Officer
19886 Ashburn Road
Ashburn, VA 20147