What data do we collect?

SOSi collects the following types of personal data:

• Contact information (e.g., your name, e-mail address, mailing address, and phone number)
• Employment information (e.g., your employment status, employment history, education history, curriculum vitae/resume, security clearance information, current salary (where necessary), and any other personal information submitted by you)
• Metadata (e.g., your IP address, digital data, device information, file types, access permissions, etc.)
• Health data (e.g., information regarding symptoms of, exposure to, or diagnoses of infectious diseases)
• Travel data
• Marketing and communications data (e.g., your preferences regarding receipt of marketing information from us and your preferred modes of communication)
• Financial payment data and disbursement information (e.g., your payment card numbers and associated identifiers, billing addresses, and bank account information)

We may collect information from or about you, such as biometric data, demographic data, photos or videos, and any other data you may wish to voluntarily provide to us as part of your application for employment, employment, our use of your services, or your use or deployment of our services. We also automatically collect information about your interactions with our services, as well as devices used to deliver the services.

How do we collect your data?

We collect information about you when you have a pre-employment,  employment or business relationship with us, when you visit one of our facilities, and/or when you visit a website or request access to our network and/or computing assets. Data is typically collected by recording:

• details you provide in your communications with us (e.g., during phone calls, via e-mail, or through use of our website);
• information you provide when you visit one of our facilities; and
• your use of our services and any technologies associated with those services, including cookies.

We may also receive information from other sources and combine that information with the information we collect directly. Examples of information we may receive from other sources include delivery or payment information, or information supplied in connection with a technical support request. Some of our services may also involve software applications that request permission to determine your location. When you grant this permission, we may collect information about your location using geotracking technology. Some devices will allow you to control access to precise location information. We may also look up your IP address to determine your general location.

How will we use your data?

We will only collect, use and share your personal data in cases where we are satisfied that we have an appropriate legal basis to do so. We may use your personal data:

• to the extent you have consented to our use;
• when the personal data is necessary to employ or engage you, provide you with our services, manage our business, or for security purposes;
• to execute a contract or perform contractual obligations;
• when required by third parties who help manage our business and deliver products and services;
• in aggregate, anonymized statistical form when sharing website traffic patterns and usage with our partners, affiliates, or advertisers;
• as a disclosure to an interested purchaser or transferee in a potential sale or transfer of some or all of our business or assets to such interested purchaser or transferee; and/or
• to comply with any applicable laws, regulations and rules, and requests of law enforcement, regulatory and other governmental agencies.

Non-government third parties with whom SOSi shares your information have agreed to confidentiality restrictions and use any personal information we share with them or which they collect on our behalf solely for the purpose of providing the contracted service to us. These may include service providers that help manage our back-office functions.

How and for how long do we store and protect your data?

Storing Your Personal Data

SOSi securely stores your personal data for as long as is reasonably necessary for the purposes for which it was collected, as explained in this Policy. In some circumstances, SOSi may store your personal data for longer periods of time to remain in compliance with legal, regulatory, tax, and accounting requirements or to address/respond to complaints or litigation.

Protecting Your Data

SOSi has implemented and maintains appropriate administrative, technical, physical, and organizational security measures and procedures designed to reduce the risk of accidental destruction or loss of, or the unauthorized disclosure or access to, your personal data. Our security controls are designed to maintain data confidentiality, integrity, and an appropriate level of availability.

What are your data access, protection, and transfer rights?

SOSi wants to make sure you are fully aware of all your data access, protection, and transfer rights. Every user is entitled to the following:

Right to access. You have the right to request copies of your personal data.

Right to rectification. You have the right to request that SOSi correct any information you believe is inaccurate. You also have the right to request that SOSi complete information you believe is incomplete.

Right to erasure. You have the right to request that SOSi erase your personal data, under certain conditions.

Right to restrict processing. You have the right to request that SOSi restrict the processing of your personal data, under certain conditions.

Right to object to processing. You have the right to object to SOSi’s processing of your personal data, under certain conditions.

Right to data portability. You have the right to request that SOSi transfer the personal data we have collected to another organization, or directly to you, under certain conditions.

If you would like to exercise any of these rights, please contact us at:

Ethics and Compliance Department
SOS International LLC
1881 Campus Commons Drive, Suite 500
Reston, VA 20191

Ethics Helpline: 1-844-231-3572 or (sosi.ethicspoint.com) or Privacy@sosi.com

All requests will be processed in accordance with applicable law. Where permitted by law, an administrative fee may be charged. We will advise you of any applicable fees prior to acting upon your request.

Residents of California

Shine the Light Law

SOSi does not share information that identifies you personally with non-affiliated third parties for their own marketing uses without your permission.

California Consumer Privacy Act

If you are a resident of California, you may submit a request to exercise your rights with respect to your personal data using the Data Rights Request Form available [here].

Residents of Nevada

SOSi does not sell information that identifies you personally with non-affiliated third parties for their own marketing uses without your permission. If you would like to make a request that we not sell identifying information about you in the future, you may submit that request using the contact information below.

Residents of Canada

If you are a resident of Canada, and you have an inquiry regarding your personal data as held by SOSi, including personal information collected through your use of our services, you may request further information using the Data Rights Request Form available [here].

Residents of the European Economic Area (EEA)

If you are a resident of the EEA, the following additional disclosures apply:

Data Controller: When you use SOSi’s services, Northstar Systems ApS, a wholly owned subsidiary of SOSi, acts as the Controller of your personal data.

Legal Basis for Processing: When we process your personal data, we will only do so under the following situations:

• We need to use your personal data to perform our responsibilities to you as a potential employer, employer, or under our contract with you (e.g., accepting services from you, providing the services you purchase or request, or for processing payments related to those services).
• We have a legitimate interest in processing your personal data to provide, secure, and improve our service offerings; or communicate with you about changes to our services, including any new service offerings.
• We have your consent to process your personal data.
• We need to process your personal data to comply with our legal obligations.

Data Transfers: We transfer personal data to countries outside of the EEA through a series of intercompany agreements based on the Standard Contractual Clauses under European Union (EU) law and applicable EU regulations.

Individual Rights Requests and Withdrawal of Consent: You may submit a request to exercise your rights with respect to your personal data using the mechanisms outlined in the “What are your data access, protection, and transfer rights?” section above or by submitting a Data Rights Request Form available [here]. The Data Rights Request Form can be used by anyone, regardless of residence. If you initially consented to our processing of your personal data, you may withdraw your consent using the same mechanisms or the Data Rights Request Form.

Supervisory Authority and Complaints: If you are an EU/EEA Data Subject (as this term is defined under EU law) and have a concern about our practices relative to the processing of personal data that we are unable to resolve, you have the right to lodge a complaint with the data protection authority where you reside or in which you work, or in which the alleged infringement occurred, as applicable.

Links to Other Websites

Our site and services may contain links to other websites for your convenience and information. These websites may be operated by entities not affiliated with SOSi. Linked websites may have their own privacy policies or notices, which we strongly encourage you review if you visit those sites. We are not responsible for the content, privacy practices, or use of any site or service not affiliated with SOSi.

Contact Us

Click [here] to contact us regarding this Policy, or other related privacy issues.

You can also write to us.