Privacy Policy

We respect your privacy and want you to be comfortable with how we use the personal information that you provide to us.  For that reason, we are providing you with this privacy policy (“Policy”) that describes how Soteria, LLC (“Soteria,” “we,” “us,” or “our”) collects and uses personal information.

See our California Consumer Privacy Act (CCPA) Privacy Notice.

Application

This Policy applies to this website and its subpages (collectively, the “Soteria Website”) as well as all transactions in which Soteria collects Personal Information (as defined below) from its customers.  Please note, this Policy does not apply to any third party websites (including those that may be linked to our website) or third party solution providers for whom Soteria facilitates and/or resells services or solutions.

This Policy applies to all Personal Information received by Soteria in any format including electronic, paper or verbal.

Scope; Usage

Collection of Personal Information

In this Policy, “Personal Information” means any information that identifies, or could be used to identify, an individual. Your Personal Information includes all information that we receive from you when you register to receive services by or through us, which may include your first and last name, your telephone number, your email address, and other similar registration-related information.

We may also collect certain information automatically through the use of cookies. Cookies are small files placed on your hard drive that assist us in providing you with a customized browsing experience. We use cookies to provide you with the convenience of not having to reenter information, such as user IDs and passwords, multiple times during your visits to the Soteria Website. Cookies can also be utilized to help us provide you with information targeted to your interests, based upon your prior browsing at the Soteria Website. The “help” section of the toolbar on most browsers will inform you on how to prevent your browser from accepting new cookies, how to have the browser notify you upon the receipt of a new cookie, or how to disable the use of cookies completely. If you configure your browser to decline cookies, then certain features of the Soteria Website may not function correctly and you may be required to re-enter any user IDs and passwords more frequently. If you access the Soteria Website on a mobile device, then depending on the device’s specifications, you may not be able to control tracking technologies through the device’s settings.

From time to time, we may implement Google Analytics to assist us in gathering analytics and statistical data in connection with the Soteria Website. On our behalf, Google processes this information to analyze the usage of the Soteria Website. If you have any questions or concerns with regard to Google Analytics’ privacy practices, you can review Google’s privacy policy.

Use / Disclosure of Your Personal Information

We use your Personal Information to provide you with information that you request. If you are a Soteria customer, then we use your Personal Information as necessary to provide you with or facilitate (as applicable) information technology-related services (“Services”).

If necessary for our provision or facilitation of the Services, we may disclose your Personal Information to third party solution providers with whom we maintain a trusted business relationship (“Third Party Providers”). Microsoft® is an example of a Third Party Provider with whom we may share your Personal Information. Each Third Party Provider is required to limit its use of your Personal Information to the purpose for which the information was given to that provider.

If you believe that a Third Party Provider has used your Personal Information in a manner that is contrary to this Policy or the privacy policy of the relevant Third Party Provider, we would like to know about it. Please contact our designated privacy officer (listed below) to notify us of any misuse of your Personal Information by a Third Party Provider.  Please note, we cannot and do not take responsibility for the misuse of your Personal Information by a Third Party Provider.

On occasion, we may hire third parties to perform certain functions on our behalf. Examples include removing repetitive information from our customer lists, analyzing data, providing marketing assistance, and providing customer service. These third parties have access to your Personal Information to the extent necessary to permit them to do their jobs, however, they are bound by confidentiality agreements before any information is provided to them, and they are restricted from using the information for other purposes.

We may also disclose your Personal Information if we are required to do so by law or we in good faith believe that such action is necessary to (i) comply with the law or with legal process; (ii) protect and defend our rights and property; (iii) protect against misuse or unauthorized use of the Soteria Website or any of the Services; or (iv) protect the personal safety or property of our users or the public (among other things, this means that if you provide false information or attempt to pose as someone else, information about you may be disclosed as part of any investigation into your actions).

We may also use your Personal Information in the aggregate to determine our customers’ demographics and preferences. In addition, we may use your Personal Information to analyze the use of the Soteria Website to understand and improve our service, or for investing in or developing new services.

Other than as stated in this Policy (or as expressly permitted by you in writing, if applicable), we will not release your Personal Information to unknown or unaffiliated third parties, and we will not cross-reference your Personal Information with that of any other customer or entity.

Cross-border Transfers

To prevent unauthorized access, maintain data accuracy, and ensure the correct use of information, we have put in place appropriate physical, electronic, and managerial procedures to safeguard and secure the information we collect online.

How You Can Access Or Correct Your Information

The Services are operated and/or facilitated by us from the United States, and are not intended to subject us to the laws or jurisdiction of any state, country, or territory other than that of the United States.  Your Personal Information may be stored and processed in any country where we have facilities or in which we engage Third Party Providers, and by using the Services you consent to the transfer of information to countries outside of the United States, which may have different data protection rules than those of the United States.

Additional Information Relating To Your Personal Information

Soteria keeps your Personal Information in an encrypted format while on our servers.  When we transmit your Personal Information, we do so in a secure fashion.  We will take commercially reasonable steps to protect your information; however, no security system or mechanism is completely foolproof, and we cannot and do not warrant or guarantee that your Personal Information is 100% free from unauthorized access or viewing.

Also, if all or substantially all of our assets are transferred or acquired in a sale or assignment, or in connection with similar corporate transactions, your Personal Information may be one of the transferred assets.  It is our practice to seek appropriate protection for information in these types of transactions.

Your Choices

You will have the option to opt-out of any uses of your Personal Information that are not reasonably necessary for us to provide or facilitate the Services.  Should that situation arise, we will provide you with reasonable “opt out” mechanisms to exercise your choice before we disclose any information as described in this paragraph.

Accuracy & Access

We will take reasonable steps to ensure that your Personal Information is relevant, accurate, complete and current, to its intended use.  We provide individuals with reasonable access to Personal Information that they provided to us, as well as the ability to review and correct such information, if applicable.

To protect your privacy and security, we may also implement multi-factor authentication and/or take other reasonable steps to verify your identity before granting access to your Personal Information. To view and change the Personal Information that you provided to us directly, you can also contact our privacy officer as indicated below.

Please note, at times we may need to retain some information about you to satisfy our internal business, legal, and/or security obligations. For that reason, some of your Personal Information may remain archived even if you ask us to delete it.

Security

To prevent unauthorized access or disclosure, to maintain data accuracy, and to ensure the appropriate use of your Personal Information, we utilize physical, technical, and administrative procedures to safeguard the information we collect.

Among other things, we use Secure Sockets Layer (SSL) encryption when collecting or transferring sensitive data, such as credit card information. SSL encryption is designed to make the information unreadable by anyone but us.

We also use firewalls and restricted access methods to ensure the security of the information we collect.  Any of our employees who have been granted physical access to your Personal Information will be made aware of their responsibilities to protect the security, confidentiality and integrity of that information and have been (or will be promptly after their hiring) provided training and instruction on how to do so.

Contact for Privacy Issues

Soteria’s designated contact for questions related to our website’s privacy is Bradley Gross, Esq. email: [email protected].  If you have any questions or comments about this Policy, please direct them to our designated privacy contact person.

Changes to this Policy

The practices described in this Policy are current as of October 2025.

California Consumer Privacy Act (CCPA) Privacy Notice

This Privacy Notice applies only to California consumers and supplements the Policy.

Personal Information We Collect

We collect 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 (“CCPA Personal Information”). We have collected categories of CCPA Personal Information noted in the Collection of Personal Information (above) within the last twelve (12) months.

Use of CCPA Personal Information

We may use categories of CCPA Personal Information for the purposes noted in Use / Disclosure of Your Personal Information section, above.

Categories of CCPA Personal Information Disclosed for a Business Purpose

We may disclose the categories of CCPA Personal Information noted in the Use / Disclosure of Your Personal Information section (above) for business purposes related to our provision or facilitation (as applicable) of the Services. Specifically, we may disclose these categories of information for business purposes to the following categories of third parties: Third Party Service Providers (as defined in our Master Services Agreement), any entity that purchases or obtains all or substantially all of our assets or ownership interests, or (if legally required to do so or to protect the integrity or security of the Services or our infrastructure), law enforcement, courts, governments and regulatory agencies.

Sources of CCPA Personal Information

The sources of information we collect are listed in the Collection of Personal Information section, above.

Your Rights

You have the right to request that we disclose (i) the categories of CCPA Personal Information we collect about you, (ii) the sources from which we collect CCPA Personal Information, (iii) our business purpose for collecting or using CCPA Personal Information, and (iv) the third parties with whom we share CCPA Personal Information.

You also have the right to request that we delete any CCPA Personal Information about you that we possess. If you request that we delete such information, then we will do so in accordance with applicable legal requirements. You may request that we delete your CCPA Personal Information by contacting our privacy officer or by calling your assigned account technician. We reserve the right to retain your CCPA Personal Information if we are required to do so to complete a transaction with you or on your behalf, to detect and remediate security incidents, to exercise free speech, and/or to comply with legal obligations. We may also keep the information for internal purposes reasonably aligned with your expectations based on your business relationship with us.

You also have the following additional rights:

You are hereby notified that we may use or rely upon automated decision-making technology (ADMT) in the provision and/or facilitation of the Services in the manner described in Use / Disclosure of Your Personal Information, above. Effective January 2026, to the extent that ADMT is used, you have the following rights:

We will not discriminate against you based on your exercise of any of your CCPA rights.

You can assert these rights only where we receive a verified request from you. In order to verify the request and your identity, we may ask you to verify your identity. Because we only collect limited information about individuals, we may be unable to verify requests to the standard required by the CCPA.