PRIVACY POLICY

Last updated January 6, 2023

This privacy policy (the “Policy”) for Stealth Software Technologies, Inc. (“Stealth,” “we,” us,” “our”) describes our privacy practices regarding how we might collect, store, use, and/or share (“process”) your information when you visit and/or use our website located at https://www.stealthsoftwareinc.com or any website of ours that links to this privacy notice (collectively, the “Website”).

WHAT INFORMATION DO WE COLLECT?

In Brief:

  • We collect personal information that you provide to us voluntarily.
  • Some information—such as your Internet Protocol (IP) address and/or browser and device characteristics—is also collected automatically when you use the Website.

Personal Information You Provide to Us.  You may choose to send us inquiries or other communications using contact forms on the Website.  These forms will ask you to provide information such as your name, email address, the subject of your communication, and the message you wish to send us.  You are not legally required to provide any such information; however, if you do not provide information marked as required, you will not be able to send us a message using the Website’s contact forms.

Information Automatically Collected.  We automatically collect certain information when you visit and/or interact with the Website.  This information may include information about your device and your use of and interaction with the Website, such as your internet protocol (IP) address, country, location, browser and device characteristics, language preferences, referring URLs, which links you click, and which pages of the Website you visit.

HOW DO WE PROCESS YOUR INFORMATION?

In Brief:  We may process your information to respond to your communications; for our marketing purposes; to comply with laws; to protect an individual’s vital interest or the interest of the public; and to provide, improve, and administer the Website.  We may also process your information for other purposes with your consent.

We may process information you provide to us through contact forms on the Website to respond to your communications and to address any inquiries you may submit.

We may process information that you provide to us voluntarily or that is collected automatically when you use the Website if we are required to do so by law.  We may also process your information when necessary to protect an individual’s or vital interest or the public interest, including to prevent harm.

We will use information that is automatically collected when you use the Website to provide, improve, administer, and maintain the operation of the Website, as well as to tailor the Website to user preferences.

WHEN AND WITH WHOM DO WE SHARE YOUR INFORMATION?

In Brief:  We may share your information with vendors, consultants, and/or other third-party service providers; with our corporate affiliates; or with competent authorities if required by law or by order.  We may also share your information in the event of a change in control or ownership of Stealth, a transfer of its assets, or other change in structure.

We may share your information with third-party service providers, vendors, consultants, contractors, or agents (as used in this paragraph, “third parties”) who perform services for us or on our behalf and who require access to your information to perform such services.  The categories of such third parties with whom we may share personal information include analytics, monitoring, testing, and website-hosting service providers.  Such third parties are authorized to use your personal information only to the extent required for their provision of such services. 

We do not sell your personal information to third parties.

We may share your information with our affiliate entities, in which case we will require those affiliate entities to abide by the terms of this privacy policy.  Affiliate entities include any subsidiaries, joint venture partners, or other entities that we control or that are under common control with us, whether now or in the future.

We may share or transfer your information in connection with, or during negotiation of, any merger, sale or transfer of our assets, financing, acquisition of all or a portion of our business by another entity, or other similar change in structure.

We will share your information with competent judicial, regulatory, or other government authorities if required to do so by law or by order of such a competent authority. 

We may also share your information if necessary to protect an individual’s vital interest or the public interest, including to prevent harm.

DO WE USE COOKIES OR OTHER TRACKING TECHNOLOGIES?

In Brief:  We may use cookies and/or similar tracking technologies to store your information.

We may use cookies and/or similar tracking technologies, such as web pixels or web beacons, to access or to store your information.

We use certain cookies that are necessary for the Website to function properly.  Most browsers are configured to accept cookies by default.  If you prefer, you may be able to use your browser settings to block these cookies, but doing so may cause some parts of the Website to function improperly.  You can delete cookies that have been saved on your device through your browser or device.

CONTROLS FOR DO-NOT-TRACK FEATURES

Some web browsers and mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored or collected.  At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized.  As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online.  If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy policy.

HOW LONG DO WE RETAIN YOUR INFORMATION?

In Brief:  We keep your information for as long as necessary to accomplish the purposes outlined in this privacy policy.  Subsequently, we may retain your information as required for record-keeping purposes as required or permitted by law.

We will retain your personal information for as long as it is necessary to accomplish the purposes set forth in this privacy policy, including to support our operation of the Website and to interact with users of the Website.  Subsequently, we may retain your information for record-keeping purposes as require or permitted by law, such as to comply with tax, accounting, or other legal requirements; for dispute resolution; or to establish, pursue, or defend against legal claims.

When we have no legitimate ongoing business purpose for processing your personal information, we will either delete or anonymize such information or, in the event that this is impossible (e.g., if your personal information has been stored in backup archives), we will store your personal information securely and isolate it from further processing until it can be deleted.

HOW DO WE KEEP YOUR INFORMATION SECURE?

In Brief:  We aim to safeguard your personal information through organizational and technical security measures.

We implement appropriate and reasonable organizational and technical security measures intended to protect the security of personal information we process.  However, these measures do not provide perfect security.  No electronic transmission of information over the Internet or electronic information-storage technology can be guaranteed to be completely secure, and we cannot promise or guarantee that that your information or your use of the Website will be free of security risks; in particular, we cannot promise or guarantee that cybercriminals, hackers, or other unauthorized parties will be unable to overcome our security measures and thereby access, collect, misappropriate, or modify your information.  You should access the Website only within a secure environment.  We will make reasonable efforts to protect your personal information, but transmission of your personal information to and from the Website, and your use of the Website, is at your own risk. 

CAN MINORS USE THIS WEBSITE?

In Brief:  No.  You must be of age 18 or older to visit or to interact with the Website.

This Website is intended for use only by adults over the age of 18.  IF YOU ARE UNDER THE AGE OF 18, YOU MAY NOT VISIT, INTERACT WITH, OR USE THE WEBSITE IN ANY WAY.

ADDITIONAL INFORMATION FOR USERS IN THE UK AND EUROPEAN UNION

In Brief:  Stealth is the data controller of personal information processed through the Website.  We will process your personal information when we believe it is necessary and we have a valid legal basis to do so under applicable law, such as with your consent, to comply with legal obligations, to protect vital interests, or to fulfill our legitimate business interests.  If you are in the UK or the European Union (EU), you have rights that allow you access to and control over your personal information.

The data controller for data collected through the Website is:

Stealth Software Technologies, Inc.
12100 Wilshire Blvd., 8th Floor
Los Angeles, CA 90025
USA

The General Data Protection Regulation (GDPR) and UK GDPR require that we explain the legal bases we rely on to process your personal information.  We may rely on the following legal bases to process your personal information:

  • Consent.  We may process your information if you have given us consent to use you personal information for a specific purpose.  You may withdraw your consent at any time.
  • Legal Obligations.  We may process your information when we believe it is necessary to comply with our legal obligations, such as to cooperate with law enforcement or a regulatory authority, to exercise or defend our legal rights, or to disclose your information as evidence in litigation or a similar proceeding in which we are involved.
  • Vital Interests.  We may process your information when we believe it is necessary to protect your vital interests or the vital interests of another party, such as in situations involving threats to the life or safety of any person.
  • Legitimate Business Interests.  We may process your information when we believe it is necessary to fulfill our legitimate business interests.  In particular, we will process personal information you voluntarily provide to us in communications, including through contact forms on the Website, to fulfill our legitimate business interests in responding to your communications and in marketing our products and services.  We will process your personal information that is automatically collected when you visit and/or interact with the Website to fulfill our legitimate business interests in providing, maintaining, and improving the Website and in developing our business.

Information we collect from you is processed in the United States.  When we transfer your information from within the EU (respectively the UK) to a jurisdiction outside the EU (respectively the UK), we will do so using safeguards adequate under GDPR (respectively UK GDPR).

If you are in the EU (respectively the UK), your rights under GDPR (respectively UK GDPR) include:

  • The right to access.  You have the right to request copies of your personal information that we process.  We may charge you a small fee for this service.
  • The right to rectification.  You have the right to request that we correct any information that you believe is inaccurate, and you have the right to request that we complete personal information that you believe to be incomplete.
  • The right to erasure.  You have the right to request that we erase your personal information, under certain conditions.
  • The right to restrict processing.  You have the right to request that we restrict the processing of your personal information, under certain conditions.
  • The right to object to processing.  You have the right to object to our processing of your personal information, under certain conditions.
  • The right to data portability.  You have the right to request that we transfer your personal data that we have collected to another organization or directly to you, under certain conditions.
  • The right to withdraw your consent.  If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time.  You can withdraw your consent at any time by contacting us by using the contact details provided in the section “HOW CAN YOU CONTACT US ABOUT THIS PRIVACY POLICY?” below.  However, please note that this will not affect the lawfulness of the processing before its withdrawal, nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

If you would like to exercise any of these rights, please contact us via e-mail at:  [email protected].  We reserve the right to request reasonable evidence to verify your identity before providing you with information.  In the event that we are not able to provide information that you have requested, we will explain why we are so unable.

If you are located in the European Economic Area (EEA) or the UK and believe that we are unlawfully processing your personal information, you have the right to lodge a complaint with your local data protection supervisory authority.  For a list of supervisory authorities, current as of the date of this Privacy Policy, visit:  https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm.  If you are located in Switzerland, contact information for the data protection authorities are currently located at:  https://www.edoeb.admin.ch/edoeb/en/home.html.

ADDITIONAL INFORMATION FOR USERS IN CANADA

In Brief:  In Canada, you have rights that allow you access to and control over your personal information.  In some exceptional cases, we may be legally permitted to process your information without your consent.

If you are located in Canada, you have certain rights under applicable data protection laws.  These may include the right to (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability.  In certain circumstances, you may also have the right to object to the processing of your personal information.  You can make such a request by contacting us by using the contact details provided in the section “HOW CAN YOU CONTACT US ABOUT THIS PRIVACY POLICY?” below.

If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time.  You can withdraw your consent at any time by contacting us by using the contact details provided in the section “HOW CAN YOU CONTACT US ABOUT THIS PRIVACY POLICY?” below.  However, please note that this will not affect the lawfulness of the processing before its withdrawal, nor when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

In some exceptional cases, we may be permitted under applicable law to process your information without your consent.  Such cases include, for example:

  • If collection is clearly in the interest of an individual and consent cannot be obtained in a timely matter.
  • For investigations and for detection and prevention of fraud.
  • For business transactions, provided certain conditions are met.
  • If information is contained in a witness statement and collection is necessary to assess, process, or settle an insurance claim.
  • To identify injured, ill, or deceased persons and to communicate with next of kin.
  • If we have reasonable grounds to believe that an individual has been, is, or may be a victim of financial abuse.
  • If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province.
  • If disclosure of information is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records.
  • If information was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced.
  • If collection of information is solely for journalistic, artistic, or literary purposes.
  • If the information is publicly available and is specified by the regulations.

ADDITIONAL INFORMATION FOR USERS IN CALIFORNIA

In Brief:  When you use the Website, parties other than us may collect information about your online activities over time and across different websites.

The California Online Privacy Protection Act (CalOPPA) requires us to disclose that parties other than Stealth may collect personally identifiable information about your online activities over time and across different websites when you use the Website.

DO WE MAKE CHANGES TO THIS PRIVACY POLICY?

In Brief:  We will update this notice as necessary to remain compliant with relevant laws.

We may update this privacy policy from time to time.  The updated version will be indicated by the “last updated” date on this policy, and it will be effective as soon as it is accessible on the Website.  We encourage you to review this privacy policy frequently to remain informed about our privacy practices.

HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have any questions or comments regarding this Policy, you can contact us by e-mail at [email protected].