PRSONAS Privacy and Information Handling Practices

As the operator of a secure software solution designed to humanize the digital experience by promoting the use of intelligent avatars as a primary means of communication, PRSONAS is committed to maintaining the integrity, privacy, and security of the information that is processed by our platform. This document describes the policies and practices that guide our provision of services to our customers and their constituents.

Compliance with Laws
The practices described in this document do not supersede or replace applicable laws that govern how PRSONAS or our customers use and disclose sensitive and personally identifiable information. In their use of the PRSONAS services, our customers are required to remain compliant with all applicable laws.

Use of the PRSONAS Platform
The PRSONAS platform provides an avatar that communicates information to and collects information from our customers constituents for a variety of purposes. The information that is transmitted and collected through the PRSONAS Platform may be sensitive or personally identifiable information that is certain controls or restrictions based on applicable law or it may be other forms of information that is not subject to regulatory guidelines.

PRSONAS customers are required to request, use and disclose information made available through the PRSONAS Platform in accordance with all applicable laws and in compliance with the obligations that are placed on them pursuant to the licensing agreements that they sign with us.

Prohibited Uses
In operating and managing the PRSONAS Platform and associated services, PRSONAS does not rent or sell sensitive or personally identifiable information for PRSONAS’s own purposes or for purposes of third parties.

Customers may not use our services to conduct the following activities:
a) uses prohibited by or that would violate any applicable law;
b) uses which are defamatory, deceptive, obscene, or otherwise inappropriate;
c) attempts to impersonate another person or business; and,
d) misrepresenting the source or nature of the information provided.

Safeguarding Protected Information
Maintaining the privacy and security of sensitive and personally identifiable information accessible through the PRSONAS Platform is of the utmost importance to us. We have implemented administrative, physical, and technical security safeguards designed to prevent unlawful use or disclosure of this sensitive information. These safeguards include:

  • Use of appropriate technologies. PRSONAS has selected our core technologies and vendor partners based on their ability to support highly regulated and secure computing environments.
  • Disciplined operational framework. PRSONAS has developed, documented, and implemented an operations framework that augments the technical safeguards deployed in the PRSONAS services. This framework segments activity and access to data by role, provides necessary controls and processes to manage change, and ensures that the PRSONAS staff are properly trained in their responsibilities regarding the safekeeping of sensitive information.
  • Audits. PRSONAS performs regular and recurring security audits, including audits performed by independent auditing entities and penetration testing, on the PRSONAS Platform and data services.
  • Industry Certifications. PRSONAS has developed and implemented an operations framework that is designed to meet the requirements of the relevant industry certification programs. At the appropriate time, we will seek certification from the relevant standards groups.

Consent and Disclosures
Customers are required to obtain all necessary consents and authorizations required under applicable law before sending or receiving sensitive information through or collecting information from the PRSONAS Platform. PRSONAS will refer any consumer questions regarding consent or other requests related to disclosures to the compliance department of the customer in question.

Breach and Notification
PRSONAS will report breaches and misuses of sensitive information or potential security issues within the time frames required by applicable law. Additionally, PRSONAS maintains an Ethics and Compliance Hotline where any concerned individual or business entity may report a suspected Breach, misuse of sensitive information, or security incident at any time. This hotline can be reached at compliance@prsonas.com.

Contacts
If you have any questions, comments, or concerns about the privacy and information
handling practices contained in this document, please contact the PRSONAS team:

Chief Compliance Officer
PRSONAS, Inc
11845 Retail Drive, #1007
Wake Forest, NC 27587
compliance@prsonas.com