Effective as of November 24, 2025

TABLE OF CONTENTS 

Purpose and Scope 
How We Obtain Information 
How We Use Information 
Legal Basis 
How We Disclose Information Collected 
International Transfers 
Security and Breach Notification 
Retention 
Your Privacy Choices 
Additional Information for Individuals Residing in Certain U.S. States 
General 

Purpose and Scope

Netrio, LLC, including its subsidiaries and affiliates, provider of the NetrioNow application, described more fully below, (collectively, “NetrioNow,” “we,” or “us”), respects the privacy of individuals. 

This Services Privacy Statement (“Services Notice”) applies to our collection, use, and disclosure of information obtained in connection with the provision and use of our software applications and Mobile Applications (the “Subscription Service”) to the extent that we act as data controller (for example, in respect of account management and billing information). It also applies to our processing of personal data in the context of the ancillary services provided through or by other platforms outside of the Subscription Service (including, for example, NetrioNow Learning, NetrioNow Community, NetrioNow Support, the App Store, the Partner Portal, and any other sites in the NetrioNow ecosystem) to the extent that we are acting as a data controller. In this Services Notice, all of these offerings in respect of which we are acting as data controller are collectively referred to as the “Services.” 

For clarity, this means that this Services Notice does not apply where we process personal data as processor on behalf of our Customers in the context of providing the Subscription Service. We or our Customers or Partners may also provide applications and integrations hosted by third party services. This Services Notice does not cover such third-party services even if this information is collected using our Service. 

This Services Notice also does not apply to information or data collected by NetrioNow for other purposes outside of or unrelated to the Service. Please see our Website and Event Privacy Statement for details on our privacy practices with respect to data processed in relation to our websites, events and marketing activities or our Applicant Privacy Statement which covers our privacy practices in relation to an individual’s application for employment at NetrioNow. 

For the purposes of this Services Notice: 

• “Customer” means the entity that purchases our Service (or who obtains a free trial of our Service, where applicable). 

• “Customer Agreement” means the definitive agreement between Customer and NetrioNow under which the Customer purchased access to the Service. 

• “Customer Data” means the electronic data uploaded into the Subscription Service by or for Customer or its Users. 

• “Account Data” means a credit card or billing information, and the Customer or Partner representatives’ contact information. 

• “Mobile Applications” means applications downloaded by an authorized user of our software applications to a mobile device. 

• “Usage Data” means data derived from Users’ use of the Service. For the avoidance of doubt, Usage Data does not include or form part of Customer Data. 

• “User” means an individual authorized to access and use the Services. 

• “Partner” means an entity that sells NetrioNow products and services or provides services or technology to NetrioNow customers that relate to the Service. 

How We Obtain Information 

We collect several types of information from and about our Customers, Users, and Partners in the course of hosting, providing, maintaining, supporting, and improving our Services. 

We may act as a data controller with respect to personal data uploaded to our platforms. However, for the avoidance of doubt, we act as a data processor when processing Customer Data on behalf of our Customers in the course of providing the Subscription Service to them. 

We may process personal data as a data controller that Users choose to submit to these platforms, which may include name, contact details, log in details, job titles, photographs, and education history. Where Users or individuals choose to provide feedback about the Services to our research team, we may process contact details, take photographs, collect audio and/or video recordings of Users. 

We also collect Account Data from our Customers or Partners. Account data includes credit card or billing information and the Customer or Partner representatives’ contact information, job title, or information about the Services purchased or configured. 

We may obtain additional information through Mobile Applications that Customers or their Users download to their mobile device. In addition to the personal data Users provide, we also collect certain other personal data through the use of our Mobile Applications. For example, our Mobile Applications may also provide us with information related to a User’s use of the Mobile Applications, including information regarding a User’s device and operating system, language, location, and time zone. Mobile 

Applications may also collect information regarding a User’s interaction with Mobile Applications, which NetrioNow may use to provide and improve the Mobile Application and/or Services. 

Additionally, we collect Usage Data directly from the User’s use of the Services. This may include usage patterns, session duration, traffic data, location data, approximate location, logs and other communication data, and the resources that the User accesses, as well as information about the User’s device and internet connection, including their operating system and browser type. 

Finally, we may process certain User login data for certain Services. 

How We Use Information 

We may process personal data for a number of reasons. We may process Account Data for billing, account management, and contracting purposes. We may process Usage Data for general maintenance, support, security, and to improve the Service. We may process User log-in data to administer individual accounts related to training/learning activities. 

Where we have a Customer’s prior authorization and agreement, we may process their Customer Data for the purpose of training NetrioNow’s artificial intelligence (“AI”) and machine learning (“ML”) models. Additionally, we may also process other personal data which is not Customer Data (including data inputted by Users into other NetrioNow platforms), for the purpose of training these AI and ML models. 

We may also deploy AI and ML features within the Services to provide a better experience, and use of these features may involve us processing any personal data submitted to them. By way of example, we may process data submitted in NetrioNow Support to generate suggested solutions for our Users or to produce more relevant search results. We recommend that Users do not submit sensitive or confidential information to NetrioNow Support. 

We may use third party service providers to deploy or assist in the deployment of AI or ML features or to train our models, which may involve the transfer of personal data to those third parties. 

By registering for the Service, NetrioNow will create a profile on the User’s behalf that will allow the User to access any of the other NetrioNow designated sites using the same username and password for all sites. The personal data may be collected during registration and/or use of any one of these sites that the User choose to make public, may be visible to other users of the sites. In addition, the User’s personal data may be used by the other sites for the purposes of enhancing the User’s experience and improving the quality of our services. 

We may also process Account Data and other personal data we receive from Users or representatives of Customers or Partners for other purposes, including to: 

• Operate, maintain, and improve the Services (including by asking for feedback in certain circumstances); 

• Develop new products and features; 

• Provide Users, Customers, and Partners with information, products, or services that they request from us; 

• Carry out our obligations and enforce our rights arising from any contracts entered into between us; 

• Conduct industry analysis, benchmarking, analytics, and other business purposes; 

• Enforce our legal rights or to defend a claim or otherwise to protect the rights and property of NetrioNow and others; 

• Comply with legal and financial obligations. 

Legal Basis 

To the extent that we process personal data, including Account Data or Usage Data or certain User log-in data, we do so on the basis of our legitimate business interest to do so (taking into account the fundamental privacy rights of any relevant individuals), and/or on the basis of compliance with a legal obligation, and/or on the basis of performance of a contract, and/or on the basis of consent, depending on the specific activity involved. 

Where we process personal data to train AI or ML models, this processing is conducted either on the basis of the legitimate interests of both NetrioNow and our Customer, or consent from applicable data subjects, in order to improve our AI and ML models and, therefore, to provide a more accurate and reliable service to NetrioNow’s Customers and Users. Where applicable, we also take steps to minimise the amount of personal data processed for this purpose. 

How We Disclose Information Collected 

We may disclose personal data covered by this Services Notice to the following categories of recipients: 

• To our subsidiaries and affiliates as necessary for the purposes outlined above. 

• To our contractors, Partners, and service providers we use to support our Services and Partners who provide services on our behalf and on behalf of our Customers (including AI and ML service providers, where applicable). 

• To a potential buyer (and its agents and advisors) in connection with any proposed merger, acquisition, or any form of sale or transfer of some or all of our assets (including in the event of a reorganization, dissolution, or liquidation), in which case personal data held by us about our Customers, Users, and Partners will be among the assets transferred to the buyer or acquirer. 

• To any competent law enforcement body, regulatory, government agency, court or other third party to: (i) comply with any court order, a request from any competent law enforcement agency, or any other legal obligation; (ii) enforce or apply the terms of the Customer Agreement or any contract to which NetrioNow is party; (iii) enforce or apply the terms of the agreement for partnership with our Partners; (iv) protect the rights, property, or safety of NetrioNow, its affiliates, employees, and agents and/or NetrioNow’s Customers, Users, or others; and (v) to defend against a legal claim. 

• To any other user of the site or any other sites in the NetrioNow ecosystem, where the User chooses to make that information public. 

• To any other person at your direction or with consent to the disclosure. 

We also disclose aggregated or de-identified information that cannot reasonably be used to identify you. NetrioNow processes, maintains, and uses this information only in a de-identified fashion and will not attempt to re-identify such information, except as permitted by law. 

International Transfers 

We may store and process data covered by this Services Notice in: (i) any country where we have facilities; and (ii) any country in which we engage service providers. 

For international transfers of personal data from the EEA, UK, or Switzerland, we implement such measures as are necessary to ensure we provide appropriate safeguards for the transferred data, including through the use of Standard Contractual Clauses or another lawful transfer data transfer mechanism. 

Security and Breach Notification 

NetrioNow maintains appropriate technical and organisational measures designed to protect the data covered by this Services Notice from accidental or unlawful destruction, loss, alteration, unauthorised disclosure, and access. NetrioNow personnel and service providers with access to such data are required to keep them confidential and secure. 

Retention 

We retain personal data only for so long as we have an ongoing legitimate business need to do so (for example, to provide the User with a service they or the Customer or Partner has requested or to comply with applicable legal, tax, or accounting requirements, or to maintain a record of consent preferences). 

Your Privacy Choices 

Where we act as data controller, we provide Users with certain choices regarding the personal data they provide to us in accordance with applicable laws. Depending on where the User resides, the User may have the following rights: 

• If a User wishes to access, correct, update, or request deletion of personal data, they may contact us to request the exercise of such rights. 

• Depending on where you live, you may have additional specific privacy rights under applicable law, including the right to object to processing, to request restriction of processing, or to request a portable copy of personal data, or to lodge a complaint with us in relation to our processing of a User’s personal information. We will process your requests to exercise such rights in accordance with applicable data protection laws. 

• Users have the right to complain to a data protection authority if they are unhappy about our collection and use of their personal data. 

• Under applicable laws, Users may have the right to appeal where we make a decision in relation to their request regarding their personal data. 

We will respond to such requests in accordance with the requirements of applicable data protection laws. Please note that in order to fulfil a User’s request, we may need the User to provide certain information to verify their identity. Additionally, depending on where you reside, you can use an authorized agent to exercise your rights. We may request evidence that the User has provided such agent with authority to submit requests on their behalf and ask that the User verify their identity directly with us. If you are an authorized agent seeking to make a request, please contact us at privacy@netrio.com. 

To exercise certain rights under applicable laws, Users may submit a form [INSERT LINK]. Alternatively, Users may contact us to exercise these or other rights using the details in the “Contact Information” section below. 

Additional Information for Individuals Residing in California and Certain Other U.S. States 

If you are a resident of the State of California, which has enacted the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (as amended, the CCPA), or if you are a resident of another U.S. state where NetrioNow is subject to similar requirements (the “Other States”), this section applies to you. 

How We Collect, Use, and Disclose Personal Information 

In addition to the chart below:

For information about the sources and categories of the personal information that we collect, please see the “How We Obtain Information” section above.

For information on how and for what purposes we use personal information, please see the “How We Use Information Collected” section above.

For information on how we disclose personal information (including to service providers), please see the “How We Disclose Information Collected” section above.

How We Disclose Information Collected” section above.

Approximate geolocation data (such as your city of residence) | From you; From your Employer; From your online activity or transactions with us, including with our websites, apps, and other digital properties; From cookies or other tracking technologies, unless you opt out | To provide information, products, and/or services that you have requested (or have been requested on your behalf); To provide customer support; To operate, maintain, and improve our products and services; To keep our products and services safe and secure; To promote our products, services, and Events to you; To perform our obligations and enforce our rights under our contract with you or your Employer; To comply with our legal and regulatory obligations | Our subsidiaries and affiliates; Our sub-processors; Our Platform Service Providers; Our marketing and advertising service providers; Our data analytics service providers; Any other person at your direction or with your consent; Law enforcement, government, or other competent agencies when validly required by law | | Audio, electronic, visual, or similar information (such as photographs, audio recordings, or video recordings) | From you | To provide information, products, and/or services that you have requested (or have been requested on your behalf); To provide customer support; To operate, maintain, and improve our products and services; To promote our products, services, and Events to you; To perform our obligations and enforce our rights under our contract with you or your Employer; To comply with our legal and regulatory obligations; With your or your Employer’s consent: To train and improve NetrioNow’s artificial intelligence (“AI”) and machine learning (“ML”) models | Our subsidiaries and affiliates; Our sub-processors; Our Platform Service Providers; Our marketing and advertising service providers; Our data analytics service providers; Third party services in connection with developing NetrioNow’s AI/ML; Any other person at your direction or with your consent; Law enforcement, government, or other competent agencies when validly required by law | | Inferences (such as preferences, characteristics, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes) | From your online activity or transactions with us, including with our websites, apps, and other digital properties; From cookies or other tracking technologies, unless you opt out | To provide information, products, and/or services that you have requested (or have been requested on your behalf); To provide customer support; To operate, maintain, and improve our products and services; To promote our products, services, and Events to you; To perform our obligations and enforce our rights under our contract with you or your Employer; To comply with our legal and regulatory obligations | Our subsidiaries and affiliates; Our sub-processors; Our Platform Service Providers; Our marketing and advertising service providers; Our data analytics service providers; Any other person at your direction or with your consent; Law enforcement, government, or other competent agencies when validly required by law |

Your California and Other State Privacy Rights

If you are a California resident or a resident of one of the Other States, you may have the following rights under applicable law:

Right to Know. You have the right to request that we disclose to you the personal information we collect, use, or disclose, and information about our data practices.

Right to Request Deletion. You have the right to request that we delete personal information we have collected from you.

Right to Correct. You have the right to request that we correct inaccurate personal information that we maintain about you.

Right to Opt-Out of Sale or Sharing. You have the right to opt out of the “sale” or “sharing” of your personal information. We do not “sell” personal information as most people would commonly understand that term. However, we may “share” your personal information with third parties for cross-context behavioral advertising purposes. You can opt out of this sharing by clicking “Do Not Sell or Share My Personal Information” on our website or by contacting us using the information provided below.

Right to Limit Use of Sensitive Personal Information. You have the right to limit our use and disclosure of sensitive personal information to certain specified purposes. We do not use or disclose sensitive personal information for purposes other than those specified purposes, so this right may not apply.

Right to Non-Discrimination. You have the right not to receive discriminatory treatment for exercising any of these rights.

To exercise these rights, please contact us using the information provided in the “Contact Information” section below or submit a request at [INSERT LINK]. We will need to verify your identity before processing your request, which may require us to request additional personal information from you or require you to log into your account, if you have one. In certain circumstances, we may decline or limit your request, particularly where we are unable to verify your identity or locate your information in our systems, or as permitted by law.

You may use an authorized agent to submit a request on your behalf if you provide the authorized agent written permission signed by you. We may request that you verify your identity directly with us and confirm that you provided the authorized agent permission to submit the request.

Retention

We retain personal information for as long as necessary to fulfill the purposes outlined in this Services Notice, unless a longer retention period is required or permitted by law.

Appeals Process

If you are a resident of certain states, you may have the right to appeal our decision with respect to your request by contacting us using the information provided in the “Contact Information” section below.

General

Changes to this Services Notice

We may update this Services Notice from time to time. When we do, we will post an updated version on this page, unless another type of notice is required by applicable law. By continuing to use our Services or providing us with personal data after we have posted an updated Services Notice, or otherwise notified you if required by law, you consent to the revised Services Notice.

Contact Information

If you have any questions or concerns about this Services Notice or our privacy practices, please contact us at:

Email: privacy@netrio.com

For individuals in the European Economic Area, United Kingdom, or Switzerland, our representative can be contacted at:

Email: verasafe.com