Privacy Policy

Intracom Privacy Policy

This Intracom Privacy Policy describes how Intracom Systems LLC as a data controller collects, uses and shares your personal data.

We have developed this policy because you are entitled to feel confident about the privacy and security of your Personal Information. We have appropriate technical and operational measures in place to prevent loss, misuse, unauthorized access and alteration of all data (including Personal Information) under our control. Our security arrangements and policies are regularly reviewed and access to our records is restricted to authorized personnel.

When we refer to Personal Information in this privacy policy, we mean any information relating to an identified or identifiable natural person; an identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identification number or to one of more factors specific to his physical, physiological, mental, economic, cultural or social identity (“Personal Information”). Accordingly, we may hold and use Personal Information about you in your capacity as a business customer, as an individual acting on behalf of a business customer, or in any other capacity, for example as a visitor to our Websites.

If you access our Website from the European Economic Area (EEA) please also see additional information on our use of your Personal Information and your privacy rights at the end of this privacy policy.

Scope of Privacy Policy

This privacy policy sets out the basis on which any Personal Information we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your Personal Information and how we treat it.

This privacy policy does not cover information, communication or material you submit to the Websites that does not meet the definition of Personal Information. Any information that is not Personal Information, that you provide in any manner and for any reason, will not be deemed confidential or proprietary and may be used by Intracom at any time, for any reason, and without prior or subsequent notice to you. In addition, we may reproduce, transmit, publish, broadcast, modify, revise or otherwise use such information, communication or material without your permission and without financial or other liability to you.

This privacy policy also does not apply to any other company’s websites, even if you access them through Intracom. If you disclose Personal Information to other companies your information will be dealt with according to their privacy practices.

Collection of Personal Information

Registration with our Portal

You may be required to register in order to use our Portal and certain other areas within the Websites, and in the course of the registration process, you may provide your name, address, email address, phone number, account number and other voluntary Personal Information. We will use this information to provide the account, newsletters and other information you have requested, and to help us better target our other marketing activities.

Contacting us

You can always contact us via email or via our “contact us” section on our website, e.g. to send inquiries about our services. In this context, we will process your name, e-mail address, content of the message and other Personal Information you provide to us. Purpose of the processing is to process your inquiry.

Location of Data

The data that we collect from you (including Personal Information) may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). Information may also be transferred to our other offices or processed by third parties acting on our behalf and such locations may be outside the EEA. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy. Via the technical and organization measures referred to above, Intracom will do its best to protect your Personal Information, we cannot guarantee the security of your data transmitted to our Website and any transmission is at your own risk.

Sharing of Data

We may share your Personal Information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.

In the course of providing our Products and Services to you, we may engage third party service providers to assist us. They may process Personal Information exclusively on our behalf. The Personal Information transfer is privileged under article 28 GDPR. In case such third party service provider is located outside the EEA, please see Section “Transfers from EEA to third country”.

Transfers from EEA to third country

When we collect Personal Information from customers located in the EEA, and this Personal Information is transferred to a third country outside the EEA, the collection, use and retention of the Personal Information is conducted in accordance with Standard Contractual Clauses approved by the European Commission. These clauses ensure that your data is protected with appropriate safeguards, in compliance with applicable data protection laws. For more information, please refer to the Standard Contractual Clauses.

Where a third party service provider that we engage, processes Personal Information outside of the EEA (e.g. Unites States of America ), Intracom will obtain assurances from such third party that (i) it is included in the Data Privacy Framework List (based on the Adequacy Decision of the EU Commission) or (ii) otherwise safeguards your Personal Information consistently with the same level of privacy protection as is required by Standard Contractual Clauses (see below).

In the context of an onward transfer, Intracom has responsibility for the processing of Personal Information it receives under the Standard Contractual Clauses and subsequently transfers to a third party acting as an agent on its behalf. Intracom shall remain liable under the Standard Contractual Clauses if its agent processes such Personal Information in a manner inconsistent with the Standard Contractual Clauses, unless Intracom proves that it is not responsible for the event giving rise to the damage.

In addition, we may be required to disclose Personal Information in response to lawful requests by public authorities, including meeting national security or law enforcement requirements.

Retention Periods

The time period for which we keep information varies according to what the information is used for. In some cases, there are legal requirements to keep Personal Information for a minimum period. Unless there is a specific legal requirement for us to keep the information, we will retain it for no longer than is necessary for the purposes for which the Personal Information was collected or for which it is to be further processed.

We may use the Personal Information in the following ways:

• to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;

• to provide you with information about other goods and services we offer that are similar to those that you have already purchased, enquired or viewed on the Websites; and

• to answer questions or queries you have submitted to us via the Websites.

Access to Personal Information

Certain privacy laws entitle you to access the Personal Information we hold about you and to have any inaccuracies rectified. Where you are entitled to do so, any request for access to Personal Information may be subject to the payment of a fee up to the relevant statutory limit.

Additional information if you access our website from a country in the European Economic Area (EEA):

The following information only applies to you if you access our Website from the EEA.

Legal bases for the processing of Personal Information

As outlined above, we process your Personal Information for different purposes. Below you may find the legal bases that justify these processing activities. This also includes the sharing of:

• Informational use of the website: The legal basis for the processing is Article 6 (1) (1) (b) GDPR. The Personal Information is necessary for the provision of our Products and Services.

• Registration within our Portal: The legal basis for the processing is Article 6 (1) (1) (b) GDPR as the Personal Information is necessary to provide the user account. This may also include information (including our newsletter) you requested from us.

• Contacting us: The legal basis for the processing is Article 6 (1) (1) (b) GDPR where the processing is necessary to perform an existing contract or as part of contract initiation. Further, we may rely on Article 6 (1) (1) (f) GDPR. We have a legitimate interest in properly processing and responding to your requests.

Your rights

You may be entitled to exercise some or all of the following rights:

• require: (i) information whether your Personal Information is retained and (ii) access to and/or duplicates of your Personal Information retained, including the purposes of the processing, the categories of Personal Information concerned, and the recipients of Personal Information as well as potential retention periods;

• request rectification, removal or restriction of your Personal Information, e.g. because: (i) it is incomplete or inaccurate, (ii) it is no longer needed for the purposes for which it was collected, or (iii) the consent on which the processing was based has been withdrawn;

• refuse to provide and – without impact to processing activities regarding Personal Information that have taken place before such withdrawal – withdraw your consent to processing of your Personal Information at any time;

• object, on grounds relating to your particular situation, to processing of your Personal Information, in case such processing is either based on our or a third party’s legitimate interests or on a performance of a task carried out in the public interest. In this case, please provide us with information about your particular situation. After the assessment of the facts presented by you we will either stop processing your Personal Information or present you our compelling legitimate grounds for an ongoing processing;

• take legal actions in relation to any potential breach of your rights regarding the processing of your Personal Information, as well as to lodge complaints before the competent data protection regulators; and/or

• require: (i) to receive the Personal Information concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and (ii) to transmit those Personal Information to another controller without hindrance from our side; where technically feasible you shall have the right to have the Personal Information transmitted directly from us to another controller.

You may (i) exercise the rights referred to above or (ii) pose any questions or (iii) make any complaints

regarding our data processing by contacting us under the contact details set out above.

Contact:

Intracom Systems LLC

12th Floor

One State Street

NY 10004

United States

contactlegal@ipc.com

Website Last Updated: 6 February 2025