Privacy policy.

Last updated September 23, 2021

This is the Privacy Notice for Illuno Inc. and our affiliates and subsidiaries (collectively, “Illuno,” “us,” or “we”). It explains how we collect and use information via illuno.com and other websites and digital channels we own or operate (the “Site”), our world class software for administering off-duty officer programs (the “Platform”), and other services, solutions, and products we offer (altogether with the Site and Platform, the “Services”). Please read this Privacy Notice carefully to understand our privacy practices.

This Privacy Notice is governed by and part of our Terms of Use. Your use of our Services is subject to this Privacy Notice and our Terms of Use, including its applicable limitations on damages and the provisions regarding resolution of disputes. Capitalized terms not defined in this Privacy Notice have the meanings given to them in the Terms of Use. Any additional notices we may provide you about our privacy practices will be considered to form part of this Privacy Notice.

CONSENT

By using or accessing our Services in any manner, you acknowledge and accept this Privacy Notice, and you consent to Illuno’s collection, use, and disclosure of your information as described below. If you do not agree with this Privacy Notice, do not use our Services.

PERSONAL INFORMATION

As used in this Privacy Notice, “Personal Information” means 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, such as:

• Identifiers (e.g., name, address, username, IP address, email address);
• Protected Information (e.g. race, citizenship, marital status, sex);
• Biometric information (e.g., DNA, face/voice prints, health data) and audio, electronic, visual, thermal, olfactory, or similar information;
• Commercial information (e.g., products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies);
• Employment-related information (e.g. current or past employment);
• Non-public educational information, including information protected under the Family Educational Rights and Privacy Act (20 U.S.C. § 1232g, 34 C.F.R. Part 99);
• Internet activity (e.g., interactions with a website, content, or advertisement);
• Inferences drawn from Personal Information to create a profile about preferences, characteristics, trends, predispositions, behavior, attitudes, and aptitudes; and
• Sensitive Personal Information (e.g. social security or government ID number; precise geolocation; racial or ethnic origin; biometrics; health information; union membership; contents of messages when we are not the recipient).

Personal Information does not include (i) publicly available information (ii) aggregate information, meaning data about a group or category of services or users from which individual identities and other Personal Information has been removed; or (iii) deidentified information that cannot reasonably be used to infer information about, or otherwise be linked to, a particular consumer.

INFORMATION WE COLLECT

The types of Personal Information we collect about you and the manner of collection depends on how you interact with us, whether as an Officer, Client, Department, or other user of the Services. We only collect, use, retain, and share Personal Information as reasonably necessary and proportionate to provide the Services or for other purposes that we disclose to you and are compatible with the context of how we collected your Personal Information. We will update this Privacy Notice or otherwise notify you before we collect additional categories of Personal Information or use your Personal Information for purposes that are incompatible with the purpose stated at the time of collection.

Categories of Personal Information

During the preceding 12 months, we have collected these categories of Personal Information:

• Identifiers
• Employment-related information
• Sensitive personal information
• Internet or other similar activity

Sources of Collection

We collect Personal Information about you directly from you, from your Department, and indirectly from your use of the Services, as follows:

• Officers: If you are an Officer, we collect Personal Information about you when you register with Illuno. Once registered, Officers can use Illuno to accept jobs, clock in/clock out, submit timesheets, and manage their Personal Information on the Platform. We collect your identifiers (e.g. name, mailing address, phone, and email), employment-related information (e.g. job title, Department), sensitive personal information (e.g. social security number or tax ID) and other Personal Information necessary to facilitate our Clients’ ability to hire and pay you via the Services. We collect this information directly from you with your consent. If your Department uses Illuno to facilitate its off-duty officer program, we may receive some or all this information from your Department administrator in our role as a service provider to your Department.
• Departments: If you are a Department administrator, we will collect your identifiers and employment-related information like your name, email, and job title. Once registered as a Department admin, you can use the dashboard to approve requests, staff Officers, manage contracts, receive payments for Officer services, and access real time data for Officer staffing and scheduling. We collect and use this information with your consent and in our role as a service provider to the Department. Illuno uses this information to facilitate your use of the Platform dashboard on behalf of your Department and to communicate with you about the Services.
• Clients: If you register as the point of contact for a Client using Illuno to hire off-duty Officers, we will collect your identifiers and employment-related information like your name, email, and job title. As a registered Client point of contact you can request Officers for off-duty services, manage contracts, and facilitate payments. We collect this information directly from you with your consent in our role as a service provider to the Client. We use this information to facilitate the Client’s use of the Services, including your use of the Platform Client dashboard and communications with you as the Client point of contact.
• Inquiries: If you contact us via the Site or by email, phone, or other means to request information or support, we will collect your name, contact information, and employment-related information as needed to respond to your inquiry. We collect this information with your consent, and we use it for the purposes stated at the time of collection.
• Technical Information: When you visit the Site or use the Platform, we automatically collect technical information that may include some Personal Information. More specifically, we collect your device data (e.g. IP address, device ID, mobile network information) and usage details (e.g. session active time, referring URL, content viewed, functions completed). We collect this information to achieve our legitimate interest of providing and improving our Services.

Payroll and Payment Processing

Illuno is not a payment processor. All payments made through the Services are processed by a PCI-compliant payment processor or directly through your banking institution. If you are an Officer using Illuno through your Department, please direct questions about payments to your Department administrator.

Retention of Personal Information

Illuno retains all categories of Personal Information we collect only as long as your Illuno account remains active or as necessary to provide you with the Services you request. We may also retain and use Personal Information to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. We regularly review and deidentify unnecessary Personal Information and other data and we periodically deidentify unused accounts.

Other Uses

In addition to the specific uses described above, Illuno might use also your Personal Information to:

• Provide, maintain, and improve our Services.
• Send you support and administrative messages.
• Monitor your compliance with any of your agreements with us.
• Detect, investigate, and prevent fraudulent transactions and other illegal activities and protect the rights and property of Company and others.
• Protect your privacy and enforce this Privacy Notice.
• If we believe it is necessary, to identify, contact, or bring legal action against persons who may be causing injury to you, to us, or to others.
• Comply with a law, regulation, legal process, or court order.
• Fulfill any other purpose to which you consent.

DISCLOSING PERSONAL INFORMATION

Recipients

We may disclose Personal Information to the recipients described below, or to other recipients with your permission or as required by law.

• Your Department: If you use Illuno through your Department, we will share information with your Department such as the jobs you accept, your schedule, and information related to your receipt of payment for those jobs. Your Department uses this information for scheduling, payroll, and other purposes according to the Department’s own policies and practices. Your Department may integrate this information into its on-duty staffing software.
• Clients: If you accept a job from a Client, we may disclose Personal Information like your contact information, schedule, pay rate, credentials, and Department contact information as needed for the Client to use our Services. We will not disclose any Personal Information to a Client except as needed for the Client to staff jobs, pay Officers, and communicate with Officers and Departments as part of the Services.
• Service Providers: Illuno uses a variety of service providers such as data hosting companies, analytics services, email hosting services, and payment processors. The type of information that we share with a service provider will depend on the service that they provide to us. Our service providers are subject to contractual agreements that protect your Personal Information, and we require all service providers to maintain confidentiality standards that are commercially reasonable to ensure the security of your Personal Information. However, the use of your Personal Information by our service providers is ultimately governed by their privacy notices and is not within our direct control.
• Government Agencies: Occasionally Illuno may be required by law enforcement or judicial authorities to provide Personal Information to governmental authorities. We fully cooperate with law enforcement agencies in identifying those who use our Services for illegal activities. Illuno reserves the right to disclose Personal Information to law enforcement and other governmental agencies, at our sole discretion in connection with an investigation of any matter that is illegal or that could expose Illuno or our affiliates to liability.
• Cookie Information Recipients: In some cases, we may allow specific cooperating entities to use cookies or similar technologies to collect non-personal data from your browser or device for measurement purposes. Receipt and use of such information is subject to each cookie information recipient’s Privacy Notice.
• Affiliate and Third Parties: We may disclose the Personal Information we collect about you to our affiliates like a parent company or subsidiaries. For example, we share Personal Information for Client support purposes, marketing, or technical operations. Under specific circumstances, we may disclose Personal Information to certain third parties as permitted by applicable law, for example: if we go through a business transition (e.g., merger, acquisition, or asset sale); to comply with a legal requirement or a court order; when we believe it is appropriate to take action regarding illegal activities or prevent fraud or harm to any person; to exercise or defend our legal claims; or for any other reason with your consent.

Aggregated and Deidentified Information

We reserve the right to disclose aggregated, anonymized, or deidentified information about any individuals with affiliated or nonaffiliated entities for marketing, advertising, research, or other purposes, without restriction. For example, we may share reports showing trends about the general use of our Services without identifying an individual.

Limited Sensitive Personal Information

In no case will Illuno use or disclose any sensitive Personal Information for the purpose of inferring characteristics about you. If this ever changes in the future, we will update this Privacy Notice and provide you with methods to limit use and disclosure of Sensitive Personal Information.

No Sale or Sharing With Third Parties

Illuno does not sell your Personal Information or share your Personal Information with third parties for cross-contextual advertising purposes. If this ever changes in the future, we will update this posting and provide you with methods to opt-out of such sale and sharing.

MINIMUM AGE AND CHILDREN'S PRIVACY

You must be at least 21 years old to register with Illuno. We do not knowingly collect Personal Information from individuals under 21, and we reserve the right to delete account information if we discover an individual under 21 has registered with Illuno. In no case do we knowingly collect information from children. If we discover that a child has provided us with Personal Information, we will delete such information from our systems. If you believe we might have any information collected online from a child, or if you become aware of any unauthorized submission of information to us, please contact us at privacy@illuno.com.

YOUR PRIVACY RIGHTS

Illuno believes you should have the ability to control the Personal Information we collect and hold about you on your own. You can use the methods described below to control how we collect and use your Personal Information.

• Your Account: You can change or delete the Personal Information in your account at any time by signing into the Platform and editing your information or changing your settings. Illuno may offer instructions to guide you in making additional changes. You can delete all of your Personal Information on Illuno by closing your account. Closing your account may not free up your email address, or username for reuse on a new account. Note that you may not be able to change or delete all types of information. For example, you cannot delete records of your jobs and payments because we need this data for our business purposes or legal obligations.
• Email Communications: We may send you informational or support emails related to your use of the Services. Depending on your communication preferences, we may also send you promotional emails. If you do not wish to receive emails from us, you may change your preferences via the links provided in the emails or by sending a request to privacy@illuno.com to be removed from our email list. Note that if you opt-out of marketing communications, we may still send you non-promotional communications, such as those about your account or our ongoing business relations.
• Texting Consent: If you provide us with your wireless phone number, you consent to Illuno sending you informational or service text messages. However, we will only send you marketing text messages if you opt-in to receive these notifications from us. For all Illuno text messages, the number of texts you receive will depend on the Services you use and the information you request from us. You can unsubscribe from Illuno text messages by replying STOP or UNSUBSCRIBE to any of these text messages. Messaging and data charges may apply to any text message you receive or send. Please contact your wireless carrier if you have questions about messaging or data charges.
• Do Not Track: Do Not Track signals are signals sent through a browser informing us that you do not want to be tracked. Currently, our systems do not recognize browser “do-not-track” requests. If this changes in the future, we will update this Privacy Notice.

Depending on where you reside, you may have additional privacy rights or be entitled to additional controls over your Personal Information. Please see our supplemental notices specific to residents of California (See section CALIFORNIA PRIVACY RIGHTS Below).

Consumer Privacy Requests

If you wish to exercise your privacy rights beyond the methods available through the Platform, or if you want to express concerns, lodge a complaint, or request information, please submit a verifiable Consumer Privacy Request using our online Consumer Privacy Request form or by sending an email to privacy@illuno.com.

Illuno can only fulfill a Consumer Privacy Request when we have sufficient information to verify that the requester is the person or an authorized representative of the person about whom we have collected Personal Information, and to properly understand, evaluate, and respond to the request. We do not charge a fee to process or respond to a verifiable request unless we have legal grounds to do so. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

We endeavor to respond to Consumer Privacy Requests in accordance with the requirements of the law applicable to your jurisdiction. Depending on the circumstances and the nature of your request, we may be unable to fulfill your request in part or in whole, for example, if your request falls within a statutory exception or if fulfilling your request would prevent us from complying with a statutory or contractual obligation.

CALIFORNIA PRIVACY RIGHTS

This section provides residents of the State of California (“California Consumers”) with the disclosures and notices required under the California Consumer Privacy Act of 2018 (“CCPA”). The following paragraphs apply solely to California Consumers and describe the specific rights afforded under the CCPA. California Consumers may exercise the following rights over their Personal Information, subject to any exceptions and limitations that may apply:

• Right to Disclosure: You have the right to request that we disclose information to you about our collection and use of your Personal Information, such as: (i) the categories of Personal Information we have collected about you; (ii) the categories of sources for the Personal Information we have collected about you; (iii) our business or commercial purpose for collecting, selling or sharing your Personal Information; (iv) the categories of third parties with whom we disclose your Personal Information; and (v) a list of specific pieces of Personal Information we have collected about you. You also have the right to request that we disclose the categories of your Personal Information we have sold or shared and the categories of third parties to whom that Personal information was sold or shared, as well as the categories of Personal information disclosed for a business purpose and the categories of recipients of that information. Illuno is only required to respond to two disclosure requests from you within a 12-month period.
• Right to Access: You have the right to request that we provide you with access to specific pieces of Personal Information we have collected about you over the past 12 months (also called a data portability request). If you submit a right to access request, we will provide you with copies of the requested Personal Information in a portable and readily usable format. Please note that Illuno may be prohibited by law from disclosing copies of certain Personal Information when the disclosure would create a substantial, articulable, and unreasonable risk to the security of the information, our systems, or your account. We are only required by law to respond to two access requests from you within a 12- month period.
• Right to Correct: If you discover that we maintain inaccurate Personal Information about you, or if your Personal Information changes, please inform us and we will update our records to reflect the correct information.
• Right to Deletion: You have the right to request that we delete Personal Information that we collected from you and retained, with certain exceptions. Illuno may permanently delete, deidentify, or aggregate the Personal Information in response to a request for deletion. If you submit a right to deletion request, we will confirm the Personal Information to be deleted prior to its deletion, and we will notify you when your request is complete.
• No Selling or Sharing Personal Information: Illuno does not sell your Personal Information or share your Personal Information with third parties for cross-contextual behavioral advertising purposes. If this changes in the future, we will update this Privacy Notice and provide you with a method to opt-out of such sale and sharing.
• Limited Use and Disclosure of Sensitive Personal Information: Illuno does not use or disclose your Sensitive Personal Information for the purpose of inferring characteristics about you. If this ever changes in the future, we will update this Privacy Notice and provide you with methods to limit use and disclosure of Sensitive Personal Information.
• Right to Nondiscrimination: We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by law, we will not: (i) deny you goods or services; (ii) charge you different prices or rates for goods or services; (iii) provide you a different level or quality of goods or services; or (iv) suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services, because you exercised a right under the CCPA.
• Right to Disclosure of Marketing Information: Under California’s Shine the Light Act (Ca. Civ. Code § 1798.83-1798.84), California Consumers are entitled to request certain disclosures about Personal Information sharing with affiliates and/or third parties for marketing purposes. Please contact us if you wish to obtain these disclosures.

California Consumers may exercise the following rights over their Personal Information, subject to our receipt of a verifiable Consumer Privacy Request Form, as well as any exceptions and limitations that may apply. Note that if we process your Personal Information in our capacity as a service provider, then we cannot fulfill your request directly. In that case, we will relay your request to the appropriate Client for further processing and fulfillment.

Employee Data Exception

In many cases, the Personal Information we collect about you is in a business-tobusiness context when you are acting as an employee to a Client or potential in the performance of your job duties. Please note that Personal Information collected and used in this context is not protected under the CCPA.

COOKIES

Illuno may use cookies and other tracking technologies on the Services to track engagement, manage, and improve the Services. Cookies are small text files downloaded and stored on your device when you visit a website or other platform. Cookies are generally used for functionality, security, analytics, or advertising. Some cookies are strictly necessary to the function of the website or other platform, while others enable certain features.

Illuno does not link data automatically collected by cookies and similar technologies to your Personal Information. Third parties may also set cookies on the Services to collect information about you when you use the Services. We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

On your device, you can set your browser or device to refuse all or some cookies or to alert you when cookies are being sent. You can also install third-party plugins to control cookie behavior. If you disable or refuse cookies or block the use of other tracking technologies, some parts of the Services may then be inaccessible or not function properly. If you get a new device, install a new browser, or erase or otherwise alter your device’s cookie file or privacy settings, your privacy preferences may not be saved. If you disable or refuse cookies or block the use of other tracking technologies, you will be able to use certain features, but some or all features may not function properly.

DATA SECURITY

Illuno implements reasonable and appropriate security procedures and practices to help protect your Personal Information from unauthorized or illegal access, destruction, use, modification, or disclosure. Illuno follows the Open Web Application Security Project (OWASP) best practice security standards with regard to platform security. We encrypt all data at rest as well as in transit to prevent unauthorized parties from viewing the data, including your Personal Information, when it is transmitted to us. All data is stored on secure servers and is only accessible to our personnel and contractors via encrypted password and on an as needed basis. We ensure that Illuno employees, contractors, and agents responsible for handling your inquiries are informed of applicable privacy law requirements and we restrict access to those who need that information to process it.

Please note, however, that no transmission of data over the Internet is 100% secure. We cannot guarantee that unauthorized third parties will not defeat our security measures, use your Personal Information for improper purposes. We also have no control over the security measures or practices of the Departments and Clients that use our Services, and we make no representations or guarantees that your Personal Information is secure once transmitted or stored on their systems.

It is your responsibility to keep your Illuno account secure from unauthorized access. If you have an account with Illuno, we encourage you to take steps to protect against unauthorized access to your account. These steps include, without limitation, choosing a robust password that nobody else knows or can easily guess, keeping your password private, and signing off after using a shared computer or other device. Illuno is not responsible for any lost, stolen, or compromised passwords, or any unauthorized activity on your account.

CONSENT TO DATA TRANSFERS

Illuno is owned and operated in the United States and is intended for use by users living in the United States or Canada. We do not warrant that Illuno is appropriate or authorized for use in any other jurisdictions. If you use Illuno from outside of the United States, Personal Information we collect about you will be transferred to our servers in the United States and maintained there indefinitely. This may require the transfer of your Personal Information out of your country of origin with laws governing data collection and use that may differ from or be more restrictive than U.S. law, or may result in governments, courts, law enforcement or agencies having access to or obtaining disclosure of your Personal Information pursuant to the laws of the applicable foreign jurisdiction. You are responsible for determining whether this Privacy Notice and Illuno comply with the laws that apply to you. By allowing us to collect Personal Information about you, you consent to the transfer and processing of your Personal Information as described in this paragraph.

THIRD PARTY WEBSITES

The Services may contain links to websites owned or operated by third parties. We have no ability to control, and we are not responsible for, the privacy and data collection, use, and disclosure practices of third-party websites. We encourage you to read the privacy statements of each website that collects your Personal Information.

CHANGES TO THIS PRIVACY NOTICE

We may periodically update this Privacy Notice. If we make any material changes, we will notify you by updating this posting or by posting notice in the Services. The date that this Privacy Notice was last revised is identified at the top of the page. Your continued use of the Services after the effective date will be subject to the new Privacy Notice. You are responsible for periodically checking this Privacy Notice for changes.

CONTACT ILLUNO

If you have questions about our privacy practices or would like to make a complaint, please contact us at privacy@illuno.com or by phone at 1-214-247-6767.