BLUCADIA PRIVACY POLICY


Last Updated: June 14, 2017

This Privacy Policy discloses the privacy practices for the Blucadia (blucadia.com and blucadia.io) site and various related services (together referred to as the “BLUCADIA Marketplace Platform”). Blucadia, Inc. doing business as Blucadia (hereinafter “BLUCADIA”), the provider of the BLUCADIA Marketplace Platform, is committed to protecting your privacy online. Please read the information below to learn the following regarding your use of the BLUCADIA Marketplace Platform.

You acknowledge that this Privacy Policy is part of our Site Terms and Conditions of Use, and by accessing or using the BLUCADIA Marketplace Platform, you agree to be bound by all of its terms and conditions. If you do not agree to these terms, please do not access or use the BLUCADIA Marketplace Platform.

BLUCADIA reserves the right to change this Privacy Policy at any time. Such changes, modifications, additions or deletions shall be effective immediately upon notice thereof, which may be given by means including, but not limited to issuing an email to the email address listed by registered Users and posting the revised Policy on this page. You acknowledge and agree that it is your responsibility to maintain a valid email address as a registered User, review the BLUCADIA Marketplace Platform and this Policy periodically and to be aware of any modifications. Your continued use of the BLUCADIA Marketplace Platform after such modifications will constitute your: (a) acknowledgment of the modified Policy; and (b) agreement to abide and be bound by the modified Policy.

BLUCADIA’s Site Terms and Conditions of Use require all Users to be at least 21 years of age, therefore, this Privacy Policy does not discuss use of the BLUCADIA Marketplace Platform or services by minors.

1. Types of Information Collected


In order to better provide you with our numerous services, BLUCADIA collects two types of information about our Users and non-users: Personally Identifiable Information and Nonpersonally Identifiable Information. Our primary goal in collecting information from you is to provide you with a smooth, efficient, and customized experience while using the BLUCADIA Marketplace Platform.

Personally Identifiable Information: This refers to information that lets BLUCADIA know the specifics of who you are. When you engage in certain activities on the BLUCADIA Marketplace Platform, such as registering an account, ordering a service, or sending BLUCADIA feedback, BLUCADIA may ask you to provide certain information about yourself by filling out and submitting an online form. It is completely optional for you to engage in these activities. If you elect to engage in these activities, however, we may ask that you provide us personal information, such as your first and last name, mailing address (including zip code), social security number, identification ID or tax ID, date of birth, email address, employer, job title and department, telephone and facsimile numbers, bank account information, and other personal identifying information. When ordering services on the BLUCADIA Marketplace Platform, you may be asked to provide a credit card number. Depending upon the activity, some of the information BLUCADIA asks you to provide is identified as mandatory and some as voluntary. If you do not provide the mandatory data with respect to a particular activity, you will not be able to engage in that activity.

Nonpersonally Identifiable Information: This refers to information that does not by itself identify a specific individual. BLUCADIA gathers certain information about you based upon where you visit on the BLUCADIA Marketplace Platform in several ways. This information is compiled and analyzed on both a personal and an aggregated basis. This information may include the Web site’s Uniform Resource Locator (“URL”) that you just came from, which URL you next go to, what browser you are using, and your Internet Protocol (“IP”) address. A URL is the global address of documents and other resources on the World Wide Web. An IP address is an identifier for a computer or device on a Transmission Control Protocol/Internet Protocol (“TCP/IP”) network, such as the World Wide Web. Networks like the Web use the TCP/IP protocol to route information based on the IP address of the destination. In other words, an IP address is a number that is automatically assigned to your computer whenever you are surfing the web, allowing web servers to locate and identify your computer. Computers require IP addresses in order for users to communicate on the Internet.

2. Collection Methods and Use of Information


BLUCADIA does not collect any Personally Identifiable Information about you unless you voluntarily provide it to us. You provide certain Personally Identifiable Information to BLUCADIA when you: (a) register for our services and register your email address with us; (b) sign up for services with selected third parties affiliated with the BLUCADIA Marketplace Platform; (c) send email messages, submit forms or transmit other information by telephone or letter; or (d) submit your credit card or other payment information when ordering and purchasing services on the BLUCADIA Marketplace Platform. BLUCADIA may also collect information from you at other points on the BLUCADIA Marketplace Platform that states that such information is being collected.

In addition, BLUCADIA may also collect, or our content server may collect, certain Nonpersonally Identifiable Information. This information is ultimately stored in the form of store categories, and, in some cases, specific URLs. BLUCADIA uses your IP address to diagnose problems with our servers, software, to administer the BLUCADIA Marketplace Platform and to gather demographic information.

BLUCADIA will primarily use your Personally Identifiable Information to provide our services to you, as required by our agreements with you. BLUCADIA will also use Personally Identifiable Information to enhance the operation of the BLUCADIA Marketplace Platform, fill orders, improve our marketing and promotional efforts, statistically analyze BLUCADIA Marketplace Platform use, improve our product and service offerings, and customize the BLUCADIA Marketplace Platform’s content, layout, and services. BLUCADIA may use Personally Identifiable Information to deliver information to you and to contact you regarding administrative notices. BLUCADIA may also use Personally Identifiable Information to resolve disputes, troubleshoot problems and enforce our agreements with you, including our Site Terms and Conditions of Use, and this Private Policy.

3. Release of Information


BLUCADIA does not sell, trade, or rent your Personally Identifiable Information to others. BLUCADIA does provide some of our services through contractual arrangements with affiliates, services providers, partners and other third parties. BLUCADIA and our service partners use your Personally Identifiable Information to operate the BLUCADIA Marketplace Platform and to deliver their services. For example, BLUCADIA must release your Personally Identifiable Information to confirm payment for services purchased on the BLUCADIA Marketplace Platform; and provide order information to third parties that help BLUCADIA provide customer service.

BLUCADIA will encourage our service partners to adopt and post privacy policies. However, the use of your Personally Identifiable Information by our service partners is governed by the privacy policies of those service partners, and is not subject to our control.

Occasionally BLUCADIA may be required by law enforcement or judicial authorities to provide Personally Identifiable Information to the appropriate governmental authorities. BLUCADIA will disclose Personally Identifiable Information upon receipt of a court order, subpoena, or to cooperate with a law enforcement investigation. BLUCADIA fully cooperates with law enforcement agencies in identifying those who use our services for illegal activities. BLUCADIA reserves the right to report to law enforcement agencies any activities that BLUCADIA in good faith believes to be unlawful.

4. Updating and Correcting Information


BLUCADIA believes you should have the ability to access and edit the Personally Identifiable Information that you have provided to us. You may change any of your Personally Identifiable Information in your account online at any time by linking to your account in accordance with instructions posted elsewhere on the BLUCADIA Marketplace Platform. You may also access and correct your personal information and privacy preferences by writing BLUCADIA at:

Blucadia
Attn: Support
PO Box 7636
Olympia, WA 98507-7636

Please include your name, address, and/or email address when you contact us.

BLUCADIA encourages you to promptly update your Personally Identifiable Information if it changes. You may ask to have the information on your account deleted or removed; however, because BLUCADIA keeps track of past transactions, you cannot delete information associated with past transactions on the BLUCADIA Marketplace Platform. In addition, it may be impossible to completely delete your information without some residual information because of backups.

BLUCADIA will retain your information only for as long as is necessary for the purposes set out in this policy, for as long as your account is active, or as needed to provide you services. If a User no longer wants BLUCADIA to use the User’s information to provide the User services, the User may close their BLUCADIA account. BLUCADIA will retain and use the User’s information to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. Please note that closing your account may not free up your email address, or username for reuse on a new account.

You may inform us of any changes or requests regarding your personal data, and in accordance with BLUCADIA’s obligations under applicable data protection law and our contractual obligations with Users, we may update or delete your personal data accordingly. We'll respond to your request within a reasonable timeframe.

5. Communications Between BLUCADIA and Users


On occasion, BLUCADIA will contact Users regarding our services. Primarily, these messages will be delivered by email, and every account is required to keep a valid email address on file to receive messages. BLUCADIA may contact you by telephone to provide User support or for transaction related purposes if you give us permission to call you. Additionally, BLUCADIA may send you an SMS message in order to provide you with customer support or to provide you with information about features you may find of interest.

Some messages from BLUCADIA will be service-related and required for Users. Examples of service-related messages include an email address confirmation/welcome email when you register your account, notification of an order, and correspondence with BLUCADIA’s support team. Unless you close your account, you may not opt out of receiving service-related messages from BLUCADIA.

BLUCADIA may also send you messages related to certain features or your activity on the BLUCADIA Marketplace Platform. BLUCADIA may send you news or updates about changes to the BLUCADIA Marketplace Platform or services. From time to time, we may develop new types of messages and share them with you to inform you about our services. Primarily, Users will receive these messages via email, but you may choose to opt out of receiving different types of messages through the settings on your BLUCADIA account.

6. Security of Information and Data Retention


On the BLUCADIA Marketplace Platform you can be assured that your Personally Identifiable Information is secure, consistent with current industry standards. The importance of security for all Personally Identifiable Information associated with our User is of utmost concern to us. Your Personally Identifiable Information is protected in several ways. Access by you to your Personally Identifiable Information is available through a password and unique customer ID selected by you. This password is encrypted. BLUCADIA recommends that you do not divulge your password to anyone. In addition, your Personally Identifiable Information resides on a secure server that only selected BLUCADIA personnel and contractors have access to via password. While at rest and while in transmission BLUCADIA encrypts all data, including your Personally Identifiable Information, and thereby prevents unauthorized parties from viewing such information when it is transmitted to us.

In order to most efficiently serve you, credit card transactions and order fulfillment are handled by established third party banking, processing agents and distribution institutions. They receive the information needed to verify and authorize your credit card or other payment information and to process your order.

BLUCADIA follows the Open Web Application Security Project (OWASP) best practice security standards with regard to platform security. BLUCADIA agrees to comply with applicable data privacy and security requirements under the Payment Card Industry Data Security Standard (“Association PCI DSS Requirements”) with regards to BLUCADIA’s use, access, and storage of certain credit card non-public personal information. Where applicable BLUCADIA requires our Payment Service Provider’s to follow the PCI DSS Requirements. Additionally, BLUCADIA agrees to comply with its obligations under any applicable law or regulation as may be in effect or as may be enacted, adopted or determined regarding the confidentiality, use, and disclosure of information.

If BLUCADIA receives and retains Personally Identifiable Information (“PII”) or Third Party PI, the BLUCADIA shall limit its retention of such data to no longer than reasonably useful to carry out its legitimate business purpose, or legally required. Regardless of the time period of retention, so long as BLUCADIA has PII or Third Party PII in its possession or control, the requirements included herein shall apply to such information. All non-PII data will be available on-line within our platform for a period of time not less than seven (7) years from the completion of each event/transaction.

No data transmission over the Internet or any wireless network can be guaranteed to be 100% secure. As a result, while BLUCADIA strives to protect your Personally Identifiable Information, you acknowledge that: (a) there are security and privacy limitations of the Internet which are beyond our control; (b) the security, integrity and privacy of any and all information and data exchanged between you and BLUCADIA through the BLUCADIA Marketplace Platform cannot be guaranteed; and (c) any such information and data may be viewed or tampered with in transit by a third party.

7. User Choices on Collection and Use of Information thru Cookies and Log Files


When you use the BLUCADIA Marketplace Platform, BLUCADIA will store cookies on your computer in order to facilitate and customize your use of the BLUCADIA Marketplace Platform. A cookie is a small data text file, which a Web site stores on your computer’s hard drive (if your Web browser permits) that can later be retrieved to identify you to us. Our cookies store randomly assigned user identification numbers, the country where you are located, and your first name to welcome you back to the BLUCADIA Marketplace Platform. The cookies make your use of the BLUCADIA Marketplace Platform easier, make the BLUCADIA Marketplace Platform run more smoothly and help BLUCADIA to maintain a secure site. By modifying your browser preferences, you have the choice to accept all cookies, to be notified when a cookie is sent, or to reject all cookies. If you choose to reject all cookies some parts of the BLUCADIA Marketplace Platform may not work properly in your case.

BLUCADIA also maintains log files concerning parties who visit the BLUCADIA Marketplace Platform. A log file is a computer file that lists actions which have occurred. For example, web servers maintain log files listing every request made to the server by a visiting party. With log file analysis tools, it's possible to get a good idea of where parties are coming from, how often they return, and how they navigate through an internet web site. A web server is a computer that delivers (serves up) internet web pages. Every web server has an IP address and possibly a domain name.

8. Privacy Policies of Third Party Sites


Except as otherwise discussed in this Privacy Policy, this document only addresses the use and disclosure of information BLUCADIA collects from you. Other sites accessible through the BLUCADIA Marketplace Platform have their own privacy policies and data collection, use and disclosure practices. Please consult each site’s privacy policy. BLUCADIA is not responsible for the policies or practices of third parties.

9. Miscellaneous Privacy Issues


You must be at least 21 years old to have our permission to use the BLUCADIA Marketplace Platform. Our policy is that BLUCADIA does not knowingly collect, use or disclose Personally Identifiable Information about visitors that are under 21 years of age. If you have any questions about this Privacy Policy, the practices of the BLUCADIA Marketplace Platform, or your dealings with the BLUCADIA Marketplace Platform, please contact BLUCADIA by sending a letter to:

Blucadia
Attn: Legal
PO Box 7636
Olympia, WA 98507-7636

You may also contact BLUCADIA by email at legal@blucadia.com.

10. Change of Name


COPSFORHIRE, INC., the U.S. based company providing a complete and fully automated off- duty management solution for Police Departments, Cops, Licensed Armed Private Security Guards, and Licensed Unarmed Private Security Guards, giving Customers access to the best trained and qualified security professionals available, is proud to announce that it has changed its name to BLUCADIA, INC. This change is effective immediately. The revised name now accurately reflects how the company is recognized in its markets as providing access to commissioned off-duty law enforcement and Licensed Armed and Unarmed Private Security Guards for client events. The change of name will not affect any User’s rights with regard to the BLUCADIA Marketplace Platform, and all prior agreements entered into under the COPSFORHIRE, INC. name are still valid with BLUCADIA, INC.

For further information about this change please contact Blucadia’s legal department at:

Blucadia
Attn: Legal
PO Box 7636
Olympia, WA 98507-7636

You may also contact BLUCADIA by email at legal@blucadia.com.