Two Six Labs Privacy Policy

Introduction

This Privacy Policy describes how Two Six Labs, LLC (together with affiliates, “TwoSix”) collects, uses, or discloses personal information we receive through our website (https://www.twosixlabs.com/) and any mobile applications or other related online services we may offer (collectively, the “Services”).

The purpose of this Privacy Policy is to provide information about how TwoSix collects and uses your personal information, with whom TwoSix shares the information, and your rights and choices with respect to the use of the information. The Policy also describes the security measures TwoSix takes to protect your information and how you may contact TwoSix about its privacy policies.

Please read the Privacy Policy carefully before you start to use our Services. As a visitor to and/or user of a Two Six Labs website, web platform, or product, depending upon how you interact with our websites and products, you agree to be bound and abide by our posted Terms of Use and Privacy Policy. If you do not agree to both the Terms of Use and our Privacy Policy, or if you violate them in any way, your right to access or use the Services is terminated.

How We Collect Information

Personal information means any information relating to an identified or identifiable natural person. An identifiable person is one who can be identified, directly or indirectly, by reference to either: (a) an identifier such as a name, an identification number, location data, or online identifier; or (b) one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that person.

We may collect personal information about you by various means, including:

  • Directly from you, both online and offline;
  • Through our Services; and
  • From other third party sources and social media platforms that you may use to engage with us, as well as from our affiliates, partners, or third parties, including but not limited to public databases, for the purposes provided below, and/or to supplement information we already possess.

Unless we explain otherwise at the time, providing personal information that we request is optional and disclosures are made voluntarily.

Types of Information We Collect

We may collect the following categories of information from or about you:

  • Contact information, such as your name, mailing address, e-mail address, phone number, and business interests, which may include signing up for some of our communications
  • Communications between you and us, such as via e-mail, mail, phone, or other channels
  • Offline activity you engage in with us
  • Information that you post on our website or our service. This information is available to the general public.
  • Automatically collected information about your online activity through cookies, logs, and other automated means when interacting with our Services, including information to help us administer, protect, and improve our website, analyze usage; and improve users’ experience.
  • If you provide us with information regarding another individual, you represent that you have that person’s consent to give us his or her information and to permit us to use the information in accordance with this policy.
  • Job applicants who visit twosixlabs.com may also provide us information as part of their employment application that includes such things as the applicant’s name, email, social media profile, resume (including employment and education information), and cover letter. We do not use this information for any purpose other than to evaluate the individual for employment with us. Job applicants may provide additional information for routine background checks to a third-party provider of such services, under specific privacy terms and consents that will be provided at the time of collection. TwoSix uses iCIMS to manage our careers page and application process, and we strongly recommend you read the iCIMS privacy policy, found here.

Cookies and Other Tracking Technologies

TwoSix and our third-party providers may set and use cookies and similar technologies to store and manage user preferences, enable content, and gather analytic and usage data.

Cookies are a commonly-used web technology that allow websites to store and retrieve certain information on a user’s system and track users’ online activities. We, our service providers, and our business partners may collect information about your use of our websites and mobile apps by such automated means, including but not limited to cookies, pixels, SDKs, and other similar technologies.

Cookies and similar technologies can help us automatically identify you when you return to our website or app. Cookies help us review website traffic patterns, improve the website, and determine what Services are popular. We can also use such information to deliver customized content and advertising to users of the Services whose behavior indicates that they are interested in a particular subject area.

When you use the Services, the information we may collect by automated means include web server and application logs, where our servers automatically collect certain information to help us administer and protect the Services, analyze usage, and improve users’ experience. The information collected may include:

  • IP address and browser type
  • Access times (date, time, time zone)
  • Device information including Unique Device Identifier (UDID), MAC address, and similar identifiers we or others may assign
  • Device operating system and other technical facts
  • The city, state, and country from which you or your Internet Service Provider access our website
  • Pages visited and content viewed
  • Information or text entered
  • Links and buttons clicked

We may also ask advertisers or other partners to serve ads or services to your device, which may use cookies or similar technologies placed by us or the third party. If a user does not want information collected through the use of cookies, most browsers allow the visitor to reject cookies, but if you choose to decline cookies, you may not be able to fully experience the interactive features our Services provide. We may share non-personal information obtained via cookies with our advertisers and affiliates. Because there is not yet a consensus on how companies should respond to web browser-based do-not-track (“DNT”) mechanisms, we do not respond to web browser-based DNT signals at this time. We and our service providers and business partners may collect information about users’ online activities over time and across third-party websites.

Information You Share Socially

The Services may allow you to connect and share your actions, comments, content, and information publicly or with others who participate in the Services. We are not responsible for maintaining the confidentiality of any information you share publicly or with other participants in the Services.

In addition, the Services may allow you to connect with us and share on third-party websites, applications, and services. Please be mindful of your personal privacy needs and the privacy needs of others, as you choose whom to connect with and what to share and make public. We cannot control the privacy or security of Personal Information you choose to make public or share with others. We also do not control the privacy practices of third parties. Please contact those websites and services directly if you want to learn about their privacy practices.

How We Use Personal Information

Other than as described in this Statement, we DO NOT use or share with third parties your personal information for any purpose other than for the requests, issues, transactions, or projects for which we receive it, unless doing so is required by law, regulation, or judicial process.

We use information that we collect about you or that you provide to us for our legitimate commercial interests including, among other things, the following:

  • Provide the Services and information you have requested from us and notices relating thereto, including providing customer and technical support for the Services and collecting fees or other amounts owed in connection with the Services.
  • Verify that you qualify as a registered user of the Services.
  • Provide information to you about our products or services and third-party products and services that we think may be of interest to you.
  • Provide you with marketing communication and information.
  • Analyze, improve, and customize the Services including measuring the effectiveness of advertising and internal research on users’ interests and behaviors to better serve our users.
  • Administer the website, web platform, and Services for internal operations, including troubleshooting, data analysis, testing, research, security, statistical, and survey purposes.
  • Respond to your inquiries about posted job positions and evaluate employment applications.
  • For legal and compliance reasons, such as the prevention, detection, or investigation of a crime, loss prevention, or fraud.
  • Internal and external audit requirements, information-security purposes, and as we otherwise believe to be necessary or appropriate: (a) under applicable law, which may include laws outside your country of residence; (b) to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include such authorities outside your country of residence; (c) to enforce our terms and conditions or other agreements; and (d) to protect our rights, privacy, safety, or property, or those of other persons.

When We Share Personal Information

TwoSix shares or discloses personal information when necessary to provide our Services or conduct our business operations as described below. When we share personal information, we do so in accordance with data privacy and security requirements. Below are the parties with whom we may share personal information and why.

  • Within TwoSix: Our business is supported by a variety of TwoSix functions, and personal information will be made available to them if necessary for the provision of services, account administration, sales and marketing, customer and technical support, and business and product development.
  • Our business partners: We occasionally partner with other organizations to deliver Services. As part of this partnering, we and our partners may collect and share information about you. TwoSix will handle personal information in accordance with this Statement, and we encourage you to review the privacy statements of our partners to learn more about how they collect, use, and share personal information.
  • Our third-party service providers: Our business operations are sometimes supported by third-party service providers. Personal information will be made available to these parties only when necessary to fulfill the services they provide to us, such as legal services, job applicant screening, and employee benefits administration. Our third-party service providers are not permitted to share or use personal information we make available to them for any other purpose than to provide services to us.
  • Third parties for legal reasons: We will share personal information when we believe it is required, such as (a) to comply with legal obligations and respond to requests from government agencies, including law enforcement and other public authorities, which may include such authorities outside your country of residence; (b) to protect our and others’ rights, property, safety, systems, and Services.
  • Third parties in corporate transactions: Personal information may be shared in connection with a purchase, transfer, or sale of services or assets such as in a merger or acquisition (e.g. if we sell all or part of our business or assets, personal information may be one of the transferred assets) or in the event of a bankruptcy.

TwoSix does not share the personal information it collects to third parties for their direct marketing use.

Securing Information

While your personal information is in our possession, we will protect it using the same administrative, physical, and technology safeguards to protect against accidental loss and unauthorized access, use, destruction, or disclosure of data that we use to protect our own highly confidential information.

However, no method of electronic transmission or storage is 100% secure, and we cannot ensure the security of any information you transmit to us, or guarantee that this information will not be accessed, disclosed, altered, or destroyed. We will make any legally required disclosures in the event of any compromise of personal information. You also play a role in protecting your Personal Information. Please safeguard your username and password for your Account and do not share them with others. If we receive instructions using your Account login information, we will consider that you have authorized the instructions. You agree to notify us immediately of any unauthorized use of your Account or any other breach of security related to the Services. We reserve the right, in our sole discretion, to refuse to provide the Services, terminate your Account, and to remove or edit content.

How Long We Keep Personal Information

TwoSix has policies and rules relating to the retention of personal information. Our Records Retention Schedule is based upon a classification scheme consisting of Business Functions, Record Classes, and Record Types. In determining data retention periods, TwoSix takes into consideration local laws, contractual obligations, and the expectations and requirements of our customers. When we no longer need personal information, we securely delete or destroy it.

Your Privacy Choices

We offer you certain choices about what information we collect from you, how we use and disclose the information, and how we communicate with you.

  • Marketing Emails: From time to time, we may contact you via email or through other channels for the purpose of providing announcements, promotional information, and/or other general communication. In order to improve our Services, we may be notified when you open an email from us or click on a link therein. You may choose not to receive marketing emails from us by forwarding a marketing email you received from us to info@twosixlabs.com. Even if you opt out of receiving such communications, we may continue sending you non-marketing email communications, such as administrative or transaction alerts, or information about changes to our terms of service.
  • Cookies: Web browsers may offer users the ability to disable receiving certain types of cookies. However, if cookies are disabled, some features or functionality of our websites and mobile apps may not function. You can read more about your choices and opting out by visiting www.aboutads.info/choices or http://www.networkadvertising.org/choices.
  • Targeted Advertising: Some of our business partners that collect information about your activities on our websites and in our mobile apps may be members of organizations or programs that provide you with choices regarding the use of your browsing behavior for purposes of targeted advertising.

Notice to California Residents

Under the California Consumer Privacy Act (CCPA), California residents have new rights with respect to their personal information. If you are a California resident and you would like to exercise your rights under CCPA, you should contact TwoSix either by calling (703) 543-9662 or emailing us at info@twosixlabs.com. For full information on CCPA, please read the following notice here.

Notice to Nevada Residents

We do not transfer personal information for monetary consideration. If you would like to tell us not to sell your information in the future, please email us at info@twosixlabs.com with your name, postal address, telephone number, and email address with “Nevada do not sell” in the subject line.

Notice to Persons Accessing this Website from Outside the United States

Our Services are controlled and operated by us from the United States, are made available to residents of the United States, and are not intended to subject us to the laws or jurisdiction of any state, country, or territory other than those of the United States. Any information you provide through use of the Services may be stored and processed, transferred between and accessed from the United States and other countries which may not guarantee the same level of protection of personal information as the one in which you reside. If you do not want your personal information to leave your country, please do not provide such information to Two Six Labs and do not use our website. By providing personal information to TwoSix, you explicitly consent to the transfer of your information to the United States.

Two Six Labs or its service providers may also transfer your personal information from the European Economic Area (EEA) to other countries, some of which have not yet been determined by the European Commission to offer an adequate level of data protection according to EEA standards. For transfers to countries not requiring a level of data protection that meets EEA standards, TwoSix uses a variety of legal mechanisms to protect your personal information, including contractual provisions and written assurances from service providers.

We will handle your personal information in accordance with this Privacy Policy regardless of where your personal information is stored or accessed.

Links to Other Websites and Third Party Content

Our website may contain links to, and may be used by you in conjunction with, third-party applications, services, tools, and websites that are not affiliated with, controlled, or managed by us. Examples include Facebook, LinkedIn, YouTube, Twitter, and third-party applications like voice software and readers.

Users of our Services wishing to provide links to third party applications, services, tools, or websites in content that they post must obtain our prior permission to do so.

The privacy practices of a third party will be governed by that party’s Privacy Statement. We do not endorse and are not responsible for the security or privacy of any information collected by these third parties. You should review the privacy statements or policies applicable to these third-party services.

Children’s Privacy

Our website and the nature of our business are not intended for children. Children under the age of 13 should not register for services or provide any personal information, including name, address, telephone number, or email address to TwoSix through its websites or online services. We do not knowingly collect personal data from children under the age of 13 on our Services. If you have reason to believe that a child under the age of 13 has provided personal information to us through our Services, please contact us, and we will endeavor to delete that information from our systems. In the event that we learn that we have collected personal information from a child under age 13 without parental consent, we will endeavor to delete that information as quickly as possible. If you believe that we might have any information from or about a child under 13, please contact us as directed below.

How to Contact Us

For further questions or concerns about this Statement or our privacy practices, please feel free to contact us at the following:

Two Six Labs
901 N. Stuart Street, Suite 1000
Arlington, VA 22203
USA
(703) 543-9662
info@twosixlabs.com

Changes to the Privacy Policy

TwoSix reserves the right to amend this Privacy Policy at any time, for any reason, without notice, other than posting of the amended Privacy Policy at this Website with an updated Effective Date. TwoSix suggests you check this page regularly to see our most up-to-date Privacy Policy. Changes are effective on the date TwoSix posts the revised Privacy Policy to its website and supersede all previous versions of the Privacy Policy. The Policy in effect at the time you use the website or the Service governs how we may use your information.

Effective Date: This Privacy Policy was last updated June 26, 2020.