Privacy Policy

Netragard respects your privacy. This Policy informs you of Our privacy practices, and of the options you have with regard to how your personal information is collected and used.

Netragard LLC (“Netragard” or “We”, “Us” or “Our”) self-certifies the privacy policies described below in accordance with the U.S.-E.U. Safe Harbor principles, specifically, Notice, Choice, Onward Transfer, Access and Accuracy, Security, and Oversight/Enforcement.

More information about the U.S. Department of Commerce’s Safe Harbor Program can be found at http://www.export.gov/safeharbor.

Application

This Privacy Policy applies to all Websites owned or used by Netragard (“Netragard’s Websites”), as Well as all Website-based transactions in which We collect Personal Information (as defined below) from Our customers. Moreover, this Privacy Policy applies to all Personal Information (defined below) received by Us in any format including electronic, paper or verbal. Netragard will not sell or share this information with third parties in ways different than what is disclosed in this Privacy Policy. On a global basis, Netragard will, and will cause its affiliates to, establish and maintain business procedures that are consistent with this Policy.

Please note, Netragard’s Websites may contain links to third-party sites for your convenience and/or information. If you access those links, you will leave Netragard’s site and be re-directed to a third party site. We do not control the privacy practices of those third party sites, which may differ significantly from Netragard’s privacy practices. We do not endorse or make any representations about third party Websites, and the personal data you choose to provide to third party Websites is not covered by this Privacy Policy. We encourage you to review the privacy policy of any Website or company before submitting your personal information to them.

Collection of Personal Information

For the purposes of this Policy, “Personal Information” means any information that identifies, or could be used by or on behalf of Netragard to identify, an individual. Personal Information does not include information that is encoded, nor does it include publicly available information that has not been combined with non-public Personal Information.

In order to provide you with certain products and services, such as access to Netragard’s whitepapers, newsletters or related materials, some of the landing pages at Netragard’s Websites require you to provide Us with certain Personal Information about yourself. Your Personal Information includes your first and last name, your email address, and contact telephone number.

Use of Your Personal Information

Currently, We use your Personal Information only to provide you with the information that you specifically request at or through Our site. If, in the future, We believe that you could benefit from the products or services of certain third parties, We will require you to opt in before We disclose any of your Personal Information to such third parties.

Although We do not share your Personal Information without your permission, We may nonetheless disclose your Personal Information if We are required to do so by law or We in good faith believe that such action is necessary to (1) comply with the law or with legal process; (2) protect and defend Our rights and property; (3) protect against misuse or unauthorized use of Our Website; or (4) protect the personal safety or property of Our users or the public (among other things, this means that if you provide false information or attempt to pose as someone else, information about you may be disclosed as part of any investigation into your actions).

On occasion, We may hire third parties to perform certain functions on Our behalf. Examples include removing repetitive information from Our customer lists, analyzing data, providing marketing assistance, and providing customer service. These third parties have access to your Personal Information to the extent necessary to permit them to do their jobs, however, they are bound by confidentiality agreements before any information is provided to them, and they are restricted from using the information for other purposes.

In addition, We may use your Personal Information in the aggregate and in a de-identified manner to determine Our customers’ demographics and preferences. By doing so, We are able to deliver to you targeted events, such as relevant advertisements and/or information, which you may find to be helpful and informative.

Other than as stated in this Privacy Policy, We will not release your Personal Information to unknown or unaffiliated third parties, and We will not cross-reference your Personal Information with that of any other customer or entity. If Netragard has knowledge that one of Netragard’s employees or agents is using or disclosing Personal Information in a manner contrary to this Privacy Policy, Netragard will take reasonable steps to prevent or stop the use or disclosure. Netragard holds its employees and agents accountable for maintaining the trust that Our customers place in Our company.

Also, in the unlikely event that all or substantially all of Netragard’s assets are acquired or transferred, your Personal Information may be one of the transferred assets. It is Netragard’s practice to seek appropriate protection for information in these types of transactions.

Your Choices

You will have the option to opt-in to any uses of Your Personal Information in which your Personal Information would be disclosed to a non-agent third party, or where such information would be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by you. If you do not opt-in to such use(s), then Netragard will not release Your Personal Information.

Accuracy & Access

Netragard will take reasonable steps to ensure that your Personal Information is relevant accurate, complete and current, to its intended use. We provide individuals with reasonable access to personal information that they provided to us, as well as the ability to review and correct such information, as applicable.

To protect your privacy and security, We may take reasonable steps to verify your identity, such as requiring a password and user ID, before granting access to your Personal Information. To view and change the Personal Information that you directly provided to us, you should contact our Privacy Officer, listed below.

In addition, We may limit or deny access to Personal Information where providing such access would be unreasonably burdensome or expensive in the circumstances, or as otherwise permitted by the Safe Harbor Agreement. In some circumstances, We may charge a reasonable fee, where warranted, for access to Personal Information.

Security

To prevent unauthorized access or disclosure, to maintain data accuracy, and to ensure the appropriate use of your Personal Information, We utilize physical, technical and administrative procedures to safeguard the information We collect.

We also use firewalls and restricted access methods to ensure the security of the information We collect. We limit access to your Personal Information and data to those persons in Netragard, or as agents of Netragard, that have a specific business purpose for maintaining and processing such information. Netragard’s employees who have been granted physical access to your Personal Information will be made aware of their responsibilities to protect the security, confidentiality and integrity of that information and have been provided training and instruction on how to do so.

Contact for Privacy Issues

Netragard’s designated contact for questions related to Our Website’s privacy officer is:

Bradley J. Gross, Esq.
c/o Becker & Poliakoff, P.A.
3111 Stirling Road
Fort Lauderdale, Florida 33312
bgross@becker-poliakoff.com

If you have any questions or comments about this Policy, please direct them to the above designated person.

Dispute Resolution

Netragard will investigate and attempt to resolve complaints and disputes regarding use and disclosure of Personal information in accordance with the principles contained in this Policy. For complaints that cannot be resolved between Netragard and the complainant, We have agreed to participate in the dispute resolution procedures of the panel established by the EU data protection authorities to resolve disputes pursuant to the Safe Harbor Principles. In the event that We or such authorities determine that We did not comply with this policy, We will take appropriate steps to address any adverse effects and to promote future compliance.

Changes to This Privacy Policy

The practices described in this Policy are the current Personal Information protection policies for Netragard’s Websites as of May 16, 2011. Netragard reserves the right to modify or amend this Policy at any time consistent with the requirements of the Safe Harbor Principles. Appropriate notice will be given concerning such amendments.