Merlin International, Inc. (“Merlin,” “us,” or “we”) is committed to protecting your privacy.  Merlin has prepared this Privacy Policy to describe to you, or if you represent an entity or other organization, that entity or organization, (in either case, “You” or “User”) our practices regarding the personal information that Merlin collects, uses, and shares regarding our online informational platform (the “Platform”) accessed through the website located at https://www.merlincyber.com/ and any other websites operated by Merlin (each, a “Site”).

Merlin reserves the right, at any time, to modify this Privacy Policy.  If we make revisions that change the way we collect, use, or share personal information, we will post those changes in this Privacy Policy.  You should review this Privacy Policy periodically so that You keep up to date on our most current policies and practices.  We will note the effective date of the latest version of our Privacy Policy at the end of this Privacy Policy.

  1. Collection of Personal Information. Personal information refers to information that is connected to You, and may include things such as Your email address, mailing address, mobile number, demographic information, billing and payment preferences, and any other technical information related to Your computer network or architecture.

Merlin collects personal information when Users voluntarily submit it to us.  For example, we may collect or receive information from You when You create an account, submit Your content or product comments, use or access Merlin products or services, or otherwise interact with us or other Users of the Platform.

In addition to personal information that we may receive from You, Merlin may collect other information from Users using the following technologies:

    • Cookies. “Cookies” are small bits of information that the Platform places on the hard drive of Your computer.  Cookies remember information about Your activities on the Platform to make Your visits to the Platform more enjoyable and valuable to You by providing a customized experience and recognizing Your preferences when You visit the Platform.  If You’ve chosen to disable cookies on Your browser, some of the functionality of the Platform may be lost.  Certain services provided by Merlin, require that cookies be enabled in Your browser and cannot be used when You have disabled cookies in Your browser.
    • Flash cookies (also called Local Shared Objects or “LSOs”). Flash cookies are data files similar to cookies, except that they can store more complex data.  Flash cookies are used to remember settings, preferences, and usage, particularly for video, interactive gaming, and other similar services.
    • Web beacons or clear pixels. Web beacons are small graphic images on a web page or in an email that can be used for such things as recording the pages and advertisements that You select, or tracking the performance of email marketing campaigns.
    • Web Server Logs. Web server logs are records of activity created by the computer that delivers the webpages You request to Your browser.  For example, a web server log may record the search term You entered or the link You clicked to bring You to a webpage.  The web server log also may record information about Your browser, such as Your IP address and cookies set on Your browser by the server.
    • Device Information. We may collect information related to Your computer network or architecture You use to access the Platform, including without limitation the hardware model, operating system and version, browser type, unique device identifiers, and network information.
  1. Use of Personal Information. Merlin’s primary purpose in collecting personal information is to provide You with products and services that match Your interests.  Merlin may also use personal information about You for various purposes, including without limitation to:
    • To conduct research and analysis.
    • To help diagnose problems with the Platform, to administer the Platform, and to enhance the Platform for optimal User experience.
    • To monitor the usage and performance of the Platform, and to determine aggregate information about our Users and usage patterns.
    • To customize products and services that may be of interest to our Users.
    • To facilitate orders, product transactions, and process payments.
    • To send Users materials, updates, and information regarding the Platform.
    • To send You information about special events and promotions that we offer.
    • To provide maintenance, support, and customer service for the Platform.
    • To contact Users for information verification purposes.

We may also participate in behavioral-based advertising.  This means that a third party may use technology, such as a cookie or a web beacon, to identify You on the Platform so that they can provide advertising about products and services tailored to Your interest.  That advertising may appear either on the Platform, or on other web sites.

  1. Sharing of Personal Information.

Merlin may share Your personal information with companies that are affiliated with us (that is, that control, are controlled by, or are under common control with Merlin).  We do not share Your information with third parties to directly market to You, but we may market to You on behalf of such third parties that would like to send You information about their products and services.  For example, Merlin may offer a promotion in conjunction with a co-sponsor that may have special offers or services that might be of interest to our Users.  We may also extend to You special offers from the co-sponsor that may be of interest to You.

Merlin may disclose personal information to service providers for the purposes of operating our business, delivering, improving, and customizing our products or services, sending marketing and communications related to our business, and payment processing.  Personal information handled by service providers is subject to their terms and privacy policies.  Please review the service provider’s terms and privacy policies to better understand how they manage Your personal information.

There may also be instances when Merlin may disclose Your personal information without providing You with a choice in order to protect the legal rights of Merlin, other affiliated companies or their employees, agents, and contractors; to honor a request that You have made through the Platform; to protect the safety and security of other Users; to protect against fraud or for risk management purposes; or to comply with the law or legal process.  In addition, if Merlin sells all or part of its business or makes a sale or transfer of assets or is otherwise involved in a merger or business transfer, Merlin may transfer Your personal information to a third party as part of that transaction.

  1. Security. Merlin employs reasonable administrative, technical, and physical safeguards to protect personal information from becoming disclosed to individuals who are not described in this Privacy Policy.  While there is no such thing as “perfect security” on the Internet, we will take reasonable steps to ensure the safety of Your personal information.
  2. Access & Choice. Merlin has implemented the following procedure that You may use to access, correct, or delete Your personal information, or choose how Your information is used:
    • If You would like to know whether Merlin has collected personal information about You please send us the activities and services that You participated in on the Platform that requested personal information. After reviewing the relevant databases, Merlin will confirm whether Merlin has collected such information about You and provide a list of Your personal information that we have on file.
    • If Your personal information is incorrect, You may correct the personal information by sending a written request for correction to Merlin’s General Counsel at the address below. Your request must include: (a) all of the incorrect personal information that You wish to change, (b) the corrected personal information, and (c) Your signature authorizing such changes.  Merlin will then correct the personal information in our database and send a written confirmation to You.
    • If You wish to stop receiving email marketing communications from Merlin, please contact us at the address listed below or use the unsubscribe link at the bottom of any email marketing communication. If You opt out, we may still send You non-promotional communications, such as those about Your account or to facilitate orders You have made.
    • Some web browsers and devices permit You to broadcast a preference that You not be “tracked” online. At this time Merlin does not modify Your experience based upon whether such a signal is broadcast.
  1. International Data Transfers. Merlin is a global company with business processes, management structures, and technical systems that cross borders.  The personal information that we collect from You may be transferred to, and stored at, a destination outside of the country in which it was originally collected. This may include transfers outside of United States.  It may also be processed by personnel working outside of the United States who work for us or for one of our providers.  Such personnel may be engaged in, among other things, the fulfilment of Your order, the processing of Your payment details and the provision of products and services.  We will take all steps reasonably necessary to ensure that personal information is treated securely and in accordance with this Privacy Policy and applicable law. For example, if You are located in the EU, You, as a data controller, may only transfer personal information to Merlin, as a data processor, by entering into the EU standard contractual clause or agreeing to another adequacy measure.
  2. Notice to California residents. Under California Civil Code sections 1798.83-1798.84, California residents who have an established business relationship with Merlin are entitled to ask us for a notice describing what categories of personal customer information we share with third parties for their direct marketing purposes. This notice will identify the categories of information shared with and will include a list of the third parties with which it is shared, along with their names and addresses.  If You are a California resident and would like a copy of this notice, please submit a written request to us at the address listed below in the Section titled “Communications”.
  3. Other Websites. This Privacy Policy does not apply to web sites or applications offered by other organizations or individuals that may be displayed as content in a search on the Platform.  Merlin encourages You to read the privacy policy of any third party web site or applications before transmitting personal information.
  4. Communications. If You have any additional questions or concerns about our Privacy Policy or any other privacy or security issue, please contact us at:

Merlin International, Inc.
Attn: Legal Department, General Counsel
8330 Boone Blvd, 8th Floor
Tysons, VA 22182

legal@merlin-intl.com

If Merlin needs, or is required, to contact You concerning any event that involves information about You, we may do so by email, telephone, or mail.

Effective as of June 1, 2019.