MajorKey Technologies LLC

Effective Date: January 1, 2021 | Last Updated: September 1, 2026

1. Introduction

MajorKey Technologies LLC ("MajorKey," "we," "us," or "our") respects your privacy and is committed to protecting the personal information you share with us. This Privacy Policy describes how we collect, use, disclose, and protect personal information when you visit our websites – majorkeytech.com, www.majorkeytech.com, and info.majorkeytech.com (collectively, the "Sites") – use our services, or otherwise interact with us, including job applicants.

MajorKey operates in the business-to-business (B2B) identity security advisory and consulting space. We primarily collect and process information from business contacts and professionals, not consumers in their personal capacity.

By using our Sites or services, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with our practices, please do not use our Sites.

2. Information We Collect

2.1 Information You Provide to Us

We collect information you voluntarily provide when you interact with us, including:

  • Contact information. Name, job title, company name, and business contact details (email address, phone number, mailing address)
  • Inquiry and engagement data. Information submitted through contact forms, event registrations, webinar sign-ups, or newsletter subscriptions
  • Job application data. Resumes, cover letters, work history, and related information submitted through our careers page or job listings
  • User-generated content. Testimonials, blog comments, and other content you choose to post on our Sites

2.2 Information Collected Automatically

When you visit our Sites, we automatically collect certain technical information, including:

  • ‍Device and browser data. IP address, browser type and version, operating system, device type, screen resolution, and language preferences.
  • ‍Usage data. Pages visited, links clicked, referring and exit URLs, date and time of visits, and time spent on pages.
  • Cookie and tracking data. Information collected through cookies, web beacons, and similar technologies as described in our Cookie Policy, set only as permitted by your consent choices.

2.3 Information from Third-Party Sources

We may receive information about you from publicly available sources (such as LinkedIn or company websites) and from third-party data providers, which we use to supplement the information we hold about business contacts.

2.4 Sensitive Personal Information 

“Sensitive Personal Information” (SPI), as defined under the CPRA and similar laws, includes categories such as government identifiers, precise geolocation, racial or ethnic origin, and account log-in credentials. We do not collect sensitive personal information from visitors to our Sites. Job applicants are invited to provide voluntary equal employment opportunity self-identification, which may include ethnicity or race and disability status. Providing it is optional, you may decline any question, and declining has no effect on your application. That information is held separately from your application, is not shown to hiring managers, and is not used to evaluate you. We use it only to meet our equal employment opportunity and federal contractor reporting obligations, and we do not use or disclose sensitive personal information for any purpose beyond those permitted under CPRA Section 1798.121(a). See Section 10.2 for the right to limit the use of SPI.

3. How We Use Your Information

We use the information we collect for the following purposes:

  • Service delivery. To respond to your inquiries, process orders, deliver services, and provide customer support
  • Communications. To send you newsletters, event invitations, and marketing communications relevant to your business interests (you may opt out at any time).
  • Site improvement. To understand how visitors use our Sites, identify trends, and improve the content, functionality, and user experience of our Sites.
  • Security and fraud prevention. To protect our Sites, detect fraud, and enforce our terms of use.
  • Legal compliance. To meet our obligations under applicable laws, regulations, or legal processes.
  • Recruitment. To evaluate candidates who apply for positions with us.

4. Legal Bases for Processing

If you are located in the European Economic Area (EEA), United Kingdom, or Switzerland, we process your personal data under one or more of the following legal bases:

  • ‍Performance of a contract. Where processing is necessary to perform a contract with you or to take steps at your request before entering into a contract.
  • ‍Legitimate interests. Where processing is necessary for our legitimate business interests, provided those interests are not overridden by your rights (e.g., operating and securing our Sites, B2B marketing).
  • Consent. Where you have given clear, affirmative consent for a specific purpose (e.g., opting in to marketing emails or to non-essential cookies). Non-essential tracking technologies are not activated until you provide this consent.
  • ‍Legal obligation. Where processing is required to comply with a legal obligation to which we are subject.

5. How We Share Your Information

MajorKey sells and shares personal information as those terms are defined by the CCPA. We do not receive cash payments for your information, but the CCPA definition covers monetary or other valuable consideration. Two of our practices meet it. First, where you register for a webinar or event that we run jointly with a technology partner, we disclose your registration record to that partner and we receive commercial benefits in return, including preferred rates and licensing terms. Second, we share online identifiers with advertising partners for cross-context behavioral advertising. You may opt out of both at any time using the “Your Privacy Choices” link in the footer of any page. We share information in the following circumstances:

  • ‍Affiliates. We may share information with our subsidiaries and affiliated companies for purposes consistent with this Privacy Policy.
  • ‍Service providers. We engage third-party companies to perform services on our behalf, such as hosting, analytics, payment processing, email delivery, and customer relationship management. These providers are contractually obligated to use your information only to provide services to us and to maintain appropriate security measures.‍
  • Advertising partners. Only after you opt in through our cookie consent manager, certain third-party advertising partners (such as LinkedIn, Google, and ZoomInfo) may collect information through cookies on our Sites for targeted advertising. See our Cookie Policy‍ and Section 10 for details on managing or withdrawing this consent.
  • Legal requirements. We may disclose information when required by law, subpoena, court order, or governmental request, or to protect our rights or the safety of others.‍
  • Business transfers. If MajorKey is involved in a merger, acquisition, reorganization, or sale of assets, your information may be transferred as part of that transaction, with notice as required by law.

6. Data Processed on Behalf of Our Clients

In the course of providing identity security advisory and consulting services, MajorKey may process personal data on behalf of our clients. In these cases, our clients are the data controllers or business, and MajorKey acts as a data processor or service provider.

We process client data solely in accordance with the client's instructions and the terms of our service agreements. We do not use client data for our own purposes.

If you are an individual whose data has been processed by MajorKey on behalf of one of our clients and you wish to exercise your privacy rights, please contact the organization that engaged MajorKey (the data controller or business) directly. MajorKey will cooperate with our clients to fulfill such requests.

7. Cookies and Tracking Technologies

We use cookies and similar tracking technologies on our Sites to support site functionality, analyze usage, and - where you consent - deliver targeted advertising. Our use of these technologies is governed by our Cookie Policy, available at www.majorkeytech.com/cookie-policy.

Non-essential cookies and third-party tracking technologies (including analytics and advertising tags such as Google Analytics, Google Ads, the LinkedIn Insight Tag, HubSpot analytics, and ZoomInfo) are blocked and do not load until you provide affirmative consent through our cookie banner. Strictly necessary cookies, which are required for the Sites to function and to record your consent choices, are always active.

You can manage or withdraw your cookie preferences at any time through the "Cookie Preferences" link in the footer of our Sites, which is powered by TrustArc Cookie Consent Manager.

8. Data Retention

We retain your personal information only for as long as necessary to fulfill the purposes for which it was collected, including to satisfy legal, accounting, or reporting obligations.

In general:

  • Business contact information is retained for the duration of the business relationship and for a reasonable period thereafter to allow us to respond to follow-up inquiries or provide ongoing support.
  • Job application data is retained for at least two years from the date of application or the close of the recruitment process, and longer where required by our obligations as a federal contractor and by equal employment opportunity (“EEO”) recordkeeping requirements (including applicable OFCCP and EEOC rules). Where you have consented, we may keep your information beyond this period to consider you for future roles.
  • Client data (processor role) is retained in accordance with the terms of our service agreement with the applicable client.
  • Marketing contact data - where you provide personal information for marketing purposes (for example, by subscribing to communications or downloading content), we retain it for as long as you remain subscribed and have not objected. We delete or anonymize it upon your unsubscribe, withdrawal of consent, or deletion request, and we automatically remove contacts that have been inactive for 24 months.
  • Technical and analytics data - cookie-based identifiers expire automatically (our HubSpot analytics cookies within six months; advertising cookies per the schedule in our Cookie Policy). Server-side analytics data is retained no longer than necessary for reporting and, where configurable, for a maximum of fourteen months (for example, Google Analytics) before deletion or aggregation.

When personal information is no longer needed, we securely delete or anonymize it.

9. Data Security

We implement reasonable administrative, technical, and physical safeguards to protect personal information from unauthorized access, use, alteration, or destruction. These measures include encryption of data in transit using TLS, access controls, and regular security assessments.

No method of transmission over the Internet or electronic storage is completely secure. While we strive to protect your personal information, we cannot guarantee absolute security.

10. Your Privacy Rights

Depending on your location, you may have certain rights regarding your personal information. We describe these rights below by jurisdiction.

10.1 European Economic Area, United Kingdom, and Switzerland

If you are located in the EEA, UK, or Switzerland, you have the following rights under the GDPR or equivalent legislation:

  • ‍Right of access. To request a copy of the personal data we hold about you.
  • ‍Right to rectification. To request correction of inaccurate or incomplete personal data.
  • ‍Right to erasure. To request deletion of your personal data where there is no compelling reason for its continued processing.
  • ‍Right to restriction of processing. To request that we restrict processing under certain conditions.
  • ‍Right to data portability. To receive a copy of your personal data in a structured, commonly used, machine-readable format.
  • ‍Right to object. To object to processing based on our legitimate interests.
  • ‍Right to withdraw consent. Where processing is based on consent, to withdraw that consent at any time without affecting prior lawful processing.
  • ‍Right to lodge a complaint. To lodge a complaint with your local data protection authority.

To exercise these rights, contact us at privacy@majorkeytech.com. We will respond within 30 days, or within the timeframe required by applicable law.

MajorKey has a designated DPO who may be contacted at DataPrivacyOfficer@majorkeytech.com.

10.2 California Residents (CCPA/CPRA)

If you are a California resident, the California Consumer Privacy Act, as amended by the California Privacy Rights Act (collectively, "CCPA"), provides you with the following rights:

  • ‍Right to know. To know what categories and specific pieces of personal information we have collected, the sources of collection, the business purposes, and the categories of third parties with whom we share it.
  • ‍Right to delete. To request deletion of personal information we have collected from you, subject to certain exceptions.
  • ‍Right to correct. To request correction of inaccurate personal information.
  • ‍Right to opt out of sale/sharing. To opt out of the “sale” or “sharing” of your personal information, via the “Your Privacy Choices” link in our footer or at https://www.majorkeytech.com/privacy-choices.
  • Right to limit use of Sensitive Personal Information: To limit our use and disclosure of Sensitive Personal Information to the purposes permitted under CPRA Section 1798.121. Although we do not use SPI for purposes beyond those permitted, you may submit a request using the methods below. 
  • ‍Right to non-discrimination. We will not discriminate against you for exercising any of your CCPA rights.

The tables below describe the categories of personal information we have collected in the preceding twelve months, where it came from, why we collect it, whether we sell or share it, the categories of third parties we disclose it to, and how long we keep it. The first table covers personal information as defined in Cal. Civ. Code Civil Code Section 1798.140(v)(1). The second covers sensitive personal information as defined in Civil Code Section 1798.140(ae). These tables describe our own collection through the Sites, our services, and our other interactions with you, including as a job applicant. They do not describe personal information we process on behalf of our clients, where we act as a service provider or processor. See Section 6.

Categories of personal information
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Category of personal information Examples of information we collect Sources of collection Business or commercial purpose Do we sell or share it? To whom, and why Disclosed for a business purpose, and to whom Retention period or criteria
Identifiers (Civil Code Section 1798.140(v)(1)(A)) Name; job title; company name; business email address; telephone number; mailing address; IP address; and online identifiers set by cookies and pixels, including the HubSpot visitor token, the Google Analytics client ID, and LinkedIn and ZoomInfo identifiers. We do not collect an account name, because the Sites have no user accounts. Directly from you through web forms (Contact Us, newsletter, gated content, event and webinar registration). Automatically from your device and browser. From publicly available sources such as LinkedIn and company websites, and from third-party data providers used to supplement business contact records (Section 2.3). For job applicants, through our careers page and our applicant tracking provider. Respond to inquiries; deliver requested content; marketing and event communications; recruitment; site security and bot mitigation; analytics; advertising. Yes. The online identifiers are shared with LinkedIn and Google for cross-context behavioral advertising and advertising measurement (Section 5). Disclosed to ZoomInfo for business-to-business visitor identification. Business-to-business visitor identification is not cross-context behavioral advertising, so it is not a share under Civil Code Section 1798.140(ah)(1); we treat it as a sale because we receive a commercial benefit.

Separately, contact details you give us when registering for a jointly run event are disclosed to that event partner. We treat it as a sale rather than a share. Where you register for a webinar or event that we run jointly with a technology partner, we disclose your registration record to that partner. In return we receive commercial benefits including preferred rates, licensing terms and deal registration credit. Because Civil Code Section 1798.140(ad)(1) covers monetary or other valuable consideration, that is a sale. Categories of third party: technology and co-marketing partners. 		HubSpot (customer relationship management, forms, email); Webflow (hosting); Cloudflare (bot mitigation); Google reCAPTCHA (form abuse prevention on info.majorkeytech.com); TrustArc (consent management); Paycor Recruiting (applicant tracking). Business contact information: for the duration of the business relationship and a reasonable period afterward. Marketing contacts: while you remain subscribed and have not objected, and automatically removed after 24 months of inactivity. Job applicants: at least two years from the date of application or the close of recruitment, and longer where required by our obligations as a federal contractor and by equal employment opportunity recordkeeping rules (OFCCP, EEOC). Where you have consented, we may keep your information beyond that period to consider you for future roles. The IP address and cookie identifiers listed here are held with the analytics data described in the Internet activity row and kept for the same periods.
California Customer Records personal information (Civil Code Section 1798.140(v)(1)(B); Civil Code Section 1798.80(e)) Name, telephone number, mailing address, and employment or employer. These also appear under Identifiers and under Professional information; Civil Code Section 1798.80(e) overlaps those categories by design. Billing contact details where you engage us for services, so that we can invoice you and manage accounts receivable. We do not process card or bank payments: there is no payment flow on the Sites and no merchant gateway. We do not collect a signature, Social Security number, driver's license, state identification card or passport number, physical characteristics, insurance policy number, or medical or health insurance information. Directly from you through the Contact Us form and engagement correspondence. Respond to inquiries; contact you about our services; billing and accounts receivable in the course of an engagement. No. HubSpot (customer relationship management); our accounting system for invoicing. Business contact information: for the duration of the business relationship and a reasonable period afterward. Records are also kept for as long as needed to satisfy legal, accounting or reporting obligations.
Characteristics of protected classifications under California or federal law (Civil Code Section 1798.140(v)(1)(C)) Not collected from Site visitors or business contacts. For job applicants, voluntary equal employment opportunity self-identification of gender, ethnicity or race, protected veteran status, and disability status. Providing any of it is optional, you may decline each question, and declining has no effect on your application. The disability form also records your name and the date you complete it. For job applicants, directly from you through Paycor Recruiting, on the self-identification screens presented before the application form. Satisfy equal employment opportunity and federal contractor obligations under VEVRAA and the OFCCP rules. It is kept separate from your application, is not shown to hiring managers, and is not used to evaluate your application. No. Paycor Recruiting (applicant tracking). Job applicants: at least two years from the date of application or the close of recruitment, and longer where required by our obligations as a federal contractor and by equal employment opportunity recordkeeping rules (OFCCP, EEOC). Where you have consented, we may keep your information beyond that period to consider you for future roles.
Commercial information (Civil Code Section 1798.140(v)(1)(D)) Records of services considered or requested: gated content downloaded, webinars and events registered for, resources requested, newsletter subscription, and the subject of your inquiry. The Sites have no e-commerce, so we hold no cart, abandoned cart, loyalty program or subscription purchase history. Directly from you through content, event and webinar registration forms, and from your interactions with the Sites. Deliver requested content; qualify and route inquiries; marketing; measure content performance. Yes, and we treat it as a sale rather than a share. Where you register for a webinar or event that we run jointly with a technology partner, we disclose your registration record to that partner. In return we receive commercial benefits including preferred rates, licensing terms and deal registration credit. Because Civil Code Section 1798.140(ad)(1) covers monetary or other valuable consideration, that is a sale. Categories of third party: technology and co-marketing partners. HubSpot (customer relationship management, landing pages, email); our event and webinar platforms. Marketing contacts: while you remain subscribed and have not objected, and automatically removed after 24 months of inactivity.
Internet or other electronic network activity information (Civil Code Section 1798.140(v)(1)(F)) IP address; browser type and version; operating system; device type; screen resolution; language preferences; pages visited; links clicked; referring and exit URLs; date, time and duration of visits; site search queries; and cookie, pixel and tag identifiers. Automatically from your device and browser as you use the Sites, through cookies, pixels and tags. Through Google reCAPTCHA on gated content forms. Analytics and site performance; security, bot mitigation and form abuse prevention; personalization; advertising and advertising measurement. Yes. Shared with LinkedIn and Google for cross-context behavioral advertising and advertising measurement (Section 5). Disclosed to ZoomInfo for business-to-business visitor identification. Business-to-business visitor identification is not cross-context behavioral advertising, so it is not a share under Civil Code Section 1798.140(ah)(1); we treat it as a sale because we receive a commercial benefit. HubSpot; Cloudflare; Webflow; Google reCAPTCHA; TrustArc; Intellimize (on-site personalization). Server-side analytics data: no longer than necessary for reporting and, where the platform allows a limit to be set, a maximum of 14 months, for example Google Analytics. HubSpot analytics cookies expire within 6 months. Advertising cookie identifiers expire according to the schedule in our Cookie Policy, which currently runs from session length to 13 months. Cookie expiry is a browser lifetime, not a retention period. Request-level logs held by our content delivery provider are retained for no more than 7 days.
Geolocation data (Civil Code Section 1798.140(v)(1)(G)) Approximate location (country, region, city) inferred from your IP address. We do not collect precise geolocation. The Sites never request browser location permission. Automatically, derived from your IP address. Security and fraud prevention; analytics; content relevance. Yes, to the extent your IP address is transmitted. Shared with LinkedIn and Google for cross-context behavioral advertising and advertising measurement. Disclosed to ZoomInfo for business-to-business visitor identification. Business-to-business visitor identification is not cross-context behavioral advertising, so it is not a share under Civil Code Section 1798.140(ah)(1); we treat it as a sale because we receive a commercial benefit. HubSpot; Cloudflare; Webflow. Held with the identifiers and analytics data described in the Internet activity row and kept for the same periods. Request-level logs held by our content delivery provider are retained for no more than 7 days.
Audio, electronic, visual, thermal, olfactory, or similar information (Civil Code Section 1798.140(v)(1)(H)) We do not use live chat, session replay or call recording on any MajorKey web property. We do record some webinars and virtual events. Those recordings capture the presenters. Attendee video is never captured. Where a session includes a live audience question, an attendee's voice may be captured in the recording. Whether that happens varies by event. Our webinar and event platform, where a session is recorded. Deliver and distribute event content; marketing. No. Our webinar and event platforms. Recordings are kept for as long as the content remains published and in use for marketing. We do not currently delete webinar or event recordings.
Professional or employment-related information (Civil Code Section 1798.140(v)(1)(I)) Job title, employer or company name, and work history. For job applicants: resumes, cover letters, education history and related application materials, together with anything you include in the free-text message field on the Contact Us form. Pre-employment screening happens only after an offer is accepted and is covered by our Employee Privacy Notice rather than this policy. Directly from you through the Contact Us form and your application materials. From publicly available sources such as LinkedIn and company websites, and from third-party data providers used to supplement business contact records (Section 2.3). For applicants, through Paycor Recruiting. Respond to and route inquiries; qualify business contacts; marketing; event administration; recruitment and candidate evaluation. Yes, and we treat it as a sale rather than a share. Where you register for a webinar or event that we run jointly with a technology partner, we disclose your registration record to that partner. In return we receive commercial benefits including preferred rates, licensing terms and deal registration credit. Because Civil Code Section 1798.140(ad)(1) covers monetary or other valuable consideration, that is a sale. Categories of third party: technology and co-marketing partners. Job applicant information is never sold or shared. HubSpot (customer relationship management); our event and webinar platforms; Paycor Recruiting (applicants). Business contact information: for the duration of the business relationship and a reasonable period afterward. Job applicants: at least two years from the date of application or the close of recruitment, and longer where required by our obligations as a federal contractor and by equal employment opportunity recordkeeping rules (OFCCP, EEOC). Where you have consented, we may keep your information beyond that period to consider you for future roles.
Inferences drawn from the above (Civil Code Section 1798.140(v)(1)(K)) Company and firmographic attributes such as industry, size and segment; content and topic interests; audience segments; and lead scoring or routing. These are not derived from purchase history. Derived from your interactions with the Sites and the information you submit, combined with information from publicly available sources and third-party data providers (Section 2.3). Qualify and route inquiries; personalize content; measure marketing performance; build advertising audiences. Yes, shared. The audience segments are shared with LinkedIn and Google to build and target advertising audiences for cross-context behavioral advertising (Section 5). Lead scoring and routing are used internally and are not sold or shared. HubSpot; Intellimize (on-site personalization). Business contact information: for the duration of the business relationship and a reasonable period afterward. Marketing contacts: while you remain subscribed and have not objected, and automatically removed after 24 months of inactivity.

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Categories of sensitive personal information
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Category of sensitive personal information Do we collect it Sources of collection Business or commercial purpose Do we sell or share it Disclosed for a business purpose, and to whom Retention period or criteria
Racial or ethnic origin, citizenship or immigration status, religious or philosophical beliefs, or union membership (Civil Code Section 1798.140(ae)(1)(D)) Not collected from Site visitors or business contacts. Yes for job applicants, in two forms. First, voluntary self-identification of ethnicity or race, which you may decline. Second, before you reach the application we ask whether you will now or in the future require sponsorship for employment visa status, and whether you currently live in the United States; an answer to the sponsorship question can reveal your immigration status. That question is required in order to apply. For job applicants, directly from you through Paycor Recruiting. Equal employment opportunity and federal contractor reporting, and determining whether you are eligible for the role without sponsorship. The self-identification data is not used to evaluate your application. 2.4. No. Paycor Recruiting (applicant tracking). Job applicants: at least two years from the date of application or the close of recruitment, and longer where required by our obligations as a federal contractor and by equal employment opportunity recordkeeping rules (OFCCP, EEOC). Where you have consented, we may keep your information beyond that period to consider you for future roles.
Personal information collected and analyzed concerning health (Civil Code Section 1798.140(ae)(2)(B)) Not collected from Site visitors or business contacts. No Site form has a health field. Yes for job applicants: we invite voluntary self-identification of disability status on the OFCCP form, which asks whether you have, or have ever had, a disability and lists the conditions that qualify. You may decline. The form records your name and the date. Pre-employment screening happens only after an offer is accepted and is covered by our Employee Privacy Notice rather than this policy.

Separately, the free-text message field on the Contact Us form is unbounded and a person could volunteer health information into it; we do not solicit or analyze it.		 For job applicants, directly from you through Paycor Recruiting. Federal contractor reporting under Section 503 of the Rehabilitation Act. It is kept separate from your application and is not used to evaluate it. 2.4. No. Paycor Recruiting (applicant tracking). Job applicants: at least two years from the date of application or the close of recruitment, and longer where required by our obligations as a federal contractor and by equal employment opportunity recordkeeping rules (OFCCP, EEOC). Where you have consented, we may keep your information beyond that period to consider you for future roles.

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Sensitive personal information. We do not use or disclose sensitive personal information for purposes other than those permitted under Cal. Civ. Code Civil Code Section 1798.121(a) and Cal. Code Regs. tit. 11, Section 7027(m). You may still ask us to limit our use and disclosure of it using the methods in Section 10.2.

Why we disclose for business purposes. We disclose personal information to vendors who perform services for us, including website hosting, customer relationship management, email delivery, event and webinar administration, applicant tracking, security and bot mitigation, consent management, and analytics.

Your right to opt out. Because we sell and share personal information, you may opt out at any time. Use the “Your Privacy Choices” link in the footer of any page, or go directly to https://www.majorkeytech.com/privacy-choices.

Your right not to be retaliated against. We will not retaliate against you for exercising any of your privacy rights. This applies whether you deal with us as a consumer, a job applicant, an employee or an independent contractor.

Retention. Where we cannot state a fixed period, we describe the criteria we use to decide how long we keep each category.

Scope. These tables do not cover personal information we process on behalf of our clients, where we act as a service provider or processor. If your information was given to us by an organization that engaged us, please contact that organization. They also do not cover personal information about our own employees and independent contractors, or pre-employment screening carried out after an offer is accepted, including background checks.

MajorKey does not sell personal information for monetary consideration. However, certain advertising cookies may constitute "sharing" under the CCPA when they enable third-party advertising partners to collect data for targeted advertising. These cookies are activated only with your opt-in consent, and you may withdraw consent at any time through our cookie consent manager or the "Your Privacy Choices" link.

We honor the Global Privacy Control (GPC) browser signal as a valid opt-out of the sale or sharing of personal information.

Submitting a request (California)

California residents may submit a verifiable request to know, delete, correct, or limit SPI through either of the following two methods:

We will verify your identity before fulfilling your request and respond within 45 days (extendable by an additional 45 days with notice).

Authorized agents

You may designate an authorized agent to submit a request on your behalf. We will require (i) written permission signed by you authorizing the agent or a valid power of attorney, and (ii) verification of your own identity directly with us. We may deny a request from an agent who cannot provide proof of authorization.

10.3 Other U.S. State Privacy Laws

Residents of states with comprehensive privacy laws may have rights to access, delete, correct, and opt out of targeted advertising or the sale of personal data, and to appeal a denied request. We do not collect, use or sell personal information to train large language models.

To exercise your rights under any applicable state law, contact us at privacy@majorkeytech.com or via the toll-free number above. We will process your request in accordance with the requirements of your state's law.

Appeals

If we decline to act on your request, you may appeal that decision by emailing appeals@majorkeytech.com with the subject line "Privacy Rights Appeal" (or by writing to the address in Section 20, Attn: Privacy Appeals). This appeal channel is separate from the initial request channel. We will respond to your appeal within 45 days (or within the period required by your state's law) and will explain the reasons for our decision. If your appeal is denied, we will provide information on how to contact your state Attorney General to submit a complaint.

10.4 Canada (PIPEDA)

If you are located in Canada, the Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable provincial legislation provide you with the right to access and correct your personal information, to withdraw consent to its collection and use, and to challenge our compliance.  To exercise your rights or file a complaint, please contact us at privacy@majorkeytech.com.  If you feel we have not handled your request to your satisfaction, you may escalate your concern to the Office of the Privacy Commissioner of Canada at https://www.priv.gc.ca/en/report-a-concern/.

Your personal information may be stored outside Canada by MajorKey or our service providers and may be lawfully accessed by local authorities.

To exercise these rights, contact us at privacy@majorkeytech.com. We will respond within 30 days.

11. International Data Transfers

11.1 Data Privacy Framework

MajorKey Technologies LLC complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework as set forth by the U.S. Department of Commerce, and has certified its adherence to the DPF Principles for personal data received from the EU, UK (and Gibraltar), and Switzerland. To view our certification, please visit https://www.dataprivacyframework.gov/.

If there is any conflict between this Privacy Policy and the DPF Principles, the Principles shall govern.

11.2 Transfer Mechanisms for Service Providers and Partners

Some of our service providers and advertising partners (including Google, LinkedIn, HubSpot, and ZoomInfo) are located in, or transfer data to, the United States and other countries outside the EEA, UK, and Switzerland. Where we transfer personal data internationally, we rely on an appropriate safeguard such as the EU Standard Contractual Clauses, the UK International Data Transfer Addendum, the Data Privacy Framework, or an adequacy decision.

11.3 Accountability for Onward Transfers

MajorKey remains responsible for personal data it receives under the Data Privacy Frameworks and subsequently transfers to third parties acting as agents on its behalf, consistent with the DPF Principles. 

11.4 Dispute Resolution

Individuals in the EU, UK, or Switzerland with a complaint regarding our DPF compliance should first contact us at privacy@majorkeytech.com. If unresolved, we have committed to refer unresolved complaints to TRUSTe, an independent dispute resolution provider; see https://feedback-form.truste.com/watchdog/request. Under certain conditions you may invoke binding arbitration as described in Annex I of the DPF Principles. MajorKey Technologies LLC is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC).

12. Do Not Track and Global Privacy Control

Browser "Do Not Track" (DNT) signals: There is no accepted industry standard for interpreting DNT signals, and our Sites do not currently respond to them.

Global Privacy Control (GPC): We do honor the GPC signal. When we detect a GPC signal from your browser, we treat it as a valid opt-out of the sale or sharing of your personal information under the CCPA and other applicable state laws. We will continue to monitor developments in universal opt-out signal requirements and update our practices as new laws take effect. 

13. Third-Party Links and Services

Our Sites may contain links to websites and services operated by third parties. This Privacy Policy does not apply to those third-party sites. We encourage you to review the privacy policies of any third-party site you visit.

Social Media Features

Our Sites may include social media features (such as LinkedIn or X share buttons and widgets). These features may collect your IP address and the page you are visiting and may set a cookie to function. Your interactions with these features are governed by the privacy policy of the company providing them.

14. Testimonials and User-Generated Content

We may display testimonials from satisfied clients on our Sites. With your consent, we may post your testimonial along with your name and company. If you wish to update or remove your testimonial, contact us at privacy@majorkeytech.com.

Any content you submit to public areas of our Sites (such as blog comment sections) may be viewable by other users. Exercise caution when disclosing personal information in these areas.

15. Children's Privacy

Our Sites and services are designed for business professionals and are not directed to individuals under the age of sixteen. We do not knowingly collect personal information from children. If we learn that we have collected such information, we will take steps to delete it promptly. If you believe we have collected information from a child under sixteen, please contact us at privacy@majorkeytech.com.

16. Automated Decision-Making

We use automated screening when you apply for a role with us. Our applicant tracking system asks a small number of qualification questions before you submit an application, and an answer that does not meet the stated requirement for the role can result in your application being declined without a person reviewing it. The questions cover matters such as whether you are located in the United States, whether you hold the experience or certification the role requires, and whether you would need visa sponsorship. We do not use the voluntary self-identification information described in Section 2.4 in any screening or hiring decision. Outside of recruitment, our analytics and marketing tools may create audience segments or interest profiles, but these are used solely for marketing optimization and do not affect your access to our services. If your application was declined by automated screening and you would like it reviewed by a person, contact us at privacy@majorkeytech.com.

17. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. When we make material changes, we will update the "Last Updated" date and, where required by law, provide notice via email or a prominent notice on our Sites before the changes take effect. We review this policy at least annually. 

18. Accessibility and Alternative Formats

We are committed to making this Privacy Policy reasonably accessible to all individuals, including those who use assistive technologies. A printable/downloadable version is available on request. If you communicate with us predominantly in a language other than English and need this policy in an alternative format or language, contact us at privacy@majorkeytech.com.

19. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

MajorKey Technologies LLC

Attn: Privacy

1 Mid America Plaza, 3rd Floor, Oakbrook Terrace, IL 60181

Email: privacy@majorkeytech.com

Toll-free: (866) 265-8665