Last revised September 2023

September 2023

CellTrust Corporation updated its privacy policy statement to incorporate the following changes:

1. Reference to Privacy Shield was modified to reflect the updated Data Privacy Framework and its requirements.
2. Section 2.1 was modified to update and clarify the information CellTrust collects, CellTrust’s use of third parties in relation to collected personal information, and the role of personal information with audits that CellTrust is subject to.
3. Section 3 was updated to reflect and clarify CellTrust’s use of third-party cookies/identifiers for its website, to make clear certain cookies are not used with SL2, and to provide a clear mechanism on how to revoke consent to CellTrust’s use of cookies.
4. In addition to the updates to reflect the Data Privacy Framework and its current requirements, Section 4 was modified as follows:
   1. to provide a mechanism for clarifications regarding CellTrust’s privacy policy statement
   2. to include the use of opt-out keyword as an option to restrict certain uses of personal information
   3. to set forth CellTrust’s policy related to law enforcement requests
   4. to set forth the duration in which CellTrust retains personal information
   5. to set forth CellTrust’s commitment to annual review of the policy statement to verify its accuracy
   6. to identify CellTrust’s designated Privacy Officer and contact info
   7. to clarify the role of communication conduits in relation to the Data Privacy Framework
5. Section 9 was updated to reflect CellTrust’s notification process for changes to the privacy policy statement.