SaaS Agreement

            This SaaS Agreement (“Agreement”), together with any applicable Invoices, and the Data Processing Agreement (“DPA”), applies to Services provided to Customer by PSNI, LLC (“PSNI”). Customer and PSNI are referred to individually as a “Party” and jointly as “Parties.”

            Please read this Agreement carefully before accessing or using the Services. By (i) executing or agreeing to an Invoice (as defined below), (ii) accessing or using the Services, or (iii) permitting any Authorized User to access or use the Services, Customer agrees to be bound by this Agreement.

1. Definitions. The following terms shall have the following meanings.
   1. “Affiliate” means any entity controlled, directly or indirectly, by, under common control with, or controlling, a party, and specifically includes without limitation, subsidiaries, partnerships, joint ventures, and other entities or operations for which the party has operational or management control. For the purposes of this definition, “control” means the power to direct, or cause the direction of, the management and policies of such entity whether by contract, law, or ownership of the majority of the voting shares or assets of another entity.
   2. “Authorized Users” means employees, agents, representatives, consultants or contractors of Customer and other persons expressly authorized by Customer to use the Services.
   3. “Customer” means the entity or individual identified as the Customer on the applicable Invoice under which the Services are provided.
   4. “Customer Data” means all data or information provided by Customer to PSNI or collected by PSNI in the course of providing Services to Customer under the Agreement. For clarity, Customer Data includes Personal Information and Customer Confidential Information.
   5. “Confidential Information” means all documents, data, information and other materials that a Party receives, acquires or learns or are provided to that Party (“Receiving Party”) by, for, or on behalf of the other Party (“Disclosing Party”) that are not generally known by persons who are not employees, agents, or representatives of Disclosing Party. This term: (i) includes information, documents, data, and other materials (a) related to customers, potential customers, goods and services, Services, operations, manufacturing, production, maintenance, distribution, sales, marketing, customer service, finance, agreements, costs, prices, business plans, purchase orders, invoices, account information, and billing records, (b) marked or designated with a word or symbol indicating that it should be considered confidential, such as “Confidential”, “Personal” or “Privileged”, (c) that Disclosing Party informs Receiving Party are confidential, and (d) that Receiving Party knows or should know are confidential or proprietary information or trade secrets of Disclosing Party or a third-party; but (ii) does not include documents, data, information and other materials that are (a) available from a publicly accessible source, (b) known to Receiving Party at the time of disclosure, (c) obtained by Receiving Party on a non-confidential basis from a third-party without violation of any contractual, statutory, common law, or other duty or obligation, and (d) independently developed by Receiving Party.
   6. “Deidentified” means information that does not, and cannot reasonably be used to, identify a particular individual, household, or device of an individual.
   7. “DPA” means the Data Processing Agreement set forth in Exhibit A to this Agreement.
   8. “Fees” has the meaning assigned to it in the applicable Invoice.
   9. “Invoice” means the quotation, or any other document for provision of Services, including any amendment of or supplement to that document, that references this Agreement. Any changes to the Invoices must be agreed upon in writing by the Parties.
   10. “Liability” means costs, expenses, losses, obligations, damages, actions, suits, demands, settlements, judgments, awards, fines, penalties, fees (including attorney’s fees), and any other form of liability whatsoever.
   11. “Personal Information” means information that identifies or is identifiable to a natural person, that PSNI receives from Customer or Processes for or on behalf of Customer.
   12. “PSNI Content” means PSNI supplied text, audio, video, graphics and other information and data related to or available by means of the Service or on PSNI’s web site, including information and data created, developed, or structured by PSNI to store, save, evaluate, compare, or analyze Customer Data.
   13. “Services” means PSNI’s online services as further described in the applicable Invoice.
   14. “Sub-Processor” means any third-party that Processes Customer Data by, for, or on behalf of PSNI arising out or related to PSNI’s performance of its obligations under the Agreement.
2. Access and Use. Subject to Customer’s timely payment of all undisputed Fees and its continued compliance with the Agreement, PSNI grants Customer, and its Authorized Users and Affiliates a limited, non-exclusive, non-transferable, non-assignable, and non-sublicensable (except as expressly permitted herein) right, during the applicable Term, to access and use the Services for Customer’s internal lawful business purposes. Customer shall use and access the Services in accordance with the Agreement and any documentation and usage guidelines for the Services provided by PSNI to Customer, as updated from time to time by PSNI (“Documentation”). Customer acknowledges that the Services (including any associated software components) are licensed, not sold. All rights not expressly granted to Customer are reserved by PSNI and its licensors. PSNI will provide Customer with the necessary credentials, passwords, and connectivity details to enable access to the Services. The number of Simultaneous Authorized Users permitted to access and use the Services shall be as expressly specified in the applicable Invoice. Customer may request to add additional Simultaneous Authorized Users by providing written notice to PSNI, and any such addition shall be subject to PSNI’s prior written approval and may require the execution of an amendment to the applicable Invoice, and/or the payment of additional Fees, as determined by PSNI.
3. Compliance with Law. Each Party agrees to comply with all applicable federal, state, and local laws, ordinances and regulations. If at any time during the Term, a Party is informed or information comes to its attention that it is or may be in violation of any law, ordinance, code, or regulation (or if it is so determined by any court, tribunal or other authority), that Party shall immediately take all appropriate steps to remedy such violation and comply with such law, ordinance, code, or regulation in all respects, at the Party’s sole cost and expense.
4. Use Restrictions. Customer shall not use the Services in any manner not expressly permitted by the applicable Agreement or the Documentation. Without limiting the foregoing, Customer shall not, and shall not permit any third party to, directly or indirectly: (i) use the Services in any manner that violates any applicable law; (ii) use the Services in any manner that violates this Agreement; (iii) use the Services in any manner that infringes, misappropriates, or otherwise violates any third-party’s rights; (iv) copy, modify, or create derivative works of the Services or create models that may compete with the Services, in whole or part; (v) rent, lease, lend, sell, sublicense, assign, transfer, or make available the Services to any third-party; (vi) reverse engineer, disassemble, decompile, decode, adapt, or attempt to derive or gain access to any software code or component of the Services; (vi) use the Services or any related outputs to provide services to third parties except as expressly permitted in writing by PSNI; (vii) use the Services for purposes of benchmarking, competitive analysis, or publication of performance tests without PSNI’s prior written consent; (viii) interfere with or disrupt the integrity, performance, or security of the Services, including attempting to bypass or disable any security or access controls; (ix) input, store, or transmit malicious code, unlawful content, or any material that violates third-party privacy or IP rights through the Services; or (x) remove any proprietary notices from the Services.
5. Suspension or Termination of Services. PSNI may suspend, temporarily or permanently terminate, deny, discontinue, or restrict Customer’s and any Authorized User’s access to and use of the Services, without any Liability to Customer, if: (i) PSNI determines that Customer’s or any Authorized User’s use of the Services (1) violates any applicable law or this Agreement, (2) creates or causes any security or privacy threat or risk, or disrupts any other person’s use of the Services, or (3) is illegal, unlawful, fraudulent, deceptive, defamatory, obscene, offensive, abusive, unethical, immoral, or dishonest; (ii) there is a threat or attack to the Services or PSNI’s systems or infrastructure; (iii) Customer’s or PSNI’s connection to computer systems, Internet, or hosting providers is impaired; (iv) PSNI must do so under any applicable law or pursuant to an order or instruction of any law enforcement, governmental, or regulatory authority; (v) PSNI has ceased to continue its business in the ordinary course, made an assignment for the benefit of creditors or similar disposition, or becomes the subject of any bankruptcy, reorganization, liquidation, dissolution, or similar proceeding; or (vi) there is suspension or termination of PSNI’s use of any third-party technology or service required to support the Services. Unless prohibited from doing so or otherwise commercially impracticable, PSNI shall use commercially reasonable efforts to provide notice of any suspension or termination of the Services to Customer under this section, and update Customer about the resumption of the Services following any such suspension or termination. PSNI has no Liability to Customer arising out of or related to any suspension or termination of the Services under this section.
6. Customer Responsibilities. Customer is liable to PSNI for all Liability arising out of or related to Customer’s and Authorized Users’ access to and use of the Services. Without limiting the foregoing, Customer shall (i) ensure that it has all rights and authorizations necessary to provide Customer Data to PSNI for the purposes described in this Agreement; (ii) ensure that Customer’s systems, networks, and devices meet the minimum technical requirements specified by PSNI for the Services and are properly configured and maintained; (iii) implement and maintain commercially reasonable measures designed to ensure the confidentiality and security of all passwords, biometrics, tokens, or other credentials used by Customer and Authorized Users to access the Services, and ensure that access credentials are not shared with or disclosed to any third-party; (iv) be responsible for the acts and omissions of its Authorized Users, including ensuring that Authorized Users comply with this Agreement; (v) provide all notices and obtain all consents from individuals whose Personal Information may be processed in connection with Customer’s use of the Services, if such notice and consent is required by applicable laws; and (vi) promptly notify PSNI of any unauthorized access to, or use of, the Services of which Customer becomes aware.
7. PSNI Ownership. As between the Parties, PSNI retains all rights, title, and interest in and to the following: (i) the Services and the Documentation; (ii) PSNI Confidential Information; (iii) PSNI Content; and (iv) Deidentified data derived from Customer Data. Customer is permitted during the Term to store, print, and display the PSNI Content and to permit Authorized Users to access it only in connection with use of the Services. No other use of PSNI Content is permitted. Except for the limited rights expressly granted in this Agreement, no licenses or other rights are granted to Customer, whether by implication, estoppel, or otherwise.
8. Customer Ownership. As between the Parties, Customer retains all rights, titles, and interest in and to Customer Data. Customer hereby grants to PSNI a non-exclusive, worldwide, royalty-free, fully paid-up license to access, process, use, reproduce, display, perform, distribute, modify, and otherwise utilize Customer Data as necessary to perform the Services, operate and maintain the systems used to provide the Services, comply with applicable law, and to develop, improve, and enhance PSNI’s products, Services, tools, and methodologies. In addition, PSNI may aggregate, anonymize, and/or De-Identify Customer Data and may use such aggregated, anonymized and De-Identified Data for analytics, benchmarking, research, product development, and other lawful business purposes, provided that such data does not identify Customer or any individual and cannot reasonably be re-identified. PSNI shall own all rights, title, and interest in and to any such anonymized, aggregated and De-Identified Data.
9. Confidentiality.
   1. Obligations. Except as permitted under the Agreement, the Receiving Party shall not disclose or provide access to any third party to any Disclosing Party’s Confidential Information without express written authorization from the Disclosing Party. Either party may disclose Confidential Information on a need-to-know basis to (i) its personnel, auditors and Affiliates who are subject to the same confidentiality obligations, and (ii) its attorneys and accountants who are either subject to professional obligations of confidentiality or have agreed to be bound by confidentiality obligations at least as protective as those set out herein. The Receiving Party will use at least the same level of care to prevent unauthorized use of the Disclosing Party’s Confidential Information as it uses for its own Confidential Information, but in no event less than a reasonable standard of care.
   2. Compelled Disclosures. If the Receiving Party receives a subpoena or other request to disclose any Disclosing Party’s Confidential Information, the Receiving Party will (to the extent permitted by law) do the following: (i) promptly notify the Disclosing Party; (ii) provide the Disclosing Party with a copy of the subpoena or request unless the law prohibits the Receiving Party from doing so; (iii) where possible, and to the extent permitted by law, direct the requesting authorities to request the information directly from the Disclosing Party; and (iv) not disclose any such Confidential Information unless and until (a) the Disclosing Party authorizes such disclosure in writing, or (b) a judicial, legislative, executive, or administrative body orders the Receiving Party to disclose such Confidential Information, the time for the Disclosing Party to appeal or challenge the order has expired, and the Disclosing Party has not appealed or challenged the order within that time.
10. Data Processing Agreement. If and to the extent Customer Data includes Personal Information subject to Data Protection Laws (as that term is defined in the DPA), the DPA will apply to the Services that PSNI provides to Customer, in which case the DPA is incorporated herein.
11. Sub-Processors. In the course of providing Services, PSNI may engage Sub-Processors. PSNI shall use contractual or other means to obligate such Sub-Processors to comply with terms that are comparable to the terms of this Agreement.
12. Term. This Agreement will commence on the earlier of the date Customer executes or accepts an applicable Invoice, the date Customer pays such Invoice, or the date Customer first accesses or uses the Services (“Effective Date”), and will continue until terminated as provided in this Agreement or as specified in an applicable Invoice. 
13. Termination.
    1. For Convenience. Customer may terminate this Agreement for convenience upon ninety (90) days’ prior written notice to PSNI. In the event of such termination for convenience by Customer, Customer will remain responsible for all Fees due during the applicable notice period. PSNI may terminate this Agreement for convenience upon thirty (30) days’ prior written notice to Customer. In the event of such termination, PSNI will refund to Customer any prepaid, unused Fees on a pro rata basis for the period following the effective date of termination. To the extent an Invoice specifies a fixed service period or prepaid term, such term will control with respect to the applicable Services, and termination for convenience will not relieve Customer of its obligation to pay any Fees applicable to such period.
    2. For Cause. In the event that either Party materially breaches any of the applicable Agreement, or any applicable law, and is unable or fails to cure such breach within thirty (30) days of written notice of such breach from the other Party, or if either Party becomes insolvent or bankrupt, or a receiver, assignee, or other liquidating officer is appointed for such Party for its business or assets, then the other Party may terminate the Agreement and the applicable Invoice immediately, and without incurring any Liability. If Customer terminates this Agreement due to PSNI’s uncured material breach, PSNI will refund any prepaid, unused Fees on a pro rata basis for the period following the effective date of termination.
14. Effect of Termination. Upon termination or expiration of this Agreement, all Invoices then in effect shall automatically terminate unless the Parties expressly agree in writing to a limited transition or wind-down period. During any such transition period, PSNI shall continue to provide Services solely for the purpose of ensuring an orderly transition of work or personnel, subject to Customer’s timely payment of all outstanding and ongoing fees. PSNI shall be entitled to charge Customer for such transition assistance at its then-current time and materials rates, unless otherwise agreed in writing by the Parties. Within thirty (30) days of termination or expiration, each Party shall return or, at the disclosing Party’s written request, destroy all Confidential Information and Customer Data in its possession or control, except for copies retained for legal, regulatory, or archival purposes, which shall remain subject to the confidentiality obligations herein.
15. Fees. Fees for the Services will be as set forth in the applicable Invoice. Customer will pay all undisputed Fees in accordance with the payment terms specified in the applicable Invoice, unless otherwise agreed in writing by the Parties. Where Services are purchased through an authorized reseller or third-party provider, Customer’s payment obligations will be satisfied by payment to such reseller in accordance with Customer’s agreement with that reseller. PSNI will have no obligation to provide Services to the extent it has not received payment from the applicable reseller for such Services. Unless otherwise specified in an applicable Invoice, PSNI may invoice annually in advance for the Services. All undisputed amounts are due within forty-five (45) days of the invoice date, unless otherwise stated in the applicable Invoice. If undisputed Fees remain unpaid when due, PSNI may, upon reasonable prior notice, suspend access to the Services until such amounts are paid. Any overdue amounts may accrue interest at the rate of 1.5% per month (or the maximum rate permitted by applicable law, if lower). Customer will be responsible for reasonable costs incurred by PSNI in collecting overdue undisputed amounts, to the extent permitted by law. Except as expressly provided in this Agreement, all Fees are non-cancellable and non-refundable. Fees are exclusive of taxes. Customer is responsible for all applicable sales, use, value-added, or similar taxes, duties, or governmental charges, other than taxes based on PSNI’s net income. Customer must notify PSNI in writing of any disputed charges within thirty (30) days of the applicable Invoice date, describing the nature of the dispute in reasonable detail. The Parties will work in good faith to resolve any such dispute. Undisputed amounts remain payable in accordance with this section.
16. Warranties. Each Party warrants it has full power to enter into the Agreement. Customer represents and warrants that all Customer Data and other information and materials that Customer provides or makes available to PSNI under the Agreement: (i) is owned by Customer, or Customer is authorized to provide it to PSNI for the purposes set forth in the applicable Agreement; (ii) does not infringe or misappropriate any trademark, service mark, copyright, or any third-party rights, including intellectual property rights; (iii) does not contain any libelous material or otherwise violate the rights or causes damage or injury to any person; (iv) complies with Data Protection Laws and any other applicable law; and (v) is not a violation of any contractual, statutory, common law, or other legal obligation or duty.
17. Disclaimer. Except as expressly provided in the Agreement, the Services are provided “as is” and “as available.” PSNI disclaims all warranties, express or implied, including any warranties of merchantability, fitness for a particular purpose, and non-infringement.
18. Liability.
    1. Customer Liability. Customer is liable to PSNI for Liability arising out of or related to the following: (i) any material violation by Customer or its Affiliates or Authorized Users of applicable law, including Data Protection Laws, or the Agreement; (ii) any authorized use by PSNI of Customer Data; (ii) any grossly negligent, reckless or intentional act or omission of, or by Customer or its Affiliates or Authorized Users.
    2. PSNI Liability. PSNI is liable to Customer for Liability arising out of or related to the following: (i) any material violation by PSNI of applicable law, including Data Protection Laws, or the applicable Agreement; and (ii) any grossly negligent, reckless or intentional act or omission of, or by PSNI or its employees, agents, officers, or directors.
19. Limitation of Liability. Except for (i) payment obligations; (ii) any breach of Confidentiality obligations; and (iii) Liability under the DPA, each Party’s aggregate Liability is limited to fees paid or payable by Customer for the Services during the twelve (12) months preceding the event giving rise to Liability.
20. Scheduled Maintenance; Service Level Commitment; Technical Support.
    1. PSNI will periodically schedule the complete or partial shutdown of the Services for maintenance, bug fixes, upgrades, or other reasons (“Scheduled Maintenance”). Scheduled Maintenance will be implemented in such a way as to minimally interrupt the use of and access to the Services by Customer under this Agreement. PSNI shall provide Customer with email notice 48 hours in advance of any Scheduled Maintenance that will disable the Services for more than three consecutive hours. PSNI may perform emergency maintenance services at any time during the Term of this Agreement without prior notice to Customer. (“Emergency Maintenance”).
    2. PSNI will provide access to the Services for Customer on a twenty-four hour a day, seven days a week (24x7) basis, except for Scheduled Maintenance and Emergency Maintenance and except for any downtime, delays, loss or interruption of hosting services which are caused by telecommunications or network service providers outside of PSNI’s firewall, a Force Majeure Event, or interruptions or failures caused by Customer or the equipment or facilities utilized by Customer. PSNI does not provide any guarantee of up time of the Service or refunds for any downtime of the Service.
    3. During the Term, PSNI shall provide technical support to Customer for Services and all optional software hosted on PSNI servers. Telephone (toll free in U.S.) and email technical support available Mon through Fri from 7:30 AM - 6:00 PM Eastern Time excluding federal holidays. PSNI’s support may not extend to issues arising from: (i) use of the Services other than in accordance with the guidelines provided by PSNI; (ii) modifications, alterations, or configurations of the Services not performed or authorized by PSNI; (iii) failures or issues of Customer’s equipment, networks, or third-party software or services not supplied by PSNI; (iv) any Third-Party Materials; or (v) factors outside PSNI’s reasonable control. Where practicable, PSNI will use commercially reasonable efforts to assist Customer in diagnosing such excluded issues, and PSNI may offer remediation subject to additional fees as agreed in writing.
21. Third-Party Products. PSNI may display, include, or make available third-party content (including data, information, applications, and other products, services, and/or materials) or provide links to third-party websites or services, including through third-party advertising (“Third-Party Materials”) through the Services. Customer acknowledges and agrees that PSNI is not responsible for Third-Party Materials, including their accuracy, completeness, timeliness, validity, copyright compliance, legality, decency, quality, or any other aspect thereof. PSNI does not provide any warranties or make representations with respect to any Third-Party Materials and does not assume and will not have any liability or responsibility to Customer or any other person or entity for any Third-Party Materials.
22. Monitoring and Reporting. PSNI may, at any time, in its sole discretion, and without notice to or consent from Customer or any Authorized User, (i) monitor and review Customer’s and Authorized Users’ use of the Services, and (ii) report to and cooperate with any law enforcement, governmental, or regulatory authority, including providing information, documents, data, and Customer Data to such authority, if and to the extent PSNI (a) reasonably believes that Customer’s or any Authorized Users’ use of the Services violates any law, or (b) is required to do so by subpoena or other legal process.
23. Force Majeure. Notwithstanding anything to the contrary in this Agreement, PSNI shall have no Liability to Customer, and shall not be in violation of the Agreement, for any failure or delay in performing its obligations if and to the extent any such failure or delay is caused by any circumstance beyond PSNI’s reasonable control, including acts of God, flood, fire, earthquake, explosion, war, terrorism, invasion, riot or other civil unrest, strikes, pandemic or public health crisis, labor stoppages or slowdowns or other industrial disturbances, or passage of law or any action taken by a governmental or public authority, including imposing an embargo. Upon the occurrence of a Force Majeure event, PSNI shall timely notify Customer of the force majeure event, the period of time the occurrence is expected to continue, and its efforts to mitigate the cause and circumstances of such delay or failure with respect to the Services affected thereby. PSNI shall resume the performance of its obligations as soon as reasonably practicable after the removal of the cause.
24. No Agency. PSNI shall perform the Services as an independent contractor and nothing contained herein shall be deemed to create any association, partnership, joint venture or relationship of principal and agent, employer and employee, or master and servant, between the Parties, or to provide either Party with the right, power or authority, whether expressed or implied, to create any such duty or obligation on behalf of the other Party.
25. Waiver. Failure to object or to take affirmative action with respect to any conduct by the other Party which is in violation of the applicable Agreement shall not be construed as a waiver of any future breach or subsequent wrongful conduct. Any waiver of the provisions of the applicable Agreement or of a Party’s rights or remedies under the applicable Agreement must be in writing to be effective.
26. Notice. Notices required hereunder shall be sent to physical and electronic addresses customarily used by the Parties to communicate with one another.
27. Governing Law. The Agreement shall be governed by the laws of the state of New Hampshire, both as to interpretation and performance, regardless of the choice of law rules of that state or any other jurisdiction. The Parties shall be subject to personal jurisdiction in the state of New Hampshire, and the exclusive jurisdiction and venue for any action arising out of or related to the Agreement shall be the state or federal courts of the state of New Hampshire, except as may be necessary to enforce an order of such court.
28. Publicity. Either Party may advertise or publicize the relationship formed hereunder to the extent that such Party deems it beneficial, provided that any detailed description of the engagement or use of a Party’s marks beyond nominal reference shall require the other Party’s prior written consent.
29. Severability. Each term, condition, and provision of the Agreement shall be valid and enforced to the fullest extent permitted by law. If there is any conflict between any term, condition, or provision of the Agreement and any statute, law, ordinance, order, rule, or regulation, the latter shall prevail; provided, that any such conflicting term, condition, or provision shall be curtailed and limited only to the extent necessary to bring it within the legal requirements and the remainder of the Agreement shall not be affected thereby.
30. Successors and Assigns. The Agreement is binding upon and will inure to the benefit of the Parties and their respective permitted successors and assigns. Neither Party may assign or transfer the Agreement, in whole or in part, without the prior written consent of the other Party, except that PSNI may assign the Agreement without consent in connection with a merger, acquisition, corporate reorganization, or sale of all or substantially all of its assets. Any attempted assignment in violation of this section will be null and void.
31. Modifications. The Agreement, including any Invoices may be amended, waived, changed, modified or discharged only by an agreement in writing signed on behalf of all of the Parties.

 Revision 1.0 - March 31, 2026

Exhibit A

Data Processing Agreement

This Data Processing Agreement (“DPA”) is entered into by PSNI, LLC (“PSNI”) and the Customer identified in the applicable Invoice. This DPA governs PSNI’s Processing of Personal Information. Capitalized terms used but not defined in this DPA have the meanings set forth in the Agreement.

1. Definitions.
   1. “Breach” means the following: (i) any Processing of Personal Information that (a) is not authorized by Customer under the Agreement, (b) is not otherwise authorized by Customer expressly and in writing, (c) exceeds the scope of either such authorization, (d) compromises the confidentiality, integrity or availability of Personal Information, (e) is a breach of the DPA, or (f) violates Data Protection Law; (ii) any access to, use of, or activity on or in any PSNI network, system, equipment, device, cloud, or online or offline account that is unauthorized or exceeds to scope of authority and involves Personal Information; provided that (iii) this term does not include (a) a Breach of encrypted Personal Information, as long as the decryption key also has not been compromised, or (b) the unintended or good faith Processing of Personal Information by an employee of PSNI, or the disclosure of Personal Information by an employee of PSNI to another employee of PSNI, as long as the Personal Information is not otherwise further Processed without authorization, beyond the scope of authorization, or in a manner or to an extent that compromises the confidentiality, integrity or availability of the Personal Information or violates Data Protection Law.
   2. “Data Protection Laws” mean all domestic and foreign laws, rules, and regulations that govern (i) a breach or security incident involving Personal Information, (ii) technological, physical, or administrative safeguards for protecting the confidentiality, integrity, or availability of Personal Information, or (iii) Processing of Personal Information, including, to the extent applicable, the Family Educational Rights and Privacy Act (“FERPA”), and the Health Insurance Portability and Accountability Act of 1996 and its implementing regulations (“HIPAA”); provided that (iv) this term encompasses only laws, rules, and regulations that a Party is subject to such and that govern the Personal Information at issue.
   3. “Liability” has the same meaning as set forth in the Agreement. With respect to a Breach of Personal Information, Liability includes the following: (i) computer, technology, and forensic investigation; (ii) attorney fees; (iii) public relations costs; (iv) notification of affected individuals and regulators; (v) credit and identity monitoring and restoration; (vi) call and email support; and (vii) investigation, inquiry, request, subpoena, other legal process, fine, penalty, settlement, judgment, claim, suit, lawsuit, action, cause of action, or other allegation issued or made by an individual, group or class of individuals, regulator, or any other third-party arising out of or related to the Breach.
   4. “Process” and any derivation of that term means any operation or set of operations which is performed upon Personal Information, whether or not by automatic means, such as collection, recording, organization, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restricting, erasure or destruction.
2. Roles. Customer is the data controller of Personal Information under Data Protection Laws. PSNI is a data processor of Personal Information under Data Protection Laws.
3. Term. In the event of termination of the Agreement, the Parties’ obligations under this DPA will continue until PSNI has either returned or permanently destroyed all Confidential Information and Personal Information. Once PSNI has done so, the Parties’ obligations under this DPA terminate.
4. Details of Processing. PSNI may Process Personal Information for the purpose of performing its obligations under the Agreement, and for the duration of the Agreement. Such Processing shall include collecting, accessing, storing, altering, using, transferring and disclosing to a Sub-Processor, and deletion of Personal Information.
5. Confidentiality. PSNI shall maintain Confidential Information and Personal Information as strictly confidential. PSNI shall not disclose or provide access to any third party to any Confidential Information or Personal Information without Customer authorization, except transfers and disclosures of Personal Information to a Sub-Processor permitted by the Agreement. PSNI shall not Process Confidential Information or Personal Information for any purpose other than to provide Services to Customer, and any Processing shall be limited to Processing of Confidential Information or Personal Information only to the extent doing so is necessary to provide the Services, unless Customer expressly authorizes additional Processing of Confidential Information or Personal Information.
6. Security Measures. PSNI shall implement and maintain reasonable physical, technological, and administrative controls designed to safeguard the confidentiality, integrity, and availability of Personal Information in compliance with Data Protection Laws, including FERPA and HIPAA. In addition to the foregoing, PSNI represents that it has conducted an audit of its information security policies, practices and controls based on the criteria set forth in DC 200, 2018 Description Criteria for a Description of a Service Organization’s System in a SOC2® Report (“SOC 2 Type 2”). Upon request, PSNI will provide Customer with a copy of its most recent SOC 2 Type 2 audit report. Throughout the duration of the Term, PSNI shall commission an annual SOC 2 Type 2 audit or undergo an audit of equivalent scope to assess its information security policies, practices and controls, and upon Customer’s request, shall provide a copy of the resulting audit reports or certifications to Customer within 30 days after PSNI’s receipt of the same. PSNI acknowledges that throughout the duration of the Term, PSNI will implement and maintain information security controls that are no less protective than the safeguards enumerated in its current SOC 2 Type 2 audit report.
   1. Data Encryption. All EHR data shall be encrypted at rest and in transit.
7. Obligations Pursuant to Data Protection Laws.
   1. Customer’s Compliance with Data Protection Laws. Customer shall comply with all Data Protection Laws governing Processing of Personal Information by PSNI, including, but not limited to: (i) ensuring all instructions given by it to PSNI in respect of the Processing of Personal Information comply with Data Protection Laws; (ii) providing all notices and obtaining all consents required by Data Protection Laws for PSNI’s Processing of Personal Information under the Agreement; and (iii) addressing all requests made by individuals to assert any right afforded under Data Processing Laws. Company shall be liable to PSNI for Liability arising out of or related to any breach of this provision.
   2. PSNI’s Compliance with Data Protection Laws. PSNI shall comply with all Data Protection Laws governing the Processing of Personal Information. PSNI shall not sell, share, or otherwise disclose Personal Information to any third party (except for transfers or disclosure to a Sub-Processor permitted by the Agreement or this DPA), or Process Personal Information by, for, or on behalf of any third party. PSNI shall Process Personal Information as specified in the Agreement, unless additional processing is authorized expressly and in writing by Customer. When PSNI engages a Sub-processor, PSNI shall contractually obligate such Sub-Processor to comply with terms that are comparable to the terms in this DPA governing PSNI’s Processing of Personal Information. PSNI shall only retain Sub-Processors that are capable of appropriately protecting the privacy, confidentiality and security of Personal Information.
   3. PSNI Employees. PSNI will ensure that employees engaged in the Processing of Confidential Information and Personal Information are informed of the confidential nature of such information, have received appropriate training in their responsibilities concerning such information, and are contractually required to maintain the confidentiality of such information. PSNI shall ensure that such obligations survive the termination of employment. PSNI will ensure that PSNI’s access to Personal Information is limited to those personnel who require such access to perform the Services under the DPA.
   4. Privacy Rights. PSNI shall provide reasonably assistance to Customer with respect to Customer’s compliance with Data Protection Laws.
   5. Data Transfers. If and to the extent PSNI transfers Personal Information outside the country from which it was originally delivered or made available to PSNI, or from which PSNI otherwise accessed or obtained it, PSNI shall comply with applicable privacy laws and implement a data transfer mechanism in accordance with Data Protection Laws to the extent required for such cross-border transfer.
8. Breach Notification. PSNI will notify Customer of a Breach of Personal Information within three business days after PSNI confirms that such Breach occurred. At the time of such initial notification and continuing thereafter, PSNI will disclose to Customer non-privileged information that PSNI has or receives concerning such Breach, including, but not limited to, the following: (i) names and other information available about individuals affected by the breach; (ii) the nature and scope of information compromised or potentially compromised in the breach or as a result of the breach; (iii) timing, manner, and cause of the breach; and (iv) acts taken in response to the breach. PSNI will provide Customer with assistance and cooperation reasonably requested by Customer related to such Breach, and shall follow and comply with reasonable requests made by Customer related to such breach. Unless otherwise required by applicable law, PSNI shall not disclose to any person, other than its attorneys and other agents, information related to such Breach without express written authorization from Customer, including by not notifying any individual affected or potentially affected by the breach, any local, state, or federal government authority or agency, any media outlet, or any other person or entity.
9. Breach Liability. PSNI is liable to Customer for Liability arising out of or related to a Breach of Personal Information within the possession, custody, or control of PSNI that is not caused by an act or omission of Customer, any sub-processor of Customer, or any of their respective employees, agents, representatives, or sub-processors (“PSNI Breach”). Customer is liable to PSNI for Liability arising out of or related to a Breach of Personal Information within the possession, custody, or control of PSNI that is caused by an act or omission of Customer, any sub-processor of Customer (excluding PSNI), or any of their respective employees, agents, representatives, or sub-processors (“Customer Breach”). Customer and PSNI shall each respectively maintain their own commercially reasonable insurance policies that provide coverage for Liability arising out of or related to a Breach. PSNI shall maintain a policy that has an overall limit of at least $4 million. PSNI’s policy shall be primary coverage and Customer’s policy shall be secondary coverage for a PSNI Breach. Customer’s policy shall be the primary coverage and PSNI’s policy shall be secondary coverage for a Customer Breach. If PSNI maintains such an insurance policy, and that insurance policy provides coverage for Liability arising out of or related to a PSNI Breach, then PSNI’s Liability to Customer arising out of or related to a PSNI Breach shall be limited to the coverage provided by that insurance policy. If Customer maintains such an insurance policy, and that insurance policy provides coverage for Liability arising out of or related to a Customer Breach, then Customer’s Liability to PSNI arising out of or related to a Customer Breach shall be limited to the coverage provided by that insurance policy.
10. Audit. Upon Customer’s reasonable request, and subject to the confidentiality obligations in this DPA and the Agreement, PSNI will provide to Customer non-privileged information evidencing PSNI’s compliance with its obligations in this DPA.
11. Return of Information. On the expiration or termination of the Agreement, PSNI shall return to Customer or destroy all Personal Information within sixty (60) days after the expiration or termination of the Agreement; provided that PSNI may retain such Personal Information on backup media as long as such media is periodically erased or overwritten, and such retained Personal Information shall remain subject to the DPA for as long as PSNI retains it.
12. Data Storage. Student Data shall be stored within the continental United States.

 Revision 1.0 - March 31, 2026

Terms of Use

ACCEPTANCE OF TERMS.

The services that PSNI, LLC (PSNI) provides to you are subject to the following Terms of Use ("TOU"). PSNI reserves the right to update the TOU at any time without notice to you. The most current version of the TOU can be reviewed by clicking on the "Terms of Use" hypertext link located at the bottom of our Web pages.

DESCRIPTION OF SERVICES.

PSNI provides you with access to a variety of resources, including communication forums and product information (collectively "Services"). The Services, including any updates, enhancements, new features, and/or the addition of any new Web properties, are subject to the TOU.

PERSONAL AND NON-COMMERCIAL USE LIMITATION.

Unless otherwise specified, the Services are for your personal and non-commercial use. You may not modify, copy, distribute, transmit, display, perform, reproduce, publish, license, create derivative works from, transfer, or sell any information, software, products or services obtained from the Services.

NOTICE SPECIFIC TO RESOURCES AVAILABLE ON THIS WEB SITE.

Any resources that are made available to download from the Services ("Resources") are the copyrighted work of PSNI and/or its suppliers.

The Resources are made available for download solely for use by end users. Any reproduction or redistribution of the Resources is expressly prohibited by law, and may result in severe civil and criminal penalties. Violators will be prosecuted to the maximum extent possible.

WITHOUT LIMITING THE FOREGOING, COPYING OR REPRODUCTION OF THE RESOURCES TO ANY OTHER SERVER OR LOCATION FOR FURTHER REPRODUCTION OR REDISTRIBUTION IS EXPRESSLY PROHIBITED, UNLESS SUCH REPRODUCTION OR REDISTRIBUTION IS EXPRESSLY GRANTED IN WRITING BY PSNI. PSNI HEREBY DISCLAIMS ALL WARRANTIES AND CONDITIONS WITH REGARD TO THE RESOURCES, INCLUDING ALL WARRANTIES AND CONDITIONS OF MERCHANTABILITY, WHETHER EXPRESS, IMPLIED OR STATUTORY, FITNESS FOR A PARTICULAR PURPOSE, TITLE AND NON-INFRINGEMENT. FOR YOUR CONVENIENCE, PSNI MAY MAKE AVAILABLE TOOLS AND UTILITIES FOR USE AND/OR DOWNLOAD. PSNI DOES NOT MAKE ANY ASSURANCES WITH REGARD TO THE ACCURACY OF THE RESULTS OR OUTPUT THAT DERIVES FROM SUCH USE OF ANY SUCH TOOLS AND UTILITIES.

NOTICE SPECIFIC TO DOCUMENTS AVAILABLE ON THIS WEB SITE.

Permission to use Documents (such as white papers, press releases, datasheets and FAQs) is granted, provided that (1) the below copyright notice appears in all copies and that both the copyright notice and this permission notice appear, (2) use of such Documents is for informational and non-commercial or personal use only and will not be copied or posted on any network computer or broadcast in any media, and (3) no modifications of any Documents are made. Use for any other purpose is expressly prohibited by law, and may result in severe civil and criminal penalties. Violators will be prosecuted to the maximum extent possible.

PSNI AND/OR ITS RESPECTIVE SUPPLIERS MAKE NO REPRESENTATIONS ABOUT THE SUITABILITY OF THE INFORMATION CONTAINED IN THE DOCUMENTS AND RELATED GRAPHICS FOR ANY PURPOSE. ALL SUCH DOCUMENTS AND RELATED GRAPHICS ARE PROVIDED "AS IS" WITHOUT WARRANTY OF ANY KIND. PSNI AND/OR ITS RESPECTIVE SUPPLIERS HEREBY DISCLAIM ALL WARRANTIES AND CONDITIONS WITH REGARD TO THIS INFORMATION, INCLUDING ALL WARRANTIES AND CONDITIONS OF MERCHANTABILITY, WHETHER EXPRESS, IMPLIED OR STATUTORY, FITNESS FOR A PARTICULAR PURPOSE, TITLE AND NON-INFRINGEMENT. IN NO EVENT SHALL PSNI AND/OR ITS RESPECTIVE SUPPLIERS BE LIABLE FOR ANY SPECIAL, INDIRECT OR CONSEQUENTIAL DAMAGES OR ANY DAMAGES WHATSOEVER RESULTING FROM LOSS OF USE, DATA OR PROFITS, WHETHER IN AN ACTION OF CONTRACT, NEGLIGENCE OR OTHER TORTIOUS ACTION, ARISING OUT OF OR IN CONNECTION WITH THE USE OR PERFORMANCE OF INFORMATION AVAILABLE FROM THE SERVICES.

THE DOCUMENTS AND RELATED GRAPHICS COULD INCLUDE TECHNICAL INACCURACIES OR TYPOGRAPHICAL ERRORS. CHANGES ARE PERIODICALLY ADDED TO THE INFORMATION HEREIN. PSNI AND/OR ITS RESPECTIVE SUPPLIERS MAY MAKE IMPROVEMENTS AND/OR CHANGES IN THE PRODUCT(S) AND/OR THE PROGRAM(S) DESCRIBED HEREIN AT ANY TIME.

MEMBER ACCOUNT, PASSWORD, AND SECURITY.

If any portion of this site requires you to open an account, you must complete the registration process by providing us with current, complete and accurate information as prompted by the applicable registration form. You also will choose a password and a user name. You are entirely responsible for maintaining the confidentiality of your password and account. Furthermore, you are entirely responsible for any and all activities that occur under your account. You agree to notify PSNI immediately of any unauthorized use of your account or any other breach of security. PSNI will not be liable for any loss that you may incur as a result of someone else using your password or account, either with or without your knowledge. However, you could be held liable for losses incurred by PSNI or another party due to someone else using your account or password. You may not use anyone else's account at any time, without the permission of the account holder.

NO UNLAWFUL OR PROHIBITED USE.

As a condition of your use of the Services, you will not use the Services for any purpose that is unlawful or prohibited by these terms, conditions, and notices. You may not use the Services in any manner that could damage, disable, overburden, or impair any PSNI server, or the network(s) connected to any PSNI server, or interfere with any other party's use and enjoyment of any Services. You may not attempt to gain unauthorized access to any Services, other accounts, computer systems or networks connected to any PSNI server or to any of the Services, through hacking, password mining or any other means. You may not obtain or attempt to obtain any materials or information through any means not intentionally made available through the Services.

PSNI reserves the right at all times to disclose any information as PSNI deems necessary to satisfy any applicable law, regulation, legal process or governmental request, or to edit, refuse to post or to remove any information or materials, in whole or in part, in PSNI's sole discretion.

Always use caution when giving out any personally identifiable information about yourself or your children in any Communication Services. PSNI does not control or endorse the content, messages or information found in any Communication Services and, therefore, PSNI specifically disclaims any liability with regard to the Communication Services and any actions resulting from your participation in any Communication Services. Managers and hosts are not authorized PSNI spokespersons, and their views do not necessarily reflect those of PSNI.

LINKS TO THIRD PARTY SITES.

THE LINKS IN THIS AREA WILL LET YOU LEAVE PSNI'S SITE. THE LINKED SITES ARE NOT UNDER THE CONTROL OF PSNI AND PSNI IS NOT RESPONSIBLE FOR THE CONTENTS OF ANY LINKED SITE OR ANY LINK CONTAINED IN A LINKED SITE, OR ANY CHANGES OR UPDATES TO SUCH SITES. PSNI IS NOT RESPONSIBLE FOR WEBCASTING OR ANY OTHER FORM OF TRANSMISSION RECEIVED FROM ANY LINKED SITE. PSNI IS PROVIDING THESE LINKS TO YOU ONLY AS A CONVENIENCE, AND THE INCLUSION OF ANY LINK DOES NOT IMPLY ENDORSEMENT BY PSNI OF THE SITE.

COPYRIGHT NOTICE.

Copyright © 2025 PSNI, LLC -  All rights reserved.

Privacy

Last Updated: May 1, 2025

Our Commitment to Privacy

PSNI, LLC (PSNI) respects your privacy and we have developed the following policy to demonstrate our commitment to you. This privacy policy applies to personally identifiable information we collect about you on the PSNI website located at www.psnihealth.com (the “Site”) and describes the types of information collected, how that information is used, and the choices users have about collection and use of this information.

Information We Collect

Although much of the Site is available without registration or providing personal information, in order to take advantage of some of the Site’s features, you may be asked to provide personal information. This personal information is provided voluntarily by you, the user, in order to participate or register for a particular product or service, or when you otherwise communicate with us or the Site. Personal information will be collected at various pages on the Site, including when you:

• Submit an online inquiry
• Sign up for e-mail alerts, newsletters and other PSNI information
• Submit an employment application

We clearly identify data you must provide so we can deliver the services or information you request. PSNI may ask that you provide personal information, such as your first and last name, mailing address (including ZIP/Postal code), country of residence, e-mail address, employer, job title and department, telephone numbers and other personal information. Providing this information is optional, but failure to do so in some cases could limit the services available to you.

In addition, our Web servers automatically collect and log Web usage data from you when you visit the Site. This information, including your Internet Protocol (IP) address, referring sites, pages viewed, browser type, operating system, CPU speed, referring or exit Web pages, and length of visit, informs us about how visitors use and navigate the Site.

How We Use and Share the Information Collected

PSNI does not share your personally identifiable information to unaffiliated third parties, but we may use your information to, among other things:

• Provide newsletters and information about PSNI
• Provide the information or service requested or otherwise respond to your inquiries
• Improve the content, navigation and efficiency of the Site
• Make you aware of other benefits, products, services or events offered by PSNI that may interest you
• Enforce the PSNI Terms of Use and otherwise prevent illegal or improper activity related to the Site
• Notify you of changes to this Privacy Policy or to other policies that may affect you and your use of the Site

We may disclose your information to third parties (1) in connection with a merger, sale or consolidation of all or substantially all our assets, or (2) to comply with valid legal process such as a search warrant, subpoena or court order. By using this Site, you agree and acknowledge that personal information collected through the Site may be transferred across national boundaries and stored and processed in any of the countries around the world in which PSNI maintains offices, including the United States.

We may use and share with others aggregated or anonymous (not personally identifiable) information that we have collected based on Web usage data, surveys or statistical information that we have compiled about our users.

Cookies

Like most websites, we employ "cookies," "Web beacons," and similar devices to help you more efficiently use the Site and to track your activities. A cookie is small amount of data that is transferred to your browser by a Web server and can only be read by the server that gave it to you. It functions as your identification card and enables PSNI to record your activities and preferences. It cannot be executed as code or deliver viruses. Cookies from PSNI can only be read by PSNI websites. A Web beacon is a small transparent gif image that is embedded in an HTML page or e-mail used to track when the page or e-mail has been viewed. PSNI uses cookies and similar devices to track your use of the Site, types of Products and Services viewed and information downloaded, count visitors we receive daily, and our Web servers automatically log the IP/Internet address of your computer. PSNI does not generally use this information to identify you personally. If you do not want your browser to accept cookies, you can modify the cookie option in your browser’s settings. However, some Site features or services may not function properly or be accessible without cookies.

Children

The Site is not directed towards children under 13 years of age, nor do we knowingly collect information from children under the age of 13.

Links

Our Site may contain links to other sites. Links do not imply endorsement by PSNI. Please be aware that these other sites are not subject to the PSNI privacy policy and we are not responsible for the privacy practices of such other sites. We recommend that you review the privacy policies of those sites when you visit them.

Reviewing and Correcting Your Information

We try to keep information about you accurate and current. Personal information submitted through this Site is not accessible online, including resumes submitted. To update or correct such information and privacy preferences, you may write PSNI at the address below. In your correspondence, please indicate with as much detail as possible the location on this Site or otherwise where you provided your personal information.

Changes to this Privacy Policy

We will occasionally update this privacy policy. When we do, we will also revise the "last updated" date at the top of the privacy policy. Please check the Site from time to time for the most current version of our privacy policy. Your continued use of the Site after we have notified you of changes as described above constitutes your acceptance of the changes.

How to Contact Us

If you have any questions or concerns about our privacy policy, please contact us by:

E-mail   This email address is being protected from spambots. You need JavaScript enabled to view it.

Mail  PSNI, LLC, 4 Limbo Lane, Hollis, NH 03031, USA

Privacy Policy

PSNI, LLC “PSNI” processes information that identifies individuals or is identifiable to individuals, which is referred to as “Personal Information.” PSNI intends this Policy to comply with the various laws, rules, and regulations in the United States and other local, state, federal, and foreign laws, rules, and regulations that govern PSNI’s Processing of Personal Information (collectively, “Data Privacy Laws”); provided that such Data Privacy Law apply only if and to the extent PSNI is subject to them and they govern Personal Information Processed by PSNI. This Policy does not apply to PSNI’s processing of Personal Information for employment, or to the processing of Personal Information that is otherwise excluded from Data Privacy Laws.

This Policy informs individuals about how PSNI Processes Personal Information and how you can submit privacy rights requests to us concerning Personal Information. If you have any questions or concerns about this Policy or about PSNI’s Processing of Personal Information, please contact our Data Privacy Officer as follows:

Data Privacy Officer
4 Limbo Ln. Amherst NH 03031
603-318-0253
This email address is being protected from spambots. You need JavaScript enabled to view it.

Personal Information

PSNI provides a cloud-based student health software platform, including its SNAP Health Center electronic health record system, which provides K–12 school health clinics with tools to manage student health records, streamline clinical workflows, facilitate communication, and perform health data reporting and analysis, together with any related hosting, support, maintenance, updates, and associated services provided by PSNI, which are referred to as “Services.”

In the course of providing the Services and conducting Operations (as defined below), PSNI interacts with a broad range of individuals, including: (1) prospective, current, and former students of PSNI’s school clients; (2) family members and other individuals associated with such students; (3) members of PSNI’s school clients’ communities, including their employees; (4) owners, shareholders, members, managers, directors, officers, employees, associates, contractors, customers, vendors, service providers, agents, representatives, insurers, attorneys, and affiliates of PSNI’s clients; (5) individuals who attend PSNI events, use the PSNI website or other PSNI technology systems, receive communications from PSNI, or otherwise interact with PSNI personnel; and (6) PSNI’s vendors, service providers, contractors, agents, and representatives. All such individuals are referred to collectively as “Individuals.”

Due to the broad range of our Services and Operations, PSNI processes a broad range of Personal Information. While it would be imprudent to attempt to list every type of Personal Information we process, the following lists some common categories, including Personal Information that we have processed in the preceding 12 months.

• Contact Information. Name, physical and mailing address, telephone number, email address, emergency contact details, and related identifiers.
• Family and Social Information. Details about family relationships, dynamics, guardianship, and other legal matters and other social and community matters.
• Therapeutic and Health Information. Information relating to physical, mental, or emotional health, counseling records, and special education or therapeutic support services.
• Demographic Information. Race, ethnicity, gender, age, disability status, and dietary preferences, when voluntarily provided or required for compliance or support purposes.
• Technological Information. Internet Protocol or IP address, Media Access Control or MAC address, browsing activity, use of PSNI’s website and technology systems, and other technological information.
• Security Information. Information relating to access to and use of PSNI’s physical facilities and technology systems, and other security information.
• Billing Information. Information about the Services, the fees we charge for those Services, our invoicing for Services, and other billing information.
• Operations Information. Information that PSNI processes to conduct our own operations, including administration, accounting, finance, marketing, technology, cybersecurity, privacy, management of vendors and services providers, human resources, records management, facilities management, and other types of operations, which are referred to as “Operations.”

If you provide Personal Information to PSNI about any Individual other than yourself, we ask and expect that you have the authority to do so or consent to do so from that Individual.

Sensitive Personal Information

In addition to Processing the types of Personal Information listed above, PSNI necessarily Processes a wide variety of Personal Information about Individuals that is of a sensitive nature (“Sensitive Personal Information”), which includes, but is not necessarily limited to, the following: (1) Individuals who are children; (2) date of birth; (3) race, ethnic origin, national origin, and sexual orientation and identity; (4) health information; (5) biometric information; and (6) geolocation information. For purposes of this Policy, Sensitive Personal Information is considered to be a special category of Personal Information.

Depending on how Individuals interact with us, we may collect Personal Information when you: (1) request demos, free website reports, or consultations using our web forms; (2) when you register for an event or participate in an event; (3) when you engage with our support team; (4) when you participate in any of our surveys; (5) send communications to us or contact us with questions or concerns; or (6) otherwise interact with us.  

Legal Bases for Processing of Personal Information

Due to the broad range of our Services and Operations, PSNI may process Personal Information for a broad range of purposes and bases. While it would be imprudent to attempt to list every such purpose or basis, the following lists some of the more common purposes and bases for which we process Personal Information.

• Consent and Direction. Based on consent and direction given to us by Individuals, and third parties about whom the Personal Information pertains or who otherwise have authority or consent to provide such consent or direction.
• Provide Services. Activities related to providing Services to or for Individuals, and improving the Services that we offer and provide.
• Business Relationships. Interact with Individuals, and third parties with respect to PSNI’s or their business activities and interests.
• Compliance, safety, claims, and website. To comply with applicable laws and regulations, including Data Privacy Laws; to ensure safety and protect PSNI, our personnel, Individuals, third parties, and PSNI’s physical facilities and technology systems; to establish, enforce, and exercise our rights and defend against claims; protect an interest that is essential for the life or physical safety of the Individual or another person; detect, respond to, prevent or protect against illegal or unlawful activity, fraud, harassment, malicious or deceptive activities, identity theft, or other any other security incident; create, evaluate, develop, improve, enhance, and otherwise manage the Services; and engage in other educational, academic, non-academic, curricular, extra-curricular, business, operational, financial, technological, and other activities that are or should be reasonably aligned with the expectations of Individuals, reasonably anticipated based on your relationship with PSNI, or otherwise compatible with the Processing of Personal Information in furtherance of providing the Services; and to monitor, develop and maintain the operation, security and integrity of our website and technology systems.
• Operations. Activities related to PSNI’s Operations, including business, operational, financial, technological, and other activities that are or should be reasonably aligned with the expectations of Individuals, reasonably anticipated based on your relationship with PSNI, or otherwise compatible with the Processing of Personal Information and Sensitive Personal Information in furtherance of providing the Services.

Disclosure of Personal Information

PSNI may disclose Personal Information under the following circumstances.

• Consent and Direction. Based on consent and direction given to us by Individuals and third parties about whom the Personal Information pertains or who otherwise have authority or consent to provide such consent or direction.
• Provide Services. As necessary or appropriate to provide Services.
• Agents of Individuals and PSNI. To owners, shareholders, members, managers, directors, officers, employees, associates, contractors, customers, vendors, service providers, agents, representatives, insurers, and attorneys of PSNI or Individuals as necessary or appropriate to provide Services or support our Operations.
• Compliance, safety, claims and legal process. To comply with applicable laws and regulations, including Data Privacy Laws; to ensure safety and protect PSNI, our personnel, Individuals, third parties, and PSNI’s physical facilities and technology systems; to establish, enforce, and exercise our rights and defend against claims; to child safety and public health agencies, authorities, and officials and to comply with a valid subpoena or other legal process or lawful request by governmental, regulatory, and law enforcement authorities.
• Business Transfers. In anticipation of or the course of an acquisition, merger, consolidation, restructuring, sale of ownership interests, assets or both, or other such corporate change.

Marketing and TCPA Compliance

From time to time, PSNI may disclose some of your Personal Information to our service providers and/or subcontractors to assist us in our marketing activities. Our service providers and/or subcontractors do not have any right to use the Personal Information we share with them beyond what is necessary to assist us in providing Services to you. If and to the extent we send you any marketing communications via text messages, we do so in compliance with the Telephone Consumer Protection Act (TCPA) and based on your prior express consent (if and to the extent required by TCPA). You may revoke this consent at any time by opting-out of receiving any marketing-related communication via text messages by completing and submitting the Privacy Rights Request Form on our website. You can also change your preferences for receiving our marketing communications from us at any time by following the instructions to unsubscribe specified in our marketing emails. PSNI does not send marketing-related text-messages to any telephone number registered with the National Do Not Call Registry (Registry). For additional information on the Registry, or to register your telephone number(s) with the Registry, please see Federal Trade Commission’s National Do Not Call Registry webpage. Please note that not all of our communications sent via text messages or email are for marketing purposes, and you may continue to receive service messages for our Services (like bills, transactional notices, customer service, etc.) despite you opting-out of receiving marketing-relating communications from PSNI. 

Privacy Rights

Depending on the Personal Information PSNI processes about an Individual, and the manner in which we process such Personal Information, an Individual may have the following rights with respect to our processing of Personal Information about that Individual.

• Scope of Processing. Disclosure about how we process Personal Information, the categories of Personal Information we process, and the categories of sources from which such Personal Information was obtained.
• Access. Access or receipt of a copy of Personal Information, including (if appropriate) in a portable, machine-readable, and commonly used format.
• Correction. Rectify or correct inaccurate or incomplete Personal Information.
• Deletion. Deletion or erasure of Personal Information.
• Withdraw Consent. Withdraw consent if we rely on consent as a basis for processing Personal Information, provided that such withdrawal will not affect the lawfulness of our processing of Personal Information before such withdrawal or the continued processing of it after withdrawal for a purpose or basis other than consent.
• Selling, Profiling, and Targeted Advertising. Disclosure about whether PSNI sells, shares, trades, exchanges, or brokers Personal Information with or to a third party for the purpose of that or any other third party using the Personal Information to market on their own behalf, which is referred to as “Selling”; disclosure about whether PSNI uses automated decision making to evaluate, analyze or predict personal aspects related to an Individual’s economic situation, health, personal preferences, interests, reliability, behavior, location, or movements, which is referred to as “Profiling.”; disclosure about whether PSNI targets advertising to individuals based on their activities on unaffiliated third party websites, which is referred to as “Targeted Advertising”; and to object or opt-out of such Selling, Profiling and Targeted Advertising.

To make a request concerning these rights, please complete and submit the Privacy Rights Request Form on our website. PSNI will respond to all complete requests within 45 days, subject to extension of that period. Also, there may be a delay in processing a request while we verify that the request is valid and originates from a person authorized to make it.

There may be valid reasons that require or permit us to decline to honor a request, in whole or in part, including legal and regulatory requirements that we retain and process certain information. Also, honoring certain requests may limit or prevent us from providing Services to the Individual about whom the request is made. In those situations, we will notify you in writing within 45 days, subject to extension of that period. You may also contact one of our Privacy Officers for information about and help with those situations.

PSNI will not discriminate against an Individual for exercising these rights or any other rights under Data Privacy Laws, including by not denying Services to that Individual, not providing a different level or quality of Services to that Individual, and not suggesting that Individual will receive a different level or quality of Services.

Selling, Profiling, and Targeted Advertising

PSNI does not engage in Selling, Profiling, or Targeted Advertising, except with respect to tracking technologies as discussed below.

Use of Artificial Intelligence

PSNI uses artificial intelligence or AI to process Personal Information and for other purposes, including for the purposes and bases described above and with respect to our Services. While it would be imprudent to attempt to list every such use of AI, particularly since it is an evolving technology, the following lists some ways that PSNI uses AI to process Personal Information and for other purposes: organize, summarize, analyze, recognize patterns, and identify specific aspects of information; create records, documents, text, images, communications, and similar content generated by AI based on information and prompts input into AI; conduct research; use notetakers and transcribers for meetings, video conferences, and PSNI events; and perform other discrete aspects of our Services.

Video and Audio Recording

PSNI uses technology to facilitate meetings, video conferences, and other PSNI events, including technology that captures video, images, and audio, such as recording devices and AI notetakers and transcribers. By participating in PSNI meetings, video conferences, and events, you consent to PSNI’s recording and processing of video, images, and audio collected during such meetings, video conferences, and events.

Website, Cookies, Tracking Technology, and Third Party Tools

PSNI may collect and generate information about you when you interact with our website, which may include name and contact information (as described above), information about the device you use to interact with our website, and information about your interaction with our website (such as content you view, features you access, sites you view immediately before and after you access our website, content you view on our website, search terms you use on our website, and content in which you have indicated interest).

When you visit PSNI’s website, we may place a cookie (a text file containing a randomly assigned number) or a similar technology on your device so we have the ability to customize the look and feel of the website for you. Cookies remember information about you, your preferences, and your device for a better user experience when visiting the website. Using cookies, we may also collect other information about your use of the website, including your IP address, username, session identification, browser, web pages you view and referring web pages, when you access the website, and general online behavior for performance and marketing purposes.

PSNI may use third-party analytics tracking technologies and tools to collect information about how you use our website, such as the frequency of visits, pages viewed, traffic data, location, referring and exit pages, and error information. These tools may also collect device-specific data, including your IP address, operating system, browser type, and Internet connection details. These tools examine website activities to prepare usage reports, and this information helps us improve our website and enhance user experience. Tracking information will be shared with the third-party analytics provider, which may use that information for its own purposes, potentially including marketing or advertising. While the tracking information we collect through such tools is not sufficient on its own for PSNI to identify you, the third-party analytics provider may be able to combine it with other data it has to identify you.

If you would like to limit the ability of cookies or tracking technologies and tools to track your activity on our website, you can either configure your preferences for cookie settings on our website, or disable cookies in your Internet browser settings, although doing so may impact the performance and effectiveness of our website or other websites.

PSNI may use third party tools to provide Services and for other purposes, and our website may contain links to third party websites. We have no control over the policies and practices of such third-party tools and websites. Please review the applicable policies of such third parties for information regarding their processing of Personal Information.

Duration of Retention

Because the Services that PSNI provides vary significantly, the duration we retain Personal Information varies significantly, depending on the types of Services that PSNI provides to Individuals, the duration and depth of PSNI’s relationship with the particular Individual, and the nature of Personal Information in question. PSNI endeavors to retain Personal Information that it receives from or collects for only as long as is necessary or appropriate to achieve the purposes for which such information was collected, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements).

Automated Decision Making

PSNI does not use automated decision making or profiling in the Processing of Personal Information, and does not make decisions that affect you based on automated decision making or profiling using Personal Information.

Changes to Policy

PSNI reserves the right to change or amend this Policy at any time and for any reasons, including to remain in compliance with Data Privacy Laws.

Questions or Concerns

If you have any questions or concerns about this Policy or about PSNI’s Processing of Personal Information, please contact our Data Privacy Officer.

Last Updated: 3/5/2026