1. Personal information we use

You can generally visit our Website without actively revealing any personal information about yourself. However, in certain areas of this Website or on the User Portal, we may ask you to contact us with questions or comments, or request more information about our products/services. We may also receive information about you when you submit job application forms or order forms or contact us through other channels. In these cases, we will collect personal information from you directly as described below.

We may be required by law to collect certain personal information about you, or as a consequence of any contractual relationship we have with you. Failure to provide this information may prevent or delay the fulfilment of these obligations. We will inform you at the time your information is collected whether certain data is compulsory and the consequences of the failure to provide such data.

The categories of information that we collect from you are:

• Personal details (e.g. name, date of birth, employer or organization)
• Contact details (e.g. phone number, email address, postal address or mobile number)
• Additional information about your organization and the transaction (e.g. invoice and billing information, transaction history, etc.)
• Employment and experience information for job applicants (e.g. employment history, job role, salary, professional or academic references, educational background and any professional licences and qualifications)
• Correspondence you had with us and other information you have given us
• Information we collect automatically from you including data collected using cookies and other device identifying technologies (‘Cookies and Tracking Technologies’) Further information about our use of Cookies and Tracking Technologies is available in our Cookies Policy available above.

Occasionally we may collect your personal information from a third party, in particular from authorized, regulatory, public sources such as government regulators, industry self-governing bodies and other publicly available records. This will be most common when we are complying with our legal obligations regarding sanctions, money laundering and other financial crimes. If appropriate, in these circumstances we will either notify you of our sources or seek your consent to their use.

2. How we use your personal information and the basis on which we use it

We use your personal information to:

• Provide and personalize our services
• Respond to your enquiries and requests
• Manage the recruitment process including assessing your suitability for the position you have applied for and to communicate with you in relation to your application and the recruitment process
• Comply with legal obligations to which we are subject and cooperate with regulators and law enforcement bodies
• To exercise, defend and protect our legal rights or the rights of third parties
• Contact you with marketing and offers relating to products and services offered by us (unless you have opted out of marketing, or we are otherwise prevented by law from doing so)
• Personalize the marketing messages we send you to make them more relevant and interesting

We must have a legal basis to process your personal information. In most cases the legal basis will be one of the following:

• To fulfill our contractual obligations to you, for example to provide the services, to ensure that invoices are paid correctly, and to ensure you are able to access our premises when required. Failure to provide this information may prevent or delay the fulfillment of these contractual obligations
• To complete necessary pre-contractual checks to ensure that we can provide you the services you request or assess your suitability for employment with us
• To comply with our legal obligations, for example obtaining proof of your identity to enable us to meet our anti-money laundering obligations and respond to binding requests from regulators, law enforcement authorities or other government authorities
• To meet our legitimate interests, for example to understand how you use our services, to enable us to derive knowledge from that enable us to develop new services and run our business and manage our human resources in an effective and efficient way. When we process personal information to meet our legitimate interests, we put in place robust safeguards to ensure that your privacy is protected and to ensure that our legitimate interests are not overridden by your interests or fundamental rights and freedoms. For more information about the balancing test that is carried out when we rely on legitimate interests, please contact us at the details below
• To exercise our legal rights where it is necessary to do so, for example to detect, prevent and respond to fraud claims, intellectual property infringement claims or violations of law.

We may obtain your consent to collect and use certain types of personal information when we are required to do so by law (for example, in relation to our direct marketing activities, Cookies and Tracking Technologies). If we ask for your consent to process your personal information, you may withdraw your consent at any time by contacting us using the details at the end of this privacy notice.

3. Your rights over your personal information

You have certain rights regarding your personal information, subject to local law. These include the following rights to:

• Access your personal information
• Rectify the information we hold about you
• Erase your personal information
• Restrict our use of your personal information
• Object to our use of your personal information
• Receive your personal information in a usable electronic format and transmit it to a third party (right to data portability)
• Lodge a complaint with your local data protection authority.

If you would like to discuss or exercise such rights, please contact us at the details below. We will contact you if we need additional information from you in order to honor your requests.

We encourage you to contact us to update or correct your information if it changes or if the personal information we hold about you is inaccurate.

4. Information Sharing

We may share your personal information with third parties under the following circumstances:

• Service providers and business partners. We may share your personal information with our service providers and business partners that perform marketing services and other business operations for us. For example, we may partner with other companies to process secure payments, fulfill orders, optimize our services, send newsletters and marketing emails, support email and messaging services and analyze information.
• Law enforcement agency, court, regulator, government authority or other third party. We may share your personal information with these parties where we believe this is necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights or the rights of any third party.
• Asset purchasers. We may share your personal information with any third party that purchases, or to which we transfer, all or substantially all of our assets and business. Should such a sale or transfer occur, we will use reasonable efforts to try to ensure that the entity to which we transfer your personal information uses it in a manner that is consistent with this privacy notice.

Because we operate as part of a global business, the recipients referred to above may be located outside the jurisdiction in which you are located (or in which we provide the services). See the section on “International Data Transfers” below for more information.

5. Information Security and Storage

We implement technical and organizational measures to ensure a level of security appropriate to the risk to the personal information we process. These measures are aimed at ensuring the on-going integrity and confidentiality of personal information. We evaluate these measures on a regular basis to ensure the security of the processing.

We will keep your personal information for as long as we have a relationship with you. Once our relationship with you has come to an end, we will retain your personal information for a period of time that enables us to:

• Maintain business records for analysis and/or audit purposes
• Comply with record retention requirements under the law
• Defend or bring any existing or potential legal claims
• Deal with any complaints regarding the services

We will delete your personal information when it is no longer required for these purposes. If there is any information that we are unable, for technical reasons, to delete entirely from our systems, we will put in place appropriate measures to prevent any further processing or use of the data.

6. International Data Transfers

Your personal information may be transferred to, stored, and processed in a country that is not regarded as ensuring an adequate level of protection for personal information under European Union law or by the European Commission. We have put in place appropriate safeguards (such as contractual commitments) in accordance with applicable legal requirements to ensure that your data is adequately protected. For more information on the appropriate safeguards in place, please contact us at the details below.

7. Contact Us

Ursa Space Systems Inc. is the controller responsible for the personal information we collect and process.

If you have questions or concerns regarding the way in which your personal information has been used, please contact privacy@ursaspace.com.

Our Data Protection Officer can be contacted at: privacy@ursaspace.com.

We are committed to working with you to obtain a fair resolution of any complaint or concern about privacy. If, however, you believe that we have not been able to assist with your complaint or concern, you have the right to make a complaint to the data protection authority of your country of residence.

8. Changes to the Policy

You may request a copy of this privacy notice from us using the contact details set out above. We may modify or update this privacy notice from time to time.

If we change this privacy notice, we will notify you of the changes. Where changes to this privacy notice will have a fundamental impact on the nature of the processing or otherwise have a substantial impact on you, we will give you sufficient advance notice so that you have the opportunity to exercise your rights (e.g. to object to the processing).