Cityon Systems, Inc.  (“Cityon”) respects individual privacy and values the confidence of its clients, employees, vendors, business partners and others. Cityon strives to access, use and disclose Personal Information (as defined below) in a manner consistent with the laws of the countries in which it does business, and has a tradition of upholding the highest ethical standards in its business practices. Cityon complies with the Privacy Laws, including the California Consumer Privacy Act (CCPA), the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks and EU General Data Protection Regulation (GDPR) regulations ,regarding the collection, use, and retention of personal information, that it may receive related to providing services and catering to Cityon’s Clients’ order processing and fulfillment needs. Cityon certifies that it adheres to the Privacy Laws including the California Consumer Privacy Act (CCPA), the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks and EU General Data Protection Regulation (GDPR) principles of notice, choice, onward transfer, security, data integrity, access, and enforcement.

Cityon is a leading provider of Enterprise AI SaaS platforms, driving digital transformation in the supply chain industry. We develop innovative, proprietary AI algorithms and machine learning frameworks. With over 10 years of experience in supply chain and building AI-powered platforms, we solve complex business challenges. Drawing on deep industry expertise and a portfolio of proven business processes, applications and infrastructure services, we blend strategic design, technology and timely delivery, to create effective solutions that maximize our client’s returns on their IT investment.

Cityon provides SaaS cloud base platform and software integrations solutions. Through its software development and integration services, Cityon offers software products and software solutions to its clients to collect, process, store and manage their business processes and transactions. Cityon Clients may or may not use these products to collect personal data from individuals located in the US, UK, the EU, the EEA or Switzerland, directly or through distributers. In providing our services, we sometimes get access to our Client’s data, which may/may not contain the personal information from individuals who have used their services.  We do not use any personal information, for the purposes, other than providing Cityon software services to Cityon clients. Cityon will handle all personal information collected and received in connection with delivering its services,  as pledged and outlined in this Privacy Policy . Cityon pledges to conduct its business according to the Privacy Laws, including the California Consumer Privacy Act (CCPA), the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks and EU General Data Protection Regulation (GDPR) and has adopted the following Privacy Policy applicable to personal information that it may receive related to the processing of Cityon Clients business process transactions. The Privacy Policy is publicly available and can be found on Cityon’s website at: https://Cityon.com/privacy-policy/

Cityon knows that you care how information about you is used and shared, and we appreciate your trust that we will do so carefully and sensibly. Cityon is committed to the security, availability, confidentiality, and processing integrity of all information collected. This notice describes our Privacy Policy and is applicable to Cityon’s all online products, applications and websites. By visiting the Cityon Web site, you are accepting the practices described in this Privacy Policy.

Cityon does not collect any personal information about individuals. The information Cityon gets from customers is used to deliver our services, personalize, and continually improve the online experience of Cityon customers. All information is gathered and stored in the US. Cityon Application only collects, stores, processes, and manages business data related to its client’s  business process transactions.

Information about our customers is an important part of our business. We do not share customer information with anyone outside of Cityon , without asking for permission from our customers. We do not sell, rent or trade personal information with third parties for commercial purposes.

Cityon is committed to the security, availability, confidentiality, and processing integrity of all information collected, regardless of location.  Cityon has extensive security and privacy policies and procedures which serve as a strong foundation to address the key components within  Privacy Laws, including the CCPA Privacy Laws, the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks and EU General Data Protection Regulation (GDPR) regulations.  We use reasonable precautions to protect personal information from unauthorized use, access, disclosure, alteration or destruction. These precautions include appropriate physical, electronic and managerial procedures. Each Cityon client using the web site is provided with a secure method of data transfer from the internet to their organization. We provide a secured transmission method for the electronic transmission of personal data through Secured Socket Layer (SSL) 256 bit encryption, which encrypts information you input, and secures during its transmission over the internet. Be sure to sign off when finished using a shared computer. It is important for you to protect against unauthorized access to your password and to your computer.  Access to data through Web Application is protected by custom defined user-role based access security. All data is stored in secured RDBMS database, protected by Operating System and Database Security. In addition, the sensitive data is encrypted in the database as per the Cityon Client’s requirements.

Cityon maintains an information security and privacy program consistent with industry standards, which includes appropriate administrative, physical, and technical safeguards to

a) maintain and protect against anticipated threats or hazards to the security, privacy, confidentiality, and integrity of data; and

b) protect against any security incident.

Cityon may statistically aggregate in non-person-specific and other information collected for our Client’s internal research purposes. Such aggregated non-person-specific information may be used to enhance, develop or improve software products and services, offered to our clients. When you use Cityon Client’s services, you give your consent to this non-person-specific data aggregation and the use and transmission of this aggregated statistical data as outlined herein

Cityon may disclose personally identifiable information in the following situations:

(a) in response to a subpoena, court order or legal process, to the extent permitted and required by law;

(b)(b) to protect your security or the security of other persons, consistent with applicable law;

(c)(c) in connection with a sale, joint venture or other transfer of some or all of the assets of Cityon.;

(d)(d) to organizations, who are working as our contractors or agents and who are committed or obliged to protect your privacy in a manner consistent with this Privacy Policy. By utilizing Cityon Client’s services, you give your consent for your personal information to be transmitted in the situations outlined above. All Cityon Clients are responsible for complying with national and international protocols covering data use and transfer.

Data will be retained by Cityon

1) for as long as the Controller or Processor is a client of Cityon,

2) until the data is requested to be deleted by the Controller, Processor, or Data Subject, or

3) until the data is no longer necessary to provide the requested services. Anonymized data may be aggregated for our own research purposes

Cityon get access to the data for

• providing SaaS platform and related services

• Providing Client Business Process Transaction Services

Cityon does not link IP addresses to personally identifiable information; however, we reserve the right to link IP addresses and other information supplied by the ISP to personally identifiable information in order to protect the integrity of our system and for security purposes.

Cookies are small text files that a Web site transfers to your computer’s browser. Cookies are used by Web Applications to measure traffic patterns, personalize content and control security. The cookies we use supply non-personally identifiable information, but they may identify your computer, browser and Internet specifications. Cityon does not use any cookie information for any purposes other than providing software services to the Clients.

Cityon will not discriminate against you for exercising any of your Privacy Rights

Cityon reserves the right to change the terms of this Privacy Policy from time to time by posting an updated Privacy Policy. We encourage you to review this Privacy Policy periodically for any changes or updates.

Cityon adheres and is committed to the privacy principles of the General Data Protection Regulation (GDPR) regulation, which comes under EU law on data protection and privacy in the European Union (EU) and the European Economic Area (EEA). Information regarding the General Data Protection Regulation (GDPR) regulation can be found at the website: https://edps.europa.eu/

In regard to GDPR, Cityon is generally considered a Processor or Sub-Processor, although there may be some instances where Cityon may be a Controller. As such, Cityon’s legal basis for processing data will typically rely on the provisions set forth for ‘performance of a contract’  and/or ‘legitimate interest’.

To access and correct any personal information that we have collected under this policy, please contact the organization, where you provided your data, or send us an email at INFO@Cityon.com. To protect your privacy and security, we will take reasonable steps to verify your identity before amending any of your personal information in our databases.

If you have questions or concerns about this Privacy Policy or how we have handled personal data, please contact us at INFO@Cityon.com. If we are unable to satisfactorily address your concerns or if a dispute arises, Cityon will cooperate with the EU Data Protection Authorities to resolve any complaints and disputes arising in connection with its privacy policy. The EU Data Protection Authorities may be reached by emailing at edpb@edpb.europa.eu.  Please contact us with requests for data access, data deletion, or any other questions.  Please contact us as set forth below.

Cityon complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use and retention of personal information from the European Union and the United Kingdom. Cityon is committed to adhere to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability. If there is any conflict between the policies in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/.

Cityon regularly reviews how we’re meeting these privacy promises, and we provide an independent way to resolve complaints about our privacy practices. OAPL is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).

In compliance with the Privacy Shield Principles, Cityon commits to resolve complaints about our collection or use of your personal information. EU individuals with inquiries or complaints regarding our Private Shield policy should first contact Cityon. Cityon commits to refer unresolved privacy complaints under the EU-US Privacy Shield Principles BBB EU Privacy Shield, a non-profit alternative dispute resolution provider located in the United States and operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint. If your complaint is not resolved through these channels, under limited circumstances, a binding arbitration option may be available before a Privacy Shield Panel.

This Privacy Notice for California residents supplements the information contained in our Privacy Policy above and applies solely to individuals who reside in the State of California. If you have any questions about the information provided in this privacy statement or our privacy practices, please contact us as set forth below.

If you have any questions or comments about Cityon’s Privacy Policy, the ways in which Cityon collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights, please do not hesitate to contact us at info@atp.com