PRIVACY POLICY FOR
ICOUNTER

1. INTRODUCTION AND SCOPE

Last Updated: July 2026

iCOUNTER is a cybersecurity threat intelligence company that provides threat information products and services to business customers. This Privacy Policy describes how iCOUNTER collects, uses, and shares personal information through our website at [icounter.com]. This policy applies to visitors to our marketing website. It does not apply to information collected or processed under separate contractual agreements with our customers, which is governed by the terms of those agreements.

This Privacy Policy covers the rights and obligations arising under the California Consumer Privacy Act and California Privacy Rights Act (CCPA/CPRA), the General Data Protection Regulation (EU GDPR), the United Kingdom General Data Protection Regulation (UK GDPR), and emerging U.S. state privacy laws, including the Virginia Consumer Data Protection Act (VCDPA), the Colorado Privacy Act (CPA), and the Connecticut Data Privacy Act (CTDPA). Where this policy refers to the European Economic Area (EEA), which comprises the EU member states plus Iceland, Liechtenstein, and Norway, it includes all such member states and associated countries. Jurisdiction-specific provisions are set forth in the applicable sections below.

iCOUNTER does not collect personal information about individuals who visit our website beyond what is described in this policy, unless we have a separate contractual agreement with them or their organization to do so.
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2. INFORMATION WE COLLECT

iCOUNTER collects personal information in the following ways when you visit our website at [icounter.com].

2.1 Information You Provide Directly. When you complete forms on our website, including contact forms, newsletter signup forms, and resource download forms, we may collect your name, phone number, email address, physical address (when applicable), company name, and job title. We may also collect information you provide through surveys we conduct from time to time.

2.2 Information Collected Automatically. When you visit our website, we automatically collect certain information through analytics tools, advertising technologies, and session recording tools, including: IP addresses; browser type and version; device type and operating system; referring URLs; pages visited and interaction data; cookie data and similar tracking technologies; and session recording data (such as mouse movements, clicks, scrolls, and page navigation patterns).

2.3 Information from Third-Party Sources. iCOUNTER may obtain professional contact information about business professionals from third-party data providers and publicly available professional sources. The categories of information obtained include professional contact details (such as name, business email address, and phone number), job title, company name, and professional background information. This information is processed on the basis of our legitimate interests in maintaining accurate business contact records and marketing our products and services to relevant professionals. Where providing individual notice of this data collection would involve disproportionate effort given the volume of records and the professional, publicly available nature of the information, this Privacy Policy serves as the required notice of such processing, including the categories of data obtained, the sources, and the purposes of processing.

3. HOW WE USE YOUR INFORMATION

iCOUNTER uses the personal information it collects for the following purposes:

1. Responding to inquiries and providing requested information.
2. Sending marketing communications and newsletters (with consent where required by applicable law).
3. Lead management, including lead scoring and account scoring, to prioritize outreach to prospective customers.
4. Content personalization based on professional attributes such as job title, company, and industry.
5. Advertising, including retargeting and audience segmentation, to reach relevant business professionals.
6. Data enrichment to maintain accurate and current business contact records.
7. Website analytics and performance optimization.
8. User experience research and improvement, including through session recording.
9. Network security and fraud prevention.
10. Complying with applicable laws, regulations, legal processes, or enforceable governmental requests, including responding to subpoenas, court orders, regulatory inquiries, and law enforcement requests, and establishing, exercising, or defending legal claims.
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4. COOKIES AND TRACKING TECHNOLOGIES

iCOUNTER uses cookies and similar tracking technologies on our website. These technologies fall into the following categories.

1. Strictly Necessary Cookies: These cookies are required for basic site functionality, security, and consent management. Because they are essential to the operation of the website, they cannot be disabled.
2. Analytics Cookies: These cookies help us understand how visitors interact with our website by collecting usage information, which is typically aggregated. This information allows us to measure and improve website performance.
3. Functional Cookies: These cookies enable enhanced functionality and personalization, such as remembering user preferences.
4. Advertising and Targeting Cookies: These cookies are used to deliver relevant advertisements, measure advertising campaign performance, and build audience profiles for targeted advertising. Advertising and targeting cookies may be placed by our advertising partners.

You can manage your cookie preferences at any time through our cookie preference center, which provides the full current list of cookies and tracking technologies in use on our website. With the exception of strictly necessary cookies, you may accept or reject each category of cookies through the preference center. Your preferences will be stored and applied to subsequent visits.

For information about the specific third-party providers whose technologies are used on our website, please refer to Section 5.

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5. THIRD-PARTY SHARING

iCOUNTER may share personal information with the following categories of third parties.

5.1 Service Providers. iCOUNTER engages service providers that process data on our behalf under data processing agreements: customer relationship management platforms (HubSpot, Salesforce); email marketing and sales engagement platforms (HubSpot, Outreach); website hosting and content management (Webflow); and cookie consent management (Usercentrics).

5.2 Analytics and User Experience Providers. iCOUNTER uses website analytics services (Google Analytics, Google Tag Manager) and session recording and heatmap tools (Hotjar) to understand website usage and improve the user experience.

5.3 Advertising Partners. iCOUNTER shares information (such as hashed email addresses) with LinkedIn for advertising, retargeting, and audience matching. Additional advertising platforms (e.g., Reddit, Meta) may be added and will be reflected in the cookie preference center. This sharing may constitute "sharing" as defined under the CCPA. See Sections 10 and 12 for opt-out rights.

5.4 Data Enrichment Providers. iCOUNTER uses third-party data enrichment services (Clay, Apollo) that supply professional contact information from publicly available sources and proprietary databases.

5.5 Other Third Parties. iCOUNTER may share personal information with: gifting and promotional platforms (SwagPro) for fulfillment; legal and regulatory authorities when required by law; professional advisors; and parties in connection with a merger, acquisition, or sale of assets.

5.6 No Sale of Personal Information. iCOUNTER does not sell your personal information.

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6. DATA RETENTION

iCOUNTER retains personal information only as long as necessary for the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by applicable law. The following retention periods apply:

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Session recording data consists of recordings of how visitors interact with our website, including mouse movements, clicks, scrolling patterns, and page navigation. This data is used to identify usability issues and improve the website experience. Session recordings are configured to suppress capture of text entered into form fields.

When personal information is no longer required for the purposes set out in this Privacy Policy and no legal obligation mandates its retention, iCOUNTER will securely delete or anonymize the information in accordance with applicable law.

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7. SECURITY

iCOUNTER implements technical and organizational measures designed to protect personal information against unauthorized access, alteration, disclosure, or destruction. These measures include:

• Encryption of data in transit;
• Access controls limiting personal information access to authorized personnel on a need-to-know basis;
• Security assessments of third-party vendors and service providers;
• Employee training on data protection and information security practices;
• Regular review and updating of security measures in light of current risks and technology.

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

[Note: Confirm specific security measures with IT before publication.]
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8. INTERNATIONAL DATA TRANSFERS

8.1 Processing Location. iCOUNTER is based in the United States. Personal information collected through our website is primarily processed and stored in the United States. Some of our service providers may process personal information in other countries.

8.2 Transfers from the United Kingdom and the European Economic Area. For individuals located in the United Kingdom or the EEA, personal data may be transferred to the United States or other countries that have not received an adequacy decision from the European Commission or the UK Secretary of State. When such transfers occur, iCOUNTER relies on the following safeguards:

1. EU Standard Contractual Clauses (SCCs) approved by the European Commission, for transfers of personal data from the EEA;
2. The UK International Data Transfer Addendum (UK IDTA) to the EU SCCs, for transfers of personal data from the United Kingdom; and
3. The EU-U.S. Data Privacy Framework, including the UK Extension, where the recipient service provider is certified under the framework.

You may request a copy of the applicable transfer safeguards by contacting us at privacy@icounter.com.

8.3 Other Jurisdictions. For individuals located outside the United Kingdom and the EEA, personal information may be transferred to countries whose data protection laws differ from those in your jurisdiction. iCOUNTER takes reasonable steps to ensure that personal information receives adequate protection in accordance with applicable law.

[Note: Confirm vendor processing locations and ensure DPAs incorporating SCCs and UK IDTA are executed for all vendors listed in Section 5. Verify Data Privacy Framework certification status for applicable vendors at dataprivacyframework.gov.]

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9. YOUR PRIVACY RIGHTS

Regardless of where you reside, you may exercise the following rights with respect to the personal information iCOUNTER holds about you:

1. Right to Know and Access: You may request confirmation of whether iCOUNTER processes your personal information and, if so, obtain a copy of that information.
2. Right to Correct: You may request correction of inaccurate personal information we maintain about you.
3. Right to Delete: You may request deletion of your personal information, subject to applicable legal retention requirements.
4. Right to Opt Out of Marketing: You may opt out of receiving marketing communications at any time by using the unsubscribe mechanism included in each communication or by contacting us directly.
5. Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out prior to withdrawal.
6. Right to Lodge a Complaint: If you are a resident of the United Kingdom or the European Economic Area (EEA), you have the right to lodge a complaint with a supervisory authority. See Section 11.5 for relevant supervisory authority contact information.

To exercise any of these rights, please contact us at privacy@icounter.com. iCOUNTER will respond to your request within the timeframes required by applicable law. Jurisdiction-specific rights and procedures are described in Sections 10, 11, and 12 of this Privacy Policy.

10. CALIFORNIA PRIVACY RIGHTS (CCPA/CPRA)

This section applies to California residents and supplements the rest of this Privacy Policy in accordance with the California Consumer Privacy Act, as amended by the California Privacy Rights Act (collectively, "CCPA").

10.1 Categories of Personal Information Collected. iCOUNTER collects the following categories of personal information, as defined by the CCPA:

• Identifiers (name, email address, phone number, IP address, physical address)
• Professional or employment-related information (job title, company name)
• Internet or other electronic network activity information (browsing history, pages visited, interaction data, session recording data)
• Geolocation data (approximate location derived from IP address)
• Inferences drawn from the above categories (such as lead scores or professional interest profiles)

10.2 Sale and Sharing of Personal Information. iCOUNTER does not sell your personal information. iCOUNTER may share certain personal information (such as hashed email addresses or identifiers) with advertising partners for purposes of targeted advertising, which may constitute "sharing" as defined under the CCPA. When iCOUNTER provides customer information to advertising platforms to deliver targeted ads or build similar audiences (groups of people with similar professional characteristics to existing customers, sometimes called "lookalike audiences"), this constitutes sharing under California law. You have the right to opt out of this sharing. See Sections 10.3 and 12 for details on exercising this right.

10.3 Your California Privacy Rights. Under the CCPA, California residents have the following rights:

• Right to Know and Access: request disclosure of the categories and specific pieces of personal information collected about you.
• Right to Delete: request deletion of personal information, subject to applicable exceptions.
• Right to Correct: request correction of inaccurate personal information.
• Right to Opt Out of Sharing: opt out of the sharing of personal information for targeted advertising purposes.
• Right to Limit Use of Sensitive Personal Information: iCOUNTER does not currently collect sensitive personal information as defined by the CCPA.
• Right to Non-Discrimination: iCOUNTER will not discriminate against you for exercising any of these rights.

10.4 Exercising Your Rights. To exercise any of the rights described above, contact iCOUNTER at privacy@icounter.com. You may also designate an authorized agent to submit a request on your behalf. Authorized agents must provide written authorization from the consumer and, where applicable, proof of power of attorney.

10.5 Verification. When you submit a request, iCOUNTER will verify your identity by matching information you provide in your request against information maintained in our records. iCOUNTER may request additional information as necessary to complete the verification process.

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11. UK AND EEA PRIVACY RIGHTS (EU GDPR AND UK GDPR)

11.1 DATA CONTROLLER. iCOUNTER is the data controller for personal data processed through its website. For questions about data protection, contact privacy@icounter.com or write to 12240 Inwood Rd. Suite 430. Dallas, TX 75244. [Note: Confirm whether an Article 27 representative is required for the UK and/or EEA, and if so, identify and disclose the representative here before publication.]

11.2 LAWFUL BASES FOR PROCESSING.

Legitimate Interests (primary basis for most processing): iCOUNTER processes personal data on the basis of legitimate interests for the following activities: website analytics and performance optimization; lead management, including lead scoring and account scoring; data enrichment to maintain accurate business contact records; advertising, including retargeting and audience segmentation; content personalization; outbound sales communications to business contacts; user experience research, including session recording; and network security and fraud prevention. Our legitimate interests include marketing and promoting our products and services to business professionals, understanding how our website is used, maintaining accurate business contact information, and protecting the security of our systems. We have conducted assessments to ensure our legitimate interests are not overridden by the rights and freedoms of the individuals whose data we process. In the B2B context, we process professional contact information about individuals acting in their business capacity, where privacy expectations differ from consumer contexts. You have the right to object to processing based on legitimate interests. If you object, we will cease processing unless we demonstrate compelling legitimate grounds that override your interests, rights, and freedoms.

Consent: non-essential cookies and tracking technologies; marketing emails and newsletters; session recording.

Contract Performance: responding to inquiries; providing requested resources.

Legal Obligation: retaining records as required by law; responding to lawful regulatory or law enforcement requests; complying with court orders and subpoenas; establishing, exercising, or defending legal claims.

11.3 ARTICLE 14 DISCLOSURE. iCOUNTER may obtain professional contact information from third-party data providers and publicly available professional sources, as described in Section 2.3. Categories of data obtained include professional contact details, job title, company name, and professional background. This data is processed on the basis of legitimate interests. Where individual notice would involve disproportionate effort given the volume of records and the professional, publicly available nature of the information, this Privacy Policy serves as notice of such processing.

11.4 YOUR GDPR RIGHTS. Subject to applicable conditions and exceptions, you have the right to: access your personal data; rectification of inaccurate data; erasure; restriction of processing; data portability; object to processing; and withdraw consent at any time. Regarding automated decision-making: iCOUNTER uses lead scoring to assist in prioritizing business contacts, but this does not produce legal or similarly significant effects on individuals.

11.5 SUPERVISORY AUTHORITY. UK residents may lodge a complaint with the Information Commissioner's Office (ico.org.uk). EEA residents may lodge a complaint with the relevant supervisory authority listed at edpb.europa.eu.

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12. U.S. STATE PRIVACY RIGHTS AND PRIVACY SIGNALS

12.1 U.S. STATE PRIVACY RIGHTS

If you are a resident of Virginia, Colorado, Connecticut, or another U.S. state with an applicable consumer privacy law, you may have the following rights with respect to your personal information:

• Right to access the personal information we have collected about you.
• Right to correct inaccuracies in your personal information.
• Right to delete your personal information, subject to certain exceptions.
• Right to data portability in a readily usable format.
• Right to opt out of targeted advertising.
• Right to opt out of the sale of personal information (iCOUNTER does not sell your personal information).
• Right to opt out of profiling in furtherance of decisions that produce legal or similarly significant effects.
• Right to appeal a denial of a privacy rights request.

To exercise any of these rights, contact us at privacy@icounter.com. If we deny your request, you may appeal by contacting us at the same address. We will respond within the timeframes required by applicable law.

12.2 GLOBAL PRIVACY CONTROL AND DO NOT TRACK

iCOUNTER honors Global Privacy Control (GPC) signals. GPC is a browser-level setting that sends an automated signal to websites you visit, indicating that you opt out of the sale or sharing of your personal data. GPC is available in browsers such as Firefox, Brave, and DuckDuckGo, and as an extension for other browsers. When we detect a GPC signal, we treat it as a valid request to opt out of the sharing of your personal information for targeted advertising purposes, as required by the California Consumer Privacy Act and other applicable state privacy laws.

Our website does not respond to Do Not Track (DNT) browser signals, as there is no uniform industry standard for DNT. However, we do honor GPC signals as described above.
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13. CHILDREN'S PRIVACY

The iCOUNTER website is a business-to-business platform directed at business professionals and is not intended for children under the age of 16. iCOUNTER does not knowingly collect, use, or disclose personal information from children under 16.

If iCOUNTER becomes aware that it has collected personal information from a child under 16, iCOUNTER will take prompt steps to delete that information from its systems.

If you are a parent or guardian and believe that your child has provided personal information to iCOUNTER through our website, please contact us at privacy@icounter.com so that we can take appropriate action.
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14. CHANGES TO THIS POLICY

iCOUNTER may update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or other factors. When we make changes, we will revise the "Last Updated" date at the top of this Privacy Policy and post the updated version on our website.

We encourage you to review this Privacy Policy periodically to stay informed about how iCOUNTER collects, uses, and protects your personal information. Your continued use of our website after any changes to this Privacy Policy constitutes your acknowledgment of those changes.
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15. CONTACT US AND INTERNAL NOTES

If you have questions about this Privacy Policy or wish to exercise any of your privacy rights, please contact us at:

Email: privacy@icounter.com Mailing Address: 12240 Inwood Rd. Suite 430. Dallas, TX 75244

• California Residents: To opt out of the sharing of your personal information for targeted advertising, use the "Do Not Sell or Share My Personal Information" link available on our website, or contact us at the email address above.
• UK Residents: You may lodge a complaint with the Information Commissioner's Office (ICO) at ico.org.uk.
• EEA Residents: You may lodge a complaint with your relevant supervisory authority. A list of supervisory authorities is available at edpb.europa.eu.

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