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Privacy Policy Effective Date: November 12, 2024

Applicability This Privacy Policy describes how Systems Planning & Analysis (or SPA), and its affiliates, treats the personal information of individuals who interact with us. This includes on the sites where it appears. This Policy does not describe our use of employees’ information. It also does not apply to our use of information that may be subject to other obligations or restrictions. This includes information we may receive under contract from government-agency customers.

Notice at collection Information We Collect The information we collect depends on your relationship with us and the jurisdiction in which you reside. It may include any of the following: Contact and demographic information. We collect your name and email address. We may also collect your phone numbers or address. In some cases, we may collect your date of birth or gender. Information for events or visiting our facilities. We may collect additional identification information such as driver’s license or passport. We may also collect information about your security clearance. Site and device information. We collect log and session data when you visit our platforms. We collect your IP address. We also collect device identifiers. Job application information. If you apply for a job, or are referred by a friend for a job, we will collect information as permitted by law. This may include education, work history, skills, and qualifications. We may also ask about your ability to perform a position, work permit status, and security clearance. We may also collect marital status, gender, race/ethnicity, citizenship, and veteran status. Security-related information. We may collect information about certain individuals who interact with us about their security clearance levels. Other information you submit. We collect personal information you provide to us. This includes information in emails or during calls. California law requires us to tell you if we share categories of information for cross-contextual behavioral advertising, as defined under California law. We do not engage in this practice, and thus, do not use your information for cross-contextual advertising.

Business Purposes for Information Use How we use your information depends on your relationship with us. It may include any of the following reasons disclosed and described here: Communicating with you. We use your information to answer questions and respond to your feedback. This includes responding to your inquiries. We may also send to you information about job opportunities or communicate about a job application you submit. We may provide you with technical notices or security alerts. Improving products and platforms. We use your information to improve our platforms and your experience. This may include customizing your experience with us. Marketing purposes. We may use your information to provide you with information in which we think you may be interested. We may provide this information by email or on social media platforms. Providing products and services. We use your information to provide or perform services that you may have requested of us. We also use your information to provide access to our facilities. This includes our conference center. Protecting our company and constituents. We use your information to protect our company and individuals with whom we interact. We may also use your information to identify fraud and secure our systems. We will use your information to comply with the law. This includes responding to law enforcement or regulatory requests. Recruitment purposes. We use your information for recruitment purposes. This includes reviewing your information for suitability for potential positions. We use all categories of information for other purposes as permitted by law or as we may notify you.

More Information We keep information for as long as necessary or relevant for the purposes described in this Privacy Policy. We also keep information as required by law. We do not use or disclose sensitive personal information, as defined by California law, for inferring characteristics or for purposes other than those permitted by law. For more information about our privacy practices, read the rest of this Privacy Policy, below. How we collect and combine information We collect information directly from you. This includes when you contact us or as part of a recruitment or informational event. We also collect information from you online or if you call us. This includes during the job application process.

We collect information passively.  We collect information through tracking tools including cookies and pixels. To learn more read our Ad and Cookie Policy below. We may also passively collect information when monitoring our IT and communications systems.

We collect information about you from others. We may collect information about job applicants from their schools. We may collect information about referral sources from friends who refer them for a job. We may also get personal information for governmental security authorities. We may get information about you from others when you attend our events or visit our facilities. We may receive information about you from courts, authorities or others during legal proceedings or authority proceedings and investigations.

We combine information that we have collected offline with information we collect online. We also combine information that we get from others with information we already have.

Security measures We use reasonable security measures as required by law. The Internet is not 100% secure. We cannot promise that your use of our sites will be completely safe. We encourage you to use caution when using the Internet. This includes not sharing your passwords. Information storage Information we collect may be stored in the country in which you reside. It may, in some cases, be transferred to the United States. If you live outside of the United States, you understand this, and that the United States may not afford the same level of protection as laws in your own country.

When we disclose information We may disclose your information with the parties below:

We disclose information to vendors who perform services on our behalf. We may disclose all categories of information with trusted service providers. This includes contractors or vendors of SPA who provide services to us. For example, IT service providers, fraud prevention services, and data analytics companies. We disclose information to comply with the law or to protect ourselves. We disclose all categories of information to respond to a court order or subpoena. We also disclose this information in response to a government agency, public authority, or investigatory body request. This includes to meet national security or law enforcement requirements. We may also disclose this information to investigate potential fraud or to enforce our policies and terms. We will transfer information with successors to all or part of our business. If all or part of our business is sold, we may transfer all categories of information as part of that transaction. If there is a merger or acquisition, we will do this as well. We may disclose information for other reasons we may describe to you. We will also disclose information as otherwise permitted by law. Additional information for residents of certain jurisdictions: California and Nevada law require that we tell you if we sell personal information with a third party for monetary or (in California) other valuable consideration. We do not do this. We also do not sell personal information of minors under the age of 16 for monetary or other valuable consideration.

Financial incentives From time to time, we may offer certain financial incentives such as part of one of our referral programs. The terms of the financial incentive, including if required by law a “notice of financial incentive” under California law will be presented to you at the time you sign up. That notice will explain how you can withdraw from any of the financial incentives. Your rights and choices Marketing choices We may send marketing materials. You may opt out of receiving marketing emails you receive from us. To do so follow the instructions in the message you receive. You will still receive our transactional communications. Ad and cookie policy We collect personal information about users over time and across different websites when you use this website, app or service. We also have third parties that collect personal information this way. To do this, we use several common tracking tools. These may include browser cookies. To learn more about cookies, visit this page. We may also use web beacons, flash, cookies, and similar technologies. We may have third parties collect personal information this way. How we use tracking tools. We use tracking tools to recognize new or past site visitors or to understand where they have come from or where they go after they leave our site. We also use these tools to improve our sites and better understand how you use our platforms. We may also use them to serve content in which we think you may be interested. You can control cookies and tracking tools. Your browser may give you the ability to control cookies or other tracking tools. How you do so depends on the type of tool. Certain browsers can be set to reject browser cookies. To control flash cookies, which we may use, go here, because flash cookies cannot be controlled through your browser settings. Some browsers or browser extensions also allow you to tell websites not to share your information for cross-contextual behavioral advertising through the “global privacy control” signal. We will respond to this signal in a frictionless manner. If you configure this setting on your browser, certain features on our site may not work. To learn how to configure this setting, view here. Our Do Not Track Policy: Some browsers have “do not track” features that allow you to tell a website not to track you. These features are not all uniform. We do not currently respond to those signals. If you block cookies, certain features on our sites may not work. If you block or reject cookies, not all of the tracking described here will stop. Options you select are browser and device specific.

Specific Rights in Certain Jurisdictions If you are a consumer who lives in the EU, the UK, Canada, Australia, and California, or jurisdictions with similar laws, you may have additional rights. Those rights depend on our relationship with you and are not absolute. This might include if a legal exception applies. If that is the case, we will not be able to process your request. We will let you know when or if a right does not apply to you. If you disagree with our decision, you can contact us as described at the end of this Policy. We will not discriminate against you because you exercised your rights. The rights may include the following: Access: This includes finding out the categories of information we hold about you and the purposes of processing. It also includes the recipients and retention periods. For those in California, to also find out the sources of collection and disclosure and the business purpose for collection. Portability: This means getting a copy of your information in a structured, commonly used, and machine-readable format. Correction: This includes having us make changes to your information. Restriction: This right means to ask us in to restrict the processing of your information. Deletion: This right is subject to exceptions and means asking that we delete your information. UK and EU Residents: If you are in the UK or EU, you have the right to object to how we process your information. Your objection may be based on grounds relating to your particular situation. This right exists when we process your personal data based on our legitimate interests. If you are in the UK, for questions, suggestions, and comments on the topic of data protection, you may also contact the Information Commissioner’s Office at https://ico.org.uk/. You can exercise your rights by contacting us at privacy@spa.com or by visiting spa.com/privacy-rights-request-form. You must be able to provide your name and email address or other information sufficient to allow us to identify you. We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. If you are submitting a request on someone else’s behalf, we may ask for additional verification. This may include a signed letter verifying your right to make this request.

Social Sharing We use a Social Share widget, Sassy Social Share, on our website to allow you to share our webpages on your social platforms. Some of these platforms may log information when you interact with the widget. This may include your IP address, user-agent string, browser type, operating system, referral URLs, device information (e.g., device IDs), pages visited, links clicked, user interactions (e.g., voting data), the requested URL and hardware settings, in accordance with their privacy policy. For more information, you can review GDPR and privacy policy information about the sharing widget here.

Updates to this Privacy Policy We may update this notice from time to time. We will notify you as required by law and will post the updated version on the sites where this appears. Please check back periodically for updates. How to contact us You can contact us at privacy@spa.com with any questions about this Policy or our data practices. Or write to us at:

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Alexandria, VA 22311

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