Privacy Policy

ALL COMMERCE LLC

PRIVACY POLICY

Effective Date: 1-10-2015 | Last Updated: 4-16-26

This policy applies to allcommercellc.com and all services provided by All Commerce LLC.

Privacy Contact Information

Questions about this Privacy Policy or requests   regarding your data may be directed to:

All Commerce LLC — Privacy Officer

Email: info@allcommercellc.com| Phone: 855-527-5880

Mailing   Address: P.O. Box 353, O’Fallon, IL 62269

1. Who We Are

All Commerce LLC is an IT professional services company providing staffing, consulting, and technology support services to government, education, and commercial clients. Our principal place of business is located in Illinois.

This Privacy Policy explains how All Commerce LLC collects, uses, discloses, and protects information in connection with our website (allcommercellc.com), our business operations, and our service delivery activities. It also describes the rights available to individuals regarding their personal information.

2. Scope of This Policy

This policy applies to:

• Visitors to our website

• Individuals who contact us regarding our services

• Prospective employees and contractors who submit applications or inquiries

• Personnel of our clients with whom we interact in the course of delivering services

This policy does not apply to information we process on behalf of our clients in our capacity as a service provider. When All Commerce LLC processes data on behalf of a client — such as student records in connection with education contracts — our handling of that data is governed by our agreement with that client, not this policy. For GCPS, that agreement includes the GCPS Privacy & Security Terms (v1.1).

3. Information We Collect

3.1 Information You Provide to Us

We collect information you provide directly when you:

• Contact us through our website contact form, email, or phone

• Submit a job application or expression of interest in contracting with us

• Engage us to provide services on your behalf

This may include your name, email address, phone number, mailing address, professional background, and any other information you choose to provide.

3.2 Information We Collect Automatically

When you visit our website, we may automatically collect certain technical information, including your IP address, browser type, pages visited, time of visit, and referring URL. This information is used to operate and improve our website.

3.3 Information Collected in Connection with Government and Education Contracts

In connection with certain contracts — including contracts with government and education clients — we may be provided access to data that includes personally identifiable information (PII) about students, employees, or other individuals. We access and use this data solely for the purpose of performing the contracted services. This data is governed by the applicable client contract and all applicable law, including FERPA and COPPA where applicable.

We do not use client-provided data for our own marketing, research, or commercial purposes.

4. How We Use the Information We Collect

Purpose

Description

Service Delivery -To perform IT professional services contracted by our clients,   including staffing, consulting, and technology support.

Business Operations -To communicate with clients, manage contracts, process payments,   and administer our business.

Employment and Contracting -To evaluate and process job applications, onboard employees and   contractors, and manage employment relationships.

Legal Compliance -To comply with applicable federal, state, and local laws,   including FERPA, COPPA, Illinois employment law, and applicable government   contract requirements.

Website Operation -To operate, maintain, and improve our website and respond to   inquiries submitted through it.

Security -To detect, investigate, and respond to security incidents, fraud,   or other harmful activity.

We do not sell personal information. We do not use personal information for targeted advertising.

5. How We Share Information

All Commerce LLC does not sell, rent, or trade personal information. We may share information in the following limited circumstances:

5.1 Client Engagements

Information provided by clients in connection with service delivery is used solely to perform those services. Where required by client contracts, we maintain confidentiality of client data and restrict access to authorized personnel only.

5.2 Subcontractors and Service Providers

We may engage subcontractors or third-party service providers to assist in delivering services. Any such party is required to protect the confidentiality and security of data consistent with our contractual obligations and this policy. Subcontractors with access to client Protected Data must execute written data protection agreements.

5.3 Legal Requirements

We may disclose information when required by applicable law, court order, or lawful government request. Where permitted by law, we will notify the relevant client or individual prior to such disclosure so they may seek appropriate legal remedies.

5.4 Business Transfers

In the event of a merger, acquisition, or sale of all or substantially all of our assets, information may be transferred as part of that transaction, provided the acquiring party agrees to be bound by privacy obligations consistent with this policy and applicable client contracts.

6. Family Educational Rights and Privacy Act (FERPA)

All Commerce LLC performs services for education clients as a “school official with a legitimate educational interest” as defined under FERPA (20 U.S.C. § 1232g) and its implementing regulations (34 CFR § 99). In this capacity:

• We access Education Records only to the extent necessary to perform authorized services.

• We do not disclose Education Records to unauthorized parties.

• We do not use Education Records for any purpose other than the services for which we were engaged.

• We comply with all applicable FERPA requirements governing our access to and handling of Education Records.

Requests related to Education Records — including requests for access, correction, or deletion — must be directed to the applicable educational institution, not to All Commerce LLC. We will cooperate with the institution in responding to such requests consistent with our contractual obligations.

7. Children's Online Privacy Protection Act (COPPA)

All Commerce LLC does not knowingly collect personal information directly from children under the age of 13 through our website or services. Our website is not directed to children.

In connection with education contracts, we may have access to information about students under the age of 13 as provided by the educational institution. This access is governed by FERPA and the applicable client contract. We do not use such information for commercial purposes and do not disclose it except as authorized by the educational institution and required to perform the contracted services.

8. Data Security

All Commerce LLC maintains a Written Information Security Policy that establishes administrative, physical, and technical safeguards designed to protect personal information and client data from unauthorized access, disclosure, destruction, or modification.

These safeguards include access controls and multi-factor authentication, encryption of data in transit and at rest, regular vulnerability assessments and penetration testing, annual employee training on data privacy and security, and incident response procedures including prompt notification to affected clients.

No security program is perfect. In the event of a security incident affecting your personal information or client data for which we are responsible, we will notify affected parties consistent with applicable law and our contractual obligations.

9. Data Retention

We retain personal information for as long as necessary to perform contracted services, comply with applicable legal obligations, and resolve disputes. Client data — including Protected Data and Education Records — is retained only for the term of the applicable contract and is returned to the client or securely destroyed upon contract termination consistent with the terms of that contract.

10. Your Rights

Depending on your location, you may have certain rights regarding your personal information. These may include the right to request access to the information we hold about you; the right to request correction of inaccurate information; the right to request deletion of your information, subject to our legal and contractual obligations to retain certain records; and the right to opt out of certain uses of your information.

To exercise any of these rights, please contact us at the address in Section 1 of this policy. We will respond to requests within the timeframes required by applicable law.

Note: Rights related to Education Records must be exercised directly with the applicable educational institution, not with All Commerce LLC.

11. Illinois Residents

All Commerce LLC is headquartered in Illinois and complies with applicable Illinois privacy and data protection laws, including the Illinois Personal Information Protection Act (PIPA) and applicable Illinois employment privacy laws.

Illinois residents who have questions about their rights under applicable state law, or who wish to submit a request regarding their personal information, may contact us at the address provided in Section 1.

12. Third-Party Links and Services

Our website may contain links to third-party websites or services. This Privacy Policy does not apply to those third-party sites, and we are not responsible for their privacy practices. We encourage you to review the privacy policies of any third-party sites you visit.

13. Updates to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, applicable law, or client contract requirements. When we update this policy, we will revise the “Last Updated” date at the top of this page. We encourage you to review this policy periodically.

Material changes to this policy will be communicated to clients whose data we process as required by applicable contracts.

14. Contact Us

Privacy Inquiries and Data   Requests

For questions about this Privacy Policy, to   exercise your data rights, or to report a privacy concern:

All Commerce LLC — Privacy Officer

Email: info@allcommercellc.com

Phone: 1-855-527-5880

Mailing   Address: P.O. Box 353, O’Fallon, IL 62269