PRIVACY POLICY

1. INTRODUCTION

Transcontinental Services Group LLC ("Company," "we," "us," or "our") is committed to protecting the privacy and security of personal information we collect and process. As a United States defense contractor subject to the International Traffic in Arms Regulations (ITAR) and other federal regulations, we maintain stringent controls over all information in our possession.

This Privacy Policy describes how we collect, use, disclose, and safeguard information obtained through our website, business operations, and in connection with our defense contracting activities. By accessing our website or providing information to us, you acknowledge that you have read and understood this Privacy Policy.

2. REGULATORY COMPLIANCE FRAMEWORK

Our privacy practices are governed by and comply with:

• International Traffic in Arms Regulations (ITAR) (22 CFR Parts 120-130)
• Export Administration Regulations (EAR) (15 CFR Parts 730-774)
• Defense Federal Acquisition Regulation Supplement (DFARS)
• National Industrial Security Program Operating Manual (NISPOM)
• Federal Acquisition Regulation (FAR)
• Cybersecurity Maturity Model Certification (CMMC) requirements
• California Consumer Privacy Act (CCPA) where applicable
• Other applicable federal, state, and local privacy laws

3. INFORMATION WE COLLECT

3.1 Categories of Information

We collect the following categories of information:

Personal Information:

• Full name and title
• Business contact information (email, phone, address)
• Government-issued identification numbers (where required for security clearance or compliance)
• Citizenship and nationality information (required for ITAR compliance)
• Security clearance status and level
• Professional qualifications and employment history
• Background check information (where authorized)

Technical Information:

• IP addresses and device identifiers
• Browser type and operating system
• Access logs and usage data
• Cookies and similar tracking technologies

Controlled Information:

• ITAR-controlled technical data
• Export-controlled information
• Classified information (handled per applicable security protocols)
• Proprietary and competition-sensitive information

3.2 Methods of Collection

We collect information through:

• Direct submissions via our website or correspondence
• Security clearance and background check processes
• Contract performance and business relationships
• Facility access control systems
• Automated technologies on our digital platforms

4. ITAR COMPLIANCE AND EXPORT CONTROLS

4.1 Access Restrictions

Access to ITAR-controlled technical data through our systems is strictly limited to:

• U.S. citizens
• U.S. lawful permanent residents (Green Card holders)
• Protected individuals under 8 U.S.C. § 1324b(a)(3)
• Authorized foreign persons with appropriate licenses or agreements

4.2 Nationality Verification

We are required by law to verify the nationality and citizenship status of individuals before granting access to controlled information. This verification may include:

• Collection of citizenship documentation
• Execution of non-disclosure agreements
• Export control compliance certifications
• Regular re-verification of status

4.3 Foreign Person Restrictions

Foreign persons may not access ITAR-controlled technical data without proper authorization from the U.S. Department of State, Directorate of Defense Trade Controls (DDTC) or other appropriate authority.

5. USE OF INFORMATION

We use collected information for:

Compliance and Security:

• ITAR and export control compliance
• Security clearance processing and maintenance
• Facility and information security
• Compliance with government contracts and regulations
• Audit and investigation support

Business Operations:

• Contract performance and administration
• Communication regarding products and services
• Quality assurance and improvement
• Business relationship management
• Legal compliance and risk management

Website and Technology:

• Website functionality and improvement
• Cybersecurity and threat monitoring
• System maintenance and troubleshooting

6. INFORMATION SHARING AND DISCLOSURE

6.1 Authorized Disclosures

We may share information with:

Government Entities:

• U.S. Department of Defense and military services
• Defense Security Service (DSS) / Defense Counterintelligence and Security Agency (DCSA)
• Department of State, Directorate of Defense Trade Controls
• Other federal agencies as required by law or contract

Business Partners:

• Prime contractors and subcontractors (under appropriate agreements)
• Joint venture partners (with proper controls)
• Professional service providers (under confidentiality agreements)

Legal and Compliance:

• Law enforcement pursuant to legal process
• Courts and tribunals as required
• Regulatory bodies for compliance purposes

6.2 Disclosure Restrictions

We will NOT disclose ITAR-controlled or classified information except:

• To authorized U.S. persons with appropriate clearances and need-to-know
• To authorized foreign persons under approved licenses or agreements
• As specifically authorized by applicable regulations

7. DATA SECURITY

7.1 Security Measures

We implement comprehensive security measures including:

• Physical security controls compliant with NISPOM requirements
• Encryption of sensitive data in transit and at rest
• Multi-factor authentication for system access
• Regular security assessments and penetration testing
• Incident response and breach notification procedures
• Continuous monitoring and threat detection
• CMMC-compliant cybersecurity practices

7.2 Classified Information Systems

Classified information is processed only on accredited systems meeting applicable security requirements and is never processed through public-facing websites or unclassified systems.

8. DATA RETENTION

We retain information for periods required by:

• ITAR recordkeeping requirements (minimum 5 years)
• Government contract requirements
• Security clearance maintenance needs
• Legal and regulatory obligations
• Litigation holds and investigation requirements

Controlled and classified information is destroyed in accordance with applicable regulations and security procedures.

9. INDIVIDUAL RIGHTS

9.1 Access and Correction

Subject to security and regulatory restrictions, you may:

• Request access to your personal information
• Request correction of inaccurate information
• Request information about our data practices

9.2 Limitations on Rights

Rights may be limited where:

• Disclosure would violate ITAR or export control regulations
• Information is classified or otherwise protected
• Disclosure would compromise security or investigations
• Required by law or government contract

9.3 California Residents

California residents may have additional rights under the CCPA, subject to applicable exemptions for defense contractors and regulated information.

10. INTERNATIONAL CONSIDERATIONS

10.1 Cross-Border Restrictions

We do not transfer ITAR-controlled technical data outside the United States except under approved export licenses or agreements.

10.2 Foreign Access to Website

Access to certain portions of our website may be restricted based on geographic location to ensure compliance with export control regulations.

11. COOKIES AND TRACKING TECHNOLOGIES

We use cookies and similar technologies for:

• Security and access control
• Website functionality
• Analytics and performance monitoring
• Compliance with security requirements

You may manage cookie preferences through your browser settings, though some features may not function properly without cookies.

12. CHILDREN'S PRIVACY

Our services are not directed to individuals under 18. We do not knowingly collect personal information from children except as may be required for dependent information in security clearance processes.

13. CHANGES TO THIS POLICY

We may update this Privacy Policy to reflect changes in:

• Legal or regulatory requirements
• Security procedures
• Business operations
• Technology implementations

Material changes will be posted on our website with an updated effective date.

14. CONTACT INFORMATION

15. ACKNOWLEDGMENT

By accessing our website or providing information to us, you acknowledge that:

• You have read and understood this Privacy Policy
• You understand the requirements related to ITAR and export controls
• You will not attempt to access controlled information without proper authorization
• You will report any suspected security incidents or policy violations

16. LEGAL DISCLAIMER

This Privacy Policy is subject to U.S. law. Nothing in this policy creates rights beyond those required by applicable law. In case of conflict between this policy and legal requirements, legal requirements prevail.