PRIVACY NOTICE FOR CALIFORNIA RESIDENTS

This PRIVACY NOTICE FOR CALIFORNIA RESIDENTS supplements the information contained in the privacy policy of Sixgill, Inc. (“Sixgill” or “we”) to be found at the following link: www.cybersixgill.com/privacy-policy (“Privacy Policy”) and applies solely to visitors, users, and others who reside in the State of California (“consumers” or “you”) in connection with the use of our Services (as defined in Privacy Policy). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws. Any terms defined in the CCPA have the same meaning when used in this notice.

Personal Data We Collect

Section 2.1 of our Privacy Policy includes the categories of Personal Data (as defined in the Privacy Policy) we have collected and/or processed during the past twelve (12) months.

We may obtain the categories of Personal Data from the following categories of sources:

• Directly from our clients. For example, from information our clients provide to us related to the Services for which they engage us.
• Directly from third parties.
• Directly from you. For example, through information we ask from you when engage our Services.
• Directly and indirectly from you when using our Services or visiting our website and/or from your device or browser.
• From the web. We search and store information, publicly available on the Internet and the dark web.

Use of Personal Data

We may use or disclose Personal Data we collect for one or more of the following business purposes:

• To provide you with email alerts and other notices concerning our Services.
• As required for the provision, maintenance and improvement of the Services.
• To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• As described to you when collecting your Personal Data or as otherwise set forth in the CCPA.
• For processing the Personal Data on your behalf.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by us is among the assets transferred.

We will not collect additional categories of Personal Data or use Personal Data we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Data

We may disclose your Personal Data to a third party for a business purpose. When we disclose Personal Data for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that Personal Data confidential and not use it for any purpose except performing the contract.

For additional details about third parties with whom we share your Personal Data, including sharing for a business purpose, please see Section 2.4 of our Privacy Policy.

In the preceding twelve (12) months we may have sold Personal Data collected from the Web (for more details on such data please see paragraph titled “Information collected from the Web” under Section 2.1 of the Privacy Policy) to our customers who have a legitimate interest in obtaining such information. Please see details on how to opt out of the sale of Personal Data in Section 6 below.

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their Personal Data. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information Right

You have the right to request that we disclose certain information to you about our collection and use of your Personal Data over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

• The categories of Personal Data we collected about you.
• The categories of sources for Personal Data we collected about you.
• Our business or commercial purpose for collecting that Personal Data.
• The categories of third parties with whom we share that Personal Data.
• The specific pieces of Personal Data we collected about you (also called a data portability request).
• If we sold or disclosed your Personal Data for a business purpose, two separate lists disclosing: (a) sales, identifying Personal Data categories that each category of recipient purchased; and (b) disclosures for a business purpose, identifying Personal Data categories that each category of recipient obtained.

Deletion Request Right

You have the right to request that we delete any of your Personal Data we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Data from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service providers to:

1. Complete the transaction for which we collected Personal Data, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
3. Debug products to identify and repair errors that impair existing intended functionality.
4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
8. Comply with a legal obligation.
9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Your Rights

To exercise your rights under the CCPA, please submit a verifiable consumer request to us by either: (a) sending an e-mail to us at: info@cybersixgill.com; or (b) submitting a request through https://www.cybersixgill.com/contact-us/; or (c) sending a letter to us at Derech Menachem Begin 132, Azrieli Tower, Triangle Building, 42^nd Floor, Tel Aviv, 6701101 or (d) calling us at +972-73-3236855.

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Data. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Data or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with Personal Data if we cannot verify your identity or authority to make the request and confirm the Personal Data relates to you.  Making a verifiable consumer request does not require you to create an account with us. We will only use Personal Data provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to the registered email associated with the account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Data that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded.  If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Personal Data sales opt-out and opt-in rights

You have the right to opt out of the sale of Personal Data by sending an e-mail to us at: info@cybersixgill.com. We do not sell Personal Data of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the “right to opt-in”) from either the consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer who is between 13 and 16 years of age. Consumers who opt-in to Personal Data sales may opt-out of future sales at any time.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights.

1.              Other California Privacy Rights

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our websites that are California residents to request certain information regarding our disclosure of Personal Data to third parties for their direct marketing purposes. To make such a request, please send an email to  info@cybersixgill.com

Changes to Our Privacy Notice

We reserve the right to amend this Privacy Notice at our discretion and at any time. This Privacy Notice will be updated at least once every 12 months. The date this Privacy Notice was last updated is identified at the bottom of this page. You are responsible for periodically visiting our website and this Privacy Notice to check for any changes. Your continued use of our websites following the posting of changes constitutes your acceptance of such changes.

Contact Information

If you have any questions or comments about this Privacy Notice, our Privacy Policy, the ways in which we collect and use your Personal Data, your choices and rights regarding such use, or wish to exercise your rights under California law, you may contact us via email at info@cybersixgill.com

Updated: October, 2020.