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Introduction
IMPORTANT NOTE TO USERS OF OUR SERVICES: BY USING SIXGILL INC’S, SIXGILL LTD.’S OR ANY OF THEIR AFFILIATES’ (“COMPANY” OR “WE“) SOLUTIONS OR SERVICES (COLLECTIVELY, THE “SERVICES“) YOU (“YOU“) CONSENT TO THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY AND CONSENT THAT ALL PII (DEFINED BELOW) THAT YOU SUBMIT OR THAT IS PROCESSED OR COLLECTED THROUGH OR IN CONNECTION WITH YOUR USE OF THE SERVICES WILL BE PROCESSED BY THE COMPANY AND ITS AFFILIATES IN THE MANNER AND FOR THE PURPOSES DESCRIBED IN THE FOLLOWING PRIVACY POLICY.
Company is a controller of the PII it processes in connection with management of its engagements with its customers and partners (e.g. contact personnel data, email communications and usage metrics). Company is a joint controller, together with its customers and partners, of PII made available by Company to such customers and partners, from Company’s data-lake (e.g. cyber threat intelligence). When Company processes PII on behalf of its customers (e.g. the customer submits a search query to Company’s solutions or Company acquires compromised data pursuant to a specific request from a data controller), Company is a data processor of such PII, to the extent applicable, and Company’s customer or Company’s partner’s customer, as the case may be, will be the data controller, and will be responsible to establish the lawful basis for processing and to ensure that data subjects can exercise their rights set forth in Section 9 below.
AS A USER OR OUR SERVICES AND/OR SOLUTIONS, YOU ARE NOT LEGALLY REQUIRED TO PROVIDE US WITH PII, HOWEVER, USE OF THE SERVICES REQUIRES THAT YOU PROVIDE PII. IF YOU CHOOSE TO WITHHOLD ANY PII REQUIRED IN RESPECT THEREOF, IT WILL NOT BE POSSIBLE FOR YOU TO USE THE SERVICES. IF YOU DO NOT AGREE TO THE TERMS AND CONDITIONS SET FORTH HEREIN PLEASE DO NOT USE THE SERVICES.
“PII” means any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
We recognize that privacy is important. This Privacy Policy applies to all of the services, information, tools, features and functionality available on the Services offered by the Company or its subsidiaries or affiliated companies and covers how PII that the Company collects and receives, including in respect of any use of the Services, is treated. If you have any questions about this Privacy Policy, please feel free to contact us at: dpo@cybersixgill.com
2. Information We Collect and How We Use It
Summary: We collect personal data about our customers’ and partners’ representatives who are contact persons or otherwise users of our Services. We also receive your queries on our Services, which may include PII. We use such PII in order to provide the Services, improve our solutions and services and enforce our agreement.
We also collect PII from various sources in the clear-web, deep-web and dark-web and sometimes purchase compromised PII on behalf of data controllers. We use such PII for purposes such as, assisting our customers and partners to mitigate or prevent security breaches, assisting law enforcement or other government agencies in investigation or indictment of suspected cyber-criminals and in cyber-security research and fulfillment of other similar legitimate interests.
In order to provide and operate our Services and provide services in connection therewith, we collect and process PII, including the following types of information:
When you subscribe to use the Services we ask you to provide PII, including: Full name, email address, phone number and the organization for whom you work.
When you use the Services, we automatically receive and record information from your browser and information related to such usage for analysis of your usage for improving our solutions and services, including without limitation information and statistics about your online/offline status, your IP address, device identifiers, internet service provider, connection speed, search history, type of browser, your regional and language settings and software and hardware attributes. Our systems automatically record and store technical information regarding the method and nature of your use of the Services, including without limitation your search queries, meta-data of search queries, which pages of the Services you viewed, exit and entrance pages and your use time of the Services. An IP address is a numeric code that identifies your browser on a network, or in this case, the Internet. Your IP address is also used to gather broad demographic information. The Company uses all of the PII identified in this Section in order to understand the usage trends and preferences of our users, including recent visits to our Services and how you move around different sections of our Services for analytics purposes and in order to make our Services more intuitive. We may also disclose aggregated user statistics in order to describe our services to current and prospective business partners, and to other third parties for other lawful purposes.
3. Data From Third Parties
We collect information from the clear-web, dark-web and deep-web and some-times also purchase compromised data on behalf of data controllers, which often includes also PII, in order to assist our customers and partners to mitigate, prevent and remediate cyber security risks and security breaches. We do that by, inter alia: (i) identifying data that may have been breached or leaked online (which often includes PII); (ii) tracking vulnerabilities and exploits targeting our customers; (iii) enabling organizations to remediate compromised credentials; and (iv) assisting organizations in researching security threats. We may also use such PII in order to comply with legal or ethical obligations or with any order of a court or competent authority.
4. User Communications
When you send emails or other communications to the Company, we retain those communications in order to process your inquiries, respond to your requests and improve our Services. We may send customers, partners and other subscribers periodic emails or newsletters and updates from Company’s blog, including promotional materials. Data subjects who wish to unsubscribe from the list may do so at any time by following the detailed instructions found at the bottom of each email they receive from the Company or send us a request here dpo@cybersixgill.com. Please note that even if you opt-out of receiving the newsletters and communications, we may still send you transactional communications such as responses to any of your emails as well as administrative e-mails necessary to facilitate your use of our Services.
5. Aggregate and Analytical Data
In the effort to produce insights regarding use of the Services in order to improve our services and develop and improve new features and automated processes on our Services, we often conduct research on PII arising from use of our Services, including usage data and search queries. This research is compiled and analyzed on an aggregate basis, and we share this aggregate data with Company’s affiliates, agents and business partners and also disclose aggregated information in order to describe our services to current and prospective business partners or investors. This aggregate information does not identify you or your customers or employees personally.
6. Cookies
Summary: We use cookies and similar technologies on our Services. You can disable cookies but then your online experience on our Services will be limited.
In order to collect some of the data described herein we use temporary cookies that remain on your browser for a limited period of time. We also use persistent cookies that remain on your browser until the Company’s Services are removed, in order to manage and maintain the Services and record your use of the Services. Cookies by themselves cannot be used to discover the identity of the user. A cookie is a small piece of information which is sent to and stored on your browser. Cookies do not damage your browser. Most browsers allow you to block cookies but you may not be able to use some features on the Services if you block them. You may set most browsers to notify you if you receive a cookie (this enables you to decide if you want to accept it or not). We also use web beacons via the Services to collect information. Web beacons or “gifs”, are electronic images that are used in our Services or in our emails. We use Web beacons to deliver cookies, count visits and to tell if an email has been opened and acted upon.
7. Links
Links to other services, sites and applications are provided by the Company as a convenience to our users (e.g. links to sources). The Company is not responsible for the privacy practices or the content of other sites and applications and you visit them at your own risk. This Privacy Policy applies solely to PII collected by us.
8. Minors
We do not intentionally collect PII of minors.
9. Information Sharing
Summary: We transfer your PII to third parties who assist us in providing the Services. We have a contract with those third parties to govern their processing on our behalf. We may also transfer PII to comply with any obligations by which we are bound or to an investor or in connection with a merger or acquisition or similar transaction.
As part of providing the Services our affiliates, agents, representatives and service providers will have access to your PII. We require these parties to process such information in compliance with this Privacy Policy and subject to security and other appropriate confidentiality safeguards. The Company will also share PII in the following circumstances: (a) as required for providing the Services; (b) for maintenance and improvement of the Services; (c) if we become involved in a reorganization, merger, consolidation, acquisition, or any form of sale of some or all of our assets, with any type of entity, whether public, private, foreign or local; and/or (d) to satisfy applicable law or due to an order or request by any competent authority, prevention of fraud or harm or to enforce applicable agreements and/or their terms, including investigation of potential violations thereof.
The server on which the Services are hosted and/or through which the Services are processed may be outside the country from which you access the Services and may be outside your country of residence. Some of the uses and disclosures mentioned in this Privacy Policy involve the transfer of your PII to various countries around the world that may have different levels of privacy protection than your country and will be transferred outside of the European Economic Area. If there is a transfer of your PII outside the EEA or UK (as the case may be) we will, in the absence of an EC Adequacy decision relevant to the destination country or to the transfer, seek to rely on appropriate safeguards such as entering into appropriate EC approved standard contractual clauses (see:
http://ec.europa.eu/justice/data-protection/international-transfers/transfer/index_en.htm).
10. Data Security
We follow generally accepted industry standards to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of PII. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your PII, we cannot guarantee its absolute security. We retain your PII only for as long as reasonably necessary for the purposes for which it was collected or to comply with any applicable legal or ethical reporting or document retention requirements.
11. Data Retention
Summary: We retain PII only for as long as necessary to meet our legal and ethical obligations, which for different types of PII will be different periods.
The Company processes PII only for the purposes for which it was collected and in accordance with this Privacy Policy or any applicable service agreements. We review our data collection, storage and processing practices to ensure that we only collect, store and process the PII needed to provide or improve our Services. We take reasonable steps to ensure that the PII we process is accurate, complete, and current, but we depend on our users to update or correct their PII whenever necessary. Nothing in this Privacy Policy is interpreted as an obligation to store information, and we may, at our own discretion, delete or avoid from recording and storing any and all information.
13. Rights of Data Subjects
Data subjects have the right to know what PII we collect about them and to ensure that such data is accurate and relevant for the purposes for which we collected it. We allow data subjects the option to access and obtain a copy of their PII and to rectify such PII if it is not accurate, complete or updated. However, we may first ask data subjects to provide us certain credentials to permit us to identify their PII.
Data subjects have the right to delete their PII or restrict its processing. We may postpone or deny such requests if the PII is in current use for the purposes for which it was collected or for other legitimate purposes such as compliance with legal obligations.
Data subjects have the right to withdraw their consent to the processing of their PII. Exercising this right will not affect the lawfulness of processing the PII based on consent obtained before its withdrawal.
Where technically feasible, data subjects have the right to ask to transfer their PII in accordance with their right to data portability, if required pursuant to applicable law.
Data subjects may exercise the above rights by sending a request to dpo@cybersixgill.com
Data subjects also have the right to lodge a complaint with a data protection supervisory authority regarding the processing of their PII.
14. Enforcement
The Company regularly reviews its compliance with this Privacy Policy. Please feel free to direct any questions or concerns regarding this Privacy Policy or our treatment of PII by contacting us as provided above. When we receive formal written complaints it is the Company’s policy to contact the complaining user regarding his or her concerns. We will cooperate with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of PII that cannot be resolved between the Company and an individual.
15. Changes to This Privacy Policy
The Company may update this Privacy Policy. We will notify you about significant changes in the way we treat PII by sending a notice to the email address provided by you or by placing a prominent notice on the Services. We encourage you to periodically review this Privacy Policy for the latest information about our privacy practices. Our customers and business partners will be notified of such changes and are responsible to inform their data subjects.
16. Legal Justification and Consent To Processing
You may contact our DPO here: dpo@cybersixgill.com. If you have any questions about this Privacy Policy or concerns about the way we process your PII, please contact us at dpo@cybersixgill.com. If you wish to delete all information regarding your use of the Services, please contact us at: dpo@cybersixgill.com
17. Your California Privacy Rights and Do Not Track Notices
California Civil Code Section 1798.83 permits customers of Company who are California residents to request certain information regarding its disclosure of PII to third parties for their direct marketing purposes. To make such a request, please send an email to dpo@cybersixgill.com. Please note that we are only required to respond to one request per customer each year.
