Last Updated: January 13, 2023

Privafy, Inc. (“Privafy” or “we”) respects your right to privacy.  This Customer Privacy Policy applies to personal information that Privafy collects, shares and uses personal information and how you can exercise your privacy rights.

Privafy offers end-to-end Data-in-Motion security solutions for enterprises of all sizes (our “Services”).  For more information about Privafy, please see the “About” section on https://www.privafy.com (our “Site”).

DATA CONTROLLER

In this Customer Privacy Policy (and under certain data protection laws), the person or entity that controls the purposes and means of processing of personal information (also known as personal data) is known as the “data controller.”

• The data controller for the personal information collected through the Site is Privafy, Inc., 2 Burlington Woods Drive, Burlington, Massachusetts 01803 USA
• Privafy is the data controller of data generated from and about how you use the Services, some of which certain privacy laws might consider personal information.

If you have a question about whether and when Privafy is the data controller of your personal information, please contact Privafy at privacy@privafy.com.

INFORMATION WE COLLECT AND WHY WE COLLECT IT

In general, we collect personal information from or about you for the purposes described in this Customer Privacy Policy or for purposes that we explain to you when or before we collect your personal information.  We also may use your personal information for other purposes that are not incompatible with the purposes that we disclose to you but only when permitted by applicable laws.

1. We collect the information that you provide to us.

When you use our Site or Services, we may ask you to provide certain personal information and other information.

Personal Information that Privafy Collects	Why Privafy Collects The Personal Information
Business Contact details, including name, telephone numbers, email address and postal address.	To complete your subscription for the Services To respond to your correspondence and requests. To obtain your feedback regarding our Site or Services. To send you information about our Services that we think will interest you.
User credentials, including name, email address, job title, office address, device type and ID and other personal information that you or your employer choose to provide to us.	To set up and maintain your account. To monitor and enforce compliance with our Terms of Service or other agreement with you or your employer. For customer service and support for our Services
Ordering information, including shipping information and email address for your “welcome email”	To complete your purchase of the NetEdge Device and CloudEdge that enable you to connect to and use our Services PLEASE NOTE: Your credit card payments are processed by a third-party credit card processing service.  Privafy does not collect or have access to your complete credit card information.
Information you give us when you fill out our on-line form or send us an email.	To respond to your request in the form or email. To learn more about your products or services if you are a prospective or current vendor or service provider. To process your application if you apply for a job with us.

 

When requested by a customer, Privacy uses its proprietary content analysis tool to inspect the data that our customers transmit through the Services.  Some of this information is personal information.  Privafy does not store this data or use it for any purpose other than to perform the specific analysis requested by our customer.

2. We automatically collect information when you use the Site or Services.

We automatically collect certain information from your computer or mobile device when you use the Site or Services.  Some of this automatically collected information is personal information under certain laws.

The information that we automatically collect includes:

• Incoming and outgoing network traffic on the network for which you or your employer use our Services. This information is necessary for Privafy to provide the Services for the network connected to the NetEdge Device that you purchased from us.
• Information about how your computer or device interacts with our Site and Services, including the date, time, search requests and results, the pages accessed and links clicked.
• IP address, broad geographic location (e.g., country or city-level location which Privafy derives from other data), device type, device identification number, browser type, operating system and other technical information.

 

We use this automatically-collected information:

• To provide the Services
• For pricing and billing purposes
• To better understand how the Services are used so that we can update and improve the quality of the Services and develop new ones
• For our analytics purposes, such as to track usage of our Site, to measure the number of unique visitors to the different sections of our Site, to understand how people find our Site and to help us make our Site and marketing more useful
• To send you information about our Services that we think will interest you

 

Some of this information is automatically collected using cookies and similar tracking technology.  See our NOTICE ABOUT COOKIES AND TRACKING TECHNOLOGY below.

3. We collect information from third party sources

From time to time, we may receive personal information about you from third-party sources, which include:

• Your employer which may provide us with your business contact information in connection with use of the Services on behalf of your employer
• Distributors that promote the use of our Services and help us distribute them to our channel partners and other customers
• Channel partners that co-brand and market and sell the Services
• Marketing partners that help us identify individuals who may be interested in learning more about the Services and to supplement personal information we already have about you, such as when we acquire an email list from a marketing partner

 

Our distributors and channel partners provide us with your business contact details, including name, telephone numbers, email address and postal address so that we can provide the Services to you.

We only accept personal information from third parties when we have confirmed that these third parties have your authorization or are otherwise legally permitted (e.g., by a service agreement) or are required to disclose your personal information to us.

4. We collect information when you use our apps

When you download, access or otherwise use one of our mobile applications (“apps”), the information that we collect depends on your operating system and permissions.  Our apps need to use certain features and data from your mobile device in order to function, such as data from Internet, Near Field Communication, Bluetooth device pairing and settings and network connections.  We automatically collect app usage statistics and crash logs to help us identify and fix problems.

To learn more about the specific information collected by our apps, please check your device settings or review the information available on the particular platform from which you downloaded it, such as in Google Play.  Our apps also allow you to check or change your status for certain data collection in the preferences or settings.  If you change your settings, certain features may be unavailable or not function properly.  To stop collection of all information through an app, please uninstall the app.

HOW PRIVAFY SHARES PERSONAL INFORMATION

We may disclose your personal information to the following categories of recipients:

• Service providers, such as payment card processors, that help us provide the Services and Site for you;
• Channel partners with which Privafy may share order information, business contact information and other information the channel partner may require to help deploy the Services;
• Distributors with which Privafy may share order information, business contact information and other information the distributor may require to help deploy the Services;
• Marketing partners that help us identify individuals who may be interested in learning more about the Services and to supplement personal information we already have about you, such as when we acquire an email list from a marketing partner
• Competent law enforcement, regulatory or other government agencies, courts or other third parties when we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person;
• Potential acquirers and their agents and professional advisers in connection with any proposed purchase, merger or acquisition of any part of our business. We will inform the buyer that the terms of this Customer Privacy Policy apply to your personal information;
• Any other person with your consent to the disclosure.

 

Third parties may collect and use personal information that you disclose through our community forum without our knowledge and outside our control.  As a result, you may receive unsolicited communications.

PRIVAFY DOES NOT AND WILL NOT SELL OR EXCHANGE FOR VALUE YOUR PERSONAL INFORMATION.

NOTICE ABOUT COOKIES AND SIMILAR DATA TRACKING TECHNOLOGY

We use cookies and other data tracking technology to collect and use personal information about you.  We also may allow others to use cookies and similar technologies (e.g., pixels) to recognize you and/or your device(s) when you use the Site or Services.

What are cookies?

Cookies are small text files that are sent to or accessed from your web browser or your computer’s hard drive. A cookie typically contains the name of the domain (internet location) from which the cookie originated, the “lifetime” of the cookie (i.e., when it expires) and a randomly generated unique number or similar identifier. A cookie also may contain information about your computer, such as user settings, browsing history and activities conducted while using the Site and certain Services.

Privafy also uses “pixels” (also known as web beacons).  Pixels are transparent images that are used in collecting information about website usage across websites and over time.

Cookies that Privafy sets on the Site or through PrivafyCentral are called first-party cookies. Cookies set by any other party are called third-party cookies. Third-party cookies enable third-party features or functionality on or through the Site or through PrivafyCentral, such as analytics, marketing automation and customer support. The parties that set third-party cookies can recognize your computer both when it visits the Site and also when it visits certain other websites.

Most browsers accept cookies automatically but allow you to disable them.  You also can opt-out of certain cookies using the following link: http://optout.networkadvertising.org/?c=1.  You can reset your browser to refuse all cookies or to indicate when a cookie is being sent. Some features of our Site and Services may not work properly without cookies.  To learn more about cookies generally, visit www.allaboutcookies.org and http://optout.aboutads.info/?c=2&lang=EN.

Does Privafy respond to ‘Do Not Track’ signals?

Some web browsers (including Safari, Internet Explorer, Firefox and Chrome) incorporate a “Do Not Track” (“DNT”) or similar feature that signals to websites that a user does not want to have his or her online activity and behavior tracked. If a website that responds to a particular DNT signal receives the DNT signal, the browser can block that website from collecting certain information about the browser’s user. Not all browsers offer a DNT option and DNT signals are not yet uniform. For this reason, many website operators, including Privafy, do not respond to DNT signals.

Why does Privafy use cookies and other tracking technology?

Some cookies are required for the Site or Services to operate.  Other cookies enable us to track the interests of Site users, to enhance the experience the Site and to target advertising.

The types of cookies served the Site and why they are used is as follows:

• “Strictly necessary” cookies are required to allow us to deliver the Sites to you and to provide specific services that you request from us.
• “Performance” or “Analytics” cookies help us to collect information about how visitors use the Site and helps us analyze and improve the Site. Performance or analytics cookies remain on your computer after you close your browser until you delete them.
• “Advertising” cookies are used to make advertising more relevant to you. They help to display advertisements that are based on your inferred interests, prevent the same ad from appearing too often and ensuring that ads are properly displayed for advertisers.

 

Pixels and similar data collection technology typically work with cookies and enable Privafy to monitor the traffic patterns of visitors from one Site page to another, to deliver or communicate with cookies, to understand whether you visit the Site after seeing our online advertisement displayed on a third-party website, to improve performance of the Site and to measure the success of our email marketing campaigns.

The cookies used on the Site and Services are:

Third Party	Cookie Type
AdSense	Advertising Cookie
Facebook	Advertising Cookie
LinkedIn	Advertising Cookie
Marketo	Performance Cookie
Mixpanel	Performance Cookie
OneTrust	Performance Cookie
Swiftype Search	Performance Cookie

 

We also use Google Analytics (including Double Click).  Google Analytics provides us with demographic data about Site users, such as age and gender. Google uses a cookie that Google or its affiliate DoubleClick recognizes when you visit other websites. For more information about how Google collects, uses, and shares your information, please visit the Google Privacy Policy-Partners website at https://www.google.com/policies/privacy/partners/  or Google’s Privacy Policy.

Google uses cookies to help us analyze how visitors use the Site. The information generated by the cookie about your use of the Site (including your IP address) will be transmitted to and stored by Google on servers in the United States. On behalf of Privafy, Google will use this information to evaluate your use of the Site and compile reports on your activity for us and third parties who help operate and provide services related to Privafy. Google will not associate your IP address with any other data held by Google. You may refuse the use of these cookies by selecting the appropriate settings on your browser as discussed in this notice.

Google has developed an opt-out browser add-on; if you want to opt out of Google Analytics, you can download and install the add-on for your web browser.

To learn more about Facebook’s pixels and cookies and to view and update your Facebook ads preferences, please visit https://www.facebook.com/policies/cookies/.

To learn more about LinkedIn’s pixels and cookies and to learn more about how to control use of your personal information for advertising purposes, please visit https://www.linkedin.com/psettings/advertising/actions-that-showed-interest.

Does Privafy use targeted advertising?

Privafy currently does not serve targeted advertisements on the Site. Privafy may use information about your visits to the Site to serve advertisements to you on other websites.  Privafy and third parties also may deploy technology that measures the effectiveness of advertisements by using cookies or other technology tools to collect information about your visits to the other websites to provide relevant advertisements. The information collected through this process does not enable us or the third parties to identify your name or similar directly identifying details unless you choose to provide them.

HOW PRIVAFY PROTECTS PERSONAL INFORMATION

We use technical, physical and administrative safeguards intended to protect the personal information that we collect from and about you.  Our safeguards are designed to provide a level of security appropriate to the risk of processing your personal information and include (as applicable) measures to ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and a procedure for regularly testing, assessing and evaluating the effectiveness of technical and organizational measures for ensuring the security of the processing of personal information.

You are responsible for maintaining the security of your account credentials for the Services. Privafy will treat access to the Services through your account credentials as authorized by you.  We may suspend your use of all or part of the Services without notice if we suspect or detect any breach of security.  If you believe that information you provided to us is no longer secure, please notify us immediately using the contact information provided below.

If we become aware of a breach that affects the security of your personal data, we will provide you or your employer with notice as required by applicable law.  To the extent permitted by applicable law, Privafy will provide its notice to you through the email address associated with your account.

UNAUTHORIZED ACCESS TO SITE OR SERVICES – INCLUDING SCRAPING – IS PROHIBITED AND MAY LEAD TO CRIMINAL PROSECUTION.

HOW PRIVAFY RETAINS PERSONAL INFORMATION

We retain personal information for as long we have a legitimate business need to do so, such for the duration of our contract with you or to comply with applicable legal, taxation or accounting requirements.

When we have no longer have a legitimate business need to process your personal information, we follow our information governance procedures and either delete or anonymize your personal information.  If we cannot delete or anonymize your personal information, then we will segregate and securely store your personal information until deletion or anonymization is possible.

For more information, please contact privacy@privafy.com.

CHILDREN’S PRIVACY

The Site and Services are not intended for use by minors (i.e., children under age 18 or the age of majority if older in a particular jurisdiction) or to collect personal information from minors.

Privafy does not knowingly collect personal information from minors.  Consistent with the requirements of applicable law, if we learn that a minor has improperly provided us with personal information, we will use that information only to respond directly to that child (or his or her parent or legal guardian) to inform the minor that he or she cannot use the Sire or Services and subsequently will delete that information.

YOUR PRIVACY RIGHTS

PLEASE NOTE: PRIVAFY DOES NOT AND WILL NOT SELL OR EXCHANGE FOR VALUE YOUR PERSONAL INFORMATION.

Depending on where you reside, you have the following privacy rights:

• Right to know the personal information that Privafy collects, uses and discloses about you
• Right to access, correct or to request deletion of your personal information
• Right to prevent disclosure of your information to third parties for their direct marketing purposes
• Right to request that we provide you with a copy of your personal information
• Right to receive notice of any financial incentive that Privafy may in the future provide to an individual in exchange for the retention or sale of his or her personal information.
• Right to object to processing of your personal information or the right to ask us to restrict processing of your personal information (for EU residents)
• Right to withdraw your consent if you provide to us (for EU residents). Please note however that withdrawing your consent may not affect the lawfulness of any processing that we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on a legal basis (as described below) other than consent.
• Right to complain to an EU data protection authority about our collection and use of your personal information (for EU residents).  For more information, please contact your local data protection authority.

 

You can opt out of our marketing emails by clicking on the “unsubscribe” or “opt-out” link in the marketing emails we send you.

Privafy does not and will not treat you discriminatorily if you choose to exercise any of your privacy rights.

If you are a California resident, PLEASE NOTE:

Privafy does not share personal information about you to third parties for their direct marketing purposes.  If Privafy changes this policy, Privafy will notify you and obtain your consent.  As noted above, you have the right to prevent disclosures of personal information to third parties for their direct marketing purposes.

If you have questions about how to exercise any privacy right you may have, please contact our Privacy Policy Coordinator at privacy@privafy.com.

HOW TO EXERCISE YOUR PRIVACY RIGHTS

We respond to all requests we receive from individuals wishing to exercise their rights in accordance with applicable laws.  We will acknowledge your request within ten (10) days and provide you with any necessary information about how we will process your request.

If you would like to exercise your rights, please fill out send us an email to privacy@privafy.com.

In your request, please make clear the right you are exercising, the personal information that is subject to your request and any limitation you would like to put on our use of your personal information.  For your protection, we only fulfill requests for the personal information associated with the particular email address that you use to send us your request and we may need to verify your identity before fulfilling your request.

Please note that we often need to retain certain data for recordkeeping purposes and our databases and other records may have residual data which will not be removed. In addition, we also may not allow you to review certain data for legal, security or other reasons. If at any time you believe that Privafy has not adhered to this Privacy Policy, please contact us at privacy@privafy.com.  We will use good faith efforts to determine and correct the problem.

PRIVAFY’S LEGAL BASIS FOR PROCESSING PERSONAL INFORMATION

Certain privacy laws require that we identify the legal bases on which we process personal information. Our legal basis for collecting and using personal information depends on the context in which it is collected.

Generally, we only collect personal information from you only when we need the personal information to perform a contract with you (such as when you subscribe to one of our products), when we have your consent to do so or when the processing is in our legitimate business interests and not overridden by your privacy or other fundamental rights and freedoms (such as when we process personal information to provide our Services to you).   In some cases, we also may have a legal obligation to collect personal information from you.

If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether providing your personal information is mandatory and the possible consequences if you do not provide your personal information.

Similarly, if we collect and use your personal information in reliance on our legitimate interests (or those of any third party), this interest is typically to provide our products and services and communicating with you as necessary to provide our services to you and for our legitimate commercial interest, for instance, when responding to your queries, improving our products and services, advising you of product features or new releases, informing you of product maintenance, or undertaking marketing activities.   We may have other legitimate interests and if appropriate we will make clear our legitimate interests at the relevant time.

If you have questions about or need further information concerning the legal bases on which we collect and use your personal information, please contact us using the contact details provided below.

INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION

Privafy may transfer your personal information to jurisdictions other than the one in which you reside.  These other jurisdictions may have data protection laws that are different from the laws of your place of residence (and, in some cases, not as protective).

Specifically, our servers are located in various countries which may be located outside of the jurisdiction where we collected the data.  This means that when we collect your personal information we may transfer it to or process it in any of the countries in which we do business.  Also, some of the third-party service providers with which we may share personal information (as described above) are located in and transfer personal information to various jurisdictions around the world.

Privafy primarily uses the European Union Commission’s Standard Contractual Clauses for transfers of personal information from the European Economic Area, Switzerland and the United Kingdom (if and when it leaves the European Union) to other countries outside the European Economic Area, Switzerland and the United Kingdom (if and when it leaves the European Union).

UPDATES TO THIS CUSTOMER PRIVACY POLICY

We may update this Customer Privacy Policy from time to time in response to changing legal, technical or business developments.  When we update our Customer Privacy Policy, we will post the updated version and change the Effective Date above.  We also will take appropriate measures to inform you in advance so that you have an opportunity to review the revised Customer Privacy Policy before it is effective.  If your consent is required by applicable privacy laws, we will obtain your consent to changes before the revised Customer Privacy Policy applies to you.

HOW TO CONTACT US

If you have any concerns or questions about any aspect of this Privacy Policy, please contact our Privacy Policy Coordinator as follows:

Privafy, Inc.
Attn: Legal
2 Burlington Woods Drive
Burlington, MA 01803.
privacy@privafy.com

If you are a Data Protection Authority in the EEA with questions about the processing of personal data of individuals in the European Union pursuant to the EU’s General Data Protection Regulation (GDPR) or its implementing laws:  , please contact  Privafy at privacy@privafy.com or the above address or VeraSafe (as per GDPR Article 27) using this contact form: https://www.verasafe.com/privacy-services/contact-article-27-representative  or via telephone at: +420 228 881 031 or via mail at VeraSafe Netherlands BV, Keizersgracht 555  1017 DR Amsterdam, The Netherlands.