Updated April 3, 2019
For purposes of applicable data protection legislation, the data controller of your personal data is Cofense Inc. at 1602 Village Market Blvd SE suite 400, Leesburg, VA 20175. Our data protection officer is our Chief Privacy Officer, reachable at firstname.lastname@example.org.
We may collect information that is related to you but that does not personally identify you (“Non-Personal Data”). Non-Personal Data also includes information that could personally identify you in its original form, but that we have modified (for instance, by aggregating, anonymizing or de-identifying such information) to remove or obscure any Personal Data.
We may also collect Technical Information about you when you visit our websites, which your web browser automatically sends whenever you visit a website on the Internet. “Technical Information” is information that does not, by itself, identify a specific individual but which could be used to indirectly identify you. Our servers automatically record Technical Information, which may include your Internet Protocol (“IP”) address, browser type, browser language, and the date and time of your request.
How We Collect Information
Cofense collects Personal Data about you when you submit information through our websites. Examples include requests for product information; registering for Cofense whitepapers, reports, newsletters or webcasts; or entering promotions.
We use pixel tags and cookies in our marketing emails so that we can track your interaction with those messages, such as when you open the email or click a URL link that’s embedded within them. When recipients click on one of those URLs, they pass through a separate web server before arriving at the destination page on a Cofense website. We use tools like pixel tags and cookies so that we can determine interest in particular topics and measure and improve the effectiveness of our communications.
Log files record website activity on our services and enable us to gather statistics about our users’ browsing habits. These entries help Cofense determine how many and how often users have accessed or used our services, which pages they’ve visited, and other similar data.
Cookies and Similar Technologies
We may collect information about your use of the websites through cookies and similar technologies. A “cookie” is text that we store through your computer’s web browser so that we can keep track of your interests and/or preferences and recognize you as a return visitor to the websites.
|Our websites uses the following types of cookies for the purposes set out below:|
|Type of cookies||Purpose|
|Essential Cookies||These cookies are essential to provide you with services available through our websites and to enable you to use some of its features, e.g., to allow you to log in to secure areas of our websites. Without these cookies, the services that you have requested cannot be provided.|
|Functionality Cookies||These cookies allow our websites to remember choices you make when you use our website, such as remembering your user preferences. The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you visit our website.|
|Analytics and Performance Cookies||These cookies are used to collect information about traffic to our website. The information gathered does not identify any individual visitor. The information is aggregated and anonymous. We use this information to help operate our website more efficiently, to gather broad demographic information and to monitor the level of activity on our website.
We may use Google Analytics and other third party analytics services for this purpose. Google Analytics uses its own cookies. It is only used to improve how our website works. You can find out more information about Google Analytics cookies here: https://developers.google.com/analytics/resources/concepts/gaConceptsCookies. You can find out more about how Google protects your data here: www.google.com/analytics/learn/privacy.html.
You can prevent the use of Google Analytics relating to your use of our website by downloading and installing the browser plugin available via this link: http://tools.google.com/dlpage/gaoptout?hl=en-GB.
|Social Media Cookies||These cookies are used when you share information using a social media sharing button or “like” button on our website or you link your account or engage with our content on or through a social networking website such as Facebook, Twitter, or Google+. The social network will record that you have done this.|
Clear GIFs, sometimes called “web bugs” or “web beacons,” are small electronic images that are placed on a web page or in an email message. We use clear GIFs to monitor user behavior, deliver cookies, collect information, count visits, understand usage and campaign effectiveness, and to tell if a recipient has opened and acted upon an email.
Links to Other Websites
Public Forums, Blogs and the Customer Reference Program
Cofense websites may feature bulletin boards, blogs or forums (collectively, “Forums”). Any Personal Data that you choose to submit via such a Forum may be read, collected, or used by others who visit these forums, and may be used to send you unsolicited messages.
Purposes for Collecting Your Information
We will only process your personal data in accordance with applicable data protection and privacy laws. We need certain personal data in order to provide you with access to the website. If you registered with us, you will have been asked to check a box indicating your agreement to provide this data in order to access our services or view our content. This consent provides us with the legal basis we require under applicable law to process your data. You maintain the right to withdraw such consent at any time. If you do not agree to our use of your personal data in line with this policy, please do not use our website. When fulfilling our contractual obligations to our customers (i.e., the data controllers), we have a legitimate interest in processing certain personal data for such contractual purposes.
Use of Information Collected
We may use your information:
- To provide you with personalized content;
- To process and respond to inquiries;
- For the purposes for which you provided the information;
- To improve the content and navigability of our website;
- To alert you about new features, special events and important announcements; and
- To provide the products and services.
In accordance with the Cofense Master Software and Services Agreement or other fully executed agreement between the parties, and as may be required by applicable law, Cofense may access and process Personal Data for the purposes of providing products and services, or preventing or addressing technical problems. We may use Non-Personal Data for any reason and may share such information freely with third parties.
Cofense gives you choices about the ways we collect, use, and share your Personal Data. You can choose what contact and financial information will be stored in your account and preferences. However, if you choose not to provide certain details, some of your experiences with us may be affected.
We do not use your personal data for the purposes of automated decision-making. However, we may do so in order to fulfill obligations imposed by law, in which case we will inform you of any such processing and provide you with an opportunity to object.
If you would like to know what Personal Data we hold about you, you may submit a request to us by using privacy@Cofense.com. We will supply Personal Data about you that we hold in our own files within the reasonable timeframes stipulated by law. Please note that some requests may be subject to a reasonable fee.
Sharing of Information Collected
Cofense will not rent or sell your Personal Data to others but may disclose Personal Data with contracted third-party vendors and service providers (including cloud service providers) that work with Cofense and are contractually bound by confidentiality obligations. We will only share Personal Data with these vendors and service providers to help us provide a product or service to you.
Cofense may also share customer information within our family of companies for a variety of purposes, for example to provide you with the latest information about our products and services and offer you our latest promotions. Cofense primarily stores data about its customers and users in the United States. Customer information, including Personal Data that we collect from you, may be transferred to, stored at and processed by us and our affiliates and other third parties outside the country in which you reside.
If Cofense sells any part of its operations, Cofense may transfer Personal Data in connection with the sale. If a sale does occur, Cofense will attempt to notify you of the disclosure of your Personal Data.
We reserve the right to disclose information by law, litigation, or as a matter of national security to comply with valid legal process including subpoenas, court orders or search warrants, and as otherwise required by applicable law. We may also need to disclose Personal Data in the event of an emergency that threatens an individual’s life, health, or security.
Opt-out. You may contact us anytime to opt-out of: (i) direct marketing communications; (ii) automated decision-making and/or profiling; (iii) our collection of sensitive personal data; (iv) any new processing of your personal data that we may carry out beyond the original purpose; or (v) the transfer of your personal data outside the EEA. Please note that your use of the websites may be impacted upon opt-out.
Access. You may access the data we hold about you at any time by contacting us directly.
Amend. You can also contact us to update or correct any inaccuracies in your personal data.
Move. Your data is portable – i.e. you to have the flexibility to move your data to other service providers as you wish.
Erase and forget. In certain situations, for example when the data we hold about you is no longer relevant or is incorrect, you can request that we erase your data.
Security of all information is of the utmost importance for Cofense. Cofense uses reasonable administrative, technical and physical safeguards to protect the security of your Personal Data from unauthorized disclosure. We also try to ensure that only necessary people and third parties have access to Personal Data. Nevertheless, such security measures cannot prevent all loss, misuse or alteration of Personal Data and we are not responsible for any damages or liabilities relating to any such incidents to the fullest extent permitted by law. Where required under law, we will notify you of any such loss, misuse or alteration of Personal Data that may affect you so that you can take the appropriate actions for the due protection of your rights. Cofense also reviews its security procedures periodically to consider appropriate new technology and updated methods.
We require that our third-party service providers and channel partners agree to keep all confidential information we share with them and to use the information only to perform their obligations in the agreements we have in place with them. While we provide these third parties with no more information than is necessary to perform the function for which we engaged them, any information that you provide to these third parties independently is subject to their respective privacy policies and practices.
Data Retention and Storage
Cofense retains your information for business purposes, for as long as your account is active, and/or as long as is reasonably necessary to provide you with our products and services. Cofense will also retain your information as reasonably necessary to comply with our legal obligations, resolve disputes and enforce our agreements. We may also retain cached or archived copies of your information for a reasonable period of time
Location of Data Processing/Storage
Any Personal Data collected about EU (and UK and/or Switzerland) visitors via our websites is processed in the United States by Cofense or by a third party acting on our behalf. When you provide Personal Data to Cofense, you consent to the processing of your information in the United States. Our websites are hosted in the United States.
We comply with the EU-US Privacy Shield Principles regarding the collection, use, and retention of personal information transferred from the European Union and the United Kingdom and/or Switzerland, as applicable, to the United States.