SCADAfence Privacy Policy

We at SCADAfence Ltd. (“SCADAfence” “us”, “we”, or “our”) recognize and respect the importance of maintaining the privacy of our customers. This Privacy Policy describes the types of information we collect from you when you visit our website and/or use our cybersecurity and visibility solutions (respectively, the “Site” and “Solution”). This Privacy Policy also explains how we may process, transfer, store and disclose the information collected, as well as your ability to control certain uses of the collected information. If not otherwise defined herein, capitalized terms have the meaning given to them in the Terms of Use, available at www.scadafence.com (“Terms”).

SCADAfence is the data controller in respect of the processing activities outlined in this Privacy Policy. Our registered office is 4 Menorat Hamaor Street, Tel-Aviv, 6744832 Israel and our registration number 515136612.

“Personal Data” means any information that refers, is related to, or is associated with an identified or identifiable individual or as otherwise may be defined by applicable law.

Privacy Policy Key Points

The key points listed below are presented in further detail throughout this Privacy Policy. These key points do not substitute the full Privacy Policy.

• Personal Data We Collect. When you schedule a demo or contact us with questions we collect Personal Data provided by you, such as (but not limited to) your name, email address, the company you work for and your country. We also (automatically) collect information about your use of the Site. When you use the Solution we scan and monitor your systems. The Solution monitors applicable network and communication traffic, including the parties to any communication, the applicable protocol and the duration of the communication (“Network Data”). Network Data is your confidential information. We shall use such Network Data to provide services through the Solution, but shall otherwise not use or disclose Network Data except as set forth herein. We do not intend that any Network Data contain personally identifiable information. If you believe that Network Data contains personally identifiable information, you shall obtain all necessary consents from your users to allow us to use and store the Network Data as set forth herein. In the future, and only following reasonable prior notice to you, we may compile data from our users (“Statistical Information”). Statistical Information is anonymized and does not, in and of itself, identify any client or individual end user. Statistical Information helps understand trends and customer needs so that new services can be considered and so the Solution and associated technology and services can be tailored to customer desires. We may also share Statistical Information with our partners, pursuant to commercial terms that we determine in our sole discretion. If you contact us for questions or complaints, we will collect the information related to your inquiry.
• How We Use the Information We Collect. We use the information (including Personal Data) we collect mainly to administer and provide the Solution and the Site, contact you with administrative information, contact you with marketing offers (if you indicated your desire to receive them), and improve the Solution and Site.
• Basis for Processing Your Personal Data. Processing your Personal Data is necessary for the performance of the Terms and the provision of the Solution to you. Processing the information for marketing purposes is based upon your consent. Processing for the purposes of developing and enhancing our products and services, for analytics and usage analysis, for fraud prevention and security and for our recordkeeping and protection of our legal rights – are all necessary for the purposes of legitimate interests that we pursue.
• Sharing the Personal Data We Collect. We may share the Personal Data we collect with our service providers and subcontractors who assist us in the operation of the Solution and/or Site and process the information on our behalf and under our instructions, as well as with our business partners and affiliates who may offer you products and services, based on your preferences (if you indicated your desire to receive these).
• International Transfer. We may use service providers and/or subcontractors and/or cooperate with or have business partners and affiliates located in countries other than your own, and send them your Personal Data. We will ensure to have agreements in place with such parties ensuring the same level of privacy and data protection as set forth in this Privacy Policy. You hereby consent to such international transfer.
• Your Rights. Subject to applicable law and additional rights as set forth below, you may have the right request to access, update and/or delete your Personal Data and obtain a copy of the Personal Data we have collected about you. You can change your mind at any time about your election to receive marketing communications from us and/or having your Personal Data processed for direct marketing purposes. You may do so by Unsubscribing from our mailing list, from a link available at the bottom of all our emails. You also have the right to object at any time to processing your personal data for marketing purposes.
• Use of Cookies and Similar Technologies. We use cookies and similar technologies to help personalize your experience. You can adjust your settings to determine which cookies you do or do not allow. Changing your settings and/or deleting existing cookies may affect the Services.
• Retention. We retain information for as long as necessary for the purposes set forth in this Privacy Policy.
• Security. We implement industry standard measures aimed at reducing the risks of damage and unauthorized access or use of Personal Data, but they do not provide absolute information security.
• Changes to the Privacy Policy. We may change this Privacy Policy from time and shall notify you of such changes.

Information We Collect

We also collect Personal Data when you make use of the Solution and/or Site, request information from us, sign up for newsletters or our email lists, complete online forms, or contact us for any other reason.

Examples of the Personal Data that we collect from you may include (but not only) your name, email address, the company you work for and your country. Such Personal Data may be collected by us through the Solution and/or Site.

When you use the Solution we scan and monitor your systems. The Solution monitors applicable network and communication traffic, including the parties to any communication, the applicable protocol and the duration of the communication (“Network Data”). We may retain Network Data in order to allow for auditing of cybersecurity events. Network Data is your confidential information. We shall use such Network Data to provide services through the Solution, but shall otherwise not use or disclose Network Data except as set forth herein. We do not intend that any Network Data contain personally identifiable information. If you believe that Network Data contains personally identifiable information, you shall obtain all necessary consents from your users to allow us to use and store the Network Data as set forth herein. We will fully cooperate with any law, law enforcement authorities or court order requiring the disclosure of Network Data. We may disclose or transfer data and information in the event of connection with a merger or acquisition sale of all or part of our business, or in the event of an insolvency, bankruptcy, or receivership in which information shall be transferred to one or more third parties under the applicable laws. In the future, and only following reasonable prior notice to you, we may compile data from our users (“Statistical Information”). Statistical Information is anonymized and does not, in and of itself, identify any client or individual end user. Statistical Information helps understand trends and customer needs so that new services can be considered and so the Solution and associated technology and services can be tailored to customer desires. We may also share Statistical Information with our partners, pursuant to commercial terms that we determine in our sole discretion.

In addition, when you use the Site, certain information may be automatically gathered about your computer or mobile device, such as operating system, IP address, device ID, and subject to your consent as may be required under applicable law, (geo) location, as well as your browsing history and any information regarding your viewing and purchase history on our Site.

It is your voluntary decision whether to provide us with any such Personal Data, but if you refuse to provide such information we may not be able to register you to the Solution and/or Site and/or provide you with the services.

How We Use Your Personal Data

General
We and any of our trusted third-party subcontractors and service providers may use the Personal Data we collect from and about you for any of the following purposes: (1) to provide you with the Site and/or Solution; (2) to respond to your inquiries or requests, contact and communicate with you; (3) to develop new products or services and conduct analyses to improve our current content, products, and services; (4) to provide you with customized content, targeted offers, and advertising on the Site, on other third-party sites or apps you may visit, or via e-mail; (5) to contact you with informational newsletters and promotional materials relating to our Site and/or Solution; (6) to review the usage and operations of our Site and/or Solution; (7) to use your data in an aggregated, non-specific format for analytical purposes (as detailed below); (8) to prevent fraud, protect the security of our Site and/or Solution, and address any problems with the Site and/or Solution and (9) to provide customer support.

Statistical Information
By analyzing all information we receive, including all information concerning users, we may compile statistical information across a variety of platforms and users (“Statistical Information”). Statistical Information helps understand trends and customer-needs so that new products and services can be considered and so existing products and services can be tailored to customer desires. Statistical Information is anonymous and aggregated and we will not link Statistical Information to any Personal Data. We may share such Statistical Information with our partners, without restriction, on commercial terms that we can determine in our sole discretion.

Analytics
We, or our service providers or subcontractors, may use analytics tools (“Tools”), including “Google Analytics”, marketing automation platforms or any other tools in order to collect information about the use of the Site. Such Tools collect information such as how often users visit the Site, what pages they visit when they do so, and what other sites and mobile applications they used prior to visiting the Site. [The Tools may collect certain Personal Data, and may link such Personal Data to specific information stored in our customer database]. We use the information we get from the Tools to improve our Site and services. Google’s ability to use and share information collected by Google Analytics about your visits to this site is restricted by the Google Analytics Terms of Use located at http://www.google.com/analytics/terms/us.html and the Google Privacy Policy located at http://www.google.com/policies/privacy/.

Legal Uses
We may use your Personal Data as required or permitted by any applicable law.

Disclosure of Information

We may share your information, including Personal Data, as follows:

Business Partners, Service Providers, Affiliates, and Subcontractors
We may disclose information, including Personal Data we collect from and/or about you, to our trusted service providers, business partners, affiliates, subcontractors, who may use such information to: (1) help us provide you with the Site and/or Solution; (2) aid in their understanding of how users are using our Site and/or Solution; (3) when you have consented to such disclosure, provide to you targeted offers and advertising on both our App/Solution/Site, as well as on other apps/platform/sites you choose to visit.

International Transfer
We may use subcontractors and service providers and have business partners and affiliates who are located in countries other than your own and send them information we receive (including Personal Data). We will ensure that these third parties will be subject to written agreements ensuring the same level of privacy and data protection as set forth in this Privacy Policy. You hereby consent to such international transfer.

Business Transfers
We may transfer our databases containing your Personal Data if we sell our business or part of it, including in cases of liquidation. Information about our users, including Personal Data, may be disclosed as part of, or during negotiations of, any merger, sale of company assets or acquisition and shall continue being subject to the provisions of this Privacy Policy.

Law Enforcement Related Disclosure
We will fully cooperate with any law enforcement authorities or court order requesting or directing us to disclose the identity, behavior or (digital) content and information of or related to an individual, including in the event of any user suspected to have engaged in illegal or infringing behavior. We may also share your Personal Data with third parties: (i) if we believe in good faith that disclosure is appropriate to protect our rights, property or safety (including the enforcement of the Terms and this Privacy Policy); (ii) to protect the rights, property or safety of third parties; (iii) when required by law, regulation subpoena, court order or other law enforcement related issues; or (iv) as is necessary to comply with any legal and/or regulatory obligation. You can request such Personal Data as specified herein by emailing us at privacy@scadafence.com .

How We Protect Information

We make efforts to follow generally accepted industry standards to protect the Personal Data submitted to us, both during transmission and once we receive it. 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 Personal Data, we cannot guarantee its absolute security.

How to Access and Limit Our Use of Certain Information

You have certain rights in relation to the Personal Data that we [or our co-controllers] hold about you, as detailed below. [For any requests to exercise such rights with respect to information held by our co-controllers, please contact the applicable co-controller directly.] We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any information and/or comply with any of your requests, as detailed below:

• Right of Access and Data Portability. You have a right to know what Personal Data we collect about you and, in some cases, to have the information communicated to you. Subject to the limitations in applicable law, you may be entitled to obtain from us a copy of the Personal Data you provided to us (excluding information that we obtained from other sources) in a structured, commonly-used, and machine-readable format, and you may have the right to (request that we) transmit such Personal Data to another party. If you wish to exercise this right please contact us at privacy@scadafence.com letting us know what information in particular you would like to receive and/or transmit. Subject to applicable law, we may charge you with a fee. Please note that we may not be able to provide you with all the information you request, for instance, if the information includes Personal Data about another person. Where we are not able to provide you with information that you have asked for, we will endeavor to explain to you why. We will try to respond to any request for a right of access as soon as possible.
• Right to Correct Personal Data. Subject to the limitations in applicable law, you may request that we update, correct or delete inaccurate or outdated Personal Data and/or that we suspend the use of Personal Data, the accuracy of which you may contest, while we verify the status of that Personal Data. We will correct your Personal Data within a reasonable time from the receipt of your written request thereof.
• Deletion of Personal Data. In certain circumstances you have a right to have Personal Data that we hold about you deleted. Should you wish to have any Personal Data about you deleted, please contact us, using the contact information specified in this Privacy Policy. Subject to applicable law, we will delete Personal Data provided to us by a user within a reasonable time from the receipt of a written (including via email) request by such user to delete such collected Personal Data. We cannot restore information once it has been deleted. Please note that to ensure that we do not collect any further Personal Data, you should also clear our cookies from any device where you have accessed our Site. We may retain certain Personal Data (including following your request to delete) for audit and record-keeping purposes, as well as other purposes, all as permissible and/or required under applicable law. We may also retain your information in an anonymized form.
• Direct Marketing Opt Out. You can change your mind at any time about your election to receive marketing communications from us and/or having your Personal Data processed for direct marketing purposes. If you do, please notify us by contacting us as detailed in this Privacy Policy. We will process your request as soon as reasonably possible, however it may take a few days for us to update our records before any opt out is effective.
• Right to Object. Subject to applicable law, you may have the right to object to processing of your Personal Data including for the purpose of direct marketing.
• Supervisory Authority. If you are a European Citizen, you may have the right to submit a complaint to the relevant supervisory data protection authority.

Data Retention

Subject to applicable law, we retain information as necessary for the purposes set forth above. We may delete information from our systems, without Policy to you, once we deem it is no longer necessary for the purposes set forth in this Privacy Policy.

Cookies and Similar Technologies

We use cookies and similar technologies to help personalize your experience [and to personalize the ads we serve you]. A “persistent” cookie may be used to help save your settings and customizations across visits. Third parties through which we provide the Services and/or our business partners may be placing and reading cookies on your browsers, or using web beacons to collect information in the course of advertising being served on different websites.

Cookies and Similar Technologies

What are Cookies?

A cookie is a small piece of text that is sent to a user’s browser or device. The browser provides this piece of text to the device of the originating user when this visitor returns.
– A “session cookie” is temporary and will remain on your device until you leave the Site.
– A “persistent” cookie may be used to help save your settings and customizations across visits. It will remain on your device for much longer or until you delete it.
– First-party cookies are placed by us, while third-party cookies may be placed by a third party. We use both first- and third-party cookies.
– Information may also be collected through web beacons, which are small graphic images (“pixel tags”), which usually work together with cookies in order to identify users and user behavior. These may be shared with third parties.

We may use the terms “cookies” to refer to all technologies that we may use to store data in your browser or device or that collect information or help us identify you in the manner described above.

How We Use Cookies

We use cookies and similar technologies for a number of reasons, for example, in order to help personalize your experience and to help personalize the ads we serve you.

The specific names and types of the cookies, web beacons, and other similar technologies we use may change from time to time. However, the cookies we use generally fall into one of the following categories:

Type of Cookie Why We Use These Cookies

Necessary These cookies are necessary in order to allow the Site to work correctly. They enable you to access the Site, move around, and access different services, features, and tools. Examples include remembering previous actions (e.g. entered text) when navigating back to a page in the same session. These cookies cannot be disabled.
Functionality These cookies remember your settings and preferences and the choices you make (such as language or regional preferences) in order to help us personalize your experience and offer you enhanced functionality and content.
Security These cookies can help us identify and prevent security risks. They may be used to store your session information to prevent others from changing your password without your login information.
Performance These cookies can help us collect information to help us understand how you use our Site, such as whether you have viewed messages or specific pages and how long you spent on each page. This helps us improve the performance of our Site.
Analytics These cookies help us learn more about which features are popular with our users and how our Site can be improved.
Advertising These cookies are placed in order to delivery content, including ads relevant and meaningful to you and your interests. They may also be used to deliver targeted advertising or to limit the number of times you see an advertisement. This can help us track how efficient advertising campaigns are, both for our own Services and for other websites.

How to Adjust Your Preferences

Most Web browsers are initially configured to accept cookies, but you can change this setting so your browser either refuses all cookies or informs you when a cookie is being sent. In addition, you are free to delete any existing cookies at any time. Please note that some features of the Services may function improperly when cookies are disabled or removed.

[By changing your device settings, you can prevent your device’s ad identifier being used for interest-based advertising, or you can reset your device’s ad identifier. Typically, you can find the ad identifier settings under “privacy” or “ads” in your device’s settings, although settings may vary from device to device.

Adjusting your preferences as described in this section herein does not mean you will no longer receive advertisements, it only means the advertisement you do see will be less relevant to your interests.]

Third Party Cookies

Facebook: Privacy Policy:  https://www.facebook.com/privacy/explanation ; Cookies:  https://www.facebook.com/policies/cookies/

Twitter: Privacy Policy:  https://twitter.com/en/privacy; Cookies: https://help.twitter.com/en/rules-and-policies/twitter-cookies

Google Analytics: Privacy Policy: http://www.google.com/intl/en/analytics/privacyoverview.html

Amazon Web Services: Privacy Policy: http://aws.amazon.com/privacy/

Salesforce: Privacy Policy: http://www.salesforce.com/company/privacy/

Azure: Privacy Policy: https://azure.microsoft.com/en-us/support/legal/

LinkedIn: Privacy Policy: https://www.linkedin.com/legal/privacy-policy; Cookies: https://www.linkedin.com/legal/cookie-policy

Mailchimp: Privacy policy:  https://mailchimp.com/legal/privacy/; Cookies: https://mailchimp.com/legal/cookies/

The list above may be amended from time to time.

Third-Party Applications and Services

All use of third-party applications or services is at your own risk and subject to such third party’s privacy policies.

Communications

Subject to your consent and applicable law, we may send you e-mail or other messages and/or a newsletter about us or our Services. You may remove your Personal Data from our mailing list and stop receiving future communication from us by following the UNSUBSCRIBE link located at the bottom of each communication or by emailing us at privacy@scadafence.com. You will also be given the opportunity to unsubscribe from commercial messages in any such e-mail or message we send Please note that we reserve the right to send you service-related communications, including service announcements and administrative messages relating to your account, without offering you the opportunity to opt out of receiving them. Should you not wish to receive such communications you may cancel your account.

Children

We do not knowingly collect personally-identifiable information from children under the age of sixteen (16). In the event that you become aware that an individual under the age of sixteen (16) has enrolled without parental permission, please advise us immediately.

Changes

When visiting this Site, you shall be asked to accept the terms of this Privacy Policy. If you do not agree with the terms hereof, please do not use the Site and/or Solution. We may update this Privacy Policy from time to time – [we encourage you to review it periodically. By continuing to access or use the Solution and/or Site after those changes become effective, you agree to be bound by the revised privacy Policy]. We will post the updated Privacy Policy on this page. Please come back to this page every now and then to make sure you are familiar with the latest version. Any new Privacy Policy will be effective from the date it is accepted by you.

Comments and Questions

If you have any comments or questions about our privacy policy, or if you wish for us to amend or delete your Personal Data, please contact us at privacy@scadafence.com.

Last updated: February 27, 2019