Securonix Privacy Policy December 2020

Effective Date December 1, 2020 to August 19, 2021

This privacy policy applies to Securonix, Inc., www.securonix.com, and Securonix Cloud service, which is owned and operated by Securonix, Inc. This privacy statement describes how Securonix (‘Securonix”, ‘we’, ‘us’ or ‘our’) collects and uses information, including personally identifiable information (“Personal Information”) collected from users of our website www.securonix.com (the “Website”) and our Services (collectively, “Services”). It also describes the choices available to you regarding our use of your personal information, how you can access and update this information, how Securonix adheres to the Privacy Principles and your rights with respect to them.

Privacy Matters – Securonix never collects private information that is unnecessary for the provision of information, for the completion of a transaction, or for the delivery of products or services. The use of information collected by us is limited to the purpose of providing the service for which you have engaged Securonix. Securonix is committed to uphold the privacy principles articulated in the EU-U.S. Privacy Shield (“Privacy Principles”).

IMPORTANT NOTE FOR EUROPEAN USERS AND CUSTOMERS

Please note that information covered by this Privacy Policy will be hosted and stored in the United States of America, where data protection laws differ from the European Union and therefore, law enforcement agencies in the United States may have access to your Personal Information.

EU-U.S. Privacy Shield and Swiss-U.S. Privacy Shield

Securonix (its affiliates, and its subsidiary companies) participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework.  Securonix is committed to subjecting all personal data received from European Union (EU) member countries and Switzerland, in reliance on the Privacy Shield Framework, to the Framework’s applicable Principles.  To learn more about the Privacy Shield Frameworks, and to view our certification, visit the U.S. Department of Commerce’s Privacy Shield List.

Securonix is responsible for the processing of personal data it receives, under the Privacy Shield Framework, and subsequently transfers to third parties acting as an agent on its behalf.  Securonix complies with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions.

With respect to personal data received or transferred pursuant to the Privacy Shield Framework, Securonix is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Securonix may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please see the Independent Recourse Mechanism Section, below.

Information We Collect and Purpose of Collection

We are the sole owners of the information collected through our Services. We only have access to and/or collect information that you voluntarily provide. We do not sell or rent this information to anyone.

Information Provided to Us

• Contact and Registration Information – e.g. first and last name, email address, mailing address, account name, mobile number to issue accounts for access to our online services or respond to requests (e.g., for marketing materials from our website).

Information Present in Data Uploaded to our Service

• Personal or Confidential Data in Log Files –We do not access information present in logs/files that you upload to the Securonix Cloud service. We provide security, privacy controls, and audit controls to allow you to securely manage your information.

Information We May Collect

• Marketing Data – We (or third-parties acting on our behalf) may collect Information, including Personal Information, when providing the Services and via public databases, joint marketing partners, social media platforms, conference hosts, event companies, and other third-parties. We use the information to send marketing communications, educational materials or information about special offers or upcoming online or offline events, invitations to participate in various promotional activities, webcasts, sweepstakes, usability studies, campaigns, surveys and product tests, and to assess their effectiveness.
• Data From the Service (Usage and Analytics) – We collect and process usage data (e.g., ingest volume, search concurrency, number of unique user logins, apps loaded, operating system, internet protocol address, source type (count), session duration and other use and diagnostic data) (“Usage Data”) in order to enforce licensing, maintain, improve, diagnose, and fix technical issues, monitor security of our environment and to personalize our service. In addition, we collect and process anonymized, aggregated data about a group or category of Services, features or users in order to improve the performance of our Services (“Analytics Data”). For example, Analytics Data may include anonymized Usage Data, information about the server environment (e.g., OS type/version, CPU type/version, database type/version, disk utilization), information about the devices operating the Services (e.g., browser type/version, OS type/version, device type/version), or such other similar information about user configuration or operation of Service features or functionality.

This data includes the following elements of personal information:

Information we collect directly from you: We receive Personal Data directly from you when you provide us with such Personal Data, including without limitation the following:

First and last name
Company name and job title
Email address
Mailing address
Telephone number
Credit/debit card and other payment information

Some Personal Data is automatically collected when you use our Services or browse our website, such as the following:

IP address
Device identifiers
Web browser information
Page view statistics
Browsing history
Usage information and click tracking
Transaction information (e.g. transaction amount, date and time such transaction occurred)
Cookies and other tracking technologies (see below for more information)

Customer Consent, Options and Obligations

Consent for Collection Required – The collection of private information of prospects, customers, and others with whom Securonix does business, is customary and is permissible via online or offline consent. Securonix does not collect private information from prospects or customers without their knowledge or consent.

Opting Out from Unsolicited Contacts – You have options regarding access, use and disclosure of their Personal Information for marketing purposes. We do not share your personal information with anyone without your consent. We will give you an opportunity to choose whether your Personal Data may be used for a purpose that is materially different from the purposes for which it was originally collected. To review, correct, or update personal information contact [email protected].  Request are processed as soon as reasonably practicable, consistent with applicable law.

You can Opt-Out of email marketing using the Opt-Out link in our email communications. You may also contact us at the marketing email address above and request that your Personal Information be removed If you do not wish to be contacted through unsolicited direct mail, telemarketing, and related promotions.

Consent – By using the Services, you agree to be bound by the terms and conditions of this Privacy Policy. You can visit the Site without providing any Personal Information. If you choose not to provide any Personal Information you may not be able to use certain Services.

Sensitive Information – You agree to not forward or disclose to us any sensitive Personal Information (e.g., information related to racial or ethnic origin, political opinions, religion or other beliefs, health, criminal background, or trade union membership) or any protected health information as defined by the Health Insurance Portability and Accountability Act of 1996 (otherwise known as “HIPAA”) Standards for Privacy of Individually Identifiable Health Information, as amended, unless otherwise provided in your written agreements with Securonix.

Requesting, Correcting, and Updating Personal Information –   If you wish to verify, correct, update or delete any Personal Information we have collected, you may do so by emailing [email protected]. Requests to access, change, or delete your information will be handled within 30 days. Questions regarding this Policy or the information practices of the Company’s Websites should be directed to Chief Privacy Officer by clicking here or by mailing Securonix, Attn: Legal Department, Office of the General Counsel, 5080 Spectrum Drive, Suite 950W, Addison, Texas, 75001.

By voluntarily providing us with Personal Information, you are consenting to our use of it in accordance with this Privacy Policy. If you provide Personal Information to the Services, you acknowledge and agree that such Personal Information may be transferred from your current location to the offices and servers of Securonix and the authorized third parties.

HR Data

HR Data – HR Data consists of names, titles, contact information, addresses, telephone numbers, fax numbers, email addresses, personal, employee, and/or tax identification number(s), job descriptions, performance evaluations, resumes, qualifications, accolades, disciplinary actions, salary histories, pictures/photos, and sensitive data that may relate to an employee’s health or other sensitive matters, such as information pertaining to an employee’s dependents and family members.

Purpose of HR Data Collection – Securonix collects, uses, and processes HR Data only for the following purposes: (1) determining, evaluating, and implementing employment-related actions and obligations; (2) recruiting and hiring job applicants; (3) performing background checks and verifying references; (4) assessing qualifications; (5) designing, evaluating, and administering compensation, benefits, payroll, training, and other human resource programs; (6) development and training programs; (7) monitoring and evaluating employee conduct and performance; (8) implementing security programs and policies; (9) maintaining facility and employee security, health, and safety; (10) maintaining a global directory; (11) other general human resources purposes, including but not limited to team-building; (12) collecting and conducting accounting, auditing, and financial transactions and analyses; (13) collecting and storing information in compliance with contractual and legal obligations; (14) carrying out obligations under employment contracts, and employment, tax, and benefits laws, in connection with working relationships or arrangements; (15) facilitating business communications, negotiations, and transactions, including but not limited to employee communications and employee surveys; (16) fulfilling our business or contractual obligations; (17) managing and operating any Securonix  Company(ies) and its/their functions and activities; (18) cooperating with law enforcement and other governmental agencies; and (19) the purposes stated, above.

Email Monitoring – We may randomly monitor any job-related emails sent to and from our employees and other personnel. The information such emails contain (which may include personal data relating to third parties) may be used when investigating incidents. Although we endeavor not to review the contents of personal emails, there may be occasions in which this is necessary, for example, to investigate a breach of security or to investigate a disciplinary matter (but any such review will always be in compliance with applicable law).

Notification – EU employees are notified in detail regarding how their HR Data will be processed and used at the time of their employment.  Before using an EU employee’s HR Data for any purpose other than described above, affirmative consent from such employee will be obtained. Such consent may be declined or withdrawn at any time; provided, however, that HR Data will be retained in the manner and for the time-periods required under applicable laws and regulations.

Access/Disclosure – HR Data may be accessed by other employees of Securonix only as necessary for legitimate human resources or business functions or issues. HR Data will be disclosed to third parties only as follows: (1) to customers, vendors, suppliers, and partners as required to facilitate the operations, management, and business of Securonix; (2) to those retained by Securonix as Agents for the purposes set forth in the paragraph above, including but not limited to, professional advisors such as accountants and lawyers, (3) as required pursuant to an applicable law, governmental or judicial order, or regulation, or to protect the rights or property of Securonix, (4) as authorized in writing by the EU employee, and (5) where such Data is voluntarily provided by an EU employee in a context that makes it clear that such information will be provided to a third party.

EU employees may, for legitimate HR purposes, disclose Personal Data about their family members.  In this event, such Personal Data shall be treated in accordance with this Policy as though such Data is HR Data.

Transfer – Where HR Data is transferred to the U.S. from the EU in the context of an employment relationship, Securonix will cooperate with investigations by and comply with the advice of the appropriate EU authorities, as applicable.

How We Share Your Information

We share your personal information with third parties only in the ways that are described in this Privacy Policy. We never disclose specific information about customer accounts, transactions, or relationships to unaffiliated third parties for their independent use, except under special circumstances. These circumstances are limited to the disclosure of information to a reputable information reporting agency such as a credit bureau, those circumstances when the customer requests the disclosure, the disclosure is required by or permitted by law, or the customer has been informed about the possibility of such a disclosure for marketing or similar purposes, and has been given an opportunity to decline.

Securonix may disclose Information to third parties in the following ways:

Affiliates. We may disclose Information to our affiliates subject to these obligations. Securonix Inc. is the party responsible for the management of jointly-used Personal Information.

Service Providers. We may disclose Information to our third-party service providers, vendors, or others who provide services for Securonix’s business operations. This may include such things as infrastructure, data analysis, order fulfillment, IT services, customer service, professional services or audit services, among others.

Partners and Resellers. We may disclose Information to third-parties, including our strategic partners and resellers to permit them to assess your interest in the Services, conduct user research and surveys, or send you marketing communications, subject to the terms of their privacy policies.

Compliance and Safety. We may disclose Information as necessary or appropriate under applicable laws (including laws outside your country of residence) to: comply with legal process or requirements, including applicable notification obligations; respond to requests from public and government authorities (including public and government authorities outside your country of residence); enforce our terms and conditions; and protect our operations or those of any of our affiliates and our rights, privacy, safety, or property, and/or that of our affiliates, you or others.

Merger, Sale, Etc. We may disclose Information in the event of a proposed or actual reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of Securonix business, assets or stock (including in connection with any bankruptcy or similar proceedings).

Other Users. We may disclose Personal Information to other users of the Service in aggregated format, provided it does not include Personal Information. This may include “best practices” tips, performance benchmark data or other such aggregated information useful to the user community. This aggregate information does not identify you, personally.

How We Secure Your Information

• The security of your personal information is important to us. It is your responsibility to ensure that the Information you provide to us can be legally collected in the country of origin, transmitted to us and maintained or used by us.
• We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once we receive it. No method of transmission over the internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security. If you have any questions about security on our website, you can contact us at [email protected].
• If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please notify us immediately in accordance with the “Contact Securonix” section below.
• If Securonix learns of a breach of its systems, Securonix may notify you or others consistent with applicable law and as agreed. By using the Services or providing Personal Information to Securonix, you agree that Securonix may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Services and the Information.
• While, we always secure all stored data using encryption at rest and secure communication in and out of our Service environment using SSL/TLS encryption, it is your responsibility to ensure that any personal or confidential Information uploaded to the Service is appropriately secured from unauthorized viewing using the security and privacy controls provided within our service, such as role based access controls, data masking, and regular monitoring of the audit logs.

Cookies

Technologies such as: cookies, beacons, tags and scripts are used by Securonix and our partners for marketing automation, demand marketing and web analytics partners. These technologies are used in analyzing trends, administering the site, tracking users’ movements around the site and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis.

We use cookies in our login form, to remember users’ settings (e.g. language preference), for authentication. Users can control the use of cookies at the individual browser level. If you reject cookies, you may still use our site, but your ability to use some features or areas of our site may be limited.

Do Not Track

Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

Securonix Also Observes the Following Practices

Retention Period. We will retain your Personal Information for the period necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or not prohibited by applicable law.

Use of Services by Minors. The Services are not directed to individuals under the age of thirteen (13) or those not of the age of majority in your jurisdiction, and we request that these individuals do not provide Personal Information through the Services. If you are under 13, do not use or provide any information on the Website or Services or on or through any of their features, make any purchases through the Website or Services, use any of the interactive or public comment features of this Sites or provide any information about yourself to us, including your name, address, telephone number, e-mail address or any screen name or user name you may use. If you believe we might have any information from or about a child under 13, please contact us at [email protected] and we will delete that information immediately.

Cross-Border Transfers. Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using any of our Services, you consent to the transfer of Information to countries outside of your country of residence, including to the United States, which may have different data protection rules than in your country. It is your responsibility to ensure that the Information you provide to us can be legally transferred to the United States or another country.

Notification of Privacy Policy Changes

We may change this Privacy Policy from time to time. If we change our Privacy Policy, we will post an updated privacy policy, and it will become effective as of the date of posting (“Effective Date”). We encourage you to periodically review this page for the latest information on our privacy practices. Your use of the Services following these changes means that you accept the revised Privacy Policy.

Privacy Shield Recourse Mechanism

In compliance with the Privacy Shield Principles, we commit to resolve complaints about our collection or use of Personal Data.  Individuals with inquiries or complaints regarding this Policy should first contact Securonix by emailing us at [email protected]

We will respond to any inquiry or complaint within 45 days of receipt.

There are readily available independent recourse mechanisms to investigate and expeditiously resolve disputes and complaints if a timely acknowledgment of a complaint is not received from us, or if we have not resolved a complaint. The proper independent recourse mechanism to use depends upon the type of Personal Data at issue:

Non-HR – Data

With regard to unresolved Privacy Shield Complaints regarding Business Contact Data, Securonix has committed to refer those to the American Arbitration Association (AAA)’s International Centre for Dispute Resolution®/AAA Program (the “ICDR/AAA Program”) at www.icdr.org/privacyshield, an alternative dispute resolution provider located in the United States. If timely acknowledgment of a complaint is not received from us, or if we have not resolved a complaint, please contact or visit http://go.adr.org/privacyshield.html for more information or to file a complaint.

The services of ICDR/AAA are provided at no cost to you and by reference to the Principals. Damages may be awarded in accordance with applicable law or private-sector initiatives.

Individuals have the possibility, under certain conditions, to invoke binding arbitration for complaints regarding Privacy Shield compliance not resolved by any other Privacy Shield mechanisms.  Please visit Annex I for additional information:  ANNEX I.

HR Data

For human resources data of EU residents  Securonix has committed to cooperate with the dispute resolution procedures and the panel established by the EU Data Protection Authorities (DPAs) and Swiss Federal Data Protection and Information Commissioner (FDPIC) , and comply with the information and advice provided to it by an informal panel of DPAs in relation to such unresolved complaints (as further described in the Privacy Shield Principles).

Contact Securonix

If you have any questions or comments about this Privacy Policy, the information practices of the Services, or your dealings with Securonix, you can contact us at any time:

Securonix, Inc.
Attention: Legal Department-Privacy
5080 Spectrum Drive

Suite 950W
Addison, Texas 75001
[email protected]

Important Information for California Residents

This section applies only to California residents. It describes how we collect, use and share Personal Information of California residents in operating our business, and their rights with respect to that Personal Information. For purposes of this section, “Personal Information” has the meaning given in the California Consumer Privacy Act of 2018 (“CCPA”) but does not include information exempted from the scope of the CCPA.

Your California privacy rights. As a California resident, you have the rights listed below. However, these rights are not absolute and, in certain cases, we may decline your request as permitted by law.

• Information. You can request the following information about how we have collected and used your Personal Information during the past 12 months:
  • The categories of Personal Information that we have collected.
  • The categories of sources from which we collected Personal Information.
  • The business or commercial purpose for collecting and/or selling Personal Information.
  • The categories of third parties with whom we share Personal Information.
  • Whether we have disclosed your Personal Information for a business purpose, and if so, the categories of Personal Information received by each category of third party recipient.
  • Whether we’ve sold your Personal Information, and if so, the categories of Personal Information received by each category of third party recipient.
  • California Civil Code Section § 1798.83 (“Shine the Light”) permits users of our Services that are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes.

• Access. You can request a copy of the Personal Information that we have collected about you during the past 12 months.
• Deletion. You can ask us to delete the Personal Information that we have collected from you.
• Opt-out of sales. If we sell your Personal Information, you can opt-out. In addition, if you direct us not to sell your Personal Information, we will consider it a request pursuant to California’s “Shine the Light” law to stop sharing your personal information covered by that law with third parties for their direct marketing purposes.
• Nondiscrimination. You are entitled to exercise the rights described above free from discrimination. This means that we will not penalize you for exercising your rights by taking actions such as denying you services; increasing the price/rate of services; decreasing service quality; or suggesting that we may penalize you as described above for exercising your rights.

How to exercise your rights

You may exercise your California privacy rights described above as follows:

• Right to information, access and deletion. You can request to exercise your information, access and deletion rights by:
  • Calling us toll free at: 1- (855) 732-6649
  • Emailing to: [email protected]
  • Mailing us at: Securonix, Inc., 5080 Spectrum Drive, Suite 950W, Addison, Texas 75001.
• Right to opt-out of the “sale” of your Personal Information. Like many companies, we may use services that help deliver interest-based ads to you. In some instances, California law classifies our use of these services as a “sale” of your Personal Information to the companies that provide the services. This is because we allow them to collect information from our website users (e.g., online identifiers and browsing activity) so they can help serve ads more likely to interest you. You can request to opt-out out of this “sale” of your personal information here: Do Not Sell My Personal Information.

Please note that the CCPA limits these rights by, for example, prohibiting us from providing certain sensitive information in response to an access request and limiting the circumstances in which we must comply with a deletion request. If we deny your request, we will communicate our decision to you.

Personal information that we collect, use and share

With respect to most commercial transactions, our business acts solely as a processor, merely processing personal information provided to us by our customers (i.e. the controllers) and returning the results to them. In those instances, we will not use or share any personal information provided by our customers with third parties except as authorized by law and this policy.

However, in some instance, such as where we collect personal information from employees or business-to-business (B2B) contacts, we may share personal information with eligible service providers under the CCPA who provide us with valuable services and have committed not to share personal information with unauthorized third parties. The chart below summarizes how we collect, use and share Personal Information by reference to the statutory categories specified in the CCPA, and describes our practices during the 12 months preceding the effective date of this Privacy Policy. Categories in the chart refer to the categories described above in the general section of this Privacy Policy. We disclose the following Personal Information to business transferees: