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COFENSE PRIVACY POLICY

Updated December 26, 2019

 This Privacy Policy describes how Cofense Inc. and its subsidiaries and
affiliates (collectively “Cofense” “our,” “we” or “us”) collects, uses,
discloses, stores and otherwise processes information when you use our public
websites.

By providing your Personal Data (defined below) to Cofense, you agree that you
are authorized to provide that information and are accepting this Privacy Policy
and any supplementary privacy statement that may be relevant to you. If you do
not agree to our practices, please do not register, subscribe, create an
account, or otherwise interact with our websites.

Cofense may review and update this Privacy Policy periodically without any prior
notice. Cofense will post a notice to its main website at www.cofense.com to
inform you of any changes to our Privacy Policy and indicate when it was most
recently updated. Your continued use of our websites after changes have been
posted to this Privacy Policy will constitute your acceptance of such changes.
In the case of material changes that may adversely affect you, Cofense may
notify you directly of changes to this Privacy Policy.


INFORMATION COLLECTED

This Privacy Policy applies to Personal Data and other information collected by
Cofense or its service providers from or about visitors to, or users of, Cofense
websites. For purposes of applicable data protection legislation, Cofense Inc.
located at 1602 Village Market Blvd SE suite 400, Leesburg, VA 20175 is the data
controller of your Personal Data when you submit it on our website or we
otherwise collect it directly from you by your use of our websites.

This Privacy Policy does not apply when we receive personal data from customers
of our phishing defense products and services. In such instances, we are a data
processor and our fully executed agreements (including data protection
agreements) with our customers will apply to our processing of such personal
data.

The term “Personal Data” in this Privacy Policy refers to information that does
or is capable of identifying you as an individual. Personal Data may include the
following: name, address, date of birth, and contact data (i.e. email address,
telephone number and employer name).

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


WEBSITE

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.


EMAIL COMMUNICATION

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

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

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.


SOCIAL MEDIA

Our websites may contain social media features. These features may collect your
IP address, the pages visited on our site, and may set a cookie to enable the
feature to function properly. Social media features and widgets are either
hosted by a third party or hosted directly on our site. Your interactions with
these features are governed by the privacy policy of the organization providing
it.


LINKS TO OTHER WEBSITES

Our websites, products or services may link to third party web websites, and
Cofense is not responsible for any Personal Data collected by these third-party
websites. Information collected is governed through the third party’s website’s
privacy policy. Any interactions you have with these web websites, or any
services or applications they offer, are beyond the control of Cofense. When you
post information to or through such services, those websites’ privacy policies
and cookie usage policies apply directly. We urge you to read the privacy and
security policies of any third-party websites before providing any Personal Data
while accessing those 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; and
 * To alert you about new features, special events and important announcements

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 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.

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.


INDIVIDUAL RIGHTS

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.

Delete. You can request that we erase your Personal Data.


SECURITY

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.


CALIFORNIA PRIVACY RIGHTS

If you are a California Resident, the California Consumer Privacy Act of 2018
(“CCPA”) may give you certain rights relating to your personal information.
Please visit the California Attorney General’s privacy laws page
located here for more information.

At points throughout our website, you may be able to provide your contact
information. If you provide your contact information, we will maintain that
information until you request that we delete it. If you want us to delete your
contact information, please email us from the email address you provided
originally. Cofense will not discriminate against you for exercising your
privacy rights.

Cofense does not sell any Personal Information (as defined in the CCPA) to third
parties, and has not done so in the previous 12 months.


CONTACT

Our data protection officer is our Chief Privacy Officer. If you have any
questions, concerns, or suggestions regarding this Privacy Policy, or would like
to reach our data protection officer, please contact us by email
at privacy@Cofense.com.

Cofense Headquarters
1602 Village Market Blvd. SE
#400
Leesburg, VA 20175
Tel: 1-888-304-9422

1602 Village Market Blvd, SE #400
Leesburg, VA 20175

(888) 304-9422

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