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CYBERARK PRIVACY NOTICE



OVERVIEW

This privacy notice (“privacy notice”, “privacy policy” etc.)  describes how
CyberArk will process your personal data, where CyberArk acts as a controller of
your Personal Data; namely, in connection with your use of the CyberArk owned
and operated websites including without limitation www.cyberark.com and any of
its related or subdomains (the “Website(s)“), including the CyberArk portals
(such as Technical Community, Partners Community, Training and Certification
Portal and the Marketplace) (the “Portals“); in connection with certain
instances of your use of CyberArk’s products, services, and other technical
applications and tools (the “Services“), where CyberArk acts as the controller
of your personal data; and in connection with other occasions where CyberArk
collects and processes your Personal Data, as further detailed in this Privacy
Notice.

References to “we”, “us” or “CyberArk” in this statement mean CyberArk Software
Ltd, and any of its affiliated entities, as far as they are related to the
operation of the Websites, the Portals or the Services. Our contact details for
these entities and their respective office locations can be found here. The
CyberArk entity that will be responsible for processing your personal data will
depend on how you use CyberArk Services and your geographical location.

References to “you” or “your” mean the individual who has or may in the future
enter into a relationship with CyberArk as a user of CyberArk mobile
applications (excluding: (i) when you are using CyberArk Mobile on behalf of
your employer or customer; or (ii) CyberArk’s Identity mobile application, in
which case CyberArk will be processing the data on behalf of our customer), a
representative of a prospective or existing customer or authorized channel
partner, a user of our Website or Portals, an investor, or otherwise use the
CyberArk Websites or Services. When you are browsing our Websites or using our
Services for your own benefit, CyberArk is the controller of your personal data,
as such term is used in the GDPR.

If you are an end user of CyberArk Services, this policy does not apply to our
processing of your personal data. The “controller” (as such term is used in the
EU General Data Protection Regulations (“GDPR“)) of your personal data is your
employer or the organization to which you are providing services and which is a
CyberArk customer. CyberArk is the “processor” of such personal data. In such
case, the processing of the personal data by us is subject to a data processing
agreement between the applicable CyberArk entity and such customer, and this
privacy notice does not apply to you.

General

At CyberArk, we pride ourselves on being an organization that has a
privacy-minded culture consistent with legal requirements.

You can contact CyberArk at any time to request more information about the way
we process personal data by using this form or sending an email
to privacy-request@cyberark.com. We will respond to your request in the
timescales prescribed by applicable laws.

WHAT PERSONAL DATA DOES CYBERARK PROCESS AND FOR WHAT PURPOSES?

The following describes the types of personal data that CyberArk processes about
you, in which instances this personal data is collected and processed, the
purposes of processing, and the lawful bases for processing in accordance to
GDPR.

WHEN YOU USE ONE OF OUR WEBSITES

Instance of data collection Personal Data Processed Purposes of Processing
Lawful Bases for processing where the GDPR applies When you browse our Websites
Certain identity information (e.g. names, usernames or similar identifiers)
Information from your Web browser (such as browser type and browser language),
your Internet Protocol (“IP”) address, internet service provider (ISP),
operating system, date/time stamp, and clickstream data and the actions you take
on the Company’s Web sites (such as the web pages viewed and the links clicked)
• Administer our Websites
• Provide you with relevant website content and advertisements
• Measure the effectiveness of the content served to you and of our marketing
efforts
• Analyze the use of the Websites and improve our Websites
• Provide more relevant and personalized information, promote our business in
various platforms and assess the success of our promotional activities
• Fraud prevention and security of our Websites Our legitimate interests in
monitoring and improving our Websites • When you submit a contact form or
request a demo form through the Website
• When you download any whitepapers or other downloadable materials from our
website
• When you subscribe for a free trial First and last name, email address,
telephone number, company name, role, job title, department, and country • To
reply to your request or query
• To set up a demo at your request
• To send the requested materials to you, if requested
• To send you communications related to our products and services, or our events
and webinars, including marketing communications (either by email, postal mail
or telephone) subject to applicable law, for example, where applicable, where
you have provided your consent to be included in our marketing mailing lists Our
legitimate business interests

WHEN YOU USE OUR PORTALS (EITHER AS A REPRESENTATIVE OF A CUSTOMER/PROSPECTIVE
CUSTOMER, CHANNEL/ALLIANCE PARTNER, OR A PROSPECTIVE CHANNEL/ALLIANCE PARTNER

Instance of data collection Personal Data Processed Purposes of Processing
Lawful Bases for processing where the GDPR applies • When you set up an account
in our Portal First and last name, telephone number, mobile phone number,
country, language, email address, job function, organization, address • To set
you up as an authorized user of the Portal and create a user profile for you
• To manage and administer your use of the Portals
• To send you communications related to our products and services, or our events
and webinars, including marketing communications (either by email, postal mail
or telephone) to the extent you provided your consent to be included in our
marketing mailing lists
• To operate our business, for example transmitting your personal data within
the CyberArk group for internal administrative purposes, such as auditing and
accounting Our and/or our customers legitimate business interests • When you log
into and use our Portals Browser type and browser language, referring URL, your
Internet Protocol (“IP”) address, internet service provider (ISP), operating
system, date/time stamp, and clickstream data and the actions you take on the
Portals (such as the web pages viewed the links clicked and any searches
performed) • To provide you with support and training related to the Portals
• To keep records regarding how our partners/customers use the Portals and
analysis thereof for the purpose of monitoring and improvement of Portals
• Measure the effectiveness of the content served to you
• To improve our understanding of your needs and interests as our partner or
customer
• Understand how you and other partners move around the Portals, including to
assess which content is the most useful to our partners/customers
• To send you communications related to our products and services, or our events
and webinars, including marketing communications (either by email, postal mail
or telephone) to the extent you provided your consent to be included in our
marketing mailing lists
• To operate our business, for example transmitting your personal data within
the CyberArk group for internal administrative purposes, such as auditing and
accounting Our and/or our customers legitimate business interests

WHEN YOU DOWNLOAD AND USE CYBERARK MOBILE (EXCLUDING WHEN YOU ARE USING THE
APPLICATIONS ON BEHALF OF YOUR EMPLOYER OR CUSTOMER)

Instance of data collection Personal Data Processed Purposes of Processing
Lawful Bases for processing where the GDPR applies When you set up an account
for use of any of our Services First name, last name, phone number, phone model
and operating system, and, if you choose to provide this, a profile picture • To
allow you access to the services, in accordance with the specific functionality
for which you have access rights and authorizations
• Provide technical support Fulfilment of our contractual obligation • Measure
our marketing efforts and performance
• To operate our business, for example transmitting your personal data within
the CyberArk group for internal administrative purposes, such as auditing
• To notify you about transactional issues, or other issues relating to CyberArk
services (such as new features, version releases) or invitations to our
customers related events Our legitimate business interest

WHEN YOU ATTEND A CYBERARK HOSTED OR SPONSORED PHYSICAL OR VIRTUAL CONFERENCE OR
EVENT

Instance of data collection Personal Data Processed Purposes of Processing
Lawful Bases for processing where the GDPR applies When you register to the
event First and last name, email address, telephone number, company name, role,
job title, department, and country • To set you up as a registered participant
in the event
• To manage and administer your participation in the event
• To send you communications related to the event the event
• To send you communications related to our products and services, or our events
and webinars, including marketing communications (either by email, postal mail
or telephone) to the extent you provided your consent to be included in our
marketing mailing lists
• To operate our business, for example transmitting your personal data within
the CyberArk group for internal administrative purposes, such as auditing and
accounting Fulfilment of our contractual obligation, our legitimate business
interest or consent When you log into the event and during the event in which
you participate (online events) Log in and out time, time spent, any information
that you choose to provide for networking purposes, chat stream Browser type and
browser language, referring URL, your IP address, internet service provider
(ISP), operating system, and clickstream data and the actions you take on the
Portals (such as the web pages viewed the links clicked and any searches
performed) • To manage and enable your access to the event
• To provide you with technical support related to the event
• To keep records regarding our events and analysis thereof for the purpose of
planning of future events
• Measure the effectiveness of our events
• To improve our understanding of your needs and interests
• Understand how you and other participants benefit from the events including to
assess which content is the most useful
• To send you communications related to our products and services, or our events
and webinars, including marketing communications (either by email, postal mail
or telephone) to the extent you provided your consent to be included in our
marketing mailing lists
• To operate our business, for example transmitting your personal data within
the CyberArk group for internal administrative purposes, such as auditing and
accounting Fulfilment of our contractual obligation, our legitimate business
interest or consent During the event in which you participate (in person)
Business card info • To send you communications related to the event the event
• To send you communications related to our products and services, or our events
and webinars, including marketing communications (either by email, postal mail
or telephone) to the extent you provided your consent to be included in our
marketing mailing lists
• To operate our business, for example transmitting your personal data within
the CyberArk group for internal administrative purposes, such as auditing and
accounting Fulfilment of our contractual obligation, our legitimate business
interest or consent

WHEN WE OTHERWISE COMMUNICATE WITH YOU WHEN YOU ARE OR WHEN YOU REPRESENT A
CUSTOMER/PARTNER/INVESTOR

Instance of data collection Personal Data Processed Purposes of Processing
Lawful Bases for processing where the GDPR applies When we request and you
submit feedback to a survey, for example following closing of a support ticket,
delivery of our services or following training; or on a periodic basis Your
responses to the survey • To consider your feedback and assess the level of
service we have provided, and to improve our processes and services
• Follow-up with you depending on the nature of your feedback Our legitimate
business interests To deliver communications to you (including marketing
communications and advertising). Your email address, display name of your email
account, personal information contained or referred to within such electronic
communications, information about opening/clicks/form fills/ consumption of
links/content included in the email, actions that you take on our and our
partners’ websites such as your visits or interactions with such websites. • To
monitor electronic communications sent or received by our users, including to
gain insights on interactions we have with you to tailor our communications
accordingly and measure our marketing efforts
• Security and fraud prevention
• To cater to your requests, for example, to reply to your inquiry, arrange a
meeting for you, arrange a demo for you etc.
• Measure the effectiveness of our (online) advertising, improve our marketing
practices, and helps us deliver more relevant communications and advertising to
you and people like you (including on social media). Our legitimate business
interests and/or your consent where required under applicable law.

In addition to the above, under some circumstances we may collect and process
other types of personal data; in these cases, we will provide and in-time
notification with respect to the additional personal data collected and
processed.

In addition to the above uses of your personal data, we will also process your
personal data for the following purposes:

 1. To prevent, detect and fight fraud or other illegal or unauthorized
    activities
 2. To ensure legal compliance – from our side (to legal requirements that apply
    to us (such as various records keeping) and to our obligations under the
    Terms of Use) and from your side (Compliance with laws applicable to you and
    with the Terms of Use)

For some of the above processing, we may rely on multiple legal grounds. For
example, we process some information both for our legitimate interests as a
business regarding user compliance with applicable terms of use and to comply
with legal obligations applying to us (GDPR Article 6(1)(f) and 6(1)(c)).

HOW WILL CYBERARK SHARE YOUR PERSONAL DATA WITH THIRD PARTIES?

We may share your personal data with third parties as follows:

 * Where we use third party service providers or subcontractors to outsource
   certain tasks or processes whether in relation to the Website operation, the
   Services, or our internal requirements, such as audit or security
   requirements. We use the following categories of service providers:
   relationship management software providers, marketing automation platform
   providers, webinar software providers, email platforms, Website hosting
   providers, customer success software providers, online community platform
   providers, learning management system software providers, human resources
   information system provider (Workday) and our background check service
   providers; analytics providers, customer reference management software
   providers, hosting provider (currently Amazon Web Services), our online
   community platform provider, customer success software provider, survey tool
   service providers, calendar scheduling tool providers, accounting and payment
   management system providers. These service providers are authorized to use
   our personal data only as necessary to provide these services to us.
 * We may also share your personal data with our partners when we run or sponsor
   events with them and with social media and/or advertising companies to
   personalize our communications and your experience on our and other websites.
 * Where you are a member of staff at a CyberArk Customer or Partner and you
   register for a CyberArk event, this information may be shared with that
   Customer or Partner.
 * We may use or disclose personal data if required by applicable law or if we
   reasonably believe that use or disclosure is necessary to protect our rights,
   protect your safety or the safety of others, investigate fraud and/or to
   comply with a judicial proceeding, court order, legal process or other
   governmental authority; provided, however, that unless prohibited by law, we
   will use reasonable efforts to give you notice to enable you to seek a
   protective order or take other appropriate action.
 * We will also disclose your information to third parties in and outside your
   country only to the extent allowed by applicable law, if we sell, buy, merge
   or partner with other companies or businesses, undergo a reorganization,
   bankruptcy, or liquidation; or otherwise undertake a business transaction or
   sell some or all of our assets. In such transactions, your information may be
   among the transferred assets.

PROCESSING DATA OUTSIDE OF EUROPEAN ECONOMIC AREA (“EEA”)

We may store, process and/or transfer personal data to countries outside of the
EEA (including countries where the European Commission has not made a decision
of an adequate level of protection of personal data), especially to servers in
the United States and in Israel but not only. The transfer of such data will be
in compliance with local legislation for the cross-border transfer of data,
where applicable. The safeguards we deploy for performing such transfers across
boundaries:

 * We transfer the data, including personal data, to our offices located in
   Israel and process it there. Any transfers to Israel may be made on the basis
   of an adequacy decision made by the European Commission.
 * Model Clauses. With some of our processors and affiliates, we use standard
   contractual clauses approved by the European Commission that are binding
   standards of processing of personal data committed to contractually by third
   parties processing information for us and on our behalf.
 * In the absence of an adequacy decision or Model Clauses, and in the absence
   of any other right to transfer your data, we may rely on your consent as the
   basis for such transfer. We will take steps reasonably necessary to ensure
   that your data is treated securely and in accordance with this Privacy Policy
   and no transfer of your personal data will take place to an organization or a
   country unless there are adequate controls in place including the security of
   your personal data.

HOW LONG WILL CYBERARK STORE YOUR PERSONAL DATA?

We will retain your personal data for such periods of times required or
permitted by law or subject to our retention policies as may be in place from
time to time. The considerations Company takes into account in order to
determine the retention period are as follows: the time required to retain
personal data to fulfill business purposes, including providing products and
services; maintaining corresponding transaction and business records;
controlling and improving the performance and quality of the Site; handling
possible user queries or complaints and locating problems; whether the user
agrees to a longer retention period; whether we reasonably believe that this
data will be needed for the handling of any litigation; and whether the laws,
contracts, and other equivalencies pose any requirements for data retention.

SECURITY OF PROCESSING

We will maintain administrative, physical and technical safeguards designed to
protect the security, confidentiality and integrity of your personal data
processed by us as part of your use of our products/services, this website and
any other aspects of our business as described in this policy; and will not
materially decrease the overall security of such items. However, no method of
data security is 100% effective. Therefore, we cannot guarantee or warrant its
absolute security.

COMMUNITY FORUMS

CyberArk provides community forums on some of the Company’s Websites, Portals or
Services. Any personal data you choose to submit in such a forum may be viewed
by others who visit these forums. CyberArk is not responsible for any misconduct
by any person or entity of any personal data you choose to submit in these
forums.

ADDITIONAL TERMS WHICH APPLY WHERE YOU ARE A PARTNER USING CYBERARK’S PORTALS

If you submit a Deal Registration Form via the Portal, we will also collect the
following information: corporate name of end customer and contact details for
your point of contact within the end customer (including name, job title and
address).

Any marketing consents opt-ins/opt-outs or other preference details provided to
us in connection with another website or service operated by us (such as the
CyberArk community or our transactional websites) will be recorded and
administered separately from any preferences or consents provided in connection
with the Portal. You have the option to change your preferences registered in
connection with any of our sites or services at any time.

If you are an authorized channel partner and no longer want us to contact you
related to marketing events or information, please contact us
at channel@cyberark.com.

HOW CAN YOU EXERCISE YOUR LEGAL RIGHTS IN RESPECT OF PERSONAL DATA OR CONTACT US
OR COMPLAIN ABOUT OUR USE OF PERSONAL DATA?

You may contact us at any time by completing this form or sending an email to
privacy-request@cyberark.com to request to fulfill any of your rights in
relation to your personal data, depending on the laws applicable to you. We will
respond to your request in the timescales prescribed by the relevant local laws.

Depending on your location and on the laws that are applicable to you, you may
be entitled to some or all of the following rights:

The right to access – You have the right to request Company for copies of your
personal data, which includes the right to obtain confirmation as to whether or
not personal data concerning you are being processed.

The right to rectification – You have the right to request that Company correct
any information you believe is inaccurate. You also have the right to request
Company to complete the information you believe is incomplete.

The right to erasure – You have the right to request that Company erase your
personal data, under certain conditions.

The right to restrict processing – You have the right to request that Company
restrict the processing of your personal data, when: (a) you contest the
accuracy of your personal data, for a period allowing Company to verify the
accuracy of said data; (b) if you believe personal data has been unlawfully
processed and you wish to restrict processing rather than delete it; (c) Company
no longer needs the personal data but you require to keep it in order to
establish, exercise or defend a legal claim; or (d) you have exercised your
right to object the processing (below) for a period allowing Company to consider
whether your legitimate grounds override those of Company.

The right to object to processing – You have the right to object to the
processing of a part or all of your personal data at any time. When relating to
processing for marketing purposes, you have an absolute right to object; while
for other purposes, the existence of the right depends on what lawful basis the
processing relies on and on the existence of our compelling legitimate grounds
to continue the processing.

The right to data portability – You have the right to request that Company
transfer the data that we have collected to another organization, or directly to
you, under certain conditions.

If allowed by applicable laws, you have the right to withdraw your consent at
any time when Company processes your personal data based on your consent.
However, withdrawal does not affect the legitimacy and effectiveness of how we
process your personal data based on your consent before the withdrawal is made.

Although we will make reasonable efforts to accommodate your requests, in some
circumstances we may deem your request unfounded or not eligible under
applicable law. In such instances we reserve the right to refuse your request.
We may require, as pre-requisite to fulfilling any request, to verify your
identity which we may do by asking you to provide certain information or
identification to ensure that all data subjects’ privacy is protected. We may
charge you a small fee for the exercise of some of your rights under certain
conditions.

While we would always appreciate the chance to deal with your concerns before
you approach an external regulator, you can also contact a data protection
supervisory authority in any of the countries in which CyberArk is established
and/or the country in which you are based, such as the Information
Commissioner’s Office in the United Kingdom, and lodge a complaint You can
obtain the contact information for all of the EEA data protection authorities at
https://edpb.europa.eu/about-edpb/board/members_en.

HOW CAN YOU OPT-OUT OF RECEIVING MARKETING COMMUNICATIONS FROM CYBERARK?

To opt-out of receiving communications relating to marketing, events or
promotions from CyberArk, you can contact us at any time by completing this form
or sending an email to privacy-request@cyberark.com. Please note that if you are
an existing customer then we may need to retain business contact information in
order to provide you with CyberArk services, however this will not be used for
marketing purposes.

HOW WILL YOU KNOW IF CYBERARK UPDATES THIS STATEMENT?

We will make periodic updates to our privacy policy via this statement, and will
note the date the then-existing version takes effect. If you have any queries
concerning such changes then please contact us via privacy-request@cyberark.com.

HOW DOES CYBERARK USE COOKIES IN RELATION TO YOUR USE OF THE WEBSITES AND
PORTALS?

What are cookies?

A cookie is a very small text document, which often includes a unique
identifier. Cookies are created when your browser loads a particular website.
The website sends information to the browser which then creates a text file.
Every time the user goes back to the same website, the browser retrieves and
sends this file to the website’s server. Find out more about the use of cookies
at www.allaboutcookies.org.

We also use other forms of technology which serve a similar purpose to cookies
and which allow us to monitor and improve our Websites. When we talk about
cookies, this term includes these similar technologies.

What cookies do we use and what information do they collect?



Category Purpose Required cookies These cookies are required to enable core
functionalities of our Websites. Without these cookies, services you have asked
for, like identifying you while you are logged in, cannot be provided. If you
disable these cookies certain parts of the Websites will not function for you.
Functional cookies These cookies help us improve, analyse or optimise the
experience we provide. In particular, these allow us to measure how visitors
interact with our Websites and we use this information to improve the user
experience and performance of our Websites. These cookies are used to collect
technical information such as the number of pages visited, which parts of our
website are clicked on and the length of time between clicks. Advertising
cookies We use these cookies to collect information about your browsing habits
in order to make advertising more relevant to you and your interests. They are
also used to limit the number of times you see an advert as well as help measure
the effectiveness of an advertising campaign. We may share this information with
other parties who help manage online advertising – please see the “Third
Parties” section below for more details

Third parties

Your use of our Websites may result in some cookies being stored that are not
controlled by us. This may occur when the part of the Websites you are visiting
makes use of a third party analytics or marketing automation/management tool or
includes content displayed from a third party website

How do you manage these technologies?

If you want to delete any cookies that are already on your device, please refer
to the help and support area on your internet browser for instructions on how to
locate the file or directory that stores cookies.

To manage your cookie consent preferences, please click here.

NOTICE FOR CALIFORNIA RESIDENTS

If you are a California resident, we will not sell your personal data (within
the meaning of “sell” under the California Consumer Privacy Act). However, we
may transfer personal data to our service providers. In addition to the below
disclosures, please read the section How CyberArk uses Cookies in relation to
your use of the websites and partners portal above for further information on
how we share your personal data. Please click here to record your cookies
preferences.

This section is only applicable to California residents for purposes of
compliance with the California Consumer Privacy Act of 2018 (“CCPA”). Defined
terms used in this section, including but not limited to “Business Purpose”,
“Consumers,” “Personal Information” and “Sale” (or “Sell”) are used as such
terms are defined by and interpreted pursuant to the CCPA.

The categories of Personal Information we have collected about Consumers, which
we have disclosed for a business purpose, in the preceding 12 months are:

(1)        Identifiers, such as name and Social Security number;

(2)        Personal information, as defined in the California safeguards law,
such as contact information and financial information;

(3)        Characteristics of protected classifications under California or
federal law, such as sex and marital status;

(4)        Commercial information, such as transaction and account information;

(6)       Internet or network activity information, such as browsing history and
interactions with the Website;

(7)        Geolocation data, such as device location;

(8)        Audio, electronic, visual, thermal, olfactory, and similar
information, such as video, photography and call and video recordings;

(9)        Inferences drawn from any of the Personal Information listed above to
create a profile about, for example, an individual’s preferences and
characteristics.

The sources we have collected this Personal Information from are: directly from
California residents or their representative or employers.

In the past 12 months, however, we have not “sold” Personal Information relating
to California residents within the meaning of the CCPA.

If you are a California resident, you may request that we disclose to you the
following information covering the 12 months preceding your request:

(1)        the categories of Personal Information that we collected about you
and the categories of sources from which we collected such Information;

(2)        the business or commercial purpose for collecting Personal
Information about you;

(3)        the categories of Personal Information about you that we disclosed to
third parties for a business purpose and the categories of third parties to whom
we disclosed such Personal Information (if applicable); and

(4)        the specific pieces of Personal Information we collected about you.

If you are a California resident, you may also request that we delete Personal
Information that we collected from you.

We may ask to verify your identity by providing us with certain information or
identification. In some instances, we may decline to honor your request. For
example, we may decline to honor your request if we cannot verify your identity
or confirm that the Personal Information that we maintain relates to you, or if
we cannot verify that you have the authority to make a request on behalf of
another individual. In other instances, we may decline to honor your request
where an exception applies, such as where the disclosure of Personal Information
would adversely affect the rights and freedoms of another consumer or where the
Personal Information that we maintain about you is not subject to the CCPA’s
access or deletion rights, such as information relating to our employees and
contractors that is used for our employment and vendor management purposes.

You have the right to be free from unlawful discrimination for exercising your
rights under the CCPA.

CALIFORNIA AND DELAWARE “DO NOT TRACK” DISCLOSURES

CyberArk does not monitor or respond to Do Not Track browser requests. Hence
please ensure to change any settings of your browser and/or our Services,
whenever you wish cookies to cease.

Contacts

You may contact CyberArk’s Data Protection Office and make the requests
permitted pursuant to applicable law by completing this form or sending an email
to privacy-request@cyberark.com.

Last Updated: 31 January 2022





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