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RISKIQ GLOBAL PRIVACY STATEMENT

Effective from June 15, 2019


INTRODUCTION

Our Mission

RiskIQ, Inc., including our affiliates (“we”, “us” “our” or “RiskIQ”) seeks to
redefine the global standard for digital cybersecurity risk management beyond
the traditional perimeter of a firewall. We provide attack surface-based digital
risk protection by illuminating risk associated with an organization’s digital
presence in open, deep and dark web, mobile, and social digital channels to
proactively protect the organization, its brands, people, and data.

Our Sites and Services

We fulfill our mission by providing cloud computing featuring software through a
browser interface (primarily SaaS) made extensible by way of APIs, which
together with our managed security or professional services whether paid,
unpaid, or offered on a trial basis, we refer to individually, or collectively
as our ‘services’ throughout this statement. Through our sites, we also provide
information related to our services.

RiskIQ aspires to play an essential role in safeguarding the privacy and
personal information of individuals through our sites and services as we seek to
fulfill our mission. ‘Personal information’ for purpose of this statement means
any information relating to an individual from which that person is or can be
directly or indirectly identified.

When this Statement Applies

This RiskIQ Global Privacy Statement (this “statement”) applies to our services
and sites that we operate that display this statement. In the event of a
conflict between this statement and the terms of any agreement(s) between RiskIQ
and our customers, the terms of those agreement(s) shall control. This statement
neither applies to the personal information of our business partners, suppliers
or other organizations with which we have or contemplate a business
relationship, nor to the personal information of our employees.


PERSONAL INFORMATION WE COLLECT

To fulfill our mission, we collect a wide variety of data that may contain
personal information through our sites and services. We collect RiskIQ data from
publicly accessible information, either directly, or through others, which may
contain personal information. We also collect information from customers (the
companies, organizations, or other legal entities that subscribe to, or register
to access, any of our services), their respective authorized users of our
services, and from visitors to our sites, which may contain personal
information, which we individually and collectively refer to as ‘your personal
information’ throughout this statement.

Types of Information We Collect

We collect different types of information that may contain your personal
information, such as (i) Identity and Contact Info (first and last name, job
title or position, physical mailing or delivery address, business email address,
phone and fax, area of responsibility, and other similar data that is provided
to us when you express interest in, or subscribe to our services, or register to
attend one of our events); (ii) Transaction Data (details about orders placed
with us, which may include payment information or other information necessary to
process your order or verify your payment, as well as account information
provided to us when you register through our sites to access our services);
(iii) Credentials (usernames and passwords, and any security information used to
authenticate access to our sites or services); note that “single sign-on” or
“SSO” makes it possible for users to log in without the need to disclose
passwords to us, and those credentials are supplied by to the SSO provider, a
third party engaged by us, such as Ping Identity Corp., that authenticates the
SSO data for authorized users of our services; (iv) Communication Preferences
(your preferences related to receiving updates or communications from us,
including your individual marketing preferences); (v) Usage Info (current and
historical information about how you use our sites or services, which may
include technical information about your devices used to access our sites or
services, such as operating system or IP address, as well as other information
collected by us automatically, such as individual usage details and clickstream
data, and other browsing actions and patterns – learn more); (vi) Service Data
(any data you submit to us for the performance or delivery of the services on
your behalf, or that you transmit through the services, or store in the
services. This category includes your personal information that a customer (as
determined by its authorized users) shares with a restricted set of individuals
through its private “project” or “workspace”; (vii) Other Correspondence – any
other correspondence you submit to us through our sites that contain your
personal information; and (viii) Publicly Shared Data (any of your personal
information that you, as an authorized user or visitor, deliberately make
publicly available online through our sites or offerings, testimonials, recorded
content from training sessions, and other similar contributions that you as an
individual choose to make public online (e.g., your contributions to the broader
security community through a publicly shared project in PassiveTotal). We
recommend that you exercise caution when deciding what to share publicly over
the Internet, which is generally an open, global system, where anyone can make
copies of a public data item and store it in an arbitrary location; and the
public portion of the web does not account for the number, owner or location of
such copies.

How We Collect Information

We use different methods to collect information that may contain your personal
information, including through:

 * Direct interactions. You may share your personal information through direct
   interactions, such as by corresponding with us by post, phone, electronically
   or otherwise. Examples of how we may receive your personal information
   through your direct interactions include when you (i) subscribe to one of our
   services or create an account on one of our sites; (ii) request support or
   information; (iii) subscribe to our newsletters, or download one of our white
   papers; (iv) attend one of our trainings or events, or sign up to watch one
   of our webinars; (v) request a demo or quote in relation to our services;
   (vi) request marketing materials or sales communications; (vii) complete a
   voluntary survey to fulfill order expectations, or to improve, enhance,
   promote or market our services or sites; and when you (viii) give us feedback
   or contact us.
 * Indirect interactions. One of our customer’s authorized users may share your
   personal information with us through various interactions, such as by
   corresponding with us by post, phone, electronically, or otherwise.
 * Technologies. We use various technologies, some of which are automated, to
   collect and store data, which may have your personal information, including
   cookies, pixel tags, browser web storage, and server logs. Learn more.
 * Third parties or publicly available sources. We combine different types of
   your personal information to create customized profiles about you and your
   organization to form a view on what we think you may want or need, or which
   of our services are relevant to your organization, some of which we may
   receive from third parties, such as other users or visitors from your
   organization, business partners, publicly available sources, or confidential
   brokers to whom you have recently provided express consent to be contacted by
   us on behalf of your organization to market our services. Subject to any
   additional restrictions that also may be imposed by our data suppliers, we
   seek to only use third-party data in accordance with the practices as
   described in this statement.


WHY AND HOW WE USE YOUR PERSONAL INFORMATION

Why We Use Your Personal Information

We strive to use personal information that we collect proportionately and
responsibly to fulfill our mission through our sites and services. Other than by
obtaining your valid consent, we otherwise use your personal information that we
collect because we have a contractual necessity to do so, or in furtherance of
our legitimate interest not overridden by your individual interests, fundamental
rights or freedoms that legally require protection, or because we need to use
your personal information to satisfy a legal obligation to which we are subject.

How We Use Your Personal Information

When you request specific information from us, or that we contact you for a
specific purpose, we use your personal information that we collect from you to
fulfill your request, as well as to assess whether there are new potential
customer opportunities, and to market our services to you with your valid
consent, whether through our sites by sending you newsletters, or through direct
marketing, which may include service recommendations (learn how to control our
use of your personal information for marketing, and your individual rights).

We use your personal information that we collect to perform our contract with
you for the use of our sites and services. When you visit our sites, we also use
your personal information that we collect as necessary to operate, administer,
develop and improve our sites and services and provide you with the information
you access and request, as well as to analyze trends and track your usage of and
interactions with our sites to develop and improve our sites and services, and
provide more relevant information.

To sustain and grow our business, when you use any of our services, we use your
personal information that we collect for (i) account-based marketing to keep you
(and any customer for whom you are an authorized user, including its contacts)
engaged with us, and to deliver the outcomes reasonably expected, including by
enhancing and improving our sites and services; and for (ii) general corporate
operations and due diligence in the day-to-day running of our business and
planning for our strategic growth.

We use your personal information that we collect to prevent fraud, claims, and
other liabilities and to comply with or enforce our legal obligations, and our
policies and terms. We also use your personal information that we collect to
protect our information, system, network and cyber security, such as preventing
unauthorized access, intrusion, misuse or abuse of our systems, networks,
computers and information, protecting our intellectual property, and securing
our supply chain; for example, if you visit our offices, we may use camera
supervision in accordance with applicable law. We use your personal information
that we collect for these purposes where we have a good faith belief that doing
so is necessary to protect, exercise or defend our legal rights, or required to
comply with a legal obligation to which we are subject.

We reserve the right to use your personal information in furtherance of a
merger, reorganization, dissolution or other fundamental corporate change, or in
furtherance of a sale of one of our sites or business units, or of a portion of
our business assets.


HOW WE SHARE YOUR PERSONAL INFORMATION

We only share your personal information either within the RiskIQ group or with a
third-party outside of RiskIQ, as described below.

 * within our group, such as with our wholly-owned subsidiary RiskIQ UK Limited
   ( 09135597) based in the United Kingdom with offices at 33 Cannon Street,
   Fourth Floor, City of London EC4M 5SB, England as a co-controller to fulfill
   your request, or for administrative purposes, such as support, marketing
   technical operations or account management purposes;
 * with our Channel Partners, where you or a person delegated by your
   organization has subscribed to one or more of our services through a third
   party, we may need to exchange information with them as part of managing that
   relationship and your account, including to fulfill your order;
 * with our contracted service providers in accordance with our instructions,
   who are only authorized to use your personal information as strictly
   necessary to provide services to us;
 * with a delegate from your organization that manages your organization’s
   subscription to one of our services and provides you with access as part of
   the subscription package, or one of its other authorized users;
 * with any third-party to comply with a legal obligation to which we are
   subject, or where doing so is necessary to protect, exercise, or defend our
   legal rights or to enforce our terms;
 * for any stated purpose, when in aggregated form that cannot reasonably be
   used to identify you;
 * to any third party with your prior valid consent;
 * to any third party that agrees to use or disclose such personal information
   consistent with this statement (unless said person obtains your valid consent
   for other use or disclosure), where the sharing of such information is in
   furtherance of a merger, reorganization, dissolution or other fundamental
   corporate change, or in furtherance of a sale of one of our sites or business
   units, or of a portion of our business assets; in accordance with applicable
   laws, we will use reasonable efforts to notify you of any transfer of your
   personal information to an unaffiliated third party.


OTHER IMPORTANT PRIVACY INFORMATION

Personal Data Security and Retention

As many other institutions have demonstrated, information security can never be
assured. We strive to maintain a reasonable, continuous process for
implementing, reviewing, improving, and documenting personal information
protection. We intend to protect your personal information and to maintain its
accuracy by putting in place reasonable physical, administrative, and technical
safeguards to help us prevent unauthorized access, use and disclosure. We expect
the same from our suppliers, and we are committed to having our security
professionals work closely with our privacy team to document that our security
systems are appropriate to the risk associated with the loss of confidentiality,
integrity and availability of information.

As part of this process, we retain your personal information only as necessary
to fulfill the purpose for which we collected it as described in this statement,
or possibly longer to the extent doing so is necessary either to protect,
exercise, or defend our legal rights, or to comply with our legal obligations.

International Transfers of Your Personal Information

We may transfer your personal information outside of your country of residence
within the RiskIQ group as well as to third parties as described in this
statement.

We transfer personal information from the European Economic Area and Switzerland
to other countries, some of which have not yet been determined by the European
Commission to have an adequate level of data protection. For example, their laws
may not guarantee you the same rights, or there may not be a privacy supervisory
authority capable of addressing your complaints. When we engage in such
transfers, we rely on either the EU-U.S. Privacy Shield Framework and Swiss-U.S.
Privacy Shield Framework (including the onward transfer liability provisions),
or other lawful measures, such as certain service providers with binding
corporate rules that have been approved by the European Commission, or contracts
that include the EU standard contractual clauses.

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

RiskIQ participates in and has certified its compliance with the EU-U.S. Privacy
Shield Framework and Swiss-U.S. Privacy Shield Framework. We are committed to
subjecting all personal data received from the European Union (EU) member
countries and Switzerland, respectively, in reliance upon each Privacy Shield
Framework, to the Frameworks’ 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 at https://www.privacyshield.gov/.

RiskIQ is responsible for the processing of personal data it receives, under
each Privacy Shield Framework, and subsequently transfers to a third party
acting as an agent on its behalf. RiskIQ 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 transferred or received pursuant to the Privacy
Shield Frameworks, RiskIQ is subject to the regulatory enforcement powers of the
U.S. Federal Trade Commission. In certain situations, we 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 there is any conflict between the terms in this statement and the Privacy
Shield Principles, the Privacy Shield Principles shall govern. To learn more
about the Privacy Shield program, and to view our certification, visit the
Privacy Shield website.

If you have a question or complaint related to participation by RiskIQ in the
EU-U.S. or Swiss-U.S. Privacy Shield, we encourage you to contact us. If you
have an unresolved privacy or data use concern that we have not addressed
satisfactorily, please contact our U.S.-based third party dispute resolution
provider (free of charge) at https://feedback-form.truste.com/watchdog/request.
Under certain conditions more fully described on the Privacy Shield website
[https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint] you may be
entitled to invoke binding arbitration when other dispute resolution procedures
have been exhausted.

Children

We do not knowingly solicit or receive information from children under the age
of 16. Please contact us promptly if you believe we might have collected any
information from a child under the applicable age of consent in your country, so
that we may appropriately investigate and address the issue.

Updates to this Statement

We may update this statement when we believe it is necessary. Please refer to
the “Effective Date” at the top of this statement. You can access prior versions
to track the changes we have made. If we make any material changes, we will
notify you by prominently posting a notice before the changes will take effect,
or by directly sending you a notification. We encourage you to periodically
review this statement to keep track of any changes to this statement.

Websites Linked to from our Sites and other Third-Party Services

We may provide hyperlinks to other sites for your convenience that are not
covered by this statement. If you click on any such hyperlink, we recommend that
you read the relevant privacy notice to make sure you are comfortable with the
applicable privacy and data security practices that govern, which may be
different than as described in this statement.

Similarly, when you connect or enable a third-party application, database,
software or service together with our services (including one that is integrated
by you or at your direction), we recommend you review the applicable privacy
notice.

More about cookies and tracking technologies

Like most websites, we record page requests made from our visitors in “server
logs” that may include your personal information. We typically keep server logs
for up to 90 days.

We also use “local storage” to store data in your browser across sessions—even
after your browser has been closed and reopened. We deliver files from our sites
and services through your browser that contain site data (‘cookies’ or
‘trackers’), which are stored on your computer, either as set by us directly, or
by one of our suppliers we have entrusted. We recommend managing these cookies
using the browser functions in your browser (typically, under “options” or
“settings”) if this is important to you, but you may not have the visibility to
do so from your mobile device.

You can selectively use browser plug-ins or add-ons to add privacy-enhancing
capabilities to your browser, such as Cookie Auto-Delete and uBlock Origin. You
should make sure you are comfortable with the privacy practices of any such
third-party browser add-ons. All popular browsers have help documentation
available on how to adjust your cookie settings. We also recommend choosing your
browser selectively if greater flexibility for privacy customizations is
important to you.

Some of the files we deliver through your browser are required information.
Therefore, while you may have the technical option of disabling all files from
being stored on your computer through your browser settings, you should be aware
that if you disable all cookies or other site data, which includes those that
are required, you will no longer be able to use some functions or features on
our sites or services. For example, we use cookies for session management, which
is required for our services to be redundant to the failure of any one server.
Without this, users would also have to provide a username and password on every
screen, and we would not be able to track the completion of downloads from our
services, so that our subscribers can export data from our services as intended.

If you use our services or visit our sites, some of the analytical cookies we
use are required for error and connectivity monitoring, logging and analytics,
event tracking for service improvement, and support. We also use cookies to
interact with you while you are using our services or visiting our sites. If you
choose to disable any of these cookies, we will no longer be able deliver our
services as intended. We recommend that you address any concerns you may have as
an authorized user directly with our customer. For example, without Google Tag
Manager, other scripts that are loaded into the page may no longer function. If
you disable Google Analytics, you may impair our ability to monitor our
performance when you visit our sites.

We also use some cookies that may contain some of your personal information on
our sites and in some of our services in furtherance of our legitimate interests
in customer analytics and/or account-based marketing, such as through Woopra
and/or Marketo.

In furtherance of our legitimate marketing-related interests, we also partner
with third parties to deliver advertising cookies to those visiting our sites in
order to display advertising on our sites and to manage advertising on other
sites. Examples include cookies we deliver through DoubleClick and Twitter. If
you wish to opt out of interest-based advertising, click here [or if located in
the European Union, click here].

Apart from following the instructions on how to manage cookies in your browser,
we also provide a way you may be able to adjust some of your preferences through
a third-party cookie consent manager here. This is made available to you at your
own risk. A downside of this may be that you must allow third-party cookies in
your browser settings to use it, and some of the opt-outs may fail, including
due to your cookie settings in your browser. It also may not necessarily be up
to date, depending on when we last reviewed the scans, and how often those scans
occur.

Your Rights as an Individual

We respect your rights and control over your personal data. You may exercise any
of the following rights as the law allows (which means under some circumstances,
there may be legal or official reasons that we may not be able to fully address
the specific request you make) by contacting us. Please note that for security
purposes, we may ask you to verify your identity before taking further action on
your request. We aim to respond to your request within 30 days, or otherwise
within a reasonable timeframe under the circumstances subject to applicable law.

Right of Access – the right to verify the accuracy of your personal information
that we hold about you upon your request, including to the right to be informed
of and request access to personal information we process about you;

Right to Rectification - the right to amend or update your personal information
upon your request where it is inaccurate or incomplete;

Right to Erasure - the right to have your personal information deleted upon your
request without undue delay under any of the following circumstances with
respect to your personal information: (i) it is inaccurate, (ii) it is no longer
necessary in relation to the purpose for which it was collected or otherwise
used, (iii) there are no overriding valid legitimate grounds that we rely on for
using your personal information and you have objected, (iv) it has been
unlawfully used; or (v) it is required to be erased to comply with a valid legal
obligation.

Right to Restrict - the right that we temporarily or permanently stop processing
all or some of your personal information in certain situations upon your
request, such as to verify its accuracy or where the processing is unlawful and
you object to erasing it, or where we no longer need your personal information
but you need it for certain valid legitimate interests or to comply with a legal
obligation, or pending verification whether there is a valid legitimate grounds
for processing your personal information over your objection.

Right to Object - the right at any time (1) on grounds relating to your
particular situation to object that our processing of your personal information
for our valid legitimate interests is not compelling, in which case we will no
longer process your personal information unless (i) we demonstrate our interests
are still valid because they outweigh your rights and freedoms taking your
particular situation into account, or (ii) continuing to process your personal
information is necessary to protect, exercise or defend our legal rights; you
also have the right (2) to stop your personal information from being processed
by us for direct marketing purposes upon your request.

Direct Marketing – Exercising Your Right to Object

You may choose to exercise your right to object to direct marketing by
contacting us. You can also opt-out of any direct marketing electronic
newsletters by using the ‘unsubscribe’ functionality at the bottom of our
emails. You can also opt-out of marketing phone calls (we do not use automated
means) by telling our representative to add you to our “Do Not Call” list. You
may contact us to opt out of receiving any postal mail.

Right to Data Portability - the right to receive upon your request, a copy of
your personal information that we are processing by automated means or based on
your valid consent, and to transmit it to a different controller without
hindrance from us, in a structured, commonly used and machine-readable format,
or directly from us to a different controller, where technically feasible.

Right not to be subject to Automated Decision-making - We do not subject you to
any decision based solely on automated processing of your personal information,

In addition to the rights you may have subject to and in accordance with
applicable law, as set forth above in this statement with respect to access,
updating or correcting your personal information, as well as objecting to direct
marketing, you may have other rights pursuant to your local law applicable to
the processing.

Furthermore, in the event you consider our processing of your personal
information to infringe on your rights pursuant to applicable data protection
laws, please lodge a complaint with us by contacting us below. Without prejudice
to any other rights you may have, you may also lodge a complaint with your local
or other competent data protection authority. Contact details for data
protection authorities in the European Economic Area (EEA) are available here,
including for the Information Commissioner’s Office, which is where we have our
main establishment within the EEA.

If you wish to exercise any of your individual rights as an authorized user with
respect to your personal information that we process on behalf of our customer,
we request that you first contact our customer as the data controller. We cannot
assume responsibility for the privacy or security practices of our customer,
which may be different than as described in this statement.


CONTACT US

If you have support-related questions, comments or concerns with our services or
to close your account, please contact us via support@riskiq.com.

If you have any questions, comments or concerns with this statement, or our
privacy or data protection practices, please email privacy@riskiq.com.

You can also contact us at +1.888.415.4447 to leave a message for our Personal
Data Protection Team. If you are still unsatisfied, you may contact our legal
department via legal@riskiq.com. We will respond to questions or concerns within
30 days, or otherwise within a reasonable timeframe under the circumstances
subject to applicable law.

For the purposes of the EU General Data Protection Regulation (GDPR), the
controller of your personal information is RiskIQ, Inc., 22 Battery Street –
10th floor, San Francisco, California, 94111, United States, unless indicated
otherwise. RiskIQ UK Limited in the United Kingdom is a co-controller of
personal data when it transfers personal data that is processed in connection
with certain legitimate interests we have in marketing and sales, and day-to-day
business operations, including information collected from its offices in London.


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