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LEGAL

 * Overview
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 * Agreements Terms & Conditions
 * Global Trade Compliance
 * Notices
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PRIVACY


SOPHOS GROUP PRIVACY NOTICE


GENERAL

This is the privacy notice of Sophos Limited and its subsidiaries.

This document was last updated on 10 February 2022.

We are committed to safeguarding the privacy of your personal data. Please read
the following privacy notice to understand how we collect and use your personal
data, for example when you contact us, visit or use one of our websites, mobile
applications, portals, or other parts of our network (each a “Site”), apply for
a job, or use our products and services, regardless of how you access them. This
privacy notice also explains the rights available to you in respect of your
personal data.

 * What personal data do we collect, how do we collect it, and why?
 * Other specific ways we collect and use your personal data
 * Legal basis for processing personal data
 * With whom might we share your personal data
 * International transfers of data
 * Data retention
 * Use by children
 * Automated decision-making
 * Your data protection rights
 * Links
 * Security
 * California privacy rights
 * Data Processing Agreement
 * Contact
 * Notification of changes


WHAT PERSONAL DATA DO WE COLLECT, HOW DO WE COLLECT IT, AND WHY?

Data that you provide voluntarily to us

When you use our Site, products or services, or you otherwise communicate with
us, we may ask you to provide certain personal data voluntarily, including but
not limited to your name, company position, postal address, telephone number,
mobile number, fax number, email address, credit card or other payment details,
age or date of birth, account usernames, passwords, or gender. For example, we
may ask you to provide some or all of this personal data when you register an
account with us, subscribe to our marketing communications, purchase products or
services, and/or submit enquiries to us. We use this information to create and
administer your account, send you marketing communications, provide you with the
products and services you request, and to respond to your enquiries. In general,
the personal data that you are asked to provide, and the reasons why you are
asked to provide it, will be made clear to you at the point we ask you to
provide your personal data.

Data collected automatically

When you use our Site, products, or services, we may collect certain data
automatically from your computers or devices (including mobile devices). The
data we collect automatically may include your IP address (explained further
below), device type, operating system details, unique device identification
numbers (including mobile advertising identifiers), browser-type, browser
language, operating system, geographic location (as explained further under the
heading “Location information”) and other technical information. We may also
collect data about how your device has interacted with our Site, products or
services, including the pages or features accessed and links clicked, the amount
of time spent on particular pages, mouse hovers, the date and time of the
interaction, error logs, referring and exit pages and URLs, and similar
information. Collecting this data enables us to better understand the visitors
who use our Site, products, and services, including where they come from and
what features are of interest to them. We use this information for our internal
analytics purposes, and to improve the quality, relevance, and security of our
Site, products and services.

For example, every time you connect to the Site, we store a log of your visit
that shows the unique number your machine uses when it is connected to the
Internet - its IP address. This log tells us what your machine has looked at,
whether the page request was successful or not, and which browser your machine
used to view the pages. This data is used for statistical purposes as well as to
help customize the user experience as you browse the Site and subsequently
interact with Sophos. This helps us to understand which areas of the Site are of
particular interest, which pages are not being requested, and how many people
are visiting the Site in total. It also helps us to determine which products and
services may be of specific interest to you. We may also use this information to
block IP addresses where there is a breach of the terms and conditions for use
of the Site.

Some of the data may be collected automatically using tracking technologies, as
explained further under the heading “Cookies and similar tracking technology”.

Data that we obtain from third party sources

From time to time, we may receive personal data about you from third party
sources (including without limitation recruitment agencies, credit check
agencies, agencies providing compliance checks, lead generation providers,
resellers, and other partners who sell our products and services to you), but
only where such third parties have confirmed that they have your consent or are
otherwise legally permitted or required to disclose your personal data to us.

The types of information we collect from third parties include contact details,
CVs, credit history, and order information, and we use the information we
receive from these third parties to assess your suitability for a job position,
carry out compliance checks required under applicable law (such as anti-bribery
and corruption checks), make credit decisions, maintain and improve the accuracy
of the records we hold about you, and market our products and services to you.

We also receive information from other members of the industry that forms part
of or otherwise helps us to develop, test, and enhance our own product offering
(for example spam lists, malicious URL lists, and sample viruses), some of which
could contain personal data (where permitted by applicable law).

We may combine information that we collect from you with information about you
that we obtain from such third parties.

Data collected through our products and services

We use data that we collect from products and services for the purposes for
which you provided it, usage and audience counts, monitoring the performance and
effectiveness of the products/services, monitoring compliance with our terms and
conditions, enabling compatibility with third party operating
systems/products/services, planning future roadmap strategy, planning
product/service/feature lifecycles and retirements, conducting spam, threat and
other scientific research, developing new products and services, enhancing
existing products and services, troubleshooting product issues, generating
statistics, reporting, and trend analysis. This may include incidental personal
data (for example usernames, machine IDs, domain names, IP addresses, file
names, and file paths).

Our products and services may collect further additional personal data about you
beyond the data described in this privacy policy, or use your personal data in
ways that are different to or in addition to those described in this privacy
policy. We provide a Product Privacy Information page that explains how our
products and services collect and use personal data. Please review the relevant
section of the Product Privacy Information page for the product or service you
are using to ensure that you are fully informed.

Cookies and similar tracking technology

A cookie is a piece of text that gets entered into the memory of your browser by
a website, allowing the website to store information on your machine and later
retrieve it.

Our Site, products, and services may use cookies, unique device identifiers
(like Apple ID For Advertisers on iOS devices, and Android Advertising ID on
Android devices), and other tracking technologies (collectively, "Cookies") to
distinguish you from other users and better serve you when you return to the
Site, product, or service, and to monitor and analyse the usage of the Site,
product, or service. Cookies also enable us and our third party partners to
track and target the interests of our users to enhance the onsite or in-product
experience through content, features, and advertisements.

We, along with our service providers, may also use other Internet technologies,
such as Flash technologies, Web beacons or pixel tags, and other similar
technologies, to deliver or communicate with cookies and track your use of the
Site, product, or service, as well as serve you ads and personalize/customize
your experience when you are using our Site, product, or service and/or when you
are on other websites where those cookies can be accessed. We may also include
Web beacons in email messages, newsletters, and other electronic communications
to determine whether the message has been opened and for other analytics,
personalization, and advertising. As we adopt additional technologies, we may
also gather additional information through other methods. This practice is
explained further under the heading “Marketing and promotions”.

As explained above, we occasionally share information you have provided to us
with service providers, who will de-identify the information and associate it
with cookies that enable us to reach you. We may also help these service
providers place their own cookies, by deploying a cookie that is associated with
a 'hashed' value associated with interest-based or demographic data, to permit
advertising to be directed to you on other websites, applications or services.

Most browsers automatically accept cookies, but you can modify your browser
setting to decline cookies by visiting the Help portion of your browser's
toolbar. If you choose to decline cookies, please note that your ability to sign
in, customize, or use some of the interactive features of our Site, product, or
service may be impeded, and the advertisements you see may not be as relevant to
you.

For more information about the cookies that we use, please refer to our Cookie
Information page.

Location information

We may collect different types of information about your location, including
general information (for example IP address or ZIP code) and more specific
information (for example GPS-based functionality on mobile devices when used to
access a Site, product, or service). This information may be used to customize
the services provided to you, such as location-based information, advertising,
and features. In order to do this, your location information may be shared with
our agents, vendors, or advertisers. If you access the Services through a mobile
device and you do not want your device to provide us with location-tracking
information, you can disable the GPS or other location-tracking functions on
your device, provided your device allows you to do this. See your device
manufacturer's instructions for further details.


OTHER SPECIFIC WAYS WE COLLECT AND USE YOUR PERSONAL DATA

Job applications

If you are making a job application or inquiry, you may provide us with a copy
of your CV or other relevant information. We may use this information for the
purpose of assessing your application or inquiry. We may also keep this
information on file to contact you about future opportunities, unless you ask us
not to do this.

Partner portal

Our resellers, distributors, and other partners may visit our partner portal
Site. We may use the information provided on that Site for partner relationship
management, billing, forecasting, trend analysis, renewal management, marketing,
and in order to sell and provide the products and services.

Account management

If you obtain products or services from us, we may use your contact details and
(where applicable) payment information for the purposes of (i) providing
training, customer support, and account management, (ii) order processing and
billing, (iii) verifying your usage of the products and services in accordance
with the terms and conditions of your agreement with us, (iv) carrying out
checks for export control, anti-bribery, anti-corruption, the prevention of
modern slavery, and other compliance purposes in accordance with requirements
under applicable law; (v) contacting you (including by email communication)
regarding license expiry, renewal, and other related notices, and (vi)
maintaining our company accounts and records.

Market research and surveys

If you participate in surveys, we may use your personal data for our internal
business analysis and training purposes in order to improve our understanding of
our users’ demographics, interests and behaviour, to measure and increase
customer satisfaction, and to improve our products and services.

Competitions, contests, promotions

If you participate in a competition, contest, or promotion conducted by us or on
our behalf, we may use your personal data in order to administer such
competition, contest, or promotion. We may also use your personal data as
explained further under the heading “Marketing and promotions”.

Chat rooms

Please be careful and responsible whenever you are online. Should you choose to
voluntarily disclose information to open areas of our Site, such as via the
Sophos Community, online help, or other chat rooms, that information can be
viewed publicly and may be collected and used by third parties without our
knowledge or consent, and may result in unsolicited messages from other
individuals or third parties.

Marketing and promotions

We (or our resellers or other selected third parties acting on our behalf) may
contact you from time to time in order to provide you with information about
products and services that may be of interest to you. Such communications may
contain tracking technology that tells us whether you opened the communication
and whether you followed the hyperlinks within the communication, in order to
help us analyse the effectiveness of, monitor, and improve our marketing
campaigns. All marketing communications that we send to you will respect any
marketing preferences you have expressed to us and any consent obligations
required under applicable privacy and anti-spam rules. You have the right to ask
us not to process your personal data for certain or all marketing purposes, but
if you do so, we may need to share your contact information with third parties
for the limited purpose of ensuring that you do not receive marketing
communications from them on our behalf.

Network monitoring

We may collect logs and other data about access to and traffic passing through
our network and equipment for the purposes of availability and performance
monitoring, maintenance, security monitoring and investigations, conducting
spam, threat and other scientific research, new product and service development,
the enhancement of existing products and services, generating statistics,
reporting, and trend analysis.

Sample submissions

We collect information about suspected spam, suspected malicious files, and
files that may be unwanted or undesirable for our customers (for example file
names, URLs, file paths, hashes, and file samples) that are (i) received by our
own network and equipment, and (ii) voluntarily submitted via our products and
services or our Site submission pages. We use this information for spam, threat
and other scientific research, new product and service development, the
enhancement of existing products and services, generating statistics, reporting,
and trend analysis.


LEGAL BASIS FOR PROCESSING PERSONAL DATA

Our legal basis for collecting and using personal data will depend on the
personal data concerned and the specific context in which we collect it.

However, we will normally collect personal data from you only where we need the
personal data to perform a contract with you, or where the processing is in our
legitimate interests and not overridden by your data protection interests or
fundamental rights and freedoms, or where we have your consent to do so. In some
cases, we may also have a legal obligation to collect personal data from you or
may otherwise need the personal data to protect your vital interests or those of
another person.

If we collect and use your personal data in reliance on our legitimate interests
(or those of any third party) other than as described in this privacy policy, we
will make clear to you at the relevant time what those legitimate interests are.

If you have questions about or need further information concerning the legal
basis on which we collect and use your personal data, please contact us using
the contact details provided under the “Contact” heading.


WITH WHOM MIGHT WE SHARE YOUR PERSONAL DATA

We may transfer or disclose your personal data to the following categories of
recipients:

 * to our group companies, third party services providers, suppliers, agents,
   and other organisations who provide data processing services to us (for
   example, to support the delivery of, provide functionality on, or help to
   enhance the security of our Site, products, or services), or who otherwise
   process personal data on our behalf for purposes that are described in this
   privacy policy or notified to you when we collect your personal data (such as
   advertising, sweepstakes, analytics, research, customer support, fraud
   prevention, and legal services);;
 * to our authorised resellers, distributors, and other channel partners in
   order to process your order or sales enquiry, manage your subscription,
   provide technical or customer support, advise of upcoming product or service
   subscription expiry and renewal dates, or as otherwise notified to you when
   we collect your personal data;
 * a subset of our threat intelligence data to selected reputable members of the
   IT security industry for the purpose of anti-spam and security threat
   research;
 * to any government department, agency, court or other official bodies where we
   believe disclosure is necessary (i) as a matter of applicable law or
   regulation (such as in response to a subpoena, warrant, court order, or other
   legal process), (ii) to exercise, establish, participate in, or defend our
   legal rights, or limit the damages we sustain in litigation or other legal
   dispute, or (iii) to protect your vital interests, privacy, or safety, or
   those of our customers or any other person;
 * to a potential or actual buyer or transferee (and its agents and advisers) in
   connection with any proposed or actual transfer of control, purchase, merger,
   reorganisation, consolidation, or acquisition of any part of our business,
   provided that we inform the buyer or transferee it must use your personal
   data only for the purposes disclosed in this privacy policy;
 * to any other person with your consent to the disclosure.

Except as set out above, we will not disclose your personal data save where we
need to do so in order to enforce this privacy policy, our End User License
Agreement, our rights generally, or where required or permitted by applicable
local or foreign law.

Whenever we share personal data, we take all reasonable steps to ensure that it
is treated securely and in accordance with this privacy policy. This may include
without limitation aggregating or de-identifying information so that it is not
intended to be used by the third party to identify you.


DATA TRANSFERS

As a global company, we and our service providers operate, and our Site,
products, and services are accessed from, all over the world. When you give us
personal data, that data may be used, processed, or stored anywhere in the
world, including in countries that have data protection laws that are different
to the country in which you reside. 

However, we have taken appropriate safeguards to require that your personal data
will remain protected in accordance with this privacy policy. For example, these
include implementing the European Commission’s Standard Contractual Clauses
(SCCs) for transfers of personal data between our group companies, which require
all group companies to protect personal data they process from the European
Economic Area in accordance with European Union data protection law. We have
implemented similar appropriate safeguards with our third party service
providers , and further details can be provided upon request by contacting us
using the contact details provided under the “Contact” heading. 


DATA RETENTION

We retain personal data we collect from you for as long as necessary for the
purposes for which the personal data was collected or where we have an ongoing
legitimate business need to do so (for example, to provide you with a product or
service you have requested, to ensure that transactions can be processed,
settled, refunded, charged back, or to identify fraud), or to comply with
applicable legal, tax, or regulatory requirements. Even if you close your
account, we will retain certain information in order to meet our obligations.

When we have no ongoing legitimate business need to process your personal data,
we will either securely destroy, erase, delete or anonymise it, or if this is
not possible (for example, because your personal data has been stored in backup
archives), then we will securely store your personal data and isolate it from
any further processing until deletion is possible.


USE BY CHILDREN

The Site, the products, and the services are not intended for persons under the
age of 16. By using the Site, product, or service, you hereby represent that you
are at least 16 years old.


AUTOMATED DECISION-MAKING

In some instances, our use of your personal data may result in automated
decisions being taken that legally affect you or similarly significantly affect
you.

Automated decisions mean that a decision concerning you is made automatically on
the basis of a computer determination (using software algorithms), without our
human review. For example, our products and services use automated decisions to
determine whether a domain, URL, or IP address is sending spam or malicious
content in order to protect our customers from unwanted or undesirable content.
We have implemented measures to safeguard the rights and interests of
individuals whose personal data is subject to automated decision-making,
including controlled product releases and regular quality assessments.

When we make an automated decision about you (for example if we block a domain,
URL, or IP address used by you), you have the right to contest the decision, to
express your point of view, and to require a human review of the decision. You
can exercise this right by contact us using the contact details provided under
the “Contact” heading.


YOUR DATA PROTECTION RIGHTS

You have the following data protection rights:

 * You can access, delete or request portability of your personal data by
   completing this form.
 * You may also ask us to correct or update your personal data, object to
   processing of your personal data, or ask us to restrict processing of your
   personal data using the contact details provided under the “Contact” heading
 * You have the right to opt-out of marketing communications we send you at any
   time. You can usually exercise this right by clicking on the “unsubscribe” or
   “opt-out” link in the marketing e-mails we send you. Alternatively, or to
   opt-out of other forms of marketing (such as postal marketing or
   telemarketing), then please contact us using the contact details provided
   under the “Contact” heading.
 * If we have collected and process your personal data with your consent, then
   you can withdraw your consent at any time by contacting us using the contact
   details provided under the “Contact” heading. Withdrawing your consent will
   not affect the lawfulness of any processing we conducted prior to your
   withdrawal, nor will it affect processing of your personal data conducted in
   reliance on lawful processing grounds other than consent.
 * You have the right to complain to a data protection authority about our
   collection and use of your personal data. For more information, please
   contact your local data protection authority.

We respond to all requests we receive from individuals wishing to exercise their
data protection rights in accordance with applicable data protection laws.


LINKS

This privacy policy applies to personal data collected by us. If we provide a
link to a third party site (whether through our Site, a product or service, or
in an e-mail we send you), please be aware that we are not responsible for the
content or privacy practices of such third party site. We encourage our users to
be aware when they leave our Site, and to read the privacy policy of other sites
that collect personal data. We are not liable for any disputes, loss, or damage
that may arise from or in connection with your use of such third party sites.


SECURITY

While we strive to protect your personal data, no data transmission or storage
can be guaranteed as 100% secure. We endeavour to protect all personal data
using reasonable and appropriate physical, administrative, technical, and
organisational measures, and in accordance with our internal security procedures
and applicable law. These safeguards vary based on the sensitivity of the
information that we collect, process, and store, and the current state of
technology.

If you have been given or have created log-in details to provide you with access
to certain parts of our Site (for example our partner portal), you are
responsible for keeping those details confidential in order to prevent
unauthorised access to your accounts.


CALIFORNIA PRIVACY RIGHTS

California Online Privacy Protection Act Notice Concerning Do Not Track Signals

Do Not Track (“DNT”) is a privacy preference that users can set in certain web
browsers. DNT is a way for users to inform websites and services that they do
not want certain information about their webpage visits collected over time and
across websites or online services. We do not recognize or respond to
browser-initiated DNT signals, as the Internet industry is currently still
working toward defining exactly what DNT means, what it means to comply with
DNT, and a common approach to responding to DNT. To learn more about Do Not
Track, you can do so here.

Your California privacy rights

California law permits users who are California residents to request and obtain
from us once a year, free of charge, a list of the third parties to whom we have
disclosed their 'personal information' (if any, and as defined under applicable
California law) for their direct marketing purposes in the prior calendar year,
as well as the type of personal information disclosed to those parties. If you
are a California resident and would like to request this information, please
submit your request using the contact details provided under the “Contact”
heading.


DATA PROCESSING AGREEMENT 

If the provision of products and/or services constitutes processing by Sophos of
personal data as processor under applicable data protection laws, Sophos’
obligations are documented in the Sophos Data Processing Addendum (“DPA
Addendum”). The DPA Addendum is incorporated by reference into our agreements
with our Customers, Managed Service Providers and OEM partners. If you require a
signable Data Processing Agreement (“DPA”), you can countersign our pre-signed
version here.    

Please note, Sophos will not sign a Data Processing Agreement with its
distributors and resellers, unless they are using Sophos products. Order data
from end customers that is provided by distributors/ resellers to Sophos is
received by Sophos in its capacity as a data controller.  


CONTACT

This is the website of Sophos Limited, a company registered in England and Wales
under company number 2096520, whose registered office is at The Pentagon,
Abingdon Science Park, Abingdon, Oxon, OX14 3YP, United Kingdom, and whose VAT
registration number is 991 2418 08. Sophos Limited is the controller of personal
data collected under this privacy policy (unless we indicate otherwise).

We have appointed individuals who are responsible for the protection and
security of your personal data. If you have any questions, comments, concerns,
grievances, or complaints about this privacy policy or the manner in which we
treat your personal data, or if you want to request any information about your
personal data or believe that we are holding incorrect personal data on you,
please contact our Data Protection and Privacy team at
dataprotection@sophos.com.

If you wish to unsubscribe from marketing communications, please email
unsubscribe@sophos.com.


NOTIFICATION OF CHANGES

We reserve the right to amend or vary this policy from time to time to reflect
evolving legal, regulatory, or business practices. When we update our privacy
policy, we will take appropriate measures to inform you, consistent with the
significance of the changes we make (which, for minor changes, may include
posting the revised privacy policy to our Site with immediate effect). Please
check this page periodically for changes. We will obtain your consent to any
material privacy policy changes if and where this is required by applicable data
protection laws.

You can see when this privacy policy was last updated by checking the “last
updated” date displayed at the top of this privacy policy under the “General”
heading.

Sophos Group Privacy Notice


PRIVACY

 * Sophos Group Privacy Notice
 * Data Processing Addendum
 * Sophos Sub-processor List
 * Sophos Cookie Information


LEGAL

 * Column 1
   * Privacy
     * Cookies
     * GDPR
     * Shareholder Data Privacy
 * Column 2
   * Global Trade Compliance
     * Export Information on Sophos Products
     * Sophos Product Classifications
 * Column 3
   * Policies
     * Modern Slavery Policy
     * Data Handling Statement
     * Sophos Anti-Corruption Policy
     * SophosLabs Information Security Policy
     * Employee Personal Use Policy
 * Column 4
   * Agreements - Terms & Conditions
     * Sophos End-User License Agreement (EULA)
     * EULA Addendum for Government Licensees or Users
     * Sophos Services Agreement
     * Service Description - Sophos Managed Threat Response and Rapid Response

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© 1997-2022 Sophos Ltd. All Rights Reserved.




PRIVACY PREFERENCE CENTER




 * YOUR PRIVACY


 * STRICTLY NECESSARY COOKIES


 * PERFORMANCE COOKIES


 * FUNCTIONAL COOKIES


 * TARGETING COOKIES


YOUR PRIVACY

When you visit any website, it may store or retrieve information on your
browser, mostly in the form of cookies. This information might be about you,
your preferences or your device and is mostly used to make the site work as you
expect it to. The information does not usually directly identify you, but it can
give you a more personalized web experience. Because we respect your right to
privacy, you can choose not to allow some types of cookies. Click on the
different category headings to find out more and change our default settings.
However, blocking some types of cookies may impact your experience of the site
and the services we are able to offer.
More information


STRICTLY NECESSARY COOKIES

Always Active

These cookies are necessary for the website to function and cannot be switched
off in our systems. They are usually only set in response to actions made by you
which amount to a request for services, such as setting your privacy
preferences, logging in or filling in forms.    You can set your browser to
block or alert you about these cookies, but some parts of the site will not then
work. These cookies do not store any personally identifiable information.


PERFORMANCE COOKIES

Performance Cookies


These cookies allow us to count visits and traffic sources so we can measure and
improve the performance of our site. They help us to know which pages are the
most and least popular and see how visitors move around the site.    All
information these cookies collect is aggregated and therefore anonymous. If you
do not allow these cookies we will not know when you have visited our site, and
will not be able to monitor its performance.


FUNCTIONAL COOKIES

Functional Cookies


These cookies enable the website to provide enhanced functionality and
personalisation. They may be set by us or by third party providers whose
services we have added to our pages.    If you do not allow these cookies then
some or all of these services may not function properly.


TARGETING COOKIES

Targeting Cookies


These cookies may be set through our site by our advertising partners. They may
be used by those companies to build a profile of your interests and show you
relevant adverts on other sites.    They do not store directly personal
information, but are based on uniquely identifying your browser and internet
device. If you do not allow these cookies, you will experience less targeted
advertising.


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