Effective starting: November 18, 2020
What this policy covers
Your privacy is important to us, and so is being transparent about how we collect, use, and share information about you. This policy is intended to help you understand:
- What information we collect about you
- How we use information we collect
- How we share information we collect
- How we store and secure information we collect
- How to access and control your information
- Other important privacy information
This policy also explains your choices surrounding how we use information about you, which include how you can object to certain uses of information about you and how you can access and update certain information about you. If you do not agree with this policy, do not access or use our Services or interact with any other aspect of our business.
Where we provide the Services under contract with an organization (for example, your employer) that organization controls the information processed by the Services. For more information, please see Notice to End Users below. This policy does not apply to the extent we process personal information in the role of a processor on behalf of such organizations.
What information we collect about you
We collect information about you when you provide it to us, when you use our Services, and when other sources provide it to us, as further described below.
Information you provide to us
We collect information about you when you input it into the Services or otherwise provide it directly to us.
- Account and Profile Information: We collect information about you when you register for an account, create or modify your profile, set preferences, or contract for Services. For example, you provide your contact information and, in some cases, billing information, when you contract for the Services. You also have the option of adding a user name and other details to your profile information in our portal.
- Content you provide through our services: The Services include the Soteria products you use, where we collect and store content that you post, send, receive and share. This content includes any information about you that you may choose to include.
- Content you provide through our website: The Services also include our website. We collect other content that you submit to this website, which include social media or social networking websites operated by us. For example, you provide content to us when you provide feedback or when you participate in any interactive features, surveys, activities or events.
- Information you provide through our support: The Services also include our customer support, where you may choose to submit information regarding a problem you are experiencing with a Service. Whether you designate yourself as a technical contact, open a support ticket, speak to one of our representatives directly or otherwise engage with our support team, you will be asked to provide contact information, a summary of the problem you are experiencing, and any other documentation, screenshots or information that would be helpful in resolving the issue.
- Payment Information: We collect payment and billing information when you contract for paid Services. For example, we ask you to designate a billing representative, including name and contact information, upon registration. You might also provide payment information, which we collect via secure third party payment processing services.
Information we collect automatically when you use the Services
- We collect information about you when you use our Services. The types and nature of the data collected by our services is detailed in our service contracts.
- Device and Connection Information: We collect information about your computer, phone, tablet, or other devices you use to access the Services. This device information includes details about your operating system, browser type, IP address, and URLs of referring/exit pages.
Information we receive from other sources
We receive information about you from other Service users. This helps us to update and improve our records, identify new customers, create more personalized services.
Other users of the Services: Other users of our Services may provide information about you when they submit content through the Services. For example, you may have one team completing a security assessment and another team utilizing managed detection services by Soteria. Similarly, an administrator may provide your contact information when they designate you as the billing or technical contact on your company’s account or when they designate you as an administrator.
How we use information we collect
How we use the information we collect depends in part on which Services you use, how you use them, and any preferences you have communicated to us. Below are the specific purposes for which we use the information we collect about you.
- To provide the Services and personalize your experience: We use information about you to provide the Services to you, including to process transactions with you, authenticate you when you log in, provide customer support, and operate, maintain, and improve the Services. We may use your email domain to infer your affiliation with a particular organization or industry to personalize the content and experience you receive on our websites. Where you use multiple Services, we combine information about you and your activities to provide an integrated experience, such as to allow you to find information from one Service while searching from another or to present relevant product information as you travel across our websites. Based on your interactions with different Soteria products, we will personalize your experience and tailor our communications and offers to you.
- For research and development: We are always looking for ways to make our Services smarter, faster, secure, integrated, and useful. We use information and collective learnings (including feedback) about how people use our Services to troubleshoot, to identify trends, usage, activity patterns, and areas for integration and to improve our Services and to develop new products, features and technologies that benefit our users and the public. We also test and analyze certain new features with some users before rolling the feature out to all users.
- To communicate with you about the Services: We use your contact information to send transactional communications via email and within the Services, including confirming your purchases, reminding you of subscription expirations, responding to your comments, questions and requests, providing customer support, and sending you technical notices, updates, security alerts, and administrative messages. We also send you communications as you onboard to a particular Service to help you become more proficient in using that Service. These communications are part of the Services and in most cases you cannot opt out of them. If an opt out is available, you will find that option within the communication itself or in your account settings.
- To market, promote and drive engagement with the Services: We use your contact information and information about how you use the Services to send communications that may be of specific interest to you, including by email. We also communicate with you about new Services, product offers, promotions, and contests. You can control whether you receive these communications as described below under “Opt-out of communications.”
- Customer support: We use your information to resolve technical issues you encounter, to respond to your requests for assistance, and to repair and improve the Services.
- For safety and security: We use information about you and your Service to verify accounts and activity, to detect, prevent, and respond to potential or actual security incidents and to monitor and protect against other malicious, deceptive, fraudulent or illegal activity, including violations of Service policies.
- To protect our legitimate business interests and legal rights: Where required by law or where we believe it is necessary to protect our legal rights, interests and the interests of others, we use information about you in connection with legal claims, compliance, regulatory, and audit functions, and disclosures in connection with business activities.
- With your consent: We use information about you where you have given us consent to do so for a specific purpose not listed above. For example, we may publish testimonials or featured customer stories to promote the Services, with your permission.
How we share information we collect
We are not in the business of selling information about you to advertisers or other third parties.
Sharing with other Service users
When you use the Services, we share certain information about you with other Service users.
- Managed accounts and administrators: If you register or access the Services using an email address with a domain that is owned by your employer or organization or associate that email address with your existing account, and such organization wishes to establish an account, certain information about you including your name, contact info, content and past use of your account may become accessible to that organization’s administrator and other Service users sharing the same domain. If you are an administrator for a particular site or group of users within the Services, we may share your contact information with current or past Service users, for the purpose of facilitating Service-related requests.
Sharing with third parties
We share information with third parties that help us operate, provide, improve, integrate, customize, support and market our Services.
- Compliance with Enforcement Requests and Applicable Laws; Enforcement of Our Rights: In exceptional circumstances, we may share information about you with a third party if we believe that sharing is reasonably necessary to (a) comply with any applicable law, regulation, legal process or governmental request, including to meet national security requirements, (b) enforce our agreements, policies and terms of service, (c) protect the security or integrity of our products and services, (d) protect Soteria, our customers or the public from harm or illegal activities, or (e) respond to an emergency which we believe in good faith requires us to disclose information to assist in preventing the death or serious bodily injury of any person. For more information on how we respond to government requests, contact us at email@example.com.
How we store and secure information we collect
Information storage and security
We use industry standard technical and organizational measures to secure the information we store. For more information on where and how we store your information, please contact us at firstname.lastname@example.org.
While we implement safeguards designed to protect your information, no security system is impenetrable and due to the inherent nature of the Internet, we cannot guarantee that information, during transmission through the Internet or while stored on our systems or otherwise in our care, is absolutely safe from intrusion by others.
If you use our server or data centers, responsibility for securing storage and access to the information you put into the Services rests with you and not Soteria. We strongly recommend that server or data center users configure SSL to prevent interception of information transmitted over networks and to restrict access to the databases and other storage points used.
How long we keep information
How long we keep information we collect about you depends on the type of information, as described in further detail below. After such time, we will either delete or de-identify your information or, if this is not possible (for example, because the information has been stored in backup archives), then we will securely store your information and isolate it from any further use until deletion is possible.
- Account information: We retain your account information for as long as your account is active and a reasonable period thereafter in case you decide to re-activate the Services. Where we retain information for Service improvement and development, we take steps to eliminate information that directly identifies you, and we only use the information to uncover collective insights about the use of our Services, not to specifically analyze personal characteristics about you.
- Information you share on the Services: If your account is deactivated or disabled, some of your information and the content you have provided will remain in order to allow your team members or other users to make full use of the Services. For example, we continue to display messages you sent to the users that received them and continue to display content you provided, but when requested details that can identify you will be removed.
- Managed accounts: If the Services are made available to you through an organization (e.g., your employer), we retain your information as long as required by the administrator of your account. For more information, see “Managed accounts and administrators” above.
- Marketing information: If you have elected to receive marketing emails from us, we retain information about your marketing preferences for a reasonable period of time from the date you last expressed interest in our Services, such as when you last opened an email from us or ceased using your Soteria account. We retain information derived from cookies and other tracking technologies for a reasonable period of time from the date such information was created.
How to access and control your information
You have certain choices available to you when it comes to your information. Below is a summary of those choices, how to exercise them and any limitations.
You have the right to request a copy of your information, to object to our use of your information (including for marketing purposes), to request the deletion or restriction of your information, or to request your information in a structured, electronic format. Below, we describe the tools and processes for making these requests. Where the Services are administered for you by an administrator (see “Notice to End Users” below), you may need to contact your administrator to assist with your requests first. For all other requests, you may contact us as provided in the Contact Us section below to request assistance.
Your request and choices may be limited in certain cases: for example, if fulfilling your request would reveal information about another person, or if you ask to delete information which we or your administrator are permitted by law or have compelling legitimate interests to keep. Where you have asked us to share data with third parties, for example, by installing third-party apps, you will need to contact those third-party service providers directly to have your information deleted or otherwise restricted. If you have unresolved concerns, you may have the right to complain to a data protection authority in the country where you live, where you work or where you feel your rights were infringed.
- Access and update your information: Our Services and related documentation give you the ability to access and update certain information about you from within the Service. For example, you can access your profile information from your account. You can update your profile information within your profile settings and modify content that contains information about you using the editing tools associated with that content.
- Deactivate your account: If you no longer wish to use our Services, you or your administrator may be able to deactivate your portal account. Please be aware that deactivating your account does not delete your information; your information remains visible based on your past participation within the Services. For more information on how to delete your information, see below.
- Delete your information: Our Services and related documentation give you the ability to delete certain information about you from within the Service. Please note, however, that we may need to retain certain information for record keeping purposes, to complete transactions or to comply with our legal obligations.
- Request that we stop using your information: In some cases, you may ask us to stop accessing, storing, using and otherwise processing your information where you believe we don’t have the appropriate rights to do so. For example, if you believe an account was created for you without your permission or you are no longer an active user, you can request that we delete your account as provided in this policy. Where you gave us consent to use your information for a limited purpose, you can contact us to withdraw that consent, but this will not affect any processing that has already taken place at the time.
- Opt out of communications: You may opt out of receiving promotional communications from us by using the unsubscribe link within each email, updating your email preferences within your Service account settings menu, or by contacting us as provided below to have your contact information removed from our promotional email list or registration database. Even after you opt out from receiving promotional messages from us, you will continue to receive transactional messages from us regarding our Services. You can opt out of some notification messages in your account settings.
Other important privacy information
Notice to End Users
Our products are intended for use by organizations. Where the Services are made available to you through an organization (e.g. your employer), that organization is the administrator of the Services and is responsible for the accounts and/or Service sites over which it has control. If this is the case, please direct your data privacy questions to your administrator, as your use of the Services is subject to that organization’s policies. We are not responsible for the privacy or security practices of an administrator’s organization, which may be different than this policy.
Please contact your organization or refer to your administrator’s organizational policies for more information.
- Exercising your rights: If you are a California resident, there are some additional rights that may be available to you under the California Consumer Protection Act (“CCPA”). This policy explains the tools that we have made available to you to exercise your data rights under the CCPA, such as the right to deletion and the right to request access to the categories of information we have collected about you. For more information on how to exercise your rights please visit the “How to access and control your information” section of this policy. In order to protect your information from unauthorized access or deletion, we may require you to provide additional information for verification. If we cannot verify your identity, we will not provide or delete your information.
- Sharing your personal information: We don’t sell your personal information. We do share your information with others as described in the “How we share information we collect” section of this policy.
- Processing your information: This policy describes the categories of personal information we may collect, the sources of that information, and our deletion and retention policies. We’ve also included information about how we may process your information, which includes for “business purposes” under the CCPA – such as to protect against illegal activities, and for the development of new products, features, and technologies. If you have questions about the categories of information we may collect about you, please be sure to visit the section of this policy called, “What information we collect about you.” For more details about our processing activities, please be sure to visit the section called, “How we use information we collect.”
If you have any questions or would like to exercise your rights under the CCPA, you can reach out to us at email@example.com.
Our policy towards children
The Services are not directed to individuals under 18. We do not knowingly collect personal information from children under 18. If we become aware that a child under 18 has provided us with personal information, we will take steps to delete such information. If you become aware that a child has provided us with personal information, please contact us at firstname.lastname@example.org.
Your information is controlled by Soteria. If you have questions or concerns about how your information is handled, please direct your inquiry to email@example.com, which we have appointed to be responsible for facilitating such inquiries