Privacy Policy of White Hat IT Security

Effective Date: September 1, 2020

This is the Privacy Policy of White Hat T Security and its wholly owned subsidiaries (collectively, “White Hat,” “we,” “our,” or “us”). We provide security solutions that help protect the data and systems of our business customers from continually evolving risks. It is our policy to provide security and privacy. Each is important, and they are sometimes co-dependent. We believe in Security by Design and Privacy by Design. This Privacy Policy covers White Hat IT Security’s handling of two categories of information:

  • Personal data that our partners and customers ask us to process on their behalf (“Processor Data”). White Hat IT Security offers security services and solutions, and related support and professional services (i.e. the “White Shark Managed Security Services”). With some exceptions as identified below, under applicable law, in certain contexts White Hat is considered the “processor” of the personal data we receive through the White Shark services or through our other IT security services, and our customer is (or acts on behalf of) the “controller” of the data (i.e. the company with the right to decide how the data is used).
  • Personal data that we handle for our own business (“Controller Data”), other than for our human resources and recruiting operations. Under applicable law, White Hat is a “controller” of this data.

This Privacy Policy includes details specific to Processor Data, details specific to Controller Data, and information relevant to our handling of both kinds of data.

1. Privacy Practices Specific to Processor Data
a. Types of Processor Data We Collect

We receive information from or on behalf of our customers and their users, and for most of such data, we act as a “processor.” Because of the nature of the White Shark and other White Hat services, this information may contain any type of personal data. For example, we may collect the following categories of information, that may be Processor Data, through the White Shark MSS:

  • Device identifiers, such as IP addresses, firmware versions, operating system, time zone, language, MAC addresses, and other information about computing systems, applications, and networks;
  • Contact details and registration information (including identifiers), such as names, emails, age, gender, phone numbers, and photographs;
  • Internet or other electronic network or device activity information, such as system logs, traffic, URLs, metadata, and antivirus and other malware statistics;
  • Other information that identifies or can be reasonably associated with you, including information contained in files, communications content, and information provided to us through dashboards or portals associated with the security and firewall solutions of the White Shark MSS, such as troubleshooting requests and security inquiries regarding files, systems.

Some of the technical information listed above is considered personal data in certain contexts. White Hat also collects Processor Data through the technology described in the “Cookies and Similar Automated Data Collection” section below. We use Processor Data as described in the following section.

b. Uses of Processor Data

Subject to our contractual obligations, and depending on the particular White Hat services, we may use and disclose the information described above (sometimes in combination with other information we obtain, such as from our customers) as follows:

  • To provide the White Hat Services, including by:
    • Providing maintenance and technical support
    • Providing product upgrades
    • Addressing security and business continuity issues
    • Analysing and improving the White Shark MSS
  • To enforce the legal terms that govern the White Hat Services
  • To comply with law and protect rights, safety, and property
  • For other purposes requested or permitted by our customers or users, or as reasonably required to perform our business.

Many White Hat Services like White Shark MSS use automated technology to recognize and defend against cybersecurity risks, such as by blocking or quarantining suspected malicious data. To better protect our customers and assist them with their own security compliance, some White Hat services use external threat information gathered in these situations to improve security for customers of White Hat services in similar situations. For example, if certain White Hat services determine that a hacker is attacking some of our customers, we may use information about that threat in order to help protect other customers from similar attacks. This provides our customers’ data with much better protection than what would be possible if our services could not learn from experience. We handle “Threat Data” like this as described in the “Privacy Practices Specific to Controller Data” section below.

c. Disclosures of Processor Data

Subject to our contractual obligations, and depending on the particular White Hat Services, we may disclose the information described above as follows:

  • To provide the White Hat Services, which can involve sharing personal data with our customer and with third parties selected by the customer or its users (for example, to detect security incidents, and protect against malicious, deceptive, fraudulent, or illegal activity, we process data about third-party threat actors such as the IP address of certain hacker-controlled devices that attempt cyberattacks on our customers)
  • To enforce the legal terms that govern the White Hat Services
  • To comply with law, and where we deem disclosure appropriate to protect rights, safety and property (for example, for national security or law enforcement)
  • As part of an actual or contemplated business sale, merger, consolidation, change in control, transfer of substantial assets or reorganization
  • For other purposes requested or permitted by our customers or users, or as reasonably required to perform our business.

For those purposes, we may share information with our affiliates and other entities that help us with the activities described in this Privacy Policy.

2. Privacy Practices Specific to Controller Data
a. Types of Controller Data We Collect

As described above, we act as a processor for most of the White Hat Services. We are, however, a “controller” under applicable law with respect to Controller Data. Controller Data includes two general categories of data: Business Data and Threat Data.

For example, we may collect certain data about customers, prospective customers, partners and their personnel (“Business Data”), which may include:

  • Contact details and professional details, such as name, email address, phone number, title and name of company
  • Information about users’ experience with our products, services or events
  • Information about actual or prospective customer personnel’s other interactions with White Hat, e.g., procurement, customer service, and point of sale data
  • Data we handle in connection with the White Hat Certified Defender training and other training and certification programs, including contact information, identity documents and other personal data collected for authentication of the candidate’s identity and test security, and testing results.
  • Information about actual or prospective users’ interests
  • Financial data, such as payment information for White Hat products and services
  • Investor relations-related data
  • Other business-related data collected on our websites (such as online forum registrations) and elsewhere for our own business (such as at events).

We obtain Business Data directly from the relevant individuals or their employers, and also from third-party sources, such as distributors, resellers and partners, credit card issuers, clearinghouses, data brokers, fraud databases, referrals from customers and users, as well as publicly available sources such as company websites.

In connection with some White Hat Services, White Hat is also considered a controller of certain personal data relevant to security threats, i.e. “Threat Data.” To the extent it is personal data, IP addresses, device identifiers, URLs, and other data associated with malicious activity are part of Threat Data. We obtain Threat Data through White Hat Services, publicly available sources such as online forums, other security providers and researchers, and independent research.

White Hat also collects Business Data and Threat Data through the technology described in the Cookies and Similar Automated Data Collection section below. We use all Controller Data as described in the following section.

b. Uses of Controller Data (Business Data and Threat Data)

White Hat uses Controller Data as follows:

  • To provide our products, services, events, websites, communities, training, certifications, and other business offerings
  • For marketing, advertising, and other communications (including customizing and tailoring all of them for the particular recipient)
  • To manage our relationships with customers, partners, suppliers, event attendees, and others
  • For surveys and other market research
  • For cybersecurity research
  • To analyse, improve, and create White Hat Services and other business offerings
  • To enforce the legal terms that govern our business and online properties
  • To provide security and business continuity
  • To comply with law and protect rights, safety, and property
  • For other purposes requested or permitted by our customers or users, or as reasonably required to perform our business.
c. Disclosures of Controller Data (Business Data and Threat Data)

Subject to our contractual obligations, we share the information described above as follows:

  • For the uses of information described above
  • As part of an actual or contemplated business sale, merger, consolidation, change in control, transfer of substantial assets or reorganization
  • For other purposes requested or permitted by our customers or users, or as reasonably required to perform our business.

For those purposes, we may share information with our affiliates, contractual partners and other entities that help us with the activities described in this Privacy Policy. We shall not share any of the abovementioned information for marketing purposes with 3rd parties or as entire database or bulk data.

d. Legal Bases for Processing Controller Data (Business Data and Threat Data)

The laws in some jurisdictions require companies to tell you about the legal ground they rely on to use or disclose your personal data. To the extent those laws apply, our legal grounds for processing Controller Data are as follows:

  • Legitimate interests: In most cases, we handle personal data on the ground that it furthers our legitimate interests in commercial activities such as the following in ways that are not overridden by the interests or fundamental rights and freedoms of the affected individuals:
    • Protecting our business, personnel and property
    • Providing cybersecurity, including for the protection of personal data
    • Customer service
    • Marketing
    • Analysing and improving our business; and/or
    • Managing legal issues

We may also process personal data for the same legitimate interests of our customers and business partners.

  • To honour our contractual commitments to the individual: Some of our processing of personal data is to meet our contractual obligations to individuals, or to take steps at the individuals’ request in anticipation of entering into a contract with them.
  • Consent: Where required by law, and in some other cases, we handle personal data on the basis of consent. Where legally required (e.g., for the use of fingerprints for security purposes in certain jurisdictions), this is explicit consent.
  • Legal compliance: We need to use and disclose personal data in certain ways to comply with our legal obligations.
3. Additional Information About Our Privacy Practices (applicable to both Processor Data and Controller Data)
a. Personal Data Rights and Choices (including Direct Marketing Opt-Out)

We offer the options described below for exercising rights and choices under applicable law. Many of these are subject to important limits or exceptions under applicable law.

  • To exercise rights or choices with respect to Processor Data, please make your request directly to the White Hat customer for whom we process the data, particularly if the self-service options described below do not fully resolve your concern.
  • You may review and update certain user information by logging in to the relevant portions of the White Hat Services or White Hat websites or online services or by contacting White Hat personnel.

In addition, the law of your jurisdiction (for example, within the European Economic Area) may give you additional rights to request access to and rectification or erasure of certain of your personal data we hold. In some cases, you may be entitled to receive a copy of the personal data you provided to us in portable form or to request that we transmit it to a third party. The law may also give you the right to request restrictions on the processing of your personal data, to object to processing of your personal data, or to withdraw consent for the processing of your personal data (which will not affect the legality of any processing that happened before your request takes effect).

You may contact us as described below to make these requests.

  • For example, residents of the European Union and European Economic Area and certain other jurisdictions have a right to opt out of our processing of Controller Data for direct marketing purposes. You can exercise this right by contacting us at our contact data described below.
  • Our marketing emails and certain other communications include unsubscribe instructions, which you can use to limit or stop the relevant communications. Opt-out processes may take some time to complete, consistent with applicable law. Certain communications (such as certain billing-related communications or emergency service messages) are not subject to opt-out.
  • Many White Hat Services are designed to block hacking and other unauthorized activity, and they use automated means to compare user activity or device traits to similar data points that been associated with hacking or other unauthorized activity. If you believe that our services have been used to block you in error, please contact the relevant White Hat customer for assistance.
  • You may contact us with any concern or complaint regarding our privacy practices, and you also may lodge a complaint with the relevant governmental authority.
b. Aggregate or De-Identified Data

Subject to applicable law and our contractual obligations, (i) we may aggregate or de-identify Controller Data or Processor Data so that the information cannot be linked to the relevant individual and (ii) our use and disclosure of aggregated, anonymized, and other non-personal information is not subject to any restrictions under this Privacy Policy or applicable laws, and we may disclose it to others without limitation for any purpose.

c. Cookies and Similar Automated Data Collection

In our websites, apps and emails, we and third parties may collect certain information by automated means such as cookies, Web beacons, JavaScript and mobile device functionality. This information may include unique browser identifiers, IP address, browser and operating system information, device identifiers (such as the Apple IDFA or Android Advertising ID), geolocation, other device information, Internet connection information, as well as details about individuals’ interactions with our apps, websites and emails (for example, the URL of the third-party website from which you came, the pages on our websites that you visit, and the links you click on in our websites).

We and third parties may use automated means to read or write information on users’ devices, such as in various types of cookies and other browser-based or plugin-based local storage (such as HTML5 storage or Flash-based storage).

Cookies and local storage are files that contain data, such as unique identifiers, that we or a third party may transfer to or read from a user’s device for the purposes described in this Privacy Policy, such as recognizing the device, service provision, record-keeping, analytics and marketing, depending on the context of collection.

You may be able to set your web browser to refuse certain types of cookies, or to alert you when certain types of cookies are being sent. Some browsers offer similar settings for HTML5 local storage, and Flash storage can be managed here. However, if you block or otherwise reject our cookies, local storage, JavaScript or other technologies, certain websites (including our own websites) may not function properly.

These technologies help us (a) keep track of whether you are signed in or have previously signed in so that we can display all the features that are available to you; (b) remember your settings on the pages you visit, so that we can display your preferred content the next time you visit; (c) display personalized content; (d) perform analytics, and measure traffic and usage trends, and better understand the demographics of our users; (e) diagnose and fix technology problems; and (f) otherwise plan for and enhance our business.

Also, in some cases, we may through no fault or intention of our own facilitate the collection of information by advertising services administered by third parties (i.e. Google, ISP or domain provider). These ad services may track users’ online activities over time by collecting information through automated means such as cookies, and they may use this information to show users ads that are tailored to their individual interests or characteristics and/or based on prior visits to certain sites or apps, or other information we or they know, infer or have collected from the users. For example, these providers may use different types of cookies, other automated technology, and data (i) to recognize users and their devices, (ii) to inform, optimize, and serve ads and (iii) to report on our ad impressions, other uses of ad services, and interactions with these ad impressions and ad services (including how they are related to visits to specific sites or apps).

To learn more about interest-based advertising generally, including how to opt out from the targeting of interest-based ads by some typical ad service providers, visit aboutads.info/choices or youronlinechoices.eu from each of your browsers. You can opt out of Google Analytics and customize the Google Display Network ads by visiting your Google Ads Settings. Google also allows you to install a Google Analytics Opt-out Browser Add-on for your browser. If you replace, change or upgrade your browser, or delete your cookies, you may need to use these opt-out tools again. We do not respond to browser-based do-not-track signals.

Please visit your mobile device manufacturer's website (or the website for its operating system) for instructions on any additional privacy controls in your mobile operating system, such as privacy settings for device identifiers and geolocation.

d. International Data Transfers

White Hat and the recipients of the data disclosures described in this Privacy Policy have locations mainly in the European Union but also elsewhere in the world, including where privacy laws may not provide as much protection as those of your country of residence. White Hat data centres for Processor Data are located primarily in the EU. We comply with legal requirements for cross-border data protection, including through the use of European Commission-approved Standard Contractual Clauses. To exercise any legal right to request data transfer mechanism documents that White Hat uses to transfer data to third parties, please contact us.

Certain White Hat Services allow our customers and users to make international data transfers to third parties, for which they are solely responsible.

e. Security

We have put in place physical, electronic, and managerial procedures to safeguard data and help prevent unauthorized access, to maintain data security, and to use correctly the data we collect. However, we cannot assure you that data that we collect will never be used or disclosed in a manner that is inconsistent with this Privacy Policy.

If a password is used to help protect your personal information, it is your responsibility to keep the password confidential. Do not share this information with anyone.

f. Data Retention

We will retain your information for the period necessary to fulfil the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law. To provide security and business continuity for the activities described in this Privacy Policy, we make backups of certain data, which we may retain for longer than the original data. For example, some of our White Shark MSS features may store logs of suspicious activities for 1 year.

g. Notification of Changes

White Hat reserves the right to change this Privacy Policy at any time to reflect changes in the law, our data collection and use practices, the features of our services, or advances in technology. Please check this page periodically for changes. Any updated Privacy Policy will be posted on https://whitehat.eu and https://whiteshark.io via a hyperlink in the footer or other convenient location.

h. How to Contact Us

If you have questions regarding our practices or this Privacy Policy, please contact us at privacy@whitehat.eu.

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