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BUFFERZONE SECURITY, INC. PRIVACY POLICY

Introduction

This Privacy Policy (“Policy”) informs you of BUFFERZONE Security, Inc.’s (“BUFFERZONE,” “We,” “Us,” “Our” or related terms, and including Our wholly owned subsidiaries (collectively, “BUFFERZONE Security Ltd”)) commitment to protecting the privacy of individuals who visit our website bufferzonesecurity.com and its subdomains (“Site Visitors” and “Site”), as well as the privacy of individuals whose personal information is shared with Us in connection with the downloading and installation of our software (“Software”) offered as part of subscriptions to our BUFFERZONE Solutions (the “Solutions” and together with the Site and Software, “BUFFERZONE Services”). For the purposes of this Policy, the term Site shall refer collectively to bufferzonesecurity.com and its subdomains as well as any other websites that We operate and that link to this Policy. By visiting the Site, downloading the Software and/or subscribing to the Solutions, you agree to the terms of this Policy.

Scope of this Policy

In this Policy, “Personal Information” means any information relating to an identified or identifiable natural person, whereby an identifiable natural person is one who can be identified, directly or indirectly, by particular reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

The use of information collected through our BUFFERZONE services is limited to the purpose of providing the service for which you have engaged with Us, as further described below, and in compliance with applicable laws and the terms of this Policy. When you visit the Site, We collect information, including Personal Information, only as necessary to interact with you, improve your user experience and provide you relevant data and services. We collect information, including Personal Information, under the direction of subscribers to any of the BUFFERZONE Services (“Subscriber(s)”), and have no direct relationship with individuals whose Personal Information We may process in connection with one of Our Subscribers’ subscription to and/or use of the BUFFERZONE Services. If you are an individual who interacts with the BUFFERZONE Services in connection with your relations with a Subscriber (such as an employee of one of our Subscribers) and would no longer like your Personal Information to be processed by Us in providing BUFFERZONE services to a Subscriber, please contact the Subscriber that you interact with directly.

Personal Information Collection and Use

BUFFERZONE Site. When you visit Our Site to learn about BUFFERZONE and its BUFFERZONE Services, or to portals connecting to the Site, We gather information only as necessary to interact with you, provide you relevant data and services, contact you about Our BUFFERZONE Solutions, personalize or customize your experience (based on preferences or geography, for example), send you relevant marketing materials (subject to your opt-out option), for research purposes, and to generally improve the content and availability of the Site. Most of the information We collect is aggregated automatically, does not include Personal Information and includes Internet Protocol (IP) address, information about your browser and operating system, the state and country from which you access the Site, device ID, the type of computer and technical information about a user’s means of connection to the Site or related portals, the Internet service providers utilized, and Site features you access while browsing the Site. We may also send you notifications via email regarding BUFFERZONE Services to keep you informed of any BUFFERZONE Services updates, support or similar information. If you would like to review your communication preferences, or amend the manner and/or frequency at which you receive information or materials from Us, you can update your information or opt-out by following the instructions contained within email communication from Us. You can also contact us at support@bufferzonesecurity.com or write to Us at the address listed at the end of this Policy.

From users who are required to login to gain access to a particular Site feature or portal, We may also collect usernames, passwords and other login credentials for the purpose of verifying user authorization to access the feature or offering. On our Site, you can sign up to receive additional information, attend a webinar, sign up to attend a live event or participate in any other offering. To receive additional information from Us, you must provide information such as your name, company name, email address, and phone number. This information is retained by Us and our third-party business partners to provide you with information, marketing materials, and updates regarding BUFFERZONE Services similar or related to information You have previously requested. Our third-party business partners provide BUFFERZONE with services that may require Us to provide them with your Personal Information. These third-party business partners are not permitted to use the information collected on our behalf except to help Us improve the Site and serve you in relation to your visit to Our Site and interest in the BUFFERZONE Services. BUFFERZONE requires all its third-party business partners with whom it shares Personal Information collected from the Site to take commercially reasonable steps and implement policies to safeguard your Personal Information. We do not sell, share or rent the Personal Information we collect from the Site to others.

The Site may offer publicly accessible blogs, community forums, comments sections, discussion forums, or other interactive features (“Interactive Areas”). Any information that you post in an Interactive Area might be read, collected, and used by others who access it. To request removal of your Personal Information from an Interactive Area, contact us at support@bufferzonesecurity.com. In some cases, We may not be able to remove your Personal Information, in which case We will inform you of the underlying reasons. If you provide Us with feedback about BUFFERZONE, the Solutions, Software or Site, We consider this to be freely given and We may use your feedback without compensation or attribution to you.

Our Site also includes social media features. These features may collect your IP address, which webpage you are visiting on our Site, and may set a cookie to enable the feature to function properly. Social media features are either hosted by a third-party or hosted directly on our Site. Your interactions with these features are governed by the privacy policy of the company providing it.

From time to time, We may post testimonials on the Site or associated portals that may contain Personal Information. We obtain your consent to post your name along with your testimonial. If you wish to update or delete your testimonial, you can contact us at support@bufferzonesecurity.com.

BUFFERZONE Solutions. The BUFFERZONE Solutions offer a comprehensive Management Console (BZMS), and endpoint agents, comprising of multiple functionalities and features including malware protection and sanitization; comprehensive statistical analysis of Subscribers’ endpoints’ behavior; data presentation tools; security tools; connected devices identification; endpoint controls and more.

Most of the information that BUFFERZONE collects through the Solutions is not Personal Information and relates to the computing processes of devices protected against malware infection by the BUFFERZONE Services, or device standard identifiers. Such information includes device or network usage, endpoint login data, types and versions of operating systems and browsers, computer name, file execution information, and information about installed software applications. Some of the data We collect may be considered Personal Information depending on the laws of the jurisdiction where it is collected, such as IP addresses and endpoint browsing history. In some cases We collect Personal Information to the extent it is included within usernames, filenames, file paths, and machine names. We also offer Our Subscribers the ability to directly provide Us or to configure the Solutions to collect files, endpoint browsing history, and other content which may constitute and/or contain Personal Information, or when submitting crash reports, to make the product more reliable. At your direction, We may also collect or retrieve files as part of our Solutions, additional data to analyze certain malware threats, or network information to enable connected device discovery and mapping. Files, file names, file paths and machine names, for example, may contain Personal Information if such Personal Information is included in such files.

To the extent that We collect your Personal Information through our BUFFERZONE Solutions, We do so under the authority and direction of Our Subscribers, which often are corporate entities. BUFFERZONE has no direct relationship or contact with individuals whose personal information We may collect or receive from a corporate Subscriber and subsequently analyze and use. The use of information collected through Our Solutions is limited to the purpose of providing the Solutions for which Our Subscribers engage BUFFERZONE. We do not use any Personal Information collected through Our Solutions to contact or market products or services to these individuals. We also do not provide any Personal Information obtained through the Solutions to third parties for the purpose of contacting individuals, or marketing products or services to these individuals. Instead, BUFFERZONE only uses the data it collects to provide the BUFFERZONE Solutions, as well as improve the BUFFERZONE Services, increase reliability and efficacy of the Solutions, and provide our Subscribers the best possible user experience, as more broadly described in Our more specific Solutions documentation. If you are a user of the Solutions, We will obtain the Personal Information you provide Us during the sales and/or fulfillment process. We may use such Personal information including name, phone number, mailing address, and email address to contact you and to provide you the Solutions, send you an invoice, perform accounting, auditing and collection activities, answer questions, provide support and update you about the solutions.

Our Subscribers are solely responsible for establishing policies for and ensuring compliance with all applicable laws and regulations, as well as any and all privacy policies, agreements or other obligations relating to the collection of Personal Information in connection with the use of Our Solutions by individuals with whom such Subscribers interact. We collect information under the direction of our Subscribers, and have no direct relationship with individuals whose Personal Information We process in connection with the use of Our Solutions. If you are an individual associated with one of Our Subscribers whose Personal Information was collected by BUFFERZONE in providing the Solutions to a BUFFERZONE Subscriber, and no longer wishes to be contacted as Our Subscriber’s representative, please contact the relevant Subscriber with whom you work directly. In addition, an individual who seeks access, or would like to correct or delete Personal Information, should direct his/her query to the Subscriber acting as the data controller of such Personal Information. Upon receiving a request from Our Subscribers with respect to Personal Information, including requests to access, correct or delete the Personal Information, We will respond in accordance with the process detailed in this Policy. We will retain the Personal Information We process on behalf of our Subscribers for as long as needed to provide the Solutions to our Subscribers, to comply with our legal obligations, resolve disputes, and enforce our agreements.

We may share your Personal Information with third-party business partners and service providers who assist Us in conducting business and providing you with BUFFERZONE Services. Transfers of Personal Information to such third-party business partners for these purposes are governed by Our Terms of Use with Subscribers subscribing to the BUFFERZONE Solutions and this Policy. BUFFERZONE contractually requires all its third-party business partners with whom it shares Personal Information to take commercially reasonable steps and implement policies to safeguard your Personal Information, and to not use your Personal Information for any purpose other than assist BUFFERZONE e in serving its Subscribers. In the course of interacting with you via the BUFFERZONE Services We may share information, including Personal Information, with any member of the BUFFERZONE Group.

Cookies and Other Tracking Technologies

BUFFERZONE and its service providers use browser cookies, web beacons, tags and scripts or similar technologies to analyze trends, administer the Site, track users’ movements around the Site, and gather demographic information about our user base as a whole. You may manage how your mobile device and browser handles cookies by adjusting its privacy and security settings.

We engage third party providers to serve marketing cookies that enable us to track and analyze usage, navigational and other statistical information from visitors to the Site and to display advertisements on other websites. This information does not include Personal Information though We may reassociate this information with Personal Information we have collected when it is received.  Marketing cookies are also used to track the performance of our advertisements and are employed by third party advertising networks that We utilize. These advertising networks follow online activities of visitors to the Site and use this information to inform, optimize and serve tailored advertisements on the Site or on other websites they visit that We believe would most effectively promote the Service to you. We also use third parties to collect information that assists us in other methods of “remarketing” our Service to visitors to the Site, including customized email communications. We also engage with Google Analytics as a third-party provider for analytics cookies. Analytics cookies collect information about how You use Our Site to help us improve Our Site usage and to better understand what may interest You on Our Site. The information generated by the analytics cookie (including the IP address) is transferred and stored on a Google server located in the United States. Google uses the information on Our behalf to evaluate how the Site is used, create reports about the activities on the website, and to perform additional services regarding website and internet utilization. Further information concerning the terms and conditions of use and data privacy can be found here or here.

You can generally accept or decline the use of cookies through a functionality built into your web browser.  To learn more how to control cookie settings through your browser:

Click here to learn more about the “Private Browsing” setting and cookie setting in FireFox;

Click here to learn more about “Incognito” and cookie setting in Chrome;

Click here to learn more about “InPrivate” and cookie setting in Internet Explorer; or

Click here to learn more about “Private Browsing” and cookie setting in Safari.

You can prevent the collection and processing of analytics cookies via Google by downloading and installing the browser-plugin available under the following link. You can refuse the use of Google Analytics by clicking on the following link. An opt-out cookie will be set on the device, which prevents the future collection of your data when visiting the Site.

If you want to learn more about cookies, or how to control or delete them, please visit http://www.aboutcookies.org for detailed guidance. In addition, certain third-party advertising networks, including Google, permit users to opt out of or customize preferences associated with your internet browsing.  To learn more about this feature from Google, click here.  Please note that if you do elect to disable your web browser’s ability to accept cookies, you may not be able to access or take advantage of many features of the Service.

We and our third-party partners also use Local Storage (HTML5) to provide certain features on Our Site and related portal, to display advertising based on Your browsing activities and to store content and preferences. Various web browsers may offer their own management tools for removing HTML5. If you wish to not have this information used for the purpose of serving you interest-based ads, You may clear Your browsers’ HTML5 storage. If you are located in the European Union, click here to opt out of such HTML5 use. Please note this does not opt you out of being served ads, and you will continue to receive generic ads.

Mobile devices and browsers are different, so refer to instructions related to your device and browser to learn about cookie-related and other privacy and security settings that may be available. You can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functions on our website or service.

We do not currently respond to web browsers’ “Do Not Track” signals that provide a method to opt out of the collection information about visitors’ activities on the Site and BUFFERZONE Services, and across other websites. If we do so in the future, we will provide all relevant information in this Privacy Policy.

As is true with most websites and services delivered over the Internet, BUFFERZONE gathers certain information automatically and stores it in log files. This information includes IP addresses as well as browser, internet service provider, referring/exit pages, operating system, date/time stamp, and click stream data. We may connect Personal Information to information gathered in our log files, as necessary to improve the Service for individual Subscribers. Otherwise, We generally use this information to analyze trends, administer and maintain the Solutions, or track usage of various features within the Service.

Third-Party Links

The Site and other BUFFERZONE Services may include links and/or may allow you to link the Solutions to third-party sites, products or services. Please note that your access to and use of these third-party sites, products or services may result in the collection of or sharing of your information, including Personal Information. These third-parties have separate and independent privacy policies, and We are not responsible or liable for your interactions with such third-parties (as further described in Our Terms of Use). The option to link to such third-party sites, products or services from any BUFFERZONE Services is not an endorsement or representation regarding any third-party sites, products or services, and We encourage you to review and understand such third-parties privacy policies.

Outside Parties; Disclosure of Information

Except as provided in this Policy, We do not lease, rent, or otherwise transfer your Personal Information to third parties. In certain situations, We may be required to disclose Personal Information in response to lawful requests by competent authorities, including to meet law enforcement requirements. We may disclose Personal Information in response to lawful subpoenas, court orders or similar legal process, or to establish or exercise our legal rights or defend against legal claims. We may also share such information if we believe it is necessary in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threat to the physical safety of any person, violations of our Terms of Use, or as otherwise required by law. In addition, We provide information regarding Our business to our auditors and legal counsel and, in some cases, that information may contain Personal Information, however such information may only be used for the purpose of providing Us their professional services.

Security

The security of Our Subscribers data, including your Personal Information, is not only important to Us, it is Our mission! We have adopted a range of administrative, physical and technical security measures based on leading information security standards, to ensure that Our practices in processing and storing Subscribers data protect against unauthorized access, alteration, disclosure or destruction of Subscriber data and your Personal Information. We follow rigorous security standards to ensure excellent protection of Subscribers data and the Personal Information collected and submitted to us, both during transmission and once we receive it. Please contact Us at support@bufferzonesecurity.com with questions about the security of your Personal Information collected through Our Solutions or Site.

International Transfer of Information Collected

BUFFERZONE is a U.S.-based, global company. We store Personal Information about Site Visitors and Subscribers in various regions where Our Subscribers are located, primarily within the European Economic Area (the “EEA”) and the United States. To facilitate Our global operations, We may transfer and access such Personal Information from around the world, including from other countries in which the BUFFERZONE has operations for the purposes described in this Policy. We may also transfer your Personal Information to Our third party subprocessors, who may be located in a different country to you.

Privacy Shield Frameworks

BUFFERZONE complies with the principles of the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework (“Privacy Shield Frameworks”) as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of Personal Information transferred from the European Union and Switzerland to the United States. BUFFERZONE has certified to the Department of Commerce that it adheres to the Privacy Shield Principles, and the Federal Trade Commission (FTC) has jurisdiction over BUFFERZONE’s compliance with the Privacy Shield Principles of notice, access, choice, onward transfer, security, data integrity, access and enforcement (“Principles”). If there is any conflict between the terms in this Policy and the Principles, the Principles shall govern. To learn more about the Privacy Shield Framework please visit https://www.privacyshield.gov/, and to view Our Privacy Shield certification, please visit https://www.privacyshield.gov/list. BUFFERZONE is responsible for the processing of Personal Information it receives under the Privacy Shield Framework and subsequently transfers to a third-party acting as an agent on its behalf. In certain situations, We may be required to disclose Personal Information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

In compliance with the Privacy Shield Principles, BUFFERZONE commits to resolve complaints about Our collection or use of your Personal Information. EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact BUFFERZONE at: BUFFERZONE Security, Inc. (Attn: Legal Department) 800 Chestnut ST STE 26, Philadelphia, PA 19107, United States or by email to support@bufferzonesecurity.com. BUFFERZONE has further committed to refer unresolved Privacy Shield complaints to the Judicial Arbitration and Mediation Services, Inc. (JAMS), an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from Us, or if We have not addressed your complaint to your satisfaction, please contact or visit https://www.jamsadr.com/eu-us-privacy-shield for more information or to file a complaint. The services of JAMS are provided at no cost to you.

It is possible, that under certain conditions, it may be possible for you to invoke a binding arbitration for complaints regarding Privacy Shield compliance not resolved by the other Privacy Shield mechanisms detailed above. For additional information about your right to invoke binding arbitration, please visit: https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint.

Compliance with Applicable Privacy Laws

As a leading information Security company, We are passionate about our Subscribers security and privacy. We process all Personal Information in accordance with applicable data privacy laws. Note, however, that the Solutions do not include dedicated data fields or dedicated databases, for the insertion or hosting of specific Personal Information protected under data privacy regulations such as PCI or HIPAA.

Correcting, Updating and Removing Your Information

Upon request, We will provide you with information about whether We hold, or process on behalf of a third party, any of your Personal Information. To request this information please contact us at support@bufferzonesecurity.com. Subscribers of our Solutions may update or change their account information by editing their profile or organization record or by contacting support@bufferzonesecurity.com for more detailed instructions. To make a request to have Personal Information maintained by us returned to you or removed, please email Us at support@bufferzonesecurity.com. Requests to access, change, or remove your information will be handled within 30 days.

If you are a BUFFERZONE Subscriber or otherwise provide Us with Personal Information in connection with your use of Our Site, We will delete this information upon your request, provided that, notwithstanding such request, such Personal Information may be retained for as long as you maintain an account for Our Solutions, or as needed to provide you the Solutions, comply with our legal obligations, resolve disputes and enforce our agreements.

An individual who seeks access to, or who seeks to correct, amend, or delete inaccuracies in their Personal Information stored or processed by Us on behalf of a BUFFERZONE Subscriber, should direct his/her query to the Subscriber (who is the data controller as related to BUFFERZONE acting as the data processor of such Personal Information on behalf of such Subscriber and data controller). Upon receipt of a request from one of our Subscribers for Us to remove the data, We will respond to their request within 30 days. We will retain Personal Information that we store and process on behalf of our Subscribers for as long as needed to provide the Solutions to our Subscribers, subject to their requests for Personal Information removal. In some cases We may also retain and use Personal Information as necessary to comply with our legal obligations, resolve disputes, and enforce Our agreements.

Children’s Personal Information

We do not knowingly collect any Personal Information from children under the age of 13, and the Solutions are directed to people who are at least 13 years old. If you are under the age of 13, please do not submit any Personal Information through Our Site or Solutions. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce this Policy by instructing their children never to provide Personal Information through the Site or Solutions without their permission. If you have reason to believe that a child under the age of 13 has provided personal information to us through the Site or Solutions, please contact Us at support@bufferzonesecurity.com. We will use commercially reasonable efforts to delete such Personal Information.

**Additional Terms and Conditions **

This Policy applies only to information collected through Our Site or by the use of our Solutions, and not to information collected offline. Your download and use of our Software may be subject to additional terms and conditions that define your rights, as well as Our rights, with respect to the Software and its use. Such additional terms and conditions are contained in Our Terms of Use, Our Software Evaluation License Agreement or other agreements that you may be required to accept prior to using certain BUFFERZONE Services.

Business Transactions

We may assign or transfer this Policy, as well as your account and related information and data, including any personal information, to any person or entity that acquires all or substantially all of Our business, stock or assets, or with whom We merge.

Changes to This Policy

If there are any material changes to this Policy, you will be notified by our posting of a prominent notice on the Site prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices. Your continued use of the Site and other BUFFERZONE Services constitutes your agreement to be bound by such changes to this Policy. If you do not accept the terms of this Policy, your only remedy is to discontinue use of the Site or Solutions.

Contact Us

If you have questions regarding this Policy or about Our privacy practices, please contact us by email at support@bufferzonesecurity.com or at:

BUFFERZONE’s United States Representative:
BUFFERZONE Security, Inc.,
Attn: Privacy
800 Chestnut St Suite 26, Philadelphia, PA 19107, United States

BUFFERZONE’s European Representative:
BUFFERZONE Security, LTD,
Attn: Israel Levy, CEO
3 Arik Einstein St., B Building, Herzliya, 4659071, Israel

English Version Controls

Non-English translations of this Policy are provided for convenience only. In the event of any ambiguity or conflict between translations, the English version is authoritative and controls.