- our Site and its subdomains for the time being, regardless of the medium you (or any other user of the Site and such) may access it (e.g., via a web or mobile browser) (collectively the “Websites”); and
- any events hosted by us, whether such events are open to the public or are by invitation (collectively the “Events”).
Types of Personal Data We Process
We process the Personal Data we collect about you when you use our Data Sources. In this Policy, “Personal Data” means any information that may be used alone, or in combination with other information, to identify a natural person (you), in connection with your use of the Data Sources. This definition also considers “Personal Data” as it defined in the General Data Protection Regulation (“GDPR”), the California Consumer Privacy Act (“CCPA”), and other relevant laws in which Cyware must comply.
As set out in the section below, we may process the following categories of Personal Data:
- Contact information, including your first and last name, mailing address, email address, telephone number, mailing preference and other contact information you may provide when communicating with us through our Data Sources.
- Communication Information, which means the contents of the communications and correspondence between us, whether by email, or otherwise through one of our Services, through your submission of an online form, or when you otherwise contact us.
- Recruitment Information, which means your resume, employment history, qualifications, contact information, reference information, and other information you may submit when applying for a job with us.
- Account Information, which means the contact information you provide to us when creating a Cyware account, including your username and user identification (“ID”) number.
- Application Security Information, which means your passwords, two-factor authentication software or key pairs, security questions (including the answers the said questions) and security device identification number.
- Financial Transaction Information, which means payment information, such as your credit or debit card number and other card information; other account and authentication information; and billing or contact details.
- Other Identifying Information, which means your IP address, device name and device ID, MAC address, GUID, coarse location and fine location (the “Log Data”).
We collect Personal Data through:
- Your use of or participation in our Data Sources;
- A third party’s use of our Data Sources relating to you; and
- Direct or unsolicited interactions, such as when you voluntarily provide your information to us by contacting us, submitting requests and comments, subscribing to our newsletters, submitting job applications, or otherwise engaging with us through our Data Sources
How We Use Your Personal Data
- Grant you access to our Data Sources
- Maintain our security protocols for our network and security measures (which also improves upon the safety and reliability of our Site and various Data Sources for you)
- Interact with you directly in case there is any suspicious activity detected
- For internal business / technical operations (i.e. troubleshooting, data analysis, statistical findings, customer satisfaction surveys, etc.)
- To understand exactly how our Site, Services, software/products, or any other offering to you are being used
- Improve usability for users like you in our products and our Site (focusing on functionality, ease of use, improved product features, more targeted product features used to meet your needs, and more)
- To assist in developing new products, services, and software; or simply expand our offerings to meet more of your needs
- Comply with applicable privacy laws relating to Personal Data
- Contact you with promotional items, discounts, endorsements, newsletter, or other information related to the Site, products/software, the Services offered, future industry events, or business dealings
- Obligations required under a contract with you
- Ensure that our compelling legitimate interest in our business operations and dealings is maintained
In addition, and in compliance with the CCPA, we have provided a table that lays out the purpose of processing certain Personal Data, the categories (as identified above) such Personal Data is in, and the basis for which it is being collected:
Cyware as a provider of Services
Personal Data collected through our Websites
Data Collected at our Events
How We Share Your Personal Data
Third-party service providers who need access to Personal Data to assist us in delivering Services.
- For example, such third parties include payment processors; information technology service providers; providers of identity verification services; websites hosting providers; marketing, accounting, shipping, and delivery vendors; other business process outsourcing providers; and partners who assist us with enhancements to Services we offer to you, such as CTIX Lite.
Third-party service providers who need access to Personal Data to provide advertising and analytics services.
- For example, we use HubSpot for the collection and management of your Personal Data that enables us to deliver marketing communications about our Services to you.
- Relevant third parties in which we may have: merged, sold, or transferred our business or assets (or parts of it), for instances such as a re-structure, dissolution, or liquidation.
- Our corporate affiliates, when necessary to complete the processing activities described above.
- Public and governmental authorities that regulate or have jurisdiction over us, such as regulatory authorities, law enforcement, public bodies, and judicial bodies.
Any relevant party, claimant, law enforcement agency, court, governmental, supervisory or regulatory bodies, to the extent necessary for the:
- establishment, exercise or defense of legal rights in accordance with applicable laws protect the legitimate rights,
- protection of our privacy, our property, our safety, our customers, our business partners, our personnel, and/or the general public;
- pursuit of available remedies or limit damages;
- to respond to an emergency.
Third Party Applications and Websites
Advertising and Analytics Services Provided by Third Parties
Rights of Individuals in Certain Jurisdictions
- Accessing the Personal Data we maintain about you. We will provide you free of charge with a copy of your Personal Data, but we may charge you a fee to cover our administrative costs if you request further copies of the same information.
- Providing you with information about how we process your Personal Data. This will include information on the categories of data, the sources from which it originated, the purpose and legal basis for the processing, the expected retention period, and the safeguards regarding data transfers to other jurisdictions, subject to the limitations set out in applicable laws and regulations.
- Correcting any errors regarding your Personal Data. You have the right to ask us to rectify Personal Data you think is inaccurate or incomplete. In some cases, you will need to make certain of these changes yourself by using the tools we provide in the Data Sources.
- Requesting to have your Personal Data erased. You have the right to ask us to delete your Personal Data. In some cases, you will need to do the deletion yourself using the tools we provide in the Data Sources. We will decline your request for deletion if processing your Personal Data is necessary: (i) for the continued performance of a contract, (ii) to comply with our legal obligation; (iii) in pursuit of a legal action; (iv) to detect and monitor fraud; or (v) for the performance of a task in the public interest.
- Objecting to how we process your Personal Data. Where we process your Personal Data based on our legitimate interest (or that of a third party), you have the right to object to this processing on grounds relating to your particular situation if you feel it impacts on your fundamental rights and freedoms. We will decline your request where we have a compelling legitimate ground for the processing which overrides your rights and freedoms, such as our adherence to applicable laws, or where the processing is in connection with the establishment, exercise or defense of legal claims.
- Receiving notices that are direct marketing. You have the right to request us to tell you how your Personal Data has been shared, if at all, with third parties for the third parties’ direct marketing purposes.
- Stopping your Personal Data from being used for direct marketing purposes. At your request, we will stop using your Personal Data for the purpose of direct marketing. If you want to stop us from contacting you in connection with marketing communications, please email us at the email address specified below.
Restricting how we process your Personal Data. At your request, we will limit the processing of your Personal Data if:
- you dispute the accuracy of your Personal Data;
- your Personal Data was processed unlawfully and you request a limitation on processing, rather than the deletion of your Personal Data;
- we no longer need to process your Personal Data, but you require your Personal Data in connection with a legal claim, or
- you object to the processing pending verification as to whether an overriding legitimate ground for such processing exists.
- (We may continue to store your Personal Data to the extent required to ensure that your request to limit the processing is respected in the future.)
Collecting your data portability. You have the right to receive your Personal Data in a structured, commonly used and machine-readable format, if:
- the processing of your Personal Data is based on your consent or required for the performance of a contract; or
- the processing is carried out by automated means.
(Please note information might already be available to you via the Data Sources.)
- Withdrawing any consent that you gave us to process your Personal Data. You have the right to withdraw any consent you may have previously given us at any time.
- Providing a complaint to a supervisory authority. If you are not satisfied with our response, you have the right to complain to or seek advice from a supervisory authority and/or bring a claim against us in any court of competent jurisdiction.
To exercise any of the above rights, please contact us at the email address specified below. We will consider and process your request within a reasonable period of time. Please be aware that under certain circumstances, or in relation to certain types of data, including pseudonymous data, the applicable legislation may limit your exercise of these rights.
International Data Transfers. We may transfer your Personal Data to countries outside of your jurisdiction for processing in accordance with this Policy and as permitted by applicable law. Where this is the case, we will ensure that any data processors receiving your Personal Data are subject to laws ensuring an adequate level of data protection as set out in an applicable adequacy decision of the relevant regulatory authority or will ensure that an adequate level of data protection will be available on the basis of standard contractual clauses that will allow you to directly enforce your rights as a third-party beneficiary.
Where regulation in a jurisdiction requires us to provide you with a notice, or other explanation of the information about you that we collect and process (or similar), this Policy shall be understood as fulfilling our obligation to provide you with such notice or explanation.
Retention of Personal Data
Do Not Track
California Privacy-Related Disclosures
- Sharing Personal Information for Direct Marketing Purposes. Before sharing Personal Data of California consumers with third parties for direct marketing purposes we will obtain opt-in consent from the applicable California consumers or provide such California consumers with a cost-free method to opt out.
- Information on Marketing Disclosures. California Civil Code Section 1798.83 permits our users who are California residents to request and obtain from us once a year, free of charge, information about the Personal Data (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year. If applicable, this information would include a list of the categories of personal information that was shared and the names and addresses of all third parties with which we shared information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us at: ________________________________ or __________________________________.
- In order to view the categories of Personal Data and description of its use of such data, please review the tables above concerning Personal Data in Section III (How We Use Your Personal Data).
If you have any questions, comments, or complaints, or would like to access or correct your Personal Data and privacy preferences, please contact us by using the following ways:
By email: email@example.com
By postal mail:
111 Town Square Place, Suite 1203, #4
Jersey City, NJ 07310
United States of America
Date of Last Update: October 5, 2021