Skycure has changed and updated the terms of its privacy policy on June 13, 2017

 
Skycure Ltd. and affiliates (“Skycure” or “We“) respects your privacy. This policy explains our privacy practices with respect to information collected from use of our website and our services. It describes the ways Skycure collects and uses your personal information and the rights and options available to you with respect to your information. Your use of our services is conditioned upon acceptance of our Terms of Service and this Privacy Policy. This Privacy Policy lists our current policies, but, as noted below, this Privacy Policy may be modified from time to time at our discretion. If you do not agree to be subject to this Privacy Policy you should not use our services or website.

WE COMPLY WITH THE EU-US PRIVACY SHIELD FRAMEWORK AS SET FORTH BY THE US DEPARTMENT OF COMMERCE REGARDING THE COLLECTION, USE, AND RETENTION OF PERSONAL INFORMATION FROM EUROPEAN UNION MEMBER COUNTRIES.

1. What personal information do you have to provide Skycure?

When you register to our services, you may be asked to provide us with personal contact information, such as name, company name, address, phone number and email. You may also be required to choose a user name and password. If you acquire paid services, we may also ask you to provide additional payment and transactions related personal information.

2. What Internet traffic or data does Skycure monitor or collect?

Skycure does not analyze, nor save any traffic generated by your mobile device, except for that generated by the Skycure App. In cases where a network threat has been identified on a specific network, your access to the Internet through your mobile device may be routed through Skycure’s VPN servers to maintain a secure connection while the threat is persistent. We may collect information from your device (such as the geo location of your device) to provide our services, we may also collect information regarding the behavior and usage of suspicious applications on your device in order to provide you with detailed analysis with respect to potential threats. Such information may include specific device configurations and suspicious application binaries, but will not include any personal content stored by these applications. Skycure will not monitor or store any content that you upload or download, such as text messages, contact list, content of emails, filled-in forms and data that a website retrieved. The stored data will be attributed to you in person, only to the extent necessary to provide you or to the organization’s administrator (collectively “User” with our services. Thereafter, Skycure will anonymize the data and will not knowingly use the data to personally identify you.

3. What does Skycure do with your personally identifiable information?

Skycure may use personally identifiable information for the following purposes:

  • To set up, administer and operate the services for organizations subscribed for the services with respect to mobile devices that are used by their employees and service providers; Skycure will retain such data in a manner that is attributable to User for a period of 6 months and will anonymize the data thereafter;
  • If Skycure decides to offer certain services for a fee, then certain payment and transactions related information will be stored and used. Such data will remain personally identifiable for as long as necessary to provide the User fee-based services, and any other purpose related to your use of such services;
  • To send Users updates and notices and to provide Users with information related to our services, to ask for your feedback in order to improve the administration and quality of experience of our website, products and services and to respond to Users inquiries and requests; Skycure will not share your e-mail address or any other personally identifiable information with online advertisers and advertising networks, without your explicit consent;
  • To enforce the Terms of Service related to Skycure’s services and to collect fees and debts, and to prevent fraud, misappropriation, infringements, identity thefts and any other misuse of our services;
  • To comply with any applicable law and assist law enforcement agencies as required; In any case where Skycure believes that the use of the information is necessary to prevent imminent physical harm or damage to property;
  • To take any action in any case of dispute, or legal proceeding of any kind between Users and Skycure, or between you and other Users or third parties with respect to, or in relation with our services.

Skycure enables organizations to manage and secure employee devices from a single administrator account. If requested by the organization, Skycure may provide the organization’s administrator with a function enabling to lock and wipe the device remotely in order to protect the data stored on the device when it is lost or stolen.

We commit to process personal information solely for the purposes described in this policy. To the extent relevant and possible, we will make efforts to maintain the information accurate, complete and up-to-date.

4. Important notice about children’s privacy

Our services are not intended for use by persons under the age of 18. If you are not 18 years old or older, then you may not use any of our services and must not provide any of your personal details. Skycure strongly encourages parents to monitor their children’s use of the Web. Skycure will delete a child’s personally identifiable information if a parent so requests by sending an e-mail to support@skycure.com.

5. How does Skycure share your personally identifiable information with others?

Skycure does not sell, rent or lease your personally identifiable information to third parties. Skycure does not share personally identifiable information with others except (a) subject to your explicit consent, or (b) under the following circumstances:

Skycure may share your personally identifiable information with third party service providers to operate the services provided that any such third party will commit to protect your privacy as required under the applicable law and this policy. for example, to store and process your information through a third-party hosting services and to process payments, to conduct quality assurance testing; to provide help desk and technical support; to provide marketing services; and/or to provide other specific services to you and/or to us, and to contact you.

In any case of dispute, or legal proceeding of any kind between Users and Skycure, or between Users and other Users or third parties with respect to, or in relation with the services; In any case where Skycure believes in good faith that sharing information is necessary to (a) comply with relevant laws; or (b) prevent imminent physical harm or damage to property;

If Skycure organizes the operation of the services within a different framework, or through another legal structure or entity, or if Skycure is acquired by, or merged with another entity, provided however, that those entities agree to be bound by the provisions of this policy, with respective changes taken into consideration; Skycure may share personally identifiable information with companies or organizations connected, or affiliated with Skycure, such as subsidiaries, sister-companies and parent companies, in which case we will require our affiliates to honor this policy.

We may be liable for onward transfers to third parties in violation of the Privacy Shield Principles. For further information, please see below the EU-US Privacy Shield chapter of this policy.

6. Disclosure of information to authorities

We may need to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

7. How does Skycure use aggregated information?

Skycure may also use anonymous, statistical or aggregated information to properly operate the services, to improve the quality and functionality of the services, to analyze request and usage patterns, to enhance your experience, to create new services, including customized services, to change or cancel existing content or services and for other internal and statistical purposes. Skycure may use and disclose such anonymous information, to third parties, at Skycure’s sole discretion, provided however, that Skycure will not knowingly, or intentionally use the information to reveal your identity without your consent.

8. What opt-out and deletion options are available to you?

If you are registered with the services, then you may access your personal account and edit, update or amend your personal information at any time. You may also request changes to or deletion of your personally identifiable information by us, by sending an e-mail to: support@skycure.com, but please note that (a) we may not be able to edit or delete your personally identifiable information stored with our third party service providers and (b) we may be required (by law or otherwise) to keep this information and not delete it (or to keep this information for a certain time, in which case we will comply with your deletion request only after we have fulfilled such requirements).

9. Accessing Your personal information

At any time you may contact us at: contact@skycure.com and request to access the identifiable information that we keep about you and to verify the accuracy of the data.

Under your right of access, you may obtain confirmation from us of whether we are processing personal data related to you, receive a copy of that data, so that you could verify its accuracy and the lawfulness of its processing, request the correction, amendment or deletion of the data if it is inaccurate or processed in violation of the applicable law or the Privacy Shield Principles (as further explained below).

We will make good-faith efforts to locate the data that you request to access. Note that we may need to ask you to provide us certain credentials to make sure that you are who you claim you are and ask you questions to better understand the nature and scope of data that you request to access.

We may redact from the data which we will make available to you, any personal information related to others.

10. How does Skycure secure your personal information?

Skycure and third parties on its behalf use a variety of industry-standard security technologies and procedures to help protect your personal information from unauthorized access, use, or disclosure. Skycure utilizes some of the most advanced technology for Internet security available today. When you access our site using industry standard Secure Socket Layer (SSL) technology, your information is protected using both server authentication and data encryption, ensuring that your data is safe and secure. Skycure.com provides each Administrator in your organization with a unique user name and password that must be entered in order to log on to Skycure’s management console. In addition, Skycure provides each end-user an authentication token that provides the Skycure App with the ability to perform actions through the Skycure API. https://mc.skycure.com is hosted in a secure server environment that uses advanced technology to prevent access from intruders. Despite these measures, you should know that Skycure cannot fully eliminate security risks or guarantee that the services will be immune from any wrongdoings, malfunctions, unlawful interceptions or unauthorized access to the information stored therein and to other information security risks, or that your private communications on or through the services will remain private.

11. EU-US Privacy Shield

We comply with the EU-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries.

We have certified that we adhere to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability.

If there is any conflict between this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles will govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/ The Federal Trade Commission (FTC) has jurisdiction over our compliance with the EU-US Privacy Shield Framework.

12. How does Skycure use Cookies?

Skycure and third parties we interact with, including our third-party service providers, may use cookies, web beacons, local shared objects (sometimes called “flash cookies”), and similar technologies in connection with your use of our services to provide and support our services (collectively referred to in this policy as “Cookies”). Cookies are small pieces of information that a website sends to your computer’s hard drive while you are viewing a website. Skycure may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them) to facilitate the use of our services, to collect information for statistical and analytical purposes, to verify information, to customize our services to your personal preferences and for information security purposes.

If Cookies are used, they may be used to collect information about you and your use of our services, such as your browser type, preferences, data relating to content that has been displayed to you or that you have clicked on, and the date and time of your use. Cookies may also be used in order to further features and processes on our services, provide authentication and security for your transactions using our services, store your preferences, facilitate relevant advertising, and help us learn more about how users engage with our services.

We sometimes use service providers to help us provide certain products and services or to integrate other features. These third-party providers may collect information when you view or use them, including information about you and your device or browser. They may do this using Cookies or similar technologies. These third-party providers also may use these technologies to help share information with us, like how you use their website or application. To learn more about the information they collect or receive, review their privacy policies.

For example, we work with services provided by Google, Inc. (“Google”) and incorporate features from Google’s APIs, such as SafetyNet API. SafetyNet API collects hardware and software information, such as device and application data and integrity reports, and sends such information to Google for analysis. In order to provide its services, Google uses Cookies and other similar information collection techniques, and the information collected (which may include your truncated IP address) is transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your, and other users’, use of our services, compiling reports for us on service activity and providing other services relating to service activity and Internet usage. Please note that if Google receives information about your IP address, Google will only receive your truncated IP address. This is sufficient for Google to identify (approximately) the country from which you are using our services, but is not sufficient to identify you, or your computer or mobile device, individually. Google’s privacy policy is found here: https://support.google.com/analytics/answer/6004245.

You can use the settings within your browser to control the Cookies that are set on your computer or mobile device. Persistent Cookies can be removed by following Internet browser help file directions. However, please be aware that Cookies are important to many aspects for our services – if you set your browser to reject Cookies, you may not be able to enjoy all of the features of our services. To find out how to see what cookies have been set and how to reject and delete cookies, please visit http://www.aboutcookies.org.

To opt-out of analysis by Google on our services and other services, please visit http://tools.google.com/dlpage/gaoptout.

13. Do Not Track

You may be able to adjust your browser settings or other settings so that “do not track” requests are sent to our websites and mobile applications. Skycure will not respond to any “do not track” requests that are sent to our services, however, as no clear industry standards have been established to govern how such requests are sent or how such requests should be addressed when received. Except as set forth in Section 2 of this policy, Skycure does not collect personally identifiable information about your online activities over time and across different websites when you use our services; however, certain service providers that use Cookies may collect your personally identifiable information over time and across different websites. For more information about how these third parties collect this personally identifiable information, please see Section 5 and Section 12.

14. Where is my personal information processed?

Skycure stores and processes the information through a third party’s hosting services currently in the USA. If you are in the European Economic Area, or in any other jurisdiction that regulates the transfer of personal information outside that jurisdiction, then you hereby grant Skycure your explicit and unambiguous consent to transfer your personal information to the USA, for the purposes described in this policy.

15. Notice of privacy rights to California residents

Section 1798.83 of the California Civil Code permits California residents to request from a business, with whom the California resident has an established business relationship, information related to the personal information disclosed by Skycure to third parties for direct marketing purposes and the names and addresses of the third parties with whom the business has shared such information during the immediately preceding calendar year. You may make one request each year by emailing Skycure at contact@skycure.com or sending a letter to:

Skycure
445 Sherman Avenue
Palo Alto, California, 94306
USA

16. Notice to residents of the European Economic Area

You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by adjusting the settings on your account, by checking the boxes on the forms we use to collect your data or by unsubscribing to any marketing materials we send to you. You can also exercise the right at any time by contacting us at contact@skycure.com.

17. Dispute resolution

We do periodical assessments of our data processing and privacy practices, to make sure that we comply with this policy, to update the policy when needed, and to verify that the policy is displayed properly and accessible.

If you have any concerns about the way we process your personal information, you are welcome to contact our privacy team at: contact@skycure.com, or write to us at:

Skycure
445 Sherman Avenue
Palo Alto, California, 94306
USA

We will look into your query and make good-faith efforts to resolve any existing or potential dispute with you.

In compliance with the EU-US Privacy Shield Principles, we commit to resolve complaints about your privacy and our collection or use of your personal information. European Union individuals with inquiries or complaints regarding this privacy policy should first contact our privacy team. Our privacy team’s contact details are indicated above.

We have further committed to refer unresolved privacy complaints under the EU-US Privacy Shield Principles to the EU Data Protection Authorities. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit the EU Commission web page on data protection for more information and to file a complaint.

Additionally, if you are an EU data subject, you may invoke binding arbitration in certain cases, as further described in Annex I of the EU-U.S. Privacy Shield Agreement. For further information, please visit the Privacy Shield web site at: www.privacyshield.gov, or contact our privacy team.

18. Changes to this Privacy Policy

Skycure may change and update the terms of this policy from time to time. If we decide to change our privacy policy materially, we will post prior notice of those changes on our website so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it.

Contact Information

Skycure welcomes your comments or questions regarding this Privacy Policy. Please e-mail us at contact@skycure.com

Effective date: June 13, 2017
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