Effective Date: June 6, 2024
Posted Date: June 6, 2024
I. Introduction
At Netarx, data privacy is important to us. This Netarx Privacy Policy (“Privacy Policy”) details our privacy practices for the activities described in this Privacy Policy. Please take the time to read this Privacy Policy carefully in order to understand how we collect, share, and otherwise process information relating to individuals (“Personal Data”), and to learn about your rights and choices regarding our processing of your Personal Data.
If you are a California resident, please review the section of this Privacy Policy for California residents.
In this Privacy Policy, “Netarx,” “we,” “our,” and “us” each mean Netarx LLC and the applicable Netarx affiliate(s) involved in the processing activity.
II. Netarx’s Roles & Responsibilities
Netarx is the controller of your Personal Data, as described in this Privacy Policy, unless otherwise stated. Please note that this Privacy Policy does not apply to the extent that we process Personal Data in the role of a processor (or a comparable role such as a “service provider” in certain jurisdictions) on behalf of our customers, including where we offer to our customers various cloud products and services, through which our customers (and/or their affiliates) connect their own websites and applications to our hosted platform, sell or offer their own products and services, send electronic communications to other individuals, or otherwise collect, use, share or process Personal Data via our cloud products and services.
Each of our customers, not Netarx, controls whether they provide you with an account or other access to the Netarx identity cloud service through their subscription, and if they provide you with such accounts or other access through their subscription, they control what information about you that they submit to our service. This content may include contact information (such as your first and last name, email address, and phone number), professional information (such as the department you work for at your place of employment), or other types of information that a customer chooses to submit. Use of this content by Netarx is governed by agreements between Netarx and the Customer.
For detailed privacy information applicable to situations where an Netarx customer (and/or a customer affiliate) who uses Netarx’s cloud products and services is the controller, please reach out to the respective customer directly. We are not responsible for the privacy or data security practices of our customers, which may differ from those set forth in this Privacy Policy. If not stated otherwise either in this Privacy Policy or in a separate disclosure, we process such Personal Data in the role of a processor or service provider on behalf of a customer (and/or its affiliates), who is the responsible controller of the applicable Personal Data.
If your Personal Data has been submitted to us by or on behalf of an Netarx customer and you wish to exercise any rights you may have under applicable data protection laws, please inquire with the applicable customer directly. Because we may only access a customer’s data upon instruction from that customer, if you wish to make your request directly to us, please provide to us the name of the Netarx customer who submitted your Personal Data to us. If we can verify the Netarx customer, we will refer your request to that customer and support them as needed in responding to your request within a reasonable timeframe.
III. Personal Data We Collect and Data Sources
Covered Data Processing Activities
This Privacy Policy applies to the processing of Personal Data that we collect in the following ways, as detailed in this section.
We collect information about you when you provide it to us, when you interact with our products and services, websites and electronic systems, when you attend events and visit our offices, and when other sources provide it to us, as further described below.
Information you provide to us
Based on our current practices (and including our practices over the last 12 months), we collect the following categories of information about you:
Contact and Professional Data. We collect contact and/or professional data about you in person, through communications, including communications from you or your colleagues, and through our websites. For example, you provide your contact and professional information to us when you sign up to learn more about Netarx’s products and services, download content, register for an event, and visit our offices. If you attend an event, we may also receive contact and professional details about you when you choose to scan your attendee badge or by providing a business card or other method(s) whereby you share Personal Data with us. Typically, contact data includes your name and contact methods, such as telephone number, email address, and office or other mailing address, and professional data includes details such as the organization you are affiliated with, your job title, and industry.
Administrator Data. When you sign up for an account to try Netarx, subscribe to any Netarx service via Netarx or another entity (such as a marketplace or authorized reseller), have the ability to submit a support request, or are designated an administrator of any part of the Netarx Service, then information is provided to us about you (“Administrator Data”). Administrator Data usually includes your name, email address, phone number, address, billing information, business contact information, credentials information (including Netarx training and credentials), subscription and service configurations you select, and other details you may provide to us about you or include in your profiles in Netarx communities and other support portals. We may also receive any Personal Data you share via tooling used to provide support, e.g., videoconferencing or other communication methods you participate in.
Biographical, Community, and Support Data. We may also collect various types of biographical, community, and support Personal Data from you via our help center and community support forums. For example, if you register for an online community that we host, we may ask you to provide a username, photo and/or biographical information, such as your occupation, organization name and areas of expertise. Additionally, you may provide Personal Data to us when you create user-generated content (for example, by posting in a forum), provide Netarx with feedback, or when you participate in interactive features, trainings, online surveys, contests, promotions, sweepstakes, activities, or events. Netarx may receive Personal Data and Administrator Data in connection with an administrator’s request for support for the Netarx service.
Job Applicant Data. We collect contact and professional information, including your resume with educational and work background, that you provide when you apply for a job with Netarx. We may also collect sensitive information, like your Social Security Number or other government identifier, criminal history information, racial or ethnic origin, or other such Personal Data that you provide in connection with your job application.
Contract and Payment Data. We may receive contract details (like signatures) from you or your organization and use payment processing services to collect payment and billing information, which may contain Personal Data such as billing name, billing address and payment card details, in connection with some of our products and services.
Audio, Electronic, or Visual Data. If you attend an Netarx in-person or virtual event or agree to be recorded in a telephone or video meeting, we may record some or all of that event or meeting. For events, we may document the event in various ways, such as by taking photos at the event, interviewing you at the event, or recording your participation in a live question-and-answer or other interactive session. We use this information for business and marketing purposes to better inform the public about Netarx, its events, and provide testimonials about our products and services, to the extent permitted by applicable law.
Consumer Products. If you use consumer products made available by Netarx (“Netarx Consumer Products”), then we may receive various types of information and content from you that you choose to share, including contact information (such as your first and last name, email address, and phone number), additional multi-factor authentication factor setup details, content you upload (such as identification or other documentation), and information regarding the websites and applications that you visit and use through Netarx Consumer Products for authentication. We also receive Ancillary Data, including device data, Usage Data, and metadata, as described below for the purposes described below.
Depending on your jurisdiction, if we collect sensitive data from you, we will do so by providing you with additional notice or confirming your consent upon collection, if required by applicable law.
Personal Data We Collect From Other Sources
While doing business (and over the 12 months preceding the effective date of this Privacy Policy), we receive Personal Data and other information from other third parties for our business or commercial purposes. This information varies and typically falls into a few categories:
- Business contact information (such as name, job title, business email, phone number, and address), social profile (such as LinkedIn or XING) including other details about your organization for sales and marketing purposes, to better inform you about Netarx products and services;
- Third-party platform usernames and identifying information;
- Details about you as a job candidate (which may include your name, resume, educational and work history, criminal history information, and feedback) as permitted under law; and
- Data used for security purposes to protect our products and services.
We receive business contact information that contains Personal Data for commercial purposes, including details about your organization from third parties for marketing and business intelligence, such as analyzing business opportunities, identifying, and communicating with potential customers, and providing our audience with more relevant content and advertising. Typically, and subject to applicable laws, we receive this information about you from a few sources, such as: (i) third-party marketing initiatives, such as events where we are a sponsor, or website forms hosted by third parties that may provide content about us; (ii) instances when you consent to having your attendee badge scanned at an event hosted by us or another entity; (iii) companies, such as information aggregators and similar entities, from whom we have licensed business contact information; (iv) referrals; or (v) resellers and channel partners, including those that offer joint marketing services. In some situations, we may combine such business contact information with other non-personal and Personal Data we possess or that you have provided to us. For example, we may combine business contact details with details about your organization, such as its address or revenue range, and analyze this information for business opportunities or use this to send you tailored content.
We also receive Personal Data to help with threat intelligence and to protect the safety and security of our service and our customers’ applications, such as breached website credentials from other entities. We use this Personal Data for various purposes, such as for security and fraud detection purposes and to enable our customers to configure the settings within the Netarx products and services to notify their administrators and users if the data that they put into the Netarx service is found within this data set.
We also receive information from third-party platforms for various business purposes such as organizational credit information, program management, or technical reasons. For example, we may receive credit information about an organization that includes the names of individuals. If you participate in an open-source project or our bug bounty program, we may receive details about you, such as your username or pull requests, to help us manage your participation in the project or program and provide you with updates.
If you are a candidate applying for a job at Netarx, subject to laws applicable in your jurisdiction, we may receive Personal Data about you from third parties for business purposes, such as through background checks (educational, employment, criminal, and financial information), publicly-available sources (like social media accounts, including LinkedIn for identifying candidates), feedback about your application and from interviews, and other third parties that may provide feedback about your application. Netarx treats references provided as part of a job application as confidential.
For our professional services work, as a processor or service provider for our customers, Netarx may also receive Personal Data about you to perform its obligations under its contract with a third party. Netarx partners may also share your business contact information with Netarx as part of their recommendation to your organization to become an Netarx customer. If Netarx is interested in partnering with, acquiring, investing in, or partners with, acquires, or invests in your employing or retaining organization, Netarx may receive Personal Data about you through the (potential or completed) transaction for its business purposes.
Device Data, Usage Data, Ancillary Data, Diagnostic Data, and Metadata We Collect
Explanation of Device Data, Usage Data, Ancillary Data, Diagnostic Data, and Other Metadata and Technology Used
Like most websites, applications, and software across the Internet, Netarx collects certain Personal Data when you access and use our websites, applications, software, and products and services subject to laws applicable in your jurisdiction. This type of data collection allows us to better understand how individuals use and the performance of our websites, applications, and products and services and allows us to provide, fix, and improve our websites, applications, software, and products and services, and detect, investigate, and combat fraud, security incidents, and other deceptive or malicious behavior. The data we collect can include the following:
Device Data. We may collect certain information from and about your device, such as unique device identifiers, browser type, the operating system installed on your device, certain device configurations, and similar device or version information (“Device Data”). We use Device Data to identify the location of the device, which we use to provide necessary disclosures, obtain necessary consents, prevent access to our products and services as required by applicable law, and comply with any other requirements applicable to Netarx, to detect, investigate, and combat fraud, security incidents, and other deceptive or malicious behavior, and to help us determine that users from one type of device use our websites, products and services in different ways than users of a different type of device, which in turn allows us to troubleshoot and investigate the performance of our products and services, improve our websites, products, and services, such as through optimizing the screen size of Netarx mobile applications, or making sure that our customers’ users have a more efficient user experience. The Device Data we collect can include the following:
Location Data. We may collect information about your location when you use our websites, mobile applications, and products and services. Your location can be determined with varying degrees of accuracy by your IP address and information about things near your device, such as Bluetooth-enabled devices. The types of location data we collect and how long we store it depend in part on your device and settings. If we collect your precise geolocation data, we will do so only with your consent.
Touch ID and Face ID. Some of our products and services may allow you to authenticate using Touch ID and Face ID for Apple devices and Face Unlock and Fingerprint Unlock for Android devices. If you authenticate using Touch ID, Face ID, Face Unlock or Fingerprint Unlock, we are only notified as to whether the authentication was successful and cannot access the Face ID, Touch ID, Face Unlock, or Fingerprint Unlock. You can enable or disable Touch ID, Face ID, Face Unlock and Fingerprint Unlock at any time through your device’s settings menu.
Usage Data. We may also collect data about your use of our websites, applications, and products and services, including data regarding service configurations and applications utilized in connection with the hosted Service, support data, operational data, log data, logs of your usage and click activities, logs about your login history, identity confirmation, and the performance results for the hosted Service (“Usage Data”). Netarx uses Usage Data to: (i) analyze usage trends, (ii) detect, investigate, and combat fraud and cyber-attacks; (iii) detect, investigate, and combat security incidents, and other such deceptive, fraudulent or malicious behavior against Netarx or its customers, including taking measures to improve Netarx’s overall security posture; (iv) improve service and product functionality; and (v) retain and/or employ another service provider or contractor.
Bug, Error, and Crash Reports. We may also collect data about any problems you experience with our websites, applications, and products and services, including bug, error, and crash reports, which can include Device Data, location data, Usage Data, and user data at the time of the bug, error, and/or crash.
Ancillary Data. Data collected may include the applications that are installed on your device. Collectively, we refer to this data as “Ancillary Data”. Some of the Ancillary Data, including Usage Data, that we receive is dependent on your organization’s policies and settings and what information it permits to be shared with Netarx. Netarx uses Ancillary Data to improve security and to provide and improve its products to customers, including to better understand customer behavior in order to create new features and provide threat-related insights for our customers.
Some of these products that collect and process Ancillary Data include:
- the Netarx browser plugin; and
- the Netarx desktop and mobile applications.
Through the Netarx browser plugin, the Ancillary Data we collect includes details about your login session, IP address, user-agent, and the web application name and website address, as well as other information that is not personal in nature. In addition, as part of Ancillary Data, we may collect interaction data about your use of the Netarx browser plugin. We use the information collected through the Netarx browser plugin for security purposes and to provide features, such as to allow you to better manage your passwords for websites that you visit.
Diagnostic Data. Some products and services may require, or may be enhanced by, your installation of on-premise software (e.g., agents). The on-premise software may collect data about the use and performance of the software, including IP address, username, and host name, which may be transmitted and used by Netarx to provide customer support, to diagnose issues with the on-premise software and/or related products and services, to improve our products and services, and/or for the purposes identified in the applicable agreement(s) between Netarx and the applicable customer.
Metadata. We may collect metadata about you, including technical data about your performance or use of our website, products and services. One common technology we use to collect metadata that may be considered Personal Data is our use of cookies. Cookies are small text files that are placed on your web browser and that help us recognize your browser or device as a unique visitor in different ways based on the type of cookie. The three main types of cookies are:
Essential cookies. Essential cookies are required for website functionality and security. For example, authentication, security, and session cookies may be required for our website or products to work.
Functional cookies. We use functional cookies to help enhance our websites’ performance, for market research, or other analytics or advertising that is not tied to a specific individual. For example, we may use Google Analytics to help us track how many individuals visited our websites. We may also utilize HTML5 local storage cookies for the reasons described in this section. These types of cookies are different from browser cookies in the amount and type of data they store and how they store it.
Targeting or advertising cookies. We use targeting and advertising cookies to help us understand our marketing efforts and to reach potential customers across the web. For example, we contract with third-party advertising networks that may track your activity over time and across different channels, including our websites, email activity, and other websites and applications that display advertisements. They may use this tracking information to understand and predict your interests, to display an advertisement for Netarx on another website, or email you with a marketing communication for an Netarx product.
If you would like to manage your cookies and your permissions to share data with cookie providers, please visit the section below on Your Information Choices.
A second common technology we use to collect metadata that may be considered Personal Data is beacon technology. We use beacons in our websites and in email communications to you. Beacons provide us with information about your activity and help us to improve our business operations and strategy, such as by understanding our email communications’ functionality and improving our websites and content. For example, if you click on a marketing email we send to you about a new product or service, the beacon will provide signals to us that you and your organization may be interested in learning more. If you would like to manage your email subscriptions with us, please visit the section below on Your Information Choices.
IV. How We Use Personal Data
How we use the Personal Data that we collect depends in part on how you choose to communicate with us, how you use our websites and interact with us, and any preferences you have communicated to us. In general, we use your Personal Data as is necessary to run our business and carry out our day-to-day activities. In addition to the uses identified elsewhere in this Privacy Policy, we may use your Personal Data to accomplish the following tasks (and we have done so during the 12 months preceding the effective date of this Privacy Policy):
For the purpose of communicating with you about our products and services and facilitate other interaction. We may use your Personal Data, such as contact data, Ancillary Data, and metadata, to send you transactional communications, notices, updates, security alerts, and administrative messages regarding our products and services that may be useful to you and your organization. We will respond to your questions, provide tailored communications based on your activity and interactions with us, and help you use our products and services effectively. We also use Administrator Data to communicate with you for various purposes, including to provide you with account updates (about your subscription, settings, security, billing, feature and product updates, technical issues, certifications, and other similar content). You cannot unsubscribe from non-promotional and transactional communications. For promotional communications, you may manage your communication preferences via your administrator settings, Netarx communities, or our subscription center (linked in the Your Information Choices section below).
In some situations, we may also share Administrator Data with authorized partners in order to provide you with information relevant to your purchase of Netarx or other entities’ tools that may connect to Netarx to meet your technical or organizational needs.
If you choose to subscribe to alerts, then we will also use your Administrator Data to send you trust alerts, including via SMS (“Netarx Alerts”). Phone numbers collected as a part of Netarx Alerts SMS subscriptions will not be used for marketing purposes and only shared with service providers as required to carry out the alerts or as otherwise required under applicable law. In some instances, the phone number you use to sign up for Netarx Alerts may be the same phone number we use for marketing purposes based on your consent or receipt through a different channel.
For the purpose of supporting safety, security, and manage operations. We use Personal Data, such as contact data, Ancillary Data and other metadata, about you and your use of our products, services, and offices to verify accounts and activity, monitor suspicious or fraudulent activity, assist our customers in their monitoring of suspicious or fraudulent activity, and identify violations of policies regarding the use of our products and services. We may also combine Ancillary Data with other data we receive for safety, security, and to manage our business operations. We also process Personal Data, such as contact data and health data, for security and operations management reasons, such as to register visitors to our offices and carry out related safety measures (including through using our Atmosphere application), including to manage non-disclosure agreements that visitors may be required to sign. We also use Administrator Data to provide our customers with the Netarx service, complete transactions, provide support and other service to the customer account, detect and prevent fraud, for audit and compliance purposes, and to comply with applicable law. Netarx physically and electronically monitors its offices with access monitoring software and tools, and has on-premise surveillance cameras in order to prevent unauthorized access to our offices and to protect employees, authorized visitors, and our property.
For the purpose of marketing our products and services. We use your Personal Data, such as contact data, Ancillary Data, and other metadata about how you use the products and services to send promotional communications that may be of specific interest to you and your organization, including by email and by displaying Netarx marketing communications on other organizations’ websites and applications, as well as on third-party platforms like Facebook, Twitter, and Google subject to laws applicable in your jurisdiction. These communications are aimed at encouraging engagement and maximizing the benefits that you and your organization can gain from Netarx’s products and services, including information about new products and features, survey requests, newsletters, and events that we think may be of interest to you and your organization.
For the purpose of analyzing, predicting, and improving results and operations. We use Personal Data to analyze and predict results (such as those arising from our sales and marketing efforts and product usage and consumption), improve the performance of our websites, products and services and customer support, identify potential customers, opportunities, and potential new product areas, ascertain trends, improve our websites’ functionality, improve our security, and provide us with general business intelligence, including through the use of automated means such as machine learning technology. Subject to the laws applicable in your jurisdiction, we may also combine the metadata and usage information collected from our websites with other information to help further the purposes described in the previous sentence.
For the purpose of managing contests or promotions and customer appreciation. Netarx may occasionally run contests or other special promotions or make available opportunities or other tokens of appreciation for customers, and if you register for these, we may process your Personal Data, such as contact information, biographical information, and contract-related data to perform our contract with you. Netarx may also use the Personal Data, such as contact data, collected in these contests, promotions, and for customer appreciation as well as to send you gifts or prizes and promotional material about Netarx and our partners.
For the purpose of processing payments. We process Personal Data, such as contact information, contract-related data, financial information, biographical information, and payment information to process payments to the extent that doing so is necessary to complete a transaction and perform our contract with you or your organization.
For the purpose of recruiting and hiring. We process your Personal Data, such as contact, job applicant, and biographical data, to assess your application and to evaluate and improve our recruitment system, our application tracking and recruitment activities. We also use your Personal Data to communicate with you regarding your application or opportunities at Netarx that appear over time that we believe may be of interest to you. We also use your Personal Data to send you new hire and employee experience information. We may verify your information, including through confidential reference checks and, where allowed, background checks.
Other purposes for our legitimate interests. Where required by law or where we believe it is necessary to protect our legal rights, interests, or the interests of others, we may use your Personal Data in connection with the management of our business, including but not limited to, for operational purposes and workflow automation, business intelligence (such as to understand subscription consumption and free trial product usage), website and product improvement, legal claims, compliance, regulatory, and audit functions, protecting against misuse or abuse of our products and services, and protecting personal property or safety. For example, we may review compliance with applicable usage terms in our customer contracts, assess capacity requirements for our products, websites, and offices, improve your user experience, respond to requests by you for support or for contact, or identify customer opportunities. If you sign up to participate in specific programs, such as the Netarx Ideas forum or other product feedback programs, we may analyze Ancillary Data, including Usage Data, related to your use of our products and Service, along with the data you choose to provide to us through Netarx Ideas, to provide you with a better customer experience. Furthermore, we use Administrator Data to provide technical support as described in our documentation and help center, and to improve our products, services, and processes related to providing such support.
Other purposes with your consent. We may use your Personal Data if 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 our products and services or record phone calls for quality and training purposes, with your permission.
If we process your Personal Data for a purpose other than those set out above, we may provide you with a notice and obtain your consent prior to such processing, where required by us under applicable law in your jurisdiction.
Legal Bases for Processing Personal Data (for United Kingdom and European Economic Area and other relevant jurisdictions)
If you are an individual in the United Kingdom, the European Economic Area (EEA), or of another relevant jurisdiction, we collect and process information about you only where we have a legal basis or bases for doing so under applicable laws. The legal bases depend on the products and services that your organization has purchased from Netarx, or the Netarx Consumer Products that you are using, as applicable, how such products and services are used, and how you choose to interact and communicate with Netarx’s websites, systems, and whether you attend Netarx events. This means we collect and use your Personal Data only where:
- We need it to operate and provide you with our products and services, provide customer support and personalized features, and to protect the safety and security of our products and services;
- It satisfies a legitimate interest of Netarx’s (which is not overridden by your data protection interests and rights), such as for research and development, to provide information to you about our products and services that we believe you and your organization may find useful, and to protect our legal rights and interests;
- You give us consent to do so for a specific purpose; or
- We need to comply with a legal obligation.
If you have consented to our use of Personal Data about you for a specific purpose, you have the right to change your mind at any time, subject to contractual and legal restrictions, and reasonable prior written notice. This will not affect any processing that has already taken place. Where we are using your Personal Data because we or another entity (for example, your employer) have a legitimate interest to do so, you have the right to object to that use; however, in some cases, this may mean that you no longer use our products and services.
In the event that we de-identify any Personal Data for further use, we commit to maintain and use the information in de-identified form and will not attempt to re-identify the information, except for the purpose of determining if our de-identification processes satisfy applicable legal requirements.
V. Personal Data Disclosed by Netarx and Data You Choose to Disclose to Other Entities
Personal Data Disclosed by Netarx
In the course of doing business (and over the 12 months preceding the effective date of this Privacy Policy), Netarx may disclose Personal Data as described below.
Service Providers. For all categories of information that we collect, we disclose Personal Data to our service providers for various business purposes, including, but not limited to, auditing interactions with users, debugging our websites, products and services, security purposes, internal research and gleaning insights through machine learning, short-term uses such as credit verification, payment processing, IT services, quality control and safety, gift fulfillment, in-person and virtual event management, as well as to perform other services on our behalf. For example, we may use service providers to help us proctor and score Netarx certification exams, or host our customer relationship management system.
In-person and Virtual Events. If you choose to register for or attend a virtual or in-person event or webinar that we host, enter a contest or raffle with us and a sponsor, or download content (such as a whitepaper) from our website, then we may disclose your contact information, content interest information or other activity data, and any other information, including Personal Data, collected in the course of these activities for commercial purposes to those sponsors. In many cases, you intentionally disclose your details by providing your information to these sponsors through consent via a registration form or by scanning your badge at the applicable sponsor’s booth. Virtual events hosted by third party platforms may also collect additional data from you when you visit their sites. The treatment of this information is subject to each of these other entities’ respective privacy statements.
Partners and Resellers. We may disclose your Personal Data, such as contact information, business details, and content interest and activity details, to our partners and resellers for business purposes, such as to carry out our business or for joint marketing efforts to reach our customers and prospective customers, subject to laws applicable in your jurisdiction. In many cases, you intentionally disclose your details by providing your information to these sponsors through consent via a registration form. You can review a list of our current partners here.
Protection of Rights, Security and Fraud Detection. For all categories of data we collect, we disclose your Personal Data for business purposes to protect our customers and users, to secure our physical and intellectual property, and to prevent or investigate security or fraudulent attempts against our users through our platform.
Law Enforcement and Legal Requests. For all categories of data we collect, we may disclose Personal Data to comply with applicable law or to respond to valid legal requests, such as a subpoena, from law enforcement or other authorities.
With our Affiliates, Related to Corporate Transactions, and Provision of Professional Services. For all categories of data we collect, we disclose Personal Data to our affiliates and subsidiaries for business purposes, including any service providers and agents that work on our behalf. For example, we may disclose your Personal Data to support service providers with whom we have in place agreements to protect your Personal Data. We may also disclose your information as required for us to carry out a corporate transaction, such as a merger or sale of assets of all or part of our company. We will also disclose your Personal Data to our professional service providers (for example, our auditors, insurance providers, financial service providers, and legal advisors) as needed for us to run our business.
Platform, Training, and Community Analytics Data. We disclose Ancillary Data, such as metadata (for example, unique identifiers and Usage Data), collected through our platform with analytics service providers for our business purposes, such as to provide a better user experience and improve our products and services.
Advertising and Marketing. We share your Personal Data, such as metadata and contact data, with third-party advertising and marketing providers, to allow us to better reach our customers and prospective customers, and to sell our products and services, to the extent permitted by laws applicable in your jurisdiction. In some circumstances, we may ask you to consent to directly disclosing your Personal Data with these third parties prior to sharing your Personal Data, such as via a consent banner on our website. For details on your choices with respect this sharing or disclosure, please see Your Information Choices below. For specific details on these companies’ privacy practices, please visit their privacy policies.
Anonymous or De-identified Usage Data. We disclose anonymized or aggregated usage data or security threat information with third parties or the public. For example, this may include disclosing trends regarding organizations’ use of Netarx’s products and services to customers and prospective customers in our “Businesses at Work” report. The data disclosed in this category is not Personal Data.
Netarx Communities, Help Center, and Other User Generated Content. We make available various community forums and self-help support materials, as well as blogs and other means for you to post information on our websites. This information you post is publicly-available information that you choose to disclose and it may be read, collected, and processed by others that visit these websites. Except for username (which may be your real name) and the details that you choose to include in your profile, the categories of data disclosed in these circumstances will depend on what information you choose to provide.
Recruitment Data. When you apply for a job at Netarx, we disclose your Personal Data, including applicant data, biographical information, and other Personal Data we possess to our affiliate companies for business reasons, such as human resource management and internal reporting; our service providers for business reasons, such as the recruitment platform, to verify references and to manage background checks; and law enforcement or government authorities, or as otherwise necessary to comply with law or as needed for the recruitment and human resources process.
Netarx Social Media Outlets
Netarx’s websites may use social media features, such as the Facebook “like” button, the Instagram “heart” button, Twitter sharing features, and other similar widgets (“Social Media Features”). You may be given the option by such Social Media Features to post information about your activities on a website to a profile page of yours that is provided by a third-party social media network in order to share content with others within your network. Social Media Features are either hosted by the respective social media network, or hosted directly on our websites. To the extent the Social Media Features are hosted by the respective social media networks and you click through to these from our website, the latter may receive information showing that you have visited our website. If you are logged in to your social media account, it is possible that the respective social media network can link your visit to our websites with your social media profile.
Your interactions with Social Media Features are governed by the privacy policies (and any other applicable terms) of the respective companies that provide the relevant Social Media Features.
VI. Netarx’s Security Posture & Measures Taken
Security is a critical priority for Netarx. We maintain a comprehensive, written information security program that contains industry-standard administrative, technical, and physical safeguards designed to prevent the loss or theft and unauthorized access, use, disclosure or alteration of Personal Data.
However, no security system is perfect, and due to the inherent nature of the Internet, we cannot guarantee that data, including Personal Data, is absolutely safe from intrusion or other unauthorized access by others. You are responsible for protecting your password(s) and other authentication factors, as well as maintaining the security of your devices.
If you use the Netarx online service via a subscription purchased for you by an Netarx customer, then that customer is responsible for configuring your instance appropriately.
VII. International Data Transfers
Your Personal Data may be collected, transferred to, processed, and stored by us in the United States, and by our affiliates, service providers, and third parties that are based in other countries. The addresses of our offices where Netarx LLC and its affiliates are located can be found online at https://netarx.com .
Some of the countries where your Personal Data may be processed, including the United States, are not subject to an adequacy decision by the European Commission or your local legislature and/or regulator, and may lack data protection laws as comprehensive as or may not provide the same level of data protection as your jurisdiction, such as the European Economic Area, the United Kingdom, or Japan. For example, as of the effective date of this policy, the United States does not have a federal privacy law that covers all types of data; however, privacy is regulated by federal and state agencies and by various state laws. Considering regional differences, Netarx has put in place various safeguards and the security measures described above. For example, when we share Personal Data, we take reasonable steps so that the recipient of your Personal Data offers an adequate level of data protection, for example, by entering into the appropriate agreements containing relevant data protection provisions or we will ask you for your prior consent to such international data transfers.
VIII. Children
Netarx’s websites are not directed at children. We do not knowingly collect Personal Data from children under the age of 16. If you are a parent or guardian and believe that your child has provided us with Personal Data without your consent, please contact us by using the information in the “How to Contact Us” section, below, and we will take steps to delete such Personal Data from our systems.
IX. How Long Does Netarx Keep Your Data?
We will retain your Personal Data for a period of time that is consistent with the original purpose of the data collection, or as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. We determine the appropriate retention period for Personal Data by considering the amount, nature and sensitivity of your Personal Data processed, the potential risk of harm from unauthorized use or disclosure of your Personal Data and whether we can achieve the purposes of the processing through other means, and on the basis of applicable legal requirements (such as applicable statutes of limitation).
X. Your Information Choices
Your Privacy Choices
In the above sections, we describe how we may collect, use and share your Personal Data for providing relevant content and advertising. Below, we describe how you may unsubscribe, opt out, or otherwise modify settings related to our processing of your Personal Data.
Direct Email Marketing. If you wish to withdraw from direct email marketing communications from Netarx, you may click the “unsubscribe” button included in our emails or:
- Visit our Subscription Center. Please note, you cannot unsubscribe from critical transactional emails that are related to our provision of our online Service (such as those related to security and your Netarx account).
- For the Netarx Talent Community, then you may visit our Talent Community unsubscribe page here.
- For Netarx Consumer Products, you may update your preferences by logging into your account here.
Direct Marketing – Phone or Postal Mailings. If you wish to withdraw from phone call or postal mail marketing communications from Netarx, please request to do so through our form.
If you are a user of the Netarx online service via a subscription purchased for you by an Netarx customer, to opt-out of platform-based analytics on an individual level, including participation in the Netarx Ideas forum, please contact us at admin@netarx.com or please make a request for this through our form.
Your Privacy Rights
Depending on your jurisdiction, you may have certain rights with respect to your Personal Data that we process in our capacity as a data controller, subject to applicable law:
Right to Access. You have the right to access your Personal Data held by us.
Right to Rectification. You have the right to rectify inaccurate Personal Data and, taking into account the purpose of processing, to ensure it is complete.
Right to Erasure (or “Right to be Forgotten”). You have the right to have your Personal Data erased or deleted.
Right to Restrict Processing. You have the right to restrict our processing of your Personal Data.
Right to Data Portability. You have the right to transfer your Personal Data, when possible.
Right to Object. You have the right to object to the processing of your Personal Data that is carried out on the basis of legitimate interests, such as direct marketing.
Right to Opt Out of Sale. You may also have the right to opt-out of the sharing of your Personal Data with third parties for targeted advertising purposes on third-party sites. As described in Section III above, Netarx may use targeted or advertising cookies for our marketing efforts and to reach potential customers across the web. Depending on your jurisdiction (for example, if you are a California resident), you have the right to opt-out of the sale or sharing of your Personal Data by us as a business. Netarx shares Personal Data as further described below in Section XI, which may be considered a “sale” of Personal Data under the California Consumer Privacy Act. You may opt out by clicking the “Your Privacy Choices” link at the bottom of our website and selecting your preferences on that page.
Right Not to be Subject to Automated Decision-Making. You have the right not to be subject to automated decision-making, including profiling, which produces legal effects. Netarx does not currently engage in the foregoing on our websites or in our products and services.
Right to Non-Discrimination for the Exercise of Your Privacy Rights. You have the right not to receive discriminatory treatment by us for the exercise of your privacy rights as described above.
If you would like to make a request and exercise your rights described above or have questions or concerns, please complete our online form or reach out to us using the contact information below. You also have the right to lodge a complaint with your relevant supervisory authority.
XI. Information for California Residents / Your California Privacy Rights
Under the California Consumer Privacy Act of 2018 (“CCPA”), California residents have certain rights to understand and request that we disclose details about how we handle your Personal Data. If you would like to learn about our process for verifying requests, including the details that you must provide to us to verify your request, click here. To learn more about how we collect, use, disclose, and share your Personal Data, please see below.
Categories of Personal Data Collected
In the preceding 12 months, we have collected the following categories of Personal Data about California consumers. We may collect this Personal Data directly from you, from third parties, and from your interactions with us. For additional detail about the Personal Data that we collect and the sources from which we collect this Personal Data, please review Section III above. The Personal Data categories are:
- identifiers, such as name, email address, address, and phone number;
- categories of Personal Data described in subdivision (e) of Section 1798.80, such as address, telephone number, employment, and employment history;
- commercial information, such as records of products or services purchased and other transactional data;
- Internet or other network or device activity details, such as technical data about your use of our website, products and services;
- geolocation data, such as your approximate location based on IP address;
- audio, electronic, or visual data, such as part of a photo or recording for an Netarx in-person or virtual event;
- professional or employment-related information, such as your employer and job role;
- education information and details such as education history, certifications and qualifications;
- any other information you provide to Netarx in connection with a job application, such as information contained in a cover letter, information disclosed in an interview, or other information you volunteer during the application process; and
- inferences drawn from any of the above information.
We may retain this Personal Data for as long as is needed for the purpose(s) for which it was collected and no longer than is relevant and reasonably necessary. Our retention periods vary based on business, legal and regulatory needs. We securely retain records of data requests for at least 24 months as required under the CCPA. For further information on our retention criteria see Section IX above.
Business and Commercial Purposes for Collection; Disclosures for a Business Purpose
We may collect all of the above categories of Personal Data to run our business and carry out our day-to-day activities, as described above in Section IV. We have disclosed each of these categories of Personal Data with our service providers for various business purposes, as described above in Section V, in the preceding 12 months.
We collect and process Personal Data related to job applicants to recruit and hire, assess and evaluate a job applicant’s skills and qualifications, comply with legal obligations, and send information about positions at Netarx that may be of interest to individuals.
Categories of Personal Data Sold or Shared for Cross-Context Behavioral Advertising
In the preceding 12 months, we have disclosed the above categories of Personal Data to third-party advertising partners, such as in connection with our use of tracking technologies for cross-context behavioral advertising or by providing lists of email addresses for potential customers, so that we can reach you across the web with advertisements for our products and services. This may be considered “sharing” or a “sale” under the CCPA. You can read more about our sharing and sales activities above in Section III and Section V. Netarx does not have actual knowledge that it sells or shares the personal data of consumers under 16 years of age.
Categories of Personal Data Sold or Shared for Job Applicants
Netarx has not sold or shared any Personal Data relating to job applicants, in the 12 months preceding the effective date of this Privacy Policy.
Sensitive Personal Data
In addition to the categories of Personal Data listed above, we may collect certain categories of Sensitive Personal Data from you as that term is defined under CCPA, if you choose to provide it. In the preceding 12 months, we may have collected the following categories of Sensitive Personal Data from California consumers:
- Social Security Number, driver’s license, state identification card, or passport number;
- account log-In, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account;
- precise geolocation;
- racial or ethnic origin, religious or philosophical beliefs, or union membership;
- contents of your email and text messages, unless we are the intended recipient of the communication;
- biometric information for the purpose of unique identification;
- health information; and
- sex life or sexual orientation information.
Categories of Sensitive Personal Data Disclosed
In the preceding 12 months Netarx has not sold or shared any Sensitive Personal Data; however, we may have disclosed your Sensitive Personal Data to service providers for business purposes as further described in Section V above and as set forth below.
Business Purposes For Which Sensitive Personal Data will be Used or Disclosed We may collect the categories of Sensitive Personal Data listed for processing job applications and the purposes as further described in Section IV above, and to further our legitimate business purposes as outlined under the CCPA:
- performing services, including maintaining or servicing accounts;
- detection and prevention of security incidents;
- protecting against malicious, deceptive, fraudulent or illegal actions and prosecuting those responsible;
- auditing related to consumer interactions;
- short-term, transient use;
- quality and safety maintenance or verification;
- internal research for technological development; and
- debugging to identify and repair functionality.
Your Rights
The CCPA gives you certain rights regarding the Personal Data we collect about you:
Right to Know About Personal Data Collected, Disclosed, or Sold. You have the right to request to know what Personal Data we collect, use, disclose, share and sell about you.
Right to Request Deletion of Personal Data. You have the right to request the deletion of your Personal Data collected or maintained by us as a business.
Right to Opt-Out of the Sale or Sharing of Personal Data. You have the right to opt-out of the sale of your Personal Data by us as a business. Netarx shares Personal Data as described above, which may be considered a “sale” of Personal Data under the CCPA.
You may opt out by clicking here “Your Privacy Choices” link at the bottom of our website and selecting your preferences on that page. You may also opt out by broadcasting an opt-out preference signal like the Global Privacy Control (GPC), but please note that this signal will be linked to your browser only. If you wish to learn more about the GPC and how to use a browser or browser extension incorporating the GPC signal, you can visit the GPC website here.
Right to Limit the Use and Disclosure of Sensitive Personal Data. In some instances, we may use or disclose your Sensitive Personal Data for the legitimate business purposes as outlined under the CCPA, and for any other purposes as set forth in Section IV, above. If we ever use or disclose your Sensitive Personal Data for a reason other than the legitimate business purposes as outlined under the CCPA and for any other purposes other than those described in Section IV, we will update this Privacy Policy and provide you with instructions to limit the use and disclosure of your Sensitive Personal Data.
Right to Correct Inaccurate Personal Data. You have the right to request the correction of your Personal Data if it is inaccurate and you may submit a request as further described below.
Right to Non-Discrimination for the Exercise of Your Privacy Rights. You have the right not to receive discriminatory treatment by us for the exercise of your privacy rights conferred by the CCPA.
Authorized Agent. You may designate an authorized agent to make a request under the CCPA on your behalf. We may require the agent to demonstrate proof of their authorization by providing us with a signed permission from you or a copy of your power-of-attorney document granting that right. In the case of the former, we may still request that you verify your own identity as described above or directly confirm that you have provided such permission.
Financial Incentives. We do not provide any financial incentives tied to the collection, sale, or deletion of your Personal Data.
If you would like to make a request and exercise your rights described above, please complete our online form, or contact us via the telephone number listed in the section below.
XII. How to Contact Netarx
If you would like to contact us with questions or concerns about our privacy policies and practices, you may contact us via any of the following methods:
Email: admin@netarx.com
XIII. Changes to the Policy
This Privacy Policy may be updated from time to time, to reflect changes in our practices, technologies, additional factors, and to be consistent with applicable data protection and privacy laws and principles, and other legal requirements. If we do make updates, we will update the “effective date” at the top of this Privacy Policy webpage. If we make a materially significant update, we may provide you with notice prior to the update taking effect, such as by posting a conspicuous notice on our website or by contacting you using the email address you provided.