SecurePalm Tech Pvt Limited. , including any affiliates worldwide services (collectively, “SecurePalm,” “we,” “us,” or “our”) value the privacy of individuals who use or express interest in the SecurePalm Websites, SecurePalm Products, and SecurePalm Services (as defined below, collectively, our “Services”). This privacy policy (the “Privacy Policy”) explains how we collect, use, and disclose Personal Data.

1. GENERAL INFORMATION

1.1. “Personal Data” means any data which relates to a living individual who can be identified from that data or from that data and other information which is in the possession of, or is likely to come into the possession of, SecurePalm (or its representatives or service providers). In addition to factual information, it includes any expression of opinion about an individual and any indication of the intentions of SecurePalm or any other person in respect of an individual.

1.2. Beyond this Privacy Policy, your use of our Services is also subject to applicable End-user License Agreement available at our website.

1.3. As part of the search functionality, third parties may collect or receive information (including, without limitation, IP addresses and search terms) and use that information to provide measurement services, search results and other advertisements, including personalized and targeted search results and advertisements.

2. THE SOURCES OF THE INFORMATION WE COLLECT

This Privacy Policy concerns the following sources of information that we collect in connection with our Service,

which include:

• Our websites (e.g. www.securepalm.com) (“SecurePalm Websites”), emails, marketing communication;
• Information we received through our business partners and vendors

3. THE TYPES OF PERSONAL DATA WE COLLECT

We may collect and receive a variety of information from you or about you or your devices from various sources, as described below. If you do not provide your Personal Data when requested, you may not be able to use our Services if that information is necessary to provide you with our Services or if we are legally required to collect it.

3.1. Information that you provide to SecurePalm. This includes Personal Data about you that you provide to us. The nature of the Services you are requesting or using will determine the kind of Personal Data we might ask for, though such information may include (by way of a non-exhaustive list):

• basic Personal Data (such as first name; family name; position in the company [title]; company name; company email address; business phone number; business address; city; postcode; country);
• any information that you choose to share through SecurePalm Services, SecurePalm Products and SecurePalm Website which may be considered Personal Data. (Please note that SecurePalm does not collate information included on SecurePalm internet forums together with Personal Data from your User Center account or profile);

3.2. Information that we collect or generate about you. This includes (by way of non-exhaustive list):

• File with your contact history to be used for enquiry purposes so that we may ensure that you are satisfied with our Services;
• Through our cloud security services, traffic and security reports that include information on the internet usage of the organization’s computer users (e.g. what websites were visited by each user, any documents downloaded, security incidents, prevention measures taken by the gateway, etc.);
• Activity data relating to the use of protected documents, such as altering a document’s permissions and information regarding the individual that performed the activity;
• Information about you provided from third parties’ sources; and
• Through our cloud Email & Office service, the files and email correspondence (included the content therein) found in your accounts connected to such service.

3.3. Cookies. We and our third-party partners may collect Personal Data using cookies, which are small files of letters and numbers that we store on your browser or the hard drive of your computer. We may also use pixel tags and web beacons on our Services. These are tiny graphic images placed on web pages or in our emails that allow us to determine whether you have performed a specific action. We use cookies, beacons, invisible tags, and similar technologies (collectively “Cookies”) to collect information about your browsing activities and to distinguish you from other users of our Services. This aids your experience when you use our Services and allows us to improve the functionality of our Services. Cookies can be used for performance management, collecting information on how our Services are being used for analytics purposes. They can also be used for functionality management, enabling us to make your visit more efficient by, for example, remembering language preferences, passwords, and log-in details. For more information on the types of Cookies we and third parties may use in connection with our Services, please see our Cookies Notice.

3.4. Anonymized data. In addition to the categories of Personal Data described above, SecurePalm may also process further anonymized information or de-identified and aggregated with other data that is not processed by reference to a specific individual.

4. HOW WE USE YOUR INFORMATION

4.1. We may process your Personal Data for the following purposes:

• for ongoing review and improvement of the information provided on SecurePalm Websites to ensure they are user friendly and to prevent any potential disruptions or cyberattacks;
• to allow you to use and access the functionality provided by the SecurePalm Products and the SecurePalm Services;
• to assess your application for SecurePalm Products and SecurePalm Services, where applicable;
• to set up customers to use SecurePalm Products and SecurePalm Services;
• to set up users to use the User Center;
• to conduct analysis required to detect malicious data and understand how this may affect your IT system;
• for statistical monitoring and analysis of current attacks on devices and systems and for the on-going adaptation of the solutions provided to secure devices and systems against current attacks;
• to understand feedback on SecurePalm Products and SecurePalm Services and to help provide more information on the use of those products and services quickly and easily;
• to communicate with you in order to provide you with: (i) our Services; (ii) information about us and our Services; or (iii) offers and marketing information;
• to send you e-mail updates on the latest cyber security trends, news, upcoming events and other marketing or promotional materials;
• for in-depth threat analysis;
• to understand your needs and interests;
• for the management and administration of our business;
• for improvement of our products and services.
• to comply with and to assess compliance with applicable laws, rules and regulations, and internal policies and procedures;
• for the administration and maintenance of databases storing Personal Data to market SecurePalm’s products and services; or
• for back-up and data loss prevention.

4.2. When we process Personal Data we verify the existence of a lawful ground for such processing activity, including:

• performing our contractual obligations;
• a lawful consent has been obtained;
• compliance with legal or regulatory obligation;
• exercising or defending our rights;
• legitimate business interests, such as:

• effectively and efficiently manage and administer the operation of our business;
• maintaining compliance with internal policies and procedures;
• monitoring the use of our copyrighted materials;
• enabling quick and easy access to information on our Services;
• offering optimal, up-to-date security solutions;
• sending you e-mail updates on our Services, the latest cyber security trends, news, upcoming events and other marketing or promotional materials; and
• obtaining further knowledge of current threats to network security in order to update our security solutions and provide these to the market.

4.3. We will take steps to ensure that your Personal Data is accessed only by such individuals that have a need to do so for the purposes described in this Privacy Policy.

5. DISCLOSURE OF INFORMATION TO THIRD PARTIES

We may share or otherwise disclose the Personal Data we collect from you as described below or otherwise disclosed to you at the time of the collection.

• Vendors and Service Providers. We may share any information we receive with vendors and service providers retained in connection with the provision and marketing of our Services or other relevant services.
• Partners and Affiliates. We may share any information with our distributors, partners, corporate affiliates, parents, or subsidiaries for any purpose described in this Privacy Policy.
• As Required by Law and Similar Disclosures. We may access, preserve, and disclose your Personal Data if we believe doing so is required or appropriate to: (i) comply with law enforcement requests and legal process, such as a court order or subpoena; (ii) respond to your requests; or (iii) protect your, our, or others’ rights, property, or safety.
• Merger, Sale, or Other Asset Transfers. We may disclose and transfer your Personal Data to service providers, advisors, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company, or we sell, liquidate, or transfer all or a portion of our business or assets.
• Consent. We may also disclose Personal Data from or about you or your devices with your permission.

6. INTERNATIONAL TRANSFERS OF PERSONAL DATA

• 6.1. SecurePalm is a global business. Our customers and our operations are spread around the world. As a result, we collect and transfer Personal Data on a global basis. That means that we may transfer your Personal Data to locations outside of your country.
• 6.2. Europe.
  Where we transfer your Personal Data to another country outside the European Economic Area (“EEA”) or the United Kingdom (“UK”), we will ensure that it is protected and transferred in a manner consistent with legal requirements. In relation to data being transferred outside of Europe or the UK, for example, this may be done in one of the following ways:

• the country that we send the data to, might be approved by the European Commission as offering an adequate level of protection for Personal Data (for example, Israel is an approved country);
• the recipient might have signed a contract based on applicable “model contractual clauses” approved by the European Commission, obliging them to protect your Personal Data; or
• in other circumstances the law may permit us to otherwise transfer your Personal Data outside the EEA or UK.

You can obtain more details of the protection given to your Personal Data when it is transferred outside the EEA or the UK (including a copy of the standard data protection clauses which we have entered into with recipients of your Personal Data) by contacting us as described in paragraph 13 below.

6.3. China. For residents in the mainland of the People’s Republic of China (“Mainland China”), we may transfer, access or store your Personal Data outside of the Mainland China where we are satisfied that adequate levels of protection are in place to protect the integrity and security of your Personal Data or adequate security measures are adopted and in compliance with the applicable laws, such as contractual arrangements. Where required by applicable laws, we will put in place appropriate measures to ensure that all processing of your Personal Data outside of the Mainland China is safeguarded by the equivalent level of data protection in the Mainland China.

7. YOUR RIGHTS

7.1. Marketing Communications. You can unsubscribe from our promotional emails via the link provided in the emails. Even if you opt out of receiving promotional messages from us, you will continue to receive administrative messages from us.

7.2. Do Not Track. There is no accepted standard on how to respond to Do Not Track signals, and we do not respond to such signals.

If you choose not to provide us with the Personal Data we collect, some features of our Services may not work as intended.

7.3. Your European Privacy Rights. If you are located in the EEA or the UK, you have additional rights described below.

• You may request access the Personal Data we maintain about you, update and correct inaccuracies in your Personal Data, restrict or object to the processing of your Personal Data, have your Personal Data anonymized or deleted, as appropriate, or exercise your right to data portability to easily transfer your Personal Data to another company. In addition, you also have the right to lodge a complaint with a supervisory authority, including in your country of residence, place of work or where an incident took place.
• You may withdraw any consent you previously provided to us regarding the processing of your Personal Data at any time and free of charge. We will apply your preferences going forward and this will not affect the lawfulness of the processing before you withdrew your consent.

You may exercise these rights by contacting us using the contact details at the end of this Privacy Policy. Before fulfilling your request, we may ask you to provide reasonable information to verify your identity. Please note that there are exceptions and limitations to each of these rights, and that while any changes you make will be reflected in active user databases instantly or within a reasonable period of time, we may retain Personal Data for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so.

• 7.4. How to Block Cookies. You can block Cookies by setting your internet browser to block some or all Cookies. However, if you use your browser settings to block all Cookies (including essential Cookies) you may not be able to access all or parts of our Services. By using our Services, you consent to our use of Cookies and our processing of Personal Data collected through such Cookies, in accordance with this Privacy Policy. You can withdraw your consent at any time by deleting placed Cookies and disabling Cookies in your browser, or as explained below. You can change your browser settings to block or notify you when you receive a Cookie, delete Cookies, or browse our Services using your browser’s anonymous usage setting. Please refer to your browser instructions or help screen to learn more about how to adjust or modify your browser settings. If you do not agree to our use of Cookies, you should change your browser settings accordingly. You should understand that some features of our Services may not function properly if you do not accept Cookies. Where required by applicable law, you will be asked to consent to certain Cookies before we use or install them on your computer or other device.

8. HOW WE SAFEGUARD YOUR INFORMATION

8.1. We have extensive controls in place to maintain the security of our information and information systems. Files are protected with safeguards according to the sensitivity of the relevant information. Appropriate controls (such as restricted access) are placed on our computer systems. Physical access to areas where Personal Data is gathered, processed or stored is limited to authorized employees.

8.2. As a condition of employment, SecurePalm employees are required to follow all applicable laws and regulations, including in relation to data protection law. Access to sensitive Personal Data is limited to those employees who need it to perform their roles. Unauthorized use or disclosure of confidential information by our employees is prohibited and may result in disciplinary measures.

8.3. SecurePalm requires its worldwide employees and contractors that have access to its internal systems to complete annual trainings on data protection and security. Such trainings are aimed to make sure that SecurePalm’s personnel understand and follow SecurePalm’s privacy policies and guidelines when handling Personal Data.

8.4. When you contact a SecurePalm representative, you may be asked for some Personal Data. This type of safeguard is designed to ensure that only you, or someone authorized by you, has access to your file.

9. THIRD PARTIES

Our Services may contain links to other websites, products, or services that we do not own or operate (“Third-Party Services”). We are not responsible for the privacy practices, policies, or other content of these Third-Party Services. Please be aware that this Privacy Policy does not apply to your activities on these Third-Party Services or any information you disclose to these Third-Party Services. If you have any questions about how these other sites use your Personal Data, you should contact them directly. We encourage you to read their privacy policies before providing any information to them.

10. HOW LONG WE KEEP YOUR PERSONAL DATA

We take measures to delete your Personal Data or keep it in a form that does not permit identifying you when this information is no longer necessary for the purposes for which we process it unless we are required by law to keep this information for a longer period. When we process Personal Data for our own purposes, we determine the retention period taking into account various criteria, such as the type of services provided to you, the nature and length of our relationship with you, possible re-enrollment with our Services, the impact on our Services we provide to you if we delete some information from or about you, and mandatory retention periods provided by law and the statute of limitations.

11. CHILDREN’S PRIVACY

We do not knowingly collect, maintain, or use Personal Data from children under 16 years of age (“Minors”), and no parts of our Services are directed at children. If you learn that a Minor has provided us with Personal Data in violation of this Privacy Policy, please alert us at support@securepalm.com

• 12. DESIGNATED REPRESENTATIVE

SecurePalm Tech (SecurePalm’s mother company) registered office may be contacted using the following contact information:

SecurePalm Tech Pvt Limited

‍600 White Oakrigde Road 

Short Hills, New Jersey

07078

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