Effective Date: Sept 20, 2022
Valence Security Inc. and its affiliates (“Valence Security”, “we”, “our” or “us”) puts great efforts in making sure that the Personal Data (as defined below) processed by us is safe and used properly, and that our data practices are properly communicated to our customers, users and prospects.
(i) Customer Data: Personal Data (defined below) that we collect and process on behalf of our business customers (“Customers”) as part of our security solution (the “Application”). We process such Customer Data as data processors on our Customers behalf as further detailed in Section 10 and 11.
(ii) User Data: Personal Data concerning our Customers’ internal individuals who directly engage with Valence Security concerning their organizational account and users of the Service on behalf of such Customers (e.g., the account administrators and users, billing contacts) and authorized signatories on behalf of the Customer (collectively, “User(s)”), as well as the Customer’s business needs and preferences, as identified to us or recognized through our engagement with them;
(iii) Website visitors & Prospects Data: Data relating to prospective Customers, participants at our events, visitors or partners (collectively, “Prospect(s)”), who visit or otherwise interact with any of our websites (the “Websites”, and collectively with the Application – the “Services”), online ads and content, emails or communications under our control.
You are not legally required to provide us with any personal data, and may do so (or avoid doing so) at your own free will. If you do not wish to provide us with your personal data, or to have it processed by us or any of our Service Providers (as defined below), please avoid any interaction with us or use of our Services. If you are a User of the Platform Application on behalf of any of our Customers, we suggest that you contact your account administrator with any questions.
We may collect the categories of data detailed below through the data subject’s interaction with us directly or through our Services, or through third party services and other business initiatives as detailed in this policy.
Specifically, we may collect or generate the following types of personal data about individuals through the Services:
When you use our Services, we may collect, record or generate certain technical data about you. We do so either independently or with the help of third-party Service Providers (as defined below). Such data consists of connectivity, technical and aggregated usage data such as IP addresses and approximate general locations derived from such IP addresses, device and application data (like type, operating system, mobile device or app id, browser version, location and language settings used), activity logs, the relevant cookies and pixels installed or utilized on your device, and the recorded activity (sessions, clicks, use of features, logged activities and other interactions) of Prospects and Users in connection with our Services.
We collect data such as: how often Prospects visit or use the Sites, which pages they visit and when, which website, ad or email message brought them there, and how Users interact with and use the Application and its various features.
Such Personal Data typically includes account creation data (full name, e-mail address, password and other information used for authentication and access control), contact and professional information (name, company, position, e-mail address, phone and physical address), workplace and position within the company, direct interactions and communications with us (email correspondences, call and video recordings), feedback and testimonials received, contractual and billing details, as well as any expressed, presumed or identified needs, preferences, attributes and insights relevant to our potential or existing engagement, and additional information submitted by Users, their colleagues or the organization.
We may collect or receive Personal Data concerning our Prospects through the “Contact Us” or “Schedule a Demo” forms on our website or subscribing to our newsletter. We may also receive such data from our business partners, service providers, and other third parties (such as from an organizer of an event or webinar in which you participated), and through the use of tools and channels commonly used for connecting between companies and individuals in order to explore potential business and employment opportunities, such as LinkedIn™ and other data services and sources.
2. Data Uses
We use Personal Data as necessary for the performance of our Services; to comply with our legal and contractual obligations; and to support our legitimate interests in maintaining and improving our Services, e.g., in understanding how our Services are used, and gaining insights which help us dedicate our resources and efforts more efficiently; in marketing, advertising and selling our Services e.g. by enhancing (enriching) existing information on Prospects by supplementing missing or incomplete data; providing customer service and technical support; and protecting and securing our Customers, Users, Prospects, ourselves and our Services.
We do not sell your personal information for the intents and purposes of the California Consumer Privacy Act (CCPA) (to the extent applicable) and have not sold your personal information in the past 12 months.
Specifically, we use the above categories of data for the following purposes (and in reliance on the legal bases for processing noted next to them, as appropriate):
Customer and User personal data
Customer, User and Prospect personal data
3. Data Location
We and our authorized Service Providers (as defined below) maintain, store and process Personal Data in the United States of America. We may also retain your Personal Data in Israel and in other locations as reasonably necessary for the proper performance and delivery of our Services, or as may be required by law.
Valence Security is headquartered in Israel, a jurisdiction which is considered by the European Commission, the UK Secretary of State, and the Swiss Federal Data Protection and Information Commissioner, to be offering an adequate level of protection for personal data of individuals residing in EU Member States, the UK and Switzerland, respectively. We transfer data from the EEA, the UK and Switzerland to Israel on this basis.
4. Data Retention
We retain Personal Data for as long as reasonably necessary in order to maintain and expand our relationship and to provide you with our Services and offerings.
Notwithstanding the aforementioned, we will also retain Personal Data for as long as is necessary in order to comply with our legal and contractual obligations, or to protect ourselves from any potential disputes (i.e. as required by laws applicable to log-keeping, records and bookkeeping, and in order to have proof and evidence concerning our relationship, should any legal issues arise following your discontinuance of use), in accordance with our data retention policy and at our reasonable discretion.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and the applicable legal requirements.
Please note that except as required by applicable law or our specific agreements with you, we will not be obligated to retain your Personal Data for any particular period, and we are free to securely delete it or restrict access to it for any reason and at any time, with or without notice to you.
If you have any questions about our data retention policy, please contact us by e-mail at: email@example.com.
5. Data Disclosure
Legal Compliance: Except in exceptional circumstances, we may disclose or allow government and law enforcement officials access to your Personal Data, in response to a subpoena, search warrant or court order (or similar requirement), or in compliance with applicable laws and regulations. Such disclosure or access may occur if we believe in good faith that: (a) we are legally compelled to do so; (b) disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing; or (c) such disclosure is required to protect our legitimate business interests, including the security or integrity of our Users, Prospects and our products and Services.
Service Providers: We may engage with selected third-party companies and individuals to perform services complementary to our own. Such service providers include hosting and server co-location services, user authentication, communications and content delivery networks (CDNs), data and cyber security services, billing and payment processing services, fraud detection and prevention services, web analytics, e-mail distribution and monitoring services, session or activity recording services, remote access services, performance measurement, data optimization and marketing services, social and advertising networks, content providers, e-mail, voicemails, support and customer relation management systems, and our legal, financial and compliance advisors and auditors (collectively, “Service Providers“).
These Service Providers may have access to your Personal Data,depending on each of their specific roles and purposes in facilitating, supporting and enhancing our Services. Service Providers may only use the data for such limited purposes as determined in our agreements with them.
Customers: Our Customers have access to any personal data we process on their behalf in our capacity as a “processor” or a “service provider.”
Protecting Rights and Safety: We may share Personal Data with others if we believe in good faith that this will help protect the rights, property or personal safety of Valence Security, any of our Users or Customers, or any members of the general public.
For the avoidance of doubt, Valence Security may share data in additional manners, pursuant to your explicit approval, or if we are legally obligated to do so, or if we have successfully rendered such data non-personal, non-identifiable and anonymous. We may transfer, share or otherwise use non-personal and non-identifiable data at our sole discretion and without the need for further approval.
6. Cookies and Tracking Technologies
In order for some of these technologies to work properly, a small data file (“cookie”) is stored on your device. By default, we use several persistent cookies for purposes of session authentication, monitoring performance of our services and generally providing and improving our Website.
A. What is a cookie?
Cookies are computer files containing small amounts of information which are downloaded to your computer or mobile device when you visit a website. Cookies can then be sent back to the originating website on each subsequent visit, or to another website that recognizes that cookie. Cookies are widely used in order to make websites work, or to work more efficiently, as well as to provide information to the owners of the website.
Cookies do lots of different jobs, like letting you navigate between pages efficiently, remembering your preferences, and generally improving the user experience. Cookies may tell us, for example, whether you have visited our Website before or whether you are a new visitor.
There are two broad categories of cookies:
• First Party Cookies – served directly by us to your computer or mobile device.
• Third Party Cookies – which are served by a third party on our behalf. We use third party cookies for functionality, performance / analytics, marketing and social media purposes.
Cookies can remain on your computer or mobile device for different periods of time. Some cookies are ‘session cookies’, meaning that they exist only while your browser is open. These are deleted automatically once you close your browser. Other cookies are ‘permanent cookies’, meaning that they survive after your browser is closed. They can be used by websites to recognize your computer when you open your browser and browse the Internet again. These cookies can last for a long time. Please see the cookie Section in your browser for details about duration for each cookie.
B. Web beacons:
Cookies are not the only way to recognize or track visitors to a website. We may use other, similar technologies from time to time, like web beacons (sometimes called “tracking pixels” or “clear gifs”). These are small graphics files that contain a unique identifier that enable us to recognize when someone has visited our Site. This allows us, for example, to monitor the traffic patterns of users from one page within our Website to another, to deliver or communicate with cookies, to understand whether you have come to our Site from an online advertisement displayed on a third-party website, to improve Website performance and to measure the success of email marketing campaigns. In most instances, these technologies are reliant on cookies to function, and therefore declining cookies prevents them from functioning.
If you don’t want your cookie information to be associated with your visits to these pages, you can set your browser to turn off cookies as described further below. If you turn off cookies, web beacon and other technologies will still detect your visits to our Website; however, they will not be associated with information otherwise stored in cookies.
C. Targeted advertising
Third parties may drop cookies on your computer or mobile device to serve advertising through our Website. These companies may use information about your visits to this and other websites in order to provide relevant advertisements about goods and services that you may be interested in. They may also employ technology that is used to measure the effectiveness of advertisements.
• Track traffic flow and patterns of travel in connection with our Website;
• Understand the total number of visitors to our Websites on an ongoing basis and the types of internet browsers (e.g. Chrome, Firefox, Safari, or Internet Explorer) and operating systems (e.g. Windows or Mac) used by our visitors;
• Monitor the performance of our Websites and to continually improve it; and
• Customize and enhance your online experience.
E. What types of cookies do we use?
The types of cookies used by us in connection with the Website can be considered ‘essential website cookies’, ‘functionality cookies’, ‘Marketing Cookies’ and ‘analytics and performance cookies’. We’ve set out some further information below. You can see all the used cookies in the cookies section in your browser.
(i) Cookies necessary for essential website purposes
These cookies are essential to provide you with services available through this Website and to use some of its features, such as access to secure areas. Without these cookies we will not be able to provide services that you require, such as transactional pages and secure login accounts.
(ii) Functionality Cookies
These cookies record information about choices you’ve made and allow us to tailor the Website to you. These cookies allow us to provide you with our services in the way in which you have required, as you continue to use or come back to our Website. For example, these cookies may allow us to:
• Save your location preference if you have set your location on the homepage in order to receive a localized information;
• Remember settings you have applied, such as layout, text size, preferences, and colors;
• Show you when you are logged in; and
• Store accessibility options.
(iii) Performance / Analytics Cookies
We use performance/analytics cookies to analyze how the Website is accessed, used, or is performing. We do this in order to provide you with a better user experience and to maintain, operate and continually improve the Website. For example, these cookies allow us to:
• Better understand our Website visitors so that we can improve how we present our content;
• Test different design ideas for particular pages, such as our homepage;
• Collect information about Website visitors such as where they are located and what browsers they are using;
• Determine the number of unique users of the Website;
• Improve the Website by measuring any errors that occur; and
• Conduct research and diagnostics to improve product offerings.
We use marketing cookies to deliver many types of targeted digital marketing. We do this in order to provide you with a better user experience and to maintain, operate and continually improve the Website. The cookie store user data and behavior information, which allows advertising services to target audience according to variables.
F. How to control or delete cookies
The following pages have information on how to change your cookies settings for the different browsers:
G. Need More Information?
If you would like to find out more about cookies and their use on the Internet, you may find the following link useful:
If you have disabled one or more Cookies, we may still use information collected from cookies prior to your disabled preference being set, however, we will stop using the disabled cookie to collect any further information.
Some web browsers may transmit Do Not Track signals to websites with which the browser communicates, telling the site not to follow its online movements. Because of differences in how web browsers interpret this feature, it is not always clear whether Visitors intend for these signals to be transmitted, or whether they are even aware of them. Therefore, we currently do not respond to such Do Not Track signals.
Please note that if you get a new computer, install a new browser, erase or otherwise alter your browser’s cookie file (including upgrading certain browsers), you may also clear the opt-out cookies installed once you opt-out, so an additional opt-out will be necessary to prevent additional tracking.
Service Communications: We may contact you with important information regarding our Services. For example, we may send you notifications (through any of the means available to us) of changes or updates to our Services, billing issues, log-in attempts or password reset notices, etc. Please note that you will not be able to opt-out of receiving certain service communications which are integral to your use of some of the Services (like password resets or billing notices).
Promotional Communications: We may engage in service and promotional communications, through e-mail, phone, SMS and notifications subject to all applicable laws; we may also notify you about new features, additional offerings, events, special opportunities or any other information we think, based on the information we process for this purpose, you will find valuable, as our Customer, User, or Prospect, subject to any necessary collection of your consent as appropriate based on applicable laws.
If you do not wish to receive such promotional communications, you may notify us at any time by sending an e-mail to: firstname.lastname@example.org or by following the instructions contained in the promotional communications you receive.
8. Data Security
We implement industry-standard systems, applications and procedures to secure your personal data, to minimize the risks of theft, damage, loss of information, or unauthorized access or use of information. Such mechanisms include encryption of data in transit and at rest where appropriate.
However, although we make efforts to protect your privacy, we cannot guarantee that our Websites, Application or Services (or any part thereof) will be immune from any wrongdoings, malfunctions, unlawful interceptions or access, or other kinds of abuse and misuse.
To learn more, please contact us via email at: email@example.com.
9. Data Subject Rights
Individuals may have rights concerning their Personal Data. If you wish to exercise your privacy rights under any applicable law, including the EU or UK General Data Protection Regulation (GDPR) or the California Consumer Privacy Act (CCPA) such as the right to know/request access to (specific pieces of personal data collected; categories of personal data collected; categories of sources from whom the personal data was collected; purpose of collecting personal data; categories of third parties with whom we have shared personal data) and rectification or erasure of your Personal Data held with Valence Security, or to restrict or object to such Personal Data’s processing (including the right to direct us not to sell your personal data to third parties now or in the future), or to port such Personal Data, or the right to equal services and prices (each to the extent available to you under the laws which apply to you) – please contact us by e-mail at: firstname.lastname@example.org.
Under some regulatory frameworks, such as the GDPR, you may also have the right to lodge a complaint with the relevant supervisory authority, as applicable.
Please note that when you ask us to exercise any of your rights under this policy or applicable law, we may need to ask you to provide us certain credentials to make sure that you are who you claim you are, to avoid disclosure to you of personal information related to others and to ask you to provide further information to better understand the nature and scope of data that you request to access. Such additional data will be then retained by us for legal purposes (e.g., as proof of the identity of the person submitting the request), in accordance with Section 4 above.
We may redact from the data which we will make available to you, any personal data related to others.
If you would like to make any requests or queries regarding Personal Data that we process on our Customers’ behalf, please contact the administrator of such customers’ account directly. For example, if you are our Customer’s User, and wish to access, correct, or delete data processed by us on behalf of our Customer, please direct your request to the relevant customer (who is the “data controller” of such data – see Section 10 below). Note that if you do contact us, we may share your communications with our Customer.
10. Data Controller/Processor
Certain data protection laws and regulations, such as the EU or UK GDPR or the CCPA, typically distinguish between two main roles for parties processing Personal Data: the “data controller” (or under the CCPA, “business”), who determines the purposes and means of processing; and the “data processor” (or under the CCPA, “service provider”), who processes the data on behalf of the data controller (or business). Below we explain how these roles apply to our Services, to the extent that such laws and regulations apply.
Valence Security is the “data processor” (or “service provider”) of Customer Data, which we process on behalf of our Customer (who is the “data controller” of such data); and our Service Providers who process such User and Customer Data on our behalf are the “sub-processors” of such data. Accordingly, Valence Security processes Customer Data strictly in accordance with such Customer’s reasonable instructions and commercial agreements with such Customer.
Valence Security is both a “data controller” and “data processor” of User Data. Such data is processed by Valence Security for its own purposes (as described in Section 2 above), as an independent ‘controller’; whilst those certain portions of it which are included in Customer Data will be processed by us on our Customer’s behalf, as a ‘processor’.
For the avoidance of doubt, each Customer is solely responsible for determining whether and how they wish to use our Services, and for providing adequate notice to its Users, and any other individual whose data may be contained in the User and Customer Data – including sufficient reference to the processing of their Personal Data via the Services, and any other information necessary to comply with all applicable privacy and data protection laws. Our Customers are also responsible for ensuring that all legal requirements applicable to the collection, use or other processing of data through our Services are fully met by the Customer or any individuals using the Services on the Customer’s behalf or at their request; and to obtain all approvals and consents from such individuals as required under such laws.
10. Our Processing Activities
Our Application allows our Customers to manage risks that may arise from third-party integrations and thereby securing app interconnectivity.
11. Additional Notices
California Requirements: This policy describes the categories of personal information we may collect and the sources of such information (in Section 1 above), and our retention (Section 4) and deletion (Section 9) practices. We also included information about how we may process your information, which includes for “business purposes” under the California Consumer Privacy Act (CCPA). We do not sell your personal information for the intents and purposes of CCPA. We may disclose personal data to third parties or allow them to collect personal data from our Services as described in Section 5 above, if those third parties are authorized Service Providers or business partners who have agreed to our contractual limitations as to their retention, use, and disclosure of such personal data, or if you integrate the services of third parties with our Services, or direct us to disclose your personal data to third parties, or as otherwise described in Section 5 above.
If you have any questions or would like to exercise your rights under the CCPA, you can contact us at email@example.com or via mail as follows: [insert address].
Our Services are not designed to attract children: We do not knowingly collect Personal Data from children and do not wish to do so. If we learn that a person who is considered a minor according to applicable law is using our Services, we will attempt to prohibit and block such use and will make our best efforts to promptly delete any Personal Data stored with us with regard to such minor. If you believe that we might have any such data, please contact us by e-mail at: firstname.lastname@example.org.
If you are a GDPR-protected individual, you also have the right to lodge a complaint with the relevant supervisory authority in the EU or the UK, as applicable.