Effective Date: October 19, 2021
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) User and Customer Data: data relating to the performance of our security solution or any part thereof (the “Platform”) by customers (or on behalf of customers) (“Customer(s)”) or by their end users (“End User(s)” or “Users”). This data may include account and activity data relating to individuals who use the Platform as well as data related to the Customer’s operation (such as the types of its business applications, (as such term defined below) and configurations;
(ii) Website and CRM Data: data relating to Customers, potential Customers and visitors of our websites or any other website in our control, on which this policy is presented), online ads and content, emails or communications under our control (“Websites” and “Visitors” respectively);
(iii) Other Types of Data: Participants’ Information (as defined below), Applicants’ Information (as defined below) or any other data or information collected while otherwise interact with us.
• Data Collection and Processing
• Data Uses
• Data Location
• Data Retention
• Data Sharing
• Cookies and Tracking Technologies
• Data Security
• Data Subject Rights
• Data Controller/Processor
• Additional Notice and Contact Details
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 an End User of the Platform on behalf of any of our Customers, we suggest that you contact your account administrator with any questions.
1. Data Collection and Processing
(i) Data from End Users and Customers of the Platform: Our Platform enables our Customers and their End Users to understand and secure their enterprise applications (the “Solution”). During such usage, we will gather records of data embedded within and related to the Customer’s enterprise applications. Such records contain various types of data, including data which might relate to identifiable individuals (“Personal Data”). We may use the Platform and the information provided thereunder, as part of the implementation and performance of our Solution (including with respect to any other related services) (the Solution and such related Services shall be referred herein as the “Services”) (all data processed in connection with these processes and in connection with any other feature of the Platform shall be referred to as “End User and Customer Data”).
When you use our Services (including, inter alia, as an End User), 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 activity logs and unique user identifiers in connection with our Services. In order to characterize the Customer’s applications configurations, to monitor its activities, and to enforce its organizational policies, we may extract certain information provided by Customer’s applications.
When you sign-in to our Services, you may provide us with your Personal Data voluntarily, either directly (by submitting you email address and other details yourself) or by signing up to third party services using your other network accounts (e.g., connecting to our Services through Google™ or MS single sign on) and selecting to grant us access to certain data available on such account(s).
Such Personal Data typically includes account creation data (full name, e-mail address), contact and professional information (name, company, position, e-mail address, phone and physical address) and other data you choose to provide.
(ii) Valence Security’s Website, CRM and Prospect Data: We collect and generate the following types of Personal Data concerning our Visitors, Participants, Customers, End Users and prospects –
• Website usage information (connectivity, technical and aggregated usage data, such as user agent, IP addresses, device data (like type, OS, device id, browser version, locale and language settings used), activity logs, session recordings, and the cookies and pixels installed or utilized on the device);
• Customer account information (contact, contractual and billing details concerning our Customers, which may also contain the details of their internal focal persons who directly engage with Valence Security concerning their organizational account, e.g., the account administrators, billing contacts and authorized signatories on behalf of the Customer; as well as the Customer’s needs and preferences, as identified to us or recognized through our engagement with them);
• Data obtained through Analytics Tools: We may use analytics tools (e.g., Google Analytics) to collect data about the use of our Website. Analytics tools collect data such as how often Visitors visit or use the Website, which pages they visit and when, and which website, ad or e-mail message brought them there.
• Information concerning our Customers and prospects: We also collect and generate the following Personal Data concerning the Customer and its End Users:
- User account and contact information (e-mail address, name, title, business unit, group association, phone number, permission levels and additional information submitted by Users, their team members or their organization);
- Direct interactions and communications with us (including, in some cases, recordings of your calls and emails with us, for user enablement, backup, support and training purposes and for the purposes detailed below). Phone calls (e.g., with our customer success or product consultants) may be automatically recorded, tracked and analyzed, for purposes including analytics, service, operations, and business quality control and improvements, and record-keeping purposes.
We collect the above categories of data either automatically, through the data subject’s interaction with us or through our Services, or through third party services, analytics tools, events we organize or participate in, and other business initiatives.
(iii) Job Applications and Participants: (A) We may collect information provided to us by job candidates (“Applicants”) when they apply to a position in our super awesome company (directly, through head hunters or through other service providers). Valence Security welcomes all qualified Applicants to apply to any of the open positions by sending us their contact details and CV (“Applicants Information”). (B) If you participate in an event or webinar that we sponsor or participate in (“Participant”), we may receive your Personal Data from any Visitor, Participant or from the event organizers. We may also receive your contact and professional details (e.g., your name, company, position, contact details and professional experience, preferences and interests) from our business partners or service provides, 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 (“Participants Information”).
2. Data Uses
Valence Security processes End User and Customer Data, and any Personal Data contained in it, strictly on the customer’s behalf, in accordance with their reasonable instructions.
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; providing customer service and technical support; and protecting and securing our Customers and their End Users, Visitors, Participants, Applicants, prospects, ourselves and our Services.
We also use Personal Data of Applicants that apply to a position in our company, in order to evaluate their candidacy. We are committed to keep Applicants Information private and use it solely for our internal recruitment purposes (including for identifying Applicants, evaluating their applications, making hiring and employment decisions, background checks on Applicants and contacting Applicants by phone or in writing).
We do not sell your personal information for the intents and purposes of the California Consumer Privacy Act (CCPA) (to the extent applicable).
Specifically, we use the above categories of data for the following purposes:
1. To facilitate, operate, and provide our Services;
2. To authenticate the identity of Users, and to allow them access to our Services;
3. To provide our Visitors, Customers and End Users with assistance and support;
4. To gain a better understanding on how individuals use and interact with our Website and Services, and how we could improve their and others’ user experience, and continue improving our products, offerings and the overall performance of our Services;
5. To facilitate and optimize our marketing campaigns, ad management and sales operations, and to manage and deliver advertisements for our products and services more effectively, including on other websites and applications. Such activities allow us to highlight the benefits of using our Services, and thereby increase your engagement and overall satisfaction with our Services. This includes contextual, behavioural and interests-based advertising based on your activity, preferences or other data available to us or to our business partners;
6. To contact our Customers, End Users and prospects with general or personalized service-related messages, as well as promotional messages that may be of specific interest to them (as further described in Section 7 below);
7. To facilitate, sponsor and offer certain events, contests and promotions;
8. To support and enhance our data security measures, including for the purposes of preventing and mitigating the risks of fraud, error or any illegal or prohibited activity;
9. To create aggregated statistical data, inferred non-personal data, or anonymized or pseudonymized data (rendered non-personal and non-identifiable), which we or our business partners may use to provide and improve our respective services, or for any other purpose; and
10. To comply with applicable laws and regulations.
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; provided that End User and Customer Data may only be processed in such locations as permitted in commercial agreements with the applicable customer.
4. Data Retention
Use and Customer Data
We retain End User and Customer Data strictly on our Customer’s behalf, in accordance with their reasonable instructions and applicable laws. We may retain End User and Customer Data for as long as your organization's account with us is active; as reasonably necessary for us to provide or offer our Services to you and your organization; or as long as we consider necessary for the purposes described herein.
Any Customer may request information regarding the storage and retention of data (“Audit”) by contacting us. Tanega shall make reasonable efforts to respond to the Audit in a reasonable time and subject to applicable law and to the protection of Valence Secuirty’s trade secrets.
Unless otherwise agreed in writing with the Customer, after a request from the Customer to delete any data or termination or expiration of the agreement with the Customer, an automated process will begin that permanently deletes the data in accordance with the timelines set forth in the tables below. Once initiated, this process cannot be reversed and data will be permanently deleted.
Timeline for Deletion (after deletion process begins) for Cancellation, Termination or Migration
Access and Security Logs
Up to 2 years
Data in Analytics Platform
Communications regarding requests for data deletion and exercise of individual rights
At least 7 years
However, some data will not be deleted and shall be kept in an anonymized manner. Some metadata and statistical information concerning the use of the Services are not subject to the deletion procedures in this policy and may be retained by Valence Security. Some data may also be retained on our third-party service providers’ servers until deleted in accordance with their deletion policy.
Other Types of Data
We may retain Visitor and Participant Personal Data for as long as reasonably necessary in order to maintain and expand our relationship and to provide them with our Services.
Notwithstanding the aforementioned, we will also retain Personal Data for as long as is required 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.
We may retain Applicants Information submitted to us in connection with a job position, even after the applied position has been filled or closed so we can re-consider Applicants for other positions and opportunities and in case the Applicant is hired, for additional employment and business purposes related to his/her work. If you previously submitted your Applicants Information to Valence Security, and now wish to access it, update it or have it deleted, please contact us at: email@example.com.
We retain all other Personal Data for as long as it is reasonably necessary in order to maintain and expand our relationship and provide you with our Services and offerings; 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), all in accordance with our data retention policy.
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: firstname.lastname@example.org.
5. Data Sharing
Legal Compliance: Except as stipulated otherwise in the commercial agreements with you, 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 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, 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 (collectively, “Service Providers“). For a full list of third parties, please contact us at: email@example.com.
To the extent applicable, our Service Providers shall each be deemed as a ‘data processor’ or ‘service provider’ in circumstances where Valence Security assumes the role of ‘data controller’; and where Valence Security acts as the ‘data processor’ or ‘service provider’ for our customer, the Service Provider shall be deemed as our ‘sub-processor’ or ‘service provider’ (as further described in Section 10 below).
Accordingly, these Service Providers may have access to data concerning End Users, Visitors, Participants, Customers and/or prospects; Service Providers access to data shall depend on each of their specific roles and purposes in facilitating and enhancing our Services. Service Providers may only use the data for such limited purposes as determined in our agreements with them. In addition, Service Providers may only have access to End User and Customer Data if we have expressly listed them in our list of Sub-Processors .
Sharing Personal Data with End Users: End User and Customer Data is shared and available to certain users of the Services within the same Customer. This means that the End Users of a Customer may access the End User and Customer Data that was uploaded and/or used during the performance of the Services by the same Customer, and will be able to monitor, and possibly process and analyse the Personal Data contained therein.
Please note that Valence Security is not responsible for and does not control any disclosure, use or monitoring by or on behalf of the Customers, that itself acts as the ‘data controller’ of such data (as further described in Section 10 below).
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 End 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, service changes, log-in attempts or password reset notices, etc. Customer and its End Users may also send notifications, messages and other updates to End Users regarding their own use of the Services. Please note that you will not be able to opt-out of receiving certain service communications which are integral to your use (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 you will find valuable, as our customer, User, Participant or prospect, which may or may not be based on you chrematistics. We may provide such notices through any of the contact means available to us (e.g., phone, mobile or e-mail), through the Services, or through our marketing campaigns on any other sites or platforms.
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 “unsubscribe”, “stop”, “opt-out” or “change e-mail preferences” instructions contained in the promotional communications you receive.
8. Data Security
We and our hosting services implement 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.
However, although we make efforts to protect your privacy, we cannot guarantee that our Sites, Platform 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 visit 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, such as the right to request access to, and rectification or erasure of your Personal Data held with Valence Security, or to restrict or object to such Personal Data’s processing, 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.
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 customer’s behalf, please contact the administrator of such customer’s account directly. For example, if you are our customer’s End User or prospect, or if you are a Customer 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; and that we may also share the contact details of the account administrator with individuals who sent us such a request or query relating to this account.
10. Data Controller/Processor
Certain data protection laws and regulations, such as the 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 Personal Data, which we process on behalf of our Customer (who is the “data controller” of such data); and our Service Providers who process such End User and Customer Data on our behalf are the “sub-processors” of such data.
Accordingly, Valence Security processes End User and Customer Data strictly in accordance with such Customer’s reasonable instructions and commercial agreements with such Customer. The Customer, as controller of such data, will be responsible for meeting any legal requirements applicable to data controllers (such as establishing a legal basis for processing and responding to Data Subject Rights requests concerning the data they control).
For the avoidance of doubt, each Customer is solely responsible for providing adequate notice to its End Users, customers and any other individual whose data may be contained in the End 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; and to obtain all approvals and consents from such individuals as required under such laws.
11. Additional Notices
Our Services are not designed to attract children under the age of 18: We do not knowingly collect Personal Data from children and do not wish to do so. If we learn that a person under the age of 18 is using our Website, Platform and/or 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 child. If you believe that we might have any such data, please contact us by e-mail at: email@example.com.