Effective Date: December 15, 2017
1. Information We Collect
When you use the website and the Services, NowSecure collects certain information that can be used to contact or identify you including, but not limited to, your email address, name, phone number, postal address, or other information (“Personal Information”). We also collect technical or non-personal information, which independent of your Personal Information cannot identify you.
Personal Information includes:
- Contact information: When you submit a form to download resources, request information, attend a webinar, respond to a survey, apply to a job opening, or otherwise contact us electronically.
- Account information: You may register to create an account and provide Personal Information in order to be able to save your profile and the data associated with it.
- Identity Provider Information: If you authenticate on the Services using an identity provider such as GitHub or Google (the “Identity Provider”), the Identity Provider may send us your registration or profile information on that service and other information that you authorize. This information enables us to authenticate you and improve the Services.
Other information includes:
- Log and Analytics Data: We may also collect information that your browser sends whenever you visit our Services (“Log Data”). This Log Data may include information such as your computer’s Internet Protocol (“IP”) address, approximate location, browser type, browser version, the pages of our Services that you visit, the time and date of your visit, the time spent on those pages and other statistics.
2. How We Use this Information
We collect Personal Information and other information for these purposes:
- To deliver, monitor and enhance the Services
- To identify and communicate with you, respond to your requests/inquiries, provide customer service and fulfill orders
- To process payments where applicable
- To control unauthorized use or abuse of the Services, and detect, investigate or prevent activities that may violate our policies or be illegal
- To analyze trends, administer or optimize the Services, monitor usage or traffic patterns (including to track users’ movements around the Services) and gather demographic information about our user base
- To market our Services to you, including by sending you newsletters, promotions and special offers or information about new products and services. Your opt-out options for promotional communications are described in Section X: Your Controls and Choices
- To deliver advertising, including by managing ads on third party sites and to tailor ads based on your interests and browsing history.
We use first party and third party cookies to collect information in order to deliver and monitor the Services. Cookies are files with a small amount of data, which may include anonymous unique identifiers, and which are sent to your browser from a web site and stored on your device. Some cookies are required for technical reasons in order for our website and Services to operate, while other cookies also enable us to track and target the interests of our users to enhance their experience. Third parties serve cookies through our website and Services for analytics and other purposes as described herein.
You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. The Help feature on most browsers provide information on how to accept cookies, disable cookies or to notify you when receiving a new cookie. If you do not accept cookies, you may not be able to use many features of our Services.
4. Sharing Your Information with Third Parties
We do not sell, trade, share or transfer your personal information to third parties except in the following limited circumstances:
- With our parent companies, subsidiaries and affiliates;
- With legal authorities or our legal advisors when we have a good faith belief that it is reasonably necessary to (a) satisfy any applicable law, regulation, legal process or enforceable governmental request, including as required by the Privacy Shield principles; (b) enforce contractual obligations, including investigation of potential violations thereof, or (c) protect against imminent harm to our rights, property or safety, or that of our users or the public as required or permitted by law;
- With business partners who offer a service to you jointly with us, for example when running a cross-promotion.
- In connection with a merger, acquisition, or any form of sale of some or all of our assets; and
- With a third party if we have your consent to do so.
We may also share aggregated or anonymized information with third parties for other purposes. Such information does not identify you individually, but may include usage, viewing and technical information including coarse geolocation, device configurations, and performance metrics related to the use of the Services which we collected through our technology. If we are required under applicable law to treat such information as personal information, then we will only disclose it as described above. Otherwise we may disclose such information for any reason.
5. Service Providers
- Twitter (Twitter Inc.): Opt-out instructions: https://support.twitter.com/articles/20170405 and Privacy practices and policies of Twitter: https://twitter.com/privacy
6. Privacy Shield Framework
NowSecure complies with the U.S. – E.U. and U.S. – Swiss Privacy Shield Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the E.U. or Switzerland to the United States. The Federal Trade Commission (FTC) has jurisdiction over NowSecure’s compliance with the Privacy Shield. To learn more about the Privacy Shield program please visit https://www.privacyshield.gov.
If you have a dispute with us about our adherence to the Privacy Shield Principles, we will seek to resolve it through our internal complaint resolution process, or if necessary through an independent dispute resolution body. NowSecure has selected JAMS as our designated independent arbitrator, which can be contacted here: https://www.jamsadr.com/eu-us-privacy-shield. In certain circumstances, the Privacy Shield Framework provides the right to invoke binding arbitration to resolve complaints not resolved by other means, as described in Annex I to the Privacy Shield Principles.
All NowSecure employees or contractors who handle personal information from Europe and Switzerland are required to comply with this Statement.
7. Your Controls and Choices
Promotional Email: We may use your Personal Information to contact you with newsletters, marketing and promotional materials and other information that may be of interest to you. If you no longer wish to receive our newsletter and promotional communications, you may opt-out of receiving them by following the instructions included on such communications or in the Services. (Please note that you may be unable to opt-out of certain service-related communications while you have an active account.)
Blocking Cookies: You can view and receive notifications on cookie activity, and remove or block certain cookies, using the settings in your browser. Be advised that the Services may cease to function properly if you block cookies.
Do Not Track: Do Not Track is a preference you can set in your web browser. Our Services do not change behavior based on a web browser’s Do Not Track signal.
Access Your Data: Individuals may request information on which personal information we have collected by emailing [email protected]. Please allow up to 21 days processing time to respond to your request. Identity verification may be required before we furnish actual personal information.
The security of your Personal Information is important to us, and we strive to implement and maintain reasonable, commercially acceptable security procedures and practices appropriate to the nature of the information we store, in order to protect it from unauthorized access, destruction, use, modification, or disclosure. Be advised that no system of transmission over the internet, or method of electronic storage is perfectly secure, and we are unable to guarantee the absolute security of the Personal Information we have collected from you.
9. International Transfer
Your information, including Personal Information, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.
If you are located outside United States and choose to provide information to us, be advised that we transfer the information, including Personal Information, to the United States and process it there.
10. Children’s Privacy
Our services are not intended for use by anyone under the age of 13 (“Child” or “Children”). We do not knowingly collect personally identifiable information from Children. If you are a parent or guardian and you learn that your Child has provided us with Personal Information, please contact us. If we become aware that we have collected Personal Information from a Child without verification of parental consent, we take steps to remove that information from our servers.
We may change this policy by posting a new version of this policy on this Website. When we do change the policy, we will also revise the “Last updated” date at the top of this page and may notify you of any material changes or post a message on the Website. Your continued use of this Website and the Services following such changes constitutes your acceptance of the revised policy. .
12. Contact Us
ATTN: NowSecure Privacy Officer
1046 Lake Street
Oak Park , IL 60301
2017-12-15 — Updated to revise structure, include new Privacy Shield information (replacing Safe Harbor) and remove references to Sensors.
2014-12-02 — Company name change, added usage and mobile intelligence data info
2014-08-20 — Clarifications, added disclaimer
2014-04-30 — Clarifications and simplified wording