Last Updated: 27 June, 2018

1. General

Access Layers Ltd., (dba Portnox) and its subsidiaries (“Portnox”, “we” or “us”) is committed to protecting the privacy of our website visitors and customers. This Privacy Policy (“Privacy Policy”) describes the information that we collect, how we obtain the information, and how we may use or disclose that information. It also describes the different ways in which we collect, use and share information related to you and the measures we take to protect the security of the information and how individuals can contact us about our privacy practices. Please read this Privacy Policy carefully.

2. The Information that you Provide us

When you use or interested in our products and services (including without limitation any support or other professional services) at our website – https://www.portnox.com (the “Website”) – or otherwise request related information about us (collectively the “Services”) we will collect the personal information you voluntarily provide us. The personal information we collect may include contact information such as your name, email address, telephone number, address, contact preferences, job title, nature of your communication and additional personal information. In addition, our customers may also voluntarily provide us (or third parties on our behalf) billing and transactional information. Please note that you have no legal obligation to provide us with any personal information and the submission of such information is entirely subject to your sole discretion and consent. However, if you will not provide us with the required personal information we may not be able to provide you with the information/services requested by you.

3. Information we Automatically Collect

When you are visiting our Website, we or our Service Providers (as defined below) may automatically collect certain information, such as your internet protocol (IP) addresses, Internet service provider, domain server, type of computer, browser type and language, referring and exit pages and URLs and amount of time spent on particular pages. Please note that we have no legal power to enforce internet service providers that allocated your internet protocol (IP) addresses which are used in your access to the Website, to provide us your identifying details. The above-mentioned collected information does not necessarily reveal your identity directly but under some jurisdictions applicable data protection laws, this information may be considered as personal information.

In addition, Portnox has engaged third party service providers to (i) track and analyze both usage and volume statistical information from your interactions with us; (ii) improve you user experience on our Website; and (iii) deliver more targeted online advertising and marketing campaigns, in accordance with the applicable law (collectively the “Service Providers”). For the aforesaid purposes, we and our Service Providers, automatically collect information regarding your use of the Website, including by using session identifiers, cookies, JavaScript tags, and other technologies, including such which are placed on your computer when you visit our Website.

4. Use of the Information 

Portnox uses the information that you voluntarily provide us (as set forth under Section 2 above) to (i) engage in transactions with you; (ii) process transactions by using payment, credit card and other billing information, provided by you; (iii) provide you Services you have ordered (iv) send administrative or Services-related information to you (“Service Announcements”); (v) answer you inquiries and provide you information regarding the Services; (vi) provide a personalized experience and implement preferences you request; (vii) offer you additional Services which may interest you; (viii) provide you with marketing and promotional communications (in accordance with the applicable law); (ix) develop and offer additional features, functionality and services.

Portnox and its Service Providers (on Portnox’s behalf) use the information that is automatically collected (as set forth under Section 3 above) to: (i) improve you user experience on our Website and our Services and to provide a personalized experience, and implement the preferences you request.; (ii) offer you additional Services which may interest you and (iii) to provide you with marketing and promotional communications (in accordance with the applicable law) and to determine the effectiveness of our (directly or via our Service Providers) marketing and promotional campaigns (iv) to analyze the usage and performance of our Website and Services.

In addition, we may use your information to enforce our terms, policies and legal agreements, to comply with court orders and warrants, and assist law enforcement agencies, to collect debts, prevent fraud, misappropriation, infringements, identity thefts and any other misuse of the Service, and to take any action in any legal dispute and proceeding.

5. Information we Process on Behalf of our Customers

In the course of using our Services, our customers may submit or upload information to our Services. This customer content is processed by us on behalf of the customer, and our privacy practices regarding such information will be governed by the agreement that we have in place with our customers. This Privacy Policy will not apply to any personal information contained in such customer content.

In accordance with such terms, we will process such customer content for the purposes of providing the relevant Services to the applicable customer and in accordance with our customer’s instructions. If you have any questions or concerns about how such information is handled, you should contact the customer who has contracted us to use our Service or to host or process such information. We will provide reasonable assistance to our customers to address any concerns you may have reading the above.

6. Sharing Your Personal Information 

We may share personal information about you with the following third parties in the following circumstances; (i) with the Service Providers and other third parties who have a legitimate purpose for accessing it; (ii) with our subsidiaries or parent company; (iii) with other person or entity, as part of, our reorganization, merger, sell of all or substantially all of our business or other corporate change, including, during the course of any due diligence process with respect to the aforesaid (iv) if required by law in order to prevent, investigate, or take action regarding illegal activities or in response to legal process, court orders, subpoenas, or to establish or exercise our legal rights or defend against legal claims; all provided that the receiving entity will undertake to comply with this policy. In addition, we may disclose your personal information for any purpose with your consent.

7. Security 

We follow generally accepted industry standards to protect the personal information from loss, misuse, and unauthorized access, disclosure, theft or destruction. However, due to the nature of internet communications and evolving technologies, unauthorized entry or use, hardware or software failure, and other factors, we cannot guarantee the absolute security of the personal information or that the personal information will be immune from any wrongdoings, malfunctions, unlawful interceptions or access.

8. Privacy Rights

If we process  personal information related to you when you are in the EU, we will take reasonable efforts in supporting your following privacy rights (i) the right to know what personal information we hold about you, where we process it and the right to access such information; (ii) the right to have any inaccurate personal information we hold about you rectified and the right to have any incomplete details completed; (iii) the right to have your personal details erased; We will review your request and use our judgment, pursuant to the provisions of the applicable law, to reach a decision about your request. Such right shall apply only in certain circumstances, such as that your personal information is no longer necessary in relation to the purposes for which we collected it or you withdraw consent for us to process it; (iv) the right to object or to restrict the processing of your personal information if you contest its accuracy, it was processed unlawfully or we no longer need the personal information for the purposes of our processing. Where processing has been restricted on this basis, we may continue to store your personal information; (v) the right to withdraw your consent to the processing of your personal information. Such right will not affect the lawfulness of processing based on consent before its withdrawal; (vi) the right to receive your personal information from us in an accessible and readable format; (vii) the right to object to the processing of your personal information for direct marketing purposes; (viii) the right to file a complaint with an information protection supervisory authority.

If you would like to exercise any of the above rights, please contact privacy@portnox.com so that we may consider your request in good faith, in accordance with the applicable law. We will make commercial reasonable efforts to address any of your concerns.

Please note that in the event that as part of our Services we process personal information on behalf of our customers (as specified under section 5 above) you should seek to exercise your rights above by direct your query to our customers which are the data controllers, with respect to such personal information.

9. Opt Out

As set forth above, we (or our Service Providers) may collect information in connection with interest-based advertising and marketing, by using cookies and different identifiers. If your browser accepts cookies, you can opt out by amending your web browser controls refuse cookies. When you will opt out from such cookies, your browser, will prevent us (and our Service Providers) from creating specific segments based on information collected from that browser.

In addition, you are entitled to unsubscribe from our Service Announcements (as defined above), by contacting us here. Please note that if you unsubscribe from such Service Announcements (as defined above), you hereby agree to take full responsibility of all consequences, directly or indirectly, arising out of not being informed about the content of the Service Announcements in a timely manner.

10. Transfer of Personal Information out of European Economic Area

Please note that personal information may be transferred, accessed and stored globally as necessary for the uses and disclosures stated above in accordance with this Privacy Policy. By providing your personal information you consent to transferring your personal information to our affiliates and Service Provider outside of the European Economic Area (“EEA”).

We have implemented appropriate safeguards for transfers of personal information originating from the EEA to other countries.

11. Access or Modification of Personal Information 

You may request to review or modify any of your personal information that you have previously provided to us or which we collected. If you have privacy concerns regarding access to or modification of your personal information, please contact us at privacy@portnox.com.

12. Retention

We will retain personal information we collect from you during the periods in which we have a legitimate business need purposes to retain such information. The specific period of retention may vary with respect to each applicable collected information. As set forth above, you can request the deletion of your personal information. When reviewing your request, we will consider our obligations in accordance with the applicable law, as well as our legitimate business need to retain such information.

13. Links to Third Party’s Websites

The Website may contain links to third-party websites. Portnox has no control over the privacy practices or the content of these websites. As such, we are not responsible for the content or the privacy policies of those third-party websites. You should check the applicable third-party privacy policy and terms of use when visiting any other website.

14. Children’s Personal Information

We do not knowingly collect personal information from children under the age of 13. If you are under 13, please do not give us any personal information. We encourage parents and legal guardians to monitor their children’s internet usage and to help enforce our Privacy Policy by instructing their children never to provide personal information through the Website without their permission. If a parent or guardian becomes aware that his or her child has provided us with personal information without his/her consent, he or she should contact us at privacy@portnox.com. If we become aware that a child under the age of 13 has provided us with personal information, we will delete such information from our files.

15. California Privacy Rights

Under California Civil Code sections 1798.83- 1798.84, California residents are entitled to ask us for a notice identifying the categories of personal information which we share with third parties for marketing purposes and providing contact information for such third parties. If you are a California resident and would like a copy of this notice, please contact us at privacy@portnox.com.

16. Changes to this Privacy Policy

We reserve the right to change or modify this Privacy Policy at any time. In such event, we will let you know of such changes or modifications by posting notice on our Website or on our Services, and such changes will enter into effect following the lapse of 30 days of the date of their post on our Website or on our Services, provided however that if we need to adapt the policy to legal requirements, the new policy will become effective immediately or as required by the applicable legal requirements. You shall be entitled to decide if you want to continue to use the Website and/or Services under the revised Privacy Policy. However please note, that your continued use of the Services will indicate Your acceptance of any revised Privacy Policy. If You will not agree to the revised Privacy Policy, please refrain from using any the Site and/or the Services.

17. How to Contact Us

If you have questions about this Privacy Policy, or you wish and request to access information that we keep about you, please contact us via e-mail at privacy@portnox.com.