Vulcan's Privacy Policy Last Revised: July 16, 2018Vulcan Cyber Ltd. (“Vulcan” or “we”) respects the privacy of its website users (“User” or “you”) and is committed to protect its Users’ personal information. We believe that you have a right to know our practices regarding the information we may collect and use about you when you use our primary website at https://vulcancyber.com/ (the “Site”). Please read the following carefully to understand Vulcan’s views and practices regarding your personal information and how Vulcan will treat it.

Table of Contents

  1. About this Privacy Policy
  2. Who we are
  3. Your acknowledgment of this policy
  4. Which information may we collect about Users?
  5. How do we collect information about our Users?
  6. What are the purposes of the collection and processing of information?
  7. Sharing Personal Information with Third Parties
  8. Your Rights
  9. Location of Your Data
  10. Minors
  11. Third Party Service Providers and Third Party Software
  12. Links to Third Party Websites
  13. Security
  14. Data Retention
  15.  Human Resources Data Privacy Policy  
  16. Changes to the  Privacy Policy
  17. Have any Questions?

About this Privacy Policy

This Privacy Policy applies when you visit our Site. It also applies where we are in contact with you in other ways whether in your capacity as an individual or as director, shareholder, partner, employee or other representative of a company or other organization.

Who we are

In this policy, references to Vulcan, or to "we" or "us" are to Vulcan Cyber Ltd., which is a registered company in the state of Israel (No. 515797876) at Yosef Caro 14 ,Tel-Aviv, Israel. Individuals wishing to contact us about data protection issues may do so by writing to us at the above address or by emailing us at privacy@vulcancyber.com.

Your acknowledgment of this policy

This Privacy Policy (“Privacy Policy”) details how your Personal Information collected via the Site is used and processed by Vulcan. BY ENTERING, CONNECTING TO, ACCESSING OR USING THE SITE, YOU ACKNOWLEDGE THAT YOU ARE OR HAVE HAD THE OPPORTUNITY TO BECOME AWARE OF AND AGREE (IN JURISDICTION WHERE SUCH CONSENT IS REQUIRED) TO THIS PRIVACY POLICY AND VULCAN’S PRACTICES DESCRIBED THEREIN, INCLUDING THE PROCESSING (INCLUDING COLLECTING, USING, DISCLOSING, RETAINING OR DISPOSING) OF YOUR INFORMATION UNDER THE TERMS OF THIS POLICY.

Which information may we collect about Users?

We collect from Users of our Site, two types of data and information:

    1. Non-personal Information. The first type is non-identifiable and anonymous information. Non-personal Information, which is being gathered, consists of technical information and behavioral information that does not pertain to a specific individual (“Non-Personal Information”).

      You may access and browse the Site without disclosing personal information, although, like most websites, we passively collect certain Non-Personal Information from your devices, including: (i) technical information such as the type and version of your device and its operating system, the type of browser, screen resolution, device browser and keyboard language, Wi-Fi connectivity and the type and name of your device and/or browser, etc; and (ii) behavioral information which may include the User’s click-stream on the Site, the activities of the User on the Site and additional information of a similar nature (collectively, “Technical and Behavioral Information”). We may also use third-party service providers such as Google Analytics and Hubspot to obtain detailed analytics on the device and the User's behavior on the Site.

      Please note that we or our third party service providers will collect such Technical and Behavioral Information by using certain technologies such as Cookies (as further detailed under our Cookie Policy. 

      2. Personal Information. \The other type of information we collect is individually identifiable information. To put it simply, this information identifies an individual or is of a private and/or sensitive nature, such as your contact information (“Personal Information"), including:

       

      Personal Information which is provided voluntarily:

        • Communications with Vulcan:  Personal Information you provide us as part of any communications with Vulcan, by any means, including by approaching our customer services or during sales calls (such information may include marketing and communication data that includes your preferences in receiving marketing from us and your communication preferences).

We may record such calls for quality assurance purposes and in order to improve our services.
        • Contact Details: when you enquire about Vulcan's services from the Site or download our e-book, we will ask you to provide us some or all of the following details: full name, e-mail address, job title and the phone number. You may also voluntarily join our mailing list by providing us with your email address.  
                    Personal Information collected via technology:
        • Geolocation data: while using the Site we will access, collect, process, monitor and/or remotely store "geolocation data", including through the collection of IP addresses and other similar information to determine your location for analytics and security purposes. Please note that we may also analyze your IP address, using our third party service providers, in order to determine the name of the company whose IP address you have used to browse our Site, for the purpose of locating prospects and in order to analyze our Site's traffic.
        • Technical and Behavioral Information: to the extent that the Technical and Behavioral Information detailed above under Section 3.1 will be linked to or associated with a specific individual then such information will be considered as Personal Information.
        • Identifiers: such as Internet Protocol (IP) address, your Unique Device Identifier (UDID), or another unique identifiers.
           
          Please note:
        • We may cross-reference Personal Information with other Personal Information we have about you and any Non-personal Information connected or linked to or associated with any Personal Information shall be deemed as Personal Information as long as such connection, linkage or association exists.
        • We use third-party tracking services and usage logs, to track and analyze data from Users of the Site and for purposes of security and fraud prevention. We may also use cookies to gather information regarding your use of the Site and the information for which you searched and accessed (for more information please refer to our Cookie Policy).

           

          How do we collect information about our Users?

There are two main methods we use to collect information:

    1. We collect information through your entry, connection, access and/or use of the Site. In other words, when you access or use the Site we are aware of your usage of the Site, and may gather, collect and record the information relating to such usage. For example, when you use the Site, we gather your Technical and Behavioral Information.

    2. We collect information which you provide us voluntarily. For example, we collect Personal Information that you provide via the Contact Form on our Site. We will inform you prior to collecting your Personal Information if it is requested on a voluntary basis and the consequences of not providing voluntary Personal Information.

    3. We collect information from public sources. We may supplement personal information that we collect about you with information which you have made public on websites associated with you or your company or on social media platforms such as LinkedIn.

      What are the purposes of the collection and processing of information?

      Non-personal Information is processed in order to:   

        • Enhance the User’s experience on the Site;
        • Create statistical information and learn about the preferences of Users and general trends on the Site (e.g. understand which features are more popular than others); and
        • Keep the Site safe and secured and for prevention of fraud.

           

          Personal Information is processed in order to:

        • Enable the operation of the Site and administer your Account;
        • To register your interest in becoming a new customer;
        • Contact you by telephone and/or by email with further information relating to our products or services which you enquired about via the Site. To ensure we offer a good and responsive service, we consider this use to be proportionate and will not be prejudicial or detrimental to you;
        • Add your contact details to our mailing list for the purposes of sending you information about our products and services by email, SMS, phone, through web-browser notification or through the post. You have the right to opt-out of marketing messages at any time by following the instructions in such message or by contacting us at: privacy@vulcancyber.com;
        • Enable our third-party advertising Service Providers (as detailed under Section 10 below) to show Vulcan's advertisements on websites across the Internet and across devices. You may opt-out such advertising activities by following the directions detailed in our Cookie Policy.  
        • Personalize your experience on the Site;
        • Ensure that content on the Site is presented in an optimal way for you and for your device (e.g. tablet, mobile phone);
        • Send you by email, SMS, phone, through web-browser notification or through the post updates, notices, announcements, and additional information related to Vulcan including with respect to changes made to our Site's terms of use and privacy policy;
        • Conduct internal operations, including troubleshooting, data analysis, testing, research and statistical purposes;
        • Keep the Site safe and secured and for prevention of fraud and crime;
        • Comply with our legal obligations and in order to be able to protect our rights and legitimate interests, including in order to improve the Site;
        • Maintain our data processing records and general administrative purposes;
        • Email tracking – we may use tracking technology within the email we may send you in order to improve interactions with you and to better understand whether our emails were opened and read, and such tracking may include capturing the time and date in which you opened our email messages and the type of device you use to open such emails.
Note to our Users in the EU:In order for Vulcan to process your Personal Information, as detailed herein, such processing must be justified by a "basis" for processing. Please note that the Personal Information processing activities detailed herein may be justified on the basis that:
  • the processing is based on your consent - where you provide us with your consent to contact you for marketing purposes or when we use cookies to collect information about your use of the Site, you will be asked to consent to such activities before we can process such information. If you choose not to give us your consent for such processing activities, or if you decide later to remove your consent, this may affect our ability to provide you with the services available on our Site;
  • the processing is necessary for performance of a contract or in order to take steps prior to entering into a contract - usually your Personal Information will be provided to us because you are interested in engaging with Vulcan for the purchase of our products and services. As such, we rely on this basis for processing activities that are required in order to enable you to use the Site and to let you know of changes to our Site's terms of use and privacy policy;
  • the processing is necessary to comply with a legal obligation - we may process your Personal Information for disclosure of information to authorities; and
  • the processing is in our legitimate commercial interests - subject to your interests and fundamental rights, under our legitimate interest in marketing our products and services via the Site and offering the public comfortable and safe access to our Site, we shall perform the Personal Information processing activities described herein, such as the processing of your Personal Information in order to personalize the Site, assisting us to prevent crime and fraud, manage our internal operations, maintaining records and email tracking. We may also use the information contained in certain cookies and other such files or tags based on such ground for our legitimate interests in a safe and user-friendly presentation of our Site. Where we rely on legitimate interests as a lawful basis, we will carry out a balancing test to ensure that your interests, rights and freedoms do not override our legitimate interests.
Note to non-EU Users:BY ENTERING, CONNECTING TO, ACCESSING OR USING THE SITE, YOU CONSENT TO THE COLLECTION AND PROCESSING OF YOUR PERSONAL INFORMATION AS SPECIFIED HEREIN.

Sharing Personal Information with Third Parties

Vulcan respects your privacy and will not disclose, share, rent, or sell your Personal Information to any third party, other than as permitted under this Privacy Policy.In addition to using the information collected by us for the purposes described under Section 6 above, we may also share your information in the following cases:

        • Vulcan Personnel: Personal Information that we collect and process may be transferred to or accessed by personnel of Vulcan for the sole purpose of enabling the operation of the Site and to contact you (as detailed in Section 6 above). Please note that all Vulcan personnel that will have access to your Personal Information are under an obligation of strict confidentiality with respect to such Personal Information.  
        • Service Providers: we share Personal Information with vendors, commercial software providers, consultants and data processers who perform services on our behalf, including without limitation, companies that provide analysis, messaging services and services which host the Site. Please note that we collect, hold and manage your Personal Information through a third party's cloud based services, as reasonable for business purposes, which may be located in countries outside of your jurisdiction. For more information regarding our Service Providers, please refer to Section 10 below.
        • In addition, we may share Personal Information in the following cases: (a) to satisfy any applicable law, regulation, legal process, subpoena or governmental request; (b) to enforce this Privacy Policy or any other agreement or terms of service between you and Vulcan, and to defend against any claims or demands asserted against us by you or on your behalf; (c) to detect, prevent, or otherwise address fraud, security or technical issues; (d) to protect the rights, property, or personal safety of Vulcan, its Users or the general public; and (e) when Vulcan is undergoing any change in control, including by means of merger, acquisition or purchase of all or substantially all of the assets of Vulcan (while such acquired company or investor may be located in countries outside of your jurisdiction).
        • For avoidance of doubt, Vulcan may transfer and disclose Non-Personal Information to third parties at its discretion including without limitation for statistical, analytical and research purposes and for customization, developing and improvement of our Site.

 Your Rights

Vulcan acknowledges you have the right to access and change the Personal Information we collect and process. If you wish to access or to correct, amend, or delete Personal Information, please send us an email to: privacy@vulcancyber.com and we will respond within a reasonable timeframe, but in any event no later than permitted by applicable law.

Note to our Users in the EU:We hereby inform you of the following rights (by virtue of EU law), in respect of your Personal Information:
  • Right to access: you may have the right to request a review of your Personal Information held by Vulcan. We may refuse to comply with your access request if the request is manifestly unfounded, excessive or repetitive in nature.
  • Right to rectification: if the Personal Information processed by Vulcan is incorrect, incomplete or not processed in compliance with applicable law or this Privacy Policy , you may have the right to have your Personal Information rectified.
  • Right to erasure: under certain conditions, you may be entitled to require that Vulcan will delete or "block" your Personal Information (e.g. if the continued processing of those data is not justified).
  • Right to Portability: you may have the right to transfer your Personal Information between data controllers (i.e. to transfer your Personal Information to another entity). The right to data portability only applies where your Personal Information is processed by us with your consent or for the performance of a contract and when processing is carried out by automated means.
  • Right to object to or withdraw consent: where that lawful basis for processing your Personal Information is either "public interest" or "legitimate interests", those lawful bases are not absolute, and you may have a right to object to such processing. Where you object on grounds of legitimate interest, we shall no longer process your personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims. If the processing of your Personal Information is based on your consent, you have the right to withdraw your consent to such processing at any time.
  • The right to restrict processing – under certain circumstances, you may have the right to object to the processing of your Personal Information due to your particular situation.
  • Right to lodge a complaint: you have the right to lodge a complaint before the relevant data protection authority or supervisory authority of your jurisdiction.
To exercise these rights, where applicable, please contact us by sending an email to: privacy@vulcancyber.com


Location of Your Data

The information collected from you by Vulcan, as detailed in this Privacy Policy, may be transferred to, and stored at, servers which may be located in countries outside of your jurisdiction and in a country that is not considered to offer an adequate level of protection under your local laws. It may also be processed by Vulcan and its suppliers, service providers or partners' staff operating outside your country. Vulcan is committed to protecting your Personal Information and will take appropriate steps to ensure that your Personal Information is processed and stored securely and in accordance with applicable privacy laws, as detailed in this Privacy Policy. Such steps include putting in place data transfer agreements or ensuring our third-party service providers comply with Vulcan's data transfer protection measures.

Note to our Users in the EU:If you are located in the EU, you have a right to request further information regarding the data transfer mechanisms used by us with respect to data transfers to third countries.In order to keep your Personal Information safe, we apply strict safeguards when transferring it outside of the EEA, which may include the following:
    • Transferring your personal information to countries approved by the European Commission as having adequate data protection laws, such as Israel;
    • Entering into standard contracts that have been approved by the European Commission and which provide an adequate level of high quality protection, with the recipients of your Personal Information;
  • Transferring your Personal Information to organizations that are Privacy Shield Scheme certified, as approved by the European Commission.

BY SUBMITTING YOUR PERSONAL INFORMATION THROUGH THE SITE, YOU ACKNOWLEDGE, AND AGREE, IN JURISDICTION WHERE SUCH CONSENT IS REQUIRED, TO SUCH TRANSFER, STORING AND/OR PROCESSING OF PERSONAL INFORMATION.

Minors

The Site is intended for Users over the age of sixteen (16). Therefore, Vulcan does not intend and does not knowingly collect directly Personal Information from children under the age of sixteen (16) and does not wish to do so. We reserve the right to request proof of age at any stage so that we can verify that minors under the age of sixteen (16) are not using the Site.

Third Party Service Providers and Third Party Software
    1. While using the Site we may be using third party service providers, who may collect, store and/or process your information, as detailed in this Privacy Policy.
    2. Note, that we collect, hold and/or manage your Personal Information through Vulcan's authorized third parties vendors of certain products or services (such as hosting cloud services) (including, as applicable, their affiliates) solely and limited to providing us with such requested services, and not for any other purposes.
    3. Such vendors may be located in a country that does not have the same data protection laws as your jurisdiction.
    4. Such third parties service providers include without limitation the following categories of service providers:

Please read such third party service providers' terms of use and privacy policies to understand their privacy practices.

Links to Third Party Websites

Certain links provided in the Site permit Users to leave our Site and enter non-Vulcan sites or services. Most of such linked sites and services provide legal documents, including terms of use and Privacy Policy governing the use thereof. It is always advisable to read such documents carefully before using those sites and services, inter alia, in order to know what kind of information about you is being collected.

Security

We take appropriate measures to maintain the security and integrity of our Site and prevent unauthorized access to it or use thereof through generally accepted industry standard technologies and internal procedures.
Your Personal Information is hosted on AWS and Hubspot servers, which provide advanced strict security standards (both physical and logical).
Some of the security measures that we employ include, without limitation: highly secure services design and implementation using state of the art encryption and architectures mechanisms, restriction of access to your Personal Information to individuals who need access to it in order to process it on Vulcan’s behalf and implementation of a secured permission management and auditing system using specific and proprietary firewall and network access filtering as well as security group mechanisms.
Please note, however, that there are inherent risks in transmission of information over the Internet or other methods of electronic storage and we cannot guarantee that unauthorized access or use will never occur.
Vulcan will comply with applicable law in the event of any breach of the security, confidentiality, or integrity of your Personal Information and will inform you of such breach if required by applicable law.
TO THE EXTENT THAT VULCAN IMPLEMENTED THE REQUIRED SECURITY MEASURES UNDER APPLICABLE LAW, VULCAN SHALL NOT BE RESPONSIBLE OR LIABLE FOR UNAUTHORIZED ACCESS, HACKING, OR OTHER SECURITY INTRUSIONS OR FAILURE TO STORE OR THE THEFT, DELETION, CORRUPTION, DESTRUCTION, DAMAGE, OR LOSS OF ANY DATA OR INFORMATION INCLUDED IN THE PERSONAL INFORMATION. 

 

Data Retention


Vulcan will retain the Personal Information for as long as we are comfortable that it is accurate and can be relied upon. Personal Information which is no longer required for the purpose for which is was initially collected will be deleted unless we have a valid justification to retain it which is permitted under applicable law, such as to resolve disputes or comply with our legal obligations.

 

Human Resources Data Privacy Policy

Purpose and Scope 

  • This Human Resources Data Privacy Policy defines the baseline set of common principles within the company.
  • This policy applies to all personal data about past, present and prospective employees, including candidates applying for a role, temporary and permanent employees, contractors, consultants and trainees that is collected, maintained or used by directors, officers, managers and employees as part of an actual or prospective employment relationship.
  • This policy requires managers and employees entrusted with the personal data as part of their job responsibility to treat it as confidential and in conformity with this Policy. 

Background 

  • This policy ensures that any third-party service providers we use to administer our Human Resources are bound to maintain confidentiality when handling your personal data on our behalf, in a manner that is consistent with this policy.
  • The company will endeavor to collect only the minimum amount of personal data required to administer and to comply with applicable employment and other relevant laws. 

Policy 

  •  The company will endeavor to collect only the minimum amount of personal data required to administer and to comply with applicable employment and other relevant laws. 
  • The company allow to delete personal data in certain circumstances. 
  • The company will delete any un necessary personal data when the employee end his employment at the company. 
  • The employees have the right to access their personal data at any time. 
  • The employee must follow appropriate security policies and procedures, completing assigned training, and reporting suspected incidents to relevant incident response contacts promptly. 
  • The personal data may be used for the following employment-related purposes: 
    • Contact employee-manage relationship, oversee compliance with policies and applicable law, assess performance, for promotions and appraisals and for training purposes. 
    • Store emails and documents on systems that we administer and make available for employment related purposes, which may contain personal data. 
    • Manage benefits, including administering remuneration, relocation, insurance, payroll, pensions and other employee benefits and tax, including disclosure to other Group companies and to others such as payroll providers, accountants, occupational health providers, insurers, pensions administrators, hosting service providers and legal advisers. 
    • Manage recruitment of employees, including legal eligibility for work, vetting, hires, promotion. 
    • Comply with policies, including in relation to claims, disciplinary actions or legal requirements and conducting investigations and incident response, including reviewing your communications in these situations in accordance with relevant internal policies and applicable law. 
    • Security purposes, for providing IT support and for employee authentication.
    • To manage occupational health and absence and fitness for work and notifying family members in emergencies.
  • The personal data will only be shared outside the company with third parties under the following circumstances:
    • where a third-party service provider retained by us is under contract to assist in administering our Human Resources activities, subject to appropriate confidentiality obligations and data processing agreements, compatible with this Policy. 
    • If the event that the company, business or division in which you are employed is being considered for outsourcing or sale, and then only subject to contractual requirements to preserve confidentiality. 
    • With private or government authorities only when we have determined that we are required to do so under applicable laws. 
    • Vulcan will disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. 
    • To investigate suspected fraud or illegality, to anticipate or defend legal claims; or to conclude a change of control of your company, business or division. 
  • Third parties which the company share employees personal information: 
    • Nextage – provide accounting services (Salaries and reimbursement for employees) 
  • Vulcan liability in cases of onward transfers to third parties: 
    • Vulcan use a contract with third-party vendor that provides that such data may only be processed for limited and specified purposes consistent with the consent provided by the individual and that the recipient will provide the same level of protection as the Principles and will notify the organization if it makes a determination that it can no longer meet this obligation.  The contract shall provide that when such a determination is made the third party vendor ceases processing or takes other reasonable and appropriate steps to remediate. 
  • Vulcan complies with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States.  (Your organization name) has certified to the Department of Commerce that it adheres to the Privacy Shield Principles.  If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.  To learn more about the Privacy Shield program, and to view our certification, please visit:  https://www.privacyshield.gov/ 
  • In compliance with the Privacy Shield Principles, Vulcan commits to resolve complaints about our collection or use of your personal information.  EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Vulcan at: Contact@vulcan.io 
  • Vulcan has further committed to cooperate with the panel established by the EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved Privacy Shield complaints concerning human resources data transferred from the EU and Switzerland in the context of the employment relationship. 
  • Vulcan is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC) 

Changes to the Privacy Policy

The Company reserves the right to change this Privacy Policy at any time, so please re-visit this page frequently to check for any changes. In case of any material change, we will make reasonable efforts to post a clear notice on the Site or we will send you an e-mail regarding such changes to the e-mail address that you may have provided us with. Such material changes will take effect seven (7) days after such notice was provided on our Site or sent to you via e-mail, whichever is the earlier. Otherwise, all other changes to this Privacy Policy are effective as of the stated “Last Revised” and your continued use of the Site on or after the Last Revised date will constitute acceptance of, and agreement to be bound by, those changes. In the event that the Terms should be amended to comply with any legal requirements, the amendments may take effect immediately, or as required by the law and without any prior notice.

Have any Questions?

If you have any questions (or comments) concerning this Privacy Policy, please send us an email to the following address: privacy@vulcancyber.com and we will make an effort to reply within a reasonable timeframe.
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