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PRIVACY NOTICE

ABNORMAL SECURITY CORPORATION PRIVACY NOTICE

LAST UPDATED MAY 10, 2024

This Privacy Notice explains how Abnormal Security Corporation (“Abnormal,”
“we,” or “us”) collects, uses, shares, and otherwise processes your personal
information (also known as personal data) in connection with: (i) the use of the
Abnormal websites and applications that link to this Privacy Notice (the
“Sites”), (ii) in the usual course of business, such as in connection with our
events, sales, and marketing activities (“Corporate Operations”), as well as our
products and services (the “Service”) It also contains information about your
choices and privacy rights. This Privacy Notice does not apply to personal
information that we collect in connection with our recruitment activities, which
is covered under our Applicant Privacy Policy. We recommend that you read this
Privacy Notice in full to ensure that you are informed.


SITES & CORPORATE OPERATIONS

Information We Collect About You Information that we collect from or about you
includes information you provide, information we collect automatically, and
information we receive from other sources. The “Service” section below
separately covers and applies to personal information submitted by our Customers
to our Service or collected through our Service on behalf of or at the direction
of our Customers.
Information You Provide To Us When you contact us by e-mail or through a contact
form on the Sites, we may collect information, such as your name, email address,
phone number, postal address, job title, and company name. We may also collect
other information that you provide such as your interactions with us, for
example, if you request information about our Service, interact with our
employees, complete a survey, provide feedback or post comments, register for an
event, or take part in marketing activities. We may keep a record of your
communications with us and other information you share during such
communications. If credit card is the method of payment chosen by you, credit
card information will be provided to our third party service providers,
including for payment and billing purposes, instead of us.
Information We Collect Automatically We collect the following information
automatically through our Corporate Operations:
Date and time of the requestTime zone difference to Greenwich Mean Time
(GMT)Access status / HTTP status codeEach transmitted amount of dataWebsite from
which the request comesBrowser typeOperating system and its interfaceLanguage
and version of the browser softwareInformation about your computer or
deviceInformation about your activities within the Sites or Corporate
OperationsCity-level geolocation information (in anonymous form)Other
statistical information relating to your use of the Sites and Corporate
Operations

Cookies and Online Identifiers In addition to the information listed above, we
use standard automated data collection tools like cookies (or online
identifiers) to collect information about how people use our Sites. When
visiting the Sites, you have the option of disabling certain types of cookies
through the Osano Cookie Consent pop-up. Cookies are small pieces of data,
stored in text files, that are stored on your computer or other device when
websites are loaded in a browser. They are widely used to “remember” you and
your preferences, either for a single visit (through a “session cookie”) or for
multiple repeat visits (using a “persistent cookie”). They provide a consistent
and efficient experience for visitors and perform essential functions such as
allowing users to register and remain logged in. Cookies may be set by the
website you are visiting (known as “first party cookies”), or by third parties,
for such purposes as serving content or providing advertising or analytics
services on the website (“third party cookies”). Both websites and HTML emails
may also contain other tracking technologies such as “web beacons” or “pixels.”
These are typically small transparent images that provide us with statistics for
similar purposes as cookies. They are often used in conjunction with cookies,
though they are not stored on your computer in the same way. As a result, if you
disable cookies, web beacons may still load, but their functionality will be
restricted. We use cookies primarily to determine how visitors engage with the
Sites (e.g., the page you view, the links you click, how frequently you access
the Sites, the number of visits over time, etc.). For example, we may place a
pixel in our email that notifies us when you click on a link in the email. We
use these technologies to improve our communications. We may also use the
information we collect automatically (for example, IP address, and unique device
identifiers) to identify the same unique person across our Corporate Operations
to provide a more seamless and personalized experience to you.
Information We Receive From Other Sources We may obtain information about you
from third party sources, including resellers, distributors, business partners,
event sponsors, security and fraud detection services, social media platforms,
and publicly available sources. We encourage you to read the terms of use and
privacy notices of such third party services before sharing your information
with them to understand how your information may be collected and used. Examples
of information that we receive from third parties include marketing and sales
information (such as name, email address, phone number, postal address, job
title, company name, and similar contact information), training information
(such as courses taken, certificates, etc.), and purchase, support, and other
information about your interactions with our Sites, Corporate Operations, and
Service. We may combine such information you provide to third parties with the
information we receive from other sources.
How We Use Your Information We use your personal information to provide,
maintain, improve, and update our Sites for our Corporate Operations. Our
purposes for the collection of your personal information include:
 * To provide, maintain, deliver, and update our Corporate Operations
 * To send you notifications about the Service, including technical notices,
   updates, security alerts, administrative messages, and invoices
 * For billing, payment, or account management
 * To measure your use and improve Corporate Operations, and to develop new
   products and services
 * To personalize your experience when using our Sites
 * To generate and analyze statistical information about how our Sites are used
   in the aggregate
 * To respond to your questions, comments, and requests, including to keep in
   contact with you regarding the products and services you use
 * To provide you with customer service and support
 * To respond to your responsible disclosure reports
 * For sales phone calls for training and coaching purposes, quality assurance,
   and administration (in accordance with applicable laws), including to analyze
   sales calls using analytics tools to gain better insights into our
   interactions with customers
 * To tailor and send you newsletters, emails, and other content to promote our
   products and services (you can always unsubscribe from our marketing emails
   by following the instructions in the email) and to allow third party partners
   (like our event sponsors) to send you marketing communications about their
   services, in accordance with your preferences
 * For advertising purposes; for example, to display and measure advertising on
   third party websites
 * To contact you to conduct surveys and for market research purposes
 * To register and provide you with training and certification programs
 * To investigate security issues, prevent fraud, or combat the illegal,
   prohibited, or unauthorized uses of our products and services
 * To send you notifications about the Service, including technical notices,
   updates, security alerts, administrative messages, and invoices
 * For other legitimate interests or lawful business purposes; for example,
   customer surveys, collecting feedback, and conducting audits
 * To comply with our obligations under applicable law, legal process, or
   government regulation
 * For other purposes, where you have given consent

How We Share Your Information We may share your personal information with third
parties as follows:
 * With our affiliates and subsidiaries for the purposes described in this
   Privacy Notice
 * In connection with a merger, sale, financing, or reorganization of all or
   part of our business
 * With our service providers who assist us in providing the Service, such as
   billing, payment card processing, customer support, sales and marketing, and
   data analysis, subject to confidentiality obligations and the requirement
   that those service providers do not sell your personal information
 * With our service providers who assist us with detecting and preventing fraud,
   security threats, or other prohibited, illegal or malicious behavior
 * With business partners, such as resellers, distributors, and/or referral
   partners, who are involved in providing content, products, or services to our
   prospects or customers
 * With event partners who are working with us to organize or sponsor an event
   to which you have registered to enable them to contact you about the event or
   their services
 * With marketing partners, such as advertising providers that tailor online ads
   to your interests based on information they collect about your online
   activity (known as interest-based advertising)
 * Where it has been de-identified, including through aggregation or
   anonymization
 * When you instruct us to do so
 * Where you have consented to the sharing of your information with third
   parties
 * When necessary to protect the personal safety, property, or other rights of
   the public, Abnormal, or our customers
 * When required to protect and defend the rights or property of Abnormal or our
   customers, including the security of our Sites, products, and services
   (including the Service)
 * When authorized by law or where necessary to comply with a legal process.


SERVICE

We provide the Service to our customers and users (collectively, “Customers”)
under an Agreement with them and solely for their benefit and the benefit of
personnel authorized to use the Service. Abnormal processes personal information
only as provided in our agreements with the relevant Customer, such as our Cloud
Terms of Service. Abnormal also includes for our Customers a Data Processing
Addendum (DPA), accompanying our Cloud Terms of Service, which contains the
Standard Contractual Clauses, for transfers between us and our Customers
(collectively, “Customer Agreements”). Additional information about our privacy
and security practices for the Service is available in our Security Hub and the
Information Security Policy. Customers may choose to enable integrations or
exchange personal data from the Service with third-party platforms. Your use of
third-party platforms and how such providers use personal data is governed by
the terms of use and privacy notices of such third party platforms.
Notice to Users Our Service is intended to be used by Customers. Where the
Service is made available to you through a Customer (e.g., your employer), the
Customer is the administrator of the Service and responsible for the accounts
and/or services over which it has control. For example, administrators can
access and change information in your account or restrict and terminate your
access to the Service. We are not responsible for the privacy or security
practices of a Customer, which may be different from this Privacy Notice. Please
contact the applicable Customer or refer to your organization’s policies for
more information. Information We Collect About You To use the Service, an user
typically authenticates by means of a Customer’s single-sign-on (SSO) provider,
so we do not collect or process any personally identifiable login credentials,
however, we do collect the IP address from which the user logs into the Service
each time. In addition, as part of its normal functioning, the Service collects
personal information contained in message content and file attachments, user
information including user names, roles, email, group assignments, and
configurations; and personal data contained within activity logs, audit logs,
and administrator reports (“Service Information”) Information We Collect
Automatically When you use our Service, we automatically collect information
about how you are using the Service
 * Information about your account (such as user ID, email address, or Internet
   Protocol (IP) address)
 * Information about your computer or device (such as browser type and operating
   system)
 * Information about your activities within the Service, such as the pages or
   features you access or use, the time spent on those pages or features, search
   terms entered, commands executed
 * Information about the types and sizes of files analyzed via the Service
 * Other statistical information relating to your use of the Service

How We Use Your Information Our purposes for the collection of your personal
information include:
 * To implement, provide, maintain, improve, and update the Service

 * To understand how our Authorized Users and Customers are using the Service

 * To develop new features, products and services

 * To create and maintain your Service portal account

 * To send notifications within the Service
 * To provide you with customer service and support
 * For billing, payment, or account management; for example, to identify your
   account and correctly identify your usage of our products and services
 * To respond to your responsible disclosure reports
 * To measure your use and improve the Service, and to develop new products and
   services
 * To generate and analyze statistical information about how the Service is used
   in the aggregate
 * For other legitimate interests or lawful business purposes; for example,
   customer surveys, collecting feedback, and conducting audits
 * To comply with our obligations under applicable law, legal process, or
   government regulation
 * For other purposes, where you have given consent.


INFORMATION ABOUT THE SITES, CORPORATE OPERATIONS, AND THE SERVICE

In the event of any conflict or inconsistency between the Privacy Notice and the
Customer Agreements, the Customer Agreements will control. International
Transfers Abnormal may transfer your personal information to countries other
than your country of residence. In particular, we may transfer your personal
information to the United States and other countries where our affiliates,
business partners, and service providers are located. These countries may not
have equivalent data protection laws to the country where you reside. Wherever
we process your personal information, we take appropriate steps to ensure it is
protected in accordance with this Privacy Notice and applicable data protection
laws. These safeguards include implementing the European Commission’s Standard
Contractual Clauses for transfers of personal information from the European
Economic Area or Switzerland between us and our business partners and service
providers, and equivalent measures for transfers of personal information from
the United Kingdom. Data Privacy Framework Notice Abnormal complies with the
EU-U.S. Data Privacy Framework (“EU-U.S. DPF”), the UK Extension to the EU-U.S.
DPF (“UK Extension”), and the Swiss-U.S. Data Privacy Framework (“Swiss-U.S.
DPF”) (EU-U.S. DPF, UK Extension, and the Swiss-U.S. DPF, collectively, the
“DPF” or “Data Protection Framework”) as set forth by the U.S. Department of
Commerce regarding the processing of personal data received from the European
Union, the United Kingdom (and Gibraltar), and Switzerland in reliance on the
DPF. Abnormal has certified to the U.S. Department of Commerce that it adheres
to the DPF Principles with respect to such personal data. If there is any
conflict between the terms in this Privacy Notice and the DPF Principles, the
DPF Principles shall govern. To learn more about the Data Privacy Framework
(DPF) program, and to view Abnormal’s certification, please visit
https://www.dataprivacyframework.gov/. Additional information about our
compliance with the DPF principles can be found in our Data Privacy Framework
Notice. Your Choices and Rights We offer you choices regarding the collection,
use, and sharing of your personal information and we will respect the choices
you make in accordance with applicable law. You may choose (opt-out) whether
your personal information is (i) disclosed with a third party or (ii) to be used
for a purpose that is materially different from the purpose(s) for which it was
originally collected or subsequently authorized. You may indicate your choice by
clicking through the appropriate dialogue box to opt out or by emailing us at
privacy@abnormalsecurity.com. Please note that if you decide not to provide us
with certain personal information, you may not be able to access certain
features of the Abnormal websites and applications that link to this Privacy
Notice or use our Service. When you participate in a call or online meeting that
is being recorded, you have the right to request that we not record that call or
meeting. Please make those requests to the call organizer before or during the
call. During webinars or other events that must be recorded, please do not share
personal information that you do not want other attendees to view in the chats,
Q&A or similar features. Opt out of Marketing We may periodically send you
marketing communications that promote our products and services consistent with
your choices. You may opt-out of receiving such communications by following the
unsubscribe instructions in the communication you receive. Please note that we
may still send you important service-related communications regarding our
products or services, such as communications about your subscription or account,
service announcements, or security information.


ADDITIONAL INFORMATION FOR CERTAIN JURISDICTIONS

Depending upon your place of residence, you may have rights in relation to your
Personal Data. Please review the jurisdiction-specific sections below, including
the disclosures for California residents. Depending on applicable data
protection laws, those rights may include asking us to provide certain
information about our collection and processing of your Personal Data or
requesting access, correction, or deletion of your Personal Data. You also have
the right to withdraw your consent, to the extent we rely on consent to process
your Personal Data. This section provides additional information about our
privacy practices for certain jurisdictions. In the event of any conflict or
inconsistency between the Privacy Notice and the DPA, the DPA will control.
California If you are a California resident, the California Consumer Privacy Act
(“CCPA”) requires us to provide you with additional information regarding your
rights with respect to your “personal information.” You may make the following
types of requests under the CCPA with respect to personal information that we
process on your behalf. Note: if you wish to make a CCPA request concerning
Personal Information submitted through or otherwise made available to the
Service, please direct your request to the relevant Customer directly, as that
data is governed by the terms of our agreement with our Customer. Request to
Know, Correct, and Delete: You may request to
 * Access to a copy of the specific pieces of personal information that we have
   collected about you;
 * Correction of personal information that we maintain about you if it is
   inaccurate; and/or
 * Deletion of personal information, subject to certain exceptions.

Requests to Opt-Out of Sale or Sharing: You may also opt out of the “sale” or
“sharing” of your personal information, as “sale” and “sharing” are defined
under CCPA. You may opt out of the “sale” or “sharing” of personal information
as described in the “Opt out of marketing” section of this Privacy Notice. Other
US States Depending on applicable laws in your state of residence, you may
request to (1) confirm whether or not we process your personal information; (2)
access, correct, or delete the personal information we maintain about you; (3)
receive a portable copy of such personal information; and/or (4) restrict or opt
out of certain processing of your personal information, such as targeted
advertising or profiling in furtherance of decisions that produce legal or
similarly significant effects. If we refuse to take action on a request, we will
provide instructions on how you may appeal the decision. We will respond to
requests consistent with applicable law. European Economic Area, UK and
Switzerland If you are located in the European Economic Area, United Kingdom, or
Switzerland, the controller of your personal information is Abnormal Security
Corporation, 185 Clara Street, Suite 100, San Francisco, CA 94107 United States.
We collect your personal information if we have a legal basis for doing so. The
legal basis we rely on depends on the personal information and the specific
context in which we collect it. Generally, we collect and process your personal
information where:
 * We need it to enter into or perform a contract with you, respond to your
   request, or provide you with customer support
 * We need to process your personal information to comply with a legal
   obligation (such as to comply with applicable legal, tax, and accounting
   requirements) or to protect the vital interests of you or other individuals
 * You give us consent, such as to receive certain marketing communications
 * Where we have a legitimate interest, such as to respond to your requests and
   inquiries, to ensure the security of the Sites and Service, to detect and
   prevent fraud, to maintain, customize and improve the Sites and Service, to
   promote Abnormal and our Service, and to defend our interests and rights

If you have consented to our use of your personal information for a specific
purpose, you have the right to change your mind at any time but this will not
affect our processing of your information that has already taken place. You also
have the following rights with respect to your personal information:
 * The right to access, correct, update, or request deletion of your personal
   information;
 * The right to object to the processing of your personal information;
 * The right to withdraw your personal information at any time, if we collected
   and processed your personal information with your consent; and
 * The right to lodge a complaint with your national data protection authority
   or equivalent regulatory body.

If you wish to exercise any of your rights under data protection laws, please
contact us as described under “Your Choices and Rights”. Data Security and
Retention Abnormal retains the personal information as provided for in the
Information Security Policy. Additional information about our privacy and
security practices for the Service is available in our Security Hub. Please use
this Privacy Notice for as long as you use our Service, as may be required by
law (for example to comply with applicable legal tax or accounting
requirements), as necessary for other legitimate business or commercial purposes
described in this Privacy Notice (for example, to resolve disputes or enforce
our agreements), or as otherwise communicated to you. Children’s Data The Sites
and Service are not directed to children under 18 years of age and Abnormal does
not knowingly collect personal information from children under 18. If we learn
that we have collected any personal information from children under 18, we will
promptly take steps to delete such information. If you are aware that a child
has submitted such information, please contact us using the details provided
below. Artificial Intelligence Tools Abnormal’s commitment to transparency and
responsible data handling extends to the use of Artificial Intelligence Tools
(AI Tools) within our Sites, Service, and Corporate Operations. The AI Tools
used by Abnormal are not designed to utilize "high-risk AI systems" as defined
in the EU-AI Act. Our AI Tools may process personal information to enhance user
experience, provide personalized recommendations, and improve our overall
service delivery. Any data processed by our AI Tools is treated with the utmost
confidentiality, and we strictly adhere to data protection regulations.


CHANGES TO PRIVACY NOTICE

Abnormal may change this Privacy Notice from time to time. We will post any
changes on this page and, if we make material changes, provide a more prominent
notice (for example, by adding a statement to the website landing page,
providing notice through the Service, or by emailing you). You can see the date
on which the latest version of this Privacy Notice was posted above. How To
Contact Us Please contact us at privacy@abnormalsecurity.com if you have any
questions about our privacy practices or this Privacy Notice. You can also write
to us at: Abnormal Security Corporation 185 Clara Street, Suite 100, San
Francisco, CA 94107 Attn: Privacy Counsel If you interact with Abnormal through
or on behalf of a Customer, then your personal information may also be subject
to the applicable Customer’s privacy practices and you should direct any
questions to that organization.
Abnormal Security Data Privacy Framework Notice

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