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 * DS
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PRIVACY POLICY

This privacy notice sets out when and how we use your personal information that
we collect, and which you or others provide to us. We are Digital Shadows, our
company group is made up of the following legal entities:



Company Name Company Location Registered Address Digital Shadows Inc. United
States 235 Pine Street, Suite 1050, San Francisco, California 94104, United
States Digital Shadows Limited United Kingdom Floor 6, 7 Westferry Circus,
Canary Wharf, London, United Kingdom, E14 4HD. Digital Shadows GmbH Germany
Theresienhöhe 30 80339, München, Bayern Germany Digital Shadows PTE. LTD
Singapore ICE71 Blk 71, Ayer Crescent, #02-18, Singapore 139951



This privacy notice is issued on behalf of the Digital Shadows group, so when we
mention  “Digital Shadows”, “we”, “us” or “our” in the privacy notice, we are
referring to the relevant company in our group responsible for handling your
personal information. We will let you know which company is responsible for your
data when you purchase a service from us. You can also contact us to ask who the
responsible company is over particular data sets at any time.

We have appointed a data protection officer. If you have any questions about
this notice, or wish to exercise your legal rights, please contact our data
protection officer at dpo@digitalshadows.com.


HOW DO YOU USE MY DATA?


WHEN YOU PURCHASE OUR SERVICES



We collect: Your name, address, email address, phone number and payment details.
Also the search keywords you give to us which you ask us to monitor for you. Our
lawful basis: To enter into and perform the contract for the services you have
purchased from us. Who we share it with: Our group companies to provide round
the clock support. Our subcontractors who are involved in the purchase process,
such as payment providers, as well as credit reference agencies who we use to
assess fraud, credit and/or security risks. We also use sub-contractors for data
storage, and will share your information with law enforcement agencies if we are
required to do this by law.




WHEN OUR SECURITY SOFTWARE CAPTURES YOUR PERSONAL INFORMATION



How does the software work?   In a similar way to how search engines work, we
search (and store) parts of the publically available webpages and files on the
Internet and the Dark Web to check for security risks that might negatively
impact our clients. As part of this, we may capture your publically available
personal information. We only do this as part of providing security services to
our clients – we do not target or focus our efforts on collecting data relating
to particular members of the public who have no links to our clients. Do we rely
on any exemptions? Due to the nature of our data collection, which is monitoring
information published on the Internet and the Dark Web, it would be impossible
for us to notify every single data subject whose personal data we collect.  Data
protection laws around the world enable us to not provide this information to
each individual before handling their personal information where doing so is
impossible, or involves a disproportionate effort. We rely on this exemption.
Any questions about this exemption can be addressed to our DPO
atdpo@digitalshadows.com. We collect: Any publically available personal
information about you on the dark web, or on the Internet (public files located
on the Internet are commonly PDF files or Word or Microsoft office documents,
but can be a very broad range of file formats).   Generally, if we capture any
personal information about you, it will include the following: name, work and
home address, email address, contact details, aliases and social media accounts.
Our lawful basis: We are providing an important service which substantially
assists our customers in identifying and addressing data breaches, whether those
breaches relate to the compromising of commercial data, personal data or both. 
We rely on public interest as our lawful basis as well as legitimate interests.
This is because it is in the public interest that companies, public authorities
and others are able to take effective steps to detect and remediate data
breaches. This is important in terms of maintaining fair play principles in the
operation of commercial markets, protecting the business assets of commercial
entities against theft and other improper misuse, as well as facilitating the
identification of personal data breaches and their swift remediation. Who we
share it with: Our subcontractors who are involved in providing security support
services and our external storage providers, and law enforcement agencies if we
are required to do this by law.




WHEN YOU ATTEND ONE OF OUR EVENTS



We collect: Your name, contact details and if required, payment information and
dietary preferences. Our lawful basis: We provide a delegate list to the
organisations and other individuals who attend our events. We do this because
our events provide a useful networking opportunity and we have a legitimate
interest in wanting to help build and develop the digital security community.
Residents of California can opt-out of this sharing of their personal
information here, and you can object to us using your information in this way by
contacting us at dpo@digitalshadows.com. Who we share it with: Event co-sponsors
as explained above. Our subcontractors who are involved in the purchase process,
such as data storage subcontractors, payment providers, as well as credit
reference agencies who we use to assess fraud, credit and/or security risks. We
may also share your information with any of our subcontractors that assist us
with the running of our events if we need to – such as venue providers, and law
enforcement agencies if we are required to do this by law.




WHEN YOU CONTACT US OR TALK TO US VIA LIVECHAT FOR CUSTOMER SERVICE PURPOSES



We collect: Your name, contact details and the other details you provide to us
via the live chat system. Our lawful basis: In accordance with the contract in
place between us, or if you are not a customer, because of our legitimate
interest to provide high quality customer service. Who we share it with: Who we
share this data with depends on what we have been discussing over our live chat,
but it will usually include our group companies. We will let you know at the
time we share your data if we will share it with anyone other than our group
companies.




WHEN YOU HAVE EXPRESSED AN INTEREST IN DIGITAL SHADOWS



We collect: Information you provide to us, including your name, email address,
postal address, telephone number and sector preferences. Where you are a
business professional who is likely to be interested in our products and
services, our data brokers provide us with your name, email address, job title
and employer. Our lawful basis: When we send you marketing emails because you
have opted-in to receive them, we rely on your consent to contact you for
marketing purposes. If you have not opted-in and we send you marketing emails,
we do this because of our legitimate interest to promote the success of our
business. You can tell us that you do not want your personal information to be
processed in this way at any time by contacting us at dpo@digitalshadows.com or,
where relevant, by following the unsubscribe link shown in every marketing
communication you receive from us. If you have opted out of our email marketing,
you may still continue to see targeted ads on social media platforms. Please
check the social media platforms for more details on how to opt out of seeing
these ads. Who we share it with: We also share your personal information with
our subcontractors who help us electronic marketing platforms




TO IMPROVE OUR WEBSITE AND LEAD GENERATION



We collect: IP address, browser type, device type, referring website. How you
interact with our website and whether you have interacted with us before. Our
lawful basis: Our legitimate interest to provide you with the best experience we
can, and to ensure that our site is kept secure, except where we collect that
information via cookies on our website and pixels in our emails which you have
consented to. Who we share it with: The service providers identified in our
cookies policy.


IF OUR BUSINESS IS SOLD



We collect: If Digital Shadows or the majority of its assets are acquired by
somebody else, your personal information held by us will be transferred to the
buyer. Our lawful basis: We process your personal information for this purpose
because we have a legitimate interest to ensure our business can be continued by
the buyer. If you object to our use of your personal information in this way,
the buyer of our business may not be able to provide services to you. In some
circumstances we may also need to share your personal information if we are
under a duty to disclose or share it to comply with a legal obligation. Who we
share it with: The purchaser of our business and our professional advisors (such
as lawyers and accountants).




COOKIES

Our site uses cookies to distinguish you from other users of our site. Our
cookies policy is available here.


WHERE IS MY DATA STORED?

We use third parties across the globe, including in the UK, EU and the US.
Whenever we transfer your personal information outside of your home territory,
we ensure it is protected in accordance with applicable data protection laws. We
use the Standard Contractual Clauses to protect personal data transferred
outside of the UK and/or the EU.

To keep this privacy policy as short and easy to understand as possible, we have
not set out the specific circumstances when each of these protection measures we
rely on are used. You can contact us at dpo@digitalshadows.com for the details
as to how we protect specific transfer of your data.


COMPLIANCE WITH THE EU-US PRIVACY SHIELD

Digital Shadows Inc. remains certified under and compliant with the EU-US
Privacy Shield Framework. Following the Schrems II case in which the EU-US
Privacy Shield was declared invalid, Digital Shadows Inc. no longer relies on
the Privacy Shield framework to facilitate any of its international data
transfers. Any international transfers of data which previously relied on the
EU-US Privacy Shield Framework are now subject to the Standard Contractual
Clauses. The italicised and indented text in this section has been retained
temporarily as it is a requirement to publicise this in order for Digital
Shadows Inc. to retain its Privacy Shield certification.

Digital Shadows Inc. complies with the EU-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 UK and the European Union
to the United States.  We have certified to the U.S. 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/.

We have further committed to cooperate with the panel established by the EU data
protection authorities (DPAs) with regard to unresolved Privacy Shield
complaints concerning human resources data transferred from the EU in the
context of the employment relationship.

When Digital Shadows Inc. receives or transfers Personal Information in
accordance with the Privacy Shield Frameworks, it will be subject to the
investigatory and enforcement powers of the Federal Trade Commission (FTC).

In compliance with the Privacy Shield Principles, we commit to resolve
complaints about our collection or use of your personal information.  EU
individuals with inquiries or complaints regarding our Privacy Shield policy
should first contact us at: dpo@digitalshadows.com. If your complaint isn’t
satisfactorily addressed by us, then you can make use of the UK’s Information
Commissioner’s Office to resolve a dispute.

You may be able to select binding arbitration under the Privacy Shield
Framework, more information about this can be found here.

We will ensure that all onward transfers of your Personal Information are in
line with the Privacy Shield Principles. Please note, we may disclose your
Personal Information where we are requested to do so by public authorities or to
meet national security or law enforcement requirements. We understand that we
shall remain liable under the Privacy Shield Principles if any of our agents
processes such personal information in a manner which is inconsistent with the
Privacy Shield Principles. Please note we will not be liable in the event we are
not responsible for any event that gives rise to the damage caused.


CCPA

We may disclose information to the organisations we co-sponsor cybersecurity
events with. We do this to introduce you to a wide variety of cybersecurity
organisations you’re likely to be interested in, and to make our events
financially viable to run. We also work with resellers to help us sell our
software, and disclose your information to them if we believe you would be
interested in hearing from them.

In each case, the information we provide includes your name, email address, job
title, office location, and company.

If you are a resident of California then you have the right to opt-out of this,
because our sharing of data in this way may constitute a “sale” of your personal
information under the California Consumer Privacy Act. If you wish to exercise
this right, please contact us via toll-free call at +1 (888) 889-4143 or use the
web form here. In order to fulfil our obligations under the California Consumer
Privacy Act, we may take steps to verify your identity, and ensure that the
request is valid, including where an authorized representative is making a
request on your behalf.

Please note where you have opted out of us sharing your information in this way,
the service you receive will not be of an inferior quality or higher price,
unless permitted by applicable law or where the services we provide to you rely
on the sale of your personal information.


HOW LONG DO WE RETAIN YOUR DATA FOR?

We will only retain your personal information for as long as necessary to fulfil
the purposes we collected it for, including for the purposes of satisfying any
legal, accounting or legal requirements.

To determine the appropriate retention period for the other personal information
we hold, we consider the amount, nature and sensitivity of the personal
information, the risk of harm from unauthorised use or disclosure of your
personal information, the reasons why we handle your personal information and
whether we can achieve those purposes through other means, and the applicable
legal requirements.

In some circumstances (to understand digital security trends and how people
interact with our website) we may anonymise your personal data so that it can no
longer be associated with you for research or statistical purposes, in which
case we may use this information indefinitely without further notice to you.


WHAT CONTROLS DO I HAVE OVER MY DATA?

We are happy to grant everyone the controls below, irrespective of where they
are in the world:

Request access to your data. Ask us for a copy of the data we hold about you and
we will provide it, following applicable data protection laws.

Request correction of the data that we hold about you. Let us know and we will
correct any incomplete or inaccurate information we hold about you.

Request erasure of your data. This enables you to ask us to delete or remove
data where there is no good reason for us continuing to process it.

Object to processing of your data, such as the sharing of your data with third
parties. If you are based in a territory that has specific laws covering rights
to object or opt-out, such as California, the UK and the EU, then we will follow
the processes set out in those applicable laws when handling your objection.

Request the restriction of processing of your data. This enables you to ask us
to suspend the processing of data about you, for example if you want us to
establish its accuracy or the reason for processing it.

Request the transfer of your data to another party.

Privacy law is often complicated, and whether these rights are available to you
sometimes depends on the types of data we are handling, as well as why we are
handling it. If you would like to exercise any of these rights, please contact
us using the details at the bottom of this notice. You always have the right to
lodge a complaint with us or the regulator for data protection in your country.


WHAT ABOUT WEBSITES WE LINK TO?

Our site connects you to different websites.  If you follow a link to any of
these websites or use our services, please note that you have left our site and
these websites have their own privacy policies. 

We do not accept any responsibility or liability for these policies or
websites.  Please check their policies before you submit any personal
information to these websites.


HOW DO I CONTACT YOU WITH FEEDBACK?

Questions, comments and requests regarding this privacy policy are welcomed and
should be addressed to our Data Protection Officer at dpo@digitalshadows.com.

This privacy policy was last updated on 03 June 2021.


DIGITAL SHADOWS

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SOLUTIONS

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 * Typosquatting Protection
 * Social Media Monitoring
 * Data Breach Detection
 * Technical Leakage Detection
 * Intellectual Property Protection
 * Third Party Risk
 * Cyber Threat Intel
 * Dark Web Monitoring
 * Vulnerability Intelligence


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RESOURCES

 * Practical Guide to Digital Risk
 * Resources Center
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Copyright 2021 Digital Shadows Ltd, All rights reserved. Digital Shadows, the
Digital Shadows Logo are trademarks and registered trademarks of Digital Shadows
Ltd. Digital Shadows Ltd is a company registered in England and Wales under No:
7637356. Registered office: 7 Westferry Circus, Columbus Building Level 6,
London, E14 4HD.

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