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customer is (or acts on behalf of) the “controller” of the data (i.e., the
company with the right to decide how the data is used).
* Personal data that we handle for our own business (“Controller Data”), other
than for our human resources and recruiting operations. Under applicable law,
Fortinet is a “controller” of this data.
This Privacy Policy includes details specific to Processor Data, details
specific to Controller Data, and information relevant to our handling of both
kinds of data.
1. PRIVACY PRACTICES SPECIFIC TO PROCESSOR DATA
A. TYPES OF PROCESSOR DATA WE COLLECT
We receive information from or on behalf of our customers and their users, and
for most of such data, we act as a “processor.” Because of the nature of the
Fortinet Services, this information may contain any type of personal data. For
example, we may collect the following categories of information, that may be
Processor Data, through the Fortinet Services:
* Device identifiers, such as IP addresses, device name, model, manufacturer,
firmware versions, operating system, metadata, time zone, language, MAC
addresses, and other information about computing systems, applications,
filenames and file paths, usernames, and technical data about the operating
system instructions flow and networks.
* Contact details and registration information (including identifiers), such as
names, aliases, usernames, emails, age, gender, phone numbers, addresses, and
photographs
* Internet or other electronic network or device activity information, such as
system logs, traffic, URLs, metadata, and antivirus and other malware
statistics
* Other information that identifies or can be reasonably associated with you,
including information contained in files, activity logs, analysis reports,
communications content and metadata, distribution lists, and information
provided to us through dashboards or portals associated with the security and
firewall solutions of the Fortinet Services, such as troubleshooting requests
and security inquiries regarding files and systems
Some of the technical information listed above is considered personal data in
certain contexts. Fortinet also collects Processor Data through the technology
described in the “Cookies and Similar Automated Data Collection”
section below. We use Processor Data as described in the following section.
B. USES OF PROCESSOR DATA
Subject to our contractual obligations, and depending on the particular Fortinet
Services, we may use and disclose the information described above (sometimes in
combination with other information we obtain, such as from our customers) as
follows:
* To provide the Fortinet Services, including by:
* Providing maintenance and technical support
* Providing product upgrades
* Addressing security and business continuity issues
* Analyzing and improving the Fortinet Services, including responding to new
threats and developing new features
* To enforce the legal terms that govern the Fortinet Services
* To comply with law and protect rights, safety, and property
* For other purposes requested or permitted by our customers or users, or as
reasonably required to perform our business
Many Fortinet Services use automated technology to recognize and defend against
cybersecurity risks, such as by blocking or quarantining suspected malicious
data. To better protect our customers and assist them with their own security
compliance, some Fortinet Services use external threat information gathered in
these situations to improve security for customers of Fortinet Services in
similar situations. For example, if certain Fortinet services determine that a
hacker is attacking some of our customers, we may use information about that
threat in order to help protect other customers from similar attacks. This
provides our customers’ data with much better protection than what would be
possible if our services could not learn from experience. We handle “Threat
Data” like this as described in the “Privacy Practices Specific to Controller
Data” section below.
C. DISCLOSURES OF PROCESSOR DATA
Subject to our contractual obligations, and depending on the particular Fortinet
Services, we may disclose the information described above as follows:
* To provide the Fortinet Services, which can involve disclosing personal data
to our customer and with third parties selected by the customer or its users
(for example, to detect security threats, and protect against malicious,
deceptive, fraudulent, or illegal activity, we process data about third-party
threat actors (such as the IP address of certain compromised devices that
attempt cyberattacks on our customers)
* To enforce the legal terms that govern the Fortinet Services
* To comply with law, and where we deem disclosure appropriate to protect
rights, safety and property (for example, for national security or law
enforcement)
* As part of an actual or contemplated business sale, merger, consolidation,
change in control, transfer of substantial assets or reorganization
* For other purposes requested or permitted by our customers or users, or as
reasonably required to perform our business
For those purposes, we may share information with our affiliates and other
entities that help us with the activities described in this Privacy Policy.
2. PRIVACY PRACTICES SPECIFIC TO CONTROLLER DATA
A. TYPES OF CONTROLLER DATA WE COLLECT
As described above, we act as a processor for most of the Fortinet Services. We
are, however, a “controller” under applicable law with respect to Controller
Data. Controller Data includes two general categories of data: Business Data and
Threat Data.
For example, we may collect certain data about customers, prospective customers,
partners and their personnel (“Business Data”), which may include:
* Contact details and professional details, such as name, email address,
address, phone number, title and name of company
* Online identifiers, such as IP address and account ID information
* Information about users’ experience with our products, services, events and
online forums and communities, such as the Fortinet Developer Network and
CTAP end-user reports
* Information about actual or prospective customer personnel’s other
interactions with Fortinet, e.g., procurement, customer service, and point of
sale data
* Data we handle in connection with the Network Security Expert Institute, the
Fortinet Network Security Academy and other training and certification
programs, including contact information, identity documents and other
personal data collected for authentication of the candidate’s identity and
test security, and testing results
* Audio or video information, such recordings of meetings, or photographs
collected from certification candidates for identity verification and
security checks
* Information about actual or prospective users’ interests
* Financial data, such as payment information for Fortinet products and
services
* Investor relations-related data
* Other business-related data collected on our websites (such as online forum
registrations) and elsewhere for our own business (such as at events)
We obtain Business Data directly from the relevant individuals or their
employers, and also from third-party sources, such as distributors, resellers
and partners, credit card issuers, clearinghouses, data brokers, fraud
databases, referrals from customers and users, as well as publicly available
sources such as company websites.
In connection with some Fortinet Services, Fortinet is also considered a
controller of certain personal data relevant to security threats, i.e., “Threat
Data.” To the extent it is personal data, IP addresses, device identifiers,
URLs, and other data associated with malicious activity are part of Threat Data.
We obtain Threat Data through Fortinet Services, publicly available sources such
as online forums, dark web sources, other security providers and researchers,
and independent research.
Fortinet also collects Business Data and Threat Data through the technology
described in the Cookies and Similar Automated Data Collection section below. We
use all Controller Data as described in the following section.
B. USES OF CONTROLLER DATA (BUSINESS DATA AND THREAT DATA)
Fortinet uses Controller Data as follows:
* To provide our products, services, events, websites, communities, training,
certifications, and other business offerings
* For marketing, advertising, and other communications (including customizing
and tailoring all of them for the particular recipient)
* To manage our relationships with customers, partners, suppliers, event
attendees, and others
* For surveys and other market research
* For cybersecurity research
* To analyze, improve, and create Fortinet Services and other business
offerings
* To enforce the legal terms that govern our business and online properties
* To provide security and business continuity
* To comply with law and protect rights, safety, and property
* For other purposes requested or permitted by our customers or users, or as
reasonably required to perform our business.
C. DISCLOSURES OF CONTROLLER DATA (BUSINESS DATA AND THREAT DATA)
Subject to our contractual obligations, we share the information described above
as follows:
* For the uses of information described above
* As part of an actual or contemplated business sale, merger, consolidation,
change in control, transfer of substantial assets or reorganization
* For other purposes requested or permitted by our customers or users, or as
reasonably required to perform our business.
For those purposes, we may share information to:
* Our affiliates.
* Our customers.
* Third parties that assist us, such as our resellers, event providers, payment
processors, marketing providers, testing providers, analytics providers,
providers of technical services (e.g., providers of data storage, data
backup, and CRM systems), and other subcontractors.
* Joint marketing partners.
* Security researchers.
* Computer Emergency Response Teams (CERT)
* Employers and others who seek verification of an individual’s claimed
certification status.
* Entities involved in dispute resolution (such as an arbitrator or an opposing
party).
* Entities involved in potential or actual significant corporate transactions
or events.
* Governmental entities.
D. LEGAL BASES FOR PROCESSING CONTROLLER DATA (BUSINESS DATA AND THREAT DATA)
The laws in some jurisdictions require companies to tell you about the legal
ground they rely on to use or disclose your personal data. To the extent those
laws apply, our legal grounds for processing Controller Data are as follows:
* Legitimate interests: In most cases, we handle personal data on the ground
that it furthers our legitimate interests in commercial activities such as
the following in ways that are not overridden by the interests or fundamental
rights and freedoms of the affected individuals:
* Protecting our business, personnel and property
* Providing cybersecurity, including for the protection of personal data (for
example, sharing information with a regional CERT team to mitigate threats
within a region)
* Customer service
* Marketing
* Analyzing and improving our business; and/or
* Managing legal issues
We may also process personal data for the same legitimate interests of our
customers and business partners.
* To honor our contractual commitments to the individual: Some of our
processing of personal data is to meet our contractual obligations to
individuals, or to take steps at the individuals’ request in anticipation of
entering into a contract with them.
* Consent: Where required by law, and in some other cases, we handle personal
data on the basis of consent. Where legally required (e.g., for the use of
fingerprints for security purposes in certain jurisdictions), this is
explicit consent.
* Legal compliance: We need to use and disclose personal data in certain ways
to comply with our legal obligations.
E. PERSONAL DATA RIGHTS AND CHOICES (INCLUDING DIRECT MARKETING OPT-OUT)
We offer the options described below for exercising rights and choices under
applicable law. Many of these are subject to important limits or exceptions
under applicable law.
* To exercise rights or choices with respect to Processor Data, please make
your request directly to the Fortinet customer for whom we process the data,
particularly if the self-service options described below do not fully resolve
your concern.
* You may review and update certain user information by logging in to the
relevant portions of the Fortinet Services or Fortinet websites or online
services.
In addition, the law of your jurisdiction (for example, within the European
Economic Area) may give you additional rights to request access to and
rectification or erasure of certain of your personal data we hold. In some
cases, you may be entitled to receive a copy of the personal data you provided
to us in portable form or to request that we transmit it to a third party. The
law may also give you the right to request restrictions on the processing of
your personal data, to object to processing of your personal data, or to
withdraw consent for the processing of your personal data (which will not affect
the legality of any processing that happened before your request takes effect).
You may contact us as described below to make these requests.
* For example, residents of the European Economic Area and certain other
jurisdictions have a right to opt out of our processing of Controller Data
for direct marketing purposes. You can exercise this right by contacting us
as described below.
* Our marketing emails and certain other communications include unsubscribe
instructions, which you can use to limit or stop the relevant communications.
Opt-out processes may take some time to complete, consistent with applicable
law. Certain communications (such as certain billing-related communications
or emergency service messages) are not subject to opt-out.
* Many Fortinet Services are designed to block hacking and other unauthorized
activity, and they use automated means to compare user activity or device
traits to similar data points that been associated with hacking or other
unauthorized activity. If you believe that our services have been used to
block you in error, please contact the relevant Fortinet customer for
assistance. If you believe our services have blocked access to certain
websites in error, please follow the instructions on our FortiGuard website
to have such blocking reviewed. In limited cases, we may be able to assist
you directly, depending on our contract with our customer and how the
blocking happened.
* You may contact us with any concern or complaint regarding our privacy
practices, and you also may lodge a complaint with the relevant governmental
authority.
* Some Residents of California and Nevada have specific rights under the next
two sections.
F. PRIVACY INFORMATION FOR CALIFORNIA RESIDENTS
This subsection applies only to “personal information” about California
residents, as that term is defined in the California Consumer Privacy Act, as
amended (“CCPA”), and it supplements the information in the rest of our Privacy
Notice above. Data about individuals who are not residents of California is
handled differently and is not subject to the same rights described below. This
section does not apply to data that we handle in our capacity as a processor or
“service provider” under the CCPA or to data that is exempt from the CCPA, such
as publicly available information. Californians who wish to exercise the rights
described here with respect to Processor Data should contact the customer on
whose behalf we handle the data. The rest of this California section applies
only to Controller Data.
CATEGORIES OF PERSONAL INFORMATION WE COLLECT AND DISCLOSE
During the 12 months leading up to the effective date of this Privacy Notice and
on an ongoing basis, Fortinet has collected all of the following information
from and about California residents:
* Identifiers, such as:
* Contact details and professional details, such as name, email address,
address, and phone number
* Online identifiers, such as IP address and account ID information
* Professional or employment related data (such as title and name of company)
* Commercial information, such as:
* Information about users’ experience with our products, services, events and
online forums and communities, such as the Fortinet Developer Network and
CTAP end-user reports
* Information about actual or prospective customer personnel’s other
interactions with Fortinet, e.g., procurement, customer service, and point
of sale data
* Information about actual or prospective users’ interests
* Certain data we handle in connection with the Network Security Expert
Institute, the Fortinet Network Security Academy and other training and
certification programs, such as testing results.
* Other business-related data collected on our websites (such as online forum
registrations) and elsewhere for our own business (such as at events)
* Audio or video information, such recordings of meetings, or photographs
collected from certification candidates for identity verification and
security checks
* Financial data, such as payment information for Fortinet products and
services Investor relations-related data
* Certain internet or other network or device activity (such as IP addresses,
device identifiers, cookie data, device attributes, device usage information,
browsing information, and metadata)
* Account login credentials
* Other information that identifies or can be reasonably associated with an
individual
* Inferences drawn from any of the above
We intend to retain this information until we determine retention no longer is
necessary for the purposes described further below. Because we may collect and
use the same category of personal information for different purposes and in
different contexts, there is not typically a fixed retention period that always
will apply to a particular category of personal information.
The Threat Data we collect (i.e., data related to security threats) may include
identifiers, commercial data, login credentials, internet or network or device
activity, or other personal information, depending on the context.
Fortinet uses personal information as follows:
* To provide our products, services, events, websites, communities, training,
certifications, and other business offerings
* For marketing, advertising, and other communications (including customizing
and tailoring all of them for the particular recipient)
* To manage our relationships with customers, partners, suppliers, event
attendees, and others
* For surveys and other market research
* For cybersecurity research
* To analyze, improve, and create Fortinet Services and other business
offerings
* To enforce the legal terms that govern our business and online properties
* To provide security and business continuity
* To comply with law and protect rights, safety, and property
* For other purposes requested or permitted by our customers or users, or as
reasonably required to perform our business
CCPA “SALE” OF CALIFORNIA PERSONAL INFORMATION
Fortinet does not sell personal information as the term “sell” is traditionally
understood. But “sell” under the CCPA is broadly defined. As described further
below, some of our disclosures of personal information qualify under the CCPA as
what it defines as a “sale” or “sharing” of personal information. In many cases,
for example, “sale” includes the disclosure of personal information to third
parties in exchange for something of value, even if no money changes hands. For
example, disclosing an advertising or device identifier to a third party to
receive their services may be considered a “sale” under the CCPA in some cases.
During the 12 months leading up to the effective date of this Privacy Policy, we
have “sold” and “shared” (as those terms are defined under the CCPA) what the
CCPA calls “identifiers” (like IP addresses), “internet or other electronic
network activity information” (like information regarding an individual’s
browsing interactions on Fortinet.com), and “commercial information” (like the
fact that a browser visited a page directed to people who are considering
purchasing from us) to third parties that assist us, such as marketing providers
and analytics providers. This practice continues today. To our knowledge, we do
not “sell” or “share” (as those terms are defined under the CCPA) the personal
information of individuals under 16 years of age.
Californians have a right to ask us not to “sell” or “share” certain personal
information as that term is defined in under the CCPA. You can make such a
request by performing BOTH of the following steps:
1. Click here and complete the form, using the phrase “Do Not Sell or Share My
Personal Information” in the form fields (or just send us an email
at privacy@fortinet.com with that request); AND
2. If you’d like your request to include CCPA “sales” and “sharing” that happen
through cookies and related technology on one of our websites, follow the
steps below that are applicable to your use of that website:
* To opt out of those “sales” and “sharing” that occur through webpages with a
URL that begins with “www.fortinet.com”, click on the Cookie Settings link in
the footer. In the Privacy Preference Center that pops up, click on the
Performance Cookies tab and make sure the toggle button is in the off
position (the left side of the slider). Click it if it is not in the off
position. Repeat this process for Advertising Cookies and Functional Cookies
and then click the “Confirm My Choices” button. Be sure to repeat this second
step from each browser you use to access our webpages that begin
with “www.fortinet.com.” Because we store this preference in a cookie, you’ll
need to repeat this process again in a particular browser if you clear your
cookies in that browser or if you have chosen to use a browser that
automatically clears cookies.
* Additional control options (which can be used to limit certain data
collection or use on Fortinet webpages that don't have a Cookie Settings link
in their footer) are described in the Cookies and Similar Automated Data
Collection section of our Privacy Policy below. Because those too store your
preference in a cookie, you’ll need to repeat this process again in a
particular browser if you clear your cookies in that browser or if you have
chosen to use a browser that automatically clears cookies.
Opting out of “sales” and “sharing” limits only some types of disclosures of
personal information, and there are exceptions to all of the rights described in
this section. For example, the federal Cybersecurity Information Sharing Act
pre-empts (cancels) the CCPA with respect to any requirement that we allow an
opt-out of certain disclosures of cybersecurity threat indicators, even if those
disclosures might otherwise be considered a “sale” under the CCPA.
OTHER DISCLOSURES OF PERSONAL INFORMATION
In the last 12 months, we disclosed California personal information to third
parties as follows:
Category of personal information
Categories of third parties to which it is disclosed
Identifiers (such as name, address, email address and other contact information)
* Our affiliates.
* Our customers.
* Third parties that assist us, such as our resellers, event providers, payment
processors, marketing providers, testing providers, analytics providers,
providers of technical services (e.g., providers of data storage, data
backup, and CRM systems), and other subcontractors.
* Joint marketing partners.
* Security researchers.
* Computer Emergency Response Teams (CERT)
* Employers and others who seek verification of an individual’s claimed
certification status.
* Entities involved in dispute resolution (such as an arbitrator or an opposing
party).
* Entities involved in potential or actual significant corporate transactions
or events.
* Governmental entities.
Commercial information, (such as information about an individual’s interests and
interactions with us, our partners, or our customers, including transaction
data)
Same as first row in this chart.
Financial data (such as payment information)
Affiliates, third parties that assist us, and governmental entities, entities
involved in dispute resolution (such as an arbitrator or an opposing party),
entities involved in potential or actual significant corporate transactions or
events.
Audio and visual information (such as CCTV images or recordings of calls or
meetings)
Affiliates, third parties that assist us, and governmental entities
Internet or other network or device activity (such as IP addresses, device
identifiers, cookie data, device attributes, device usage information, browsing
information, and metadata)
Same as first row in this chart.
Geolocation information
Affiliates, third parties that assist us, and governmental entities, joint
marketing partners, security researchers.
Account login credentials
Affiliates, third parties that assist us, security researchers.
Professional or employment related data (such as title)
Same as first row in this chart.
Other information that identifies or can be reasonably associated with an
individual
Same as first row in this chart.
Inferences drawn from any of the above Same as first row in this chart.
We do not use or disclose “sensitive personal information” covered by this
Notice and as defined in the CCPA in a manner that requires us to offer a
special right to limit our use of this data under the CCPA.
CCPA RIGHT TO ACCESS, CORRECT, OR DELETE PERSONAL INFORMATION
If you are a California resident, California law also may permit you to request
that we:
* Provide access to and/or a copy of certain information we hold about you;
* Delete certain information we have about you;
* Correct certain personal information we have about you; and
* Inform you about the categories of personal information we have collected
about you in the preceding 12 months; the categories of sources of such
information; the business or commercial purpose for collecting or selling
your personal information; and the categories of third parties with whom we
have disclosed certain personal information, and more specific detail about
what categories of information were "sold," "shared" or disclosed to
particular categories of third parties, similar to the detail above this
section of the Privacy Policy;
Please note that certain information may be exempt from such requests under
California law. For example, we need certain information to provide our services
to you, so we may reject a deletion request for that information while providing
services to you.
To request to exercise any of these rights and receive the fastest response,
please email us at privacy@fortinet.com or click here to submit a request. You
may also call us at (833) 675-6887. We reserve the right to require verification
of your identify before we fulfill a request, which may include requiring you to
login to an existing Fortinet account, providing us with information that
matches our records for you, responding to an email we send, or taking other
steps relevant to your relationship with us and the nature of your request.
If you are an agent making a request on behalf of a consumer, we reserve the
right to take steps to verify that you are authorized to make that request,
which may include requiring you to provide us with written proof such as a
notarized authentication letter or a power of attorney. We also may require the
consumer to verify their identity directly with us. Because opt-out requests for
“sales” and “sharing” made through cookies and related technology must be
performed from each browser that is used to access our Services, it is easiest
for the consumer to perform such opt-outs themselves. However, if a consumer
wishes for an agent to perform browser-based requests on their behalf, the
consumer may arrange for the agent to use the consumer’s browser to make such
requests. We are not responsible for the security risks of this or any other
arrangements that a consumer may have with an agent. For clarity, this is not
permission for any user to disclose their login credentials to an agent or any
third party. Such disclosure is prohibited and is not required for an agent to
make requests under this Privacy Policy.
For security and legal reasons, however, Fortinet reserves the right not to
accept requests that require us to access third-party websites or services.
You have a right not to receive “discriminatory treatment” (within the meaning
of the CCPA) for the exercise of the privacy rights conferred by the CCPA.
G. NOTICE TO NEVADA RESIDENTS
* Under a Nevada law, certain Nevada consumers may opt out of the “sale” of
“personally identifiable information” for monetary consideration to a person
for that person to license or sell such information to additional persons, as
those concepts are defined under the Nevada law, which differs from the CCPA.
“Personally identifiable information” under that law includes first and last
name, address, email address, phone number, Social Security Number, or an
identifier that allows a specific person to be contacted either physically or
online.
* We do not engage in such activity; however, if you are a Nevada resident who
has purchased or leased goods or services from us, you may submit a request
to opt out of any potential future sales under Nevada law by
contacting privacy@fortinet.com. We reserve the right to take reasonable
steps to verify your identity and the authenticity of the request. Once
verified, we will maintain your request in the event our practices change.
3. ADDITIONAL INFORMATION ABOUT OUR PRIVACY PRACTICES (APPLICABLE TO BOTH
PROCESSOR DATA AND CONTROLLER DATA)
A. AGGREGATE OR DE-IDENTIFIED DATA
Subject to applicable law and our contractual obligations, (i) we may aggregate
or de-identify Controller Data or Processor Data so that the information cannot
be linked to the relevant individual and (ii) our use and disclosure of
aggregated, anonymized, and other non-personal information is not subject to any
restrictions under this Privacy Policy, and we may disclose it to others without
limitation for any purpose.
B. COOKIES AND SIMILAR AUTOMATED DATA COLLECTION
In our websites, apps and emails, we and third parties may collect certain
information by automated means such as cookies, Web beacons, tags and scripts or
similar technologies, JavaScript and mobile device functionality.
This information may include unique browser identifiers, IP address, browser and
operating system information, device identifiers (such as the Apple IDFA or
Android Advertising ID), geolocation, other device information, Internet
connection information, as well as details about individuals’ interactions with
our apps, websites and emails (for example, the URL of the third-party website
from which you came, the pages on our website that you visit, and the links you
click on in our websites, and firmographic information based on IP lookup).
We and third parties may use automated means to read or write information on
users’ devices, such as in various types of cookies and other browser-based or
plugin-based local storage (such as HTML5 storage or Flash-based storage).
Cookies and local storage are files that contain data, such as unique
identifiers, that we or a third party may transfer to or read from a user’s
device for the purposes described in this Privacy Policy, such as recognizing
the device, service provision, record-keeping, analytics and marketing,
depending on the context of collection.
These technologies help us (a) keep track of whether you are signed in or have
previously signed in so that we can display all the features that are available
to you; (b) remember your settings on the pages you visit, so that we can
display your preferred content the next time you visit; (c) display personalize
content; (d) perform analytics, and measure traffic and usage trends, and better
understand the demographics and other attributes of our users; (e) diagnose and
fix technology problems; and (f) otherwise plan for and enhance our business.
Also, in some cases, we facilitate the collection of information by advertising
services administered by third parties. The ad services may track users’ online
activities over time by collecting information through automated means such as
cookies, and they may use this information to show users ads that are tailored
to their individual interests or characteristics and/or based on prior visits to
certain sites or apps, or other information we or they know, infer or have
collected from the users. For example, we and these providers may use different
types of cookies, other automated technology, and data (i) to recognize users
and their devices, (ii) to inform, optimize, and serve ads and (iii) to report
on our ad impressions, other uses of ad services, and interactions with these ad
impressions and ad services (including how they are related to visits to
specific sites or apps).
The best way to manage your preferences regarding our use of these technologies
on Fortinet websites that have a “Cookie Settings” link in the footer is to
click that link and submit your preferences. On other Fortinet webpages, you can
make certain choices by following the steps below.
You may be able to set your web browser to refuse certain types of cookies, or
to alert you when certain types of cookies are being sent. Some browsers offer
similar settings for HTML5 local storage, and Flash storage can be managed here.
However, if you block or otherwise reject our cookies, local storage, JavaScript
or other technologies, certain websites (including our own websites) may not
function properly.
To learn more about interest-based advertising generally, including how to opt
out from the targeting of interest- based ads by some of our current ad service
partners, visit aboutads.info/choices or youronlinechoices.eu from each of your
browsers. You can opt out of Google Analytics and customize the Google Display
Network ads by visiting your Google Ads Settings. Google also allows you to
install a Google Analytics Opt-out Browser Add-on for your browser.
If you replace, change or upgrade your browser (or use a browser that
automatically clears your cookies), or delete your cookies, you may need to use
all of the opt-out tools described above again. We do not respond to
browser-based do-not-track signals.
Please visit your mobile device manufacturer's website (or the website for its
operating system) for instructions on any additional privacy controls in your
mobile operating system, such as privacy settings for device identifiers and
geolocation.
C. SECURITY
We have put in place physical, electronic, and managerial procedures to
safeguard data and help prevent unauthorized access, to maintain data security,
and to use correctly the data we collect. However, we cannot assure you that
data that we collect will never be used or disclosed in a manner that is
inconsistent with this Privacy Policy.
If a password is used to help protect your personal information, it is your
responsibility to keep the password confidential. Do not share this information
with anyone.
D. DATA RETENTION
We will retain your information for the period necessary to fulfill the purposes
outlined in this Privacy Policy unless a longer retention period is required or
permitted by law. To provide security and business continuity for the activities
described in this Privacy Policy, we make backups of certain data, which we may
retain for longer than the original data. For example, FortiGate Cloud Sandbox
(SaaS) retains files and related logs if rated Suspicious for 60 days.
E. INTERNATIONAL DATA TRANSFERS
Fortinet and the recipients of the data disclosures described in this Privacy
Policy have locations in the United States, Canada and elsewhere in the world,
including where privacy laws may not provide as much protection as those of your
country of residence. Fortinet data centers for Processor Data are located
primarily in Canada. We comply with legal requirements for cross-border data
protection, including through the use of European Commission-approved Standard
Contractual Clauses. To exercise any legal right to request data transfer
mechanism documents that Fortinet uses to transfer data to third parties, please
contact us.
Certain Fortinet Services allow our customers and users to make international
data transfers to third parties, for which they are solely responsible.
F. DATA PRIVACY FRAMEWORK
Fortinet, Fortinet Holding LLC, and Fortinet Branch Holding Company, comply with
the requirements of the EU-U.S. Data Privacy Framework (“EU-U.S. DPF”) and the
UK Extension to the EU-U.S. DPF and the Swiss-U.S. Data Privacy Framework
(“Swiss-U.S. DPF”) (collectively “DPF”), as set forth by the U.S. Department of
Commerce and the Federal Trade Commission (“FTC”), regarding the collection,
use, and retention of Processor Data transferred from the European Economic Area
(“EEA”) and the United Kingdom (“UK”) and Switzerland to the United States. We
have certified to the Department of Commerce that we adhere to the DPF
Principles and Supplemental Principles with respect to “personal information”
(as defined in the DPF) that is part of Processor Data transferred to us in
reliance on the DPF. To the extent that the DPF applies to your information, if
there is any conflict between the terms in this Privacy Policy and the DPF
Principles, the DPF Principles shall govern. We are subject to the investigatory
powers of the FTC with respect to our DPF compliance. To learn more about the
DPF program, and to view Fortinet’s certification, please visit
https://www.dataprivacyframework.gov/s/. Fortinet may also protect information
through other legally valid methods, including international data transfer
agreements.
>If you are an EEA, UK, or Swiss citizen, you may be able to exercise certain
choices under the DPF regarding how some of your personal information is used
and disclosed, and may access, correct or delete certain personal information by
following the instructions in the “Personal Data Rights and Choices” section of
this Privacy Policy.
When we receive Processor Data under the DPF and then transfer it to a
third-party service provider acting as our agent on our behalf, we may have
certain responsibility under the DPF if both (a) the agent processes the
information in a manner inconsistent with the DPF and (b) we are responsible for
the event giving rise to the damage.
If you are an EEA, UK, or Swiss citizen and feel that Fortinet is not abiding by
the terms of this Privacy Policy, or is not in compliance with the DPF
Principles, please contact Fortinet at the contact information provided below.
If we are unable to resolve your concerns, Fortinet has agreed, in compliance
with DPF, to refer unresolved complaints concerning our handling of Processor
Data received in reliance on DPF to JAMS, an alternative dispute resolution
provider based in the United States. If you do not receive timely acknowledgment
of your DPF-related complaint from us, or if we have not addressed your
DPF-related complaint to your satisfaction, please
visit https://www.jamsadr.com/DPF-Dispute-Resolution for more information or to
file a complaint. The services of JAMS are provided at no cost to you.
If any request remains unresolved, you may contact the national data protection
authority for your jurisdiction of residence. In certain conditions, if your DPF
complaint has not been resolved after raising it with us following the JAMS
procedure above and taking certain other steps, complaints may be resolved
through binding arbitration, as described in Annex I of the DPF, available here:
https://www.dataprivacyframework.gov/s/article/ANNEX-I-introduction-dpf?tabset-35584=2.
G. NOTIFICATION OF CHANGES
Fortinet reserves the right to change this Privacy Policy at any time to reflect
changes in the law, our data collection and use practices, the features of our
services, or advances in technology. Please check this page periodically for
changes. Any updated Privacy Policy will be posted on Fortinet.com via a
hyperlink in the footer or other convenient location.
H. HOW TO CONTACT US
To request to exercise any of these rights and receive the fastest response,
please click here or email us at privacy@fortinet.com.
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