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* Service Privacy Policy
SERVICE PRIVACY POLICY
Find information on the types of personal data we collect through our services
and interactions with you, and how this data is processed by our services when
you use them. This policy was last updated to reflect the Data Privacy Framework
on 13 October 2023
Download PDF Get updates
* The basics
* How your personal data is collected
* How we use your personal data
* How we process personal data lawfully
* How we use automated decision-making
* Who we may share your personal data with
* Other important things to know
The basics
THE BASICS
WHO WE ARE
Egress Software Technologies Limited is a company based in the United Kingdom
and is the parent company within our group (which means that it owns the other
companies). We use the words we, us, and our to refer to our business in this
document. You can find out more about us and our group at www.egress.com/about.
WHAT IS ‘PERSONAL DATA’ OR ‘PERSONAL INFORMATION’
It is difficult to provide a single definition which applies wherever you are
located as the definitions used around the world differ, sometimes quite
subtly. Generally, it means something akin to information that “relates to an
identified or identifiable natural person”. As well as personal data/personal
information, you may hear other phrases such as sensitive data, NPI (non-public
personal information) and PHI (protected health information) and so on. These
are specific kinds of personal data that may have additional obligations in
relation to how they are stored, shared and otherwise processed.
In this document we refer to personal data.
WHO HOLDS YOUR INFORMATION
We store and process your Content and Smart Data on your behalf. These contain
personal data. Which company in our group is responsible for this will be set
out in your agreement with us which will be either our online subscriber terms
or your organisation’s contract with us if you are a user within a business
account. We describe what we mean by Content and Smart Data a little further
down. You can contact us at dpo@egress.com or through our webform to exercise
your rights .
We do collect and process some other types of personal data which we also
explain below. These are held by Egress Software Technologies Limited. We hold
this personal data for and on behalf of ourself and the other companies in our
group.
HOW LONG WE HOLD YOUR INFORMATION FOR
We keep personal data for the periods set out in our data retention policy. You
can always find the current version of this document at www.egress.com/legal.
WHERE YOUR INFORMATION IS STORED
The table below explains the different ways that we talk about the data we hold
and process. We use this data, which may contain personal data, to run our
business and deliver our services to you.
Information you control
What it is / means
Where it is stored
Content
the files, data, text, audio, video, images and other materials that you
transfer, store, share or host through use of our service.
UK, EU, US, Australia. If you register online, this is determined by your
location at the time you subscribe. If you are a business, then you may specify
your preference during discussions with us.
Smart Data
(specific to our Prevent service)
the record of your individual email behaviour and the associations that you have
with recipients that our Prevent service learns from processing, collecting and
analysing your email activity, this includes email metadata (‘metadata’ means
data that provides information about other data).
Smart Data is created by analysing your emails and prompts you before sending an
email to review things Prevent thinks may be wrong (e.g. wrong attachment, wrong
recipients). Where relevant to the services that you use, this information is
also used for adaptive risk reporting within the Egress Security Centre
Information we control
What it is / means
Where it is stored
CRM Information
the information that we hold about our relationship with you (which includes any
information shared to assist both of us in resolving any questions or support
requests).
UK and EU
System Data
(a) usage statistics, system logs, performance and security data, feedback data,
records of support requests, and aggregated data about how our websites,
services, software, support and apps are used (e.g. performance counters, access
logs, metrics and associated metadata, unique identifiers for devices, technical
information about the devices used, the network, operating system and browsers);
and (b) data identified as malicious (e.g. malware infections, cyberattacks, and
unsuccessful security incidents).
UK, EU, US, Australia
Threat Data
(specific to our Defend service)
Inbound emails and identified data which may be, for example: (a) malicious; (b)
indicative of cyberattack or other threat; or (c) capable of use to exploit
vulnerabilities, conduct malicious activity, malware or ransomware infections,
data theft or unauthorised access, cyberattacks or other activity. This data set
includes data that can be derived from our services for adaptive risk reporting.
UK, EU, US, Australia
Remember, we do not control the countries that you access our services from.
When a user responds to your secure email, their response will be stored where
their service is hosted (which may not be the same as you).
SELLING INFORMATION
We do not sell or rent your personal data to third-parties. This is a concept
that is referred to in a number of State laws in the United States (including
California, Colorado, Connecticut, Utah, Virginia and Nevada). Note that ‘sale’
does not include situations where we disclose personal data at your direction,
or when it is otherwise permitted by law.
SECURITY MEASURES
We put a lot of effort into keeping your personal data secure and confidential.
It is very important to us. We have technical and organisational measures and
tools in place to appropriately protect it. These help prevent accidental,
unauthorised, or unlawful access, use, loss, destruction or damage to it. We use
administrative (e.g. training our employees on privacy and information
security), technical (e.g. pseudonymization or encryption techniques, and the
use of firewalls), and physical (e.g. locks and video surveillance at our office
premises) measures.
Access to your personal data is limited to employees, agents, contractors and
third-parties that we have carefully checked. They only have access where they
have a business need to do so. They will only process personal data on our
instructions and are subject to duties of confidentiality.
Still, no system can be guaranteed to be 100% secure. If you have questions
about the security of your personal data, or if you have reason to believe that
the personal data that we hold about you is no longer secure, please contact us
right away.
THE RIGHTS YOU HAVE IN YOUR PERSONAL DATA
You can find out about the rights you may have in the personal data that we hold
about you here. On that page, you will also find the contact details of our
Data Protection Officer.
OPTING OUT OF MARKETING INFORMATION
If you no longer wish to receive direct marketing emails from us, you may opt
out of receiving these emails by clicking on the ‘Unsubscribe’ link at the
bottom of any marketing email you receive.
DOING YOUR PART
It is important you make sure the personal data that we hold about you (and if
you are a business, your users) is accurate, up-to-date and relevant. Tell us
promptly if there are any changes by emailing us here. Please also make sure
you are legally able to use our services and to process information through them
(in the UK and the EU this is referred to having an identified ‘lawful basis’).
How your personal data is collected
HOW YOUR PERSONAL DATA IS COLLECTED
FROM YOU WHEN YOU
* subscribe to our services
* log into or use your Egress account
* fill out forms on our website or apps
* use our website, apps and services
* communicate with those who use our services (see more on that below)
* contact us
* take part in our competitions and promotions
* attend webinars (we may record our webinars and keep a record of attendees)
* communicate by email with our customers
FROM OTHER PARTIES SUCH AS
* companies or individuals that introduce you to us (like our partners)
* credit reference agencies
* third-party data providers who we purchase information from
* publicly accessible records
* government and law enforcement agencies
* Microsoft where, if you use our add ins, you grant us permission to access
each email you send or receive in order to encrypt or decrypt it (if you use
Protect), process Smart Data (if you use Prevent) and/or Threat Data (if you
use Defend)
* Open Source Intelligence (OSINT) providers such as HaveIBeenPwned
FROM OTHER PARTIES WHO
* use our services
* fill out forms on our website or apps and provide personal data about you
* contact us and provide personal data about you
* fill out forms on websites or webforms that we host on behalf of one of our
customers
* deliver other services to you and who you choose to integrate with our
adaptive risk scoring service within the Egress Security Centre
FROM COOKIES
You can find out more about the cookies on we use on our website in our Cookie
Policy. For information about cookies that we use to deliver our services,
check out our Product Cookie Policy. Some web browsers may transmit
“do-not-track” signals to the websites and online services you communicate with.
Whilst there is no industry standard that governs what, if anything, we should
do if we receive such a signal, our website will not set cookies if your browser
is set to ‘do-not-track’.
IP ADDRESSES
When you visit our website, apps or use our services we record your IP address.
This may be kept in log files or matched against public or proprietary databases
to provide us with information about your visit. It may identify the
organisation to whom the IP address is registered (and in some cases enable us
to identify you).
REMEMBER, IF YOU COMMUNICATE WITH US AND WITH ORGANISATIONS THAT USE OUR
SERVICES
Your emails and their associated metadata will be routinely monitored to protect
against outbound risk (such as misaddressed emails), inbound risk (such as
phishing) and to improve the accuracy of the guidance provided by our services.
This monitoring may include the processing of certain information about you
(e.g. the strength of your association with the sender/recipient, and the
trustworthiness of your domain).
LASTLY, YOU MAY PROVIDE US WITH INFORMATION ABOUT OTHER PEOPLE….
This could be Content which belongs to another person. You must make sure you
have the rights and permission to do so. By providing it, or sending it via, or
uploading it to, our services, you confirm that you do.
How we use your personal data
HOW WE USE YOUR PERSONAL DATA
We use the data that we collect for a few reasons, examples of which are given
below.
MANAGING OUR RELATIONSHIP WITH YOU AND/OR YOUR ORGANISATION
* communicating with you
* retaining appropriate financial and business records
* contacting you in relation to potential sales opportunities, and to
understand you and/or your organisation better
* creating reports or profiles for marketing and analytics purposes
* contacting you and any relevant regulator in the event of a data breach where
required to do so
DELIVERING OUR SERVICES
* providing our service access and support to you including
* providing reporting analytics and risk insights about your organization
* providing guidance on our services
* responding to, and resolving, complaints, queries, requests and support
tickets
* ensuring our services are working properly
* pro-active maintenance and investigations
* alerting you to issues or updates to the services you subscribe to
MEETING OUR CONTRACTUAL OBLIGATIONS OR RIGHTS
* managing payments between us
* meeting and performing our audit obligations
* recovering money owed to us or our group companies
* responding to requests made by you in relation to your information
* exercising our rights under our contract with you or applicable law
LEGAL AND REGULATORY RISK MANAGEMENT
* detecting and preventing crime
* security and operations management
* managing risk for us, our group and our customers and users
* complying with our and our group’s legal obligations
* keeping records accurate and up-to-date
* running our business in an efficient and proper way
INNOVATION AND SERVICE IMPROVEMENT
* identifying new features, functionality and ways to meet customer and user
needs
* studying how customers and users use our websites, apps and services
* creating anonymous reports and statistics
* creating anonymous data sets
* using Threat Data and System Data to improve, update and modify the service
(including any block/allow lists, threat analysis, reports and records)
If you subscribe to our Prevent service, we do not use analysis of your
behaviour (or, you are a business, your users' behaviour) to provide insight to
other organisations and users (this is sometimes called ’cross-tenant insights’)
MARKETING AND PROMOTION
* enabling you to participate in competitions and promotions
* developing and carrying out marketing activities
How we process personal data lawfully
HOW WE PROCESS PERSONAL DATA LAWFULLY
This table shows the main basis we rely on to process personal data. Sometimes
there may be a secondary basis for the same type of processing (like keeping a
financial transaction and then sharing it with authorities). If we share
personal data, we only do so after careful consideration of whether it is
necessary and lawful to do so. We will only share information where we have a
contract with the receiving party which requires them to keep the information
just as secure as if we store it, or where we are legally required to make the
disclosure.
Action
Lawful Basis
Description / examples
Managing our relationship with you and/or your organisation
Contract, Legitimate Interest, Consent, Legal Obligation
Respond to your enquiries; pro-actively and re-actively manage your relationship
with us; contact you; respond to your support calls and complaints; track
engagement; notify you and any relevant regulator where we are legally or
contractually required to do so.
Delivering our services
Contract
Providing you with access to the services you subscribe to; provide guidance;
ensure our services are functioning properly; alert you to updates to your
services.
Adaptive Risk Scoring
Substantial Public Interest
Providing you with a reporting dashboard, when you choose to integrate with
third party sources or one or more of our services, identify likely sources of
risk within your organization
Use of sub-processors
Contract, legitimate interest
Using cloud infrastructure to deliver our services
Meeting our contractual obligations or rights
Legal obligation, Contract
Sending and receiving of payments; recover money owed to us.
Exercising our contractual rights
Legitimate Interest, Legal Obligation
Exercising or enforcing our rights under our agreement with you
Legal and regulatory risk management
Legitimate Interest,
Legal Obligation
Managing regulatory risk
Detect and prevent crime or breach of compliance obligations
Legitimate interest
Enabling us to detect and report criminal activity
Responding to Law Enforcement and obeying our legal obligations
Legitimate Interest, Legal Obligation
Assisting legal authorities where required or responding to legal or regulatory
requests
Innovation and service improvement
Legitimate interest
Identifying new features, functionality and ways to meet customer needs; testing
and releasing new features and functionality; creating anonymous reports and
statistics
Marketing and promotion
Legitimate interest, Consent
Promote and grow our business; creating anonymous reports and statistics;
enabling you to participate in promotions
System Messages
Legitimate Interest
Notification of business updates and renewals
Creating anonymous reports and statistics
Contract, Legitimate Interest
Showing a count of dangerous emails an organisation receives.
Carry out audits
Legitimate Interest,
Legal Obligation
Evidence effective security processes and procedures
How we use automated decision-making
HOW WE USE AUTOMATED DECISION-MAKING
Some of our services make use of machine learning. These services always
involve some kind of meaningful human interaction during the processing
activity. This means that if a particular risk is identified, or action is
carried out, it has been done so by confirmation of a person after being
alerted. That person may be yourself or a member your organisation’s
administrative or security teams setting an allow/deny list. Where we have
verified a particular as a verified risk (such as a malware/ransomware email),
then it may be automatically blocked. In these scenarios an administrator can
always unblock any potential ‘false-positive’ restriction.
Risk scoring uses profiling of a customer organization’s emails using a number
of sources. The scoring is adaptive using the best available information at any
given time. Customers that choose to integrate with additional third party
sources will have an enriched score. This means that by combining public sources
of verified data, the accuracy of risk scoring increases. This information is
presented to customers so they can make informed risk-based decisions. This
might include an admin team choosing to set policy-led decisions being set to
automatically apply. For example, an email with certain keywords may have
encryption enforced.
Who we may share your personal data with
WHO WE MAY SHARE YOUR PERSONAL DATA WITH
SUB-PROCESSORS
You can find details on our Sub-Processors here. These third-parties provide key
services to us that enable us to deliver our services to you or to run our own
business operations. They are only authorised to use your personal data where
this is necessary to provide the services to us that we request from them, and
we have contracts in place with them that require them to comply with applicable
law.
Examples of where they are involved include where they provide:
* hosting platforms (such as Microsoft Azure and Amazon Web Services) which we
use to host our services
* Customer relationship management platforms
* Ticketing, online chat, out-of-hours support calls and other support service
platforms that we use to provide our support services to you
* Multi-factor authentication services
* Mail relay delivery services
* Webinar, conference calls and remote access services
* Digital marketing platforms used to send out marketing communications
* Online editors (such as Microsoft Office Online) embedded in some of our
products
Where personal data is transferred outside of the country or region that you are
located in, we will ensure that it is subject to appropriate legal and technical
safeguards as required by local law.
LAW ENFORCEMENT REQUESTS
We reserve the right to disclose personal data to comply with laws and legal or
regulatory demands which apply to us, our group or our services. You can find
out more on our approach here.
ONLINE PURCHASES
If you purchase a paid-for subscription to our services through our website,
then limited personal data about you and your purchase will be shared with
relevant payment service providers. Personal data may be used by those
providers in accordance with their own privacy policies and terms to complete
your purchase, manage your relationship and any future renewal, and to comply
with applicable law.
TRANSFER OF RIGHTS
We and our group companies reserve the right to transfer obligations, rights and
permissions to any organisation to which we or they may transfer business or
assets. This includes if a third-party is exploring investing in or purchasing
us (or a relevant part of our group or assets).
Other important things to know
OTHER IMPORTANT THINGS TO KNOW
DATA PRIVACY FRAMEWORK
We participate in the EU-U.S. and Swiss-U.S. Data Privacy Frameworks (DPF) and
have self-certified to the U.S. Department of Commerce our adherence to the
Principles for all personal information received from countries in the European
Economic Area, Switzerland, and the United Kingdom in reliance on the DPF. To
learn more about the DPF, visit the website at Program Overview
(dataprivacyframework.gov). If there is any conflict between the terms in this
Privacy Policy and the DPF Principles, the Principles shall apply where it
enables stronger protections.
Under the Data Privacy Framework, we are responsible for the processing of
personal information we receive and subsequently transfer to a third party
acting for or on our behalf. We are liable for ensuring that the third parties
we engage support our DPF commitments. The U.S. Federal Trade Commission has
regulatory enforcement authority over our processing of personal information
received or transferred pursuant to Data Privacy Framework. We commit to
cooperate and comply with the advice of the regulatory authorities to whom you
may raise a concern about our processing of personal information about you
pursuant to Data Privacy Framework, including to the panel established by the EU
authorities and the Swiss FDPIC. This is provided at no cost to you.
If you do not feel that we have resolved your complaint or concern
satisfactorily you can contact our U.S. based third-party dispute provider (free
or charge) at https://https://www.privacytrust.com/drs/open. Under certain
conditions, more fully described on the Data Privacy Framework website, you may
invoke binding arbitration when other dispute resolution procedures have been
exhausted.
COMPLAINTS
If you have a complaint relating to our services you can raise it by emailing us
or by calling +1-800-732-0746 (if you are in North America) or +44 (0) 20 3973
1333 (for anywhere else). Please note calls may be recorded and/or monitored
for quality assurance and compliance purposes. Call recordings are stored in the
United Kingdom.
If your complaint relates specifically to the processing of your personal
information, please email us here.
You may also have the right to make a complaint at any time to a Supervisory
Authority (such as the Information Commissioner's Office (ICO) in the UK). We
would, however, appreciate the chance to deal with your concerns before you
approach a regulator so please contact us in the first instance.
You can find our detailed Complaints Policy at www.egress.com/legal.
ABOUT US
We are Egress Software Technologies Limited, for and on behalf of ourself and
our group of companies. You can find out more details about us
at www.egress.com/about and you can contact us at info@egress.com. When
contacting us we strongly recommend you do not email us confidential or personal
information. If you do, it is at your own risk although the terms of this policy
will apply to our use of that information.
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