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CYBERARK PRIVACY NOTICE



OVERVIEW

This privacy notice (“Privacy Notice”)  describes how CyberArk will process your
personal data, where CyberArk acts as a controller of your personal data;
namely,  in connection with your use of the CyberArk owned and operated websites
including without limitation www.cyberark.com and any of its related or
 subdomains (the “Website(s)“), including the CyberArk portals (such as
Technical Community, Partners Community, Training and Certification Portal and
the Marketplace) (the “Portals“); in connection with certain instances of your
use of CyberArk’s products, services, and other technical applications and tools
(the “Services“), where CyberArk acts as the controller of your personal data;
in connection with CyberArk’s relationship with our business-to-business
contacts, such as with the representatives of our service providers, processors,
or suppliers; and in connection with other occasions where CyberArk collects and
processes your personal data, as further detailed in this Privacy Notice.

References to “we”, “us” or “CyberArk” in this Privacy Notice mean CyberArk
Software Ltd, and any of its affiliated entities, as far as they are related to
the operation of the Websites, the Portals or the Services or as otherwise
relevant under this Privacy Notice. Our contact details for these entities and
their respective office locations can be found here. The CyberArk entity that
will be responsible for processing your personal data will depend on how you use
CyberArk Services and your geographical location.

References to “you” or “your” mean the individual who has or may in the future
enter into a relationship with CyberArk as a user of CyberArk mobile
applications (excluding: (i) when you are using  CyberArk Mobile on behalf of
your employer or customer; or (ii) CyberArk’s Identity mobile application, in
which case CyberArk will be processing the data on behalf of our customer), a
representative of a prospective or existing customer or authorized channel
partner, a user of our Website or Portals, an investor, or otherwise use the
CyberArk Websites or Services. When you are browsing our Websites or using our
Services for your own benefit, CyberArk is the “controller” (as such term is
used in the EU General Data Protection Regulations (“GDPR“) and the “business”
(as such term is used under the California Privacy Rights Act (“CPRA”) of your
personal data.

References to “personal data” mean information that identifies you or is
reasonably capable of identifying you. It also includes similar terms under data
privacy laws, such as “personal information” and “personally identifiable
information.”

If you are an end user of CyberArk Services, this Privacy Notice does not apply
to our processing of your personal data. The controller and/or the business of
your personal data is your employer or the organization to which CyberArk is
providing services and which is a CyberArk customer. CyberArk is the “processor”
or “service provider” of such personal data under the GDPR and CPRA,
respectively. In such case, the processing of the personal data by us is subject
to a data processing agreement between the applicable CyberArk entity and such
customer, and this Privacy Notice does not apply to you.

General

At CyberArk, we pride ourselves on being an organization that has a
privacy-minded culture consistent with legal requirements.

You can contact CyberArk at any time to request more information about the way
we process personal data by using this form or sending an email
to privacy-request@cyberark.com. We will respond to your request in the
timescales prescribed by applicable laws.

You should read this Privacy Notice in conjunction with the terms and conditions
of the Website, or in conjunction with the terms and conditions applicable to
you in the specific context.

WHAT PERSONAL DATA DOES CYBERARK PROCESS AND FOR WHAT PURPOSES?

The following describes the types of personal data that CyberArk processes about
you, in which instances this personal data is collected and processed, the
purposes of processing, and the lawful bases for processing (where the GDPR
applies). We collect the personal data described below from you or the company
you represent during your interactions with us.

WHEN YOU USE ONE OF OUR WEBSITES

Instance of data collection Personal Data Processed Purposes of Processing
Lawful Bases for processing where the GDPR applies When you browse our Websites
• Names, usernames or similar identifiers used on our Websites
• information from your web browser (such as browser type and browser language),
your Internet Protocol (“IP”) address, internet service provider (“ISP”),
operating system, date/time stamp, clickstream data and analytics data regarding
the actions you take on the Websites (such as the web pages viewed and the links
clicked on) • Administer our Websites
• provide you with relevant website content
• measure the effectiveness of the content served to you and of our marketing
efforts
• analyze and improve the use of the Websites
• provide more relevant and personalized information, promote our business in
various platforms and assess the success of our promotional activities
• fraud prevention and security of our Websites Our legitimate interests in
monitoring and improving our Websites and/or your consent where necessary under
applicable law. When you submit a contact form or request a demo form through
the Websites, download any whitepapers or other downloadable materials from the
Websites, and/or when you subscribe for a free trial • First and last name,
email address, telephone number, company name, role, job title, department, and
country • To reply to your request or query
• to set up a demo at your request
• to send the requested materials to you, if requested
• to send you communications related to our products, services, and/or events
through different channels Our legitimate business interests and/or your consent
where necessary under applicable law (e.g. where you have provided your consent
for CyberArk or our Partners to send you marketing communications).

WHEN YOU USE OUR PORTALS (EITHER AS A REPRESENTATIVE OF A CUSTOMER/PROSPECTIVE
CUSTOMER, CHANNEL/ALLIANCE PARTNER, OR A PROSPECTIVE CHANNEL/ALLIANCE PARTNER

Instance of data collection Personal Data Processed Purposes of Processing
Lawful Bases for processing where the GDPR applies When you set up an account in
our Portals • First and last name, telephone number, mobile phone number,
country, language, email address, job function, organization, and address • To
set you up as an authorized user of the Portal and create a user profile for you
• to manage and administer your use of the Portals
• to send you communications (including marketing) related to our products,
services or events via different channels
• to operate our business, for example, transmitting your personal data within
the CyberArk group for internal administrative purposes, such as auditing and
accounting Our and/or our customers’ legitimate business interests and/or your
consent where necessary under applicable law (e.g. where you have provided your
consent to be included in our marketing mailing lists) When you log into and use
our Portals • Credentials used to log into our Portals
• Browser type and browser language, referring URL, your IP address, ISP,
operating system, date/time stamp, and clickstream data and the actions you take
on the Portals (such as the web pages viewed, the links clicked on and searches
performed) • To provide you with support and training related to the Portals
• to understand how our partners/customers use the Portals and analysis thereof
for the purpose of monitoring and improvement of Portals
• measure the effectiveness of the content served to you
• to send you communications (including marketing) related to our products,
services or events via different channels Our and/or our customers’ legitimate
business interests and/or your consent where necessary under applicable law
(e.g. where you have provided your consent to be included in our marketing
mailing lists)

WHEN YOU DOWNLOAD AND USE CYBERARK MOBILE (EXCLUDING WHEN YOU ARE USING THE
APPLICATIONS ON BEHALF OF YOUR EMPLOYER OR CUSTOMER)

 

Instance of data collection Personal Data Processed Purposes of Processing
Lawful Bases for processing where the GDPR applies When you set up an account
for use of any of our Services • First name, last name, phone number, phone
model and operating system, and, if you choose to provide this, a profile
picture • To allow you access to the services, in accordance with the specific
functionality for which you have access rights and authorizations
• provide technical support
• measure our marketing efforts and performance
• to operate our business, for example, transmitting your personal data within
the CyberArk group for internal administrative purposes, such as auditing
• to notify you about transactional issues, or other issues relating to CyberArk
services (such as new features, version releases) or invitations to our
customers related events Fulfilment of our contractual obligation
Our legitimate business interest

WHEN YOU ATTEND A CYBERARK HOSTED OR SPONSORED PHYSICAL OR VIRTUAL CONFERENCE OR
EVENT

Instance of data collection Personal Data Processed Purposes of Processing
Lawful Bases for processing where the GDPR applies When you register to the
event • First and last name, email address, telephone number, company name,
role, job title, department, and country • To set you up as a registered
participant in the event
• to manage and administer your participation in the event including sending
your communications related to your attendance
• to send you communications (including marketing) related to our products,
services or events via different channels
• to operate our business, for example, transmitting your personal data within
the CyberArk group for internal administrative purposes, such as auditing and
accounting Fulfilment of our contractual obligation, our legitimate business
interest and/or your consent where necessary under applicable law When you log
into the event and during the event in which you participate (online events) •
Log in and out time, time spent, any information that you choose to provide for
networking purposes, and chat stream • To manage and enable your access to the
event
• to provide you with technical support related to the event
• to keep records regarding our events and analysis thereof for the purpose of
planning of future events
• to improve our understanding of your needs and interests
• understand how you and other participants benefit from the events, including
to assess which content is the most useful
• to send you communications (including marketing) related to our products,
services or events via different channels Fulfilment of our contractual
obligation, our legitimate business interest and/or your consent where necessary
under applicable law During the event in which you participate (in person)
Business card information • To send you communications (including marketing)
related to our products, services or events via different channels Fulfilment of
our contractual obligation, our legitimate business interest and/or your consent
where necessary under applicable law

WHEN WE OTHERWISE COMMUNICATE WITH YOU WHEN YOU ARE OR WHEN YOU REPRESENT A
PROSPECTIVE CUSTOMER/CUSTOMER/PARTNER/INVESTOR OR IF WE CONDUCT BUSINESS
DEALINGS WITH YOU IF YOU REPRESENT A SERVICE PROVIDER, CONTRACTOR, PROCESSOR OR
SUPPLIER

Instance of data collection Personal Data Processed Purposes of Processing
Lawful Bases for processing where the GDPR applies When we request and you
submit feedback to a survey, for example, following closing of a support ticket,
delivery of our services or following training; • Your responses to the survey •
To consider your feedback and assess the level of service we have provided, and
to improve our processes and services
• follow-up with you depending on the nature of your feedback Our legitimate
business interests including as necessary for the performance of the contract
with the relevant customer/partner/investor When delivering communications to
you (including marketing communications and advertising) • Your email address,
display name of your email account, information about your interactions with our
communications (e.g. links clicked on) =, actions that you take on our and our
partners’ websites such as your visits or interactions with such websites • To
monitor and analyze electronic communications sent or received by our users,
including to tailor our communications accordingly and measure our marketing
efforts
• security and fraud prevention
• to cater to your requests, for example, to reply to your inquiry, arrange a
meeting for you, arrange a demo for you, etc.
• measure the effectiveness of our (online) advertising, improve our marketing
practices, and helps us deliver more relevant communications and advertising to
you and people like you (including on social media) Our legitimate business
interests and/or your consent where necessary under applicable law When you
conduct business dealings with us as a representative of a service provider,
contractor, processor or supplier • Your contact information, such as name,
title, company name, email address, address, and phone number • To enter into
and perform under a contract providing us certain services
• to communicate with you about potential business dealings Fulfilment of our
contractual obligation, our legitimate business interest, and/or your consent
where necessary under applicable law

In addition to the above, under some circumstances we may collect and process
other types of personal data; in these cases, we will provide an in-time
notification with respect to the additional personal data collected and
processed.

In addition to the above uses of your personal data, we will also process your
personal data for the following purposes:

 1. To prevent, detect and fight fraud or other illegal or unauthorized
    activities
 2. To ensure legal compliance – from our side (to legal requirements that apply
    to us (such as various records keeping) and to our obligations under the
    Terms of Use) and from your side (compliance with laws applicable to you and
    with the Terms of Use)
    For some of the above processing, we may rely on multiple legal grounds. For
    example, we process some information both for our legitimate interests as a
    business regarding user compliance with applicable terms of use and to
    comply with legal obligations applying to us (GDPR Article 6(1)(f) and
    6(1)(c)).

HOW WILL CYBERARK DISCLOSE YOUR PERSONAL DATA WITH OTHER PARTIES?

We may disclose your personal data with other parties when outsourcing certain
tasks or processes to service providers or subcontractors, whether in relation
to our services, website operation or internal requirements. We use the
following categories of service providers or contractors who are only authorized
to process your personal data as necessary to provide these services to us:

 * Relationship management software
 * Marketing automation platform
 * Webinar software
 * E-mail platforms
 * Hosting provider, including website hosting
 * Customer success software
 * Online community platforms
 * Human Resources Information Systems
 * Background check service providers
 * Analytics providers
 * Customer reference management software
 * Survey tool service providers
 * Learning management system software

We may also disclose your personal data with our partners when we run or sponsor
events with them and with social media and/or advertising companies to
personalize our communications and your experience on our and other websites.
These third parties may also disclose your personal data with us where you have
provided your information to them, and they have the right to disclose this
information to us under applicable law. This includes contact details and other
identifiers.

For CyberArk’s applications available on the Google Play Store, our use and
transfer of information received from Google APIs to any other app will adhere
to Google API Services User Data Policy, including the Limited Use requirements.

Where you are a member of staff at a CyberArk Customer or Partner and you
register for a CyberArk event, this information may be shared with that Customer
or Partner.

We may use or disclose personal data if required by applicable law or if we
reasonably believe that use or disclosure is necessary to protect our rights,
protect your safety or the safety of others, investigate fraud and/or to comply
with a judicial proceeding, court order, legal process or other governmental
authority; provided, however, that unless prohibited by law, we will use
reasonable efforts to give you notice to enable you to seek a protective order
or take other appropriate action.

We may also disclose your information to third parties in and outside your
country only to the extent allowed by applicable law. We may also transfer your
information if we sell, buy, merge or partner with other companies or
businesses, undergo a reorganization, bankruptcy, or liquidation; or otherwise
undertake a business transaction or sell some or all of our assets. In such
transactions, your information may be among the transferred assets.

PROCESSING DATA OUTSIDE OF EUROPEAN ECONOMIC AREA (“EEA”)

Where information is transferred outside the EEA, and where this is to a
stakeholder or vendor in a country that is not subject to an adequacy decision
by the European Commission data is adequately protected by European Commission
approved standard contractual clauses or a vendor’s Binding Corporate Rules.

HOW LONG WILL CYBERARK STORE YOUR PERSONAL DATA?

We will retain your personal data for such periods of times required or
permitted by law or subject to our retention policies as may be in place from
time to time. CyberArk takes the following considerations into account in order
to determine the retention period:

 * The time required to retain personal data to fulfill business purposes,
   including providing products and services
 * Maintaining corresponding transaction and business records
 * Controlling and improving the performance and quality of the Websites
 * Handling possible user queries or complaints and locating problems
 * Whether the user agrees to a longer retention period
 * Whether we reasonably believe that this data will be needed for the handling
   of any litigation
 * Whether the laws, contracts, and other equivalencies pose any requirements
   for data retention.

SECURITY OF PROCESSING

We will maintain administrative, physical and technical safeguards designed to
protect the security, confidentiality and integrity of your personal data
processed by us as part of your use of our products/services, our Websites and
any other aspects of our business as described in this Privacy Notice; and will
not materially decrease the overall security of such items. However, no method
of data security is 100% effective. Therefore, we cannot guarantee or warrant
its absolute security.

CHILDREN

Our Websites, Portals and Services are not intended for or directed at children
under the age of 18. In addition, we do not knowingly collect personal data from
children under the age of 18.

COMMUNITY FORUMS

CyberArk provides community forums on some of the Company’s Websites, Portals or
Services. Any personal data you choose to submit in such a forum may be viewed
by others who visit these forums. CyberArk is not responsible for any misconduct
by any person or entity of any personal data you choose to submit in these
forums.

ADDITIONAL TERMS WHICH APPLY WHERE YOU ARE A PARTNER USING CYBERARK’S PORTALS

If you submit a Deal Registration Form via the Portal, we will also collect the
following information: corporate name of end customer and contact details for
your point of contact within the end customer (including name, job title and
address).

Any marketing consents opt-ins/opt-outs or other preference details provided to
us in connection with another website or service operated by us (such as the
CyberArk community or our transactional websites) will be recorded and
administered separately from any preferences or consents provided in connection
with the Portal. You have the option to change your preferences registered in
connection with any of our Websites or Services at any time.

If you are an authorized channel partner and no longer want us to contact you
related to marketing events or information, please contact us
at channel@cyberark.com.

YOUR CHOICES, RIGHTS AND INSTRUCTIONS

You may contact us at any time by completing this form, or sending an email to
privacy-request@cyberark.com to request to fulfill any of your rights in
relation to your personal data, depending on the laws applicable to you. We will
respond to your request in the timescales prescribed by the relevant local laws.

Depending on your location (e.g., if you are a California resident or in the
United Kingdom, Switzerland, or European Economic Area) and on the laws that are
applicable to you (e.g., CPRA or GDPR), you may be entitled to some or all of
the following rights:

The right to access – You have the right to request CyberArk for copies of your
personal data, which includes the right to obtain confirmation as to whether or
not personal data concerning you are being processed.

The right to rectification/correct – You have the right to request that CyberArk
rectify or correct any information you believe is inaccurate. You also have the
right to request CyberArk to complete the information you believe is incomplete.

The right to erasure/deletion – You have the right to request that CyberArk
erase/delete your personal data, under certain conditions.

The right to restrict processing – You have the right to request that CyberArk
restrict the processing of your personal data, when: (a) you contest the
accuracy of your personal data, for a period allowing CyberArk to verify the
accuracy of said data; (b) if you believe personal data has been unlawfully
processed and you wish to restrict processing rather than delete it; (c)
CyberArk no longer needs the personal data but you require to keep it in order
to establish, exercise or defend a legal claim; or (d) you have exercised your
right to object to the processing (below) for a period allowing CyberArk to
consider whether your legitimate grounds override those of CyberArk.

The right to object to processing – You have the right to object to the
processing of a part or all of your personal data at any time. When relating to
processing for marketing purposes, you have an absolute right to object; while
for other purposes, the existence of the right depends on what lawful basis the
processing relies on and on the existence of our compelling legitimate grounds
to continue the processing.

The right to data portability – You have the right to request that CyberArk
transfer the data that we have collected to another organization, or directly to
you, under certain conditions. This includes receiving your personal data in a
portable, structured, commonly used, and machine-readable format so that you may
transmit the data to another entity without hindrance.

The right not to be discriminated against – You have the right not to be
discriminated against for exercising any of your privacy rights, which includes
us not: (i) denying you goods or services; (ii) charging you different prices or
rates for goods or services, including through the use of discounts or other
benefits or imposing penalties; (iii) providing you a different level or quality
of goods or services; (iv) suggesting to you that you will receive a different
price or rate for goods or services or a different level or quality of goods or
services; and (v) retaliating against you for exercising your privacy rights.

If allowed by applicable laws, you have the right to withdraw your consent at
any time when CyberArk processes your personal data based on your consent.
However, withdrawal does not affect the legitimacy and effectiveness of how we
process your personal data based on your consent before the withdrawal is made.

Although we will make reasonable efforts to accommodate your requests, in some
circumstances we may deem your request unfounded or not eligible under
applicable law. In such instances we reserve the right to refuse your request.
We may require, as pre-requisite to fulfilling any request, to verify your
identity which we may do by asking you to provide certain information or
identification to ensure that all data subjects’ privacy is protected. We may
charge you a small fee for the exercise of some of your rights under certain
conditions and if permitted by applicable laws.

You may also exercise your privacy rights through an authorized agent. If we
receive your request from an authorized agent, we may ask for evidence that you
have provided such agent with a power of attorney or that the agent otherwise
has valid written authority to submit requests to exercise rights on your
behalf. If you are an authorized agent seeking to make a request, please email
us at privacy-request@cyberark.com. We will ask for further information
confirming your authority to act on behalf of the person you represent once we
receive your request.

While we would always appreciate the chance to deal with your concerns before
you approach an external regulator, you can also contact a data protection
supervisory authority in any of the countries in which CyberArk is established
and/or the country in which you are based, such as the Information
Commissioner’s Office in the United Kingdom, and lodge a complaint. You can
obtain the contact information for all of the EEA data protection authorities at
https://edpb.europa.eu/about-edpb/board/members_en.

HOW CAN YOU OPT-OUT OF RECEIVING MARKETING COMMUNICATIONS FROM CYBERARK?

To opt-out of receiving communications relating to marketing, events or
promotions from CyberArk, you can contact us at any time by completing this form
or sending an email to privacy.request@cyberark.com. Please note that if you are
an existing customer then we may need to retain business contact information in
order to provide you with CyberArk services, however, this will not be used for
marketing purposes.

HOW WILL YOU KNOW IF CYBERARK UPDATES THIS STATEMENT?

We will make periodic updates to our Privacy Notice via this statement and will
note the date the then-existing version takes effect. If you have any queries
concerning such changes then please contact us via privacy-request@cyberark.com.

HOW DOES CYBERARK USE COOKIES IN RELATION TO YOUR USE OF THE WEBSITES AND
PORTALS?

What are cookies?

A cookie is a very small text document, which often includes a unique
identifier. Cookies are created when your browser loads a particular website.
The website sends information to the browser which then creates a text file.
Every time the user goes back to the same website, the browser retrieves and
sends this file to the website’s server. Find out more about the use of cookies
at www.allaboutcookies.org.

We also use other forms of technology which serve a similar purpose to cookies,
and which allow us to monitor and improve our Websites. When we talk about
cookies, this term includes these similar technologies.

What cookies do we use and what information do they collect?



Category Purpose Required cookies These cookies are required to enable core
functionalities of our Websites. Without these cookies, services you have asked
for, like identifying you while you are logged in, cannot be provided. If you
disable these cookies certain parts of the Websites will not function for you.
Functional cookies These cookies help us improve, analyze or optimize the
experience we provide. In particular, these allow us to measure how visitors
interact with our Websites and we use this information to improve the user
experience and performance of our Websites. These cookies are used to collect
technical information such as the number of pages visited, which parts of our
website are clicked on and the length of time between clicks. Advertising
cookies We use these cookies to collect information about your browsing habits
in order to make advertising more relevant to you and your interests. They are
also used to limit the number of times you see an advert as well as help measure
the effectiveness of an advertising campaign.  We may share this information
with other parties who help manage online advertising – please see the “Third
Parties” section below for more details.

Third parties

Your use of our Websites may result in some cookies being stored that are not
controlled by us. This may occur when the part of the Websites you are visiting
makes use of a third party analytics or marketing automation/management tool or
includes content displayed from a third party website.

How do you manage these technologies?

If you want to delete any cookies that are already on your device, please refer
to the help and support area on your internet browser for instructions on how to
locate the file or directory that stores cookies.

To manage your cookie consent preferences, please click here.

NOTICE FOR CALIFORNIA RESIDENTS

This section is only applicable to California residents for purposes of
compliance with the CPRA and other California privacy laws. The CPRA requires
businesses like CyberArk to provide certain disclosures and offer certain rights
in their privacy policies.

You can learn more about these rights and how to exercise them in the Your
choices and rights and instructions section above.

Prior 12-month personal information handling practices

You can find a list of the categories of personal information we collect as well
as the purposes for which we use it under the section entitled What personal
data does CyberArk process and for what purposes? This also covers the instances
and sources from which we obtain your personal information.

For additional details regarding how we disclose personal information to third
parties please see the above section entitled How will CyberArk disclose your
personal data with other parties?

Selling or Sharing of Personal Information

Our use of tracking technologies may be considered a “sale”/ “sharing” under
California law. You can opt-out of being tracked by these third parties by
clicking the “Cookie Choices” link at the bottom of our website and selecting
your preferences.

You can also contact us at privacy.request@cyberark.com or by completing this
form.

Additional Disclosure for California Residents

California law permits residents of California to request certain details about
how their information is disclosed to third parties for direct marketing
purposes. If you are a California resident and would like to make such a
request, please email us at privacy.request@cyberark.com.

CALIFORNIA AND DELAWARE “DO NOT TRACK” DISCLOSURES

CyberArk does not monitor or respond to Do Not Track browser requests. Hence
please ensure to change any settings of your browser and/or our Services,
whenever you wish cookies to cease.

Contacts

You may contact CyberArk’s Data Protection Office and make the relevant requests
permitted pursuant to applicable law by completing this form or sending an email
to privacy.request@cyberark.com

Last Updated: June 1st 2023





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