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PRIVACY POLICY
Effective July 20, 2020 (view archived version)
This privacy policy (“Policy”) explains how information is collected, used and
disclosed by ZeroFox and applies to information collected when you access or use
our public websites, including at www.zerofox.com (collectively, “Sites”), when
you use our cloud-hosted social media and digital protection products and
services, including those at cloud.zerofox.com and protect.zerofox.com
(collectively, “Services”), or when you attend a ZeroFox event or otherwise
interact with us.
1. WHO “WE” ARE
When we say “ZeroFox,” “we,” “us” or “our” in this Policy, we are referring to
ZeroFox, Inc., a Delaware (US) corporation, however this Policy also applies to
our affiliated companies, including ZeroFox UK Ltd (organized under the laws of
England and Wales) and ZeroFox Chile SpA (organized under the laws of Chile).
2. WHO “YOU” ARE
When we say “you,” we are referring to a customer, to a visitor to our Sites or
to a participant at a ZeroFox event or activity, such as conference attendee. A
“customer” is an entity or organization that has acquired a subscription to
ZeroFox for Business Services (“business customer”), or an individual that has
acquired a subscription to ZeroFox for Everyone Services.
3. SCOPE OF POLICY
In addition to describing our practices for collecting, using and disclosing
personal information, this Policy describes the rights individuals have to
control the use of their personal information. When we say “personal
information” in this Policy we are referring to any information relating to an
identified or identifiable natural person, which may include the individual’s
name, identification number, location data, email address, social media handle
or other online identifier. If you use the Services through a business customer
(like your employer), the terms of the customer’s contract for the Services may
restrict our collection or use of your personal information more than what is
described in this Policy.
4. CHANGES TO POLICY
We may change this Policy from time to time. The most recent version of the
Policy is reflected by the date at the top of this Policy. All updates and
amendments are effective immediately upon notice, which we may give by any
means, including by posting a revised version of this Policy or other notice on
the Site. We encourage you to review this Policy often to stay informed of
changes that may affect you. Your continued use of the Sites or Services
signifies your ongoing acknowledgment of this Policy.
5. CONTACTING US
Please contact us with any questions or comments about this Policy, including
questions around how we process your personal information. You can reach us by
email at privacy@zerofox.com or by postal mail at ZeroFox, Inc., Attn: Privacy,
1834 S Charles St, Baltimore, MD 21230 USA.
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INFORMATION COLLECTED
The following paragraphs 6 through 10 describe the personal information we
collect.
6. INFORMATION YOU PROVIDE TO US
When you register for or use the Services, modify your Services account, consult
with our customer support or success teams, send us an email, participate in any
interactive features of the Sites or Services, participate in a survey,
participate in a contest, participate in a ZeroFox activity or event, apply for
a job, integrate the Services with another website or service, or communicate
with us in any way, you are voluntarily giving us information that we collect.
The types of personal information we may collect directly from you include your
first name, last name, picture, employer name, job title, industry, username,
email address, phone number, physical address, social media handle and IP
address. In cases where we ask you for certain information, for example when
completing a form requesting a whitepaper, we will tell you what information is
required. If you are a customer, we also store the information that you provide
to the Services, which in the case of a business customer includes the
information types listed above with respect to the business customer’s
personnel.
7. INFORMATION COLLECTED FOR AND BY OUR CUSTOMERS
If you are a customer using the Services, you may process personal information
that you have collected from your own personnel (if a business customer) or
other individuals. You are responsible for making sure that you have
appropriate permission for us to collect and process information about those
individuals. If you are an employee or contractor of one of our business
customers, please contact that business customer directly to update or delete
your information. If you contact us, we will provide notice to our business
customer of your request. If you are an EU resident, please refer to paragraph
23 for additional detail.
8. INFORMATION WE COLLECT FROM YOUR USE OF SERVICES
We receive information about how and when you use the Services, store it in log
files or other types of files associated with your account, and link it to other
information we collect about you. This information includes, for example, your
IP address, time, date, browser used, and actions you have taken within the
application. This type of information helps us to improve our Services for both
you and for all of our users.
9. INFORMATION WE COLLECT AUTOMATICALLY
When you access the Services or browse our Sites, we collect information about
your visit, your usage of the Services and your web browsing. That information
may include your IP address, your operating system, your browser ID, your
browsing activity and other information about how you interacted with the Sites
or other websites. We may collect this information as a part of log files as
well as through the use of cookies or other tracking technologies. Our use of
cookies and other similar technologies, such as Google Analytics, is discussed
more detail in our Cookie Statement.
Keep Reading
* We (including service providers working on our behalf) use various
technologies to collect and store information when you use our Sites or
Services. This includes using cookies and similar tracking technologies on
our Sites, such as pixels and web beacons, to analyze trends, administer the
website, track users’ movements around the Site, serve targeted
advertisements and gather demographic information about our user base as a
whole. Users can control the use of cookies at the individual browser
level. More information on disabling cookies on the most popular browsers
can be found here for Google Chrome, here for Microsoft Internet Explorer,
here for Microsoft Edge, here for Apple Safari, here for Mozilla Firefox and
here for Opera.
* We partner with third parties to manage and serve our advertising on other
websites. Our third-party partners may use cookies or similar tracking
technologies in order to provide you advertising or other content based upon
your browsing activities and interests. If you wish to opt out of
interest-based advertising, you can visit TrustArc’s publicly available tool
here for support, as well as other industry resources for the United States,
Canada and the European Union. Please note that none of these tools or
resources or provided by ZeroFox and that you might continue to receive
generic ads even after submitting opt-outs.
* We use pixel tags on our Sites and in our emails. When we send emails, we may
track behavior such as who opened the emails and who clicked the links. This
allows us to measure the performance of our email campaigns and to improve
our features for specific segments of customers. To do this, we include
pixel tags (also referred to as web beacons, clear gifs, and single-pixel
gifs), in emails we send. Pixel tags allow us to collect information about
when you open the email, your IP address, your browser or email client type,
and other similar details.
* Please note that “do not track” is a standard that is currently under
development. Because it is not yet finalized, while some features of our Site
and Services may have the ability to monitor or following do not track
browser requests, we do not commit to following any do not track browser
requests, but do adhere to the standards in this Policy.
10. INFORMATION FROM OTHER SOURCES
From time to time we may obtain personal information about you (or in the case
of business customers, your personnel) from third party sources, such as public
databases, social media platforms, third party data providers and our joint
marketing partners. We take steps to ensure that such third parties are legally
permitted or required to disclose such information to us. We use this
information, alone or in combination with other information (including personal
information) we collect, to enhance our ability to provide relevant marketing
and content to you and to develop and provide you with more relevant products
features, and services.
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11. HOW WE USE INFORMATION
We may use and disclose personal information described in this Policy only to:
* provide, operate, maintain and support the Services;
* send system alert messages, for example, we may inform you of temporary or
permanent changes to our Services, such as planned outages, new features,
version updates, releases, abuse warnings and changes to this Policy;
* communicate with customers (and business customers’ personnel) about their
accounts and provide customer support, training and other requested services;
* bill and collect money owed to us by customers, including sending emails,
invoices, receipts, notices of delinquency and alerting customers if a
different credit card number is needed (we use third parties for secure
credit card transaction processing, and we send billing information to those
third parties to process your orders and credit card payments);
* enforce compliance with our Acceptable Use Policy, our other agreements with
a customer, and/or applicable law, which may include tools and algorithms
that help us prevent violations;
* protect the rights and safety of our customers and third parties, as well as
our own;
* respond to lawful requests by public authorities, including to meet national
security or law enforcement requirements;
* meet legal requirements, including complying with court orders, valid
discovery requests, valid subpoenas, and other appropriate legal
mechanisms;prosecute and defend a court, arbitration, or similar legal
proceeding;
* provide information to our professional advisors and representatives, such as
attorneys and accountants, to help us comply with legal, accounting or
security requirements;
* in the case of personal information of our employees, perform human resources
activities such as onboarding, training and payroll;
* improve our products, technology and Services, including for example,
aggregating information from your use of the Services or visits to our Sites
and sharing this information with third parties to improve the Services and
Sites;
* send you informational and promotional content in accordance with your
marketing preferences (provided you have not unsubscribed from promotional
emails);
* promote use of our Services to you and others, for example to suggest
additional features of our Services that you might consider using (again,
provided you have not unsubscribed from promotional emails);
* process and deliver contest or sweepstakes entries and awards;
* transfer your information in the case of a sale, merger, consolidation,
liquidation, reorganization, or acquisition, provided that (1) any acquirer
will be subject to our obligations under this Policy, including your rights
to access and choice and (2) we will notify you of the change either by
sending you an email or posting a notice on the Sites; and
* link or combine personal information with other information we collect or
obtain about you (such as information we source from our third party
partners), to serve you specifically, such as to deliver Services according
to your preferences or restrictions, or for advertising or targeting purposes
in accordance with this Policy. (Any combination of personal information with
other information is treated as personal information under this Policy.)
12. SHARING INFORMATION WITHIN OUR GROUP AND WITH OUR SERVICE PROVIDERS
We are headquartered in the United States and operate internationally. For
example, certain personal information described in this Policy may be shared
with our affiliated companies, ZeroFox UK Ltd, ZeroFox Chile SpA and ZeroFox
India Pvt Ltd, and consequently accessible to our personnel in the United
Kingdom, Chile, and India, respectively. We also share personal information
described in this Policy with third-party vendors and service providers who are
working on our behalf and require access to your information to carry out that
work. For example, ZeroFox currently uses cloud services from Amazon Web
Services and Google for the infrastructure of its cloud-hosted Services. These
service providers are authorized to use your personal information only as
necessary to provide services to ZeroFox and/or the Services and are bound to
contractual obligations to maintain the confidentiality of your information.
Many of these service providers, like us, are headquartered in the United States
and operate internationally. Accordingly, you should be aware that your
personal information may be processed in countries other than your country of
residence, and that those countries may have different privacy and data
protection laws than where you reside.
13. SAFEGUARDING PERSONAL INFORMATION
We take reasonable and appropriate measures to protect personal information from
loss, misuse and unauthorized access, disclosure, alteration and destruction,
taking into account the risks involved in the processing and the nature of the
personal information. However, no means of processing of personal information
is 100% secure and while we comply with our legal obligations, we cannot
guarantee absolute security.
14. INFORMATION CHANGES AND RETENTION
If you are a customer, you may update, correct or delete personal information
about you (or your personnel, if a business customer) by logging into your
online account and modifying your information or by emailing us. We will retain
personal information that we process on behalf of our customers for as long as
the customer’s account is active and as may otherwise be appropriate to fulfill
the purposes outlined in this Policy, for example to comply with legal
obligations, resolve disputes, prevent abuse and enforce agreements.
15. SOCIAL MEDIA
(This paragraph applies to our public Sites, not the features or functionality
of the Services.) Our Sites may include social media features. These features
on our Sites may collect information about your IP address and which page you
are visiting on our Site, and they may set a cookie to make sure the features
function properly. Additional information on cookies set by social media
providers is provided in our Cookie Statement. Social media features and widgets
are either hosted by a third party or hosted directly on our Site. We also
maintain presences on social media platforms. Any information, communications,
or materials you submit to us via a social media platform is done at your own
risk without any expectation of privacy. We cannot control the actions of other
users of these platforms or the actions of the platforms themselves. Your
interactions with those features and platforms are governed by the privacy
policies of the companies that provide them.
16. COMMUNITY FORUMS AND BLOGS
We may have public blogs or other forums on our Sites from time to time. Any
information you include in a comment on a public blog may be read, collected and
used by anyone. To request removal of your personal information from our blogs
or testimonials, contact us at the email address listed above. In some cases, we
may not be able to remove your personal information, in which case we will let
you know if we are unable to do so and why.
17. LINKS TO THIRD-PARTY SITES AND SERVICES
Our Sites and Services include links to, or integrations with, other sites and
services whose privacy practices may be different from ours. If you submit
personal information to any of those sites or services, your information is
governed by their privacy policies.
18. INDIVIDUALS UNDER THE AGE OF 18
Neither the Sites nor the Services are intended for use by individuals under 18
years of age. No one under age 18 may provide any information on or through the
Sites or the Services. We do not knowingly collect personal information of
individuals under 18. If a parent or guardian becomes aware that his or her
child, who is under 18, has provided us with information, he or she should
contact us.
19. NOTICE FOR CALIFORNIA RESIDENTS
California Civil Code section 1798.83 permits California residents to request
certain information regarding our disclosure of personal information to third
parties. To make such a request, please contacts us as provided in paragraph 5.
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NOTICES FOR EUROPEAN UNION RESIDENTS
20. TRANSFERS OF PERSONAL INFORMATION FROM THE EUROPEAN UNION TO THE UNITED
STATES
As noted above, we, and many of our service providers, are headquartered in the
United States and operate internationally. In addition to ensuring those
providers are bound by restrictions on use and disclosure of personal
information, our agreements with them also reflect the legal mechanisms in place
to ensure the transfer of personal information is in compliance with European
data protection law, typically EU-U.S. Privacy Shield certification or standard
contractual clauses (also known as model clauses).
21. EU DATA PROCESSING ADDENDUM
We are committed to only processing personal information in compliance with
applicable privacy and data protection law, which may include the General Data
Protection Regulation 2016/679 of the European Parliament and of the Council of
27 April 2016 on the protection of natural persons with regard to the processing
of personal data and on the free movement of such data (“GDPR”). Our business
customers processing the personal information of EU residents may request our
personal data processing addendum which incorporates the standard contractual
clauses, in addition to (or instead of, as applicable) relying on ZeroFox’s
EU-U.S. Privacy Shield certification (discussed in paragraph 27 below).
22. CONTROLLERS, PROCESSORS AND YOUR GDPR RIGHTS
Under the GDPR, a “processor” is a person or entity that processes personal
information on behalf of the controller, and the “controller” is the person or
entity that determines how and why personal information is processed. This
distinction recognizes that not all persons or entities involved in the
processing of personal information have the same degree of responsibility. In
that vein, controllers are typically primarily responsible for managing EU
residents’ exercises of their rights under GDPR (“data subject rights”). Data
subject rights include, among others, an individual’s right to access, correct,
restrict processing of and/or delete his or her personal information.
23. OUR ROLE AS A PROCESSOR FOR BUSINESS CUSTOMERS
In the case of our business customers, the Services are intended to be used and
managed by the business customer. In general, we are collecting and processing
personal information in connection with a business customer’s use of the
Services on behalf of that customer. In that case, the business customer is
acting as the controller and ZeroFox is acting as a processor according to the
business customer’s instructions. If you are an EU resident and believe ZeroFox
is processing your personal information on behalf of a business customer, and
you would like to exercise your data subject rights, please start by contacting
the business customer.
24. OUR ROLE AS A PROCESSOR FOR INDIVIDUAL CUSTOMERS
If you are an individual EU customer using ZeroFox for Everyone Services, you
are the controller of the personal information that you process through our
Services. Individual customers may access, correct, restrict processing of and
delete that personal information through the functionality of the Services. If
you have additional questions, please contact us as provided in paragraph 5.
25. OUR ROLE AS A CONTROLLER
In other cases, such as personal information used by ZeroFox for management of a
customer’s account, invoicing and marketing, ZeroFox will be the controller with
respect to personal information. If you are an EU resident, in situations where
we are the controller of your personal information and you would like to
exercise your data subject rights, please contact us as provided in paragraph 5.
26. LEGAL BASES FOR PROCESSING
The GDPR requires that personal information be processed lawfully and outlines
specific legal bases for processing. We describe in paragraphs 6 through 10
above the personal information we may collect, and in paragraph 11 how we may
use it. The legal bases under the GDPR for those uses depends on the personal
information collected and the context of its collection. ZeroFox has determined
a basis for each use, including:
* performing a contract, or taking steps linked to a contract, such as
providing the Services to you if you are an individual customer;
* subject to our interests not being overridden by your interests and
fundamental rights and freedoms, pursuing legitimate interests in the conduct
of our business, such as processing the data of our EU employees;
* processing your personal information where you have provided consent, such as
when you submit an online form with your contact information on our Site
requesting that we get in touch with you with information on our Services;
and
* complying with legal obligations, such as responding to lawful requests by
public authorities.
27. PRIVACY SHIELD
As noted, ZeroFox participates in and has certified its compliance with the
EU-U.S. Privacy Shield Framework.
* We are committed to subjecting all personal information received from EU
member countries and the United Kingdom, in reliance on the Privacy Shield,
to Privacy Shield Principles. To learn more about the Privacy Shield, and to
view our certification, visit the U.S. Department of Commerce’s Privacy
Shield website, where the Department also maintains a list of all Privacy
Shield participants.
* ZeroFox is responsible for the processing of personal information it receives
under the Privacy Shield and subsequently transfers to a third party acting
as an agent on its behalf. We comply with the Privacy Shield for all onward
transfers of personal data from the EU, United Kingdom, including the onward
transfer liability provisions.
* With respect to personal data received or transferred pursuant to the Privacy
Shield, we are subject to the regulatory enforcement powers of the U.S.
Federal Trade Commission. In certain situations, we may be required to
disclose personal information in response to lawful requests by public
authorities, including to meet national security or law enforcement
requirements.
* If you have an unresolved privacy or data use concern that we have not
addressed satisfactorily, please contact our U.S.-based third-party dispute
resolution provider (free of charge) at https://feedback-form.
truste.com/watchdog/request. Under certain conditions, more fully described
at U.S. Department of Commerce’s Privacy Shield website, you may be entitled
to invoke binding arbitration when other dispute resolution procedures have
been exhausted.
ZeroFox is aware of the judgment of the Court of Justice of the European
Communities in relation to Privacy Shield. We are watching developments
closely, and making standard contractual clauses available to our customers who
need them and do not already have them in place. In the meantime, we will
continue to look after EU personal data in accordance with GDPR and the Privacy
Shield Principles.
28. HR DATA
This Policy also reflects the principles under which ZeroFox manages the
processing of personal information that it receives from its employees in the EU
in support of its human resources operations. ZeroFox has committed to
cooperate with EU data protection authorities with regard to unresolved EU-U.S.
Privacy Shield complaints concerning human resources data transferred from the
EU in the context of the employment relationship.
29. INQUIRIES AND COMPLAINTS
In compliance with the EU-U.S. Privacy Shield, we are committed to resolving
complaints about our collection or use of EU residents’ personal information.
For inquiries or complaints regarding this Policy, we request that EU residents
first contact ZeroFox as provided in paragraph 5. You may also approach your
local data protection authority (referred to under the GDPR as your supervisory
authority) which can provide further information about your rights and our
obligations in relation to your personal information.
--------------------------------------------------------------------------------
Individuals and data protection supervisory authorities in the EU and the UK may
contact our data protection representatives according to Articles 27 EU and UK
GDPR:
* EU: DP-Dock GmbH,
Attn: ZeroFox Inc., Ballindamm 39, 20095 Hamburg, Germany
* UK: DP Data Protection Services UK Ltd.,
Attn: ZeroFox Inc., 16 Great Queen Street, Covent Garden, London, WC2B 5AH,
United Kingdom
www.dp-dock.com
zerofox@gdpr-rep.com
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CCPA DATA PROCESSING ADDENDUM
PRIVACY STATEMENT-CALIFORNIA
This PRIVACY NOTICE FOR CALIFORNIA RESIDENTS supplements the information
contained in the Privacy Statement of ZeroFox, Inc. (“ZeroFox”) and its
subsidiaries (collectively, “we,” “us,” or “our”) and applies solely to
visitors, users, and others who reside in the State of California (“consumers”
or “you”). We adopt this notice to comply with the California Consumer Privacy
Act of 2018 (“CCPA”) and other California privacy laws. Any terms defined in
the CCPA have the same meaning when used in this notice.
30. INFORMATION WE COLLECT.
We may collect information that identifies, relates to, describes, references,
is capable of being associated with, or could reasonably be linked, directly or
indirectly, with a particular consumer or device (“personal information”). In
particular, we have collected the following categories of personal information
from consumers within the last twelve (12) months:
CategoryExamplesCollectedIdentifiers.A real name, alias, postal address, unique
personal identifier, online identifier, Internet Protocol address, email
address, account name, or other similar identifiers.YESCommercial
information.Records of products or services purchased, obtained, or considered,
or other purchasing or consuming historiesYES
Personal information does not include:
* Publicly available information from government records.
* De-identified or aggregated consumer information.
* Information excluded from the CCPA’s scope, like:
* health or medical information covered by the Health Insurance Portability and
Accountability Act of 1996 (HIPAA) and the California Confidentiality of
Medical Information Act (CMIA) or clinical trial data;
* personal information covered by certain sector-specific privacy laws,
including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act
(GLBA) or California Financial Information Privacy Act (FIPA), and the
Driver’s Privacy Protection Act of 1994.
We obtain the categories of information listed above from the following
categories of sources:
* Directly from our Customers or their agents. For example, from documents that
our Customers provide to us related to the services we are providing to them.
* Indirectly from our Customers or their agents. For example, through
information we collect from our Customers in the course of providing services
to them.
* Directly and indirectly from activity on our website. For example, from
submissions through our website portal or website usage details collected
automatically.
* From third parties that interact with us in connection with the services we
perform. For example, from our partners that engage ZeroFox to provide
services to their customers.
31. USE OF PERSONAL INFORMATION
We may use or disclose the personal information we collect for one or more of
the following business purposes:
* To fulfill or meet the reason for which the information is provided. For
example, if you provide us with personal information in order for us to
provide our services, we will use that information to maintain the service
for you.
* To provide you with information, products or services that you request from
us.
* To provide you with email alerts, event registrations and other notices
concerning our products or services, or events or news, that may be of
interest to you.
* To carry out our obligations and enforce our rights arising from any
contracts entered into between you and us, including for billing and
collections.
* To improve our website and present its contents to you.
* For testing, research, analysis and product development.
* As necessary or appropriate to protect the rights, property or safety of us,
our customers or others.
* To respond to law enforcement requests and as required by applicable law,
court order, or governmental regulations.
* As described to you when collecting your personal information or as otherwise
set forth herein.
* To evaluate or conduct a merger, divestiture, restructuring, reorganization,
dissolution, or other sale or transfer of some or all of our assets, whether
as a going concern or as part of bankruptcy, liquidation, or similar
proceeding, in which personal information held by us is among the assets
transferred.
We will not collect additional categories of personal information or use the
personal information we collected for materially different, unrelated, or
incompatible purposes without providing you notice.
32. SHARING PERSONAL INFORMATION
We may disclose your personal information to a third party for a business
purpose. When we disclose personal information for a business purpose, we enter
a contract that describes the purpose and requires the recipient to both keep
that personal information confidential and not use it for any purpose except
performing the contract.
In the preceding twelve (12) months, we have disclosed the following categories
of personal information to provide services:
Category A: Identifiers.
We disclose your personal information for a business purpose to the following
categories of third parties:
* Our affiliates.
* Service providers.
* Third parties to whom you or your agents authorize us to disclose your
personal information in connection with products or services we provide to
you.
PERSONAL INFORMATION SALES
In the preceding twelve (12) months, we have not sold, rented, or traded any
personal information.
33. YOUR RIGHTS AND CHOICES
The CCPA provides consumers (California residents) with specific rights
regarding their personal information. This section describes your CCPA rights
and explains how to exercise those rights.
ACCESS TO SPECIFIC INFORMATION AND DATA PORTABILITY RIGHTS
You have the right to request that we disclose certain information to you about
our collection and use of your personal information over the past 12 months.
Once we receive and confirm your verifiable consumer request, we will disclose
to you:
* The categories of personal information we collected about you.
* The categories of sources for the personal information we collected about
you.
* Our business or commercial purpose for collecting or selling that personal
information.
* The categories of third parties with whom we share that personal information.
* The specific pieces of personal information we collected about you (also
called a data portability request).
* If we sold or disclosed your personal information for a business purpose, two
separate lists disclosing:
* sales, identifying the personal information categories that each category
of recipient purchased; and
* disclosures for a business purpose, identifying the personal information
categories that each category of recipient obtained.
DELETION REQUEST RIGHTS
You have the right to request that we delete any of your personal information
that we collected from you and retained, subject to certain exceptions. Once we
receive and confirm your verifiable consumer request, we will delete (and direct
our service providers to delete) your personal information from our records,
unless an exception applies.
We may deny your deletion request if retaining the information is necessary for
us or our service providers to:
1. Complete the transaction for which we collected the personal information,
provide a good or service that you requested, take actions reasonably
anticipated within the context of our ongoing business relationship with
you, or otherwise perform our contract with you.
2. Detect security incidents, protect against malicious, deceptive, fraudulent,
or illegal activity, or prosecute those responsible for such activities.
3. Debug products to identify and repair errors that impair existing intended
functionality.
4. Exercise free speech and ensure the right of another consumer to exercise
their free speech rights, or exercise another right provided for by law.
5. Comply with the California Electronic Communications Privacy Act (Cal. Penal
Code § 1546 seq.).
6. Engage in public or peer-reviewed scientific, historical, or statistical
research in the public interest that adheres to all other applicable ethics
and privacy laws, when the information’s deletion may likely render
impossible or seriously impair the research’s achievement, if you previously
provided informed consent.
7. Enable solely internal uses that are reasonably aligned with consumer
expectations based on your relationship with us.
8. Comply with a legal obligation.
9. Make other internal and lawful uses of that information that are compatible
with the context in which you provided it.
34. EXERCISING ACCESS, DATA PORTABILITY, AND DELETION RIGHTS
To exercise the access, data portability, and deletion rights described above,
please submit a verifiable consumer request to us by either:
Calling us at 1.855.936.9369
Visiting ZeroFox.com
Only you or a person registered with the California Secretary of State that you
authorize to act on your behalf, may make a verifiable consumer request related
to your personal information. You may also make a verifiable consumer request on
behalf of your minor child.
You may only make a verifiable consumer request for access or data portability
twice within a 12-month period. The verifiable consumer request must:
* Provide sufficient information that allows us to reasonably verify you are
the person about whom we collected personal information or an authorized
representative.
* Describe your request with sufficient detail that allows us to properly
understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we
cannot verify your identity or authority to make the request and confirm the
personal information relates to you. Making a verifiable consumer request does
not require you to create an account with us. We will only use personal
information provided in a verifiable consumer request to verify the requestor’s
identity or authority to make the request.
35. RESPONSE TIMING AND FORMAT
We will respond to a verifiable consumer request within 45 days of its receipt.
If we require more time (up to 90 days), we will inform you of the reason and
extension period in writing. If you have an account with us, we will deliver
our written response to that account. If you do not have an account with us, we
will deliver our written response by mail or electronically, at your option.
Any disclosures we provide will only cover the 12-month period preceding the
verifiable consumer request’s receipt. The response we provide will also
explain the reasons we cannot comply with a request, if applicable. For data
portability requests, we will select a format to provide your personal
information that is readily useable and should allow you to transmit the
information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request
unless it is excessive, repetitive, or manifestly unfounded. If we determine
that the request warrants a fee, we will tell you why we made that decision and
provide you with a cost estimate before completing your request.
36. NON-DISCRIMINATION
We will not discriminate against you for exercising any of your CCPA rights.
Unless permitted by the CCPA, we will not:
* Deny you goods or services.
* Charge you different prices or rates for goods or services, including through
granting discounts or other benefits, or imposing penalties.
* Provide you a different level or quality of goods or services.
* Suggest that you may receive a different price or rate for goods or services
or a different level or quality of goods or services.
37. CHANGES TO OUR PRIVACY NOTICE
We reserve the right to amend this privacy notice at our discretion and at any
time. When we make changes to this privacy notice, we will notify you by email
or through a notice on our website homepage.
38. CONTACT INFORMATION
If you have any questions or comments about this notice, our Privacy Statement,
the ways in which we collect and use your personal information, your choices and
rights regarding such use, or wish to exercise your rights under California law,
please do not hesitate to contact us at:
Phone: 1.855.936.9369
Web: ZeroFox.com
Email: Privacy@zerofox.com
Address: 1834 S. Charles St. Baltimore, MD 21230
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