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* Products
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 * Platform
   Why Flashpoint?
   Learn more about Flashpoint’s products and services.
   Products
    * Flashpoint Ignite
      Cyber Threat Intelligence
      Vulnerability Management (VulnDB)
      Physical Security Intelligence
      National Security Intelligence
    * Managed Attribution
    * Automate
   
   Services
    * Threat Response & Readiness
    * Professional Services
    * Managed Intelligence
    * Tailored Reporting
    * Curated Alerting
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    * Vulnerability Management
    * Physical Security Intelligence
    * National Security Intelligence
   
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    * Retail
    * Healthcare & Pharmaceuticals
    * Technology
    * Public Sector & National Security

 * Resources
   Case study
   
   How Flashpoint Helped CSI (NY) Stop a Potential Synagogue Attack
    * Threat Intel Blog
    * Events & Webinars
    * Resource Library
    * Partners

 * Company
      
    * About Us
    * Careers
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    * Contact Us

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PRIVACY POLICY

Table Of Contents

Table of Contents
Effective as of February 10, 2022
General Data Protection Regulation (2016/679) (“GDPR”)
Your Rights Under the GDPR
Contact Information
Analytics Services
Cookies
Aggregate Data
Additional Uses
Business Transfers
Disclosure to Public Authorities
Opt-Out for Direct Marketing; Email Management
Retention of Personal Information
How We Protect Your Information
Children
Important Notice to Non-U.S. Residents
Important Notice for Individuals of the European Economic Area, the United
Kingdom, and Switzerland
Onward Transfer to Third Parties under the Privacy Shield
Opt-In and Opt-Out to Certain Onward Transfers under the Privacy Shield
Your Privacy Shield Rights
California Privacy Rights
External Websites
Changes to This Privacy Policy
How to Contact Us


EFFECTIVE AS OF FEBRUARY 13TH, 2023

We at EJ2 Communications, Inc. d/b/a Flashpoint (“Flashpoint,” “we,” “us,” or
“our”) provide this privacy policy (this “Privacy Policy”) because we know that
you care about how information you provide to us is used and shared. This
Privacy Policy relates to the information collection and use practices of
Flashpoint when you access and use this website (https://www.flashpoint.io/)
(the “Website”) or access and use our proprietary software products (“Products”)
via the Website. As of the Effective Date of this Privacy Policy, our Products
include Flashpoint Platform, Reports, Curated Alerting and Analysis Assistance.
Our Products may change from time to time.

By visiting our Website or accessing and using our Products, you are agreeing to
the terms of this Privacy Policy and the accompanying Terms of Service. Access
to and usage of our Products is also governed by the applicable software license
agreement.

Capitalized terms not defined in this Privacy Policy shall have the meaning set
forth in our Terms of Service.

General Data Protection Regulation (2016/679) (“GDPR”)

Flashpoint provides its Products on its customers’ behalf as a “data processor,”
as such term is defined under the GDPR. As such, customers are the data
controllers, as such terms are defined under the GDPR, when using Flashpoint’s
Products. Thus, Customers must, as applicable, have an appropriate legal basis
for its processing activities when using the Products, give appropriate notices
under Articles 13-14, and fulfill all other data controller obligations under
the GDPR.   

When serving as a processor, we have certain obligations under GDPR including
only processing personal data at our customers’ instructions reflected in the
applicable software license agreement, providing assistance with fulfillment of
rights requests, and implementing appropriate security for personal data. We
will forward any inquiries, complaints, or requests received from data subjects
with respect to use of the Products to the appropriate customer and await
instructions before taking any action.

With respect to other processing activities, Flashpoint may act as a data
controller. As examples, we are a controller with respect to certain activities
related to prospective/current customers, customer end-users, and vendors
(“Business Contacts”), and visitors to our Website to the extent they are
located in the European Economic Area (note that, in some cases, the categories
may overlap such as Business Contacts using the Website). Please see below for
more information related to such processing activities and other important
information.

Your Rights Under the GDPR

As a natural person located in the European Economic Area, you have a right to:
(i) request access to, correction and/or erasure of your personal data; (ii)
object to processing of your personal data (such as direct marketing); (iii)
restrict processing of your personal data; and (iv) request a copy of your
personal data, or have a copy thereof sent to another controller, in a
structured, commonly used and machine readable format under the right of data
portability. You may exercise these rights and submit a GDPR complaint by
contacting gdpr-requests@flashpoint-intel.com with the subject line “GDPR.”

You also have the right to lodge a complaint about the processing of your
personal data with an appropriate data protection authority, and, as applicable,
to exercise third-party beneficiary rights under Flashpoint’s Standard
Contractual Clauses.

Contact details for the EU data protection authorities can be found
at: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

Flashpoint’s intelligence portal may collect your IP address and this
information will be used by Flashpoint for security, analytics and other
internal purposes.

Contact Information

When you sign up to receive our newsletters or Product information on the
Website, we collect your contact information. Contact information is provided
via browser forms or online request forms, and includes: first name, last name,
e-mail address, job title, name of the organization, country, state/region and
phone numbers (fax, cell and/or landline). This contact information is used by
our sales, support and Product teams to contact our visitors, customers and
distributors for the purpose of providing the requested information, support, or
Products. We do not collect any contact information from you when you use the
Website unless you provide us with the contact information voluntarily.

Analytics Services

Like most organizations, we use automatic data collection technology, such as
Google Analytics, New Relic, and Pardot when you visit our Website, or license,
access, or use our Products online. These technology services may collect
information on our behalf such as your IP Address, geolocation information,
Internet service provider, browser type, operating system and language,
referring and exit pages and URLs, date and time, amount of time spent on
particular pages, what sections of the Website you visit, number of links you
click while on the Website, search terms, and other data. This information is
collected automatically and anonymized. The third parties we currently work with
include the following (click on the links to view these organizations’ privacy
policies and find out more about what data they hold about you, what they do
with it, and how to opt-out from certain data collection). Please be advised
that if you opt out of any service, you may not be able to use the full
functionality of the Website.

For Google Analytics, please visit: https://www.google.com/analytics

For Pardot, please visit: https://www.salesforce.com/company/privacy/

For New Relic, please visit: https://newrelic.com/termsandconditions/privacy

Cookies

We use cookies to compile aggregate data as described above regarding our
Website traffic which is used to improve our Website. Cookies are small packets
of data that a website stores on your computer’s hard drive so that your
computer will “remember” information about your visits to our Website and other
sites. Our cookie policy is available at https://flashpoint.io/cookie-policy/.

If you do not want the Website to place a cookie on your hard drive, you may be
able to turn that feature off on your device. Please consult your Internet
browser’s documentation for information on how to do this. However, if you
decide not to accept cookies from our Website, the Website may not function
properly.

Aggregate Data

In an ongoing effort to better understand our users and the Website, we might
analyze your information in aggregate form to operate, maintain, manage, and
improve the Website. This aggregate information does not identify you
personally. We may share this aggregate data with our affiliates, agents, and
business partners. We may also disclose aggregated user statistics in order to
describe our Products and the Website to current and prospective business
partners and to other third parties for other lawful purposes.

Additional Uses

We also use contact information and other information collected pursuant to this
Privacy Policy to respond to general inquiries, solicit feedback regarding our
Website, Products and support, provide relevant content on our Website including
advertisements regarding Products and third party products, and to communicate
with you via email regarding our current and future Products.

Business Transfers

In the event of a merger, reorganization, dissolution or similar corporate
event, or the sale of all or substantially all of our assets, we expect that the
information that we have collected, including personal information, would be
transferred to the surviving entity in a merger or the acquiring entity. All
such transfers shall be subject to our commitments with respect to the privacy
and confidentiality of such personal information as set forth in this privacy
policy.

Disclosure to Public Authorities

We may be required to disclose personal information in response to lawful
requests by public authorities, including for the purpose of meeting national
security or law enforcement requirements. We may also disclose personal
information to other third parties when compelled to do so by government
authorities or required by law or regulation including, but not limited to, in
response to court orders and subpoenas.

Opt-Out for Direct Marketing; Email Management

You may opt out at any time from the use of your personal information for direct
marketing purposes by contacting us at privacy@flashpoint-intel.com. Please
allow us a reasonable time to process your request.

You also may manage your receipt of marketing and non-transactional
communications by clicking on the “Manage Email Preferences” link located on the
bottom of any Flashpoint marketing email and following the instructions found on
the page to which the link takes you. You cannot opt out of receiving
transactional emails related to their account or purchase orders.

Retention of Personal Information

We will retain your personal information in a form that identifies you only for
as long as it serves the purpose(s) for which it was initially collected as
stated in this privacy policy, or subsequently authorized. We may continue
processing your personal information for longer periods, but only for the time
and to the extent such processing is legally required or reasonably serves the
purposes of archiving in the public interest, journalism, literature and art,
scientific or historical research and statistical analysis. Retained personal
information is subject to the protection of this Privacy Policy. After such time
periods have expired, we may either delete your personal information or retain
it in a form such that it does not identify you personally.

How We Protect Your Information

We take commercially reasonable steps to protect the personal information from
loss, misuse, and unauthorized access, disclosure, alteration, or destruction,
taking into account the risks involved in processing and the nature of such
data, and comply with applicable laws and regulations. Please understand,
however, that no security system is impenetrable. We cannot guarantee the
security of our databases, nor can we guarantee that the information you supply
will not be intercepted while being transmitted to and from us over the
Internet. In particular, e-mail sent to or from the Website may not be secure,
and you should therefore take special care in deciding what information you send
to us via email.

Children

The Website and Products are not directed to or intended for children under 16,
and we do not knowingly collect personal information from children under the age
of 16 through the Website or the Products. If you are under 16, please do not
give us any personal information. We encourage parents and legal guardians to
monitor their children’s Internet usage and to help enforce our Privacy Policy
by instructing their children to never provide personal information through the
Website or the Products without their permission. If you have reason to believe
that a child under the age of 16 has provided personal information to us, please
contact us, and we will endeavor to delete that information from our databases.

Important Notice to Non-U.S. Residents

Our servers are located in the US. If you are located outside of the US, please
be aware that any information provided to us, including personal information,
will be transferred from your country of origin to the US, which may not have
privacy laws as comprehensive as those in the country where you reside or are a
citizen. Except in the case of data transfers under the EU-US Privacy Shield
Framework and the Swiss-US Privacy Shield Framework, described below, your
decision to provide personal information to us, or allow us to collect such data
through our Website or Products, constitutes your consent to this data transfer.

Important Notice for Individuals of the European Economic Area, the United
Kingdom, and Switzerland

Although not currently in effect, Flashpoint continues to comply  with the EU-US
Privacy Shield Framework and the Swiss-US Privacy Shield Framework as set forth
by the US Department of Commerce regarding the collection, use, and retention of
personal information from the European Union member countries (including
Iceland, Liechtenstein and Norway) and the United Kingdom and Switzerland to the
United States, respectively, pursuant to the EU-US and Swiss-US Privacy Shield
Frameworks. Flashpoint maintains its certification that it adheres to the
Privacy Shield principles of Notice, Choice, Accountability for Onward Transfer,
Security, Data Integrity and Purpose Limitation, Access, Recourse, Enforcement
and Liability (the “Privacy Shield Principles”). If there is a conflict between
this privacy policy and the Privacy Shield Principles, the Privacy Shield
Principles shall govern. To learn more about the Privacy Shield program, and to
view our certification page, please visit https://www.privacyshield.gov/.

Flashpoint is subject to the investigatory and enforcement powers of the Federal
Trade Commission.

In addition, in compliance with the EU-US and the Swiss-US Privacy Shield
Principles, Flashpoint commits to resolve complaints about your privacy and our
collection or use of your personal information. European Union or Swiss
individuals with inquiries or complaints regarding this Privacy Policy should
first contact Flashpoint at privacy@flashpoint-intel.com with the subject line,
“Privacy Shield.” Flashpoint has further committed to refer unresolved privacy
complaints under the Privacy Shield Principles to an independent dispute
resolution mechanism, the BBB EU PRIVACY SHIELD, operated by BBB National
Programs. If you do not receive timely acknowledgment of your complaint, or if
your complaint is not satisfactorily addressed, please
visit https://bbbprograms.org/privacy-shield-complaints for more information and
to file a complaint. This service is provided free of charge to you.  If these
processes do not result in a resolution, you may also contact your local data
protection authority, the US Department of Commerce, and/or the Federal Trade
Commission for assistance. Please note that if your complaint is not resolved
through these channels, under limited circumstances, a binding arbitration
option may be available before a Privacy Shield Panel.

Onward Transfer to Third Parties under the Privacy Shield

Like many businesses, we hire other companies to perform certain
business-related services. We may disclose personal information to certain types
of third-party companies but only to the extent needed to enable them to provide
such services. The types of companies that may receive personal information and
their functions are: direct marketing assistance, lead generation services,
order fulfillment, billing, customer service, data storage, hosting services,
disaster recovery services, and sales support companies. All such third parties
function as our agents, performing services at our instruction and on our behalf
pursuant to contracts which require they provide at least the same level of
privacy protection as is required by this privacy policy and implemented by
Flashpoint. We may also disclose personal information to our affiliates in order
to support marketing, sale and delivery of Products.

In certain situations, we may be required to disclose personal data in response
to lawful requests by public authorities, including to meet national security or
law enforcement requirements.

Flashpoint’s accountability for personal data that it receives under the Privacy
Shield and subsequently transfers to a third party is described in the Privacy
Shield Principles. In particular, Flashpoint remains responsible and liable
under the Privacy Shield Principles if third-party agents that it engages to
process the personal data on its behalf do so in a manner inconsistent with the
Privacy Shield Principles, unless Flashpoint proves that it is not responsible
for the event giving rise to the damage.

Although Flashpoint adheres to the principles of the EU-U.S. and Swiss-U.S.
Privacy Shield Frameworks, Flashpoint does not rely on the EU-U.S. Privacy
Shield Framework as a legal basis for transfers of personal information from the
European Economic Area to third countries in light of the judgment of the Court
of Justice of the EU in Case C-311/18 (Schrems II Decision). Nor do we rely on
the Swiss-U.S. Privacy Shield Framework in light of the policy paper of the
Swiss Federal Data Protection and Information Commissioner of September 8, 2020.
To learn more, visit the U.S. Department of Commerce’s Privacy Shield website
(at: https://www.privacyshield.gov/). Accordingly, Flashpoint utilizes legally
recognized mechanisms to facilitate the transfer of personal information from
the European Economic Area and Switzerland to the United States and other third
countries, including the Standard Contractual Clauses. For transfers of personal
Information from the United Kingdom to third countries, we similarly use
authorized transfer mechanisms, such as the UK International Data Transfer
Agreement.

Opt-In and Opt-Out to Certain Onward Transfers under the Privacy Shield

Individuals have the opportunity to opt-out of sharing of their personal data
with third parties other than our agents or before we use it for a purpose other
than which it was originally collected or subsequently authorized. To limit the
use and disclosure of your personal information, please submit a written request
to privacy@flashpoint-intel.com with the subject line “Privacy Shield.” 

We will not disclose your sensitive personal information to any third party
without first obtaining your opt-in consent. In addition to any consent
mechanisms on the Site, you may provide your consent by sending us an email
at privacy@flashpoint-intel.com with the subject line “Privacy Shield.” In each
instance, please allow us a reasonable time to process your response.

Your Privacy Shield Rights

Flashpoint acknowledges that EU and Swiss individuals have the right to access
the personal information we maintain about them. Upon request
to privacy@flashpoint-intel.com with the subject line, “Privacy Shield,” we will
provide you with confirmation as to whether we are processing your personal
information, and have the data communicated to you within a reasonable time. You
have the right to correct, amend or delete your personal information where it is
inaccurate or has been processed in violation of this privacy policy. We may
require payment of a non-excessive fee to defray our expenses in this regard.
Please allow us a reasonable time to respond to your inquiries and requests.

California Privacy Rights

Pursuant to Section 1798.83 of the California Civil Code, residents of
California have the right to obtain certain information about the types of
personal information that companies with whom they have an established business
relationship (and that are not otherwise exempt) have shared with third parties
for direct marketing purposes during the preceding calendar year, including the
names and addresses of those third parties, and examples of the types of
services or products marketed by those third parties. If you wish to submit a
request pursuant to Section 1798.83, please contact Flashpoint via email
at privacy@flashpoint-intel.com. 

If you are a California resident and you have questions about our practices with
respect to sharing information with third parties for their direct marketing
purposes and your ability to exercise choice, please send your request to the
following email address: privacy@flashpoint-intel.com or write to us at our
mailing address below.

For California residents under the age of 18 and registered users, California
law (Business and Professions Code § 22581) provides that you can request the
removal of content or information you posted on the Website. Any such request
should be sent to us at privacy@flashpoint-intel.com. along with a description
of the posted content or other information to be removed. Be advised, however,
that applicable law may not permit us to completely or comprehensively remove
your deleted content or for other reasons as set forth in this California law.

In addition, Flashpoint does not monitor, recognize, or honor any opt-out or do
not track mechanisms, including general web browser “Do Not Track” settings
and/or signals.

California Consumer Privacy Act (CCPA). Your California Privacy Rights If you
are a California resident, California law may provide you with additional rights
regarding our use of your personal information pursuant to the California
Consumer Privacy Act (including as amended by the California Privacy Rights
Act). To learn more about your California privacy rights, visit CCPA Privacy
Notice for California Residents.  Flashpoint does not sell or share your
personal information to third parties for purposes of the CCPA.

Other State Privacy Rights

State consumer privacy laws in Colorado, Connecticut, Nevada, Utah and Virginia
may provide their residents with additional rights regarding our use of their
personal information. 

Colorado, Connecticut, Utah and Virginia each provide their state residents with
rights to:

 * Confirm whether we process their personal information.
 * Access and delete certain personal information.
 * Data portability.
 * Opt-out of personal data processing for targeted advertising and sales
   (However, we do not use your personal information for targeted advertising or
   sell your personal information.)

Colorado, Connecticut, and Virginia also provide their state residents with
rights to:

 * Correct inaccuracies in their personal information, taking into account the
   information’s nature processing purpose.
 * Opt-out of profiling in furtherance of decisions that produce legal or
   similarly significant effects.

If you are a resident of Nevada, you also have the right to opt-out of the sale
of your personal information to third parties.  (Again, however, we do not sell
your personal information to third parties.)

To exercise any of these rights, or appeal a decision, please send an email to
privacy@flashpoint-intel.com. Again, however, we do not use your personal
information for targeted advertising or sell your personal information.

For all verifiable consumer requests, we will confirm receipt of your request
within ten (10) business days. If you do not receive confirmation within the
10-day timeframe, please contact us at privacy@flashpoint-intel.com.

We endeavor to respond to a verifiable consumer request within forty-five (45)
days of receipt. If we require more time (up to 90 days), we will inform you of
the reason and extension period in writing.

External Websites

The Website and the Products may contain links to third-party websites.
Flashpoint has no control over the privacy practices or the content of any of
these websites. As such, we are not responsible for their content or privacy
policies. You should check the applicable third-party privacy policy and terms
of service when visiting any other websites, and before providing any personal
information to such external sites.

Changes to This Privacy Policy

This Privacy Policy is effective as of the date stated at the top of this
Privacy Policy. We may change this Privacy Policy from time to time and will
post any changes on the Website as soon as they go into effect. By accessing or
using the Website after we make any such changes to this Privacy Policy, you are
deemed to have accepted such changes. Please refer back to this Privacy Policy
on a regular basis.

How to Contact Us

If you have questions about this Privacy Policy or GDPR, please contact us in
one of the following ways:

E-mail us at privacy@flashpoint-intel.com

Or write to us at:

EJ2 Communications, Inc.
d/b/a Flashpoint
6218 Georgia Avenue NW, Suite 1, PMB 3032
Washington, D.C. 20011 USA

Attention: Privacy

For GDPR Requests Email us at gdpr-requests@flashpoint-intel.com

For GDPR Data Processing Agreement Questions Email us
at: dataprocessingagreement@flashpoint-intel.com

Copyright 2023 EJ2 Communications, Inc. All rights reserved.

Capitalized terms not defined in this Privacy Policy shall have the meaning set
forth in our Terms of Service.

6218 Georgia Avenue NW
Suite #1
PMB 3032
Washington, DC, 20011
United States

+1 (888) 468-3598

Contact us

 * 
 * 
 * 
 * 

 * Platform
   * Why Flashpoint?
   * Flashpoint Ignite
   * Cyber Threat Intelligence
   * Vulnerability Management (VulnDB)
   * Physical Security Intelligence
   * National Security Intelligence
   * Managed Attribution
   * Automate
   * Ransomware Attack Response and Readiness
   * Professional Services
   * Managed Intelligence
   * Tailored Reporting
   * Curated Alerting
   * Request for Information (RFI)
 * Solutions
   * Cyber Threat Intelligence
   * Fraud
   * Corporate and Physical Security
   * Vulnerability Management
   * DevSecOps
   * Insider Threat
   * Financial Services
   * Retail
   * Healthcare & Pharmaceutical
   * Technology
   * Public Sector & National Security
 * Company
   * About Us
   * Flashpoint Careers
   * Pricing
   * Flashpoint News
   * Contact Us
 * Resources
   * Threat Intel Blog
   * Resource Library
   * Events & Webinars
   * Partners
   * Help Center

© 2023 Flashpoint. All rights reserved.
 * Privacy Policy
 * Terms of Service
 * Cookie Policy
 * CCPA
 * Legal


ORIGINALTEXT


Bessere Übersetzung vorschlagen

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We have updated our Privacy Policy and Cookie Policy which go into effect on May
25, 2018, to comply with the new requirements of GDPR. These changes reflect
increased transparency requirements mandated by the GDPR. Changes include
clarifying and providing additional information about: your privacy rights and
how to exercise them; how we collect, use, share and protect your personal
information; and the legal bases we rely on to process your personal
information. Please review these policies to confirm your acceptance of the
recent changes. Continue? Yes No