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PRIVACY POLICY

Table Of Contents

Table of Contents
Effective as of July 26, 2024
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 EU-U.S. DPF and Swiss-U.S. DPF
Opt-In and Opt-Out to Certain Onward Transfers under the EU-U.S. DPF and
Swiss-U.S. DPF
Your Privacy Rights under the EU-U.S. DPF and Swiss-U.S. DPF
California Privacy Rights
External Websites
Changes to This Privacy Policy
How to Contact Us
More
subscribe to our newsletter



EFFECTIVE AS OF JULY 26, 2024

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.
However, 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 (the “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 Agreement, providing assistance with fulfillment of rights requests,
and implementing appropriate security for personal data. To the extent legally
permissible, 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 products (including the platform, subscription services and other
professional services) 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 and
https://policies.google.com/privacy?hl=en-US

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 data, 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 data 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 Data

We will retain your personal data 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 data 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 data is subject to the
protection of this Privacy Policy. After such time periods have expired, we may
either delete your personal data 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 data 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. Therefore, 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 data 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 data. 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 data 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 data 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 United States. If you are located outside of the
United States, please be aware that any information provided to us, including
personal data, will be transferred from your country of origin to the United
States, which may not have privacy laws as comprehensive as those in the country
where you reside or are a citizen. In particular, your personal data may be
accessible by US governmental authorities after appropriate due process. Except
in the case of data transfers under the EU-U.S, Data Privacy Framework and the
UK Extension to the EU-U.S. Data Privacy Framework, and the Swiss-U.S. Data
Privacy Framework, described below, your decision to provide personal data to
us, or allow us to collect such data through our Website or Products,
constitutes your consent to this data transfer.

EU-U.S. Data Privacy Network and the UK Extension to the EU-U.S. Data Privacy
Framework, and the Swiss-U.S. Data Privacy Framework

Flashpoint, including its US affiliate entity, Risk Based Security, Inc., has
certified its participation  in and comply with the EU-U.S. Data Privacy
Framework program (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF and the
Swiss-U.S. Data Privacy Framework program (Swiss-U.S. DPF), as set forth by the
U.S. Department of Commerce.  Flashpoint also has certified to the U.S.
Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework
Principles (EU-U.S. DPF Principles) with regard to the processing of personal
data received from the European Union and the United Kingdom in reliance on the
EU-U.S. DPF and the UK Extension to the EU-U.S. DPF. personal data.  In
addition, Flashpoint has certified to the U.S. Department of Commerce that it
adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF
Principles) with regard to the processing of personal data received from
Switzerland in reliance on the Swiss-U.S. DPF.  If there is any conflict between
the terms of this Privacy Policy and the EU-U.S. DPF Principles and/or the
Swiss-U.S. DPF Principles, the Data Privacy Framework Principles shall govern,
as applicable.  To learn more about the Data Privacy Framework  program, please
visit  https://www.dataprivacyframework.gov/.  Flashpoint’s DPF program
registration information can be accessed on the online directory at:
https://www.dataprivacyframework.gov/s/participant-search.

Flashpoint is subject to the investigatory and enforcement powers of the Federal
Trade Commission regarding possible unfair or deceptive practices and violations
of laws or regulations covering privacy.

In compliance with the EU-U.S. DPF and the Swiss-U.S. DPF, Flashpoint commits to
resolve complaints about your privacy and our collection or use of your personal
data transferred to us in the United States. Individuals in the European Union,
United Kingdom or Switzerland with DPF inquiries or complaints should first
contact Flashpoint at privacy@flashpoint-intel.com with the subject line, “Data
Privacy Framework”.

Flashpoint has further committed to refer unresolved privacy complaints
concerning our handling of personal data received in reliance on the EU-U.S. DPF
and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF to BBB National
Programs, an independent dispute resolution mechanism in the United States. If
you do not receive timely acknowledgment of your complaint, or if your complaint
is not satisfactorily addressed by us, please visit
https://bbbprograms.org/programs/all-programs/dpf-consumers/ProcessForConsumers for
more information and to file a complaint. This service is provided free of
charge to you.

However, if we or our independent dispute mechanism provider is still unable to
resolve the matter, you may pursue binding arbitration through the Data Privacy
Framework Panel (available at: https://go.adr.org/dpfeufiling.html for the
EU/EEA and UK (and Gibraltar) individuals or at:
https://go.adr.org/DPF_Swiss_AnnexI_Filing.html for Swiss individuals).

Onward Transfer to Third Parties under the EU-U.S. DPF and the UK Extension to
the EU-U.S. DPF and Swiss-U.S. DPF

Like many businesses, we hire other companies to perform certain
business-related services. We may disclose personal data 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 data 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 data to our affiliates in order to support
marketing, sale and delivery of Products and Services.

Flashpoint’s accountability for personal data that it receives under the EU-U.S.
DPF and the UK Extension to the EU-U.S. DPF. and the Swiss-U.S. DPF and
subsequently transfers to a third party is described in the EU-U.S. DPF
Principles, and the Swiss-U.S. DPF Principles. Flashpoint remains responsible
and liable under the EU-U.S. DPF Principles and the Swiss-U.S. DPF Principles if
third-party agents that Flashpoint engaged to process the personal data on its
behalf do so in a manner inconsistent with the Data Privacy Framework
Principles, unless Flashpoint proves that it is not responsible for the event
giving rise to the damage. Please be advised that Flashpoint may be required to
disclose personal data that we handle under the Data Privacy Framework program
in response to lawful requests by public authorities, including to meet national
security or law enforcement requirements.

Opt-In and Opt-Out to Certain Onward Transfers under the EU-U.S. DPF and the UK
Extension to the EU-U.S. and Swiss-U.S. DPF

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 data, please submit a written request
to privacy@flashpoint-intel.com with the subject line “Data Privacy Framework.” 

We will not disclose your sensitive personal data 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 “Data Privacy Framework.”
In each instance, please allow us a reasonable time to process your response.

Your Privacy Rights under the EU-U.S. DPF and the UK Extension to the EU-U.S.
DPF and Swiss-U.S. DPF

Flashpoint acknowledges that EEA, UK, and Swiss individuals have the right to
access the personal data we maintain about them. Upon request
to privacy@flashpoint-intel.com with the subject line, “Data Privacy Framework,”
we will provide you with confirmation as to whether we are processing your
personal data, and have the data communicated to you within a reasonable time.
You have the right to correct, amend or delete your personal data where it is
inaccurate or has been processed in violation of this Privacy Policy. 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 data 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 data 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 US State Privacy Rights

Other US State consumer privacy laws may provide their residents with similar
rights regarding our use of their personal data. 

For example, these other US State consumer privacy laws may provide the
following rights:

 * 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 data.)
 * 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 data.

For all verifiable consumer requests, Flashpoint 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.

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

To the extent applicable, Flashpoint will honor these requests and will
otherwise comply with these US State Privacy laws regarding personal data we
collect and retain.

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 2024 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.



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PRIVACY PREFERENCE CENTER

When you visit any website, it may store or retrieve information on your
browser, mostly in the form of cookies. This information might be about you,
your preferences or your device and is mostly used to make the site work as you
expect it to. The information does not usually directly identify you, but it can
give you a more personalized web experience. Because we respect your right to
privacy, you can choose not to allow some types of cookies. Click on the
different category headings to find out more and change our default settings.
However, blocking some types of cookies may impact your experience of the site
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These cookies are necessary for the website to function and cannot be switched
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which amount to a request for services, such as setting your privacy
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block or alert you about these cookies, but some parts of the site will not then
work. These cookies do not store any personally identifiable information.

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FUNCTIONAL COOKIES

Functional Cookies

These cookies enable the website to provide enhanced functionality and
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PERFORMANCE COOKIES

Performance Cookies

These cookies allow us to count visits and traffic sources so we can measure and
improve the performance of our site. They help us to know which pages are the
most and least popular and see how visitors move around the site.    All
information these cookies collect is aggregated and therefore anonymous. If you
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will not be able to monitor its performance.

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TARGETING COOKIES

Targeting Cookies

These cookies may be set through our site by our advertising partners. They may
be used by those companies to build a profile of your interests and show you
relevant adverts on other sites.    They do not store directly personal
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