Effective Date: May 18, 2021
A “Customer” means an entity that has contracted with Menlo Security (such as through an applicable services agreement) to access our products, solutions or platforms (the “Menlo Security Technology”).
A “User” means an individual who accesses the Menlo Security Technology as or on behalf of a Customer, including Customer personnel.
A “Site Visitor” means an individual who visits our Site outside of the context of our Customers’ use of the Solutions.
A “Customer End User” means an individual whose information Menlo Security receives from Customer, or otherwise processes on Customer’s behalf, in connection with the Solutions provided by Menlo Security to Customer pursuant to an applicable services agreement.
If you are a Customer End User and you have questions about how your information is collected and processed through the Solutions, please contact the Customer who has provided your information to us for more information.
THE INFORMATION WE COLLECT
We collect, store and use certain information from or about you for the purposes described below.
1. INFORMATION YOU PROVIDE TO US
We collect a variety of information that you provide directly to us. For example, we collect information from you through:
When you register for an account with us
Your use of the Services
Requests or questions you submit to us via online forms, email, or otherwise
When we reach out to you by phone or email in our sales and marketing efforts
Your participation in surveys, sweepstakes, or contests
When you communicate with our customer service teams via email, phone, or chat
When you attend our conferences or events or interact with us at other conferences or events
When you use a blog or forum made available through the Services
The types of data we collect directly from you include:
First and last name
Your company or organization name
Any other information you choose to directly provide to us in connection with your use of the Services
We may also collect and store any data and related output created, derived or generated by you through the use of the Services, as well as your Services usage, and your usage of the Menlo Security Technology.
2. INFORMATION WE COLLECT THROUGH AUTOMATED MEANS
When you use our Services, we and our service providers (who are third parties that perform services on our behalf) automatically collect certain information about your device and how you use the Services, including your IP address, browser type, browser language, operating system, the state or country from which you accessed the Services, software and hardware attributes (including device IDs), referring and exit pages and URLs, platform type, the number of clicks, files you download, domain names, landing pages, pages viewed and the order of those pages, the amount of time spent on particular pages, the date and time you used the Services, error logs, and other similar information. From your IP address, we may be able to infer your general location (e.g., city/state or postal code).
3. INFORMATION WE COLLECT FROM OTHERS
From time to time, we may collect information about you from other sources, including marketing vendors, survey providers, data enhancement services, social media, conferences, and other industry events or other purposes that we explain to you at the time of collection, to the extent permitted by applicable law. We use this information to supplement the information that we collect directly from you in order to derive your possible interests and provide more relevant experiences for you and improve our Services, analytics, and advertising.
When you “like” or “follow” us on Facebook, LinkedIn, Twitter or other social media sites, we may collect some information from you including your name, email address, and any comments or content you post relevant to us.
HOW WE USE YOUR INFORMATION
We use your information for various purposes depending on the types of information we have collected from and about you, in order to:
Provide you with access to and to administer our Services
Respond to your requests for information and provide you with more effective and efficient customer service
Contact you by email, postal mail, or phone with news, updates, information, promotions, surveys or contests relating to the Menlo Security Technology or our Services or other services that may be of interest to you, in accordance with applicable legal requirements related to such communications (note you may update your may update your Menlo Security email subscriptions on the Menlo Security Subscription Center)
Customize the content you see on our Services
Engage in analysis and research regarding use of the Site and the Services, and improve the Menlo Security Technology and our Services
Secure our Services and resolve technical issues being reported
Comply with any procedures, laws, and regulations which apply to us where it is necessary for our legitimate interests or the legitimate interests of others
Establish, exercise, or defend our legal rights where it is necessary for our legitimate interests or the legitimate interests of others
Aggregate/De-Identified Information. We may aggregate and/or de-identify any information collected through our Services so that such information can no longer be linked to you or your device (“Aggregate/De-Identified Information”). We may use such information for any purpose, including without limitation for research and marketing purposes, and may also share such data with any third parties, including advertisers, partners, and sponsors.
LEGAL BASES FOR USE OF YOUR INFORMATION
Where we need to perform the contract we are about to enter into or have entered into with you for the Services
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests
Where we need to comply with a legal or regulatory obligation in the EU
Where we have your consent to process your information in a certain way
ONLINE ANALYTICS AND ADVERTISING
ANALYTICS. We may use third-party web analytics services (such as those of Google Analytics) on our Services to collect and analyze usage information through cookies and similar tools; engage in auditing, research, or reporting; assist with fraud prevention; and provide certain features to you. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-out Browser Add-on by clicking here. If you receive email from us, we may use certain analytics tools, such as clear GIFs to capture data such as when you open our message or click on any links or banners our email contains. This data allows us to gauge the effectiveness of our communications and marketing campaigns.
ONLINE ADVERTISING. In using the Services, we allow select third party advertising technology partners to place cookies or other tracking technologies on the browser of your device to collect information about you as discussed above. These third parties (e.g., ad networks and ad servers such as Google, Facebook, and others) may use this information to serve relevant content and advertising to you as you browse the Internet, and access their own cookies or other tracking technologies on your browser to assist in this activity. If you are interested in more information about these online advertising activities, and how you can generally control cookies from being put on your computer to deliver tailored advertising, you may visit the Network Advertising Initiative’s Consumer Opt-Out link, the Digital Advertising Alliance’s Consumer Opt-Out link, or Your Online Choices to opt-out of receiving tailored advertising from companies that participate in those programs. We do not control these opt-out links or whether any particular company chooses to participate in these opt-out programs. We are not responsible for any choices you make using these mechanisms or the continued availability or accuracy of these mechanisms. Please note that if you use these mechanisms, you may still see advertising on our Services or across the Internet, but it will not be tailored to you based on your online behavior over time.
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. We are committed to providing you with meaningful choices about the information collected on our Services for third party purposes, and that is why we provide the variety of opt-out mechanisms listed above. However, we do not currently recognize or respond to browser-initiated DNT signals.
HOW WE SHARE AND DISCLOSE YOUR INFORMATION
We will share your information in the following ways:
Service Providers. We provide access to or share your information with select third parties who help us deliver or improve our Services or perform services on our behalf, including billing and credit card verification, advertising and marketing, Services content and features, analytics, research, customer service, shipping and fulfillment, data storage, security, web hosting, fraud prevention, and legal services.
Affiliates and Subsidiaries. We may share the information we collect within the Menlo Security family of companies.
Your Company. If you are a User, we may provide your information to the company you are engaged or employed by in order to fulfill and enforce our services agreement with your company, and to inform your company regarding usage, support, or training needs.
Testimonials. We may display personal testimonials and endorsements of satisfied customers on the Services, and with your consent, will associate your name or your company’s name with such postings.
Protection of Menlo Security and Others. By using the Services, you acknowledge and agree that we may access, retain, and disclose the information we collect and maintain about you if required to do so by applicable law or in a good faith belief that such access, retention or disclosure is reasonably necessary to: (a) comply with legal process (e.g. a subpoena or court order); (b) enforce any contracts with you, including our End User License Agreement; (c) respond to claims that any content violates the rights of third parties; and/or (d) protect the rights, property or personal safety of Menlo Security, its agents and affiliates, its users and/or the public.
Business Transactions. In accordance with applicable legal obligations, your information may be provided to third parties in connection with a merger or acquisition (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of Menlo Security or our assets, or as part of a corporate reorganization or stock sale or other change in corporate control or fundamental business change, including for the purpose of determining whether to proceed or continue with such transaction or business relationship.
Aggregate/De-Identified Information. From time to time, we may share Aggregate/De-identified Information about use of the Services or our user base with partners and others, but such information will not identify you personally.
RETENTION OF YOUR INFORMATION
We keep your information for no longer than necessary for the purposes for which it is processed. The length of time for which we retain information depends on the purposes for which we collected and use it and/or as required to comply with applicable laws.
YOUR RIGHTS AND YOUR CHOICES
You have certain rights with respect to your information as further described in this section.
1. YOUR LEGAL RIGHTS
If you would like further information in relation to your legal rights under applicable law or would like to exercise any of them, please contact us using the information in the “Contact Information” section below at any time. Your local laws (e.g., if you are a citizen or resident of the European Economic Area or California) may permit you to request that we:
provide access to and/or a copy of certain information we hold about you
update information which is out of date or incorrect
delete certain information that we are holding about you
restrict the way that we process and disclose certain of your information
They may also permit you to revoke your consent for the processing of your information.
We will consider all requests and provide our response within the time period stated by applicable law and as otherwise required by applicable law. Please note, however, that certain information may be exempt from such requests in some circumstances, which may include if we need to keep processing your information for our legitimate interests or to comply with a legal obligation. We may request you provide us with information necessary to confirm your identity before responding to your request. To submit a request, please contact us at firstname.lastname@example.org.
If you are a Customer End User and your information has been collected by Menlo Security as a result of our Customer’s use of the Menlo Security Technology pursuant to a services agreement between Customer and Menlo Security, Menlo Security collects and processes any information of yours under the directions of the relevant Customer. If these circumstances apply to you and you wish to access, edit, delete or exercise any rights you may have under applicable data protection laws with respect to any information that we have collected about you, please direct your query to the relevant Customer, as this may expedite the completion of your request. We nevertheless provide reasonable assistance to our Customers to give effect to data subject rights as appropriate and required by applicable laws. Please note that End User Communications are collected only temporarily by the Menlo Security Technology and the content does not persist in our systems.
THIRD PARTY LINKS AND FEATURES
Your information is maintained and processed by us and our third-party service providers in the United States, and may also be maintained, processed, and stored in other jurisdictions that may have different data protection laws than those in your country of residence. In the event that your information is transferred in these ways, please note that we comply with applicable legal requirements governing the transfer of information across borders. By using the Services, you agree to and acknowledge these transfers.
HOW WE PROTECT YOUR INFORMATION
Menlo Security takes a variety of technical and organizational security measures to protect the information provided to us from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or email transmission is ever fully secure or error free. Please keep this in mind when disclosing any information to us online.
PRIVACY INFORMATION FOR CALIFORNIA USERS
If you are a California resident, California law requires us to provide you with some additional information regarding how we collect, use, and share your “personal information” (as defined in the California Consumer Privacy Act (“CCPA”)).
Category of Personal Information
How We Use this Personal Information
Contact Information (such as your full name, phone number, address, email address)
Login Information (such as your account name and password)
Professional or Employment Information (such as the name and address of the company you work for and your title)
Device and Online Information (such as mobile device content, IP address, browsing history, and usage information)
Other information (any other information you choose to provide directly to us)
B. Your California Privacy Rights. The CCPA allows you to make certain requests about your personal information. Specifically, the CCPA allows you to request us to:
Inform you about the categories of personal information we collect or disclose about you; the categories of sources of such information; the business or commercial purpose for collecting your personal information; and the categories of third parties with whom we share/disclose personal information.
Provide access to and/or a copy of certain personal information we hold about you.
Delete certain personal information we have about you.
Provide you with information about the financial incentives that we offer to you, if any.
The CCPA further provides you with the right not to be discriminated against (as provided for in applicable law) for exercising your rights. Please note that certain information may be exempt from such requests under California law. For example, we need certain information in order to provide the Service to you. We also will take reasonable steps to verify your identity before responding to a request. In doing so, we may ask you for verification information so that we can match at least two verification points with information we maintain in our files about you. If we are unable to verify you through this method, we shall have the right, but not the obligation, to request additional information from you.
If you would like further information regarding your legal rights under California law or would like to exercise any of them, or if you are an authorized agent making a request on a California consumer’s behalf, please contact us using the contact information provided below. If you are a Customer End User, please contact the Customer who has provided your information to us for more information.
Shine the Light Disclosure: The California “Shine the Light” law gives residents of California the right under certain circumstances to request information from us regarding the manner in which we share certain categories of personal information (as defined in the Shine the Light law) with third parties for their direct marketing purposes. We do not share your personal information with third parties for their own direct marketing purposes.
NOTICE TO NEVADA RESIDENTS
Certain Nevada consumers may opt out of the sale of “personally identifiable information” for monetary consideration (as such terms are defined under Nevada law) to a person for that person to license or sell such information to additional persons. We do not engage in such activity; however, if you are a Nevada resident who has purchased goods or services from us, you may submit a request to opt out of any potential future sales under Nevada law by contacting us using the methods outlined in the “Contact Information” section. Please note we may take reasonable steps to verify your identity and the authenticity of the request. Once verified, we will maintain your request in the event our practices change.