Privacy Policy

In order to ensure transparency and to give you greater control over your personal information, this privacy policy (the “Privacy Policy“) governs how we, CISOteria Ltd. (together, “CISOteria“, “we“, “our” or “us“) use, collect and retain personal information (as defined below) that we collect or receive from you or about you (“you“), such as in the following use cases:

• When you browse or visit our website, https://cisoteria.com/ (the “Website“);
• When you use or interact with our Website
  1. When you register to join the CISOteria beta program
  2. When you contact us through the Website (for example, customer support, needing help, submitting a request)
• When you use or interact with the CISOteria platform (the “Platform“);
  1. When you create an account, log in to the Platform and purchase our services
• When you interact with us on our social media profiles (for example, Facebook, Instagram, Twitter, LinkedIn)

We greatly respect your privacy, and we therefore make every effort to provide a platform that meets the highest standards of user privacy. Please read this Privacy Policy carefully, so that you can fully understand our practices with respect to personal information. “Personal Information” means any information that can be used, alone or together with other data, to uniquely identify any living individual. Please note that some of the provisions in this Privacy Policy apply only to individuals in certain jurisdictions. For example, the legal basis in the table below is relevant only to individuals protected by the GDPR.

Important note: Nothing in this Privacy Policy is intended to limit in any way your legal rights, including your rights to a remedy or means of enforcement.

Table of Contents

What information we collect, why we collect it, and how it is used

1. How we protect and retain your personal information
2. How we share your personal information
3. Additional information regarding transfers of personal information
4. Your privacy rights
5. Use by children
6. Interaction with third-party products
7. Log files
8. Analytics tools
9. Specific provisions applicable under California privacy law
10. How to contact us

This Privacy Policy may be updated from time to time, and we therefore ask that you periodically review the current version of this Privacy Policy. If we make material changes to how we use your personal information in a manner different from that stated at the time of collection, we will notify you by posting a notice on our Website or by other means.

1. What information we collect, why we collect it, and how it is used

We collect personal information when you browse our Website, register for our beta program, use calculators, contact us, sign up for the Platform, or interact with us on social media. The categories of personal information we may collect include: full name, email address, company name, phone number, industry, job title, password, payment details, physical address, social media profile, and any other information you choose to share with us.

This information is used to: provide and operate our Website and Platform; provide our services; respond to your inquiries; provide support; personalize your experience; send marketing communications (where permitted); and comply with our legal and regulatory obligations. The legal basis for processing under the GDPR includes performance of a contract, legitimate interests, and consent. We may share personal information with third-party providers (for example, AWS for cloud storage and social media platforms such as LinkedIn and Facebook) for the purposes described above, and retain it until we no longer need it or until you submit a valid request for deletion, subject to applicable law.

Some of the personal information above will be used to detect and prevent fraud, and for security purposes. The personal information above may also be used to comply with applicable laws, for investigations conducted by the relevant authorities, for law enforcement purposes, and/or to exercise or defend legal claims. In certain cases, we may or will anonymize your personal information. “Anonymous information” means information that does not enable the identification of an individual user, such as aggregated information about the use of our services. We may use anonymous information and/or disclose it to third parties without restriction (for example, in order to improve our services and enhance your experience with them).

2. How we protect and retain your personal information

• Security. We have implemented appropriate technical, organizational and security measures designed to protect your personal information. However, please note that we cannot guarantee that the information will not be compromised as a result of unauthorized intrusion into our servers. Since information security depends in part on the security of the computer, device or network you use to communicate with us and on the security you use to protect your usernames and passwords, please be sure to take appropriate measures to protect this information.
• Retention of your personal information. In addition to the retention periods stated above, in certain circumstances we may retain your personal information for longer periods of time, for example (i) where we are required to do so in accordance with legal, regulatory, tax or accounting requirements, or (ii) in order to have an accurate record of your dealings with us in the event of complaints or appeals, or (iii) if we reasonably believe there is a prospect of litigation relating to your personal information or dealings. We have an internal data retention policy to ensure that we do not retain your personal information indefinitely. Regarding the retention of cookies, you can read more in our Cookie Policy.

3. How we share your personal information

In addition to the recipients described above, we may share your personal information as follows:

• Where necessary, with regulators, courts or competent authorities, in order to comply with applicable laws, regulations and rules (including, without limitation, federal, state or local laws), and with requests from law enforcement, regulatory and other governmental authorities, or if required to do so by court order;
• If in the future we sell or transfer, or consider selling or transferring, part or all of our business, shares or assets to a third party, we will disclose your personal information to such third party (whether actual or potential) in connection with the aforementioned events;
• In the event that we are acquired by, or merge with, a third-party entity, or in the event of bankruptcy or a similar event, we reserve the right to transfer, disclose or assign your personal information in connection with the aforementioned events; and/or
• Where you have given your consent to the sharing or transfer of your personal information (for example, where you provide us with marketing consents or sign up for additional optional services or functionality).

4. Additional information regarding transfers of personal information

• Storage: AWS – Europe (Ireland).
• Access from Israel: Access from Israel is covered by the European Commission’s adequacy decision regarding Israel.
• Internal transfers: Transfers within the CISOteria affiliated companies will be covered by an internal data processing agreement to be signed by the members of the CISOteria affiliated companies (an intra-group agreement) that contractually obligates each member to ensure that personal information receives an adequate and consistent level of protection wherever it is transferred.
• External transfers: When we transfer your personal information outside the EU/EEA (for example, to third parties that provide us with services), we will obtain contractual undertakings from them to protect your personal information. Some of these undertakings are well-recognized certification schemes such as the EU – US Privacy Shield for the protection of personal information transferred from the European Union to the United States.

5. Your privacy rights

Rights: The following rights (which may be subject to certain exceptions or derogations) will apply to certain individuals (some apply only to individuals protected by the GDPR):

• You have the right to access the personal information held about you. Ordinarily, you will be able to exercise your right of access free of charge, however we reserve the right to charge an appropriate administrative fee where permitted under applicable law;
• You have the right to request that we correct any personal information we hold that is inaccurate or misleading;
• You have the right to request the deletion of your personal information (for example, from our records). Please note that there may be circumstances in which we are required to retain your personal information, for example for the establishment, exercise or defense of legal claims;
• You have the right to object to, or request restriction of, the processing;
• You have the right to data portability. This means that you may have the right to receive your personal information in a structured, commonly used and machine-readable format, and that you have the right to transfer that data to another controller;
• You have the right to object to profiling;
• You have the right to withdraw your consent at any time. Please note that there may be circumstances in which we are entitled to continue processing your data, in particular if the processing is required in order to comply with our legal and regulatory obligations. Please also note that the withdrawal of consent will not affect the lawfulness of processing based on consent before its withdrawal;
• You also have the right to request certain details of the basis on which your personal information is transferred outside the European Economic Area, but data transfer agreements and/or other details may be required to be partially redacted for reasons of commercial confidentiality;
• You have the right to lodge a complaint with your local data protection supervisory authority (i.e., your place of habitual residence, place of work or the place of the alleged infringement) at any time or before the relevant institutions in your place of residence. We ask that you first attempt to resolve any issue with us before approaching your local supervisory authority and/or the relevant institution.

You can exercise your rights by contacting us at privacy@cisoteria.com. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly in accordance with applicable law or to notify you if further information is required in order to fulfill your request. When processing your request, we may ask you for additional information in order to confirm or verify your identity and for security purposes, before processing and/or honoring your request. We reserve the right to charge a fee where permitted by law, for example if your request is manifestly unfounded or excessive. In the event that your request would adversely affect the rights and freedoms of others (for example, would affect our duty of confidentiality toward others) or if we are legally entitled to handle your request in a manner different from that originally requested, we will attempt to handle your request to the maximum extent possible, all in accordance with applicable law.

Deleting your account: If you ever decide to delete your account, you can do so by sending an email to privacy@cisoteria.com. If you terminate your account, any link between your account and personal information we retain will no longer be accessible through your account. However, given the nature of sharing in certain services, any public activity on your account prior to deletion will remain stored on our servers and will remain publicly accessible.

6. Use by children

We do not offer our products or services for use by children, and accordingly, we do not knowingly collect personal information from, and/or about children under the age of eighteen (18). If you are under the age of eighteen (18), do not provide us with any personal information without the involvement of a parent or guardian. For the purposes of the GDPR, we do not intend to offer information society services directly to children. In the event that we become aware that you are providing personal information in violation of applicable privacy laws, we reserve the right to delete it. If you believe that we may have such information, please contact us at privacy@cisoteria.com.

7. Interaction with third-party products

We enable you to interact with third-party websites, mobile software applications and products or services that are not owned or controlled by us (each, a “Third-Party Service“). We are not responsible for the privacy practices or content of such Third-Party Services. Please note that Third-Party Services may collect personal information from you. Accordingly, we encourage you to read the terms and privacy of each Third-Party Service.

8. Log files

We use log files. The information within the log files includes internet protocol (IP) addresses, browser type, internet service provider (ISP), date/time stamp, referring/exit pages, pages clicked and any other information your browser may send to us. We use such information to analyze trends, administer the Website, track user movement on the Website and gather demographic information.

9. Analytics tools

We use a variety of analytics tools to maintain and improve our Website and services, including:

• Google Analytics – to collect information about Website usage (visit frequency, pages viewed, referring websites). You can opt out using the Google Analytics Opt-out Browser Add-on.
• Google Analytics for Firebase – to collect data about application users through mobile identifiers, cookies and similar technologies.
• Mixpanel – we collect personal information such as your email address and your user activity. You can opt out at https://mixpanel.com/optout/.
• AppsFlyer – a mobile attribution and marketing analytics platform that collects unique identifiers and technical data.
• AppSee – to collect and analyze data from our services.
• Hotjar – to better understand our users’ experience and optimize our service.
• Facebook Pixels and SDKs – to integrate, use and exchange information with Facebook for ad targeting and measurement.
• Google Signals – to enable cross-device remarketing for users who have enabled ads personalization.
• Facebook Custom Audience and Lookalike Audience.

We reserve the right to remove or add new analytics tools.

10. Specific provisions applicable under California privacy law

• California privacy rights: Section 1798.83 of the California Civil Code permits our customers who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to privacy@cisoteria.com. Please note that we will respond to one request per customer each year, unless otherwise required by law.
• Our California Do Not Track notice: We do not track consumers over time and across third-party websites, and therefore we do not respond to Do Not Track signals. We may permit third parties, such as companies that provide us with analytics tools, to collect personally identifiable information about an individual consumer’s online activities over time and across different websites when a consumer uses the Website.
• Removal of content from California residents: If you are a California resident under the age of 18 and a registered user, Section 22581 of the California Business and Professions Code permits you to remove content or personal information that you have publicly posted. If you would like to remove such content or personal information and specify which content or personal information you would like to remove, we will do so in accordance with applicable law. Please note that after removal you may not be able to restore content that has been removed. In addition, such removal does not guarantee complete or comprehensive removal of the content or personal information you have posted, and there may be circumstances in which the law does not require us to enable removal of content.
• Your privacy rights: Please see Section 5 above.

11. Contact us

If you have any questions, concerns or complaints regarding our compliance with this notice and with data protection laws, or if you would like to exercise your rights, we recommend that you first contact us at privacy@cisoteria.com.