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Privacy Notice

Privacy Notice

Last modified 24.05.2018 This Privacy Notice will help you understand what personal information Kudelski SA and its affiliates collect and use when providing Services to you and your privacy rights associated with that personal information.   

For the purposes of this Privacy Notice, “Services” refers to marketing, promotional, and customer relationship management activities carried out by Kudelski Security and websites (www.kudelskisecurity.com) and unless expressly specified herein, does not include personal information collected by products and solutions commercialized by the Kudelski Group, which are governed by privacy terms made available with such specific products and solutions.  Contact – Privacy Committee Kudelski Security is a division of the Kudelski Group, headquartered in Cheseaux-sur-Lausanne, with American headquarters in Phoenix, Arizona, United States. 

The Group has appointed Privacy Committee for you to contact if you have any question or concerns about personal data handling policies and practices. Please send your inquiry to [email protected]. In your email, please describe in as much detail as possible the nature of your inquiry or the ways in which you believe that the Privacy Notice has not been complied with.  Changes and Updates to the Privacy Notice As our Services to you may change from time to time, this Privacy Notice may need to be updated accordingly.

Kudelski Security reserves the right to amend this Privacy Notice at any time at its sole discretion and will provide notice of material changes on this website. We may email you (provided you have an email address registered with us) about material changes therein, prior to them becoming effective but we invite you to consult this page on a regular basis to get information on our latest privacy practices. By continuing to use the Services after changes to the Privacy Notice have become effective, you are giving your agreement to the revised Notice with the following exception: If at the time you provide personal information to Kudelski SA or to one of its affiliates you are given the opportunity to limit how such information will be used to communicate with you, either by Kudelski Security or by third parties, Kudelski Security will not change your preference in this regard without your express consent.

However, if Kudelski Security or one of its affiliates sells assets (or the assets of a division or subsidiary) to another entity, or Kudelski Security is acquired by, or merged with, another entity, Kudelski Security may provide to such entity customer information that is related to that part of our business that was sold to, or merged with, the other entity without your consent. If, as the result of such changes, you want to alter the ways in which Kudelski Security is allowed to use your personal information, you can do so by following the procedure described below in the section titled “Access and Control over your Personal Information”. 

Personal Information We Collect Kudelski Security collects personal information about its customers and other individuals for the purpose of providing the Services to them. This information falls into several categories, including: 

Contact Information Management

We receive information prior to/during fulfilment of contractual services for customers. This may include, for example, your name, designation/job role, company you represent, telephone number and email address that, as such, you provide us with during the pre-relationship stage, proposal discussions, contract negotiations, and the duration of time for which we provide the customer with services. We will use the data to carry out the services for which we have been contracted and to contact customers for customer care-related purposes, including regular communication regarding project status, notifying issues/concerns, sharing project deliverables, billing, carrying out day-to-day project activities, and other related activities in order to comply with our contractual obligations towards the customer.In order to reduce errors in our database, authenticate our users and prevent abuse of our system we may on occasion supplement the personal information you submit to us with information from third party sources. For example, we may supplement your registration information with address information provided by the Swiss Postal Service to qualify your information and prevent errors in our database. 

Marketing-related engagement with Kudelski Security

As a visitor to the Kudelski Security public websites and landing pages, you can engage in various activities, such as downloading publications, signing up to newsletters, events, or requesting additional information (via online forms, or email addresses, including: 

Online Subscriptions  

To sign up to newsletters, you will need to submit an online form, containing personal information.  This can include: first and last name, company name, job title, mailing address (including zip code), professional e-mail address, telephone numbers, country of residence. You will be requested to stipulate which marketing and promotional activities of Kudelski Security you wish to be contacted about.  You can unsubscribe at any given time using the link provided in the web page, email, or by contacting us directly [email protected], In order to receive other related marketing and promotional communication from Kudelski Security, you need to opt-in when you register. 

Event Registration 

Kudelski Security hosts events relating to its products, services, market trends and other relevant cybersecurity-related topics, throughout the year. These events (including webinars, webcasts, live events) are posted on the website, communicated via email, social media, and online advertising and other means (e.g. promotional flyers).  To sign up to events, you will need to submit an online form, containing personal information. This can include: first and last name, company name, job title, mailing address (including zip code), professional e-mail address, telephone numbers, country of residence. In order to receive other related marketing and promotional communication from Kudelski Security, you need to opt-in when you register. 

Training

A range of security training and education courses are held throughout the year. Information on these can be accessed via the Kudelski Security website and promotional or marketing communication.  Some training is provided by a third-party company, to whom we may need to disclose your personal information for reasons relating to the training (e.g. organization).  To sign up to training, you will need to submit an online form, containing personal information. This can include: first and last name, company name, job title, mailing address (including zip code), professional e-mail address, telephone numbers, country of residence. In order to receive other related marketing and promotional communication from Kudelski Security, you need to opt-in when you register. 

Publications Download 

We publish publications throughout the year on issues relating to cybersecurity.  Some publications (factsheets, brochures, presentations, blog posts (on www.research.com and www.ModernCISO.com and video content) do not require you to provide personal information.  Other publications (such as white papers or Reference Architectures) do require you to provide personal information.  This information can include: first and last name, company name, job title, mailing address (including zip code), professional e-mail address, telephone numbers, country of residence. In order to continue to receive related marketing and promotional communication from Kudelski Security, you need to opt-in when you register. 

Information Collected from Third Parties 

We may receive information about you from other sources, including publicly available databases, trusted third-party services, or partners with which we offer co-branded services. We may also receive information from our affiliated companies. This helps us to update and analyze our records, identify new prospects for promotional and marketing activities.  

Kudelski Security Websites 

Information That We Collect Automatically on our Websites Our websites use cookies and other technologies to provide enhanced functionality on the site, track data traffic and aggregate traffic movement (e.g. what pages are popular, what sequence of webpages are visited) for analysis, marketing campaigns (e.g. retargeting via pixel tracking), and to gather demographic information about our user base as a whole. These technologies record information about your use of our websites, including: 

  • Browser and device data, such as IP address, region or general location where your computer or device is accessing the internet device type, operating system and Internet browser type, screen resolution, operating system name and version, device manufacturer and model, language, plug-ins, add-ons and the language version of the Sites you are visiting.
  • Usage data, such as time spent on the sites, pages visited, links clicked, language preferences, and the pages that led or referred you to our sites.  

To learn more about the cookies that may be served through our websites and how you can control our use of cookies and third-party analytics, please see below.  

Information on Cookie Use A cookie is a text file placed on your computer, to help the website analyze how you use the site.  When you visit the site again, the cookie enables the site to recognize your browser and deliver an improved user experience (saving time, or retrieving pieces of information for a customized experience).We use first-party cookies (set by Kudelski Security) and third-party cookies (set by other parties) that enable features such as advertising, interactive content and analytics to be provided. 

The types of cookies we use are: 

  • Essential website cookies: These cookies are strictly necessary to provide you with services available through our Websites, Subscription Service and Mobile Apps and to use some of its features, such as access to secure areas.
  • Performance and functionality cookies: These cookies are used to enhance the performance and functionality of our Websites, Subscription Service and Mobile Apps but are non-essential to their use. However, without these cookies, certain functionality may become unavailable.
  • Analytics and customization cookies: These cookies collect information that is used either in aggregate form to help us understand how our Websites, Subscription Service and Mobile Apps are being used or how effective our marketing campaigns are, or to help us customize our Websites for you.
  • Advertising cookies: These cookies are used to make advertising messages more relevant to you. They perform functions like preventing the same ad from continuously reappearing, ensuring that ads are properly displayed for advertisers, and in some cases selecting advertisements that are based on your interests.
  • Social networking cookies: These cookies are used to enable you to share pages and content that you find interesting on our Websites, Subscription Service or Mobile Apps through third party social networking and other websites. These cookies may also be used for advertising purposes too. 

In particular, the Kudelski Security website uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”) that uses cookies. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage.

Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website. By using Kudelski Security website, you consent to the processing of data about you by Google in the manner and for the purposes set out above. How You Can Control Cookies You can typically remove or reject cookies via your browser settings. In order to do this, follow the instructions provided by your browser (usually located within the “settings,” “help” “tools” or “edit” facility). 

Many browsers are set to accept cookies until you change your settings. Further information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.youronlinechoices.com If you do not accept our cookies, you may experience some inconvenience in your use of our website. For example, we may not be able to recognize your computer or mobile device and you may need to log in every time you visit our website.

Pixel tags

We may also use pixel tags (which are also known as web beacons and clear GIFs) on our website to track the actions of users on our site. Unlike cookies, which are stored on the hard drive of your computer or mobile device by a website, pixel tags are embedded invisibly on webpages. Pixel tags measure the success of our marketing campaigns and compile statistics about usage of the site, so that we can manage our content more effectively. The information we collect using pixel tags is not linked to our users’ personal information.

Do Not Track Signals

Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to do not track signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com. 

Third Party Websites 

Please note that Kudelski Security is not responsible for the content or privacy practices of non-Kudelski SA websites to which the websites may link. You should review the privacy Notice of such websites before using the sites. 

Sharing of your Personal Information to Third Parties 

Kudelski Security will on occasion share your information with third parties as described in the notice.  We may share your personal information with thirds party services providers, affiliated companies within our corporate structure, vendors and as needed for legal purposes.  

  • Affiliates: Kudelski Security may disclose your personal information to affiliated companies within the Kudelski Group for matters pertaining to corporate management (e.g. customer relationship management or sales).
  • Vendor Partners: From time to time, we may run a joint or co-sponsored program or promotion via our line tools with another company, organization or reputable third party.  As part of this event, we may collect and process personal information.  When doing any promotional or marketing activity with another company, we will always give you the opportunity to op in to receive information directly from that third-party company.  
  • Service Providers: We may use third parties to provide service support for the internal operations of our websites, applications and online advertisements, and to assist us in the administration of our websites, applications, advertisements, and functions, programs and promotions we run. These third parties may come into contact with your personal information as a result of providing services to us. We may also disclose your personal information to any third party with your prior consent.  

Legal Basis for Processing Personal Information 

The legal basis for the processing of your Personal Information as described above is your consent or our need for processing your personal information in order to be able to perform a contract with you or your company. In some cases, we may also have a legal obligation to collect personal information from you and process it. You have the right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal. 

International Transfer of Personal Information

Within Kudelski Security 
When you submit Personal Information to Kudelski Security through the website or other digital and print means, you understand and agree that this information may be transferred across national boundaries and may be stored and processed by Kudelski Security and its affiliates in any of the countries in which Kudelski Security maintains offices, including without limitation, Switzerland and the USA. We put in place appropriate contractual data protection agreements or use other appropriate legal mechanisms to safeguard the transfer of information. 

Transfers to Third Parties 
You also acknowledge that in certain countries or with respect to certain activities, the collection, transferring, storage and processing of your information may be undertaken by technology vendor partners working with Kudelski Security (see above). When we transfer your personal information internationally to third parties, we strive to ensure the appropriate legal mechanisms are put in place, in order to safeguard the transfer and guarantee compliance with applicable data protection laws. 

Security of your personal information

Kudelski SA and its affiliates have put in place appropriate physical, technical measures and managerial procedures to safeguard and help prevent your personal information from loss, misuse, unauthorized access, disclosure, alteration or destruction. We update and test such security measures on an ongoing basis and restrict access to your personal information to those employees who need to know that information to provide Services to you. Our employees receive training about privacy matters, including confidentiality and security of your personal information. If a password is used to protect your account with us, it is your responsibility to keep the password confidential. Do not share this information with anyone. 

Retention of your personal information

Our policy is to retain your data for a reasonable period of time, taking into consideration our need to deliver services, answer queries, resolve problems, provide and communication on new and improved services, products, or analysis and comply with legal requirements. The data retention period for marketing and communications starts from the date you first provide Kudelski Security your data by subscribing to receive our content, products or services and lasts for a period of 24 months after your last interaction with us.  We retain information from cookies and other tracking technologies for a reasonable period of time from the date the information was created. 

Access and Control over your Personal Information 

Kudelski Security makes it possible for you to access your Personal Information and more particularly to:⦁ review, correct, update or delete the Personal Information you have supplied us with (to the extent Kudelski Security is not otherwise permitted or required to keep such data);⦁ object to certain data processing operations or ask us to restrict processing of your Personal Information; if we have collected and process your Personal Information based on your consent, withdraw such consent at any time; or receive a copy of your Personal Information processed by us. To exercise any of these rights, you may unsubscribe at any given time using the link of a specific web page, email, or visit section “I want to access and update my personal information” of our website, or contact us directly at [email protected] or [email protected] or by mail to: 

Kudelski SARte de Genève 22-241033 Cheseaux-sur-Lausanne Switzerland Attn. Privacy Committee 

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