Last Revised: September 21,
2022
This mobile privacy policy (“Mobile
Privacy Policy”) explains how Talon Cyber Security Ltd. (“Talon”,
“our”, “we” or “us”) collect and process information you
may provide us when you access and use our TalonWork™ mobile application that
we license to you (“App”). “Users” or “you” refer to our Customers and
End Users (as defined in our Terms of Use).
This Mobile Privacy Policy supplements and shall be read in conjunction with
our Terms of Use (the “Terms of Use”), and may be supplemented by
additional privacy statements, terms or notices provided to you. Capitalized
terms that are not defined herein, shall have the
meaning ascribed to them in our Terms of Use.
1. YOUR CONSENT
PLEASE READ THIS MOBILE PRIVACY POLICY BEFORE
ACCESSING AND USING THE APP . BY ACCESSING THE APP,
YOU AGREE TO THE TERMS AND CONDITIONS SET FORTH IN THIS MOBILE PRIVACY POLICY, INCLUDING TO THE COLLECTION AND PROCESSING OF YOUR PERSONAL
INFORMATION (AS DEFINED BELOW). IF YOU DISAGREE TO ANY TERM PROVIDED HEREIN,
YOU MAY NOT ACCESS OR USE THE APP.
IMPORTANT – PLEASE NOTE
THAT THE TALONWORK APP IS INTENDED FOR BROWSING ACTIVITIES THAT ARE STRICTLY
AFFILIATED TO YOUR WORKPLACE. UNLESS PERMITTED OTHERWISE BY CUSTOMER, THE
TALONWORK APP IS NOT INTENDED TO BE USED FOR ANY BROWSING ACTIVITIES WHICH ARE
CONSIDERED AS ‘PRIVATE’ NON-WORK
RELATED ACTIVITIES. IN PARTICULAR, YOU MAY NOT PROVIDE, MAKE
AVAILABLE OR DISPLAY ANY SENSITIVE PERSONAL DATA SUCH AS PERSONAL DATA
CONCERNING HEALTH, RELIGIOUS BELIEFS, AND SEXUAL ORIENTATION (WHETHER SUCH
PERSONAL DATA PERTAINS TO USER OR A THIRD PARTY) WHEN USING THE TALONWORK APP.
Please note: you are not
obligated by law to provide us with any Personal Information. You hereby
acknowledge and agree that you are providing us with Personal Information at your own free will. You hereby agree that we may collect
and use such Personal Information pursuant to this Mobile Privacy Policy and
any applicable laws and regulations.
2. WHAT TYPES OF INFORMATION DO YOU COLLECT?
We divide the
information we access and collect into two categories: Personal Information and
Non-Personal Information. In this section, we describe each of the two
categories of information which we may collect, and the applicable
circumstances under which such collection is performed.
2.1. Non-Personal Information: “Non-Personal Information” is un-identified and non-identifiable information pertaining to a user, which may be made available to us, or collected automatically via your use of the App. Such Non-personal Information does not enable us to identify the person from whom it was collected, and mainly consists of technical and aggregated usage information which is not linked to an identifiable individual, such as system data related to your mobile operating system.
2.2. Personal Information: “Personal Information” is information that
identifies an individual or may with reasonable efforts or together with
additional information we have access to, enable the identification of an
individual, or may be of a private or sensitive nature relating to an
identified or identifiable natural person. Identification of an individual also
includes the association of such individual with a persistent identifier such
as a name or an identification number.
Personal Information does not include information that has been
anonymized or aggregated; provided, that, such
information can no longer be used to identify a specific natural person. Such Personal Information that is collected by us consists
of the following types of information:
Ø Personal
Information that you actively provide to Talon.
Basic personal information which you may provide upon registration to the the App, which includes your name workplace email and password.
Ø Personal Information that we collect or generate in
connection with your use of the App.
The information we obtain through your use of the App, which is derived, learned, or detected as a result of such access and/or interaction:
· Browsing attributes related to your browsing activities within the App, including URLs of websites accessed through the App, browsing history and requests and responses from visited URLs (e.g. IP addresses from which web requests are sent to Talon);
· File attributes concerning files downloaded and uploaded from and to your App. We do not collect the underlying data or materials contained in such files, but only technical details pertaining such file, such as type, title, size, source and additional related information);
· IP address;
· Interaction with the App, including usage pattern, taps, clicks, scrolling information, and other information about how you interact with the App.
· Crash Data such as crash logs and related reports.
We do not collect any Personal Information from you or
related to you without your approval, which is obtained, inter alia,
through your acceptance of this Mobile Privacy Policy.
3. WHY DO YOU COLLECT AND PROCESS MY
INFORMATION?
We may use information that we collect and receive about you for the following purposes:
· To allow registration and enable your continued authenticated access to the App.
· To provide Customers an ongoing overview of its network activity and potential vulnerabilities.
· To prevent potential cyber risks which may arise in connection with certain requests, downloads or other browsing behavior through the App.
· To investigate security incidents, if and to the extent such has occurred.
· To be able to deliver and enhance the App, and to provide you with technical assistance and support.
· To send you updates, notices, notifications, and additional information related to the App.
· To create cumulative statistical data and other cumulative information that is non-personal, with which we may use in order to operate and improve our App and related products.
· To comply with any applicable rule or regulation and/or response or defend against legal proceedings versus us or our affiliates.
4. WHAT ARE YOUR LEGAL GROUNDS FOR COLLECTING
MY PERSONAL INFORMATION?
With your consent: We ask for your agreement to process your information for the specific purposes stated in this Mobile Privacy Policy and you have the right to withdraw your consent at any time.
Contractual necessity: We process certain information so we can provide and
operate the App in accordance with our contractual obligations provided in
connection with provision of the App.
Legitimate interests: We process your information for our legitimate interests while applying appropriate safeguards that protect your privacy. This means that we process your information for purposes like detecting, preventing or otherwise addressing fraud, abuse, security, usability, functionality or technical issues with our App; protecting against harm to the rights, property or safety of our properties, our users or the public as required or permitted by law; enforcing legal claims, including investigation of potential violations of this Mobile Privacy Policy; and in order to comply and/or fulfil our obligations under applicable laws, regulation, guidelines, industry standards and contractual requirements, legal process, subpoena or governmental request.
5. WHO DO YOU SHARE MY INFORMATION WITH AND
WHY?
We
may share information with third parties (or otherwise allow them access to it)
only in the following manners and instances:
Internally – We may share information with our family companies, as well as our employees, for the purposes described in this Mobile Privacy Policy and in accordance with Section 3 above. In addition, should Talon or any of its affiliates undergo any change in control, including by means of merger, acquisition or purchase of substantially all of its assets, your information may be shared with the parties involved in such event under strict security conditions, for the purpose of evaluating such event and in accordance with the terms of this Mobile Privacy Policy. If we believe that such change in control might materially affect your Personal Information then stored with us, we will notify you of this event and the choices you may have, through prominent notice on our Services.
Protecting Our Rights and Safety – We may share your information to enforce this Mobile Privacy Policy, including investigation of potential violations thereof; to detect, prevent, or otherwise address fraud, security or technical issues; or otherwise if we believe in good faith that this will help protect the rights, property or personal safety of any of our users, or any member of the general public.
Third Parties & Business Partners – We may share your information with a number of selected service providers, whose services and solutions are required or otherwise facilitate achievement of the purposes of processing set forth under Section 3 above. These third parties services include among others, cloud hosting services (e.g. AWS). Our third party services providers act as our sub-processors and may only process your information according to our instructions (which are given in accordance with the terms hereof). We remain responsible for any processing of your information done by such third party service providers on our behalf not in accordance with the terms hereof, except for events outside of such service providers’ reasonable control.
Law Enforcement – We may cooperate with government and law enforcement officials to enforce and comply with the law. We may therefore disclose any information to government or law enforcement officials as we believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), to protect our or a third party’s property and legal rights, to protect the safety of the public or any person, or to prevent or stop any activity we may consider to be, or to pose a risk of being, illegal, unethical, inappropriate or legally actionable.
For avoidance of doubt,
we may share permanently anonymized or de-identified information with any other
third party, at our sole discretion.
6. WHERE DO YOU TRANSFER OR STORE MY
INFORMATION?
Your information may be transferred to, maintained, processed and stored by us and our authorized affiliates and
service providers in the USA, EU and Israel. Please note that USA and Israeli
data and privacy laws may not be as comprehensive as those in your country of residence.
Residents of certain countries may be subject to additional protections,
as set forth in below.
GDPR (EEA Users): This
section applies only to natural persons residing in the European Economic Area
(for the purpose of this section only, "you" or "your" shall be limited accordingly). It is Talon's
policy to comply with the EEA's General Data Protection Regulation (“GDPR”).
In accordance with the GDPR, we may transfer your Personal Information from
your home country to Israel, the U.S. and/or other countries, provided that the
transferee has provided appropriate safeguards, and on condition that
enforceable data subject rights and effective legal remedies for data subjects
are available. Specifically, we may cause such transfer if we ensured that at least one of the following applies:
Ø The country to which Personal Information has been transferred, has been determined by the EU Commission to be a country providing adequate protection to the privacy rights of EU residents.
Ø Application of Standard Contractual Clauses (also known as "Model Clauses") where appropriate.
You have additional rights regarding your personal
data under the GDPR, please refer to Section 7 below.
7. WHAT ARE MY RIGHTS?
If
applicable to you under your country’s jurisdiction, you may have certain
rights in connection with your Personal Information and how we handle it. You
can exercise your rights at any time by contacting us via the contact details
set out under Section 14 below. Those rights may include, but are not limited
to, the following:
Ø Right of access. You may have a right to know what information we hold about you and in some cases to have the information communicated to you. We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any information.
Ø Right to correct Personal Information. We endeavor to keep the information that we hold about you accurate and up to date. Should you realize that any of the information that we hold about you is incorrect, please let us know and we will correct it as soon as we can.
Ø Data deletion. In some circumstances you have a right to request that some portions of the Personal Information that we hold about you be deleted or otherwise anonymized.
Ø Data portability. In some circumstances, you may have the right to request that data which you have provided to us is provided to you, so you can transfer this to another data controller.
Ø Restriction of processing. In some cases, you may have the right to request a restriction of the processing of your Personal Information, such as when you are disputing the accuracy of your information held by us.
8. DO
YOU USE COOKIES OR SIMILAR TRACKING TECHNOLOGIES?
We
use certain monitoring and tracking technologies, including ones offered by
third party service providers. These technologies are used in
order to maintain, provide and improve our App on an ongoing basis, and
in order to provide a better experience to our users. For example, these
technologies enable us to: (i) keep track of our users’
preferences and authenticated sessions, (ii) secure our App by detecting
abnormal behaviors, (iii) identify technical issues and improve the overall
performance of our App, and (iv) create and monitor analytics.
We may use cookies in
connection with our Services. A “Cookie” is a small data file that is
downloaded and stored on your computer or mobile device when you visit our
Services. We use the following third-party Cookies:
●
Frontegg - Frontegg uses a cookie for strictly functional use to
authenticate your session after your initial sign-in to the App https://frontegg.com/privacy-policy.
Learn more about your choices and how to opt-out of
tracking technologies:
In order to delete or block any tracking technologies,
please refer to the “Help” area on your internet browser for further
instructions, or you may also opt out of third party tracking technologies by
following the instructions provided by each third party service provider in its
privacy policy listed above or visiting www.youronlinechoices.eu or www.aboutads.info/choices. Please note however that deleting any of our
tracking technologies or disabling future tracking technologies may prevent you
from accessing certain areas or features of our App, or
may otherwise adversely affect your user experience.
9. HOW DO YOU KEEP MY INFORMATION SECURE?
We have implemented administrative, technical, and
physical safeguards to help prevent unauthorized access, use, or disclosure of
your Personal Information. Your information is stored on secure servers and
isn’t publicly available. We limit access of your information only to those
employees, third party service providers or partners on a “need to know” basis,
and strictly in order to enable us to perform the
agreement between you and us.
Despite these measures, Talon cannot provide absolute
information security or eliminate all risks associated with Personal
Information, and security breaches may happen. If there are any questions about
security, please contact us at legals@talon-sec.com.
10. HOW LONG WILL YOU RETAIN MY INFORMATION?
We will retain your Personal Information only for as
long as necessary to achieve the purposes for collection and processing set
forth above. Retention periods will be determined taking into
account the type of information that is collected and the purpose for
which it is collected, bearing in mind the requirements applicable to the
situation and the need to destroy outdated, unused information at the earliest
reasonable time. If you withdraw your consent to our processing your Personal
Information, we will delete your Personal Information from our systems (except
to the extent retaining such data in whole or in part is necessary to comply
with any applicable rule or regulation and/or to respond to or defend against
legal proceedings brought against us or our affiliates).
11. HOW DO YOU PROTECT THE PRIVACY OF
CHILDREN?
To use our App, users must be
over the age of eighteen (18). Therefore, we do not knowingly collect Personal Information
from individuals under the age of eighteen and do not wish to do so. We reserve
the right to request proof of age at any stage so that we can verify that
individuals under the age of eighteen are not using the Services. If you
believe that we might have any information from or about an individual under
the age of eighteen, please contact us at legals@talon-sec.com.
12. UPDATES TO THIS MOBILE PRIVACY POLICY
This Mobile Privacy Policy is subject to changes from
time to time, in our sole discretion. The most current version will always be
posted on our App (as reflected in the “Last Revised” heading). You are advised
to check for updates regularly. By continuing to access and use our App after
any updates become effective, you accept and agree to be bound by the updated
Mobile Privacy Policy.
13. GENERAL INFORMATION
This Mobile Privacy Policy, its interpretation, and
any claims and disputes related hereto, shall be governed by the laws of the
State of New York, without respect to its conflict of law principles. Any and all such claims and disputes shall be brought in,
and you hereby consent to them being litigated in and decided exclusively by a
court of competent jurisdiction located in New York, New York.
This Mobile Privacy Policy was written in English and
may be translated into other languages for your convenience. If a translated
(non-English) version of this Mobile Privacy Policy conflicts in any way with
the English version, the provisions of the English version shall prevail.
14. HOW CAN I CONTACT YOU?
If you wish to exercise any of the aforementioned rights, or receive more information, please contact us using
the details provided below:
Email: legals@talon-sec.com
Address: 80 Menachem Begin St., Tel Aviv, Israel