This Privacy Policy describes how Coronet Cyber Security Inc. (together with its affiliated companies, “Coro”, “we”, “us”) handles the personal data of the visitors of Coro’s website, and users or other third parties whose data is processed via the application for cloud security, e-mail security and end-point protection and the Coro Console (the “Platform”).
This Privacy Policy describes how Coro collects, stores, uses and discloses data relating to identified or identifiable individuals (“personal data” or “personal information”) which Coro processes as a data controller. It does not apply to the personal data Coro processes in the role of a data processor on behalf of Coro’s Customers (“Customer Data”), as further explained in Section 10 below.
Specifically, this Privacy Policy outlines Coro’s practices regarding the following types of personal data:
User Data: personal data relating to users of the Platform (e.g., Customers’ account administrators and end users of the Platform, and any other individual who uses or accesses the Platform (collectively, “Users”));
Prospect Data: personal data relating to any individual who visits Coro’s website (including www.coro.net) or otherwise interacts with Coro regarding Coro’s services via various sales and marketing channels, such as digital ads and content, emails, integrations or communications under Coro’s control (“Sites”, and collectively with the Platform, the “Services”). This also includes participants at events, webinars and other business and marketing activities that Coro organizes or participates in (collectively, “Prospects”).
Business Contact Data:personal data relating to Coro’s Customers’ internal focal persons who directly engage with Coro concerning their organization’s Coro account (e.g. billing contacts and authorized signatories), individuals who act as or work for a Service Provider (defined in Section 5 below) or supplier to Coro, and those who are employed by existing business or technology partners (“Partners”), to the extent their personal data has been disclosed to Coro in its capacity as a data controller (collectively, “Business Contacts”).
Email Protection Data: personal data relating to Customers’ Users, personnel, service providers, and any other third party whose personal data is contained in any email (including attachments) processed by Coro via the Email Protection Services (as further described in Coro’s Terms of Use (“Terms”).
This Privacy Policy describes Coro’s practices regarding:
Please read this Privacy Policy carefully and make sure that you fully understand it. Coro’s Services are designated for businesses and are not intended for personal or household use. Accordingly, Coro treats all personal data covered by this Privacy Policy, including information about any visitors to the Sites, as pertaining to individuals acting as business representatives, rather than in their personal capacity.
You are not legally required to provide Coro with any personal data, and may do so (or avoid doing so) at your own free will. However, please note that without such data, Coro may not be able to provide you with the full range of Services or with the best user experience when interacting with them. If you prefer not to disclose your personal data to Coro, or to have it processed by Coro or its Service Providers (defined in Section 5 below), please do not provide Coro with your personal data and refrain from using or interacting with the Services. You may also submit a request to exercise your rights as further explained in Section 9 below.
Data Collection and Processing
Types of personal data collected. Coro may collect and generate the following types of personal data through the Services:
Usage, login credentials to the Platform, and device information concerning Users, Business Contacts and Prospects: connectivity, technical and aggregated usage data, such as user agent, IP addresses and approximate location based on such IP addresses, digital identifiers, device data (like type, OS, device id, browser version, locale and language settings used), activity logs, session recordings, log-in credentials to the Services, the cookies and pixels installed or utilized on the device, and inferred or presumed data generated from use of the Services.
Coro collects and generates this information automatically, including through the use of analytics tools (including cookies and pixels), which collect data, such as how often the Sites are visited, which pages are visited and when, which website, ad or email message brought the individual there, and how the Services and their various features are used and interacted with.
Contact and profile information concerning Users, Prospects and Business Contacts: contact and business details such as name, email, phone number, position, workplace and related business insights, Coro’s communications with such individuals (correspondence, sensory information, including call and video recordings, and transcriptions and analyses thereof), feedback and testimonials received, CV, social media profiles, contractual and billing details, as well as any expressed, presumed, declared or identified needs, preferences, attributes and insights relevant to potential or existing engagements.
Coro collects this information directly from Users, Contacts or Business Contacts, or from other sources and third parties such as Customers as a part of Coro’s commercial engagement. Coro may also obtain personal data from Service Providers, e.g., marketing and sales tools, data enrichment services, sales and marketing partners, distributors, job recruiters, or your colleagues.
Communications with Users, Business Contacts and Prospects: Personal data contained in any forms and inquiries that may be submitted to Coro, including support requests, interactions through social media channels and instant messaging apps, registrations to events that Coro hosts, organizes or sponsors, and participation in Coro’s online and offline activities; surveys, feedback and testimonials; expressed, presumed or identified needs, preferences, attributes and insights relevant to potential or existing engagements; and sensory information including phone call and video conference recordings (e.g., with Coro’s customer experience or product consultants), as well as written correspondences, screen recordings, screenshots, documentation and related information that may be automatically recorded, tracked, transcribed and analyzed, for purposes including analytics, quality control and improvements, training, and record-keeping purposes.
Email Protection Data: Where a Customer has enabled the Email Protection Services functionality via the Platform, Coro monitors sent and received emails, including any attachments. Coro may automatically retain personal data via this process, for example personal data included in email content, documents, metadata, email addresses, IP addresses and shared files. Any personal data contained in these emails and retained on Coro’s servers, are retained for developing and improving new products and services, and improving the performance, functionality, safety, and security of the Services, or as otherwise authorized or requested by the Customer, including through the Customer’s use and configuration of the Services.
For the purposes of the California Consumer Privacy Act (“CCPA”), in the last twelve (12) months, Coro has collected the following categories of personal information: Identifiers; Professional or Employment-Related Information; Internet or other Electronic Network Activity Information; Customer Records Information; Geolocation Information; Commercial Information; Inferences; Audio, electronic, visual, thermal, olfactory information; and Sensitive Personal Information (to the extent contained in the content of emails or other files monitored by the Email Protection Services). Coro does not use or disclose Sensitive Personal Information as defined by the CCPA beyond what is necessary to provide the Services.
Data Uses
Coro uses personal data for the following purposes, in reliance on the following lawful bases for processing:
Purpose
Lawful basis for processing
To facilitate, operate, enhance, and provide the Services.
Performance of a contract; Legitimate Interest.
To provide Customers and Users with assistance and support, to test and monitor the Services, or diagnose or fix bugs or other issues.
Performance of a contract; Legitimate Interest.
To personalize the Services, including by recognizing an individual and remembering their information when they return to the Services, and to provide further localized and personalized experiences.
Legitimate Interest.
To facilitate and optimize marketing campaigns, ad management and sales operations, and to manage and deliver advertisements for the Services more effectively, including on other websites and applications. Such activities allow Coro to highlight the benefits of using the Services, and thereby increase engagement and overall satisfaction with the Services.
Legitimate Interest; Consent.
To facilitate, sponsor and offer certain events, contests and promotions.
Legitimate Interest.
To gain a better understanding of how individuals use and interact with the Services, which content they have processed through the Services, and how Coro can improve user experience and the value that can be generated from using the Services, so that Coro may continue improving its products, offerings and the overall performance of the Services.
Legitimate Interest.
To contact Users, Business Contacts and Prospects with general or personalized service-related messages, as well as promotional messages that may be of specific interest to them.
Legitimate Interest; Consent.
To support and enhance data security measures, including for the purposes of preventing and mitigating the risks of fraud, error or any illegal, criminal or prohibited activity.
Performance of Contract; Legitimate Interest; Legal Obligation.
To authenticate the identity of Users and allow them to access and use the Services.
Performance of a contract.
To explore and pursue growth opportunities by facilitating a stronger local presence and tailored experiences.
Legitimate Interest.
To create aggregated statistical data, inferred non-personal data, or anonymized or pseudonymized data (rendered non-personal and non-identifiable), which Coro anditsService Providers may use to provide and improve the respective services, or for any other purpose.
Legitimate Interest.
To develop and improve new products and services, and to improve the performance, functionality, safety, and security of the Services, including through the use of machine learning and artificial intelligence technology.
Legitimate Interest.
To enforce Coro’s Terms to resolve disputes, to carry out obligations and enforce Coro’s rights, and to protect its business interests and the interests and rights of third parties.
Legitimate Interest.
To comply with contractual and legal obligations and requirements, and maintain compliance with applicable laws, regulations and standards.
If you reside or are using the Services in a territory governed by privacy laws under which “Consent” is the only or most appropriate lawful basis for the processing of personal data (in general, or specifically with respect to the types of personal data you expect or elect to be processed by or via the Services, or due to nature of such processing), your acceptance of Coro’s Terms and this Privacy Policy will be deemed as your consent to the processing of your personal data for all purposes detailed in this Privacy Policy, unless applicable law requires a different form of consent. If you wish to revoke such consent, please contact Coro at [email protected].
Data Location
Coro and its authorized Service Providers (defined in Section 5 below) maintain, store and process personal data in the United States (“US”), the United Kingdom (“UK”), European Union (“EU”), Israel, and other locations, as reasonably necessary for the proper performance and delivery of the Services, or as may be required by law.
As Coro operates globally and may use service providers worldwide, including in the US, Europe, Israel and other locations as reasonably necessary for the proper performance of the Services, or as may be required by law, Coro may transfer your personal data outside your country of residence.
While privacy laws may vary between jurisdictions, Coro is committed to protecting personal data in accordance with this Privacy Policy and customary industry standards, and such appropriate lawful mechanisms and contractual terms requiring adequate data protection, regardless of any lesser legal requirements that may apply in the jurisdiction to which such data is transferred.
For data transfers from the European Economic Area, Switzerland or the UK, Coro will transfer personal data only to such countries, approved by the relevant authorities within those jurisdictions as providing adequate level of data protection, or enter into Standard Contractual Clauses as approved by the relevant data protection authority. To obtain a copy of these clauses, contact Coro as indicated in Section 11 below.
Data Retention
Coro retains personal data for as long as it is deemed reasonably necessary to establish, maintain and expand upon the relationship with you and provide you with the Services and offerings; in order to comply with legal and contractual obligations; or to protect Coro from any potential disputes (e.g. as required by laws applicable to log-keeping, records and bookkeeping, and in order to maintain evidence of our relationship, should any legal issues arise following a Customer’s discontinuance of the Services), all in accordance with Coro’s data retention policy.
To determine the appropriate retention period for personal data, Coro considers the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of personal data, the purposes for which Coro processes the personal data and any other applicable legal requirements.
For any questions regarding Coro’s data retention practices, please contact [email protected].
Data Disclosure
Coro may disclose personal data in the following situations:
Service Providers: Coro engages selected third-party companies and individuals to perform services on Coro’s behalf or that are complementary to our own. Such service providers include hosting and server co-location services, communications and content delivery networks (CDNs), data security services, billing and payment processing services, fraud detection and prevention services, web and product analytics, e-mail distribution and monitoring services, performance measurement, data optimization and marketing services, social and advertising networks, content and data enrichment providers, event production and hosting services, e-mail, voicemails, support, enablement and customer relation management systems, and legal, financial and compliance advisors (collectively, “Service Providers“). Coro’s Service Providers may have access to personal data, depending on each of their specific roles and purposes in facilitating and enhancing the Services, and may only use the data as determined in Coro’s agreements with them.
Partnerships: Coro engages selected business partners, resellers, distributors and providers of professional services related to the Services, which allow Coro to explore and pursue growth opportunities by facilitating a stronger local presence and tailored experiences for Customers, Users and Prospects. In such instances, Coro may disclose relevant contact, business and usage details with the respective partner, to allow them to engage with those entities and individuals for such purposes. If you directly engage with any Coro partner, please note that any aspect of that engagement which is not directly related to the Services and directed by Coro is beyond the scope of Coro’s Terms and this Privacy Policy and may therefore be covered by the partner’s terms and privacy policy instead.
Event Sponsors: If you attend an event or webinar organized by Coro or a conference in which Coro is also in attendance, or if you download or access a related asset on theSites, or other activity involving third-party sponsors or presenters, Coro may disclose personal data to them. You may consent to such disclosure via the registration form or by allowing your attendee badge to be scanned at a sponsor booth, depending on the jurisdiction and the applicable law. In these circumstances, your personal data will be subject to the sponsor’s privacy policies. If you do not wish for your personal data to be disclosed, you may choose not to opt in via event/webinar registration, elect not to have your badge scanned, or you can opt out in accordance with Section 7 below.
Business Customers & Account Administrators: Coro may disclose Users’ personal data with their affiliated organization. In certain cases, other Users from the relevant organization may control an account and will be entitled to monitor, process and analyze the data and associated content, including (i) view any content a User submits and their activities on the Services; (ii) view statistics regarding a User’s account; (iii) change a User’s account password or other access credentials or privileges; (iv) suspend or terminate account access; and (v) access or retain data stored as part of a User’s account. Please note that in these circumstances Coro is not responsible for and does not control any further disclosure, use or monitoring by or on behalf of a User’s organization, that acts as the “Data Controller” of such data (as further described in Section 10 below).
Legal Compliance: Coro may disclose or allow government and law enforcement officials access to personal data in response to a subpoena, search warrant or court order (or a similar requirement), or in compliance with applicable laws and regulations. Such disclosure or access may occur if Coro believes in good faith that: (a) Coro is legally compelled to do so; (b) disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing; or (c) such disclosure is required to protect Coro’s legitimate business interests, including the security or integrity of its products and services. Personal data may also be disclosed in the event of insolvency, bankruptcy or receivership.
Protecting Rights and Safety: Coro may disclose personal data to others if Coro believes in good faith that this will help protect the rights, property or personal safety of Coro, any User, Prospect, Business Partner or Customer, or any members of the general public.
Coro Subsidiaries and Affiliated Companies: Coro may disclose personal data for the purposes described in this Privacy Policy. Additionally, should Coro or any of its affiliates undergo any change in control or ownership, including by means of merger, acquisition, or purchase of substantially all or part of its assets, personal data may be disclosed or transferred to the parties involved in such an event. Coro may disclose personal data to a third party during negotiation of, in connection with, or as an asset in, such a corporate business transaction. If Coro believes that such change in control might materially affect your personal data then stored with us, Coro will notify you of this event and the choices you may have via e-mail and/or prominent notice on the Services.
Zoom Text Messaging: Through Coro’s use of the Zoom Text Messaging Service, Coro does not disclose personal data (mobile phone information) and any associated consents with any other third parties or affiliates for marketing and promotional purposes, excluding text messaging originator opt-in data and consent.
Personal data from Google OAuth API: Coro’s use and transfer to any other app of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.
Additional Disclosure: For the avoidance of doubt, Coro may disclose personal data in additional manners, pursuant to explicit approval, if legally obligated to do so, or if Coro has successfully rendered such data non-personal, non-identifiable and anonymous. Coro may transfer or disclose non-personal and non-identifiable data at Coro’s sole discretion and without the need for further approval.
For the purposes of the CCPA, in the past twelve (12) months, Coro has disclosed Identifiers; Professional or Employment-Related Information; Internet or other Electronic Network Activity Information; Customer Records Information; Geolocation Information; Commercial Information; Inferences; Audio, electronic, visual, thermal, olfactory information; and Sensitive Personal Information to the third parties listed above.
Cookies and Data Collection Technologies
Coro and its Service Providers use cookies and other technologies for performance, tracking, analytics and personalization purposes. Coro may disclose non-identifiable / aggregated extracts of such information with its partners for legitimate business purposes.
Cookies are packets of information sent to a web browser and then sent back by the browser each time it accesses the server that sent the cookie. Some cookies are removed when a browser session is closed. These are the “Session Cookies”. Some last for longer periods and are called “Persistent Cookies”. Coro uses both types.
Some cookies are necessary for the Services to function properly, and cannot be declined or disabled unless deleted and blocked through web browser settings. Other cookies, which are used for functional, performance, analytics and marketing purposes, are optional. These include web and app analytics tools and tools that provide Coro with insights on the performance of Coro’s ads and campaigns.
While Coro does not change its practices in response to a “Do Not Track” signal in the HTTP header from a browser or mobile application, cookie preferences can be managed, including whether or not to accept them and how to remove them, through the browser settings. Please bear in mind that disabling cookies may complicate or even prevent you from using the Services.
Coro uses Google Analytics, a web analytics tool which helps Coro understand individuals’ behavior on the Sites, including by tracking page content, and click/touch, movements, scrolls and keystroke activities. Further information about the privacy practices of Google Analytics is available at: www.google.com/policies/privacy/partners/. Further information about the option to opt out of Google Analytics is available at: https://tools.google.com/dlpage/gaoptout.
Please note that if you get a new device, install a new browser, erase or otherwise alter your browser’s cookie file (including upgrading certain browsers), you may also clear the opt-out cookies installed once you opt-out, so an additional opt-out will be necessary to prevent additional tracking.
Communications
Coro engages in service and promotional communications, including through email, phone and notifications.
Service Communications: Coro may contact Users and Business Contacts with service-related information regarding the Services. For example, Coro may send notifications (through any of the means available to Coro) of changes or updates to the Services, billing issues, log-in attempts or password reset notices, etc. Please note that you will not be able to opt out of receiving certain service communications which are integral to your use (like password resets or billing notices).
Notifications and Promotional Communications: Coro may also notify Users, Prospects, Customers and Business Contacts about new features, additional offerings, events, special opportunities or any other information Coro thinks will be valuable. Coro may provide such notices through any of the contact means available to Coro (e.g., phone, mobile or e-mail), through the Services, or through marketing campaigns.
If you do not wish to receive such promotional communications, you may notify Coro at any time by sending an e-mail to [email protected], or by following the “unsubscribe”, “stop”, “opt out” or “change e-mail preferences” instructions contained in the promotional communications you receive.
Data Security
To protect the personal data that Coro holds, Coro uses industry-standard physical, procedural and technical security measures, including encryption, as appropriate to secure personal data, to minimize the risks of theft, damage, loss of information, or unauthorized access or use of information. However, please be aware that regardless of any security measures used, Coro cannot and does not guarantee the absolute protection and security of any personal data stored with Coro or with any third parties as described in Section 5 above.
Data Subject Rights
Individuals have rights concerning their personal data. Please contact Coro by e-mail at [email protected] if you wish to exercise your privacy rights under applicable law, including the EU or UK General Data Protection Regulation (“GDPR”), the Swiss Federal Act on Data Protection, (“FADP”), the California Consumer Privacy Act (“CCPA”) and other US State laws. Such rights may include, each to the extent available to you under the laws which apply to you: the right to know/request access to (specific items of personal data collected; categories of personal data collected; categories of sources from whom the personal data was collected; purpose of collecting personal data; categories of third parties with whom we have disclosed personal data), to request rectification or erasure of your personal data held with us, to restrict or object to such personal data’s processing (including the right to direct us not to sell your personal data to third parties now or in the future), to port such personal data, or the right to equal services and prices (e.g. freedom from discrimination). You may also have a right to lodge a complaint with a competent data protection authority, such as the supervisory authority in the EU Member State of your habitual residence, place of work, or of the alleged GDPR infringement, the UK’s Information Commissioner’s Office, or your State’s Attorney General (as applicable).
You may designate an authorized agent, in writing or through a power of attorney, to request to exercise your privacy rights on your behalf. The authorized agent may submit a request to exercise these rights by emailing Coro.
Please note that when you ask us to exercise any of your privacy rights, Coro may need to ask you to provide certain credentials to make sure that you are who you claim you are, to avoid disclosure of personal data related to others, and to obtain further information that will allow us to better understand the nature and scope of the data subject to your request. Coro may not be able to fulfill your request unless you have provided sufficient information that enables Coro to reasonably verify that you are the individual about whom Coro collected the personal data, and if such data is processed on behalf of any Customer, to which Customer it particularly relates, so that Coro may forward it to them for their further handling. Such additional information may be then retained by Coro for legal purposes (e.g., as proof of the identity of the person submitting the request, or proof of request fulfillment). Coro may redact from the data made available to you any personal data or confidential information related to others.
If your request relates to personal data contained in Customer Data (i.e., personal data Coro processes on a Customer’s behalf as its “data processor” or “service provider” detailed further in Section 10 below), please note that such Customer determines how this data may be processed, as well as if and how your request should be handled. You should therefore submit your request directly to the relevant Customer.
Data Controller/Processor
Certain data protection laws and regulations, such as the EU GDPR, UK GDPR and the CCPA typically distinguish between two main roles for parties processing personal data: the “data controller” (or “business” under the CCPA), who determines the purposes and means of processing; and the “data processor” (or “service provider” under the CCPA), who processes the data on behalf of the data controller. Below is an explanation about how these roles apply to our Services, to the extent that such laws and regulations apply.
Coro is the “data controller” of User, Prospect and Business Contact Data. With respect to such data, Coro assumes the responsibilities of data controller (solely to the extent applicable under law), as set forth in this Privacy Policy. In such instances, Coro’s Service Providers processing such data on our behalf will generally assume the role of “data processor”.
Coro is the “data processor” of Customer Data (i.e. personal data that Coro collects, processes and manage solely on behalf of Customers through their use of the Platform or any other service, product or solution described on one or more applicable order forms and/or commercial agreements). Coro processes such Customer Data on behalf of and under the instruction of the respective Customer, in accordance with the commercial agreement and the Data Processing Addendum. This Privacy Policy (which describes Coro’s own privacy and data processing practices as Coro processes data independently) does not apply to such processing done on Customers’ behalf.
Coro processes Customer Data strictly in accordance with Customers’ reasonable instructions and as further stipulated in the Data Processing Addendum and other commercial agreements between Coro and the Customer.
Coro is both a “data controller” and a “data processor” of Email Protection Data. Such data is processed by Coro as a Data Processor when processing solely on behalf of the Customer, and for its own purposes (as described in Section 2 above), as an independent controller.
Coro’s Customers are solely responsible for determining whether and how they wish to use the Services, and for ensuring that all individuals using the Services on the Customer’s behalf or at their request, as well as all individuals whose personal data may be included in Customer Data or Email Protection Data processed through the Services, have been provided with adequate notice and provided informed consent for the processing of their personal data, where such consent is necessary or advised, and that all legal requirements applicable to the processing of Customer and Email Protection Data through the Services are fully met by the Customer, including in the context of an employment relationship. Coro’s Customers are also responsible for handling data subject requests under applicable law by their Users, personnel and other individuals whose data they process through the Services.
Additional Notices & Contact Details
Updates and Amendments: Coro may update and amend this Privacy Policy from time to time by posting an amended version on our Services. The amended version will be effective as of the published date. Coro will provide prior notice if Coro believes any substantial or material changes are made via any of the communication means available to Coro or via the Services. After such notice period, all amendments to this Privacy Policy shall be deemed accepted by you through your continued use of the Services.
External Links: While Coro’s Services may contain links to other websites or services, Coro is not responsible for their privacy practices. Coro encourages individuals to pay attention when leaving the Services for the website or application of such third parties, and to read the privacy policies of each and every website and service visited. This Privacy Policy applies only to Coro’s Services.
Children: Coro’s Services are not designed to attract children who are underage according to data protection laws in their respective jurisdictions. Coro does not knowingly or intentionally collect personal data from such underage children and does not wish to do so, and Coro requests that anyone underage refrains from providing their personal data to Coro. If you believe that Coro might have any such data, please contact Coro at [email protected]. If Coro is made aware that a person who is underage according to the law applicable to them is using the Services, Coro will attempt to prohibit and block such use and will make all necessary efforts to delete any personal data stored with Coro with regard to that child, except where retention is required for legal purposes. For the purposes of the CCPA, Coro does not knowingly sell or share the personal information of individuals under the age of 16.
Data Protection Officer: Coro has appointed PrivacyTeam as its Data Protection Officer (“DPO”), for monitoring and advising on Coro’s ongoing privacy compliance and serving as a point of contact on privacy matters for data subjects and supervisory authorities. If you have any comments or questions regarding our Privacy Policy, if you have any concerns regarding your privacy, or if you wish to make a complaint about how your personal data is being processed by Coro you can contact our DPO at [email protected].
UK Representative: Coronet Cyber Security UK Limited. has been designated as Coro’s representative in the UK for data protection matters pursuant to Article 27 of the UK GDPR. Enquiries regarding our UK privacy practices may be sent via email to [email protected] or via mail to 30 Old Bailey, London, EC4M 7AU, United Kingdom.
Database Controller: For the purposes of Israel’s Protection of Privacy Law (“PPL”) Coronet Cyber Security Ltd. serves as the “Database Controller” responsible for the personal data processed in connection with the Services that is subject to the PPL, and may be contacted at [email protected].
Contacting Coro: If you have any comments or questions regarding this Privacy Policy, or if you have any concerns regarding your personal data held with Coro, please contact Coro at [email protected].
