This Privacy Policy (“Privacy Policy”) explains how CipherTrace (“Company” or “we” or “us”) collects, uses, stores, and discloses personal information from our users (“users” or “you”) when you interact with our website, ciphertrace.com (our “website”) or our application (our “app”, and together with our website, our “services”). This Privacy Policy is effective as of April 15, 2021.
INFORMATION WE COLLECT AND USE
What information we collect from you: Our Services don’t collect any personal information, except (i) your name and email address to create your account or (ii) your email address if you subscribe to our newsletter.
When you use our Services, our servers may automatically log the standard data provided by your web browser. This data is considered “non-identifying information”, as it does not personally identify you on its own. It may include your computer’s Internet Protocol (IP) address, your browser type and version, the pages you visit, the time and date of your visit, the time spent on each page, and other details.
We may also collect data about the device you are using to access our Services. This data may include the device type, operating system, unique device identifiers, device settings, and geo-location data. What we collect can depend on the individual settings of your device and software. We recommend checking the policies of your device manufacturer or software provider to learn what information they make available to us.
How we collect or receive information about you: from your use of our services, using cookies, and when you provide it to us through signing up for our newsletters.
How we use your information: i.e. to contact you, to improve our business and services, to fulfil our contractual obligations, to improve our product and communicate improvements, to analyze your use of our services, and in connection with our legal rights and obligations. We also use aggregated usage information to monitor and track usage demand trends so that we can scale the system accordingly.
Why do we disclose your information to third-parties: only to the extent necessary to run our business, to fulfill any contracts we enter into with you or our service providers, or where required by law or to enforce our legal rights.
Whether we sell your information to third parties outside of the course of a business sale or purchase of a similar transaction: No.
How do we secure your information: we take measures to secure your information such as storing it on secure servers and encrypting transfers of data to or from our servers using Secure Sockets Layer (SSL) technology.
Do we use cookies and similar technologies: yes, we use cookies and similar technologies such as web beacons.
Do we use automated decision making and profiling: we do not use automated decision making and/or profiling.
What rights do you have with regard to your information:
- to have your information corrected and/or completed
- to access your information and understand how we use it
- to have your information deleted or the use of your information restricted
- to receive your information in an accessible format
- to withdraw the consent you provided to the use of your information
- to object to the use of your information
- to complain to us and/or to a supervisory authority about the use of your information.
HOW LONG WE STORE YOUR INFORMATION
As best as we can, we set out specific retention periods for your information. In the cases where that is not possible, we have set out certain criteria we use to determine the retention period for such information.
Account Credentials: When you set up an account to use the Services, we will retain your information for at least as long as your account remains active and for a period of five (5) years thereafter.
Inquiries and Correspondence: when you send us an email, fill out our contact form, call us, or correspond with us regarding any matter, we will retain your information for at least as long as it takes to respond to and resolve your inquiry and for five (5) years thereafter.
Newsletter Email Subscription: when you subscribe to our newsletter, we keep your contact information you entered for as long as you remain subscribed or until we decide to cancel our newsletter email service, whichever comes first.
Criteria for determining retention periods
Other than the foregoing, we will store your information for no longer than necessary and will assess the need for retention based on the following:
- Whether we are legally required to continue to process your information to be compliant with any record-keeping obligations;
- Whether we have your consent or other legal basis to continue to process your information;
- How valuable your information currently is and will be in the future;
- What the purposes and use of your information both now and in the future will be and whether we need to continue to retain your information in order to fulfill contractual obligations with you;
- The difficulty in ensuring your information is up to date and accurate;
- Whether there are any industry standards surrounding how long such information should be stored;
- The risk, cost, and liability involved with continuing to store your information; and
- Any other circumstances surrounding the nature of our relationship.
HOW WE SECURE YOUR INFORMATION
We take commercially reasonable measures to protect all collected information from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. Our technical and organizational measures to secure your information include:
- Storing information on secure servers;
- Encrypting transfers of data to or from the Company’s servers using Secure Sockets Layer (SSL) technology;
- Restricting access to your information and only sharing it to the minimum extent necessary, and on an anonymized basis when possible and subject to confidentiality restrictions where appropriate and;
- Verifying the identity and need of any individual who may request access to your information prior to providing them with such access.
We cannot guarantee the security of the internet, and any information you submit to us over the internet, such as email, contact form submission, or other means, is transmitted entirely at your own risk. We are not responsible for any expenses, harm to reputation, damages, liabilities, loss of profits, costs, or any other type of loss experienced by you as a result of your decision to transmit information to us via the internet.
YOUR RIGHT TO OBJECT TO THE PROCESSING OF YOUR INFORMATION
You may also exercise the right to object to us using or processing your information for direct marketing purposes by sending an email to [email protected], or by writing to us at 140 Victory Lane, Los Gatos CA, 95030, or by clicking the unsubscribe link listed at the bottom of any marketing email that we send to you and then following the instructions that appear on your browser. For more information.
CHILDREN’S PRIVACY
We are committed to protecting the privacy of children, and we comply with the Children’s Online Privacy Protection Act of 1998 (COPPA). We neither knowingly nor intentionally contact or collect any information from persons under the age of 18 years old. Our services are not intended to solicit information of any kind from persons under the age of 18 years old.
If we receive information about persons under the age of 18 by a third party, or by deception or fraud, and are notified of the collection of such information, we will, where required to do so by law, immediately seek the appropriate parental consent to use that information or we will delete such information from our servers. If you are aware of any transmission of information about persons under the age of 18 years old, please send us an email at [email protected]
CALIFORNIA DO NOT TRACK DISCLOSURES
“Do Not Track” is a privacy setting that users can set in their web browsers. If a user turns on a Do Not Track signal in their browser, the browser transmits a message to websites requesting that they do not track the user. The company has not implemented a methodology to respond to Do Not Track signals because we do not collect any.
PRIVACY QUESTIONS
CipherTrace’s data controller representative is Jelle Vink. You may contact the CipherTrace data controller representative by writing to 140 Victory Lane, Los Gatos, CA, 95030 or sending an email to [email protected]
If you have any questions about this Privacy Policy, please contact the data controller representative.