Supporting the Managed Security Service Providers Who Serve the Largest Customers
Effective as of March 1st, 2019
A reference to “Nozomi Networks”, “Nozomi”, “we”, “us” or the “Company” is a reference to Nozomi Networks Inc. and the relevant affiliate involved in the processing activity. The office locations of Nozomi Networks Inc. and its affiliates can be found here.
2.1 Responsible Nozomi Networks Entity
Data controllers are defined as the natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are specific criteria for its nomination may be provided for by Union or Member State law.
For third party events, if required by applicable law, you may consent to sharing your information via the registration form or by allowing your attendee badge to be scanned at a sponsor booth. In these circumstances, your information will be subject to the sponsors’ privacy statements. If you do not wish your information to be shared, you may choose to not opt-in via event/webinar registration or elect to not have your badge scanned, or you can opt-out in accordance with the section related to “Managing Your Information”.
2.3 Information We Collect
Nozomi Networks gathers information from you to help us manage our relationship with you. The information we gather may include:
- Contact details, such as your user name, email address, telephone number, your company, your title, and where applicable, for recruitment purposes, education details, employment history, emergency contacts, immigration status, financial information (where we need to carry out financial background checks), and social security number (further, you may choose to share other relevant information with us),
- If you contact us by email we may keep a record of your contact information and correspondence, including any information that you provide to us in your message
- Information you provide to us to receive technical assistance or during customer service interactions
- Shipping, billing, and payment information
- Your transaction history
- Information about other people that you may provide to us with any program or services
- Information about your computer or device, including browser type and settings, IP address, and traffic data relating to your Internet connection
- Product performance data and information about how you use our products and services
- Aggregated data or other information that does not specifically identify you, such as actions taken on our websites
2.4 Browser Information
2.5 How We Use Your Information
We may use your information to:
- Allow you to view information on the website
- Provide you with a customized experience when you visit our websites
- Communicate with you, including responding to you if you contact us
- Manage event registrations and attendance, and to plan and host events or webinars for which you have registered or that you attend, including sending related communications to you
- Send marketing communications. We may process your Personal Data to send you marketing information and other non-transactional communications (e.g., marketing newsletters) about us and our affiliates and partners, including information about our products, promotions or events as necessary for our legitimate interest in conducting direct marketing or to the extent you have provided your prior consent (please see the “Managing Your Information” section below, to learn how you can opt-out)
- Provide, register and support our products and services
- Verify your identity and entitlement to products and services
- Where applicable, conduct due diligence or security screening for employment consideration, background checks and employment eligibility,
- Facilitate the provisioning of services
- Manage your registered user account through which you can take advantage of the services made available by Nozomi Networks, including access to the support or product download websites
- Deliver newsletters, product updates or technical alerts
- Allow you to download our “white papers”, participate in webinars or request a space in one of our training classes
- Market specific products and services
- Provide quotes, process orders and subscriptions, update order status, ship products, and collect payment information and payment
- Evaluate, analyze and improve Nozomi Networks’ products and services through surveys, questionnaires, and other methods of gathering information
- Collect feedback, conduct chat sessions and improve our chat sessions by reviewing them with our customer service representatives
- Communicate with you about and manage your participation in contests, offers or promotions
- Secure our systems and applications
- Enforce our legal rights or comply with legal requirements
- Meet contractual obligations
2.6 Information from Third Parties
We may combine information about you that we receive from third parties with the information we have gathered to improve the quality of our product and service offerings and to tailor our communications with you.
2.7 How We Share Your Information
2.8 Legal Basis
Where required by law, we will ensure there is a legal basis for the processing of your information. In most cases our legal basis will depend on the information concerned and the specific context in which we collect it.
2.8.1 Contract: the processing is necessary for the performance of the services we provide to you, or to take steps (at your request) prior to, and anticipation of, performing, such services;
2.8.2 Legal Obligation: the processing is necessary to comply with our legal obligations, including compliance with applicable laws, regulations, governmental and quasi-governmental requests, court orders or subpoenas;
2.8.3 Consent: the processing is based on your consent to the processing of your personal information for one or more specified purposes (for example, marketing);
2.8.4 Legitimate Interests: the processing is necessary to meet our legitimate interests, for example to develop and improve our websites, products and/or services for the benefit of our customers; or
2.8.5 Vital Interests: the processing is necessary to protect your vital interests (for example, health and safety reasons if you attend a meeting at one of our locations).
2.9 Nozomi Networks Servers
2.10 Resellers and Partners
2.11 Service Providers
2.12 Interest-based Advertising
The information you provide to us about your interest in our products may be pseudonymized and shared with third parties, where allowable, to provide more relevant advertising of Nozomi Networks products and services. If you receive Nozomi Networks advertising on a third-party website and you click on our product or service advertising, we will know the domain you came from. We do not track your other activities on that website.
2.13 Compliance with Laws and Law Enforcement
Nozomi Networks cooperates with governments, regulators, and law enforcement officials to enforce and comply with the law. We may disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including subpoenas and court orders); to protect the property and rights of Nozomi Networks or a third party; the safety of the public or any person; to prevent or stop any illegal, unethical or legally actionable activity; or to comply with the law.
2.14 Business Transfers
Nozomi Networks may decide to sell, merge or otherwise reorganize its businesses. Such transactions may involve, in accordance with applicable law, the disclosure of personal information to prospective or actual purchasers. In those cases, Nozomi Networks seeks and obtains appropriate protection for personal information.
Your personal information is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems and are required to keep the information confidential. In addition, all sensitive information you supply is encrypted via Secure Socket Layer (SSL) technology.
We implement a variety of security measures when a user enters, submits, or accesses their information to maintain the safety of your personal information.
Additionally, all our employees have agreed to observe your privacy and confidentiality rights.
2.16 International Transfer of Personal Data
Your Personal Data may be collected, transferred to and stored by us in the United States and by our affiliates in other countries where we operate.
Therefore, your Personal Data may be processed outside the European Economic Area (EEA), and in countries which are not subject to an adequacy decision by the European Commission and which may not provide for the same level of data protection as the EEA. In this event, we will ensure that the recipient of your Personal Data offers an adequate level of protection, for instance by entering into standard contractual clauses for the transfer of data as approved by the European Commission (Art. 46 GDPR), or we will ask you for your prior consent to such international data transfers.
2.17 Data Retention
Personal data will be maintained only as necessary to satisfy the reasons for which it was collected. We also retain and use your information as necessary to comply with our legal obligations, resolve disputes and enforce our agreements.
Like many websites, we also use “cookies” and similar technology to, for example, collect additional website usage data and to improve our websites and service.
A cookie is a small data file that we transfer to your computer’s hard disk. Some cookies may collect personal data in order to perform their intended functions.
2.19 Our Policy Towards Children
Nozomi Networks’ business is not focused on, nor do we knowingly collect information from children under the age of 13. If a parent or guardian becomes aware that his or her child under 13 has provided us with personally identifiable information, he or she should contact us at email@example.com. If we become aware that a child under 13 has provided us with personally identifiable information, we will remove that information.
2.20 Links to Other Websites
Our websites contain links to third party websites. The fact that we link to a third party website is not an endorsement, authorization, or representation of our affiliation with that third party. We do not exercise control over third party websites.
Other websites follow different rules regarding the use or disclosure of the personal information you submit to them. We encourage you to read the privacy policies or statements of the third party websites you visit.
2.21 Managing Your Information
2.21.1 The Choice to Opt-out
We provide an opt-out choice for most types of communication, such as updates from us regarding new services and product releases. You may opt out from the use of your personal information for those non-required communications. Your opt-out choice may be exercised by clicking on the link provided in the emails you receive or by sending an unsubscribe request to firstname.lastname@example.org.
Users cannot opt out of certain communications that are necessary for the service(s) provided to the user. For example, we may use your email address to confirm your opening of an account, to send you notice of payments, to send you information about changes to our products and services, to provide those products or services, and to send notices and other disclosures as required by law. We may also communicate by phone to resolve customer complaints or investigate suspicious transactions.
If you are an employee of a Nozomi Networks customer, we recommend you contact your company’s system administrator for assistance in correcting or updating your information.
2.21.2 Your Rights Relating to Personal Data, Inquiries, Access and Updating Your Personal Data
You have certain rights relating to your Personal Data, subject to local data protection laws. Depending on the applicable laws and, in particular, if you are located in the EEA, these rights may include:
- To access your Personal Data held by us (right to access)
- To rectify inaccurate Personal Data and, taking into account the purpose of processing the Personal Data, ensure it is complete (right to rectification)
- To erase/delete your Personal Data, to the extent permitted by applicable data protection laws (right to erasure; right to be forgotten)
- To restrict our processing of your Personal Data, to the extent permitted by law (right to restriction of processing)
- To transfer your Personal Data to another controller, to the extent possible (right to data portability)
Please help us keep the personal data you have shared accurate and up to date. For further information on how to do this and how to exercise data subject rights, please visit our Data Requests webpage.
In compliance with the Privacy Shield Framework, we commit to resolve complaints about our collection or use of your personal information. Individuals with inquiries or complaints regarding our Privacy Shield policy should first contact us at email@example.com. We have a policy of responding to you within forty-five (45) days of an inquiry or complaint. If the dispute involved human resources personal information, or information collected in the context of an employment relationship, we will cooperate with the competent EU or Swiss data protection authorities and comply with the advice of such authorities.
You may have the option to select binding arbitration under the Privacy Shield Panel for the resolution of your complaint under certain circumstances. For further information, please see the Privacy Shield website. To learn more about the Privacy Shield, please visit https://www.privacyshield.gov.
4. Annex A
Nozomi Networks Data Subprocessors List
Nozomi Networks uses the following third-party service providers as data subprocessors:
- Amazon Web Service (AWS)
Terms & Conditions