PRIVACY POLICY

Coronet Cyber Security Ltd (“Coro”, “we”, “us”) respects the privacy of the visitors of our website at www.coro.net (“website”), and users of the application for cloud security, e-mail security and end-point protection and the Coro Console (the “Platform”), and we are committed to protecting the personal information that is shared with, or made available to us. 

This Privacy Policy describes how we collect, store, use and disclose the following categories of personal data:  

1. Customer Data: personal data (as described in section 1), that we collect, process and manage on behalf of our business customers (“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 with the Customer.

We process such Customer Data on behalf of and under the instruction of the respective Customer, in accordance with the commercial agreement and our Data Processing Addendum. This Privacy Policy (which describes Coro’s own privacy and data processing practices as we process data independently) does not apply to such processing done on our Customers’ behalf. To learn more about the privacy policies and practices of our Customers, please contact them, or your account managers, directly.

2. 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 using the Platform (collectively, “Users”)), including with respect to their use of the Platform (as described below);
3. CRM & Prospect Data: personal data relating to our Customers’ internal focal persons who directly engage with Coro concerning their Coro account (e.g. billing contacts and authorized signatories), partners and suppliers who directly engage with us as part of our commercial relationships, as well as visitors of our website, participants at our events and third-party events, and any other prospective customer, user or partner (collectively, “Prospects”) who visits or otherwise interacts with our website, online ads, emails, integrations or communications under our control (“Sites”, and collectively with the Platform, the “Services”). 

Specifically, this Privacy Policy describes our practices regarding:

1. Data Collection & Processing
2. Data Uses
3. Data Location
4. Data Retention
5. Data Disclosure
6. Cookies and Data Collection Technologies
7. Communications
8. Data Security
9. Data Subject Rights
10. Data Controller/Processor
11. Additional Notice & Contact Details 

If you are a User or Prospect (“you”), please read this Privacy Policy carefully and make sure that you fully understand it. Our Services are designated for businesses and are not intended for personal or household use. Accordingly, we treat all personal data covered by this Privacy Policy, including information about any visitors to our Sites, as pertaining to individuals acting as business representatives, rather than in their personal capacity.

You are not legally required to provide us with any personal data, and may do so (or avoid doing so) at your own free will. If you do not wish to provide us with your personal data, or to have it processed by us or any of our Service Providers (defined below in Section 5), please avoid any interaction with us including visiting our Sites or using our Services. If you are a User of the Services on behalf of any of our Customers, we suggest that you contact the respective Customer and your account administrator with any questions related to their privacy and data-handling practices. 

1. Data Collection and Processing

When we use the term “personal data” or “personal information” in this Privacy Policy, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to an individual. It does not include aggregated or deidentified information that is maintained in a form that is not reasonably capable of being associated with or linked to an individual.

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 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.

We collect and generate this information automatically, including through the use of analytics tools (including cookies and pixels), which collect data, such as how often visitors visit or use the Sites, which pages are visit and when, which website, ad or email message brought them there, and how Users interact with and use the Services and its various features.

• Contact and profile information concerning our Customers, Users and Prospects: contact and business details such as name, email, phone number, position, workplace and related business insights, our 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 our potential or existing engagement. 

We collect this information directly from you, or from other sources and third parties such as our Customers as a part of our commercial engagement. We may also obtain personal data from our Service Providers, e.g., marketing and sales tools, data enrichment services, our sales and marketing partners, distributors, job recruiters, or your colleagues.

• Communications with our Customers, Users and Prospects: Personal data contained in any forms and inquiries that you may submit to us, including support requests, interactions through social media channels and instant messaging apps, registrations to events that we host, organize or sponsor, and participation in our online and offline activities; surveys, feedback and testimonials received; expressed, presumed or identified needs, preferences, attributes and insights relevant to our potential or existing engagement; and sensory information including phone call and video conference recordings (e.g., with our 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 Monitoring: If you use the email protection functionality via the Platform, we monitor your sent and received emails, and may automatically retain personal data via this process, for example personal data included in email content, metadata, email addresses, IP addresses and shared files. Any personal data contained in these emails and retained on our servers are retained for facilitating, maintaining and improving our services, and are thereafter deleted. 

For the purposes of the California Consumer Privacy Act (“CCPA“), in the last twelve (12) months, we have 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; and Sensitive Personal Information (to the extent contained in the content of emails monitored by the email protection functionality). We do not use or disclose Sensitive Personal Information as defined by the CCPA beyond what is necessary to provide the Services.

2. Data Uses

We use 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 our Services.	Performance of a contract;Legitimate Interest.
To provide our 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 our Services, including by recognizing an individual and remembering their information when they return to our Services, and to provide further localized and personalized experiences.	Legitimate Interest.
To facilitate and optimize our marketing campaigns, ad management and sales operations, and to manage and deliver advertisements for our Services more effectively, including on other websites and applications. Such activities allow us to highlight the benefits of using our Services, and thereby increase your engagement and overall satisfaction with our 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 our Services, which content they have processed through our Services, and how we can improve their and others’ user experience and the value they can generate from using the Services, so we may continue improving our products, offerings and the overall performance of our Services.	Legitimate Interest.
To contact our Customers, Users 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 our 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 our Users and allow them to access and use the Services.	Performance of a contract.
To create aggregated statistical data, inferred non-personal data, or anonymized or pseudonymized data (rendered non-personal and non-identifiable), which we and our Service Providers may use to provide and improve our respective services, or for any other purpose.	Legitimate Interest.
To enforce our Terms of Use (“Terms”), to resolve disputes, to carry out our obligations and enforce our rights, and to protect our business interests and the interests and rights of third parties.	Legitimate Interest.
To comply with our contractual and legal obligations and requirements, and maintain our compliance with applicable laws, regulations and standards.	Performance of Contract;Legitimate Interest;Legal Obligation.

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 our 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 us at [email protected]. 

3. Data Location

We and our 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 our Services, or as may be required by law.

As we operate globally and may use service providers worldwide, including in the US, Europe, Israel and other locations as reasonably necessary for the proper performance of our Services, or as may be required by law, we 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, we will transfer your 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. You can obtain a copy of these clauses by contacting us as indicated below.

4. Data Retention

We retain personal data as long as we deem it reasonably necessary to establish, maintain and expand upon our relationship with you and provide you with our Services and offerings; in order to comply with our legal and contractual obligations; or to protect ourselves 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 your discontinuance of our Services), all in accordance with our data retention policy. 

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and any other applicable legal requirements. 

If you have any questions regarding our data retention practices, please contact us by email at [email protected]. 

5. Data Disclosure

We may disclose personal data in the following situations:

Service Providers: We engage selected third-party companies and individuals to perform services on our 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 our legal, financial and compliance advisors (collectively, “Service Providers“). Our Service Providers may have access to personal data, depending on each of their specific roles and purposes in facilitating and enhancing our Services, and may only use the data as determined in our agreements with them.

Partnerships: We engage selected business partners, resellers, distributors and providers of professional services related to our Services, which allow us to explore and pursue growth opportunities by facilitating a stronger local presence and tailored experiences for our Customers, Users and Prospects. In such instances, we 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 of our partners, 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.

Personal data from Google OAuth API: Our 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.

Event Sponsors: If you attend an event or webinar organized by us or a conference in which we are also in attendance, or if you download or access a related asset on our Sites, webinar or other activity involving third-party sponsors or presenters, we may disclose your 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: We may disclose Users’ personal data with their affiliated organization. In certain cases, other Users from your organization may control your account and will be entitled to monitor, process and analyze your data and associated content, including (i) view any content you submit and your activities on the Services; (ii) view statistics regarding your account; (iii) change your account password or other access credentials or privileges; (iv) suspend or terminate your account access; and (v) access or retain data stored as part of your 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 your organization, that acts as the “Data Controller” of such data (as further described in Section 10 below).

Legal Compliance: We may disclose or allow government and law enforcement officials access to your 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 we believe in good faith that: (a) we are 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 our legitimate business interests, including the security or integrity of our products and services. Personal data also may also be disclosed in the event of insolvency, bankruptcy or receivership.

Protecting Rights and Safety: We may disclose personal data with others if we believe in good faith that this will help protect the rights, property or personal safety of Coro, any of our Users, Prospects or Customers, or any members of the general public.

Coro Subsidiaries and Affiliated Companies: We 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. We 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 we believe that such change in control might materially affect your personal data then stored with us, we will notify you of this event and the choices you may have via e-mail and/or prominent notice on our Services. 

Additional Disclosure: For the avoidance of doubt, we may disclose personal data in additional manners, pursuant to your explicit approval, if we are legally obligated to do so, or if we have successfully rendered such data non-personal, non-identifiable and anonymous. We may transfer or disclose non-personal and non-identifiable data at our sole discretion and without the need for further approval.

For the purposes of the CCPA, in the past twelve (12) months, we may have disclosed Identifiers; Professional or Employment-Related Information; Internet or other Electronic Network Activity Information; Customer Records Information; Geolocation Information and Sensitive Personal Information to the third parties listed above.

6. Cookies and Data Collection Technologies

We and our Service Providers use cookies and other technologies for performance, tracking, analytics and personalization purposes. We may disclose non-identifiable / aggregated extracts of such information with our partners for our legitimate business purposes.

Cookies are packets of information sent to your web browser and then sent back by the browser each time it accesses the server that sent the cookie. Some cookies are removed when you close your browser session. These are the “Session Cookies”. Some last for longer periods and are called “Persistent Cookies”. We use both types.

Some cookies are necessary for the Services to function properly, and cannot be declined or disabled unless you delete and block them through your 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 us with insights on the performance of our ads and campaigns. 

While we do not change our practices in response to a “Do Not Track” signal in the HTTP header from a browser or mobile application, you can manage your cookies preferences, including whether or not to accept them and how to remove them, through your browser settings. Please bear in mind that disabling cookies may complicate or even prevent you from using the Services. 

We use Google Analytics, a web analytics tool which helps us understand Users’ behavior on our 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 your 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.

7. Communications

We engage in service and promotional communications, including through email, phone and notifications.

Service Communications: We may contact you with service-related information regarding our Services. For example, we may send you notifications (through any of the means available to us) of changes or updates to our 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: We may also notify you about new features, additional offerings, events, special opportunities or any other information we think you will find valuable, as our Customer, User or Prospect. We may provide such notices through any of the contact means available to us (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 us 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.

8. Data Security

To protect your personal data that we hold, we use industry-standard physical, procedural and technical security measures, including encryption, as appropriate to secure your 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, we cannot and do not guarantee the absolute protection and security of any personal data stored with us or with any third parties as described in Section 5 above. 

9. Data Subject Rights

Individuals have rights concerning their personal data. Please contact us 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 us. 

Please note that when you ask us to exercise any of your privacy rights, we may need to ask you to provide us 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. We may not be able to fulfill your request unless you have provided sufficient information that enables us to reasonably verify that you are the individual about whom we collected the personal data, and if such data is processed on behalf of any of our Customers, to which Customer it particularly relates, so that we may forward it to them for their further handling. Such additional information may be then retained by us for legal purposes (e.g., as proof of the identity of the person submitting the request, or proof of request fulfillment). We may redact from the data we make 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 we process on our 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. We therefore advise that you submit your request directly to the relevant Customer. 

10. 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 we explain how these roles apply to our Services, to the extent that such laws and regulations apply.

Coro is the “data controller” of User and Prospect Data. With respect to such data, we assume the responsibilities of data controller (solely to the extent applicable under law), as set forth in this Privacy Policy. In such instances, our Service Providers processing such data on our behalf will assume the role of “data processor”. 

Coro is the “data processor” of Customer Data and processes it on behalf of the Customer (who is the “data controller” of such data). Our Service Providers who process such Customer Data on our behalf are the “sub-processors” of such data. Coro processes Customer Data strictly in accordance with our Customers’ reasonable instructions and as further stipulated in the Data Processing Addendum the Customer has entered into with Coro and other commercial agreements between Coro and the Customer. 

Our Customers are solely responsible for determining whether and how they wish to use our 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 processed through the Services, have been provided with adequate notice and provided informed consent to the processing of their personal data, where such consent is necessary or advised, and that all legal requirements applicable to the processing of Customer Data through our Services are fully met by the Customer, including in the context of an employment relationship. Our Customers are also responsible for handling data subject requests under applicable law by their Users and other individuals whose data they process through the Services.

11. Additional Notices & Contact Details

Updates and Amendments: We 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. We will provide prior notice if we believe any substantial or material changes are made via any of the communication means available to us 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.

Requirements under US State Privacy Laws: This policy describes the categories of personal information we may collect and the sources of such information (in Section ‎1 above), and our retention and deletion practices(Section ‎4). We have also included information about how we may process your information (in Sections ‎2 through ‎7), which includes for “business information” for the intents and purposes of the CCPA and similar US state laws, as applicable. We do not sell your personal information for the intents and purposes of the CCPA. We do share and disclose personal information to third parties or allow them to collect personal information from our Services as described in Sections 5 and 6 above, if those third parties are authorized Service Providers or business partners who have agreed to our contractual limitations as to their retention, use, and disclosure of such personal information, or if you integrate the Services of third parties with our Services, or direct us to disclose your personal information to third parties, or as otherwise described in Section 5 above. Please note, you may designate, in writing or through a power of attorney, an authorized representative to request to exercise your privacy rights on your behalf. The authorized agent may submit a request to exercise these rights be emailing us. Note that we will not discriminate against you by withholding our Services from you or providing a lower quality of service to you for requesting to exercise your rights under the law. If you have any questions or would like to exercise your rights under US State laws, you may contact us by email at [email protected].

External Links: While our Services may contain links to other websites or services, we are not responsible for their privacy practices. We encourage you to pay attention when you leave our Services for the website or application of such third parties, and to read the privacy policies of each and every website and service you visit. This Privacy Policy applies only to our Services.

Children: Our Services are not designed to attract children under the age of 18. We do not knowingly collect or solicit data from or market to children who are under 18 years of age – and we do not wish to do so. If we learn that we have collected personal data from a child under the age of 18, we will deactivate the relevant account and take reasonable measures to promptly delete such data from our records. 

If you become aware of any data we may have collected from children under the age of 18, please contact us at [email protected].

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. 

Contacting Us: If you have any comments or questions regarding this Privacy Policy, or if you have any concerns regarding your personal data held with us, please contact us via [email protected]. 

Last Revised: 24 January 2024