Version 1.2
Last Updated April 12, 2022
This Privacy Policy relates to information collected online and offline by Huntress Labs Inc., (“Huntress”, “Company,” “we” or “us” or “our”), including through your use of the Huntress websites at www.huntress.com and any subdomains, services, and information available thereon (together with associated and successor websites, services, and information available thereon, or any part thereof, the “Site”), excluding the Huntress platform available at www.huntress.io. “You” and “Your” means the individual accessing or using the Site, or the company, or other legal entity on behalf of which such individual is accessing or using the Site, as applicable. You may also provide information to us when you communicate electronically with us or meet us in person, such as webinars, trainings, or business conferences, and this Privacy Policy relates to such information as well.
This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your Personally Identifiable Information when You use the Site and tells You about Your privacy rights and how the law protects You.
You should carefully read this Privacy Policy. We use Your Personally Identifiable Information to provide and improve the Site. By using the Sites, You agree to the collection and use of information in accordance with this Privacy Policy. If you do not agree to this Privacy Policy, you may not use the Site.
What Information About Me is Collected (Including Cookies)
Personally Identifiable Information
While using Our Site, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You (“Personally Identifiable Information”). Personally Identifiable Information is captured when a visitor accesses the Site, or speaks on the phone with or emails a Huntress employee, and willingly discloses that information. This disclosure may occur when a visitor registers with an online service, engages in transactions, contacts customer service, or participates in contests, promotions, webinars, surveys, forums, content submissions, requests for suggestions, or other aspects of services offered by Huntress. Personally identifiable information may include, but is not limited to: email address; first name and last name; title; organization name; organization industry or business type; phone numbers; address, state, province, ZIP/postal code, city, country; and Visitor Data.
Visitor Data
“Visitor Data” refers to data collected automatically, either generated by the use of the Site or from the Site infrastructure itself (for example, the duration of a page visit) from any device that can access the Site, such as a computer, a mobile device, or a digital tablet (“Device”). Visitor Data may include information such as Your Device's Internet Protocol address (e.g., IP address), location information inferred from an IP address, browser type, browser version, internet service provider, the pages of our Site that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data. Additionally, when You access the Site by or through a mobile device, We may collect certain Visitor Data automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.
Cookies or Other Tracking Technologies
We may collect information, including Visitor Data, using “cookies” and “web beacons.”
“Cookies” are small text files that can be placed on your computer or mobile device in order to identify your web browser and the activities of your computer on the Site and other websites. Cookies can be used to personalize your experience on the Site (such as dynamically generating content on webpages specifically designed for you), to assist you in using the Site (such as saving time by not having to reenter your name each time you use the Site), to allow us to statistically monitor how you are using the Site to help us improve our offerings, and to target certain advertisements to your browser which may be of interest to you or to determine the popularity of certain content. In addition to cookies that we may place on your computer or mobile device, cookies might also be placed on your computer or mobile device by third parties that we use to display or serve advertisements for our products and services or to collect non-personally identifiable information in order to provide advertising-related services to us. In the course of serving advertisements, such third parties could place or recognize unique cookies on your browser.
You do not have to accept cookies to use the Site. Although most browsers are initially set to accept cookies, you may reset your browser to notify you when you receive a cookie or to reject cookies generally. Most browsers offer instructions on how to do so in the “Help” section of the toolbar. However, if you reject cookies, certain features or resources of the Site may not work properly or at all and you may experience some loss of convenience. For the avoidance of doubt, the Site may use third-party service platforms (including to help analyze how users use the Site). These third-party service platforms may place cookies on your computer or mobile device. If you would like to disable “third party” cookies, you may be able to turn them off by going to the third party’s website.
“Web beacons,” also known as action tags or gif tags, are a web technology used to help track website usage information, such as how many times a specific page has been viewed. Web beacons are invisible to you, and any portion of the Site, including advertisements, or e-mail sent on our behalf, may contain web beacons.
By using cookies and web beacons together, we are able to gain valuable information to improve the Site and measure the effectiveness of our advertising and marketing campaigns. Information collected from some cookies placed on the website may be used to deliver advertisements to Huntress site visitors when such visitors are visiting other websites, including Facebook and LinkedIn.
Finally, you should be aware that other third parties may use their own cookies or web beacons when you click on a link to their websites or services on or from the Site. This Privacy Policy does not govern the use of cookies or web beacons or the use of your information by such third-party websites or services.
We may use third-party Site providers to monitor and analyze the use of our Site, including:
Children's Privacy
Our Site does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. In fact, as currently operated persons under the age of 18 may not use the Site. By providing information to Huntress, you represent that you are 18 years of age or older. If You are a parent or guardian and You are aware that Your child has provided Us with Personally Identifiable Information, please contact Us. If We become aware that We have collected Personally Identifiable Information from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers.
What Do We Do with the Information Collected?
Huntress may use Personally Identifiable Information for the following purposes:
- To provide and maintain our Site, including to monitor the usage of our Site.
- For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Site.
- To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
- To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.
- To manage Your requests: To attend and manage Your requests to Us.
- To deliver targeted advertising to You: We may use Your Personally Identifiable Information to develop and display content and advertising (and work with third-party vendors who do so) tailored to Your interests and/or location and to measure its effectiveness.
- For business transfers: We may use Your Personally Identifiable Information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personally Identifiable Information held by Us about our Site users is among the assets transferred.
- For other purposes: We may use Your Personally Identifiable Information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Site, products, services, marketing and your experience.
We may share Your Personally Identifiable Information in the following situations:
- With Service Providers: We may share Your Personally Identifiable Information with Service Providers to monitor and analyze the use of our Site, to advertise on third party websites to You after You visited our Site, to contact You. The term “Service Provider” means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Site, to provide the Site on behalf of the Company, to perform services related to the Site or to assist the Company in analyzing how the Site is used.
- For business transfers: We may share or transfer Your Personally Identifiable Information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.
- With Affiliates: We may share Your Personally Identifiable Information with Our Corporate Affiliates. For purposes of this Privacy Policy: “Corporate Affiliate” means any person or entity which directly or indirectly controls, is controlled by or is under common control with Huntress, whether by ownership or otherwise; and “control” means possessing, directly or indirectly, the power to direct or cause the direction of the management, policies or operations of an entity, whether through ownership of fifty percent (50%) or more of the voting securities, by contract or otherwise. Any information relating to you that we provide to our Corporate Affiliates will be treated by those Corporate Affiliates in accordance with the terms of this Privacy Policy.
- With other users: when You share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside.
- With Your consent: We may disclose Your Personally Identifiable Information for any other purpose with Your consent.
How Long Do We Retain Your Data?
The Company will retain Your Personally Identifiable Information only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personally Identifiable Information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.
The Company will also retain Visitor Data for internal analysis purposes. Visitor Data is generally retained for a shorter period, except when this data is used to strengthen the security or to improve the functionality of Our Site, or We are legally obligated to retain this data for longer time periods.
Where Could Your Personally Identifiable Information Be Transferred?
Your Personally Identifiable Information is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.
Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.
The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personally Identifiable Information will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.
Is Your Personally Identifiable Information Secure?
Huntress wants Your Personally Identifiable Information to remain secure. We strive to provide transmission of Your Personally Identifiable Information from your computer or mobile device to our servers through techniques that are consistent with commercially reasonable standards and to employ administrative, physical, and electronic measures designed to protect Your Personally Identifiable Information from unauthorized access.
Notwithstanding the above, you should be aware that there is always some risk involved in transmitting information over the Internet. There is also some risk that others could find a way to thwart our security systems. As a result, while we strive to protect Your Personally Identifiable Information, we cannot ensure or warrant the security or privacy of any information you transmit to us, and you do so at your own risk.
When Does Huntress Disclose Information to Third Parties?
Business Transactions
If Huntress is involved in a merger, acquisition or asset sale, Your Personally Identifiable Information may be transferred. We will provide notice before Your Personally Identifiable Information is transferred and becomes subject to a different Privacy Policy.
Laws
Huntress may disclose Your Personally Identifiable Information if we believe in good faith that we are required to do so in order to comply with an applicable statute, regulation, rule or law, a subpoena, a search warrant, a court or regulatory order, lawful requests by public authorities, including to meet national security or law enforcement requirements, or other valid legal process.
Other Legal Rights and Requirements
The Company may disclose Your Personally Identifiable Information in the good faith belief that such action is necessary to:
- Comply with a legal obligation
- Protect and defend the rights or property of the Company
- Prevent or investigate possible wrongdoing in connection with the Site
- Protect the personal safety of Users of the Site or the public
- Protect against legal liability
Service Providers
The Service Providers We use may have access to Your Personally Identifiable Information. These third-party vendors collect, store, use, process and transfer information about Your activity on Our Site in accordance with their Privacy Policies.
Analytics
We may use third-party Site providers to monitor and analyze the use of our Site. A list of those providers are contained in the cookies section above.
Email Marketing
We may use Your Personally Identifiable Information to contact You with newsletters, marketing or promotional materials and other information that may be of interest to You. You may opt-out of receiving any, or all, of these communications from Us by following the unsubscribe link or instructions provided in any email We send or by contacting Us.
We may use Email Marketing Service Providers to manage and send emails to You.
Remarketing Services
The Company uses remarketing services to advertise to You after You accessed or visited our Site. We and Our third-party vendors use cookies and non-cookie technologies to help Us recognize Your Device and understand how You use our Site so that We can improve our Site to reflect Your interests and serve You advertisements that are likely to be of more interest to You.
These third-party vendors collect, store, use, process and transfer information about Your activity on Our Site in accordance with their Privacy Policies and to enable Us to:
- Measure and analyze traffic and browsing activity on Our Site
- Show advertisements for our products and/or services to You on third-party websites or apps
- Measure and analyze the performance of Our advertising campaigns
Some of these third-party vendors may use non-cookie technologies that may not be impacted by browser settings that block cookies. Your browser may not permit You to block such technologies. You can use the following third-party tools to decline the collection and use of information for the purpose of serving You interest-based advertising:
You may opt-out of all personalized advertising by enabling privacy features on Your mobile device such as Limit Ad Tracking (iOS) and Opt Out of Ads Personalization (Android). See Your mobile device Help system for more information.
We may share information, such as hashed email addresses (if available) or other online identifiers collected on Our Site with these third-party vendors. This allows Our third-party vendors to recognize and deliver You ads across devices and browsers. To read more about the technologies used by these third-party vendors and their cross-device capabilities please refer to the Privacy Policy of each vendor listed below.
The third-party vendors We use for remarketing are:
Facebook Fan Page
Facebook Fan Page is a public profile named Huntress Labs specifically created by the Company on the Facebook social network, accessible from https://www.facebook.com/huntresslabs
As operator of the Facebook Fan Page https://www.facebook.com/huntresslabs, the Company and the operator of the social network Facebook are Joint Controllers for purposes of GDPR.
The Company has entered into agreements with Facebook that define the terms for use of the Facebook Fan Page, among other things. These terms are mostly based on the Facebook Terms of Site: https://www.facebook.com/terms.php
Visit the Facebook Privacy Policy https://www.facebook.com/policy.php for more information about how Facebook manages Personally Identifiable Information or contact Facebook online, or by mail: Facebook, Inc. ATTN, Privacy Operations, 1601 Willow Road, Menlo Park, CA 94025, United States.
Facebook Insights
We use the Facebook Insights function in connection with the operation of the Facebook Fan Page and in order to obtain anonymized statistical data about Our users.
For this purpose, Facebook places a Cookie on the device of the user visiting Our Facebook Fan Page. Each Cookie contains a unique identifier code and remains active for a period of two years, except when it is deleted before the end of this period.
Facebook receives, records and processes the information stored in the Cookie, especially when the user visits the Facebook services, services that are provided by other members of the Facebook Fan Page and services by other companies that use Facebook services.
For more information on the privacy practices of Facebook, please visit Facebook Privacy Policy here: https://www.facebook.com/privacy/explanation
What About the Links to Other Websites?
Our Site may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party's site. We strongly advise You to review the Privacy Policy of every site You visit.
We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.
How Will I Know If There Are Any Changes to This Privacy Policy?
We may revise this Privacy Policy from time to time. We will not make changes that result in significant additional uses or disclosures of your personally identifiable information without allowing you to “opt in” to such changes. We may also make non-significant changes to this Privacy Policy that generally will not significantly affect our use of Your Personally Identifiable Information, for which your opt-in is not required. We encourage you to check this page periodically for any changes. If any non-significant changes to this Privacy Policy are unacceptable to you, you must immediately contact us and, until the issue is resolved, stop using the Site. Your continued use of the Site following the posting of non-significant changes to this Privacy Policy constitutes your acceptance of those changes.
Who Do I Contact If I Have Questions About This Privacy Policy?
If you have any questions about this Privacy Policy, You can contact us:
General Data Protection Regulation (“GDPR”) Privacy Policy
This privacy notice section is for European Union (“EU”), European Economic Area (“EEA”), United Kingdom (“UK”) citizens and residents and supplements the information contained in Our Privacy Policy and it applies solely to all visitors, users, and others who reside in the EU, EEA, or the UK.
Legal Basis for Processing Personally Identifiable Information under GDPR
For the purposes of GDPR, Personally Identifiable Information means any information relating to You such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity. We may process Your Personally Identifiable Information under the following conditions:
- Consent: You have given Your consent for processing Personally Identifiable Information for one or more specific purposes.
- Performance of a contract: Provision of Personally Identifiable Information is necessary to provide the Site and related services, provide customer support and personalized features and to protect the safety and security of the Site, or for the performance of an agreement with You and/or for any pre-contractual obligations thereof.
- Legal obligations: Processing Personally Identifiable Information is necessary for compliance with a legal obligation to which the Company is subject.
- Vital interests: Processing Personally Identifiable Information is necessary in order to protect Your vital interests or of another natural person.
- Public interests: Processing Personally Identifiable Information is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Company.
- Legitimate interests: Processing Personally Identifiable Information is necessary for the purposes of the legitimate interests pursued by the Company.
In any case, the Company will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personally Identifiable Information is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
Your Rights under the GDPR
The Company undertakes to respect the confidentiality of Your Personally Identifiable Information and to guarantee You can exercise Your rights.
You have the right under this Privacy Policy, and by law if You are within the EU, EEA, or UK, to:
- Request access to Your Personally Identifiable Information. The right to access, update or delete the information We have on You. Whenever made possible, you can access, update or request deletion of Your Personally Identifiable Information directly within Your account settings section. If you are unable to perform these actions yourself, please contact Us to assist You. This also enables You to receive a copy of the Personally Identifiable Information We hold about You.
- Request correction of the Personally Identifiable Information that We hold about You. You have the right to have any incomplete or inaccurate information We hold about You corrected.
- Object to processing of Your Personally Identifiable Information. This right exists where We are relying on a legitimate interest as the legal basis for Our processing and there is something about Your particular situation, which makes You want to object to our processing of Your Personally Identifiable Information on this ground. You also have the right to object where We are processing Your Personally Identifiable Information for direct marketing purposes.
- Request erasure of Your Personally Identifiable Information. You have the right to ask Us to delete or remove Personally Identifiable Information when there is no good reason for Us to continue processing it.
- Request the transfer of Your Personally Identifiable Information. We will provide to You, or to a third-party You have chosen, Your Personally Identifiable Information in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which You initially provided consent for Us to use or where We used the information to perform a contract with You.
- Withdraw Your consent. You have the right to withdraw Your consent on using your Personally Identifiable Information. If You withdraw Your consent, We may not be able to provide You with access to certain specific functionalities of the Site.
Exercising of Your GDPR Data Protection Rights
You may exercise Your rights of access, rectification, cancellation, and opposition by contacting Us. Please note that we may ask You to verify Your identity before responding to such requests. If You make a request, We will try our best to respond to You as soon as possible.
You have the right to complain to a Data Protection Authority about Our collection and use of Your Personally Identifiable Information. For more information, if You are in the EEA or UK, please contact Your local data protection authority.
California Consumer Privacy Act (“CCPA”) Privacy Policy
This privacy notice section for California residents supplements the information contained in Our Privacy Policy and it applies solely to all visitors, users, and others who reside in the State of California.
Categories of Personal Information Collected
For the purposes of the CCPA, Personally Identifiable Information means any information that identifies, relates to, describes or is capable of being associated with, or could reasonably be linked, directly or indirectly, with You, the Consumer. For the purpose of the CCPA, the term “Consumer” means a natural person who is a California resident. We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Consumer or Device. The following is a list of categories of personal information which we may collect or may have been collected from California residents within the last twelve (12) months.
Please note that the categories and examples provided in the list below are those defined in the CCPA. This does not mean that all examples of that category of personal information were in fact collected by Us, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been collected. For example, certain categories of personal information would only be collected if You provided such personal information directly to Us.
Examples: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, driver's license number, passport number, or other similar identifiers.
Collected: Yes.
- Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
Examples: A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.
Collected: Yes.
- Category C: Protected classification characteristics under California or federal law.
Examples: Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
Collected: No.
- Category D: Commercial information.
Examples: Records and history of products or services purchased or considered.
Collected: No.
- Category E: Biometric information.
Examples: Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
Collected: No.
- Category F: Internet or other similar network activity.
Examples: Interaction with our Site or advertisement.
Collected: Yes.
- Category G: Geolocation data.
Examples: Approximate physical location.
Collected: Yes.
- Category H: Sensory data.
Examples: Audio, electronic, visual, thermal, olfactory, or similar information.
Collected: No.
- Category I: Professional or employment-related information.
Examples: Current or past job history or performance evaluations.
Collected: Yes.
- Category J: Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).
Examples: Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
Collected: No.
- Category K: Inferences drawn from other personal information.
Examples: Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Collected: No.
Under CCPA, personal information does not include:
- Publicly available information from government records
- Deidentified or aggregated consumer information
- Information excluded from the CCPA's scope, such as:
- Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data
- Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994
Sources of Personal Information
We obtain the categories of personal information listed above from the following categories of sources:
- Directly from You. For example, from the forms You complete on our Site, preferences You express or provide through our Site.
- Indirectly from You. For example, from observing Your activity on our Site.
- Automatically from You. For example, through cookies We or our Service Providers set on Your Device as You navigate through our Site.
- From Service Providers. For example, third-party vendors to monitor and analyze the use of our Site, third-party vendors to deliver targeted advertising to You, or other third-party vendors that We use to provide the Site to You.
Use of Personal Information for Business Purposes or Commercial Purposes
We may use or disclose personal information We collect for "business purposes" or "commercial purposes" (as defined under the CCPA), which may include the following examples:
- To operate our Site and provide You with our Site.
- To provide You with support and to respond to Your inquiries, including to investigate and address Your concerns and monitor and improve our Site.
- To fulfill or meet the reason You provided the information. For example, if You share Your contact information to ask a question about our Site, We will use that personal information to respond to Your inquiry.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- As described to You when collecting Your Personally Identifiable Information or as otherwise set forth in the CCPA.
- For internal administrative and auditing purposes.
- To detect security incidents and protect against malicious, deceptive, fraudulent or illegal activity, including, when necessary, to prosecute those responsible for such activities.
Please note that the examples provided above are illustrative and not intended to be exhaustive. For the purpose of the CCPA, refers to the Company as the legal entity that collects Consumers' personal information and determines the purposes and means of the processing of Consumers' personal information, or on behalf of which such information is collected and that alone, or jointly with others, determines the purposes and means of the processing of consumers' personal information, that does business in the State of California.
If We decide to collect additional categories of personal information or use the personal information We collected for materially different, unrelated, or incompatible purposes We will update this Privacy Policy.
Disclosure of Personal Information for Business Purposes or Commercial Purposes
We may use or disclose and may have used or disclosed in the last twelve (12) months the following categories of personal information for business or commercial purposes:
- Category A: Identifiers
- Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
- Category F: Internet or other similar network activity
Please note that the categories listed above are those defined in the CCPA. This does not mean that all examples of that category of personal information were in fact disclosed, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been disclosed.
When We disclose personal information for a business purpose or a commercial purpose, We enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
Sale of Personal Information
As defined in the CCPA, “sell” and “sale” mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer's personal information by the business to a third party for valuable consideration. This means that We may have received a benefit in return for sharing personal information, but not necessarily a monetary benefit. Please note that the categories listed below are those defined in the CCPA. This does not mean that all examples of that category of personal information were in fact sold, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been shared for value in return. Depending on how you use the Site, we may share the following categories of information for such interest-based advertising, which may be considered a “sale” as defined by the CCPA:
- Category A: Identifiers
- Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
- Category F: Internet or other similar network activity
Share of Personal Information
We may share Your Personally Identifiable Information identified in the above categories with the following categories of third parties:
- Service Providers
- Our affiliates
- Our business partners
- Third party vendors to whom You or Your agents authorize Us to disclose Your Personally Identifiable Information in connection with products or services We provide to You
Sale of Personal Information of Minors Under 16 Years of Age
We do not knowingly collect personal information from minors under the age of 16 through our Site, although certain third party websites that we link to may do so. In fact, as currently operated persons under the age of 18 may not use the Site. By providing information to Huntress, you represent that you are 18 years of age or older. These third-party websites have their own terms of use and privacy policies and we encourage parents and legal guardians to monitor their children's Internet usage and instruct their children to never provide information on other websites without their permission.
We do not sell the personal information of Consumers We actually know are less than 16 years of age, unless We receive affirmative authorization (the "right to opt-in") from either the Consumer who is between 13 and 16 years of age, or the parent or guardian of a Consumer less than 13 years of age. Consumers who opt-in to the sale of personal information may opt-out of future sales at any time. To exercise the right to opt-out, You (or Your authorized representative) may submit a request to Us by contacting Us.
If You have reason to believe that a child under the age of 13 (or 16) has provided Us with personal information, please contact Us with sufficient detail to enable Us to delete that information.
Your Rights under the CCPA
The CCPA provides California residents with specific rights regarding their personal information. If You are a resident of California, You have the following rights:
- The right to notice. You have the right to be notified which categories of Personally Identifiable Information are being collected and the purposes for which the Personally Identifiable Information is being used.
- The right to request. Under CCPA, You have the right to request that We disclose information to You about Our collection, use, sale, disclosure for business purposes and share of personal information. Once We receive and confirm Your request, We will disclose to You:
- The categories of personal information We collected about You
- The categories of sources for the personal information We collected about You
- Our business or commercial purpose for collecting or selling that personal information
- The categories of third parties with whom We share that personal information
- The specific pieces of personal information We collected about You
- If we sold Your Personally Identifiable Information or disclosed Your Personally Identifiable Information for a business purpose, We will disclose to You:
- The categories of personal information categories sold
- The categories of personal information categories disclosed
- The right to say no to the sale of Personally Identifiable Information (opt-out). You have the right to direct Us to not sell Your Personally Identifiable Information. To submit an opt-out request please contact Us.
- The right to delete Personally Identifiable Information. You have the right to request the deletion of Your Personally Identifiable Information, subject to certain exceptions. Once We receive and confirm Your request, We will delete (and direct Our Service Providers to delete) Your Personally Identifiable Information from our records, unless an exception applies. We may deny Your deletion request if retaining the information is necessary for Us or Our Service Providers to:
- Complete the transaction for which We collected the personal information, provide a good or service that You requested, take actions reasonably anticipated within the context of our ongoing business relationship with You, or otherwise perform our contract with You.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if You previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on Your relationship with Us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which You provided it.
- The right not to be discriminated against. You have the right not to be discriminated against for exercising any of Your consumer's rights, including by:
- Denying goods or services to You
- Charging different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties
- Providing a different level or quality of goods or services to You
- Suggesting that You will receive a different price or rate for goods or services or a different level or quality of goods or services
Do Not Sell My Personal Information
You have the right to opt-out of the sale of Your Personally Identifiable Information. Once We receive and confirm a verifiable consumer request from You, we will stop selling Your Personally Identifiable Information. To exercise Your right to opt-out, please contact Us.
The Service Providers we partner with (for example, our analytics or advertising partners) may use technology on the Site that sells personal information as defined by the CCPA law. If you wish to opt out of the use of Your Personally Identifiable Information for interest-based advertising purposes and these potential sales as defined under CCPA law, you may do so by following the instructions below.
Please note that any opt out is specific to the browser You use. You may need to opt out on every browser that You use.
Website
You can opt out of receiving ads that are personalized as served by our Service Providers by following our instructions presented on the Site:
The opt out will place a cookie on Your computer that is unique to the browser You use to opt out. If you change browsers or delete the cookies saved by your browser, You will need to opt out again.
Mobile Devices
Your mobile device may give You the ability to opt out of the use of information about the apps You use in order to serve You ads that are targeted to Your interests:
- "Opt out of Interest-Based Ads" or "Opt out of Ads Personalization" on Android devices
- "Limit Ad Tracking" on iOS devices
You can also stop the collection of location information from Your mobile device by changing the preferences on Your mobile device.
Exercising Your CCPA Data Protection Rights
In order to exercise any of Your rights under the CCPA, and if You are a California resident, You can contact Us:
Only You, or a person registered with the California Secretary of State that You authorize to act on Your behalf, may make a verifiable request related to Your Personally Identifiable Information.
Your request to Us must:
- Provide sufficient information that allows Us to reasonably verify You are the person about whom We collected personal information or an authorized representative
- Describe Your request with sufficient detail that allows Us to properly understand, evaluate, and respond to it
We cannot respond to Your request or provide You with the required information if we cannot:
- Verify Your identity or authority to make the request
- And confirm that the personal information relates to You
We will disclose and deliver the required information free of charge within 45 days of receiving Your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonably necessary and with prior notice.
Any disclosures We provide will only cover the 12-month period preceding the verifiable request's receipt.
For data portability requests, We will select a format to provide Your Personally Identifiable Information that is readily usable and should allow You to transmit the information from one entity to another entity without hindrance.
"Do Not Track" Policy as Required by California Online Privacy Protection Act (CalOPPA)
Do Not Track (“DNT”) is a concept that has been promoted by US regulatory authorities, in particular the U.S. Federal Trade Commission (FTC), for the Internet industry to develop and implement a mechanism for allowing internet users to control the tracking of their online activities across websites. Our Site does not respond to Do Not Track signals.
However, some third party websites do keep track of Your browsing activities. If You are visiting such websites, You can set Your preferences in Your web browser to inform websites that You do not want to be tracked. You can enable or disable DNT by visiting the preferences or settings page of Your web browser.
