Paladin Cyber collects some Personal Data from its Users.

Users may be subject to different protection standards and broader standards may therefore apply to some. In order to learn more about the protection criteria, Users can refer to the applicability section.

This document contains a section dedicated to Californian consumers and their privacy rights.

This document can be printed for reference by using the print command in the settings of any browser.

POLICY SUMMARY
Personal Data processed for the following purposes and using the following services:

Analytics

Google Analytics and Mouseflow

Personal Data: Cookies; Usage Data

Collection of privacy-related preferences

Personal Data: Trackers

Contacting the User

Mailing list or newsletter

Personal Data: address; company name; email address; first name; last name; phone number

Data transfer outside of the UK

Data transfer abroad the international data transfer addendum (the "UK Addendum")

Personal Data: various types of Data

Data transfer outside the EU

Data transfer abroad based the standard contractual clauses and Article 49 derogations

Personal Data: various types of Data

Displaying content from external platforms

Calendly widget

Personal Data: calendar information; email address; name

Google Fonts

Personal Data: Tracker; Usage Data

Handling payments

Stripe

Personal Data: various types of Data as specified in the privacy policy of the service

Hosting and backend infrastructure

Firebase Cloud Firestore, Firebase Cloud Functions, Firebase Cloud Storage and Firebase Realtime Database

Personal Data: Usage Data; various types of Data as specified in the privacy policy of the service

Firebase Hosting

Personal Data: various types of Data as specified in the privacy policy of the service

Infrastructure monitoring

Sentry and Uptime Robot

Personal Data: various types of Data as specified in the privacy policy of the service

Interaction with live chat platforms

Zendesk Chat

Personal Data: company name; email address

Interaction with support and feedback platforms

Zendesk Widget

Personal Data: company name; email address

Managing contacts and sending messages

SparkPost

Personal Data: email address; various types of Data as specified in the privacy policy of the service

Postmark

Personal Data: company name; email address

Customer.io

Personal Data: email address; Tracker; Usage Data

Appcues

Personal Data: email address; first name; last name; phone number

Managing data collection and online surveys

Typeform

Personal Data: email address; first name; last name

Managing support and contact requests

Zendesk

Personal Data: various types of Data as specified in the privacy policy of the service

Platform services and hosting

Webflow

Personal Data: various types of Data as specified in the privacy policy of the service

Registration and authentication

Firebase Authentication

Personal Data: email address; first name; last name; password; phone number; profile picture

Google OAuth

Personal Data: various types of Data as specified in the privacy policy of the service

Tag Management

Segment

Personal Data: email address; Trackers; Usage Data

Traffic optimization and distribution

Cloudflare

Personal Data: various types of Data as specified in the privacy policy of the service

Information on opting out of interest-based advertising

In addition to any opt-out feature provided by any of the services listed in this document, Users may learn more on how to generally opt out of interest-based advertising within the dedicated section of the Cookie Policy.

Further information about the processing of Personal Data

Network traffic data

We may analyze your network traffic data for the sake of stopping cyber attacks. We may hold on to anonymized versions of network traffic data for training and improving our detection algorithms. We will never sell network traffic data to 3rd party data brokers.

Gmail Inbox Access

We request read rights to your inbox in order to analyze emails for phishing and malware attacks. Emails are destroyed after being analyzed unless they are flagged as malicious. We keep emails that are deemed malicious to better train our detection model and to report to you the types of attacks your inbox is facing.

Google Admin SDK

We collect email and names of your employees via the Admin SDK to streamline the onboarding process and save you the trouble of typing in your employees one by one. We will never resell this data to a 3rd party data broker.

Outlook Inbox Access

In order for the Inbox Defender to analyze emails for danger, it needs access to the content of the email, to include the sender's information and email body. That information is sent to Paladin's threat detection engine, and upon processing, is deleted after a result is sent back to the client. We keep emails that are deemed malicious to better train our detection model and to report to you the types of attacks your inbox is facing.

California Consumer Privacy Act (CCPA) Data Deletion

If you would like your data deleted in conjunction with the California Consumer Privacy Act (CCPA), please email us at [email protected] for processing

California Consumer Privacy Act (CCPA) Data Resell

We do not resale consumer data in any way which qualifies under the California Consumer Privacy Act (CCPA).

Google Contacts Read Only

We utilize this permission during the on-boarding process if you are not an administrator of your domain to add users based on your contact list.

Preference Cookies

Preference Cookies store the User preferences detected on Paladin Cyber in the local domain such as, for example, their time zone and region.

Personal Data collected through sources other than the User

The Owner of Paladin Cyber may have legitimately collected Personal Data relating to Users without their knowledge by reusing or sourcing them from third parties on the grounds mentioned in the section specifying the legal basis of processing.

Where the Owner has collected Personal Data in such a manner, Users may find specific information regarding the source within the relevant sections of this document or by contacting the Owner.

Contact information

Owner and Data Controller

Paladin Data Insurance Corp.
1586 Campus Dr, Berkeley, CA 94708

EU Representative
Instant EU GDPR Representative Ltd
Represented by Adam Brogden
Office 2 12A Lower Main Street, Lucan Co. Dublin K78 X5P8 Ireland
Contact: [email protected]

UK Representative
GDPR Local Ltd
Represented by Adam Brogden
1st Floor Front Suite 27-29 North Street, Brighton England BN1 1EB
Contact: [email protected]

Owner contact email: [email protected]

FULL POLICY

Owner and Data Controller

Owner contact email: [email protected]

Types of Data collected

Among the types of Personal Data that Paladin Cyber collects, by itself or through third parties, there are: Cookies; Usage Data; email address; first name; last name; phone number; password; profile picture; address; company name; calendar information; name; various types of Data.

Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.

Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using Paladin Cyber.

Unless specified otherwise, all Data requested by Paladin Cyber is mandatory and failure to provide this Data may make it impossible for Paladin Cyber to provide its services. In cases where Paladin Cyber specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.

Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Any use of Cookies – or of other tracking tools – by Paladin Cyber or by the owners of third-party services used by Paladin Cyber serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy, if available.

Users are responsible for any third-party Personal Data obtained, published or shared through Paladin Cyber and confirm that they have the third party's consent to provide the Data to the Owner.

Mode and place of processing the Data

Methods of processing

The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.

The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of Paladin Cyber (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.

Legal basis of processing

The Owner may process Personal Data relating to Users if one of the following applies:

Users have given their consent for one or more specific purposes. Note: Under some legislations the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;
provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
processing is necessary for compliance with a legal obligation to which the Owner is subject;
processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.

In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Place

The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located.

Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.

If broader protection standards are applicable, Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.

If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Owner using the information provided in the contact section.

Retention time

Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.

Therefore:

Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.

The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

Once the retention period expires, Personal Data shall be deleted. Therefore, the right of access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

The purposes of processing

The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following: Analytics, Tag Management, Registration and authentication, Hosting and backend infrastructure, Handling payments, Managing contacts and sending messages, Contacting the User, Managing support and contact requests, Interaction with live chat platforms, Interaction with support and feedback platforms, Displaying content from external platforms, Traffic optimization and distribution, Platform services and hosting, Collection of privacy-related preferences, Data transfer outside of the UK, Data transfer outside the EU, Infrastructure monitoring and Managing data collection and online surveys.

For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data”.

Detailed information on the processing of Personal Data

Personal Data is collected for the following purposes and using the following services:

Analytics

The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.

Google Analytics (Google LLC)

Google Analytics is a web analysis service provided by Google LLC (“Google”). Google utilizes the Data collected to track and examine the use of Paladin Cyber, to prepare reports on its activities and share them with other Google services.

Google may use the Data collected to contextualize and personalize the ads of its own advertising network.

Personal Data processed: Cookies; Usage Data.

Place of processing: United States – Privacy Policy – Opt Out.

Category of personal information collected according to CCPA: internet information.

This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

Mouseflow (Mouseflow ApS)

Mouseflow is an analytics and heat mapping service provided by Mouseflow ApS.

Mouseflow is used to display the areas of Paladin Cyber that Users interact with most frequently. This shows where the points of interest are.

Personal Data processed: Cookies; Usage Data.
Place of processing: Denmark – Privacy Policy – Opt Out.
Category of personal information collected according to CCPA: internet information.

Collection of privacy-related preferences
This type of service allows Paladin Cyber to collect and store Users’ preferences related to the collection, use, and processing of their personal information, as requested by the applicable privacy legislation.

iubenda Cookie Solution (iubenda srl)

The iubenda Cookie Solution allows the Owner to collect and store Users’ preferences related to the processing of personal information, and in particular to the use of Cookies and other Trackers on Paladin Cyber.

Personal Data processed: Trackers.
Place of processing: Italy – Privacy Policy.
Category of personal information collected according to CCPA: internet information.

Contacting the User

Mailing list or newsletter (Paladin Cyber)

By registering on the mailing list or for the newsletter, the User’s email address will be added to the contact list of those who may receive email messages containing information of commercial or promotional nature concerning Paladin Cyber. Your email address might also be added to this list as a result of signing up to Paladin Cyber or after making a purchase.

Personal Data processed: address; company name; email address; first name; last name; phone number.

Category of personal information collected according to CCPA: identifiers; commercial information.

Data transfer outside of the UK

Personal Data may be transferred from the UK to countries that offer adequate levels of data protection under or pursuant to the adequacy decisions published by the relevant data of EU, as applicable, without any further safeguard being necessary.

The Owner can transfer Personal Data collected within the UK to third countries without an adequacy decision, that is subject to specific legal requirements (so-called "restricted transfers"). Restricted transfers may take place according to the conditions specified below.

Users can enquire with the Owner to learn which legal basis applies to which specific service.

Data transfer abroad based on the international data transfer addendum

(UK) (Paladin Cyber)

The transfer of Personal Data from the UK to third countries without an adequacy decision (restricted transfer) is carried out by providing appropriate safeguards for the transfer of data by the Owner with applying the international data transfer addendum (“UK Addendum”).

UK Addendum means the international data transfer addendum to the European Commission’s standard contractual clauses adopted by the UK Parliament for international restricted data transfers. This means that a standard of protection is established over the Personal Data which is required by UK Data Protection Laws.

In the absence of an adequacy decision, or of appropriate safeguards, including binding corporate rules, a transfer or a set of transfers of personal data to a third country or an international organization shall take place only on one of the derogations for specific situations pursuant of Article 49 of the GDPR.

For further information, Users are requested to contact the Owner through the contact details provided in the present document.

Personal Data processed: various types of Data.

Category of personal information collected according to CCPA: internet information.

Data transfer outside the EU

Personal Data may be transferred from the EU/EEA to countries that offer adequate levels of data protection under or pursuant to the adequacy decisions published by the relevant data of EU, as applicable, without any further safeguard being necessary.

The Owner is allowed to transfer Personal Data collected within the EU/EEA to third countries without an adequacy decision, only pursuant to specific legal requirements. Such transfers may take place according to the conditions specified below.

Users can enquire with the Owner to learn which applies to which specific service.

Data transfer abroad based on standard contractual clauses (Paladin Cyber)

The transfer of Personal Data from the EU/EEA to third countries without an adequacy decision is carried out by providing appropriate safeguards for the transfer of data by the Owner with applying the standard contractual clauses (SCC), as adopted by the European Commission.

For further information, Users are requested to contact the Owner through the contact details provided in the present document.

Personal Data processed: various types of Data.

Category of personal information collected according to CCPA: internet information.

Displaying content from external platforms

This type of service allows you to view content hosted on external platforms directly from the pages of Paladin Cyber and interact with them.
This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it.

Calendly widget (Calendly, LLC)

Calendly widget is a calendar content visualization service provided by Calendly, LLC that allows Paladin Cyber to incorporate content of this kind on its pages.

Personal Data processed: calendar information; email address; name.

Place of processing: United States – Privacy Policy.

Category of personal information collected according to CCPA: identifiers; internet information.

Google Fonts (Google LLC)

Google Fonts is a typeface visualization service provided by Google LLC that allows Paladin Cyber to incorporate content of this kind on its pages.

Personal Data processed: Tracker; Usage Data.

Place of processing: United States – Privacy Policy.

Category of personal information collected according to CCPA: internet information.

Handling payments

Payment processing services enable Paladin Cyber to process payments by credit card, bank transfer or other means. To ensure greater security, Paladin Cyber shares only the information necessary to execute the transaction with the financial intermediaries handling the transaction.
Some of these services may also enable the sending of timed messages to the User, such as emails containing invoices or notifications concerning the payment.

Stripe (Stripe Inc)

Stripe is a payment service provided by Stripe Inc.

Personal Data processed: various types of Data as specified in the privacy policy of the service.

Place of processing: United States – Privacy Policy.

Category of personal information collected according to CCPA: internet information.

Hosting and backend infrastructure

This type of service has the purpose of hosting Data and files that enable Paladin Cyber to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of Paladin Cyber. Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.

Firebase Cloud Firestore (Google LLC)

Firebase Cloud Firestore is a hosting and backend service provided by Google LLC.

Personal Data processed: Usage Data; various types of Data as specified in the privacy policy of the service.

Place of processing: United States – Privacy Policy.

Category of personal information collected according to CCPA: internet information.

Firebase Cloud Functions (Google LLC)

Firebase Cloud Functions is a hosting and backend service provided by Google LLC.

Personal Data processed: Usage Data; various types of Data as specified in the privacy policy of the service.

Place of processing: United States – Privacy Policy.

Category of personal information collected according to CCPA: internet information.

Firebase Cloud Storage (Google LLC)

Firebase Cloud Storage is a hosting service provided by Google LLC.

Personal Data processed: Usage Data; various types of Data as specified in the privacy policy of the service.

Place of processing: United States – Privacy Policy.

Category of personal information collected according to CCPA: internet information.

Firebase Hosting (Google LLC)

Firebase Hosting is a hosting service provided by Google LLC.

Personal Data processed: various types of Data as specified in the privacy policy of the service.

Place of processing: United States – Privacy Policy.

Category of personal information collected according to CCPA: internet information.

Firebase Realtime Database (Google LLC)

Firebase Realtime Database is a hosting and backend service provided by Google LLC.

Personal Data processed: Usage Data; various types of Data as specified in the privacy policy of the service.

Place of processing: United States – Privacy Policy.

Category of personal information collected according to CCPA: internet information.

Infrastructure monitoring

This type of service allows Paladin Cyber to monitor the use and behavior of its components so its performance, operation, maintenance and troubleshooting can be improved.
Which Personal Data are processed depends on the characteristics and mode of implementation of these services, whose function is to filter the activities of Paladin Cyber.

Sentry (Functional Software, Inc. )

Sentry is a monitoring service provided by Functional Software, Inc. .

Personal Data processed: various types of Data as specified in the privacy policy of the service.

Place of processing: United States – Privacy Policy.

Category of personal information collected according to CCPA: internet information.

Uptime Robot (Buzpark Bilisim Tarim Urunleri Sanayi Tic. Ltd. Sti.)

Uptime Robot is a monitoring service provided by Buzpark Bilisim Tarim Urunleri Sanayi Tic. Ltd. Sti.

Personal Data processed: various types of Data as specified in the privacy policy of the service.

Place of processing: Turkey – Privacy Policy.

Category of personal information collected according to CCPA: internet information.

Interaction with live chat platforms

This type of service allows Users to interact with third-party live chat platforms directly from the pages

of Paladin Cyber, in order to contact and be contacted by Paladin Cyber‘s support service.

If one of these services is installed, it may collect browsing and Usage Data in the pages where it is

installed, even if the Users do not actively use the service. Moreover, live chat conversations may be logged.

Zendesk Chat (Zendesk, Inc.)

Zendesk Chat is a service for interacting with the Zendesk live chat platform provided by Zendesk,Inc.

Personal Data processed: company name; email address.

Place of processing: United States – Privacy Policy.

Category of personal information collected according to CCPA: identifiers; commercial information.

Interaction with support and feedback platforms

This type of service allows Users to interact with third-party support and feedback platforms directly from the pages of Paladin Cyber.
If one of these services is installed, it may collect browsing and Usage Data in the pages where it is installed, even if the Users do not actively use the service.

Zendesk Widget (Zendesk, Inc.)

The Zendesk Widget is a service for interacting with the Zendesk support and feedback platform provided by Zendesk Inc.

Personal Data processed: company name; email address.

Place of processing: United States – Privacy Policy.

Category of personal information collected according to CCPA: identifiers; commercial information.

Managing contacts and sending messages

This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User.
These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.

SparkPost (Message Systems, Inc.)

SparkPost is an email address management and message sending service provided by Message Systems, Inc.

Personal Data processed: email address; various types of Data as specified in the privacy policy of the service.

Place of processing: United States – Privacy Policy.

Category of personal information collected according to CCPA: identifiers; internet information.

Postmark (Wildbit LLC)

Postmark is an email address management and message sending service provided by Wildbit LLC.

Personal Data processed: company name; email address.

Place of processing: United States – Privacy Policy.

Category of personal information collected according to CCPA: identifiers; commercial information.

Customer.io (Peaberry Software Inc.)

Customer.io is an email address management and message sending service provided by Peaberry Software Inc.

Personal Data processed: email address; Tracker; Usage Data.

Place of processing: United States – Privacy Policy.

Category of personal information collected according to CCPA: identifiers; internet information.

Appcues (Appcues, Inc.)

Appcues is a message sending service provided by Appcues, Inc. Appcues may also be used to manage the creation, deployment, administration, distribution and analysis of online forms and surveys.

Personal Data processed: email address; first name; last name; phone number.

Place of processing: United States – Privacy Policy.

Category of personal information collected according to CCPA: identifiers.

Managing data collection and online surveys

This type of service allows Paladin Cyber to manage the creation, deployment, administration, distribution and analysis of online forms and surveys in order to collect, save and reuse Data from any responding Users.

The Personal Data collected depends on the information asked and provided by the Users in the corresponding online form.

These services may be integrated with a wide range of third-party services to enable the Owner to take subsequent steps with the Data processed - e.g. managing contacts, sending messages, analytics, advertising and payment processing.

Typeform (TYPEFORM S.L)

Typeform is a form builder and data collection platform provided by TYPEFORM S.L.

Personal Data processed: email address; first name; last name.

Place of processing: Spain – Privacy Policy.

Category of personal information collected according to CCPA: identifiers.

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Managing support and contact requests

This type of service allows Paladin Cyber to manage support and contact requests received via email or by other means, such as the contact form.

The Personal Data processed depend on the information provided by the User in the messages and the means used for communication (e.g. email address).

Zendesk (Zendesk, Inc.)

Zendesk is a support and contact request management service provided by Zendesk Inc.

Personal Data processed: various types of Data as specified in the privacy policy of the service.

Place of processing: United States – Privacy Policy.

Category of personal information collected according to CCPA: internet information.

Platform services and hosting

These services have the purpose of hosting and running key components of Paladin Cyber, therefore allowing the provision of Paladin Cyber from within a unified platform. Such platforms provide a wide range of tools to the Owner – e.g. analytics, user registration, commenting, database management, e-commerce, payment processing – that imply the collection and handling of Personal Data.
Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.

Webflow (Webflow, Inc.)

Webflow is a platform provided by Webflow, Inc. that allows the Owner to build, run and host Paladin Cyber. Webflow is highly customizable and can host websites from simple blogs to complex e-commerce platforms.

Personal Data processed: various types of Data as specified in the privacy policy of the service.

Place of processing: United States – Privacy Policy – Opt out.

Category of personal information collected according to CCPA: internet information.

Registration and authentication

By registering or authenticating, Users allow Paladin Cyber to identify them and give them access to dedicated services.

Depending on what is described below, third parties may provide registration and authentication services. In this case, Paladin Cyber will be able to access some Data, stored by these third-party services, for registration or identification purposes.

Firebase Authentication (Google LLC)

Firebase Authentication is a registration and authentication service provided by Google LLC. To simplify the registration and authentication process, Firebase Authentication can make use of third-party identity providers and save the information on its platform.

Personal Data processed: email address; first name; last name; password; phone number; profile picture.

Place of processing: United States – Privacy Policy.

Category of personal information collected according to CCPA: identifiers; sensorial information.

Google OAuth (Google LLC)

Google OAuth is a registration and authentication service provided by Google LLC and is connected to the Google network.

Personal Data processed: various types of Data as specified in the privacy policy of the service.

Place of processing: United States – Privacy Policy.

Category of personal information collected according to CCPA: internet information.

Tag Management

This type of service helps the Owner to manage the tags or scripts needed on Paladin Cyber in a centralized fashion.

This results in the Users' Data flowing through these services, potentially resulting in the retention of this Data.

Segment (Twilio, Inc.)

Segment is a tag management service provided by Segment.io, Inc.

Personal Data processed: email address; Trackers; Usage Data.

Place of processing: United States – Privacy Policy.

Category of personal information collected according to CCPA: identifiers; internet information.

Traffic optimization and distribution

This type of service allows Paladin Cyber to distribute their content using servers located across different countries and to optimize their performance.

Which Personal Data are processed depends on the characteristics and the way these services are implemented. Their function is to filter communications between Paladin Cyber and the User's browser.

Considering the widespread distribution of this system, it is difficult to determine the locations to which the contents that may contain Personal Information of the User are transferred.

Cloudflare (Cloudflare Inc.)

Cloudflare is a traffic optimization and distribution service provided by Cloudflare Inc.
The way Cloudflare is integrated means that it filters all the traffic through Paladin Cyber, i.e., communication between Paladin Cyber and the User's browser, while also allowing analytical data from Paladin Cyber to be collected.

Personal Data processed: various types of Data as specified in the privacy policy of the service.

Place of processing: United States – Privacy Policy.

Category of personal information collected according to CCPA: internet information.

Information on opting out of interest-based advertising

Further information about the processing of Personal Data

Network traffic data

Gmail Inbox Access

Google Admin SDK

Outlook Inbox Access

Preference Cookies

Preference Cookies store the User preferences detected on Paladin Cyber in the local domain such as, for example, their time zone and region.

Personal Data collected through sources other than the User

Where the Owner has collected Personal Data in such a manner, Users may find specific information regarding the source within the relevant sections of this document or by contacting the Owner.

The Rights of Users

Users may exercise certain rights regarding their Data processed by the Owner.

Users entitled to broader protection standards may exercise any of the rights described below. In all other cases, Users may inquire with the Owner to find out which rights apply to them.

In particular, Users have the right to do the following:

Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.
Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User's consent, on a contract which the User is part of or on pre-contractual obligations thereof.
Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

Details about the right to object to processing

Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.

Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.

How to exercise these rights

Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.

Applicability of broader protection standards

While most provisions of this document concern all Users, some provisions expressly only apply if the processing of Personal Data is subject to broader protection standards.

Such broader protection standards apply when the processing:

is performed by an Owner based within the EU;
concerns the Personal Data of Users who are in the EU and is related to the offering of paid or unpaid goods or services, to such Users;
concerns the Personal Data of Users who are in the EU and allows the Owner to monitor such Users’ behavior taking place in the EU.

Cookie Policy

Paladin Cyber uses Trackers. To learn more, the User may consult the Cookie Policy.

Information about Data collection and processing

Legal action

The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of Paladin Cyber or the related Services.

The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.

Additional information about User's Personal Data

In addition to the information contained in this privacy policy, Paladin Cyber may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.

System logs and maintenance

For operation and maintenance purposes, Paladin Cyber and any third-party services may collect files that record interaction with Paladin Cyber (System logs) using other Personal Data (such as the IP Address) for this purpose.

Information not contained in this policy

More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.

How “Do Not Track” requests are handled

Paladin Cyber does not support “Do Not Track” requests.
To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.

Changes to this privacy policy

The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within Paladin Cyber and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.

Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.

Information for Californian consumers

This part of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the business running Paladin Cyber and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).

The provisions contained in this section apply to all Users who are consumers residing in the state of California, United States of America, according to "The California Consumer Privacy Act of 2018" (Users are referred to below, simply as “you”, “your”, “yours”), and, for such consumers, these provisions supersede any other possibly divergent or conflicting provisions contained in the privacy policy.

This part of the document uses the term “personal information“ as it is defined in The California Consumer Privacy Act (CCPA).

Categories of personal information collected, disclosed or sold

In this section we summarize the categories of personal information that we've collected, disclosed or sold and the purposes thereof. You can read about these activities in detail in the section titled “Detailed information on the processing of Personal Data” within this document.

Information we collect: the categories of personal information we collect

We have collected the following categories of personal information about you: identifiers, commercial information, internet information and sensorial information.

We will not collect additional categories of personal information without notifying you.

How we collect information: what are the sources of the personal information we collect?

We collect the above mentioned categories of personal information, either directly or indirectly, from you when you use Paladin Cyber.

For example, you directly provide your personal information when you submit requests via any forms on Paladin Cyber. You also provide personal information indirectly when you navigate Paladin Cyber, as personal information about you is automatically observed and collected. Finally, we may collect your personal information from third parties that work with us in connection with the Service or with the functioning of Paladin Cyber and features thereof.

How we use the information we collect: sharing and disclosing of your personal information with third parties for a business purpose

We may disclose the personal information we collect about you to a third party for business purposes.

In this case, we enter a written agreement with such third party that requires the recipient to both keep the personal information confidential and not use it for any purpose(s) other than those necessary for the performance of the agreement.

We may also disclose your personal information to third parties when you explicitly ask or authorize us to do so, in order to provide you with our Service.

To find out more about the purposes of processing, please refer to the relevant section of this document.

Sale of your personal information

For our purposes, the word “sale” means any “selling, renting, releasing, disclosing, disseminating, making available, transferring or otherwise communicating orally, in writing, or by electronic means, a consumer's personal information by the business to another business or a third party, for monetary or other valuable consideration”.

This means that, for example, a sale can happen whenever an application runs ads, or makes statistical analyses on the traffic or views, or simply because it uses tools such as social network plugins and the like.

Your right to opt out of the sale of personal information

You have the right to opt out of the sale of your personal information. This means that whenever you request us to stop selling your data, we will abide by your request.

Such requests can be made freely, at any time, without submitting any verifiable request, simply by following the instructions below.

Instructions to opt out of the sale of personal information

If you’d like to know more, or exercise your right to opt out in regard to all the sales carried out by Paladin Cyber, both online and offline, you can contact us for further information using the contact details provided in this document.

What are the purposes for which we use your personal information?

We may use your personal information to allow the operational functioning of Paladin Cyber and features thereof (“business purposes”). In such cases, your personal information will be processed in a fashion necessary and proportionate to the business purpose for which it was collected, and strictly within the limits of compatible operational purposes.

We may also use your personal information for other reasons such as for commercial purposes (as indicated within the section “Detailed information on the processing of Personal Data” within this document), as well as for complying with the law and defending our rights before the competent authorities where our rights and interests are threatened or we suffer an actual damage.

We will not use your personal information for different, unrelated, or incompatible purposes without notifying you.

Your California privacy rights and how to exercise them

The right to know and to portability

You have the right to request that we disclose to you:

the categories and sources of the personal information that we collect about you, the purposes for which we use your information and with whom such information is shared;
in case of sale of personal information or disclosure for a business purpose, two separate lists where we disclose:
for sales, the personal information categories purchased by each category of recipient; and
for disclosures for a business purpose, the personal information categories obtained by each category of recipient.

The disclosure described above will be limited to the personal information collected or used over the past 12 months.

If we deliver our response electronically, the information enclosed will be "portable", i.e. delivered in an easily usable format to enable you to transmit the information to another entity without hindrance – provided that this is technically feasible.

The right to request the deletion of your personal information

You have the right to request that we delete any of your personal information, subject to exceptions set forth by the law (such as, including but not limited to, where the information is used to identify and repair errors on Paladin Cyber, to detect security incidents and protect against fraudulent or illegal activities, to exercise certain rights etc.).

If no legal exception applies, as a result of exercising your right, we will delete your personal information and direct any of our service providers to do so.

How to exercise your rights

To exercise the rights described above, you need to submit your verifiable request to us by contacting us via the details provided in this document.

For us to respond to your request, it’s necessary that we know who you are. Therefore, you can only exercise the above rights by making a verifiable request which 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 will not respond to any request if we are unable to verify your identity and therefore confirm the personal information in our possession actually relates to you.

If you cannot personally submit a verifiable request, you can authorize a person registered with the California Secretary of State to act on your behalf.

If you are an adult, you can make a verifiable request on behalf of a minor under your parental authority.

You can submit a maximum number of 2 requests over a period of 12 months.

How and when we are expected to handle your request

We will confirm receipt of your verifiable request within 10 days and provide information about how we will process your request.

We will respond to your request within 45 days of its receipt. Should we need more time, we will explain to you the reasons why, and how much more time we need. In this regard, please note that we may take up to 90 days to fulfill your request.

Our disclosure(s) will cover the preceding 12 month period.

Should we deny your request, we will explain you the reasons behind our denial.

We do not charge a fee to process or respond to your verifiable request unless such request is manifestly unfounded or excessive. In such cases, we may charge a reasonable fee, or refuse to act on the request. In either case, we will communicate our choices and explain the reasons behind it.

Definitions and legal references

Personal Data (or Data)

Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.

Usage Data

Information collected automatically through Paladin Cyber (or third-party services employed in Paladin Cyber), which can include: the IP addresses or domain names of the computers utilized by the Users who use Paladin Cyber, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.

User

The individual using Paladin Cyber who, unless otherwise specified, coincides with the Data Subject.

Data Subject

The natural person to whom the Personal Data refers.

Data Processor (or Data Supervisor)

The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.

Data Controller (or Owner)

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, including the security measures concerning the operation and use of Paladin Cyber. The Data Controller, unless otherwise specified, is the Owner of Paladin Cyber.

Paladin Cyber (or this Application)

The means by which the Personal Data of the User is collected and processed.

Service

The service provided by Paladin Cyber as described in the relative terms (if available) and on this site/application.

European Union (or EU)

Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.

Cookies are Trackers consisting of small sets of data stored in the User's browser.

Tracker

Tracker indicates any technology - e.g Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting - that enables the tracking of Users, for example by accessing or storing information on the User’s device.

Legal information

This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).

This privacy policy relates solely to Paladin Cyber, if not stated otherwise within this document.