What this Privacy Notice Covers
This Privacy Notice covers how we treat Personal Data that we gather when you access or use our Services, which includes data collected when you visit our websites or communicate with us on our website. In these situations, Cerby is the “controller” of this Personal Data. This Privacy Notice also applies to data we handle when you are an end-user of our application or software offerings. In these situations, Cerby is acting as a service provider and is generally the “processor” of the Personal Data, and the company or organization that has entered into an agreement with Cerby to license its software product is the “controller” of the Personal Data. Cerby’s collection and use of Personal Data will differ depending on whether it is acting as a controller or a processor of the Personal Data. For purposes of this Privacy Notice, "Personal Data" means any information that identifies or relates to a particular individual and also includes information referred to as "personally identifiable information" or "personal information" under applicable data privacy laws, rules or regulations. This Privacy Notice does not cover the practices of companies we don't own or control or people we don't manage.
Personal Data
Categories of Personal Data We Collect as Processor
This chart details the categories of Personal Data that we collect and have collected over the past 12 months when Cerby is acting as a processor of Personal Data in connection with providing its software product:
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Categories of Personal Data
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Examples of Personal Data We Collect
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Purpose
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Legal Basis
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Profile or Contact Data
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- First and last name
- Email address
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- Account creation and management
- User authentication
- Service provisioning
- Customer support
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- Performance of contract
- Processing on behalf of the controller
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Personal Identifiers
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None
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N/A
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N/A
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Online Identifiers
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- Unique identifiers such as account name and passwords
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- User authentication
- Security and access control
- Service provisioning
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- Performance of contract
- Processing on behalf of the controller
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Payment Data
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None
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N/A
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N/A
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Device/IP Data
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- IP address
- Device ID
- IP-address-based location information
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- Security and fraud prevention
- Service optimization
- Troubleshooting
- Analytics and performance monitoring
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- Performance of contract
- Processing on behalf of the controller
- Legitimate interests (security, service improvement)
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Platform Analytics
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- Type of device/operating system/browser used to access the Services
- Platform interactions
- Non-identifiable request IDs
- Statistics associated with the interaction between device or browser and the Cerby Platform
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- Service optimization
- Performance monitoring
- Product development and improvement
- Technical troubleshooting
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- Performance of contract
- Processing on behalf of the controller
- Legitimate interests (service improvement)
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Social Network Data
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None
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N/A
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N/A
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Professional or Employment-Related Data
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None
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N/A
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N/A
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Biometric Data
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None
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N/A
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N/A
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Inferences Drawn from Other Personal Data Collected
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None
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N/A
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N/A
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Categories of Personal Data We Collect as Controller
This chart details the categories of Personal Data that we collect and have collected over the past 12 months when Cerby is acting as a controller of Personal Data in connection with its websites:
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Categories of Personal Data
|
Examples of Personal Data We Collect
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Purpose
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Legal Basis
|
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Profile or Contact Data
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- First and last name
- Email address
- Phone number
- Mailing address
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- Account creation and management
- Marketing communications
- Customer support
- Service provisioning
- Sales and business development
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- Performance of contract
- Legitimate interests (business development)
- Consent (for marketing communications)
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Personal Identifiers
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None
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N/A
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N/A
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Online Identifiers
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- Unique identifiers such as account name and passwords
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- User authentication
- Security and access control
- Service provisioning
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- Performance of contract
- Legitimate interests (security)
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Payment Data
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None
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N/A
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N/A
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Device/IP Data
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- IP address
- Device ID
- IP-address-based location information
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- Security and fraud prevention
- Website optimization
- Analytics and performance monitoring
- Personalization of user experience
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- Legitimate interests (security, service improvement)
- Performance of contract
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Web Analytics
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- Type of device/operating system/browser used to access the Services
- Web page interactions
- Non-identifiable request IDs
- Statistics associated with the interaction between device or browser and the website
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- Website optimization
- Marketing effectiveness
- User experience improvement
- Product development
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- Legitimate interests (service improvement, marketing)
- Consent (for certain analytics cookies)
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Social Network Data
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None
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N/A
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N/A
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Professional or Employment-Related Data
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- Company name
- Job title
- Headquarters location
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- Business relationship management
- Sales and marketing targeting
- Service customization
- Account management
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- Legitimate interests (business development)
- Performance of contract
- Consent (for marketing communications)
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Biometric Data
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None
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N/A
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N/A
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Inferences Drawn from Other Personal Data Collected
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None
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N/A
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N/A
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Recruitment and Applicant Data
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- Information provided concerning application for employment
- Educational and work background
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- Recruitment and hiring
- Applicant evaluation
- Employment decision-making
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- Legitimate interests (hiring)
- Steps prior to entering into a contract
- Consent
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Special Categories of Data
Cerby does not intentionally collect or process “special categories of personal data” as defined under applicable privacy laws, including the General Data Protection Regulation (“GDPR”) and similar international regulations. Special categories of data include information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data for the purpose of uniquely identifying a natural person, health data, or data concerning a natural person’s sex life or sexual orientation.
Cerby’s Services are not designed to collect or process such sensitive information, either as a controller or a processor. If you are a customer or end user, you should not submit special categories of data to Cerby through our Services. If Cerby becomes aware that special categories of data have been inadvertently submitted or collected, Cerby will take reasonable steps to delete such data promptly and prevent further processing, except as required to comply with legal obligations.
Categories of Sources of Personal Data
We collect Personal Data about you from the following categories of sources:
- You
- When you provide such information directly to us.
- When you create an account or use our interactive tools and Services.
- When you voluntarily provide information in free-form text boxes through the Services or through responses to surveys or questionnaires.
- When you send us an email or otherwise contact us.
- When you use the Services and such information is collected
automatically.
- Through Cookies, (defined in the "Tracking Tools, Advertising and Opt-Out" section below).
- If you download our mobile application or use a location-enabled browser, we may receive information about your location and mobile device, as applicable.
- If you download and install certain applications and software we make available, we may receive and collect information transmitted from your computing device for the purpose of providing you the relevant Services, such as information regarding when you are logged on and available to receive updates or alert notices.
- Third Parties
- Vendors
- We may use analytics providers to analyze how you interact and engage with the Services, or third parties may help us provide you with customer support.
- Advertising Partners
- We receive information about you from some of our vendors who assist us with marketing or promotional services related to how you interact with our websites, applications, products, Services, advertisements or communications.
Our Commercial or Business Purposes for Collecting Personal Data
- Providing, Customizing and Improving the Services
- Creating and managing your account or other user profiles.
- Processing orders or other transactions; billing.
- Providing you with the products, services or information you request.
- Meeting or fulfilling the reason you provided the information to us.
- Providing support and assistance for the Services.
- Improving the Services, including testing, research, internal analytics and product development.
- Personalizing the Services, website content and communications based on your preferences.
- Engaging in fraud protection, security and debugging.
- Carrying out other business purposes stated when collecting your Personal Data or as otherwise set forth in applicable data privacy laws.
- Marketing the Services
- Marketing and selling the Services.
- Showing you advertisements, including interest-based or online behavioral advertising.
- Corresponding with You
- Responding to correspondence that we receive from you, contacting you when necessary or requested, and sending you information about Cerby or the Services.
- Sending emails and other communications according to your preferences or that display content that we think will interest you.
- Meeting Legal Requirements and Enforcing Legal Terms
- Fulfilling our legal obligations under applicable law, regulation, court order or other legal process, such as preventing, detecting and investigating security incidents and potentially illegal or prohibited activities.
- Protecting the rights, property or safety of you, Cerby or another party.
- Enforcing any agreements with you.
- Responding to claims that any posting or other content violates third-party rights.
- Resolving disputes.
We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated or incompatible purposes without providing you notice.
Legitimate Interests
We may process Personal Data based on our legitimate interests, which include:
- Securing and maintaining the integrity of our platform and Services.
- Preventing fraud and misuse of our Services.
- Improving and developing our Services.
- Communicating with customers and users regarding updates, security, and support.
Mandatory Data Provision
Some Personal Data (first, last name and email address) is necessary for us to provide our Services or to fulfill our contractual obligations to you or your organization. If you do not provide this data, we may be unable to provide certain Services or enter into a contract with you. Where the provision of data is mandatory, we will make this clear at the point of collection.
How We Share Your Personal Data
Note: Please refer to the following link to see Cerby’s subprocessors: https://www.cerby.com/cerby-subprocessors
We may disclose your Personal Data to the categories of service providers and other parties listed in this section.
- Service Providers. These parties help us provide the Services or
perform business functions on our behalf. They include:
- Hosting, technology and communication providers.
- Security and fraud prevention consultants.
- Analytics providers.
- Analytics Partners. These parties provide analytics on web traffic or usage of the Services. They include:
- Companies that track how users found or were referred to the Services.
- Companies that track how users interact with the Services.
- Business Partners. These parties partner with us in offering
various services. They include:
- Businesses that you have a relationship with (e.g., exporting SIEM data to Datadog or Splunk).
- Parties You Authorize, Access or Authenticate
- Third parties you access through the services.
Legal Obligations
We may share any Personal Data that we collect with third parties in conjunction with any of the activities set forth under "Meeting Legal Requirements and Enforcing Legal Terms" in the "Our Commercial or Business Purposes for Collecting Personal Data" section above.
Business Transfers
All of your Personal Data that we collect may be transferred to a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part). Should one of these events occur, we will make reasonable efforts to notify you before your information becomes subject to different privacy and security policies and practices.
Data that is Not Personal Data
We may create aggregated, de-identified or anonymized data from the Personal Data we collect, including by removing information that makes the data personally identifiable to a particular user. We may use such aggregated, de-identified or anonymized data and share it with third parties for our lawful business purposes, including to analyze, build and improve the Services and promote our business, provided that we will not share such data in a manner that could identify you.
International Data Transfers
Cerby is based in the United States and may transfer your Personal Data to countries outside your jurisdiction, including to other countries where our service providers operate. Where we transfer Personal Data from the European Economic Area, the United Kingdom, or Switzerland to countries that have not been recognized as providing an adequate level of data protection, we use appropriate safeguards, approved by the European Commission, to protect your Personal Data, including: (i) where the GDPR applies, the standard contractual clauses annexed to the European Commission’s Implementing Decision 2021/914 of 4 June 2021 on standard contractual clauses for the transfer of personal data to third countries pursuant to Regulation (EU) 2016/679 of the European Parliament and of the Council (“EU SCCs”), and (ii) where the United Kingdom GDPR applies, the applicable standard data protection clauses adopted pursuant to Article 46(2)(c) or (d) of the UK GDPR (“UK SCCs”).
Tracking Tools, Advertising and Opt-Out
The Services use cookies and similar technologies such as pixel tags, web beacons, clear GIFs and JavaScript (collectively, "Cookies") to enable our servers to recognize your web browser, tell us how and when you visit and use our Services, analyze trends, learn about our user base and operate and improve our Services. Cookies are small pieces of data--usually text files--placed on your computer, tablet, phone or similar device when you use that device to access our Services. We may also supplement the information we collect from you with information received from third parties, including third parties that have placed their own Cookies on your device(s). Please note that because of our use of Cookies, the Services do not support "Do Not Track" requests sent from a browser at this time.
We use the following types of Cookies:
- Essential Cookies. Essential Cookies are required for providing you with features or services that you have requested. For example, certain Cookies enable you to log into secure areas of our Services. Disabling these Cookies may make certain features and services unavailable.
- Functional Cookies. Functional Cookies are used to record your choices and settings regarding our Services, maintain your preferences over time and recognize you when you return to our Services. These Cookies help us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
- Performance/Analytical Cookies. Performance/Analytical Cookies allow us to understand how visitors use our Services. They do this by collecting information about the number of visitors to the Services, what pages visitors view on our Services and how long visitors are viewing pages on the Services. Performance/Analytical Cookies also help us measure the performance of our advertising campaigns in order to help us improve our campaigns and the Services' content for those who engage with our advertising. For example, Google Inc. ("Google") uses cookies in connection with its Google Analytics services. Google's ability to use and share information collected by Google Analytics about your visits to the Services is subject to the Google Analytics Terms of Use and the Google Privacy Notice. You have the option to opt-out of Google's use of Cookies by visiting the Google advertising opt-out page at www.google.com/privacy_ads.htm... or the Google Analytics Opt-out Browser Add-on at https://tools.google.com/dlpag....
- Retargeting/Advertising Cookies. Retargeting/Advertising Cookies collect data about your online activity and identify your interests so that we can provide advertising that we believe is relevant to you. For more information about this, please see the section below titled "Information about Interest-Based Advertisements."
You can decide whether or not to accept Cookies through your internet browser's settings. Most browsers have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies, as well as (depending on the sophistication of your browser software) allow you to decide on acceptance of each new Cookie in a variety of ways. You can also delete all Cookies that are already on your device. If you do this, however, you may have to manually adjust some preferences every time you visit our website and some of the Services and functionalities may not work.
To explore what Cookie settings are available to you, look in the "preferences" or "options" section of your browser's menu. To find out more information about Cookies, including information about how to manage and delete Cookies, please visit http://www.allaboutcookies.org.
Information about Interest-Based Advertisements:
We may serve advertisements, and also allow third-party ad networks, including third-party ad servers, ad agencies, ad technology vendors and research firms, to serve advertisements through the Services. These advertisements may be targeted to users who fit certain general profile categories or display certain preferences or behaviors ("Interest-Based Ads"). Information for Interest-Based Ads (including Personal Data) may be provided to us by you, or derived from the usage patterns of particular users on the Services and/or services of third parties. Such information may be gathered through tracking users' activities across time and unaffiliated properties, including when you leave the Services. To accomplish this, we or our service providers may deliver Cookies, including a file (known as a "web beacon") from an ad network to you through the Services. Web beacons allow ad networks to provide anonymized, aggregated auditing, research and reporting for us and for advertisers. Web beacons also enable ad networks to serve targeted advertisements to you when you visit other websites. Web beacons allow ad networks to view, edit or set their own Cookies on your browser, just as if you had requested a web page from their site.
Automated Decision-Making and Profiling
Cerby does not use Personal Data to make decisions based solely on automated processing, including profiling, that produce legal effects or similarly significant effects on individuals. If we introduce such processing in the future, we will provide you with meaningful information about the logic involved, as well as the significance and potential consequences of such processing.
Data Security and Data Retention Periods
We seek to protect your Personal Data from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures based on the type of Personal Data and how we are processing that data. You should also help protect your data by appropriately selecting and protecting your password and/or other sign-on mechanism; limiting access to your computer or device and browser; and signing off after you have finished accessing your account. Although we work to protect the security of your account and other data that we hold in our records, please be aware that no method of transmitting data over the internet or storing data is completely secure.
When acting as a processor, we retain Personal Data about you for as long as you have an open account with us or as otherwise necessary to provide you with our Services. In some cases, we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes, collect fees owed, enforce our agreements, or is otherwise permitted or required by applicable law, rule or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personally. When acting as a controller, we retain Personal Data for as long as necessary to fulfill the purposes for which it was collected. In each case, the criteria used to determine retention periods include: the nature and sensitivity of the data, the purposes for which we process it, applicable legal requirements, and whether the data is needed to maintain business records or resolve disputes.
Security Measures for Processor Activities
When Cerby acts as a processor of Personal Data on behalf of its customers, Cerby implements and maintains security measures designed to protect the confidentiality, integrity, and availability of Personal Data. These measures are described in detail in Cerby’s Security Notice, available at https://www.cerby.com/security, which is incorporated by reference into this Privacy Notice.
Key features of Cerby’s security program include:
- Use of industry-standard encryption for data at rest and in transit
- Regular penetration testing and vulnerability management
- Strict access controls and multi-factor authentication for personnel
- Continuous monitoring, logging, and incident response procedures
- Physical and environmental safeguards at data center locations
- Ongoing security awareness training for personnel
Cerby’s security measures are regularly reviewed and updated to address evolving threats and to comply with applicable legal and contractual requirements. Customers may review Cerby’s Security Notice for further details and may request additional information as needed.
Personal Data of Children
We do not knowingly collect or solicit Personal Data about children under 16 years of age; if you are a child under the age of 16, please do not attempt to register for or otherwise use the Services or send us any Personal Data. If we learn we have collected Personal Data from a child under 16 years of age, we will delete that information as quickly as possible.
State Law Privacy Rights
California Resident Rights
If you are a California resident, you may have rights under the California Consumer Privacy Act (“CCPA”), as amended by the California Privacy Rights Act (“CPRA”).
Subject to certain limitations, California residents have the right to:
- Know the categories and specific pieces of Personal Data we collect about you, the purposes for which we use that information, and the categories of third parties with whom we share it.
- Access a copy of the Personal Data we have collected about you.
- Request deletion of your Personal Data.
- Request correction of inaccurate Personal Data.
- Opt out of the sale or sharing of your Personal Data (where applicable).
- Limit the use and disclosure of sensitive Personal Data (if collected).
- Not be discriminated against for exercising your privacy rights.
To exercise any of these rights, please see the “Contact Information” section below. We will verify your request in accordance with applicable law and respond within the time periods required under the CCPA/CPRA.
Please note that Cerby does not currently sell or share Personal Data as defined under the CCPA. If this changes in the future, we will update this Privacy Policy and provide the appropriate opt-out mechanisms.
For more information about your privacy rights in California, you may also visit the California Attorney General’s website at https://oag.ca.gov/privacy/ccpa.
Nevada Resident Rights
If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Data to third parties who intend to license or sell that Personal Data. You can exercise this right by contacting us with the subject line "Nevada Do Not Sell Request" and providing us with your name and the email address associated with your account. However, note that Cerby does not sell or share your Personal Data.
Other State Privacy Rights
Residents of certain other U.S. states, including Colorado, Connecticut, Virginia, Utah, Texas, Oregon, Montana, and Tennessee, may have additional rights under their respective state privacy laws. These rights may include:
- The right to know what personal information we collect, use, disclose, or sell/share.
- The right to access and obtain a copy of your personal information.
- The right to correct inaccuracies in your personal information.
- The right to delete your personal information.
- The right to opt out of targeted advertising, the sale of personal information, or profiling in furtherance of decisions that produce legal or similarly significant effects.
To exercise any of these rights, please see the “Contact Information” section below. We will not discriminate against you for exercising your privacy rights.
If you are a resident of Virginia, Colorado, or Connecticut, you may also have the right to appeal a decision we make regarding your privacy rights request. To submit an appeal, please contact us using the same contact method and indicate that your request is an “Appeal.”
Your Rights under Certain Data Protection Laws
Depending on your location and other factors, under GDPR you may have the following rights regarding your Personal Data:
- Right of access: obtain a copy of your Personal Data.
- Right to rectification: request correction of inaccurate or incomplete data.
- Right to erasure: request deletion of your Personal Data.
- Right to restrict processing: request restriction of processing under certain circumstances.
- Right to data portability: receive your Personal Data in a structured, commonly used, and machine-readable format.
- Right to object: object to processing based on legitimate interests or direct marketing.
- Right not to be subject to automated decision-making, including profiling, where it produces legal or similarly significant effects.
Right to Withdraw Consent
Where we rely on your consent to process Personal Data, you have the right to withdraw your consent at any time. Withdrawing consent does not affect the lawfulness of processing based on consent before its withdrawal.
Right to Lodge a Complaint
If you believe your data protection rights have been violated, you have the right to lodge a complaint with your local supervisory authority. For individuals in the EEA, you can find contact details for your data protection authority at https://edpb.europa.eu/about-edpb/board/members_en.
Changes to this Privacy Notice
We're constantly trying to improve our Services, so we may need to change this Privacy Notice from time to time, but we will alert you to any such changes by placing a notice on the Cerby website, by sending you an email and/or by some other means. Please note that if you've opted not to receive legal notice emails from us (or you haven't provided us with your email address), those legal notices will still govern your use of the Services, and you are still responsible for reading and understanding them. If you use the Services after any changes to the Privacy Notice have been posted, that means you agree to all of the changes. Use of information we collect is subject to the Privacy Notice in effect at the time such information is collected.
Contact Information and Data Protection Inquiries
If you have any questions or comments about this Privacy Notice, the ways in which we collect and use your Personal Data or your choices and rights regarding such collection and use, please do not hesitate to contact our support team or our Data Protection Officer at:
General Data Protection Regulation (GDPR) – European Representative
Pursuant to Article 27 of the General Data Protection Regulation (GDPR), Cerby has appointed EDPO EU Ltd, Adam Brogden as its GDPR Representative in the EU. You can contact EDPO regarding matters pertaining to the GDPR:
-by using EDPO’s online request form or email at contact@gdprlocal.com
-by writing to EDPO at Avenue Huart Hamoir 71, 1030 Brussels, Belgium
UK General Data Protection Regulation (GDPR) – UK Representative
Pursuant to Article 27 of the UK GDPR, Cerby has appointed EDPO UK Ltd, Adam Brogden as its UK GDPR representative in the UK. You can contact EDPO UK regarding matters pertaining to the UK GDPR:
– by using EDPO’s online request form or email at contact@gdprlocal.com
– by writing to EDPO UK at 8 Northumberland Avenue, London WC2N 5BY, United Kingdom