HUNTERS PRIVACY POLICY


This Privacy Policy describes how Cyber Hunters Ltd. and its affiliated companies (collectively, “Hunters”, “we”, “our” or “us”) collect, store, use, and disclose your Personal Data as a data controller in connection with the following:

  • When you browse or visit our websites (including hunters.security), portals, hubs, and online ads/content under our control (“Sites”)
  • When you make use of or interact with our Sites
  • When you create an account and when you log in
  • When you request a demo, report or download or access an asset on our Sites
  • When we process your job application
  • When you contact us (e.g., customer support, need help, submit a request)
  • When you attend a marketing event or provide us with your Personal Data in connection with marketing events
  • When we acquire your Personal Data from third-party sources (such as lead-generation companies and event organizers)
  • When we use the Personal Data of our customers (e.g., contact details)
  • When we use the Personal Data of our resellers, distributors, agents, and/or finders (e.g., contact details)
  • When we use the Personal Data of our service providers (e.g., contact details)
  • Where we collect and process your Personal Data in connection with other occasions as further detailed in this policy.

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

If you are an end user of Hunters products (“End User”), this policy does not apply to our processing of your personal data. Our processing of End Users’ Personal Data is made under our capacity as a data processor on behalf of our customers and in accordance with the Data Processing Agreement that we have with our customers. Our customers, as data controllers, are responsible to provide adequate notice of such processing to their End Users and any other information necessary to comply with applicable laws.

Please read this Privacy Policy carefully and make sure that you fully understand and agree to it. You are not legally required to provide us with any Personal Data. However, if you choose to do so, it will be at your own free will. If you do not wish to provide us with your Personal Data or to have it processed by us or any of our service providers (in accordance with this policy), please avoid any interaction with us or any use of our Sites and services.

This Privacy Policy describes our practices regarding:

  1. What Personal Data we collect, why we collect it, and what are the legal bases for using it
  2. Data Retention
  3. Data Security
  4. Data Sharing
  5. Cross-border transfers of Personal Data
  6. Communications
  7. Your rights
  8. Additional Information
  9. Contact us

1.WHAT PERSONAL DATA WE COLLECT, WHY WE COLLECT IT, AND WHAT ARE THE LEGAL BASES FOR USING IT

Specific Personal Data we collect

Why is the Personal Data collected and for what purposes?

Legal bases (where GDPR applies)

When you browse or visit our Sites

Cookies, analytic tools and log files

For more information, please read our Cookie Policy.

  • To understand the usage of our Sites
  • To enhance the Sites navigation
  • For marketing purposes

Consent

Legitimate interest (e.g., essential cookies)

When you make use of or interact with our Sites

When you create an account and when you log in

  • Email address
  • Mobile phone number
  • Name
  • Job title
  • Country/State/Province
  • When applicable, hashed password or other information used for authentication and access control
  • To be able to create an account
  • To be able to log in
  • To be able to enjoy features available to registered users only

Processing is necessary for the performance of a contract

Legitimate interest (e.g., to provide our services)

When you request a product demo

  • Full name
  • Business email
  • Job title
  • Contact number
  • Company name
  • To provide you with a demo
  • To send you demo-related communications

Processing is necessary for the performance of a contract

Legitimate interest (e.g., to provide a demo)

  • Full name
  • Email address
  • To send marketing communications

Legitimate interest and/or Consent

When you request a report or download or access an asset on our Sites

  • Email address
  • To send you our reports

Processing is necessary for the performance of a contract

Legitimate interest (e.g., to provide our reports)

When we process your job application

  • Full name
  • Email address
  • Phone number
  • Resume/CV
  • LinkedIn profile
  • Portfolio
  • Personal website
  • Personal note
  • Any other data that you decide to supply/provide us

NOTE: To learn more, please check our Job Candidate Privacy Notice.

  • To process your job application
  • To assess the candidate

Legitimate interest (e.g. process your job application)

Processing is necessary for the performance of a contract

When you attend a marketing event and/or provide us with your Personal Data in connection with a marketing event

  • Full name
  • Email address
  • Company name
  • Job title
  • Phone number
  • Address
  • To manage and administer your participation in the event including sending your communications related to your attendance
  • To establish a business connection
  • To send marketing communications
  • To respond to requests and to provide ongoing communication with potential customers who have requested information and for direct marketing

Legitimate interest (e.g., provide you with information on the marketing event; provide you with further information about Hunters)

When we acquire your Personal Data from third-party sources (such as lead-generation companies or event organizers)

  • Full name
  • Company name
  • Job title
  • Email address
  • To establish a business connection
  • To send marketing communications

Depending on the context, legitimate interest (B2B marketing), pre-contractual discussions or consent

When we use the Personal Data of our customers (e.g., contact details)

  • Full name
  • Company name
  • Email address
  • Phone number
  • Any other data customers decide to provide us
  • To communicate with our customers/clients
  • To provide our products and services
  • To perform the applicable agreement

Processing is necessary for the performance of a contract

Compliance with a legal obligation (e.g., tax laws, bookkeeping laws, etc.)

Legitimate interest (e.g., send you contract-related communications)

  • Full name
  • Email address
  • To send marketing communications

Consent

When we use the Personal Data of our partners (e.g., contact details)

  • Full name
  • Company name
  • Email address
  • Phone number
  • Job position
  • Any other type of Personal Data you decide to share with us
  • To negotiate and execute an agreement with you
  • To communicate with you (service-related communications or updates of the services)
  • To answer your questions or requests

Processing is necessary for the performance of a contract

Processing is necessary for compliance with a legal obligation to which the controller is subject (e.g., tax obligations)

Legitimate interest (e.g., to send you service-related updates)

When we use the Personal Data of our service providers (e.g., contact details)

  • Full name
  • Company name
  • Job title
  • Email address
  • Phone number
  • Any other type of Personal Data you decide to share with us
  • To contact our service providers
  • To perform the agreement with the supplier

Processing is necessary for the performance of a contract

Legitimate interest (e.g., perform the contract, send contract-related communications)

Finally, please note that some of the abovementioned Personal Data will be used for detecting, taking steps to prevent, and prosecuting fraud or other illegal activity, identifying and repairing errors, conducting audits, and for security purposes. Personal Data may also be used to comply with applicable laws, with investigations performed by the relevant authorities for law enforcement purposes, and/or to exercise or defend legal claims. In certain cases, we may or will anonymize or de-identify your Personal Data and further use it for internal and external purposes, including, without limitation, to improve the services and for research purposes. “Anonymous Information” means information that does not enable the identification of an individual user, such as aggregated information about the use of our services. We may use Anonymous Information and/or disclose it to third parties without restrictions (for example, in order to improve our services and enhance your experience with them).

2.DATA RETENTION

We retain your Personal Data for as long as we deem it reasonably necessary to fulfill our business purposes, including providing you with our services and offerings and to maintain and expand our relationship; until you send a valid deletion request; to comply with our legal and contractual obligations; or to protect ourselves from any potential disputes (i.e., as required by laws applicable to log-keeping, records, and bookkeeping, and in order to have proof and evidence concerning our relationship, should any legal issues arise following your discontinuance of use), all in accordance with applicable laws and regulations.

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

If you have any questions about our data retention practices, please contact us by e-mail at privacy@hunters.ai.

3.DATA SECURITY

We implement systems, applications, and procedures to designed to secure your Personal Data, to minimize the risks of theft, damage, loss of information, or unauthorized access or use of information. These measures provide sound industry-standard security, however, although we make efforts to protect your privacy and data, we cannot and do not guarantee the absolute protection and security of any Personal Data stored with us or with any third parties. To learn more, please visit https://www.hunters.security/privacy-and-security.

4.DATA SHARING

We disclose your Personal Data with other parties when outsourcing certain tasks or processes to service providers or subcontractors, whether in relation to our services, Sites, operation, or internal requirements pursuant to the legal bases described above. We use the following categories of service providers or contractors who are only authorized to process your personal data as necessary to provide these services to us:

  • Service providers who provide us with services such as IT and system administration and hosting, research and analytics, marketing, customer support, customer relationship management, human resources information systems, consultants, and advisors.
  • Business partners with whom we jointly offer products or services.
  • Our affiliated companies.
  • Regulators, courts, or competent authorities, to comply with applicable laws, regulations, and rules (including, without limitation, federal, state, or local laws), and requests of law enforcement, regulatory, and other governmental agencies or if required to do so by court order, judicial proceeding, or legal process.
  • Service providers and partners with which we run or sponsor events and with social media and/or advertising companies to personalize our communications and your experience on our and other websites.
  • If, in the future, we sell or transfer, or we consider selling or transferring, some or all of our business, shares, or assets to a third party, we will disclose your Personal Data to such third party (whether actual or potential) in connection with the foregoing events.
  • In the event that we are acquired by, or merged with, a third party entity, or in the event of bankruptcy or a comparable event, we reserve the right to transfer, disclose or assign your Personal Data in connection with the foregoing events, including, in connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or to another company.
  • Where you have provided your consent to us sharing or transferring your Personal Data (e.g., where you provide us with marketing consents or opt-in to optional additional services or functionality).
  • Events Sponsors. If you attend an event or webinar organized by us, or download or access an asset on our Sites related to such an event, webinar, or other activity involving third-party sponsors or presenters, we may share your Personal Data with them. If required by applicable law, you may consent to such sharing via the registration form or by allowing your attendee badge to be scanned at a sponsor booth. In these circumstances, your Personal Data will be subject to the sponsors’ privacy statements. If you do not wish for your Personal Data to be shared, you may choose to not opt-in via event/webinar registration or elect to not have your badge scanned, or you can opt-out in accordance with Section 8 below.

5.CROSS-BORDER TRANSFERS OF PERSONAL DATA

  • Your Personal Data may be collected, transferred to, and stored by us in the United States, Europe, and by our affiliates and third parties disclosed above, that are based in other countries.
  • Processing Data Outside of the European Economic Area (EEA): Where we transfer your Personal Data outside of EEA (for example to third parties who provide us with services), we will generally obtain contractual commitments from them to protect your Personal Data. When Hunters engages in such transfers of Personal Data, it relies on either i) Adequacy Decisions as adopted by European Commission (for example, when we access the data from Israel), or ii) Standard Contractual Clauses issued by the European Commission.

6.COMMUNICATIONS

  • Service Communications: we may contact you with important information regarding our products and services. For example, we may send you notifications (through any of the means available to us) of changes or updates to our products and services (such as billing issues, login attempts or password reset instructions, alerts and notifications concerning anomalies detected by our products and services, surveys, etc.). You can control your communications and notifications in accordance with the instructions included in the communications sent to you. Please note that you will not be able to opt out of receiving certain service communications which are integral to your use of our products.
  • Notifications and Promotional Communications: we and our authorized partners (e.g., event or webinar co-sponsors or partners) may also notify you about new features, additional offerings, events, webinars, special opportunities, or any other information we think you will find valuable. We may provide such notices through any of the contact means available to us (e.g., SMS, phone, mobile, or e-mail), through our products or services, or through our marketing campaigns on any other sites or platforms. In order to control your notifications settings please follow the instructions included in the promotional communications sent to you. If you do not wish to receive such communication, you may also notify us by sending an e-mail to: privacy@hunters.ai.

7. YOUR RIGHTS

The following rights which may be subject to certain exemptions or derogations shall apply to certain individuals (some of which only apply to individuals protected by specific laws):

  • The right to access – access Personal Data we hold about you. Your right of access may normally be exercised free of charge, however, we reserve the right to charge an appropriate administrative fee where permitted by applicable law
  • The right to rectification/correct – request that we rectify any Personal Data we hold that is inaccurate or misleading
  • The right to erasure/deletion – request the erasure/deletion of your Personal Data. Please note that there may be circumstances in which we are required to retain your Personal Data, for example for the establishment, exercise, or defense of legal claims
  • The right to object or restrict processing – object to, or request the restriction of, the processing
  • The right to data portability - this means that you may have the right to receive your Personal Data in a structured, commonly used, and machine-readable format, and that you have the right to transmit that data to third parties
  • The right to object to profiling
  • The right to withdraw your consent at any time. Please note that there may be circumstances in which we are entitled to continue processing your data, in particular, if the processing is required to meet our legal and regulatory obligations. Also, please note that the withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal
  • lodge a complaint with your local data protection supervisory authority (i.e., your place of habitual residence, place of work, or place of alleged infringement) or with the relevant institutions in your place of residence. We ask that you please attempt to resolve any issues with us before you contact your local supervisory authority and/or relevant institution.

You can exercise your rights by contacting us at: privacy@hunters.ai Note that if you are using the Sites on behalf of our customer, your request should be communicated to us through the account administrator of the applicable customer (i.e., your employer or the organization to which you are related). Please also note that if such a request is directed to us, we will share such a request with the relevant customer.

Privacy rights are not absolute. As described above, there are instances where applicable law or regulatory requirements allow or require us to refuse to provide some or all of the Personal Data that we hold about you. In the event that we cannot accommodate your request, we will inform you of the reasons why, subject to any legal or regulatory restrictions.

When you ask us to exercise any of your privacy rights, we may require additional information, including certain Personal Data, in order to authenticate and process your request. Such additional information may be then retained by us for legal purposes (e.g., as proof of the identity of the person submitting the request). We may redact from the data which we will make available to you, any Personal Data related to others.

8.ADDITIONAL INFORMATION

  • Updates and Amendments: we may update and amend this Privacy Policy from time to time by posting an updated version on our Sites. The amended version will be effective as of the date it is published. We will provide prior notice if we believe any substantial changes are involved via any of the communication means available to us or via the Sites. After such notice period, all amendments shall be deemed accepted by you.
  • External Links: while our Sites may contain links to other websites or services, we are not responsible for their privacy practices. We encourage you to pay attention when you leave our Sites for the website or application of such third parties and to read the privacy policies of each and every website and service you visit. This Privacy Policy applies only to our Sites.
  • Our Sites are not designed to attract children under the age of 18: we do not knowingly collect Personal Data from children and do not wish to do so. If we learn that a person under the age of 18 is using the Sites, we will attempt to prohibit and block such use and will make efforts to promptly delete any Personal Data stored with us with regard to such child. If you believe that we might have any such data, please contact us by e-mail at privacy@hunters.ai.
  • California and Delaware Do Not Track Notice: Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that Hunters does not monitor or respond to Do Not Track browser requests. Hence please ensure to change any settings of your browser and/or our services, whenever you wish cookies to cease.

9.CONTACT US.

If you have any comments or questions regarding this Privacy Policy, if you have any concerns regarding your Personal Data held with us, or if you wish to make a complaint about how your Personal Data is being processed by Hunters, you can contact us at privacy@hunters.ai.

Last Updated: July 17th, 2023