(Risk Act Licensees and Prospects)
In this privacy notice (Notice), NetraScale Ltd (NetraScale, we, our, us) describes our collection, use, and disclosure of personal information that we collect about you through our websites, mobile applications, or cloud-based services and communication platforms with a link to this Notice (collectively, Sites), and the products and services available through our Sites and interactions with you (our Services). This Notice does not apply to sites that do not display or link to this Notice. Please note that we may provide you with additional disclosures or notices based on your interaction with us (e.g., if you apply for employment with us or are a NetraScale team member) or based on your residency; those additional disclosures or notices will apply together with this Notice depending on the circumstances. References to “personal information” in this Notice mean information that identifies or can reasonably identify users of the Sites (you) personally. If you are a California resident, see Additional Information for California Consumers for additional disclosures.
We collect the following information directly from you, about you from other sources, and automatically as you use our Services and Sites:
We collect identifiers such as real name, email address, associated account name (i.e., the entity that will license RiskAct), or similar identifiers.
We collect information when you contact us with an inquiry regarding our products and Services. If you contact us, we may keep a transcript of your call with our customer support specialist for quality assurance purposes. If you have an account with us, however, we do not typically associate this recording or transcript with your account.
If you are (or become) a RiskAct licensee, then our legal basis for processing any of your personal information is to facilitate our performance of a contract (i.e., the RiskAct license). If you are a prospective licensee, then our legal basis is legitimate interest, being the process of NetraScale acquiring your organization as a RiskAct licensee during a reasonable sales period in relation to the customer acquisition process.
We collect, use, disclose, and otherwise process your information, including your personal information, for the following purposes:
We disclose your personal information in the following ways:
We may disclose personal information to our affiliates and subsidiaries.
We may disclose information where necessary to investigate or prevent an actual or suspected crime or injury to us or others, if required by law, or in response to a request from law enforcement authorities or other government officials, including as part of a judicial proceeding; in response to a subpoena, warrant, court order, or other legal process; or as part of an investigation or request, whether formal or informal. We may also disclose your information to protect the safety, rights, property, or our security, the Services, any third party, or the general public; to detect, prevent, or otherwise address fraud, security, or technical issues; to prevent or stop activity which in our sole discretion we may consider to be or to pose a risk of being an illegal, unethical, or legally actionable activity; to use as evidence in litigation; and to enforce this Notice.
During the normal course of our business, we may sell or purchase assets or equity. If another entity acquires us or any of our assets, information we have collected about you may be transferred to such entity, including during negotiations related to such transactions. In addition, if any bankruptcy or reorganization proceeding is brought by or against us, such information may be considered an asset of ours and may be sold or transferred to other parties.
We may use analytics companies, for example, Google Analytics, to evaluate use of our Services. We use these tools to help us understand the use of and to improve our Services' performance, ad campaigns, and user experiences. These entities may use cookies and other tracking technologies such as web beacons or local storage objects to perform their services.
Our Sites may link to external websites, and this Notice does not apply to those sites. For information about the privacy practices of external sites, please check the privacy policy of the specific site you're visiting to understand the privacy practices associated with that site. We are not responsible for the content or privacy practices of these websites.
Protecting your personal information is important to us. We maintain administrative, technical, and physical safeguards designed to help protect against unauthorized use, disclosure, alteration, or destruction of the personal information we collect on our Sites. However, no data security measures can guarantee 100% against compromise.
Where you or the organization with which you are associated becomes a RiskAct licensee, we may continue to process your personal information throughout the term of that license, including any extensions. If you (or your organization) do not become a RiskAct licensee, we may continue to process your personal information for a reasonable period of time while we seek to sell a license but in no event longer than 12 months. Promptly after (i) any RiskAct license expires or terminates, or (ii) the reasonable period in which we seek to sell a license expires, we will delete any of your personal information that was being processed in connection with that license or that sale process. You may request in writing to info@netrascale.com that we cease processing your personal information earlier than the dates described in this paragraph, and we will take reasonable steps to do so. However, it may not be possible to delete all of your personal information (for example, if you are a RiskAct licensee, we will need to keep some contact information for the licensee – and you may therefore need to supply alternative contact information before we can delete yours).
We may from time to time change or update portions of this Notice in accordance with applicable laws. Please check back periodically so you are aware of any changes or updates to the Policy. We will indicate the Notice's last updated date at the top of this Notice. We will post any changes to this Notice on our Site and will take steps to notify you of material changes, such as via email or prominent notice on the Site.
If you have any questions about this Notice, you can contact us at: info@netrascale.com
Under the California Consumer Privacy Act (CCPA) as amended by the Consumer Privacy Rights Act (CPRA) (which are together referred to in this Notice as California Privacy Law), we are required to provide specific disclosures about how we use and disclose personal information (CA Personal Information) about you (“consumers” in this section). This section covers how we have collected, used, disclosed, and otherwise processed your CA Personal Information over the past 12 months, as well as additional rights you may have with respect to your CA Personal Information. This section does not reflect our processing of CA Personal Information where an exception under California law applies.
Depending on your online and offline interactions with us, we may collect and process the following categories of CA Personal Information:
Including contact details such as real name, email address, account name, or other similar identifiers
Audio, electronic, visual, or similar information (note that we do not sell this information). For example, if you call us, we may retain a copy of that call recording.
Drawn from the information collected.
Certain CA Personal Information that we collect about you may be considered Sensitive Personal Information within the meaning of California Privacy Law. We only use and disclose Sensitive Personal Information as necessary in connection with the performance of services and the provision of goods, compliance with federal, state, or local laws, and as otherwise permitted by California Privacy Law.
We collect the categories of CA Personal Information directly from you only and not from third parties. This is done automatically as you use our Sites and Services.
We use CA Personal Information for the following business and commercial purposes:
We may disclose the categories of CA Personal Information described above for the business purposes described above to:
a. Customers, distributors, and intermediaries in connection with the performance of transactions; b. Government and other authorities as required by law; c. Potential purchasers and other parties in connection with the sale, purchase, or merger of a business; and d. Others to the extent necessary to comply with applicable law and as otherwise permitted under California Privacy Law.
Subject to certain exceptions detailed in California Privacy Law, as a California resident you have the right to request: (i) deletion of your CA Personal Information; (ii) correction of inaccurate CA Personal Information; (iii) the right to know/access the categories of CA Personal Information that we collect about you, including the specific pieces of CA Personal Information; (iv) the categories of CA Personal Information disclosed for a business purpose; and (v) information about the categories of CA Personal Information about you that we have shared (as such term is defined under California Privacy Law) and the categories of third parties to whom the CA Personal Information was shared.
In addition, California law grants California residents certain rights and imposes restrictions on particular business practices as set forth below.
In addition to the above-stated rights, California residents have the right to opt-out of the selling or sharing of their CA Personal Information, as such terms are defined under California Privacy Law. To exercise this right, please click here.
We will not discriminate against you by offering you different pricing or products or by providing you with a different level or quality of products based solely upon your exercising your rights under applicable law.
Finally, we do not “sell” or “share” CA Personal Information about any consumers, including consumers that we know are younger than 16 years old.
If you are a California resident and wish to request the exercise of these rights as detailed above, or have questions regarding the CA Personal Information collected or shared with third parties, please contact us at info@netrascale.com or you can submit your request online by using our Individual Rights Request Form. When submitting your request, please include the specific nature of your request, referencing "Your California Privacy Rights," as well as your first and last name, email address, and zip code or mailing address. We may apply any exceptions or other conditions available under law when responding to access, correction, deletion, or other requests. We will generally fulfill requests for access, correction, and deletion within 45 days of receiving a valid, verified request. We may extend the response time by another 45 days by notifying you of the time extension.
To the extent that you elect to designate an authorized agent to make a request on your behalf, the authorized agent must provide appropriate documentation, including written signed permission from you, proof of your identity, and verification of the agent’s identity; a valid designated power of attorney as defined under the California Probate Code, and a certificate of registration as an agent before the California Secretary of State. If you are an agent submitting the request on behalf of a California consumer, please use our Individual Rights Request Form.
We keep your CA Personal Information for as long as needed or permitted according to the purpose(s) for which it was obtained. The criteria used to determine our retention periods include (i) for as long as we have an ongoing relationship with you; (ii) for the duration of a contract with you; (iii) as required by a legal obligation to which we are subject to; or (iv) as advisable considering our legal position (such as in regard to applicable statutes of limitations, litigation, or regulatory investigations). We may remove CA Personal Information for inactive accounts from our database subject to any applicable legal or regulatory obligations. Furthermore, we may delete CA Personal Information from our database at any time and without providing any reason.
Separately under California’s “Shine the Light” law (Cal. Civ. Code § 1798.83), California residents who provide us their Personal Information are entitled to request and obtain from us free of charge information about the Personal Information (if any) we have shared with third parties for their own direct marketing use; such requests may be made once per calendar year for information about any relevant sharing in the prior calendar year (so requests submitted in 2020 would be applicable to relevant disclosures (if any) in 2019). If you are a California resident and would like to make such a request, please submit your request in writing by mailing us at info@netrascale.com using the subject line "Request for California Privacy Information." In your request, please attest to the fact that you are a California resident and provide a current California address. We will reply to valid requests by sending a response to the email address from which you submitted your request. Please note that not all information sharing is covered by the Shine the Light requirements, and only information on covered sharing and the relevant details required by the Shine the Light law will be included in our response.