Last updated 27 May 2019
1.1. This privacy notice (hereinafter the “notice“) explains how ThreatPipes (hereinafter the “Operator“ or “us“) collects or processes in any other manner the personal data of its clients and visitors of the website threatpipes.com (hereinafter the “Website“) and users of ThreatPipes platform (hereinafter the “platform”) - all such persons, including individual clients or the representatives of legal persons are referred to as “you” or the “data subject”.
1.2. This notice describes the processing of personal data (hereinafter the “data”) by the company as a data controller. This means that the company individually or along with others determine the purposes and means of the processing of personal data.
2.1. Unless expressly otherwise stated or evident in the context, the capitalised terms used in these Terms shall have the meanings set forth in the introductory language of these Terms or as set forth below:
- 2.1.1. “Account” – a common term for the Client Account and the User Account;
- 2.1.2. “Agreement” – an agreement for the use of the Platform concluded between the Operator and the Client in accordance with the Terms;
- 2.1.3. “Client Account” – A profile connected to a specific Client for the use of the Platform used to identify the Client, to provide the Users connected to the Client with access to the Platform, and to change and save the settings;
- 2.1.4. “Cookies” – Small sets of data stored in the User's device;
- 2.1.5. “Client” – a person who has entered into the Agreement with the Operator;
- 2.1.7. “Data Subject” – the natural person to whom the Personal Data refers;
- 2.1.8. “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;
- 2.1.9. “Fee” – regular payment pursuant to the Plan for using the activated Account;
- 2.1.10. “Intellectual Property” – all existing and future author’s rights (copyrights), including any neighbouring and related rights, and industrial property rights in and related to the Platform, including all applications for renewal or extension of those rights, and other similar or equivalent rights and means of protection;
- 2.1.11. “Operator (or Data Controller)” – the operator of the ThreatPipes Platform is ThreatPipes, a limited liability company established and existing under the laws of the UNITED KINGDOM, registered company number NI661784, address 46 Hill Street, Belfast, BT1 2LB, Northern Ireland;
- 2.1.12. “Party” – a common term for each of the Client and the Operator;
- 2.1.13. "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;
- 2.1.14. “Plan” – specific conditions related to the use and functionality of the Platform, which are specified on the Website, and on which the Fee is based;
- 2.1.15. “Platform” – ThreatPipes platform that is used to query data available from public and paid sources.
- 2.1.16. “Search data” – the data the Client or the User searched for by using the Platform and the data returned from the search;
- 2.1.17. “Service” – the service provided by this Platform as described in the relative Terms of Service and on this site/application;
- 2.1.18. "Usage Data" - Information collected automatically through this Platform (or third-party services employed in this Platform), which can include: the IP addresses or domain names of the computers utilised by the Users who use this Platform, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilised 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 utilised by the User, the various time details per visit (e.g., the time spent on each page within the Platform) and the details about the path followed within the Platform with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.
- 2.1.19. “User (or User Account)” – any individual that the Client has authorised to use the Platform;
- 2.1.20. “Website” – threatpipes.com with its content.
3.0 TYPES OF DATA COLLECTED
3.1. Among the types of Personal Data that this Platform collects, by itself or through third parties, there are: Cookies; Usage Data; email address; first name; last name; company name; country.
3.3. Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using this Platform.
3.4. Unless specified otherwise, all Data requested by this Platform is mandatory and failure to provide this Data may make it impossible for this Platform to provide its services. In cases where this Platform 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.
3.5. Users who are uncertain about which Personal Data is mandatory are welcome to contact the Operator.
3.7. Users are responsible for any third-party Personal Data obtained, published or shared through this Platform and confirm that they have the third party's consent to provide the Data to the Operator.
4.0 METHODS OF PROCESSING
4.1. The Operator takes appropriate security measures to prevent unauthorised access, disclosure, modification, or unauthorised destruction of the Data.
4.2. The Data processing is carried out using computers and/or IT enabled tools, following organisational procedures and modes strictly related to the purposes indicated. In addition to the Operator, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Platform (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 Operator. The updated list of these parties may be requested from the Operator at any time.
5.0 LEGAL BASIS OF PROCESSING
5.1. The Operator may process Personal Data relating to Users if one of the following applies:
- 5.1.1. Users have given their consent for one or more specific purposes. Note: Under some legislations the Operator 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;
- 5.1.2. provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
- 5.1.3. processing is necessary for compliance with a legal obligation to which the Operator is subject;
- 5.1.4. processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Operator;
- 5.1.5. processing is necessary for the purposes of the legitimate interests pursued by the Operator or by a third party.
5.2. In any case, the Operator 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.
6.0 PLACE OF PROCESSING
6.1. The Data is processed at the Operator's operating offices and in any other places where the parties involved in the processing are located.
6.2. 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.
6.3. Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organisation 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 Operator to safeguard their Data.
6.4. If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Operator using the information provided in the contact section.
7.0 RETENTION TIME
7.1. Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.
- 7.2.1. Personal Data collected for purposes related to the performance of a contract between the Operator and the User shall be retained until such contract has been fully performed.
- 7.2.2. Personal Data collected for the purposes of the Operator’s legitimate interests shall be retained as long as needed to fulfil such purposes. Users may find specific information regarding the legitimate interests pursued by the Operator within the relevant sections of this document or by contacting the Operator.
7.3. The Operator 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 Operator 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.
7.4. Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.
8.0 THE PURPOSES OF PROCESSING
8.1. The Data concerning the User is collected to allow the Operator to provide its Services, as well as for the following purposes: Hosting and backend infrastructure, Analytics, Managing contacts and sending messages, Handling payments and Traffic optimisation and distribution.
8.2. Users can find further detailed information about such purposes of processing and about the specific Personal Data used for each purpose in the respective sections of this document.
9.0 DETAILED INFORMATION ON THE PROCESSING OF PERSONAL DATA
9.1. Personal Data is collected for the purposes described and using the services listed in this section.
9.2. Analytics. The services contained in this section enable the Operator to monitor and analyse web traffic and can be used to keep track of User behaviour;
9.3. Hosting and backend infrastructure. This type of service has the purpose of hosting Data and files that enable this Platform to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of this Platform. Some services among those listed below, if any, may work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.
9.4. 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.
9.5. Traffic optimisation and distribution.This type of service allows this Platform to distribute their content using servers located across different countries and to optimise 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 this Platform 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 User are transferred.
10.0 THE RIGHTS OF USERS
10.1. Users may exercise certain rights regarding their Data processed by the Operator.
10.2.In particular, Users have the right to do the following:
- 10.2.1. 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.
- 10.2.2. 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.
- 10.2.3. Access their Data. Users have the right to learn if Data is being processed by the Operator, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
- 10.2.4. Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
- 10.2.5. Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Operator will not process their Data for any purpose other than storing it.
- 10.2.6. Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Operator.
- 10.2.7. 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.
- 10.2.8. Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.
11.0 DETAILS ABOUT THE RIGHT TO OBJECT TO DATA PROCESSING
11.1. Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Operator or for the purposes of the legitimate interests pursued by the Operator, Users may object to such processing by providing a ground related to their particular situation to justify the objection.
11.2. 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 Operator is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.
11.3. Requests to exercise User rights can be directed to the Operator through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Operator as early as possible and always within one month.
13.0 ADDITIONAL INFORMATION ABOUT DATA COLLECTION AND PROCESSING
13.1. The following describes additional information about how data collection and processing not already covered in this document;
- 13.1.1. Legal action. The User's Personal Data may be used for legal purposes by the Operator in Court or in the stages leading to possible legal action arising from improper use of this Platform or the related Services. The User declares to be aware that the Operator may be required to reveal personal data upon request of public authorities.
- 13.1.3. System logs and maintenance. For operation and maintenance purposes, this Platform and any third-party services may collect files that record interaction with this Platform (System logs) use other Personal Data (such as the IP Address) for this purpose.
- 13.1.4. Information not contained in this policy. More details concerning the collection or processing of Personal Data may be requested from the Operator at any time. Please see the contact information at the beginning of this document.
- 13.1.5. How “Do Not Track” requests are handled. This Platform 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.
14.0 LEGAL INFORMATION
14.1 This policy has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).
15.0 OPERATOR INFORMATION
15.2. Operator contact email: