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Smokescreen’s Privacy Policy

We are committed to keeping your personal information safe

Smokescreen’s Privacy Policy (the “Policy”) describes how Smokescreen, its affiliates and subsidiaries (“Smokescreen”, ”we”, “us”, “our”) collect, use, process, share, and safeguard personal information gathered through our website www.smokescreen.io (the “Website”), our products and services, and via other means.

This Policy applies to the activities for which Smokescreen is a “data controller” which means that Smokescreen decides why and how Personal Information is processed. Smokescreen may also act as a “data processor” (i.e., service provider to other companies), but this Policy does not apply to the processing of personal information we do on behalf of our customers. To learn more about the processing of your personal information in that context, please refer to the relevant customer’s privacy policy.

INFORMATION WE COLLECT

For the purpose of this Policy, “Personal Information” means any information relating to an identified or identifiable individual.

Registration or usage of any of Smokescreen services implies your express consent and agreement to this Policy. Wherever applicable and required, we indicate whether and why you must provide us with your personal information. If you do not provide the requisite information when requested, you may not be able to fully benefit from our Website and/or our products and services, if that information is necessary to service your requirement or if we are legally required to collect it.

We obtain Personal Information relating to you from various sources, more specifically described below:

Information Provided by You

  1. Business contacts: We may receive professional contact details of employees and other individuals associated with our customers, partners, and vendors, such as first and last name, email address, phone number, title and department, and other information relevant to the particular business relationship.
  2. Communications: If you contact us directly (e.g., via email, phone etc.) or fill out information on our website (e.g., to request a demo, to ask a question via our online contact form, to apply for a job on our career page etc.), we collect your name, email address, phone, company, postal address, the content, date and time of your message and any attachments thereto, and other information you may directly provide to us. If you post a public comment on our blog page, we ask you to provide your name and email address.

Information Collected via Cookies/Automated Means

The Smokescreen website may use “cookies” or similar technologies to help you personalize your online experience and improve our products and services. When we refer to “cookies” below, we mean cookies and similar technologies.

  1. Understanding cookies: A cookie is a text file that is placed on your hard disk by aweb page server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you and can only be read by a web server in the domain that issued the cookie to you.
  2. Need for us to use Cookies: One of the primary purposes of cookies is to provide a convenience feature to save you time. The purpose of a cookie is to tell the web server that you have returned to a specific page. For example, if you personalize Smokescreen pages, or register with Smokescreen’s website or services, a cookie helps Smokescreen to recall your specific information on subsequent visits. This simplifies the process of recording your Personal Information, such as billing addresses, shipping addresses, and so on. When you return to the same Smokescreen website, the information you previously provided can be retrieved, so you can easily use the Smokescreen features that you customized. Information collected via cookies is also used for the operation of the service, to maintain quality of the service, and to provide general statistics regarding use of the Smokescreen website.
  3. Your right to decline: You have the option to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you so prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of the Smokescreen services or websites you visit.
  4. Information collected via cookies: Information about your computer hardware and software, including your IP address, browser type, domain names, access times and referring website addresses.
  5. Cookies subject to change: The content and the information provide to you in this Policy is for your general information and use only. These cookies are subject to change without notice. You acknowledge that this information may contain inaccuracies or errors and is subject to change and we expressly exclude liability for any such inaccuracies or errors to the fullest extent permitted by law.

Information Collected via Third Parties

  1. Smokescreen’s business customers: We may receive Personal Information about otherindividuals from our business customers to process it on their behalf as we provide them with our products and services. We process this information as instructed by our customers. To learn more about the processing of your Personal Information in that context, please refer to the relevant customer’s privacy policy.
  2. Social sign-on: We may collect Personal Information about you when you sign in via third party services (such as LinkedIn and Google). This information may include name, email address, IP address, phone number, etc.
  3. Other third parties: We may also obtain Personal Information about you from other third parties, such as database vendors, events, etc. This information may include name, job title, email address, phone number, social media profiles, company name, company address, etc.
  4. Publicly accessible sources: We may collect information about you, including name, job title, email address, phone number, social media profiles, company name, company address, etc. from publicly accessible sources, such as social media sites, web search, etc.

HOW WE USE YOUR PERSONAL INFORMATION

Smokescreen collects and uses your Personal Information as described below:

  • Services: To operate, provide and maintain the services that we offer to our customers, our website, and other products and services that we may offer. For example, if you work at one of our customers, partners, or vendors, we may use your email address to manage the business relationship. Smokescreen does not sell, rent or lease its customer lists to third parties.
  • Communications: We may send emails to an email address you provide to us (i) for customer service or technical-support purposes, or (ii) to send you information about topics or content that may interest you; updates about the latest developments or features of our products and services; or updates regarding your order. Smokescreen may also contact you via surveys to conduct research about your opinion of current services or of potential new services that may be offered.
  • Analytics and product development: We and our service providers use Personal Information, such as your interactions with our products and services, to monitor and analyse usage of, and to improve and enhance our products, services, and website.
  • Tailored user experience: To customize your customer experience, for example by remembering your information so that you will not have to re-enter it the next time you visit our website, to determine which products or services are the most popular, to deliver customized content and advertising within Smokescreen to those whose behaviour indicates that they are interested in a particular subject area.
  • Job applications: If you apply for a job at Smokescreen, we may process your Personal Information to evaluate your application.
  • Legal: We may use your Personal Information to defend our legal rights, to comply withour legal obligations and internal policies.

WHEN WE USE INFORMATION ABOUT YOU

If you are located in the European Economic Area, we only process your Personal Information based on a valid legal ground, including when:

  • Consent: You have consented to the use of your Personal Information, for example tosend marketing communications, direct sales outreach, etc.
  • Contract: We need your Personal Information to provide you with Smokescreen’s products and services, including for account registration or to respond to your inquiries.
  • Legal obligation: We have a legal obligation to use your Personal Information, for example to prevent fraud.
  • Legitimate interest: We or a third party, have a legitimate interest in using your Personal Information. In particular, we have a legitimate interest in using your Personal Information for product development and internal analytics purposes, and otherwise toimprove the safety, security, and performance of our products and services. We only rely on ours or a third party’s legitimate interests to process your Personal Information when these interests are not overridden by your rights and interests.

HOW WE DISCLOSE INFORMATION ABOUT YOU

Smokescreen may share Personal Information about you in the following circumstances:

  • Smokescreen’s business customers: We may share Personal Information about you with our business customers when we process that information on their behalf as we provide them with our products and services.
  • Service providers: We may disclose Personal Information about you to trusted partners to help perform statistical analysis, send you email or postal mail, provide customer support, arrange for deliveries or provide other services to Smokescreen. All such third parties are prohibited from using your Personal Information except to provide these services to Smokescreen, and they are required to maintain the confidentiality of your Personal Information.
  • Merger: To a potential or actual acquirer, successor, or assignee as part of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in bankruptcy or similar proceedings).
  • Legal: If required to do so by law or in the good faith belief that such action is appropriate: (a) under applicable law, including laws outside your country of residence;(b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

SECURITY OF YOUR PERSONAL INFORMATION

Smokescreen secures your Personal Information by maintaining administrative, technical and physical safeguards that are intended to appropriately protect Personal Information against accidental or unlawful destruction, accidental loss, unauthorized alteration, unauthorized disclosure or access, misuse, and any other unlawful form of processing of the Personal Information in our possession. It is important that you maintain the security and control of your account credentials, and not share your password with anyone.

INTERNATIONAL DATA TRANSFERS

Personal Information that we collect may be stored, processed in, and transferred to countries other than the country where you initially provided the information, for example to the geographies in which we operate – the United States of America, United Arab Emirates, India, European Union – in order to enable us to use the information in accordance with this Policy. These countries may not have data protection laws equivalent to those in force in your country. By using our products or services, you agree to the transfer of your Personal Information outside of your country.

DATA RETENTION

We take measures to delete your Personal Information or keep it in a form that does not permit identifying you when this information is no longer necessary for the purposes for which we process it, unless we are required by law to keep this information for a longer period. When we process Personal Information for our own purposes, we determine the retention period taking into account various criteria, such as the type of services provided to you, the nature and length of our relationship with you, possible re-enrolment with our services, the impact on the services we provide to you if we delete some information from or about you, and mandatory retention periods provided by law and the statute of limitations.

YOUR RIGHTS AND CHOICES

  • Opt-Out & Unsubscribe: We respect your privacy and give you an opportunity to opt-out of receiving announcements of certain information. Users may opt-out of receiving any or all communications from Smokescreen by contacting us at unsubscribe@smokescreen.io. Upon request, Smokescreen will provide you with any Personal Information we hold about you. You may instruct us to delete your Personal Information at any time.
  • European Rights: If you are located in the European Economic Area, you may have additional rights described herein above. These rights may be limited in some circumstances by local law requirements. You may exercise these rights by contacting usas indicated at the bottom of this Policy.
  • Request access to and receive information about the Personal Information we maintain about you, update and correct inaccuracies in your Personal Information, restrict or object to the processing of your Personal Information, have the information anonymized or deleted, as appropriate, or exercise your right to data portability to easily transfer your Personal Information to another company. In addition, you may also have the right to lodge a complaint with a supervisory authority, including in your country of residence, place of work or where an incident took place.
  • Withdraw any consent you previously provided to us regarding the processing of your Personal Information, at any time and free of charge. We will apply your preferences going forward and this will not affect the lawfulness of the processing before your consent withdrawal.

THIRD PARTY LINKS

Smokescreen encourages you to review the privacy policies of websites you choose to link to from Smokescreen so that you can understand how those websites collect, use and share your information. Smokescreen is not responsible for the privacy policies, practices, or other content on websites outside of the Smokescreen website.

CHILDREN

Smokescreen does not knowingly collect Personal Information from children under the age of fourteen. If you are under the age of fourteen, you must ask your parent or guardian for permission to use this website.

CHANGES TO THIS POLICY

Smokescreen will from time to time update this Policy to reflect company and customer feedback or to comply with applicable legal requirements. Smokescreen encourages you to periodically review this Policy to be informed of how Smokescreen is protecting your Personal Information.

CONTACT INFORMATION

Smokescreen welcomes your questions or comments regarding this Policy. If you have any question or would like to exercise your rights and choices, please contact Smokescreen at:

Smokescreen 1st Floor, Kaledonia, Sahar Road, Andheri East, Mumbai -400069, Maharashtra, India
8, Federal Hill Road, Nashua, NH – 03062, USA
Email Address: info@smokescreen.io

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Effective as of August 31st, 2020

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