Salt Security, Inc. and its affiliates d/b/a “Salt” (“Salt”, “we” or “us”) respect the privacy of the Visitors of our websites and Users of our Platform, and are committed to protection of the personal data(defined below) that is made available to us.
This Privacy Policy describes how Salt collects, stores, uses and discloses the following categories of personal data:
Specifically,this Policy describes our practices regarding:
If you are a Customer, User, Partner or Visitor, please read this Privacy Policy carefully and make sure that you fully understand it.
Our Services are designated for businesses and are not intended for personal or household use. Accordingly, we treat all personal data covered by this Privacy Policy, including information about any visitors to our Sites, as pertaining to individuals acting as business representatives, rather than in their personal capacity.
You are not legally required to provide us with any personal data. 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(as defined below), please do not provide it to us and avoid any interaction with us or with our Sites, or use our Services.
When we use the terms “personal data” or “personal information” 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. It does not include aggregated or deidentified information that is maintained in a form that is not reasonably capable of being associated with or linked to an individual. Salt does not collect, use or disclose sensitive personal data.
Types of personal data collected. We may collect or generate the following types of personal data about individuals through the Services:
Connectivity, technical and aggregated usage data, such as user agent, IP addresses and approximate location based upon such IP addresses, digital identifiers, device data (like type, OS, device id, browser version, locale and language settings used), activity logs, session recordings,log-in credentials to the Services, the cookies and pixels installed or utilized on their device (which collect data such as how often Visitors visitor use the Sites, which pages they visit and when, and which website ad or email message brought them there), and inferred or presumed data on or generated from their use of the Services
Contact and business details such as name, email, phone number, position, workplace and related business insights, our communications with such individuals (correspondences, sensory information including call and video recordings, and transcriptions and analyses thereof), feedback and testimonials received, contractual and billing details, as well as any expressed, presumed or identified needs, preferences, attributes and insights relevant to our potential or existing engagement.
For the purposes of the California Consumer Privacy Act ("CCPA"),in the last 12 months, we have collected the following categories of personal information,as defined in the CCPA: Identifiers; Customer record information; Internet or other electronic network activity information; Professional or employment-related information; Geolocation data; Commercial information; Inferences; and Audio, electronic, visual, thermal, olfactory information.
Categories of sources from which personal data is collected. We obtain personal data from the following categories of sources:
We use personal data for the following business and commercial purposes (and in reliance on the legal bases for processing noted next to them, as appropriate):
User personal data
User, Partner and Visitor personal data
If you reside or are using the Services in a territory governed by privacy laws under which “consent” is the only or most appropriate legal basis for the processing of personal data as described herein (in general, or specifically with respect to the types of personal data you expect or elect to be processed by or via the Services, or due to nature of such processing), your acceptance of our Terms of Use (and/or the terms that govern your use of the Platform)(collectively, the “Terms”) and this Privacy Policy will be deemed as your consent to the processing of your personal data for all purposes detailed herein. If you wish to revoke such consent, please contact us at privacy@salt.security.
We and our authorized Service Providers maintain, store and process personal data in the United States, Israel,European Union and in other locations as reasonably necessary for the proper delivery and performance of our Services, or as may be required by law.
Since we operate globally and may use service providers worldwide, including in the US, Europe, Israel and other locations as reasonably necessary for the proper performance of our Services,or as may be required by law, we may transfer your personal data outside your country of residence.
While privacy laws may vary between jurisdictions, Salt is committed to protect personal data in accordance with this Privacy Policy and customary industry standards, and such appropriate lawful mechanisms and contractual terms requiring adequate data protection,regardless of any lesser legal requirements that may apply in the jurisdiction to which such personal data is transferred.
For data transfers from the European Economic Area, the UK and Switzerland, we will transfer your personal data only to such countries approved by the European Commission, FDPIC and UK Information Commissioner’s Office (ICO) respectively, as providing adequate level of data protection, or enter into Standard Contractual Clauses as approved by the relevant data protection authority. You can obtain a copy of these clauses by contacting us as indicated in Section 12 below.
We retain personal data for as long as we deem it as reasonably necessary in order to maintain and expand our relationship and provide you with our Services and offerings; in order to comply with our 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 our data retention policy.
To determine the appropriate period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and the applicable legal requirements.
If you have any questions regarding our data retention practices, please contact us by email at privacy@salt.security.
We disclose personal data in the following ways:
For the purposes of the CCPA, in the past 12 months, we may have disclosed Identifiers; Customer record information; Internet or other electronic network activity information; Professional or employment-related information; Geolocation data; Commercial information; Inferences; and Audio, electronic, visual, thermal, olfactory information to Service Providers, Partnerships, for Legal Compliance, to Protect Rights and Safety or to Salt Subsidiaries and Affiliated Companies. We did so in pursuit of the business and commercial purposes described in Section 2 above.
We and our Service Providers use cookies and other similar technologies to enable and improve the Services we provide, to track the performance of our Sites, perform analytics and gain insights on the use of our Services and the performance of our activities, and for personalization purposes including personalization of ads if we have obtained your consent.
Cookies are packets of information sent to your web browser and then sent back by the browser each time it accesses the server that sent the cookie. Some cookies are removed when you close your browser session. These are the “Session Cookies”. Some last for longer periods and are called “Persistent Cookies”. We use both types.
Some cookies are necessary for the Services to function properly, and cannot be declined or disabled unless you delete and block them through your web browser settings. Other cookies, which are used for functional, performance, analytics and marketing purposes, are optional. You may opt-in to or opt-out from the use of optional cookies through the “Cookie Settings” feature available on our website, depending on your location and activity on our Services, as applicable. If you choose to opt-out of certain cookies, this will typically generate a new cookie which will preserve your choice, and indicate it to our Services in your next visits so that the cookies you opted-out of will not be utilized. You can also manage your cookies preferences, and accept, remove or entirely block cookies, through your browser settings.
Please note that certain web browsers may transmit “Do Not Track” signals to websites with which the browser communicates, telling the website not to follow its online movements. Because of differences in how web browsers interpret this feature and send those signals, and lack of standardization, we currently do not respond to such “Do Not Track” signals.
We also use the web analytics tool Google Analytics. This tool helps us understand users’ behavior on our Services, including by tracking page content, and click/touch, movements, scrolls and keystroke activities. Further information about the privacy practices of our analytics service provider is available at: www.google.com/policies/privacy/partners. Further information about your option to opt-out of this analytics service is available at: https://tools.google.com/dlpage/gaoptout.
Please note that if you get a new device, install a new browser, erase or otherwise alter your browser’s cookie file (including upgrading certain browsers), you may also clear the opt-out cookies installed once you opt-out, so an additional opt-out will be necessary to prevent additional tracking.
Service Communications: Salt may contact you with important information regarding our Services. For example, we may notify you (through any of the means available to us) of changes or updates to our Services, billing issues,service maintenance or changes, password retrieval notices, etc. You will not be able to opt-out of receiving such service communications while using our Services, as they are integral to such use.
Notifications and Promotional Communications: We may send you notifications concerning new features, offerings, events, and special opportunities or any other information we think you will find valuable. We may provide such notices through any of the contacts means available to us (e.g.,phone, mobile or email), through the Services, or through our marketing campaigns on any other websites or platforms.
If you do not wish to receive such promotional communications, you may notify us at any time by sending an email to privacy@salt.security or by following the "unsubscribe", "stop" or "change email preferences" instructions contained in the promotional communications you receive.
Salt and its Service Providers implement systems,applications, and procedures 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,please be aware that regardless of any security measures used or implemented,we cannot and do not guarantee the absolute protection and security of any personal data stored with us or with any third parties.
Individuals have rights concerning their personal data. Please contact us by e-mail at: privacy@salt.security if you wish to exercise your privacy rights under any applicable law, including the EU or UK General Data Protection Regulation(GDPR), the Swiss Federal Act on Data Protection (FADP), or the CCPA as amended from time to time. Such rights may include, to the extent applicable, the right to know/request access to (specific pieces of personal data collected; categories of personal data collected; categories of sources from whom the personal data was collected; purpose of collecting personal data; categories of third parties with whom we have shared personal data), to request rectification or erasure of your personal data held with Salt, or to restrict or object to such personal data’s processing (including the right to direct us not to sell or share your personal data to third parties now or in the future, as described below), or to port such personal data, or the right to equal services and prices (e.g., freedom from discrimination) (each to the extent available to you under the laws which apply to you). If you are a GDPR-protected individual, you also have the right to lodge a complaint with the relevant supervisory authority in the EU or the UK, as applicable.
To the extent applicable to you, you may also designate an authorized agent, in writing or through a power of attorney, to request to exercise your privacy rights on your behalf. The authorized agent may submit a request to exercise these rights by emailing us.
When you or an authorized agent ask us to exercise any of your rights, we may need to ask you to provide us certain credentials to make sure that you are who you claim you are, to avoid disclosure to you of personal data related to others and to ask you to provide further information to better understand the nature and scope of data that you request to access. If your request relates to personal data contained in Customer Data (i.e., personal data we process on our Customer’s behalf as its “data processor” or “service provider”, as further explained in Section 10 below), such Customer exclusively determines how the data may be processed, as well as if and how your request should be handled. In such circumstances, we advise that you submit your request directly to them. We may not be able to fulfill your request unless you have provided sufficient information that enables us to reasonably verify that you are the individual about whom we collected the personal data, and if such data is processed on behalf of any of our Customers, to which Customer it particularly relates, so that we may forward it to them for their further handling. 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, or proof of request fulfillment).
We may redact from the data which we will make available to you, any personal data or confidential information related to others.
Certain data protection laws and regulations, such as the EU GDPR, UK GDPR, and CCPA, typically distinguish between two main roles for parties processing personal data: the “Data Controller” (or under the CCPA, the “Business”), who determines the purposes and means of processing; and the “Data Processor” (or under the CCPA, the “Service Provider”), who processes the data on behalf of the Data Controller. Below we explain how these roles apply to our Services, to the extent that such laws and regulations apply.
Salt is the “Data Controller” of its Visitors’, Partners’ and Users’ Personal Data. With respect to such data, we assume the responsibilities of Data Controller (solely to the extent applicable under law), as set forth in this Privacy Policy. In such instances, our Service Providers processing such data will assume the role of “data processor”.
Salt is the “Data Processor” of Customer Data. Such data is being processed by Salt on behalf of the Customer (who is the “Data Controller” of such data; and our Service Providers who process such Customer Data on our behalf are the “sub-processors” of such data). Accordingly, Salt processes Customer Data strictly in accordance with our Customer’s reasonable instructions and as further stipulated in our data processing addendum and commercial agreement with such Customer.
Our Customers are solely responsible for determining whether and how they wish to use our Services, and for ensuring that all individuals using the Services on the Customer’s behalf or at their request, as well as all individuals whose personal data may be included in Customer Data processed through the Services, have been provided with adequate notice and given informed consent to the processing of their personal data, where such consent is necessary or advised, and that all legal requirements applicable to the collection, recording, use or other processing of data through our Services are fully met by the Customer, including specifically in the context of an employment relationship. Our Customers are also responsible for handling data subject rights requests under applicable law, by their Users and other individuals whose data they process through the Services.
Under some US data protection laws, like the CCPA, our disclosure of certain internet activity and device information to third parties through cookies may be considered a “sale” or “sharing” of personal information. We do so in pursuit of the business and commercial purposes described in Section 2 above.
For the purposes of the CCPA, in the last 12 months we have"sold" or "shared" Internet or other electronic network activity information, Geolocation data, and Commercial information with our analytics and advertising partners and service providers. Salt has not knowingly sold or shared the personal information of individuals under the age of 16.
You may opt out of all Cookies that may result in a “sale” and/or“sharing” of your personal information in the following ways:
Please note: If you visit us from a different device or browser, or clear cookies, then you need to return to this screen to re-select your preferences.
Set the Global Privacy Control (GPC) for each participating browser system that you use to opt out of the use of third-party Advertising or other cookies (instructions on how to download and use GPC).
Updates and Amendments: We may update and amend this Privacy Policy from time to time by posting an amended version on our Services. The amended version will be effective as of the published date. 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 Services. After such notice period, all amendments to this Privacy Policy shall be deemed accepted by you.
External Links: While our Services may contain links or integrations to other websites, social networks or services, we are not responsible for their privacy practices, and encourage you to pay attention when you leave our Services for the website or services of such third parties,or interact with social network integrations. We recommend you read the privacy policies of each and every website and service you visit. This Privacy Policy only applies to our Services.
Children’s Privacy: Our Services are not intended for use by children under the age of 18. We do not knowingly collect personal data from minors under the age of 18 and do not wish to do so. In the event that it comes to our knowledge that a minor is using the Services, we will prohibit and block such user from accessing the Services (to the extent reasonably possible) and will make all efforts to promptly delete any personal data stored with us with regard to such user.
Representative: We value your privacy and your rights as a data subject and have therefore appointed Prighter Group with its local partners as our privacy representative and your point of contact for the following regions:
Prighter gives you an easy way to exercise your privacy-related rights (e.g., requests to access or erase personal data). If you want to contact us via our representative, Prighter or make use of your data subject rights, please visit the following website: https://prighter.com/q/15608475920.
Contacting Us: If you have any comments or questions about this Privacy Policy or if you have any concerns regarding your personal data held with us, please contact us at privacy@salt.security.