Safer Web Privacy Policy

Thanks for using Safer Web. Here we describe how Reason Cybersecurity Ltd. collects, uses and handles your information when you use the Safer Web applications (including both the desktop and mobile versions) (the "Software" or "Safer Web"). Your use of Safer Web is indicating that such updated terms and conditions are accepted and agreed by you.

This Privacy Policy is incorporated into and is subject to the Terms of Service ("Terms"): https://www.reasonlabs.com/platform/products/safer-web/terms.

Please note that you are not legally required to provide us with any personal data, and may do so (or avoid doing so) at your own discretion. If you wish not to accept these terms and conditions or any update thereto, or you do not wish to provide us with your personal data, or to have it processed by us or any of our service providers your only recourse is not to download or use the Software and uninstall it. As we may make available certain content, software or services of third parties, it is clarified that such content, software and services are not covered by this Privacy Policy. Any use or download of the Software by you, is indicating that you consent to our use of your information in accordance with this Privacy Policy.

Please note that in the event that you ask us to exercise any of your rights under this Privacy Policy or any applicable law, we may ask you to (i) provide us with certain credentials to make sure that you are the person you claim you are; (ii) provide us with further information, so we can understand the nature and scope of the information you request to access, and avoid the disclosure of personal information related to others. We will retain such additional information for legal purposes (e.g., as proof of the identity of the person submitting the request).

1. What kind of information do we use and collect?

1. When using Safer Web, we may use and collect information of technical nature, including your IP address, activity log of your use of the Software (such as time and date of certain events related to the Software, including launching and scanning, updating and uninstalling the Software, and the features of the Software you use the most), user agent, information about your operating system, browser type and version. In addition, when purchasing the Software, your email address and name, as provided by you, will be collected by us and will be used by our third party service providers for processing payments, and by us for sending you messages about Safer Web, if applicable, and for promotional purposes.
2. We use technologies like cookies and pixel tags to provide, improve, protect and promote our services. For example, cookies help us with things like understanding how you are interacting with our services, and improving them based on that information. You can set your browser to not accept cookies.

2. How we use the collected information

We use the information collected from you as necessary for the performance and facilitation of our Software, including for the following purposes:

1. To provide, support and operate the Software as well as to further develop, enhance and improve our Software and your user experience with our Software.
2. To communicate with you, including for support purposes, and for sending you Software- related information such as invoices, updates, security alerts.
3. To comply with applicable legal obligations.
4. To detect and prevent fraud, security and other issues of technical nature.
5. We may also use or share your information to operate our business, including for debugging, support, security, billing and auditing, business analysis and improving our Software (as more fully described in Section 3 below).

3. How do we share information?

1. If we have a good faith belief that disclosure is permitted by law or is reasonably required to: (i) comply with any law, regulation or legal requirement by any court or regulatory or governmental authority, or such other disclosures reasonable required to establish, protect, maintain or exercise our legal rights; or (ii) enforce this Privacy Policy or any agreement between you and us.

2. In the event of a merger, acquisition, reorganization or sale of assets, your information may be transferred or sold.

3. Third Parties. We may engage certain third parties in connection with maintenance, analysis, audit, payment and development services. We may provide such third parties with your information. The third parties we are currently engaging are:

   • NextDNS, as the DNS resolver providing the DNS services. You can read about NextDNS’s practices with respect to the protection of your information at: https://nextdns.io/privacy. Please note that by default, NextDNS stores statistical usage data based on the last three (3) months of use. You can customize that value via the Statistics tab included in the Safer Web;
   • Google Analytics, to analyze and monitor our performance. Google’s privacy policy is available at: http://www.google.com/intl/en/policies/privacy;
   • Amazon Web Services, Inc. servers to process your information. You can read about the measures taken by Amazon to protect the security of their servers and your information at: https://aws.amazon.com/security/;
   • Zendesk, to provide you with support services. Zendesk’s privacy policy is available at: https://www.zendesk.com/company/customers-partners/privacy-policy;
   • SendGrid, for providing us with email and marketing services. SendGrid’s privacy policy is available at: https://www.twilio.com/legal/privacy;
   • MixPanel, to analyze and monitor our performance. You can read about MixPanel practices with respect to the protection and the security of their servers and your information at: https://mixpanel.com/legal/privacy-policy;
   • Tableau, to help us organize our data. You can read about Tableau practices with respect to the protection and the security of their servers and your information at: https://www.salesforce.com/company/privacy/;
   • Iterable, to provide you with updates and information. You can read about Iterable’s practices with respect to the protection and the security of their servers and your information at: https://iterable.com/trust/privacy-policy/;
   • Microsoft Advertising, to promote our products. Microsoft Advertising’s privacy policy is available at https://privacy.microsoft.com/en-us/;
   • Google Ads, to promote our products. Google Ads’s privacy policy is available at: https://policies.google.com/privacy;
   • Facebook Ads, to promote our products. Facebook Ads’s privacy policy is available at: https://www.facebook.com/about/basics/;
   • Verizon Media Native, to promote our products. Verizon Media Native’s privacy policy is available at: https://www.verizonmedia.com/policies/us/en/verizonmedia/privacy/index.html;
   • TeamViewer, solely for providing remote support access services. TeamViewer privacy notice is available at: https://www.teamviewer.com/en/privacy-notice/;
   • Appsflyer, to help us manage and track our campaigns. You can read about Appsflyer practices with respect to the protection and the security of their servers and your information at: https://www.appsflyer.com/legal/privacy-policy/;
   • Hotjar, to analyze and monitor our performance. You can read about Hotjar practices with respect to the protection and the security of their servers and your information at: https://www.hotjar.com/legal/policies/privacy/;
   • TikTok, to promote our products. You can read about TikTok practices with respect to the protection and the security of their servers and your information at: https://www.tiktok.com/legal/page/row/privacy-policy/en;
   • Databricks, to provide us with server data management. Databricks privacy notice is available at: https://www.databricks.com/legal/privacynotice;
   • Vercel, to provide hosting services. Vercel privacy policy is available at: https://vercel.com/legal/privacy-policy;
   • Coralogix, to monitor our servers. Coralogix privacy policy is available at: https://coralogix.com/privacy-policy/;
   • Sentry.io, to monitor our frontend. Sentry.io privacy policy is available at: https://sentry.io/privacy/.

   Payment Processors. If you choose to use our premium edition, we will use a third- party payment processor/provider (the “Payment Processor(s)”) in order to collect your payment. The Payment Processors are authorized and regulated to handle your payment details and may not use your personal information for any purposes other than providing you with these services. Please note that the Payment Processors are independent controllers of your data, and will process your payment information in accordance with the applicable Payment Processor’s privacy policy. Please note that the Payment Processor may (as applicable) save and reuse your payment details for subsequent payments, in the event of a recurring transaction. The Payment Processors we are currently engaging are:

   Payment Processor/Provider	Privacy Policy
   Cleverbridge	https://store.reasonsecurity.com/1679/?scope=opprivacy
   Stripe	https://stripe.com/privacy
   Paypal	https://www.paypal.com/us/legalhub/privacy-full

4. With our corporate affiliates - from which we receive services, such as IT, security, storage, and other internal operations.

5. To detect and prevent fraud, security and other issues of technical nature.

6. To protect our rights as well as the rights of our users.

4. Children

We do not knowingly collect or maintain personal information collected online from children under the age of 13, except to the extent that the U.S. Children’s Online Privacy Protection Act permits us to collect and maintain such information without parental consent. If you believe your child has provided us with personal information that is covered by the U.S. Children’s Online Privacy Protection Act without your required consent, please contact us at https://reasonlabs.com/contact-us and we will make reasonable efforts to delete the information from our records. Our services may link to other websites. Please be advised that we are not responsible for the privacy practices of such other websites as those may have different privacy policies and terms of use and are not associated with us. You agree that we cannot control these websites and we will not be responsible for any use of such websites.

5. Data Subject Rights

If you wish to exercise your privacy rights under any applicable law, including the EU or UK General Data Protection Regulation (collectively, the “GDPR”), the Swiss Federal Act on Data Protection (the “FDPA”), the California Consumer Privacy Act (the “CCPA”), the California Privacy Rights Act (the “CPRA”), the Virginia Consumer Data Protection Act (the “VCDPA”), the Utah Consumer Privacy Act, Utah Code Ann. §13-61 ("UCPA"), the Connecticut Personal Data Privacy and Online Monitoring Act § 42-518 ("CTDPA"), or the Colorado Privacy Act Code § 6-1-1301 (2022) ("CPA"), please send us an email to: support@reasonlabs.com. We will make reasonable efforts to accommodate your request, as applicable to privacy laws. Please note that we may ask for additional information, in order to authenticate and validate your identity and process your request (including personal data).

You may have different privacy rights, depending on your country or state of residence, please see further details in the sub-sections below (as applicable to you):

1. European Economic Area (“EEA”) and United Kingdom (“UK”) and Switzerland:

If you are located in the EEA, UK or Switzerland, the GDPR or FDPA (as applicable) apply to you.

We act as controllers and process personal information as necessary for the performance of our agreement with you.

When we process your personal information upon your usage of our Software, we do so on the basis of your consent. Providing such personal information and using our Software, as well as your acceptance of this Privacy Policy and our TOS, shall be deemed as your consent to the processing of your personal information for all purposes detailed under this Privacy Policy. If you wish to revoke your consent, please contact us at support@reasonlabs.com.

We may also process your personal information to comply with applicable legal requirements and/or obligations, and to support our legitimate interests in developing, maintaining, and improving our Software.

Please note that under the GDPR or FDPA you may have the following rights (each, to the extent available under the law which applies to you):

1. Right to Access: You have the right to request access to the personal information that we hold about you.

2. Right to Receive Information: You have the right to receive information concerning the processing of your personal information.

3. Right to Block: You have the right to request to block or restrict the processing of your personal information.

4. Right to Erasure (Deletion): You have the right to ask that we erase (the “right to be forgotten”) and rectify your personal information (that we process as controllers).

5. Right to Object: You have the right to object to processing, which is based on our legitimate interests.

6. Right to Withdraw Your Consent: You have the right to withdraw your consent for the processing of your personal information.

   To submit a request for exercising your rights, please contact us at the following address: support@reasonlabs.com. Note that the processing of your request is subject to verification of your identity.

   If we have not addressed your concerns, note that you also have a right to file a complaint with the applicable supervisory authority (e.g., of your domicile or country).

7. United States of America:

If you are a resident of California/Virginia/Utah/Connecticut/Colorado, the CCPA, CPRA, VCDPA, UCPA, CTDPA or CPA (and/or similar state laws, as applicable) apply to you, and this section explains your rights under State privacy laws and contains disclosures required by law.

For the purposes hereof, we collect personal information as a business (as defined under applicable privacy state laws). Such information is used and disclosed for “business purposes”.

Please note that under the CCPA, CPRA, VCDPA, UCPA, CTDPA or CPA (and/or similar state laws, as applicable) you may the following rights (each, to the extent available under the law which applies to you):

1. Right to Know: You have the right to know the categories and specific pieces of personal information that are being collected about you.

2. Right to Disclose: You have the right to ask that we disclose certain information about our collection and/or use of your personal information during the past 12 months.

3. Right to Delete: You have the right to ask that we delete the personal information we have collected from you and retained.

4. Right to Opt-Out: You have the right to opt out of the 'sale' of your personal information by a business.

5. Right to Equal Service and Price: You have the right not to receive discriminatory treatment for exercising the mentioned rights.

   To submit a request for exercising your rights, please contact us at the following address: Support@reasonlabs.com. Note that the processing of your request is subject to verification of your identity. You may also appoint an authorized agent to exercise these privacy rights on your behalf (subject to certain limitations such as identity verification process and the submission of written approval to act on your behalf).

   This Privacy Policy describes what Personal Information we may collect and its sources, how it is deleted and retained. Furthermore, we have provided information about our processing of your information. Note that we may share (as such term is defined under the CPRA) information with third parties such as business partners who have accepted our contractual limitations as to their disclosure, use, and retention of such personal information. Nevertheless, for the purposes and intents of the CCPA or CPRA, we do not sell your personal information.

6. Retention of Personal Information

We will store information collected from you for as long as you are using our Software. If you decide to uninstall the Software, your data will be retained for an additional period of 30 days, following which, it will be deidentified.

7. How can we modify this Privacy Policy?

We may revise this Privacy Policy from time to time, and will post the most current version on our website. Accordingly, please visit this Privacy Policy regularly to check for any changes.

8. How can you contact us?

If you have any questions, comments or concerns regarding this Privacy Policy and/or our practices, please send an e-mail to https://reasonlabs.com/contact-us.

9. Representative for Data Subjects

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:

• United Kingdom (UK)
• European Union (EU)
• Switzerland

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/12015696620.