This document was last updated March 31, 2020.

At Spirion, we’re committed to protecting your privacy and to developing technology that gives you the most powerful and secure online experience. You can travel through most of our site without giving us any information about yourself. However, sometimes we do need information to provide services that you request, and this statement of privacy explains data collection and use in those situations.

Collecting your Personal Information

We will ask you when we need information that personally identifies you (personal information) or allows us to contact you. Generally, this information is requested when you generate a key, or when purchasing and registering Spirion products. Personal information collected by spirion.com often is limited to email address, billing name, address, sometimes IP or NetBIOS address, and credit card for purchases, but may include other information when needed to provide a service you requested. When you buy and install a new product, we may ask you to register your purchase electronically. When you do, we keep this registration information on file with any information you’ve already given us on previous visits to our website. This is considered your personal profile.

Use of your Personal Information

We use your personal information for three primary purposes:

  • To help us create keys and deliver licenses to you.
  • To alert you to product upgrades, special offers, updated information and other new services from Spirion.
  • To share articles, event announcements, invitations to webinars, and other relevant cybersecurity insights from Spirion.

We occasionally hire other companies to provide limited services on our behalf, including packaging, mailing and delivering purchases, answering customer questions about products or services, sending postal mail, and processing event registration. We will only provide those companies the information they need to deliver the service, and they are prohibited from using that information for any other purpose. Your IP address will never be disclosed to them.

Spirion will disclose your personal information, without notice, only if required to do so by law or in the good faith belief that such action is necessary to: (a) conform to the edicts of the law or comply with legal process served on Spirion or the site; (b) protect and defend the rights or property of Spirion and its family of websites, and, (c) act in urgent circumstances to protect the personal safety of users of Spirion, its websites, or the public.

Control of your Personal Information

When you register, or otherwise give us personal information, Spirion will not share that information with third parties without your permission, other than for the limited exceptions already listed. It will only be used for the purposes stated above.

Spirion may send out periodic emails informing you of technical service issues related to a product or service you requested. You will not be able to choose to unsubscribe to these mailings, as they are considered an essential part of the service you have chosen.

Spirion may send periodic informational or promotional content. However, you can always unsubscribe or choose not to receive promotional information from us by following the specific instructions in the email you receive or by notifying us via the appropriate method below. It may take a reasonable period of time to process your request, no longer than 30 days for direct mail and telephone promotions and 10 business days for email promotions. This will not apply to the receipt of mandatory service communications that are considered part of certain Spirion services, which you may receive periodically unless you cancel the service.

Security of your Personal Information

Spirion strictly protects the security of your personal information and honors your choices for its intended use. We carefully protect your data from loss, misuse, unauthorized access or disclosure, alteration, or destruction.

Your personal information is never shared outside the company without your permission, except under conditions explained above. Inside the company, data is stored in password-controlled servers with limited access. Your information may be stored and processed in the United States or any other country where Spirion, its subsidiaries, affiliates, or agents are located.

You also have a significant role in protecting your information. No one can see or edit your personal information.

Protection of Children’s Personal Information

The spirion.com site does not publish content that is targeted to children.

Use of Cookies

To ensure we are publishing content customers need and want, Spirion might collect aggregated site-visitation statistics using cookies. We do not track individuals’ use of the site. When someone visits the site, a cookie might be placed on the customer’s machine (if the customer accepts cookies) or is read if the customer has visited the site previously. Web beacons, also known as clear gif technology, or action tags, assist in delivering the cookie. This technology tells us how many visitors clicked on key elements (such as links or graphics) on a spirion.com webpage. We do not use this technology to access your personally identifiable information on spirion.com; it is a tool we use to compile aggregated statistics about spirion.com website usage. We do not share tracking information outside of Spirion, and do not allow other companies to place clear gifs on our sites. If you choose to not have your browser accept cookies from the spirion.com website, you will be able to view the text on the screens, however you will not experience a personalized visit nor will you be able to subscribe to the service offerings on the site.

Changes to this Statement

Spirion will occasionally update this privacy statement. When we do, we will also revise the “last updated” date at the top of the privacy statement. For material changes to this Statement, Spirion will notify you by placing prominent notice on the website.

Compliance with the EU General Data Protection Regulation (GDPR)

In addition to the notice provided above, the following notice applies to EU data subjects. In the event there is a conflict between the two as it applies to EU data subjects, this section shall take precedence. For purposes of this Section, the term “Personal Data” shall have the meaning given by Regulation (EU) 2016/679.

The Types of Personal Data That We Collect

  • Identity: first name, last name, role
  • Contact information: email, phone, and sometimes billing address
  • Free trial, Resource download, Contact Us: company name, company HQ
  • Contact Us: message correspondence
  • Usage information: what resources you download, webinars you attend, emails you open, forms you fill out
  • Marketing: such as your preferences for receiving marketing communications and details about how you engage with us
  • Cookies. We use cookies as described above in Use of Cookies. We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them)

For users of Spirion’s Customer Portal, we collect the following information:

  • Training completed
  • Material reviewed or downloaded
  • Information posted on the forum
  • Information you post on the forum
  • Support tickets that you submit
  • Any information they provide on their profile, which can include name, email address, job title, image, phone, and brief bio
  • Forum posts and replies

Purposes for the Processing of Personal Data; Legal Basis

We process your Personal Data on the following legal bases, and for the following purposes:

  • To help us create keys and deliver licenses to you.
  • To alert you to product upgrades, special offers, updated information and other new services from Spirion.
  • To share articles, event announcements, invitations to webinars, and other relevant cybersecurity insights from Spirion.
  • With respect to the use of cookies and other similar technologies, based on your consent and/or opt-out mechanisms as required by Directive 2002/58/EC and any successor legislation;
  • For purposes disclosed at the time you provide your Personal Data or otherwise with your consent;
  • To comply with our legal obligations.

We do not use your Personal Data for any automated decision making covered by Articles 22(1) and (4) of Regulation (EU) 2016/679.

Recipients of Personal Data

We disclose the above-referenced categories of personal information to our service providers as described above in Use of your Personal Information or below in Transfer of Personal Data to an External Country; Appropriate Safeguards.

Transfer of Personal Data to an External Country; Appropriate Safeguards

Personal Data collected by Spirion may be stored or processed in the United States or in any other country where Spirion or its affiliates, subsidiaries, or external party service providers maintain facilities. EU data subjects who provide Personal Data to Spirion acknowledge the processing and transfer of that data to the United States and around the world. Spirion will execute agreements with external parties for the transfer of personal data outside of the European Economic Area (EEA). These agreements may use European Commission-approved Standard Contract Clauses and/or employ additional or alternative appropriate safeguards.

Compliance with the California Consumer Privacy Act (CCPA)

In addition to the notice provided above, the following notice applies to California residents.  In the event there is a conflict between the two as it applies to California residents, this section shall take precedence. For purposes of this Section, the term “Personal Information” shall have the meaning given in Cal. Civ. Code §1798.100, et seq.

We have collected the following personal information from our users over the past 12 months. What information we collect varies depending on how you interact with us and our services:

  • Identity: first name, last name, role
  • Contact information: email, phone, and sometimes billing address
  • Free trial, Resource download, Contact Us: company name, company HQ
  • Contact Us: message correspondence
  • Usage information: what resources you download, webinars you attend, emails you open, forms you fill out
  • Marketing: such as your preferences for receiving marketing communications and details about how you engage with us
  • Cookies. We use cookies as described above in Use of Cookies. We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them)

For users of Spirion’s Customer Portal, we collect the following information:

  • Training completed
  • Material reviewed or downloaded
  • Information posted on the forum
  • Information you post on the forum
  • Support tickets that you submit
  • Any information they provide on their profile, which can include name, email address, job title, image, phone, and brief bio
  • Forum posts and replies

 

  • How do we use the personal information we collect?We use the above-referenced categories of personal information for our business and commercial purposes as described above in Use of your Personal Information.
  • What categories of sources do we collect your personal information from?We collect the above-referenced categories of personal information directly from you.
  • What categories of other parties do we share your personal information with?We disclose the above-referenced categories of personal information to our service providers as described above in Use of your Personal Information or in Transfer of Personal Data to an External Country; Appropriate Safeguards.

We do not sell the personal information of California residents and we have not engaged in any sales in the last 12 months.

Contact Information

Spirion welcomes your comments, questions, and concerns regarding this Statement of Privacy. Please contact our Privacy team by email at privacy@spirion.com.