Privacy Policy

Securin, Inc. (“Securin) takes your privacy seriously. This is our official Privacy Statement, which was last updated on March 17th, 2022.

Securin, Inc. (the “Company,” “we,” or “us”) offers cyber risk management solutions by providing its customers information security services through cloud-based SaaS platforms in order to assess their cyber risk exposure. This Privacy Policy is made available to inform users of our practices regarding the kinds of information we collect, the use, disclosure and your options regarding the collection of personally identifiable information.

This Privacy Policy applies to Personal Information Processed by us in our business, including on our website at http://www.securin.io, https://app.securin.io, social media and blogs (“Sites”), and other online or offline offerings ( together with similar offerings the “Services”). All Individuals whose responsibilities include Processing Personal Information for us are expected to protect it by following this Privacy Policy.

By accessing our Sites, or purchasing our products or Services, you agree to this Privacy Policy in addition to any other agreements we might have with you. In the event that such agreements contain terms that conflict with this Privacy Policy, the terms of those agreements will prevail.

1. Our Collection of Personal Information

This Privacy Policy is made available to inform users of our practices regarding the kinds of information we collect, the use, disclosure and your options regarding the collection of personally identifiable information.

This Privacy Policy applies to Personal Information Processed by us in our business, including on our website at http://www.securin.io, https://app.securin.io, social media and blogs (“Sites”), and other online or offline offerings (together with similar offerings the “Services”). All Individuals whose responsibilities include Processing Personal Information for us are expected to protect it by following this Privacy Policy.

2. Our Use of your Personal Information

Our Company may use information that we collect about you for the following purposes:

To Provide Products, Services, or Information Requested. We may use information about you to:

  • Manage Individual information and accounts;
  • Respond to questions, comments, and other requests;
  • Provide access to certain areas, functionalities, and features of our Services;
  • Answer requests for customer or technical support; and
  • Allow you to register for events.

Administrative Purposes. We may use Personal Information about you to:

  • Measure interest and engagement in our Sites and Services;
  • Develop new products and Services;
  • Ensure internal quality control;
  • Verify Individual identity;
  • Communicate with you about your account, activities on our Sites and Services and policy changes;
  • Contact you to verify your account and for informational and operational purposes, such as account management, customer service, or system maintenance;
  • Process payment for products or Services purchased;
  • Process applications and transactions;
  • Prevent potentially prohibited or illegal activities; and
  • Enforce our Terms

Marketing Our Products and Services. We may use Personal Information to provide you with materials about offers, products, and Services that may be of interest, including new content or Services. We may provide you with these materials by phone, postal mail, facsimile, or email, as permitted by applicable law. Such uses include:

  • To tailor content, advertisements, and offers;
  • To notify you about offers, products, and services that may be of interest to you;
  • To provide Services to you and our sponsors; and
  • Other purposes you consent to or are disclosed when you provide Personal Information.

You may contact us at any time to opt out of the use of your Personal Information for marketing purposes as described below.

Research and Development. We may use Personal Information to create non-identifiable information that we may use alone or in the aggregate with information obtained from other sources, in order to help us to optimally deliver our products and Services or develop new products and Services. We may perform research via surveys. We may engage Third-Party service providers to conduct such surveys on our behalf. Survey responses are voluntary, and the information collected will be used for research and reporting purposes to help us better serve Individuals by learning more about their needs and the quality of the products and services we provide. The survey responses may be utilized to determine the effectiveness of our Sites and Services, various types of communications, advertising campaigns, and/or promotional activities. If an Individual participates in a survey, the information given will be used along with that of other study participants. We may use de-identified Individual and aggregated data for research and analysis purposes.

Direct Mail, Email and Outbound Telemarketing. Individuals who provide us with Personal Information, or whose Personal Information we obtain from Third Parties, may receive periodic emails, newsletters, mailings, or phone calls from us with information on our or our business partners’ products and services or upcoming special offers/events we believe may be of interest. We offer the option to decline these communications at no cost to the Individual by following the instructions below.

Services via Mobile Devices. We may provide Services that are specifically designed to be compatible and used on mobile devices. We will collect certain information that your mobile device sends when you use such Services, like a device identifier, user settings, location information, mobile carrier, and the operating system of your device. Mobile versions of our Services may require that users log in with an account. In such cases, information about use of mobile versions of the Services may be associated with accounts and other devices. In addition, we may enable Individuals to download an application, SDK, widget, or other tool that can be used on mobile or other computing devices. Some of these tools may store information on mobile or other devices. These tools may transmit Personal Information to us and Third Parties to enable you to access your account and Services and to enable us and Third Parties to track use of these tools. Some of these tools may enable users to email reports and other information from the tool. We may use personal or non-identifiable information transmitted to enhance these tools, to develop new tools, for quality improvement and as otherwise described in this Privacy Policy or in other notices we provide.

De-identified and Aggregated Information Use. We may use Personal Information and other information about you to create de-identified and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access our Sites and Services, or other analyses we create. De-identified and aggregated information is used for a variety of functions, including the measurement of visitors’ interest in and use of various portions or features of the Sites and Services. De-identified or aggregated information is not Personal Information, and we may use such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes. We may share this information within Securin and with Third Parties for our or their purposes in an anonymized or aggregated form that is designed to prevent anyone from identifying you.

Other Uses. Securin may use Personal Information for which we have a legitimate interest, such as direct marketing, individual or market research, anti-fraud protection, or any other purpose disclosed to you at the time you provide Personal Information or with your consent.

3. Cookies, Pixel Tags/Web Beacons, Analytics Information, and Interest-Based Advertising

Securin, as well as Third Parties that provide content, advertising, or other functionality on our Services, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through the Services. We use Technologies that are essentially small data files placed on your computer, tablet, mobile phone, or other devices (referred to collectively as a "device") that allow us to record certain pieces of information whenever you visit or interact with our Sites, services, applications, messaging, and tools, and to recognize you across devices.

Social Media Widgets. Our Sites include social media features, such as Facebook, LinkedIn and Twitter that might include features such as the ‘share this’ button, or interactive mini programs. These features may collect your IP address, which page you are visiting on our Sites, and may set a cookie to enable the feature to function properly. These social media features are either hosted by a third-party or hosted directly on our Sites. Your interactions with these features are governed by the Privacy Policy of the company providing it.

Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded on the Sites that collects information about users’ engagement on that web page. The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement.

Analytics. We use Zoho, Hubspot, Google Analytics, and similar technologies for tracking visitor behavior. These technologies are used in analyzing trends, administering the Sites, tracking users’ movements around the Sites, and gathering demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/. You can opt out of Google’s collection and Processing of data generated by your use of the Services by going to http://tools.google.com/dlpage/gaoptout.

Cookies. Like many websites, we use cookie technology to collect additional website usage data and to improve the Sites and our service. A cookie is a small data file that we transfer to your computer’s hard disk. IP addresses are collected by the use of cookies.

Our uses of such Technologies fall into the following general categories:

Operationally Necessary. We may use cookies, web beacons, or other similar technologies that are necessary to the operation of our Sites, services, applications, and tools. This includes technologies that allow you access to our Sites, services, applications, and tools; that are required to identify irregular site behavior, prevent fraudulent activity and improve security; or that allow you to make use of our functions such as shopping-carts, saved search, or similar functions.

Performance Related. We may use cookies, web beacons, or other similar technologies to assess the performance of our Sites, applications, services, and tools, including as part of our analytic practices to help us understand how our visitors use our Sites, determine if you have interacted with our messaging, determine whether you have viewed an item or link, or to improve our Sites content, applications, services, or tools.

Functionality Related. We may use cookies, web beacons, or other similar technologies that allow us to offer you enhanced functionality when accessing or using our Sites, services, applications, or tools. This may include identifying you when you sign into our Sites or keeping track of your specified preferences, interests, or past items viewed so that we may enhance the presentation of content on our Sites.

Advertising or Targeting Related. We may use first-party or third-party cookies and web beacons to deliver content, including ads relevant to your interests, on our Sites or on third party sites. This includes using technologies to understand the usefulness to you of the advertisements and content that has been delivered to you, such as whether you have clicked on an advertisement.

If you would like to opt-out of the technologies we employ on our Sites, Services, applications, or tools, you may do so by blocking, deleting, or disabling them as your browser or device permits.

Third Party Websites, Social Media Platforms, and Software Development Kits

Our Sites contain links to other websites and media publications. The fact that we link to a website is not an endorsement, authorization, or representation of our affiliation with that third-party. We do not exercise control over third-party websites. These other websites may place their own cookies or other files on your computer, collect data, or solicit personal information from you. This Privacy Policy addresses the use and disclosure of information that we collect from you through the Sites. Other sites follow different rules regarding the use or disclosure of the personal information you submit to them. We encourage you to read the privacy policies or statements of the other websites you visit.

4. Our Disclosure of your Personal Information to Third Parties

Except as set forth in this Privacy Policy, Securin will not share your personally identifiable information with third parties.

Information We Share

Resellers and Partners. We will share your personally identifiable information with our resellers and partners, and such resellers and partners may use your information to market our products and services, as well as their own products and services.

Service Providers. We may engage certain trusted third parties to perform functions and provide services to us, including, without limitation, hosting and maintenance services, customer relationship services, and database storage and management services. We will share your personally identifiable information with these third parties, but only to the extent necessary to perform these functions and provide such services, and only pursuant to binding contractual obligations requiring such third parties to maintain the confidentiality of your data.

Compliance with Laws and Law Enforcement. Securin cooperates with government and law enforcement officials or private parties to enforce and comply with the law. We may disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including subpoenas); to protect the property and rights of Securin or a third-party, the safety of the public or any person; to prevent or stop any illegal, unethical, or legally actionable activity; or to comply with the law.

Business Transfers. If any or all of the assets of Securin are acquired by, or merged with another entity, we may share some or all of your information with this entity.

International Data Transfers
You agree that all Personal Information collected under this Privacy Policy may be transferred, Processed, and stored anywhere in the world, including but not limited to, the United States. Personal Information may be stored in the cloud, on our servers, on the servers of our affiliates or the servers of our service providers. By providing information to us, you explicitly consent to the storage of your Personal Information in these locations.

Potential for Other Users to Contact You
To the extent that a given application supports personal messaging functionality between and among end users, you may receive personal messages from other end users. You can disable this functionality by using the “unsubscribe” or other disabling instructions in the given application.

5. Your Choices: Right to Object to Processing

General: You have the right to object to and change your preferences or opt out of certain uses and disclosures of your Personal Information. Where you have consented to Securin’s Processing of your Personal Information or Sensitive Personal Information, you may withdraw that consent at any time and prevent further Processing by contacting us as described below. Even if you opt out, we may still collect and use non-Personal Information regarding your activities on our Sites, Services and/or information from the advertisements on Third-Party websites for other legal purposes as described above.

Email and Telephone Communications: If you receive an unwanted email from us, you can send a message to privacy@securin.io to opt out of receiving future emails.

We will process your request within a reasonable time after receipt. Note that you will continue to receive transaction-related emails regarding products or Services you have requested. We may also send you certain non-promotional communications regarding us and our Services, and you will not be able to opt out of those communications (e.g., communications regarding the Services or updates to our Terms or this Privacy Policy).

We maintain telephone “do-not-call” and “do-not-mail” lists as mandated by law: We process requests to be placed on do-not-mail, do-not-phone and do-not-contact lists within 60 days after receipt, or such shorter time as may be required by law.

Notifications: We may occasionally send you push notifications or contact you through our mobile applications, Services, Sites, social media or Third-Party services with notices or alerts that may be of interest to you. You may at any time opt out or stop from receiving these types of communications by changing the settings on your mobile device.

“Do Not Track”: Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.

Cookies and Interest-Based Advertising: As noted above, you may stop or restrict the placement of cookies on your computer or remove them from your browser by adjusting your web browser preferences. Please note that cookie-based opt-outs are not effective on mobile applications. However, on many mobile devices, application users may limit ad tracking of certain mobile ads via their device settings.

The online advertising industry also provides websites from which you may opt out of receiving targeted ads from our data partners and our other advertising partners that participate in self-regulatory programs. You can access these, and also learn more about targeted advertising and consumer choice and privacy, at http://www.networkadvertising.org/managing/opt_out.asp, or http://www.youronlinechoices.eu/ and www.aboutads.info/choices/. You can also choose not to be included in Google Analytics here.

To be clear, these cookie-based opt-outs must be performed on each device and browser that you wish to have opted-out. You must separately opt out in each browser on each device. Advertisements on Third-Party websites that contain the AdChoices link and that link to this Privacy Policy may have been directed to you based on information collected by advertising partners over time and across websites. These advertisements provide a mechanism to opt out of the advertising partners’ use of this information for interest-based advertising purposes.

6. Rights of Access, Rectification, Erasure and Restriction

You may inquire as to whether we are Processing Personal Information about you, request access to Personal Information, and ask that we correct, amend or delete your Personal Information where it is inaccurate. Where otherwise permitted by applicable law, you may send an email to us or use any of the methods set out in this Privacy Policy to request access to, receive (port), seek rectification, or request erasure of Personal Information held about you by Securin. Please include your full name, email address associated with your account, and a detailed description of your data request or follow the information provided on the Sites or Services. Such requests will be processed in line with local laws.

Although Securin makes good faith efforts to provide Individuals with access to their Personal Information, there may be circumstances in which Securin is unable to provide access, including but not limited to: where the information contains legal privilege, would compromise others’ privacy or other legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to the Individual’s privacy in the case in question or where it is commercially proprietary. If Securin determines that access should be restricted in any particular instance, we will provide you with an explanation of why that determination has been made and a contact point for any further inquiries. To protect your privacy, Securin will take commercially reasonable steps to verify your identity before granting access to or making any changes to your Personal Information.

7. Retention and Security

Data Retention
Securin will retain Personal Information for as long as needed to provide Services or as otherwise permitted by law.

Security of Your Information
Securin is very concerned about safeguarding the confidentiality of your personally identifiable information. We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security.

However, Securin takes security very seriously. All company employees are contractually obligated to safeguard Securin and user data under confidentiality and privacy agreements. Access to Securin production systems is restricted to authorized Securin team members.

We will disclose any breach of the security, confidentiality, or integrity of your unencrypted electronically stored personal data to you as required by contract in the most expedient time possible and without unreasonable delay, consistent with (i) the legitimate needs of law enforcement, or (ii) any measures necessary to determine the scope of the breach and to restore the reasonable integrity of the data system.

8. Users Outside the United States

Securin is headquartered in the United States and is subject to the applicable state and federal laws of the United States. By using our Sites, you will transfer data to the United States. By choosing to visit our Sites, utilize the Services or otherwise provide information to us, you agree that any dispute over privacy or the terms contained in this Policy will be governed by the laws of the State of New Mexico and the adjudication of any disputes arising in connection with Securin or our Sites will be in accordance with the Terms.

If you are visiting from the European Union or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your information to the United States and processing globally. By providing your Personal Information, you consent to any transfer and processing in accordance with this Policy.

9. Our Policy Towards Children

The Sites are not directed to persons under the age of 18 and we do not knowingly request or receive any information from children under the age of 18. If a parent or guardian becomes aware that his or her child has provided us with personally identifiable information without their consent, he or she should contact us at privacy@securin.io. If we become aware that a child under 18 has provided us with personally identifiable information, we will remove such information from our files.

10. Legal Basis for Processing your Personal Data (EEA and Switzerland only)

With respect to personal data collected from individuals from the European Economic Area or Switzerland, our legal basis for collecting and using the personal data will depend on the personal data concerned and the specific context in which we collect it. Our Company will normally collect personal data from you only where: (a) we have your consent to do so, (b) where we need the personal data to perform a contract with you (e.g. to deliver the services you have requested), or (c) where the processing is in our or a third party’s legitimate interests (and not overridden by your data protection interests or fundamental rights and freedoms).

11. Additional Rights (EEA and Switzerland only)

If you reside in the European Economic Area or Switzerland, you may have the right to exercise additional rights available to you under applicable laws, including:

Right of erasure. You may have a broader right to erasure of personal data that we hold about you. For example, if it is no longer necessary in relation to the purposes for which it was originally collected. Please note, however, that we may need to retain certain information for record keeping purposes, to complete transactions or to comply with our legal obligations, among other things.

Right to object to processing. You may have the right to request that we stop processing your personal data or to stop sending you marketing communications.

Right to restrict processing. You may have the right to request that we restrict processing of your personal data in certain circumstances. For example, where you believe that the personal data we hold about you is inaccurate or unlawfully held.

Right to data portability: In certain circumstances, you may have the right to be provided with your personal data in a structured, machine readable and commonly used format and to request that we transfer the personal data to another data controller without hindrance.

If you would like to exercise any of the above rights, please contact our support team or contact our Data Protection Officer at privacy@securin.io. We will consider your request in accordance with applicable laws. To protect your privacy and security, we may take steps to verify your identity before complying with the request.

You may also have the right to make a privacy complaint to the relevant Supervisory Authority. A list of Supervisory Authorities is available here:
http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

If you need further assistance regarding your rights, please contact us using the contact information provided below and we will consider your request in accordance with applicable law. In some cases, our ability to uphold these rights for you may depend upon our obligations to process personal data for security, safety, fraud prevention reasons, compliance with regulatory or legal requirements, or because processing is necessary to deliver the Services you have requested. Where this is the case, we will inform you of specific details in response to your request.

12. California Privacy Rights

Our Company does not currently respond to browser “Do Not Track” (DNT) signals or other mechanisms. Third parties may collect personal data about your online activities over time and across sites when you visit the Sites or use the Services.

If you are a California resident, California Civil Code Section 1798.83 permits you to request certain information regarding our disclosure of personal data to third parties for the third parties’ direct marketing purposes. To make such a request, please contact us by sending an e-mail to privacy@securin.io.

Our Sites, products, and Services are not intended to appeal to minors. However, if you are a California resident under the age of 18, and a registered user of our Sites or Services, California Business and Professions Code Section 22581 permits you to request and obtain removal of content or information you have publicly posted. To make such a request, please send an email with a detailed description of the specific content or information to privacy@securin.io.

Please be aware that such a request does not ensure complete or comprehensive removal of the content or information you have posted and that there may be circumstances in which the law does not require or allow removal even if requested.

Under California law, California residents who have an established business relationship with us may opt-out of disclosing personal data about them to third parties for their marketing purposes.

13. Changes

This Privacy Policy may be updated from time to time for any reason. If we make any substantial changes in the way we use your personal information we will make that information available by posting a notice on this website, prior to becoming in effect. Therefore, we suggest that you consult this Privacy Policy regularly for any changes. Continued use of the Sites after we have notified you of any such changes shall constitute your consent to such changes.

14. Terms of Service

This Privacy Policy is incorporated by reference into the Securin Terms of Service (the “Terms”).

15. Redress/Compliance and Accountability

If you have any questions about our privacy practices, this Privacy Policy, or how to lodge a complaint with the appropriate authority, please contact us. We will address your concerns and attempt to resolve any privacy issues in a timely manner.

16. Questions and Comments

If you would like to contact us about our privacy practices, or exercise any of your data subject rights, please send a written request to the data controller of your Personal Information or to us at:

Email: privacy@securin.io

Mail: Securin, Inc.

Attn: Privacy Officer

2440 Louisiana Blvd NE Suite 560

Albuquerque, NM 87110

Definitions

The following capitalized terms shall have the meanings herein as set forth below.

“Sites” are our company website www.securin.io, social media pages, blogs and content produced and managed online by Securin.

“Services” are all other online and offline offerings by Securin.

“Agent” means any Third Party that Processes Personal Information pursuant to the instructions of, and solely for, Securin or to which Securin discloses Personal Information for use on its behalf.

“Employee” refers to any current, temporary, permanent, prospective or former employee, director, contractor, worker, or retiree of Securin or its subsidiaries worldwide.

“Personal Information” is any information relating to an identified or identifiable natural person (“Individual”).

“Process” or “Processing” means any operation which is performed upon Personal Information, whether or not by automatic means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.

“Sensitive Data” or “Sensitive Personal Information” is a subset of Personal Information which, due to its nature, has been classified by law or by policy as deserving additional privacy and security protections. Sensitive Personal Information includes Personal Information regarding EU residents that is classified as a “Special Category of Personal Data” under EU law, which consists of the following data elements: (1) race or ethnic origin; (2) political opinions; (3) religious or philosophical beliefs; (4) trade union membership; (5) genetic data; (6) biometric data where Processed to uniquely identify a person; (6) health information; (7) sexual orientation or information about the Individual’s sex life; or (8) information relating to the commission of a criminal offense.

“Third Party” is any company, natural or legal person, public authority, agency, or body other than the Individual, Securin or Securin’s agents.

Last Updated: March 10th, 2022