April 30 2010
At ThreatSTOP we recognize that privacy is important. This Policy applies to all of the products, services and websites offered by ThreatSTOP Inc. or its subsidiaries or affiliated companies (collectively, ThreatSTOP's "services"). In addition, where more detailed information is needed to explain our privacy practices, we post separate privacy notices to describe how particular services process personal information, which are accessible from the navigation bar to the left of this notice.
ThreatSTOP adheres to the US safe harbor privacy principles of Notice, Choice, Onward Transfer, Security, Data Integrity, Access and Enforcement, and is registered with the U.S. Department of Commerce's safe harbor program.
If you have any questions about this Policy, please feel free to contact us through our website or write to us at Privacy Matters, c/o ThreatSTOP Inc., 701 Palomar Airport Road, Suite 300, Carlsbad, CA 92011, USA.
In order to provide our full range of services, we may collect the following types of information:
- Information you provide - When you sign up for a ThreatSTOP Account or other ThreatSTOP services or promotion that requires registration, we ask you for personal information (such as your name, email address and an account password). For certain services, such as our Internet Security Services, we also request credit card or other payment account information which we maintain in encrypted form on secure servers. We may combine the information you submit under your account with information from other ThreatSTOP services or third parties in order to provide you with a better experience and to improve the quality of our services. For certain services, we may give you the opportunity to opt out of combining such information.
- Log information - When you use ThreatSTOP services, we require you to submit firewall logs to measure the performance and improve the efficacy of our services. These server logs may include information such as allowed or denied connections and origination or destination IP addresses.
- Affiliated sites - We offer some of our services in connection with other Internet Security Services. Log information that you provide to ThreatSTOP may be shared with these sites. The affiliated sites may have different privacy practices and we encourage you to read their privacy policies.
- User communications - When you send email or other communication to ThreatSTOP, we may retain those communications in order to process your inquiries, respond to your requests and improve our services.
- Providing our products and services to users;
- Auditing, research and analysis in order to maintain, protect and improve our services;
- Ensuring the technical functioning of our network; and
- Developing new services.
You can find more information about how we process personal information by referring to the privacy notices for particular services.
ThreatSTOP processes log and personal information on our servers in the United States of America and in other countries. In some cases, we process personal information on a server outside your own country. We may process personal information to provide our own services. In some cases, we may process personal information on behalf of and according to the instructions of a third party, such as our advertising partners.
Accordingly, by using the Services, you are consenting to the aforementioned processing of log and personal information. This should not cause you any concern because, as you can see from this Policy, we will take appropriate technological and organizational security measures to keep your information secure, and to ensure it is only used for the purposes specified in this Policy.
When you sign up for a particular service that requires registration, we ask you to provide personal information. If we use this information in a manner different than the purpose for which it was collected, then we will ask for your consent prior to such use.
If we propose to use log or personal information for any purposes other than those described in this Policy and/or in the specific service notices, we will offer you an effective way to opt out of the use of personal information for those other purposes. We will not collect or use sensitive information for purposes other than those described in this Policy and/or in the specific service notices, unless we have obtained your prior consent.
You can decline to submit log or personal information to any of our services, in which case ThreatSTOP may not be able to provide those services to you.
ThreatSTOP only shares personal information with other companies or individuals outside of ThreatSTOP in the following limited circumstances
- We have your consent. We require opt-in consent for the sharing of any sensitive personal information.
- We provide such information to our subsidiaries, affiliated companies or other trusted businesses or persons for the purpose of processing personal information on our behalf. We require that these parties agree to process such information based on our instructions and in compliance with this Policy and any other appropriate confidentiality and security measures.
- We have a good faith belief that access, use, preservation or disclosure of such information is reasonably necessary to (a) satisfy any applicable law, regulation, legal process or enforceable governmental request, (b) enforce applicable Terms of Service, including investigation of potential violations thereof, (c) detect, prevent, or otherwise address fraud, security or technical issues, or (d) protect against imminent harm to the rights, property or safety of ThreatSTOP, its users or the public as required or permitted by law.
We may share with third parties certain pieces of aggregated, non-personal information, such as the number of connection attempts from particular IP addresses, for example. Such information does not identify you individually.
Please contact us at the address below for any additional questions about the management or use of log and personal data.
We take appropriate security measures to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of data. These include internal reviews of our data collection, storage and processing practices and security measures, as well as physical security measures to guard against unauthorized access to systems where we store personal data.
We restrict access to personal information to ThreatSTOP employees, contractors and agents who need to know that information in order to operate, develop or improve our services. These individuals are bound by confidentiality obligations and may be subject to discipline, including termination and criminal prosecution, if they fail to meet these obligations.
ThreatSTOP processes personal information only for the purposes for which it was collected and in accordance with this Policy or any applicable service-specific privacy notice. We review our data collection, storage and processing practices to ensure that we only collect, store and process the personal information needed to provide or improve our services. We take reasonable steps to ensure that the personal information we process is accurate, complete, and current, but we depend on our users to update or correct their personal information whenever necessary.
When you use ThreatSTOP services, we make good faith efforts to provide you with access to your personal information and either to correct this data if it is inaccurate or to delete such data at your request if it is not otherwise required to be retained by law or for legitimate business purposes. We ask individual users to identify themselves and the information requested to be accessed, corrected or removed before processing such requests, and we may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others, or would be extremely impractical (for instance, requests concerning information residing on backup tapes), or for which access is not otherwise required. In any case where we provide information access and correction, we perform this service free of charge, except if doing so would require a disproportionate effort. Some of our services have different procedures to access, correct or delete users' personal information. We provide the details for these procedures in the specific privacy notices or FAQs for these services.
ThreatSTOP regularly reviews its compliance with this Policy. Please feel free to direct any questions or concerns regarding this Policy or ThreatSTOP's treatment of personal information by contacting us through this web site or by writing to us at Privacy Matters, c/o ThreatSTOP Inc., 701 Palomar Airport Road, Suite 300, Carlsbad, CA 92011, USA. When we receive formal written complaints at this address, it is ThreatSTOP's policy to contact the complaining user regarding his or her concerns. We will cooperate with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of personal data that cannot be resolved between ThreatSTOP and an individual.
If you have any additional questions or concerns about this Policy, please feel free to contact us any time through this web site or at Privacy Matters, c/o ThreatSTOP Inc., 701 Palomar Airport Road, Suite 300, Carlsbad, CA 92011, USA.