Date last revised: 7 November 2017.

PART A – ABOUT THIS PRIVACY POLICY

1. Who we are

We are Cyclonis Limited, a company incorporated under the laws of Ireland with company registration number 57494, whose registered office is 3 Castle Street, Dublin, Ireland ("we", "us", or "our").

We are dedicated to establishing a trusting relationship with our users, based on respect for personal identity and information and by promoting the use of fair information practices. We want to demonstrate our commitment to our users' privacy and establish our users' trust in our ability to protect their information and data.

2. This Privacy Policy

This Privacy Policy describes how we and our authorised business partners, affiliates and agents process information, particularly personal data, that we receive from you and others through your use of our website, software (“products”), and services. This privacy policy sets out:

The information we collect.
How we use the information.
With whom we share information.
The choices available to users regarding collection, use and distribution of the information.
The types of security procedures that are in place to protect information under our control.
A user’s rights, how a user can contact us and update or correct any inaccuracies in their information that we collect.
Please read this Privacy Policy carefully so that you understand our approach and practices regarding your personal data and other information and how we treat it. Please do not use our website, products or services if you do not agree with the ways in which we will process your information.

PART B - INFORMATION COLLECTION

We collect information from our users at several different points on our products, in accordance with the Data Protection Legislation and other applicable data protection laws strictly for the purposes necessary to our business and our users' convenience.

All information will be obtained fairly. The information we collect will be adequate, relevant and not excessive in relation to the purposes for which it was obtained.

Except for the reasons listed in this Privacy Policy, we will not disclose your personal data to third parties.

1. Registration

In order to use our products and services, a user must first complete the registration form. During registration a user is required to provide contact information (such as name and email address) and select a user name and password. We will also collect the user’s internet protocol (IP) address.

If the user accesses our products or services through a third party provider, we may receive this information from them, along with other personal data, for example the user ID.

2. Information Use

Subject to the exceptions set out in the Privacy Policy, we will not disclose to third parties the email address you upload to our web sites for the purpose of using our products or services.

3. Supplementation of Information

In order for us to properly fulfill our obligations to users it is necessary for us to supplement the information we receive with information from third party sources. The information obtained from these third party sources is maintained in a manner consistent with our Privacy Policy.

4. When Using Our Products and Services

We collect and use the information a user directly provides to us, such as the information you provide when you use our products and services, information about how you use our products and services, and information you provide when communicating with customer support.

Your username and a uniquely generated authentication password are sent and received during each communication to authenticate you as a user.

If you click the "Check for updates" button on the user interface, Cyclonis Password Manager sends us the Cyclonis Password Manager version number and language, a unique ID that identifies your copy of Cyclonis Password Manager, and the IP address of the computer on which Cyclonis Password Manager is installed. The Cyclonis Password Manager version number and unique ID are used to identify the specific updates to transmit and to allow a specific copy of Cyclonis Password Manager to be de-activated for the security and safety of our users, products and services, or our systems. No geolocation or other identifying information (such as IP address) is analysed or stored by Cyclonis Password Manager, other than in ordinary server logs, which are purged regularly.

5. Log Files

Our servers use log files to analyse trends, administer our systems, track users’ movement in the aggregate, and gather broad demographic information for aggregate use. This information may include IP addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. We do not link this automatically collected data to other information we collect about you.

6. Flash LSOs

We may use Local Shared Objects (LSOs), such as Flash, to store content information and preferences. Third parties with whom we partner to provide certain features on our website, in our products or services or to display advertising based upon your web browsing activity may use LSOs to collect and store information. Various browsers may offer their own management tools for removing HTML5 LSOs. To manage Flash LSOs, please To manage Flash LSOs, please click here.

7. Cookies and Other Tracking Technologies

We and our partners, affiliates and service providers use cookies, beacons, tags, scripts and related technologies (collectively called “Cookies”) to provide our services to you through our products and services. By accessing or using our products and services you consent to the use of Cookies in the manner described in this Privacy Policy. Please do not use our products or services if you are not comfortable with the ways in which we use Cookies.

What is a Cookie?

Cookies are small text files sent from a server and stored to a user’s device. When a user visits a website or application more than once, the browser sends Cookies back to the website or application, allowing the website or application to recognise the user and remember things like their personalised details and preferences. More information about Cookies and details of how to manage or disable them can be found on aboutcookies.org.

Do we use Cookies?

Yes. We may obtain information about your general internet usage by using Cookies that are typically stored on the hard drive of your computer or other device.

When do we use Cookies?

We use Cookies when you navigate or access our services. For example, when you return to our website after logging in, Cookies provide information to our website so that the website remembers you. Cookies help us to improve our services, to authenticate you and to deliver a better, more personalised service.

We mainly use Cookies for the operation and security of our products and services, to improve our services for analyzing trends and administering our services.

We currently use Cookies for the following purposes:

Operation of our service: We use Cookies to monitor session and status data, to learn how you, and other users, use our services and how well they perform. This allows us to identify errors, learn how our services perform, and improve and develop our services over time. We also use Cookies to remember if you have seen our cookie banner.

Security: We use Cookies to enable and support our security features, and to help us detect malicious activity and violations of our Terms of Sale and End User License Agreement.

Preferences: We use temporary “session” cookies which enables your browser to remember which pages on our website have already been visited and the language you have selected. This information may be used to help us to improve, administer and diagnose problems with our website and servers.

Third Party Cookies

Some Cookies that have been set on our services may not be related to or controlled by us and may originate from one of our partners, affiliates or service providers. We do not control the use of these Cookies and cannot access them due to the way Cookies work, as Cookies can only be accessed by the party which originally set them.

You should check the applicable third party’s website for more information about these Cookies.

How to refuse the use of Cookies

You can change your browser or application settings so your device warns you each time a Cookie is sent, or to turn off all Cookies. Each web browser or application is different, so please look at your browser or application "help" menu to learn how to modify your Cookies preferences. However, if you disable Cookies you will not have access to certain features that may make your browsing of our website and use of our services smoother, and some of our services may not be available to you.

8. Behavioral Targeting / Re-Targeting

We may place ads for our products on various third-party websites and platforms, and as a result, you may see ads for our products when browsing the internet, for example, when visiting Google, YouTube, Facebook and a variety of other websites and platforms. We may ask the proprietors of these websites/platforms to present our ads to particular demographic groups, for example, women over 25 years of age, or all visitors to a website who are in Ireland. Third-party websites/platforms may also use information they already have about you, or may place cookies or similar tracking technologies in your browser or application, in order to decide what ads you will see, including potentially our ads. If you have questions or concerns about the ads you see on any of these third-party websites/platforms or if you have questions generally about their privacy practices, you should consult the privacy policies of those sites or inquire with the proprietors of those sites.

PART C – INFORMATION USE

Data will be kept only for clear and legal purposes. All data will be processed fairly and in keeping with the purposes for which it was obtained.

We use your information for a range of different purposes, including:

providing our products and services to you;
determining your suitability for our products and services;
administering and managing the products and services we provide to you;
promoting the safety and security of our products and services and investigating suspicious activity or violations of our policies;
providing you with information that you request from us about our products and services;
conducting surveys (as set out in Part E (Third Party Links and Content) to enhance and improve the quality of the products and services we offer; and/or
as permitted or required by any law applicable to us or arising from your interaction with us.


Customer Service

We may communicate with users to assist with enquiries and to provide users with better customer service. To do so, we may reply via email, in-app message, or phone, in accordance with the user’s account preferences. If you contact us directly for any reason, and if we are able to provide support or service to you, we will use the information you have provided in order to respond to you, to assist with enquiries you have and to maintain our records.

Service Announcements

On rare occasions it is necessary to send out a service related announcement. For instance, if our service is temporarily suspended for maintenance or we want to notify you about changes to our products and services, we might send users an email or other communication. These communications are not promotional in nature.

Spam

Generally, spamming means the use of electronic messaging systems to send unsolicited messages. We have a zero tolerance policy for abuse through spamming.

PART D - INFORMATION SHARING WITH OTHERS

We will share the information we collect from you with third parties only in the ways that are described in this Privacy Policy. We do not sell your personal data to third parties.

The information we collect from you may be transferred to third parties in connection with operating our business. It may also be processed by these third parties and/or by our and their respective employees and service providers. We will take steps to ensure that these third parties will only process data in accordance with our instructions, and take appropriate security measures to protect your data.

By submitting your information, you agree to this transfer, storing or processing of your personal data by us.

In particular we may disclose your information to the following third parties:

our professional advisers in order for them to provide us with advice;
third party service providers, where necessary for them to provide us with services or to provide products and services that you have requested;
our technology providers, including those which host your data on our behalf and provide certain IT support and IT professional services to us; or
business partners and/or possible acquirers or investors (and our and/or their advisors) in the context of a facilitating or implementing a business re-organisation or a transfer/sale of all or part of our assets or business.
Except where required by law (for example, criminal investigations) no disclosure of data will be made to third parties for those third parties' own purposes or use without your permission.

Where permitted by law, we reserve the right to release personal data without your consent and/or without consulting you, when we believe that this is appropriate to comply with our legal obligations, to protect the security of our products, services, systems and related technologies, to prevent and minimise the effects of fraud, and otherwise to protect our legitimate interests and/or the legitimate interests of our customers.

International Data Transfers

Data may be transferred to or from our third party service providers for legitimate purposes as described in this Privacy Policy. This may include the transfer of data to other jurisdictions for processing at a destination outside the European Economic Area (EEA) which may not provide the same level of protection of personal data as within the EEA. By submitting your personal data or using our products and services, you agree to this transfer, storage and processing.

PART E - THIRD PARTY LINKS AND CONTENT

1. Links

When using our products or services, you may be redirected to third party websites. Your use of these websites and any associated services will be subject to these third parties’ terms of use, privacy policies and cookie policies. Please review the specific privacy policy and terms of conditions of these websites, as we are not responsible for them.

2. Surveys

Periodically, our site may request information from users via surveys. Participation in these surveys is completely voluntary and the user therefore has a choice whether or not to disclose this information. The requested information typically includes contact information (such as name and address) and demographic information (such as post code or zip code). Survey information will be used for purposes of monitoring or improving the use and satisfaction of our products and services. Though we may use an intermediary to conduct these surveys, they may not use customers' personal data for any secondary marketing purposes.

3. Blog

Our website may offer publicly accessible blogs. Any information you provide in these areas may be read, collected, and used by others who access them. To request removal of your personal data from our blogs or community forum, contact us at the address shown at the end of this Privacy Policy. In some cases, we may not be able to remove your personal data, in which case we will let you know if we are unable to do so and why.

4. Social Media Widgets

Our website includes social media features, such as a Facebook "Like" button and widgets, such as a "Share This" button or interactive mini-programs that run on our site. These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our site. Your interactions with these features are governed by the privacy policy of the company providing the features.

PART F – SECURITY AND PROTECTION OF YOUR INFORMATION

We take precautions that we deem to be reasonably necessary to help ensure user information is treated securely and in accordance with this Privacy Policy. This includes encrypting your information at rest using industry standard 256-bit AES encryption. We also seek to ensure that we keep your personal data accurate and up-to-date.

While we take these steps to maintain the security of your information, you should be aware of the many information security risks that exist and take appropriate care to help safeguard your information. The nature of the internet is such that we cannot guarantee the security of the information you transmit to us electronically, and any transmission is at your own risk. We store information you provide to us on secure servers and deploy appropriate technical and organisational security measures in the storage and disclosure of your personal data to try to prevent unauthorised access or loss.

We also rely on you to maintain security of your account with us. Due to our security features, we will not have access to your master password, or account information and passwords stored in your encrypted vault. You are responsible for safeguarding your account by keeping track of your account information, master password, or any other password, and using a strong master password and limiting its use to this account.

If you have any questions about our security, you can contact us at the address shown at the end of this Privacy Policy.

PART G – SOME FINAL TERMS

1. Retention of Data

We retain your personal data for no longer than is necessary with regard to the purposes for which it was collected or lawfully further processed, or for so long as may be necessary in light of our legal obligations.

2. Your Rights and Subject Access Requests

You have rights under the Data Protection Acts 1988 and 2003, and, from 25 May 2018, the General Data Protection Regulation (2016/679) (“Data Protection Legislation”). You also have the right to access personal data held about you, and to request that it is updated, corrected or that any inaccuracies in your personal data is deleted. You may also request that we cease processing that is causing you harm. You have the right bring any complaints to the Irish Data Protection Commissioner. Further information on your data privacy rights is available on the website of the Irish Data Protection Commissioner at http://www.dataprotection.ie.

You can withdraw your consent to our processing of your personal data at any time. You can access, correct or delete certain personal data and update your privacy preferences by contacting customer support. Alternatively, you can contact us via our Contact Us form.

Despite this, we retain the right to collect, process and maintain information provided by and collected about you, and disclose this information to the extent required to comply with our reasonable business and legal obligations. If you choose not to provide certain information to us or if you withdraw your consent to our processing of your personal data, we may not be able to continue to provide you with the products or services you require and/or it may affect our ability to better respond to your needs.

Any access request made to us may be subject to a statutory fee to meet our costs in providing you with details of the information we hold about you.

3. Notification of Changes to this Privacy Policy

From time to time, we may need to change this Privacy Policy. If we do so, we will post an updated version of our Privacy Policy on this page and it will apply to all of your information held by us at the time. We may notify you of any material changes by in-app message, email or by posting a notice on our website. Continued use of our website, applications, products or services indicates your acceptance of the changed Privacy Policy.

4. Definitions

Any capitalised terms not defined in this Privacy Policy have the meanings given to them in the Data Protection Legislation.

5. Contacting Us

If you have any queries, comments or requests about this Privacy Policy or our management of your personal data, please contact us via our Contact Us form– please be sure to select "Privacy Policy Inquiry" in the "Inquiry Type" drop-down menu.