Privacy Policy

This ChameleonX Privacy & Security Policy (“Policy”) outlines the general policy and practices for the types of information that ChameleonX,LTD. (“ChameleonX”“we”“us” or “our”) gathers, how we use that information, and the options that our users (“you” or “your” or “our users“) have regarding our use of, and your ability to correct, such information.

It’s our overriding privacy principle that any personal information provided to us by you is just that: personal and private. As such, we will never sell, rent, share, or otherwise disclose your personal information to anyone except to provide our services or as otherwise described in this Policy, without providing explicit notice of such and the ability to opt-out.

ChameleonX’s website and services (the “Website” and the “Services” respectively) are not intended for, and ChameleonX does not knowingly collect personally identifiable information from any person under the age of eighteen. By using the Website and Services and approving ChameleonX’s Terms of Service and this Policy, you also approve that you understand that the Services and the Website are not intended for children under the age of eighteen and addressed solely to a natural person who is at least eighteen years old.

POLICY APPLICATION:

This Policy applies to information provided to us by: (i) visitors to our Website, (ii) users of our Services (i.e., subscribers to any of our plans), and (iii) information we collect from visitors to the websites of our users (“User’s Websites” and the “User’s Visitors” respectively). We generally serve merely as a conduit for information controlled by others, and as such this Policy may not apply to our Users’ Websites. Our Users’ Websites or those to which we provide links, may have their own privacy policies. Because of this, we strongly encourage awareness and understanding of such websites’ separate privacy policies.

COLLECTING AND USING INFORMATION:

ChameleonX is the owner of the service information collected on this Website and through any ChameleonX Service. As visitors browse our Website (“Our Visitors” and together with the User’s Visitors – the “Visitors“), or our User’s Websites if they are protected by ChameleonX, we normally collect the following information (the “User’s Information“):

  • log of these Visitors’ interactions in order to provide better services to our users (e.g., using visitor log data in order to detect new threats and malicious third parties);
  • certain User’s Information for the purpose of billing;
  • Information about the use of the Website and/or our User’s Websites and/or Services.

ChameleonX may use the User’s Information in the following manner:

  • To provide you with high-quality Service;
  • As part of our Services, we may build statistical reports based upon what malicious Visitors have visited certain site(s), in order to further protect your sites. We may also share User’s Information about our users or their Visitors where we have a reasonable belief that they pose a security threat.
  • To share User’s Information relating to billing with third party processors for the limited purpose of receiving payment. We do not store full credit card numbers or personal account numbers (PANs).

All User’s Information provided by you or collected by us is stored on our secure servers. Unfortunately, the transmission of information via the internet is not completely secure. Although we will take reasonable commercial effort to protect your User’s Information, we cannot guarantee the complete security of your User’s Information transmitted to the Website and therefore any transmission is at your own risk. Once we have received User’s Information, we will use strict procedures and security features in order to prevent unauthorized access.

We may store and use Personal Information outside your country, on servers which are located in the European Union, the United States (certified under the privacy shield) or any other state, subject to applicable law, including GDPR. We process data both inside and outside of Europe and rely on legally-provided mechanisms to lawfully transfer data across borders, such as an adequacy decision by the EU Commission data processing agreements incorporating the EU Commission Standard Contractual Clauses or, in the case of US providers, a certification under the Privacy Shield framework. By approving our Terms of Use and this Privacy Policy, you provide us with your consent to such transfer. If you would like to request a copy of these suitable safeguards to ensure an adequate level of protection for your Personal Information even in cases of transfers to countries outside the EU, please do so using the contact details provided in this Privacy Policy.

DISCLOSURE OF INFORMATION

In order for us to provide you with some of our services, we may also provide the User’s Information to our affiliates, vendors and service providers, which we use for billing systems, contract and account management, customer support, relationship management and other technical operations. In such cases, we will ensure that such entities are bound by appropriate confidentiality restrictions to protect the User’s Information covered by this Policy. However, we will never use or share the User’s Information in ways unrelated to those described herein other than the disclosures permitted under this Policy, without first letting you know and giving you the ability to opt-out.

We may also disclose the User’s Information subject to the following provisions:

  • as required by law, such as to comply with a subpoena, or similar legal process;
  • when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request;
  • if ChameleonX is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our Website of any change in ownership or uses of this information, as well as any choices you may have regarding this information;

We do not sell, rent, or share the User’s Information with third parties for their direct marketing purposes.

COOKIES

Our site and Services use “cookies” in order to provide a better Service to you. Cookies are placed by a browser onto your computer’s hard drive to assign a unique identification to that computer. For example, we may use cookies to help direct you to the appropriate part of our Website, by indicating that you are a repeat visitor to our Website. We may also use the information provided to us to present you with services that are customized to your preferences. ChameleonX does not store information we consider personal or private in a cookie unless that information is obscured.

Some portions of our Website are functional without cookies. You may delete ChameleonX’s cookies yourself through your browser’s cookie manager. However, disabling cookies will reset your session, disable auto-login, and may adversely affect other functions on the Website and the services we provide.

As part of our services, we may place cookies on the computers of visitors to the Website. We do this in order to identify malicious visitors and to provide customized services.

DATA AGGREGATION

ChameleonX may aggregate data we acquire about our users and the User’s Visitors. If we assemble this sort of data and provide it to external parties, our users’ personal information will never be attached to or included in such aggregated data.

DATA RETENTION POLICY, MANAGING YOUR USER’S INFORMATION

We will retain the User’s Information for as long as you use the Website and the Services and/or our User’s Websites and for no more than 48 hours thereafter. The purpose for this retention typically includes business or legal reasons. You may ask to delete such information at any time as broadly described below.

PROMOTIONAL PARTNERS AND THIRD PARTY APPS:

From time-to-time, ChameleonX may notify you about an offer from one of our promotional partners via our Website or email. While we may target particular types of users for these offers, we do all of the targeting within our systems and not externally. Our partners will not have any access to the targeting information, including the names of the people who may be interested in a particular product or service. Until you affirmatively respond to a promotional offer, we will not share any identifying information about you to any of these partners.

LAW ENFORCEMENT AND OBLIGATIONS:

It’s possible that we may be required by law, court order, or other legal processes to provide information about our customers to outside parties. It’s our policy to ensure adherence to the due process of law in all such instances, and if we are required to provide information under these circumstances, we will, whenever possible, attempt to inform users whose information we are compelled to produce, unless prohibited by law.

We may also retain copies of personal information to comply with our legal obligations, pursuant to our data retention policies, or for such reasonable period as is required to address potential disputes.

DATA SECURITY AND DATA INTEGRITY

We take all reasonable steps to protect information we receive from our users from loss, misuse or unauthorized access, disclosure, alteration and/or destruction. We’ve put in place appropriate physical, electronic and managerial procedures to safeguard and secure such information. ChameleonX only processes personal information in a way that is compatible with and relevant for the purpose for which it was collected or authorized.

RIGHTS TO ACCESS AND CONTROL THE USER’S INFORMATION

We provide many choices about the collection, usage and sharing of the User’s Information, such as deleting or correcting the User’s Information. We offer you to control and manage the User’s Information that we have about you.

You are entitled to ask us to:

  • Withdraw the consent – You may, at any time, withdraw your consent and no longer permit us to use and keep your User’s Information, but by doing so, your experience of the Website may be affected and you may not be able to use some of the Services that we offer. You can withdraw your consent with respect to certain non-functional use of your User’s Information and such withdrawal will not affect your basic use of the Website.
  • Delete Data – You can ask us to erase or delete all or some of the User’s Information (e.g., if it is no longer necessary to provide you with the Services).
  • Change or Correct Data – You can ask us to edit some of the User’s Information. You can also ask us to change, update or fix your User’s Information in certain cases, particularly if it’s inaccurate.
  • Object to, or Limit or Restrict, Use of User’s Information – You can ask us to stop using all or some of your User’s Information (e.g., if we have no legal right to keep using it) or to limit our use of it (e.g., if the User’s Information is inaccurate or unlawfully held).Further, you have the right, for reasons arising from your particular situation, to object at any time to the processing of your personal data, which is processed on the basis our legitimate interests; this also applies to any profiling based on this processing. If you object, we will no longer process your User’s Information in the future unless we can prove compelling grounds for the processing that outweigh your interests, rights, and freedoms or the processing serves to assert, exercise, or defend legal claims.
  • Right to Access and/or Take Your User’s Data Information – You can ask us for a copy of User’s Information and can ask for a copy of User’s Information you provided in machine-readable form.

In order to exercise any of your foregoing rights, you can contact us at the e-mail address provided in the “Contact Information” section below. You acknowledge that by asking us to refrain from storing or processing the User’s Information or by performing any of the foregoing actions on its own, you may be prevented from using all or part of the Services and you hereby waive any claim or demand you might have against us in this matter.

If you believe that the process of the User’s Information is not complying with the law applicable to you or that our response has not satisfied you, you may lodge a complaint to the relevant Supervisory Authority (as defined in the GDPR).

LAWFUL BASES FOR PROCESSING

We have lawful bases to collect, use and share your Personal Information. As already explained, if you are a user located in the European Economic Area (“EEA”), we will only collect and process your Personal Information where we have lawful bases. Lawful bases include consent (where you have given consent), contract (where processing is necessary for the performance of a contract with you (e.g. to deliver the Services that you have requested)) and “legitimate interests”.

NOTIFICATION OF CHANGES:

We take the trust and privacy of our customers and their users extremely seriously and do not believe that we will need to change the core principles set forth in this Policy going forward. However, if we are required to modify this Policy, we will promptly provide notice of any material changes and post the modified Policy on this Website along with the effective date of any necessary edits.

EFFECTIVE DATE:

This Policy was last updated on July 2018.

CONTACT INFORMATION:
ChameleonX, Ltd.
6 Hanechoshet St.
Tel Aviv, Israel
privacy@chameleonx.com