This privacy and cookie policy (“Policy”) describes how vArmour Networks, Inc. (“vArmour,” “we,” and “our”) collects, uses and shares personal data when using this website www.varmour.com (the “Site”), our Application Explorer, together (the “Services”), as well as through social networking websites, our marketing activities, and other activities described in this Privacy Policy.

vArmour may provide additional or supplemental privacy policies to individuals for specific products or services that we offer at the time we collect personal data.

Please note that your personal data may be provided to us by our customers. In such cases, we shall process such personal data as a data processor on behalf of those customers who use our services. In such instances, our customer’s privacy policy, rather than this Privacy Policy, will apply to our processing of your personal data.

Please read the following information carefully to understand our views and practices regarding your personal data and how we will treat it.

Who We Are:

For the purpose of applicable data protection legislation, the data controller of your personal data is vArmour
Networks, Inc of 270 3rd St., Los Altos, CA 94022 USA. By using the Services, you consent to such use of your
information and personal data and agree to the terms of this Privacy Policy.

Changes to this Policy:

We will post any modifications or changes to the Policy on our Site. We reserve the right to modify the Policy at
any time, so we encourage you to review it frequently. The “Last Updated” legend above indicates when this Policy
was last changed. If we make any material change(s) to the Policy, we will notify you via email and post a notice on
our Site prior to such changes(s) taking effect.

  1. Purposes Of Processing

    What is personal data?

    We collect information about you in a range of forms, including personal data. As used in this Policy, “personal
    data” is as defined in the UK Data Protection Act 1998/the European Data Protection Directive 95/46/EC/General
    Data Protection Regulation 2018 and any successor legislation, this includes any information which, either alone
    or in combination with other information we hold about you or identifies you as an individual, including for
    example, your name, postal address, email address and telephone number.

    Why do we need your personal data?

    We will only process your personal data in accordance with applicable data protection and privacy laws. We need
    certain personal data in order to provide you with access to our Services. If you created a profile or
    registered with us, you will have been asked to tick to agree to provide this information in order to access our
    Services, purchase our products, and view our content.

    If you are located in the EEA or the UK, we rely on the following legal bases to process your personal
    information, as appropriate:

    • necessity for us to perform a contract with you or take steps at your request prior to entering into a
      contract;
    • to comply with an applicable legal obligation;
    • to realize a legitimate interest based on an assessment of that interest and your privacy and other
      fundamental interests; and
    • your consent, where required under applicable law. You maintain the right to withdraw such consent at any
      time. If you do not agree to our use of your personal data in line with this Policy, please do not use our
      Services.

  2. Collecting Your Personal Data

    We collect information about you in the following ways:

    Information You Give Us.

    This includes:

    • the personal data you provide when you register to use the Services, including your‎ name, postal address,
      email address, telephone number, username, password and demographic information (such as your job title);
    • the personal data that may be contained in any comment or other submission you upload or post to the
      Services;
    • the personal data you provide in connection with our promotions we run on the Services;
    • the personal data you provide when you report a problem with our Services, or when we provide you with
      customer support;
    • the personal data you provide when you make a purchase thorough our Services, such as payment card
      information or bank account number;
    • the personal data you provide when you correspond with us by phone, email or otherwise; and
    • Information from third-party services, such as social networking sites (“SNS”), that you link to the
      Services. This data may include your username, profile picture and other information associated with your
      account on that third-party service that is made available to us based on your account settings on that
      service.

    Information We Get from Others.

    We may also get information about you from other sources. For example, if you have agreed to share information
    with one of our partners or from other sources such as DiscoverOrg or BrightTalk, we may add this to information
    we get from our Services.

    Information Automatically Collected.

    We automatically log information about you and your computer or mobile device when you access our Services. For
    example, when visiting our Services, we log your computer or mobile device operating system name and version,
    manufacturer and model, browser type, browser language, screen resolution, the website you visited before
    browsing to our Services, pages you viewed, how long you spent on a page, access times, information about your
    use of and actions on our Services, and general location information such as city, state or geographic area. We
    collect this information about you using cookies. Please refer to the sections on cookies, Flash Technology and
    Pixel Tags below.

    Automated Decision Making and Profiling.

    We do not use your personal data for the purposes of automated decision-making. However, we may do so in order
    to fulfill obligations imposed by law, in which case we will inform you of any such processing and provide you
    with an opportunity to object.

  3. Cookies

What are cookies?

We may collect information using “cookies.” Cookies are small data files stored on the hard drive of your computer
or mobile device by a website. We may use both session cookies (which expire once you close your web browser) and
persistent cookies (which stay on your computer or mobile device until you delete them) to provide you with a more
personal and interactive experience on our Services.

We use two broad categories of cookies: (1) first party cookies, served directly by us to your computer or mobile
device, which are used only by us to recognize your computer or mobile device when it revisits our Services; and (2)
third party cookies, which are served by service providers on our Services, and can be used by such service
providers to recognize your computer or mobile device when it visits other websites.

Cookies we use.

Our Services use the following types of cookies for the purposes set out below:

Type of cookie Purpose

Essential Cookies

These cookies are essential to provide you with services available through our Services and to enable you to use some of its features. For example, they allow you to log in to secure areas of our Services and help the content of the pages you request load quickly. Without these cookies, the services that you have asked for cannot be provided, and we only use these cookies to provide you with those services.

Functionality Cookies

These cookies allow our Services to remember choices you make when you use our Services, such as remembering your language preferences, remembering your login details and remembering the changes you make to other parts of our Services which you can customize. The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you visit our Services.

Analytics and Performance Cookies

These cookies are used to collect information about traffic to our Services and how users use our Services.The information gathered does not identify any individual visitor. The information is aggregated and anonymous. It includes the number of visitors to our Services, the websites that referred them to our Services, the pages they visited on our Services, what time of day they visited our Services, whether they have visited our Services before, and other similar information. We use this information to help operate our Services more efficiently, to gather broad demographic information and to monitor the level of activity on our Services.We use Google Analytics for this purpose. Google Analytics uses its own cookies. It is only used to improve how our Services works. You can find out more information about Google Analytics cookies here: https://developers.google.com/analytics/resources/concepts/gaConceptsCookies. You can find out more about how Google protects your data here: www.google.com/analytics/learn/privacy.html www.google.com/analytics/learn/privacy.html. You can prevent the use of Google Analytics relating to your use of our Services by downloading and installing the browser plugin available via this link:http://tools.google.com/dlpage/gaoptout?hl=en-GB.

Targeted and advertising cookies

These cookies track your browsing habits to enable us to show advertising which is more likely to be of interest to you. These cookies use information about your browsing history to group you with other users who have similar interests. Based on that information, and with our permission, third-party advertisers can place cookies to enable them to show adverts which we think will be relevant to your interests while you are on third-party websites.You can disable cookies which remember your browsing habits and target advertising at you by visiting http://www.youronlinechoices.com/uk/your-ad-choices. If you choose to remove targeted or advertising cookies, you will still see adverts but they may not be relevant to you. Even if you do choose to remove cookies by the companies listed at the above link, not all companies that serve online behavioral advertising are included in this list, and so you may still receive some cookies and tailored adverts from companies that are not listed.

Social Media Cookies

These cookies are used when you share information using a social media sharing button or “like” button on our Services or you link your account or engage with our content on or through a social networking website such as Facebook, Twitter or Google+. The social network will record that you have done this.

Disabling cookies.

You can typically remove or reject cookies via your browser settings. In order to do this, follow the instructions
provided by your browser (usually located within the “settings”, “help”, “tools”, or “edit” facility). Many browsers
are set to accept cookies until you change your settings.

Further information about cookies, including how to see what cookies have been set on your computer or mobile device
and how to manage and delete them, visit www.allaboutcookies.org and
www.youronlinechoices.com/uk.

If you do not accept our cookies, you may experience some inconvenience in your use of our Services. For example, we
may not be able to recognize your computer or mobile device and you may need to log in every time you visit our
Services.

4. PIXEL TAGS

We may also use pixel tags (which are also known as web beacons and clear GIFs) on our Services to track the actions
of users on our Services. Unlike cookies, which are stored on the hard drive of your computer or mobile device by a
website, pixel tags are embedded invisibly on webpages. Pixel tags measure the success of our marketing campaigns
and compile statistics about usage of the Services, so that we can manage our content more effectively. The
information we collect using pixel tags is not linked to our users’ personal data.

5. DO NOT TRACK SIGNALS

Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We
currently do not respond to do not track signals. To find out more about “Do Not Track,” please visit
http://www.allaboutdnt.com.

6. ADVERTISING

Generally. We may use other companies to serve third-party advertisements when you visit and use
the Services. These companies may collect and use click stream information, browser type, time and date, subject of
advertisements clicked or scrolled over during your visits to the Services and other websites in order to provide
advertisements about goods and services likely to be of interest to you. These companies typically use tracking
technologies to collect this information. Other companies’ use of their tracking technologies is subject to their
own privacy policies.

Targeted Advertising. In order to serve offers and advertisements that may interest you, we may
display targeted advertisements on the Services, or other digital properties or applications in conjunction with our
content based on information provided to us by our users and information provided to us by third parties that they
have independently collected. We do not provide personal data to advertisers when you interact with an
advertisement.

Your Ad Choices. Some of the third-party services providers and/or advertisers may be members of
the Network European Interactive Digital Advertising Alliance (“EDAA”) Self-Regulatory Program for Online
Behavioural Advertising. To learn more, visit http://www.edaa.eu/edaa-for-users
which provides information regarding targeted advertising and the “opt-out” procedures of EDAA members.

7. USING YOUR PERSONAL DATA

We may use your personal data as follows:

  • to operate, maintain, and improve our Services and products;
  • to manage your account, including to communicate with you regarding your account, if you have an account on our Services;
  • to operate and administer our rewards program and other promotions you participate in on our Services;
  • to respond to your comments and questions and to provide customer service;
  • to send information including technical notices, updates, security alerts, and support and administrative messages;
  • with your consent, to send you marketing e-mails about upcoming promotions, and other news, including information about products and services offered by us and our affiliates. You may opt-out of receiving such information at any time: such marketing emails tell you how to “opt-out.” Please note, even if you opt out of receiving marketing emails, we may still send you non-marketing emails. Non-marketing emails include emails about your account with us (if you have one) and our business dealings with you;
  • to process payments you make via our Services;
  • to link or combine user information with other personal data;
  • for research and development purposes, including to analyze and improve our Services and our business;
  • as we believe necessary or appropriate (a) to comply with applicable laws; (b) to comply with lawful requests and legal process, including to respond to requests from public and government authorities; (c) to enforce our Policy and terms and conditions that govern our Services; and (d) to protect our rights, privacy, safety or property, and/or that of you or others; and
  • as described in the “Sharing of your Personal Data” section below.

8. SHARING YOUR PERSONAL DATA

We may share your personal data as follows:

  • Third Parties Designated by You. We may share your personal data with third parties where you have provided your consent to do so.
  • Our Third Party Service Providers. We may share your personal data with our third-party service providers who provide services such as data analysis, payment processing, information technology and related infrastructure provision, customer service, email delivery, auditing and other similar services. These third-parties are only permitted to use your personal data to the extent necessary to enable them to provide their services to us. They are required to follow our express instructions and to comply with appropriate security measures to protect your personal data.
  • Affiliates. We may share some or all of your personal data with our affiliates, in which case we will require our affiliates to comply with this Policy. In particular, you may let us share personal data with our affiliates where you wish to receive marketing communications from them.
  • Business and marketing partners. Third parties with whom we co-sponsor promotions, with whom we jointly offer products or services, or whose products or services may be of interest to you.
  • Linked third-party services. If you link the Services to a social media or other third-party service, we may share your personal data with that third-party service. The third party’s use of the shared information will be governed by its privacy policy and the settings associated with your account with the third-party service.
  • Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.
  • Corporate Restructuring. We may share personal data when we do a business deal, or negotiate a business deal, involving the sale or transfer of all or a part of our business or assets. These deals can include any merger, financing, acquisition, or bankruptcy transaction or proceeding.
  • Other Disclosures. We may share personal data as we believe necessary or appropriate: (a) to comply with applicable laws; (b) to comply with lawful requests and legal process, including to respond to requests from public and government authorities to meet national security or law enforcement requirements; (c) to enforce our Policy; and (d) to protect our rights, privacy, safety or property, and/or that of you or others.

9. ANONYMOUS DATA

When we use the term “anonymous data,” we are referring to data and information that does not permit you to be
identified or identifiable, either alone or when combined with any other information available to a third party.
We may create anonymous data from the personal data we receive about you and other individuals whose personal data
we collect. Anonymous data might include analytics information and information collected by us using cookies. We
make personal data into anonymous data by excluding information (such as your name) that makes the data personally
identifiable to you. We use this anonymous data to analyze usage patterns in order to make improvements to our
Services.

10. THIRD PARTY SITES

Our Services may contain links to third-party websites and features. This Policy does not cover the privacy
practices of such third-parties. These third-parties have their own privacy policies and we do not accept any
responsibility or liability for their websites, features or policies. Please read their privacy policies before you
submit any data to them.

11. INTERNATIONAL DATA TRANSFER

Your information, including personal data that we collect from you, may be transferred to, stored at and processed
by us and our affiliates and other third-parties outside the country in which you reside, including, but not limited
to the United States, where data protection and privacy regulations may not offer the same level of protection as in
other parts of the world. By using our Services, and providing your consent, you agree to this transfer, storing or
processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in
accordance with this Policy.

12. SECURITY

We seek to use reasonable organizational, technical and administrative measures to protect personal data within our
organization. Unfortunately, no transmission or storage system can be guaranteed to be completely secure, and
transmission of information via the internet is not completely secure. If you have reason to believe that your
interaction with us is no longer secure (for example, if you feel that the security of any account you might have
with us has been compromised), please immediately notify us of the problem by contacting us using the details in
Section 18 below.

13. RETENTION

We will only retain your personal data as long reasonably required for you to use the Services and/or to provide you
with the Services, unless a longer retention period is required or permitted by law (for example for regulatory
purposes).

14. OUR POLICY ON CHILDREN

Our Services are not directed to children under 16. If a parent or guardian becomes aware that his or her child has
provided us with information without their consent, he or she should contact us using the details in Section 18
below. We will delete such information from our files as soon as reasonably practicable.

15. SENSITIVE PERSONAL DATA

Subject to the following paragraph, we ask that you not send us, and you not disclose, any sensitive personal data
(e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or
other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or
through our Services, or otherwise to us.

If you send or disclose any sensitive personal data to us, you consent to our processing and use of such sensitive
personal data in accordance with this Policy. If you do not consent to our processing and use of such sensitive
personal data, you must not submit such user generated content to our Services.

16. YOUR RIGHTS

If you wish to exercise any of these rights, please contact us using the details in Section 18 below. In your
request, please make clear: (i) what personal data is concerned; and (ii) which of the
above rights you would like to enforce. For your protection, we may only implement requests with respect
to the personal data associated with the particular email address that you use to send us your request, and we may
need to verify your identity before implementing your request. We will try to comply with your request as soon as
reasonably practicable and in any event, within one month of your request. Please note that we may need to retain
certain information for recordkeeping purposes and/or to complete any transactions that you began prior to
requesting such change or deletion.

17. COMPLAINTS

We are committed to resolve any complaints about our collection or use of your personal data. If you would like to
make a complaint regarding this Policy or our practices in relation to your personal data, please contact us at
This email address is being protected from spambots. You need JavaScript enabled to view it.. We will reply to your complaint as soon as we can and in any event, within 45 days. We hope to resolve any complaint brought to our attention, however if you feel that your complaint has not been adequately resolved, you reserve the right to contact your local data protection supervisory authority, which for the UK, is the Information Commissioner’s Office.

18. CONTACT INFORMATION

We welcome your comments or questions about this Policy. You may contact us in writing at This email address is being protected from spambots. You need JavaScript enabled to view it. or Privacy Requests, 270 3rd St., Los Altos, CA 94022 USA.

19. EMPLOYEE PERSONAL DATA

vArmour commits to cooperate with the panel established by the EU data protection authorities (DPAs) and comply with
the advice given by the panel with regard to human resources data transferred from the EU in the context of the
employment relationship. Please contact us to be directed to the relevant DPA contacts.

20. CALIFORNIA RESIDENTS

This section applies only to California residents. It describes how we collect, use and share Personal Information
of California residents in operating our business, and their rights with respect to that Personal Information. For
purposes of this section, “Personal Information” has the meaning given in the California Consumer
Privacy Act of 2018 (“CCPA”) but does not include information exempted from the scope of the CCPA.

Your California privacy rights. As a California resident, you have the rights listed below.
However, these rights are not absolute, and in certain cases we may decline your request as permitted by law.

  • Information. You can request the following information about how we have collected and used
    your Personal Information during the past 12 months:

    • The categories of Personal Information that we have collected.
    • The categories of sources from which we collected Personal Information.
    • The business or commercial purpose for collecting and/or selling Personal Information.
    • The categories of third parties with whom we share Personal Information.
    • Whether we have disclosed your Personal Information for a business purpose, and if so, the categories of Personal Information received by each category of third party recipient.
    • Whether we’ve sold your Personal Information, and if so, the categories of Personal Information received by each category of third party recipient.
  • Access. You can request a copy of the Personal Information that we have collected about you during the past 12 months.
  • Deletion. You can ask us to delete the Personal Information that we have collected from you.
  • Opt-out of sales. If we sell your Personal Information, you can opt-out. In addition, if you direct us not to sell your Personal Information, we will consider it a request pursuant to California’s “Shine the Light” law to stop sharing your personal information covered by that law with third parties for their direct marketing purposes.
  • Opt-in. If we know that you are younger than 16 years old, we will ask for your permission (or if you are younger than 13 years old, your parent’s or guardian’s permission) to sell your Personal Information before we do so.
  • Nondiscrimination. You are entitled to exercise the rights described above free from discrimination. This means that we will not penalize you for exercising your rights by taking actions such as denying you services; increasing the price/rate of services; decreasing service quality; or suggesting that we may penalize you as described above for exercising your rights

How to exercise your rights

You may exercise your California privacy rights described above as follows:

  • Right to information, access and deletion. You can request to exercise your information,
    access and deletion rights by:

    • Calling us toll free at 1-844-VARMOUR
    • Emailing This email address is being protected from spambots. You need JavaScript enabled to view it.
  • Right to opt-out of the “sale” of your Personal Information. We do not sell your Personal Information in the conventional sense (i.e., for money). However, like many companies, we use services that help deliver interest-based ads to you. California law classifies our use of these services as a “sale” of your Personal Information to the companies that provide the services. This is because we allow them to collect information from our website users (e.g., online identifiers and browsing activity) so they can help serve ads more likely to interest you. You can request to opt-out out of this “sale” of your personal information here: This email address is being protected from spambots. You need JavaScript enabled to view it.

We will need to confirm your identity and California residency to process your requests to exercise your
information, access or deletion rights. We cannot process your request if you do not provide us with sufficient
detail to allow us to understand and respond to it.

Personal information that we collect, use and share

The chart below summarizes how we collect, use and share Personal Information by reference to the statutory
categories specified in the CCPA, and describes our practices during the 12 months preceding the effective date of
this Privacy Policy. Categories in the chart refer to the categories described above in the general section of this
Privacy Policy.

Statutory category of personal information (PI)
 Source of the PI Purpose for collection Categories of third parties to whom we “disclose” the PI for a business purpose Categories of third parties to whom we “sell” the P
Identifiers • You
• Public sources
• Business partners
• Our clients 		• Service delivery
• Marketing 		• Advertising partners
• Service-related third parties
• Business transferees 		• Advertising Partners
Commercial Information • You
• Our clients 		• Service delivery
• Marketing 		• Service-related third parties
• Business transferees 		• Advertising Partners
Online Identifiers • You
• Our clients 		• Service delivery
• Marketing 		• Service-related third parties
• Business transferees 		• Advertising partners (to facilitate online advertising)
Internet or Network Information • You
• Automatic collection 		• Service delivery
• Marketing
• Compliance & Operations 		• Service-related third parties
• Authorities and others
• Business transferees 		• Advertising partners (to facilitate online advertising)
Financial Information • You • Service delivery • Service-related third parties • Payment Processors

We describe:

21. AUSTRALIAN PRIVACY LAWS

This section applies only applies to personal information we collect from individuals who are protected by the
Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles (APPs). For purposes of this Section 21,
“personal information” and “sensitive information” have the meanings given in the Privacy Act.
Use of personal information

We will collect, hold, use and disclose your personal information only for:

  • the purpose for which you provide it to us, including the purposes set out above in Section 7; and
  • any secondary purpose, where you consent to that use or disclosure, or you would reasonably expect the use or disclosure in the circumstances, and that secondary purpose is:
    • in the case of non-sensitive information, related to the primary purpose for which we have collected that information, and
    • in the case of sensitive information, directly related to the primary purpose; and
  • any other purpose permitted by law.

Disclosing personal information

We may also disclose personal information we collect about you if permitted by law.

Overseas disclosure

We will collect, store and disclose your personal information outside Australia as described above. In addition to
the United States, such overseas disclosures may be to the following countries: Canada and European Union. We will
take reasonable precautions to ensure that our affiliates and any third party recipients protect your personal
information in accordance with the APPs.

Employee records exemption

The Privacy Act does not apply to the use and disclosure of employee records directly related to your current or
former employment relationship.

Requests to access or correct personal information
If you wish to access your personal information held by us, or request that your personal information be corrected,
please contact our Privacy Team using the following details:
Email: privacy@varmour.com.

Post: Privacy Requests, 270 3rd St., Los Altos, CA 94022 USA.

Tel: +650.564.5100

Our Privacy Team will endeavour to respond to you within a reasonable time and we will provide access and/or correct
the personal information unless an exception under law applies.
Complaints

If you have any questions about this privacy and cookie policy or you believe a breach of the APPs has occurred, you
can contact Privacy Team at the details set out in the clause above.

Our Privacy Team will endeavour to address and answer any questions or complaints you have in a reasonable time, and
may further investigate or take steps in order to resolve the matter.

If you still feel our response was unsatisfactory, you may discuss the issue with us further, or contact the Office
of the Australian Information Commissioner for more information at:

Website: https://www.oaic.gov.au/about-us/contact-us/
Tel: 1300 363 992
Post: GPO Box 5218, Sydney NSW 2001

 

close

Timothy Eades

Chief Executive Officer