Last Updated: August 20, 2023
This policy applies when we process Personal Information related to you when you use our website available at: www.cognyte.com (the “website”), when you interact with us on social media and at our events, trade shows or webinars, and when you interact with our services as an end-user of customer of ours (collectively: the “services”). This policy also applies to our internal operations including sales, finance, marketing, procurement and legal.
The term “Personal Information” refers to information that identifies an individual or relates to an identifiable individual. For example, Personal Information is your name, email address, telephone number, and other contact details which you submit to us.
A Summary of this Policy
|What is Not Covered by This Policy?||This policy does not apply to our processing activities when we process Personal Information on behalf of our customers as a data processor or service provider, or when we process Personal Information on our employees and job applicants. Read More.|
|Personal Information You Provide Us||We receive and store any information you enter on our website or give us in any other way. Read More|
|Personal Information We Collect||We automatically log ‘traffic/session’ information including IP addresses and user agent. We collect session durations and additional activity information. Read More|
|What Do We Do with Personal Information?||We maintain the website, make it better and continue developing it, and protect us and the website from misuse and law violations. Read More|
|Who do we Share Personal Information Related to You with?||We use service providers, for example, to send email messages and to store information. We will transfer information when we change our corporate structure, and we will share the information with our affiliate entities. Read More|
|Disclosure of Personal Information to Authorities||We will obey orders and other lawful requirements by authorities to disclose information. Read More|
|Aggregated and Analytical Information||Aggregated information is not identifiable. We use it for legitimate business purposes and for standard analytical tools. Read More|
|Your Choice||You may opt out of our mailing lists and terminate your use of the website. Our website does not respond to Do Not Track (DNT) signals. Read More|
|Your EU Data Subject Rights||If we process Personal Information related to you when you are in the EU, further terms apply to our processing in relation to your rights as a data subject under EU data protection laws. Read More|
|Specific Provisions for US Residents||If you reside in the United States, further terms apply to our processing in relation to your rights as a consumer under U.S. state privacy laws. Read More|
|Personal Information Retention||We retain Personal Information to maintain our website and for legitimate and lawful purposes, as further explained in the data retention section of this policy. Read More|
|Transfer of Information Outside Your Territory||We keep Personal Information related to you in the United States and in the EEA, and will store them at additional sites, at our discretion. Our service providers provide us adequate security and confidentiality commitments. Read More|
|Information Security||We implement systems, applications, and procedures to secure Personal Information related to you, to minimize the risks of theft, damage, loss of information, or unauthorized access or use of information. Read More|
|Contact Us||Please contact us at: [email protected] for further information. Read More|
What is Not Covered by this Policy
This policy does not apply where we process Personal Information as a data processor or service provider on behalf of our customers, in the context of providing such customers our products, services, and solutions, where we process Personal Information relating to our employees or job applicants.
Where we process Personal Information on behalf of our customers, the applicable details on the processing operations we undertake are set out in the relevant Data Processing Addendum (DPA) between us and the customer.
Personal Information You Provide Us
We receive and store any information you enter on our website or give us in any other way. When you contact us via the website or register to one of our events or webinars, we receive any information you provide us, for example:
- Information such as your name, address, email, job title, and telephone number which you provide to us through form submissions, events, feedback, and enquiries.
- Information you share with us as part of any event and webinar registrations.
- When you apply to join our ‘Partner Portal’, you provide us with the following information: your full name, country, state and city of residence, your email address and phone number, your place of employment and your job title. Following approval of your application we will also ask you to choose login details for your account, including a username and a password.
- When you contact us via the “Contact Us” form on our website, we collect the following information: your full name, email address, phone number, place of employment, job title, country of residence, and any other information you choose to provide us.
Personal Information We Collect
Like many websites, we also use ‘cookies’ and we obtain information when your browser accesses our website. For further information on cookies and similar tracking technologies please see our Cookies Policy.
Such information includes:
Marketing and Business Development
- Information about your use of our website, events, and webinars, including event and webinar registrations and white paper downloads, and including how you use our website to help us improve it. Examples of such information we collect and analyze include the Internet Protocol (IP) address used to connect your device to the Internet; login; e-mail address; password; access device and connection information such as browser type, version, and time zone setting, browser plug-in types and versions, operating system, and platform.
- If you register for a paid event that we sponsor, we will collect Personal Information related to you through trusted third-party providers and business partners hosting or organizing such events and we will not receive your payment information.
- Information about whether you want to receive marketing communications from us and what your communication preferences are.
- Information on how you interact with any of our emails or other communications, including if you have opened and engaged with such communications.
- Information we get from third parties, including event organizers, our partners, service providers, your colleagues, and publicly available information.
Sales, Finance, and Business Operations
- We provide services to customers, and you may be an employee or representative of those customers who is involved in some aspect in the relationship we have with our customer. In such case, we will collect information you, your company or our business partner provide us such as your name, address, email, job title, and telephone number so we can deliver our services, provide proposals during a sales cycle, and negotiate agreements, manage customer accounts, and process and fulfil orders.
- Information about training or the services we provide to you or to our customer.
- Information we collect as part of partner on-boarding, including information we obtain from third parties to complete on-boarding compliance checks.
- Information we collect to deliver support to our customers, including ticketing information and details of the support request.
- Information we obtain from you to improve our services.
- Information captured by our CCTV if you visit any of our premises, visitor logs and other information we collect to ensure our premises remain safe and secure.
- We may record calls, correspondence, and other communication channels, including screen capture, for compliance, quality, training, and other purposes.
- We may video record or screen capture training seminars, presentations, webinars for compliance, quality, training, and other purposes.
- Where we demonstrate our services and solutions to you, we may collect Personal Information related to you as part of a trial or test.
What Do We Do with Personal Information?
We use Personal Information related to you for the following purposes:
- to provide you with the website and the services.
- to provide you with notifications related to your use of the website and to send you marketing materials, via electronic newsletters, social media notifications or promotional emails.
- to solicit your feedback and provide support.
- to maintain the website and to continue developing and making it better.
We obey the law and expect you to do the same. If necessary, we will use Personal Information related to you to enforce our terms, policies, and legal agreements, to comply with court orders and warrants, and assist law enforcement agencies, to collect debts, prevent fraud, misappropriation, infringements, identity thefts and any other misuse of the website, and to take any action in any legal dispute and proceeding.
We commit to process Personal Information related to you solely for the purposes described in this policy.
Who do we Share Personal Information Related to You With?
We do not sell, rent, or lease Personal Information related to you.
We share Personal Information related to you with certain employees, as well as external consultants, within our corporate group, and with our affiliates, who are all governed by this policy. In addition, we also share Personal Information related to you with our business partners.
We share Personal Information related to you with our vendors worldwide and with third-party service providers which process Personal Information related to you on our behalf, for example:
- Marketing and Business Development. To deliver our marketing and business development campaigns we will share information with digital marketing providers, social media and advertising companies, market research partners, webinar hosts, venues, event organizers and registration providers, and other trusted vendors who assist in the performance of our marketing campaigns.
- Sales, Finance, Business Operations and Delivering Service. We use (a) third-party sales tools to track pipeline activity and order information, (b) finance and invoicing tools to assist in managing orders, customer billing and fulfillment, (c) legal and compliance tools to assist in our contracting and compliance activities, (d) consultants, contractors, and other specialists to provide professional services, and (e) other vendors which support our business operations.
Such vendors and service providers are contractually bound to keep Personal Information related to you confidential and appropriately secure.
A merger, acquisition or any other structural change will require us to transfer Personal Information related to you to another entity, as part of the structural change, provided that the receiving entity will comply with this policy.
We will share Personal Information related to you only subject to the terms of this policy, or subject to your prior consent.
Disclosure of Personal Information to Authorities
We will need to disclose Personal Information related to you, as we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our Affiliates; (f) to protect our rights, privacy, safety, interests or property, and/or that of our Affiliates, you or others; (g) if we are involved in any discussions related to the sale of all or part of our business; and, (h) to allow us to pursue available remedies or limit the damages that we may sustain.
Aggregated and Analytical Information
We use the standard analytics tools of Google Analytics, and we will use additional or other analytics tools, from time to time to learn about how you and other visitors use the website, in support of our website-related activities and operations.
We use anonymous, statistical, or aggregated information and will share it with our affiliates for legitimate business purposes. It has no effect on your privacy because there is no reasonable way to extract information from the aggregated information that we or others can associate specifically with you.
We will give you choices about the ways we use and share Personal Information related to you, and we will respect the choices you make.
We will send newsletters or promotional communications to our users. To unsubscribe to these communications, you will be required to click an “Unsubscribe” link in these emails and confirm the email address for which you would like to unsubscribe.
We collect and receive Personal Information related to you that we need for the purposes described in this policy. You can stop using the Service at any time, thereafter we will stop collecting Personal Information related to you. However, we will store and continue to use or make available certain Personal Information related to you as detailed above.
You may request a copy of the Personal Information related to you that we store about you by contacting us.
When we delete Personal Information related to you that we have collected from or about you, it will be deleted from our active databases, but we will keep a reasonable number of copies in our archives. Although we will deactivate your account, we will continue to retain the Personal Information related to you for legitimate business purposes as set forth above.
Some internet browsers offer a “do not track” or “DNT” signals to indicate your preference for tracking your activities on a service or through cross-site online activities. These features are varied with no uniform or common standard adopted yet by industry groups or regulators. Therefore, our Services do not currently respond to DNT signals. We continue to monitor developments around DNT technology and the implementation of a standard.
If you wish to exercise any of your rights in relation to Personal Information related to you, including exercising your choices or opt-out rights, please send us an email to: [email protected].
Your EU Data Subject Rights
If EU data protection laws apply to the processing of the Personal Information related to you by us, then the following terms apply:
In this section, the term “Personal information” will also include the term “personal data,” as defined under EU data protection laws.
Where we process Personal Information related to you when you visit our website, as a data controller, the processing is based on the following lawful grounds:
- All processing of Personal Information related to you which is not based on the lawful grounds indicated below, is based on your consent.
- We will process Personal Information related to you to comply with a legal obligation and to protect your and others’ vital interests.
- We will further rely on our legitimate interests, which we believe are not overridden by your fundamental rights and freedoms, for the following purposes:
- Communications with you in the following circumstances:
- Where you contact us through our website and other digital assets.
- After you had signed up to our marketing or newsletter via our website.After you, on behalf of your company, had signed up for any of our services.
- After you applied to a position at our company via our website.
- Cyber security.
- Support, customer relations, service operations.
- Fraud detection and misuse of the Service and website.
- Communications with you in the following circumstances:
In addition to your rights under other sections in this policy, you have the following rights:
- At any time, contact us if you want to withdraw your consent to the processing of Personal Information related to you. Exercising this right will not affect the lawfulness of processing based on consent before its withdrawal.
- Request to delete or restrict access to Personal Information related to you. We will review your request and use our judgment, pursuant to the provisions of applicable law, to reach a decision about your request.
- If you exercise one (or more) of the above-mentioned rights, in accordance with the provisions of applicable law, you may request to be informed that third parties that hold Personal Information related to you, in accordance with this policy, will act accordingly.
- You may ask to transfer Personal Information related to you in accordance with your right to data portability.
- You may object to the processing of Personal Information related to you for direct marketing purposes. Additional information about this right is available under the Choice section in this policy.
- You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affecting you.
- You have a right to lodge a complaint with a data protection supervisory authority of your habitual residence, place of work or of an alleged infringement of the GDPR (General Data Protection Regulation).
A summary and further details about your rights under EU data protection laws, is available on the EU Commission’s website available at: Rights for citizens | European Commission (europa.eu).
Note that when you send us a request to exercise your rights, we will need to reasonably authenticate your identity and location. We will ask you to provide us with credentials to make sure that you are who you claim to be and will further ask you questions to understand the nature and scope of your request.
If we need to delete Personal Information related to you following your request, it will take some time until we completely delete residual copies of Personal Information related to you from our active servers and from our backup systems.
If you have any concerns about the way we process Personal Information related to you, you are welcome to contact our privacy team at: [email protected]. We will look into your inquiry and make good-faith efforts to respond promptly.
Data Protection Officer(s) and EU Representative
Global. Our affiliated companies, where mandated by law or voluntarily, have designated Data Protection Officer (DPO).
Local DPO of Brazil: Our offices in Brazil, Located at Rua Ferreira Lima, 238, Florianópolis and in SCN Quadra 2 Bloco A, 190, 5º andar, Edifício Corporate Financial Center, Brasília has appointed Yaniv Benedykt as the local DPO.
For individuals in the European Economic Area (EEA): If the data controller processing your Personal Information is based outside the EEA, we have nominated our company located in 139-143 Omonias Ave. The Maritime Center, Limassol as our official representative within the EEA.
Specific Provisions for U.S. Residents
This section applies solely to all website visitors, users and others who reside within the United States of America (U.S.). We adopted this section to comply with U.S. state privacy laws, and any terms defined under U.S. state privacy laws will have the same meaning when used in this section. This chapter supersedes any contradicting provisions under the other sections of this policy.
We have collected the Personal Information related to you which is described above under the section “The Personal Information that We Collect and Store” of this Policy. Such Information consists of the following categories:
- Identifiers and Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
- Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with the website.
- Commercial information, including products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
- Geolocation data, namely your physical location or movements.
- Inferences drawn from any of the above-mentioned information.
We obtain the categories of Personal Information related to you listed above from the following categories of sources:
- Directly and indirectly from you and your activity on the website.
- Third parties such as reliable service providers.
We use the Personal Information related to you that we collect or receive for the purposes mentioned under the section “How We Use Personal Information Related to You?” of this Policy.
We disclose Personal Information related to you to third parties for business purposes as described above under the section titled “Information Sharing and Disclosure?”.
Sensitive Personal Information
We do not knowingly collect sensitive Personal Information, we do not collect or process sensitive Personal Information for the purpose of inferring characteristics about you, and we do not sell sensitive Personal Information or share sensitive Personal Information for cross-context behavioral advertising.
Selling and Sharing Personal information
We do not sell or share Personal Information. However, we engage third parties to provide us with services such as analytics, marketing automation and user experience and allow them to collect Personal Information on our Services and website.
We do not knowingly sell or share the Personal Information of consumers who are under 16 years of age.
The categories of Personal Information collected by these third parties in the preceding 12 months include identifiers, online activities and inferences drawn from such activities.
These third parties do not pay us for collecting such information, but the right granted to them to collect Personal Information may be considered as disclosure for the purpose of sale or sharing for cross-context behavioral advertising. At any time, you can opt-out of the collection of Personal Information by our service Providers by contacting us.
Your rights as a U.S. Resident
In addition to your rights under other sections under this policy, if you are a resident of California or any other applicable US State, you are entitled also to the following specific rights under the CPRA (California Privacy Rights Act) or other applicable US state consumer privacy acts, regarding Personal Information related to you:
- Access to specific Personal Information and data portability rights – you have the right to request that we disclose certain information to you about our collection and use of Personal Information related to you over the past 12 months. Upon verification of your request, we will disclose to you:
- The categories of Personal Information we collected about you;The categories of sources for the Personal Information we collected about you;Our business or commercial purpose for collecting that Personal Information;The categories of Personal Information that we disclosed for a business purpose, and the categories of third parties with whom we disclosed that particular category of Personal Information;The specific pieces of Personal Information that we collected about you;
- If we disclosed Personal Information related to you for a business purpose, we will provide you with a list which will identify the Personal Information categories that each category of recipient obtained.
- Deletion rights – you have the right to request that we delete any Personal Information related to you. Upon confirmation of your request, we will delete Personal Information related to you from our records, unless an exception applies.
- Non-discrimination – you also have a right not to be discriminated against for exercising your rights under U.S. state privacy laws.
Exercising Your Rights
To exercise the access, data portability, and deletion rights described above, please submit your request to us by sending an email message to: [email protected]. Only you or a person authorized to act on your behalf, may make a request related to Personal Information related to you. A request for access can be made by you only twice within a 12-month period.
The verifiable consumer request must provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative and describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with the requested Personal information if we cannot verify your identity or authority to make the request and confirm the Personal Information related to you. We will only use the Personal Information provided in your request to verify your identity or authority to make the request.
We will do our best to respond to your request within 30 days of its receipt. If we require more time (up to an additional 30 days), we will inform you of the reason and the extension period in writing. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
Any disclosures we provide will only cover the 12-month period preceding receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable.
We do not charge a fee to process or respond to your request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will inform you of the reasons for such a decision and provide you with a cost estimate before completing your request.
We will not require that you create an account in order to exercise your rights under this policy and we will not increase the cost, or decrease the availability, of our services based solely on the fact that you have chosen to exercise one of your rights under U.S. privacy laws.
After receiving our reply, you may appeal against our decision by contacting us. We will review your appeal and provide you with our answer and our explanation of the reasons for our decision(s) within 60 days of receiving it. We will also provide you with a link (to the extent available) where you may submit a complaint with the relevant Attorney General.
Personal Information Retention
We retain different types of Personal Information related to you for different periods, depending on the purposes for processing the information, our legitimate business purposes, and pursuant to legal requirements under applicable law.
We will maintain your contact details, to help us stay in contact with you. At any time, you can contact our privacy team at: [email protected] and request to delete your contact details. Note that we will keep your details without using them if necessary, and for the necessary period, for legal requirements and proceedings.
In any case, we will keep information about you for as long as you use the website, unless applicable law requires us to delete it, or if we decide to remove it at our discretion, according to the terms of this policy and ours Terms of Service.
Transfer of Information Outside Your Territory
We store and process information, including Personal Information, either directly or using third parties, such as data hosting service providers, in the United States and in the EU. The laws of the territories where Personal Information related to you will be stored and processed may differ from the laws of the jurisdiction in which you live.
If you are a resident in a jurisdiction where transfer of Personal Information related to you to another jurisdiction requires your consent, then you provide us your express and unambiguous consent to such transfer.
If you are located in the European Economic Area (EEA), note that we will transfer Personal Information related to you to other jurisdictions, which are not deemed to provide an adequate level of data protection. In such case, we will use appropriate safeguards, in particular, by way of entering the European Union (EU) Standard Contractual Clauses as amended from time to time with the relevant recipients, or by adhering to equivalent data transfer regulations to protect the security and confidentiality of such Personal Information. You can obtain a copy of the suitable safeguards that we use when transferring Personal Information as described above or receive further information about data transfer by contacting us at: [email protected].
If you are located in Brazil, Cognyte undertakes to only transfer personal data to countries that the Brazilian National Data Protection Authority (ANPD) decides to have an adequate level of protection. Alternatively, we will take effective measures to ensure that all recipients of personal data implement an adequate level of data protection, always to guarantee data security and the rights of data subjects.
We are committed to ensuring the security of Personal Information. We and our hosting services implement systems, applications, and procedures to secure Personal Information related to you, to minimize the risks of theft, damage, loss of information, or unauthorized access or use of information. These measures provide sound industry standard security.
However, please understand that no security system is impenetrable, and although we make efforts to protect your privacy, we cannot guarantee that the website will be immune from any wrongdoings, malfunctions, unlawful interceptions or access, or other kinds of abuse and misuse.
From time to time, we will update this policy.
If the updates have minor if any consequences, they will take effect 14 days after we post a notice on the website. Substantial changes will be effective 30 days after we initially posted the notice.
Until the new policy takes effect, if it materially reduces the protection of your privacy right under the then-existing policy you can choose not to accept it and terminate your use of the website. Continuing to use the website after the new policy takes effect means that you agree to the new policy. Note that if we need to adapt the policy to legal requirements, the new policy will become effective immediately or as required by law.
Please contact us at: [email protected]; or write to the following address:
Cognyte Software Ltd.
33 Maskit St., Herzliya, 4673333, Israel
We can only process requests received with sufficient information to enable us to process your request. We may need to request additional information in order to complete your request. If you do not provide sufficient information initially and do not respond to our request for additional information, we may be unable to complete your request. Please note that email communications are not always secure, so please do not include any sensitive information in your emails to us.