Last Updated: October 2023.
a. Customer Data: personal data (as defined in Section 1) that we collect, process, and manage on behalf of our business customers (the “Customers”) as a part of the Tufin solutions and services described on one or more applicable order forms and commercial agreements with the Customer (the “Solutions”).
b. User Data: personal data relating to our Customers’ internal focal persons who directly engage with Tufin concerning their organizational account, and users of the Services on behalf of such Customers, e.g., the account administrators and users, billing contacts and authorized signatories on behalf of the Customer (collectively, “Users”); as well as the Customer’s business needs and preferences, as identified to us or recognized through our engagement with them;
c. Prospect Data: personal data relating to visitors of our websites at www.tufin.com and www.tufinnovate.com, participants at our events, and any other prospective customer, user or partner (collectively, “Prospects”) who visits or otherwise interacts with our websites, online ads and content, emails or communications under our control (the “Sites” and collectively with the Solutions, the “Services”).
Specifically, this Policy describes our practices regarding:
1. Data Collection & Processing
2. Data Uses
You are not legally required to provide us with any personal data. If you do not wish to provide us with your personal data, or to have it processed by us or any of our Service Providers (as defined below), please do not provide it to us and avoid any interaction with us or with our Sites, or use our Services.
Types of personal data collected. We may collect or generate the following types of personal data about individuals through the Services:
● Usage, login credentials, and device information concerning Users and Prospects (connectivity, technical and aggregated usage data, such as user agent, IP addresses and approximate location based upon such IP addresses, digital identifiers, device data (like type, OS, device id, browser version, locale and language settings used), activity logs, session recordings, log-in credentials to the Services, the cookies and pixels installed or utilized on their device, and inferred or presumed data on generated from their use of the Services);
● Information concerning our Customers, Users and Prospects (contact and business details such as name, email, phone number, position, workplace and related business insights, our communications with such individuals (correspondences, sensory information including call and video recordings, and transcriptions and analyses thereof), feedback and testimonials received, contractual and billing details, as well as any expressed, presumed or identified needs, preferences, attributes and insights relevant to our potential or existing engagement).
● Personal data contained in Customer Data which is provided by our Customers or processed on their behalf and under their instruction and in accordance with the data processing addendum with them. Such data may include any of the types of personal data described above with respect to Users or other individuals whose data is contained in the Customer Data (e.g., Customer’s end-users).
● Data collected directly from you. You may provide us with your personal data, e.g., when you submit a form on our website, during an event, conference, or webinar you have participated in or during our commercial engagement with you.
● Data collected from third parties. We obtain personal data from third parties, such as our Customers or Service Providers. For example, we may get your details from your employer (which is our Customer) as a part of our commercial engagement. We may also obtain personal data from our Service Providers, e.g., marketing and sales tools, data enrichment services, our sales and marketing partners, distributors, job recruiters, or your colleagues.
● Data that is automatically generated. Some personal data is automatically generated when you visit our website (such as your online activity, clicks, web-pages visits, etc.) by using Cookies and the data collection technologies described in Section 6 below. We may also collect aggregated or technical data generated when you use our Services, relating to how you use them, so we could learn how Users use our Services and improve them and our users’ experience.
We use personal data for the following purposes (and in reliance on the legal bases for processing noted next to them, as appropriate):
User personal data
● To facilitate, operate, enhance, and provide our Services (Performance of Contract with our Customers, to the extent applicable; Legitimate Interests to provide and improve our Services);
● To provide assistance and support, to test and monitor the Services, or diagnose or fix technology problems (Performance of Contract with our Customers, to the extent applicable; Legitimate Interests to ensure the ongoing availability of our Services);
● To personalize our Services, including by recognizing an individual and remembering their information when they return to our Services, and to provide further localization and personalization capabilities (Performance of Contract with our Customers, to the extent applicable; Legitimate Interests to provide a better user experience);
User and Prospect personal data
● To gain a better understanding on how individuals use and interact with our Services, which content and data they have processed through our Services, and how we could improve their and others’ user experience and the value they can generate from using the Services, so we could continue improving our products, offerings and the overall performance of our Services (Legitimate Interests to improve the user experience and performance of our Services);
● To contact our Customers, Users and Prospects with general or personalized service-related messages, as well as promotional messages that may be of specific interest to them (Performance of Contract with our Customers, to the extent applicable; Legitimate Interests to send service-related messages; Consent to receive marketing messages);
● To support and enhance our data security measures, including for the purposes of preventing and mitigating the risks of fraud, error or any illegal, criminal or prohibited activity (Performance of Contract with our Customers, to the extent applicable; Legitimate Interests to secure our services; Legal Obligation to implement appropriate security measures);
● To create aggregated statistical data, inferred non-personal data, or anonymized or pseudonymized data (rendered non-personal and non-identifiable), which we or our business partners may use to provide and improve our respective services, or for any other purpose (Legitimate Interests to improve and enhance our Services);
● To facilitate and optimize our marketing campaigns, ad management and sales operations, and to manage and deliver advertisements for our products and services more effectively, including to provide personalized ads and share data with our authorized service providers to support such activity. (Legitimate Interests to enhance engagement with our Services and promote them; Consent (including by using Cookies) to use and share personal data with specific third-party service providers to provide personalization of ads);
● To facilitate, sponsor and offer certain events, contests and promotions (Legitimate Interests to enhance engagement with our Services);
● To enforce our Terms & Conditions, to resolve disputes, to carry out our obligations and enforce our rights, and to protect our business interests and the interests and rights of third parties (Legitimate Interests to dispute resolutions);
● To comply with our contractual and legal obligations and requirements, and maintain our compliance with applicable laws, regulations and standards (Performance of Contract with our Customers, to the extent applicable; Legitimate Interests to maintain and improve our compliance; Legal Obligation, to the extent applicable).
We and our authorized Service Providers maintain, store and process personal data in the United States of America, Israel, European Union, and in other locations as reasonably necessary for the proper delivery and performance of our Services, or as may be required by law.
Tufin is headquartered in Israel, which is considered by the European Commission, the Swiss Federal Data Protection and Information Commissioner (FDPIC) and the UK Secretary of State to be offering an equally adequate level of protection for the personal data of residents of the EEA, Switzerland and the UK, respectively. We transfer personal data from the EEA, Switzerland and the UK to Israel on this basis. For data transfers from the EEA, Switzerland or the UK to countries which are not considered to be offering an adequate level of data protection (including to our US entity – Tufin Software North America Inc.), we and the relevant data exporters and importers have entered into Standard Contractual Clauses as approved by the European Commission, FDPIC and UK Information Commissioner’s Office (ICO). We will be liable in cases of onward transfers of your personal data to third parties (including our Service Providers). You can obtain a copy by contacting us as indicated in Section 11 below.
Tufin complies with the EU-US Data Privacy Framework (EU-US DPF), the UK Extension to the EU-US DPF, and the Swiss-US Data Privacy Framework (Swiss-US DPF) as set forth by the US Department of Commerce.
Tufin has certified to the US Department of Commerce that it adheres to the EU-US Data Privacy Framework Principles (EU-US DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-US DPF, and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-US DPF.
Tufin has certified to the US Department of Commerce that it adheres to the Swiss-US Data Privacy Framework Principles (Swiss-US DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-US DPF.
If there is any conflict between the terms in this policy and the EU-US DPF Principles and/or the Swiss-US DPF Principles, the Principles shall govern for personal data transferred under the DPF. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.
We retain personal data for as long as we deem it as reasonably necessary in order to maintain and expand our relationship and provide you with our Services and offerings; in order to comply with our contractual obligations; or to protect ourselves from any potential disputes (i.e. as required by laws applicable to log-keeping, records and bookkeeping, and in order to have proof and evidence concerning our relationship, should any legal issues arise following your discontinuance of use), all in accordance with our data retention policy.
To determine the appropriate period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and the applicable legal requirements.
If you have any questions regarding our data retention practices, please contact us by email at email@example.com.
We disclose personal data in the following ways:
● Service Providers: We may engage selected third-party companies and individuals to perform services on our behalf or complementary to our own. Such service providers include hosting and server co-location services, communications and content delivery networks (CDNs), data security services, billing and payment processing services, fraud detection and prevention services, web and product analytics, e-mail distribution and monitoring services, session or activity recording services, remote access services, content transcription and analysis services, performance measurement, data optimization and marketing services, social and advertising networks, content and data enrichment providers, event production and hosting services, e-mail, voicemails, support, enablement and customer relation management systems, and our legal, financial and compliance advisors (collectively, “Service Providers“). Our Service Providers may have access to personal data, depending on each of their specific roles and purposes in facilitating and enhancing our Services, and may only use the data as determined in our agreements with them.
● Legal Compliance: We may disclose or allow government and law enforcement officials access to your personal data in response to a legal request, such as a subpoena, search warrant or court order (or similar requirement), or in compliance with applicable laws and regulations, with or without notice to you. Such disclosure or access may occur if we believe in good faith that: (a) we are legally compelled to do so; (b) disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing; or (c) such disclosure is required to protect our legitimate business interest, including the security or integrity of our products and Services.
● Sharing Personal Data with our Customers: We may share Users’ personal data with their affiliated organization, or the organization to which systems (powered by Tufin’s Solutions) they attempted to access.
In certain cases, other Users from your organization may control your account and will be entitled to monitor, process and analyse your data and associated content, including (i) view any content you submit and your activities on the Services; (ii) view statistics regarding your account; (iii) change your account password or other access credentials or privileges; (iv) suspend or terminate your account access; and (v) access or retain data stored as part of your account. Please note that in these circumstances Tufin is not responsible for and does not control any further disclosure, use or monitoring by or on behalf of your organization, that acts as the “Data Controller” of such data (as further described in Section 10 below).
● Protecting Rights and Safety: We may share your personal data with others, if we believe in good faith that this will help protect the rights, property or personal safety of Tufin, any of our Visitors, Customers, Users or Prospects, or any members of the general public.
● Additional Sharing: Tufin may share your personal data in additional manners, pursuant to your explicit approval, or if we are legally obligated to do so, or if we have successfully rendered such data non-personal and anonymous. Additionally, we may transfer, share or otherwise use non-personal data at our sole discretion and without the need for further approval.
Cookies are packets of information sent to your web browser and then sent back by the browser each time it accesses the server that sent the cookie. Some cookies are removed when you close your browser session. These are the “Session Cookies”. Some last for longer periods and are called “Persistent Cookies”. We use both types.
Some cookies are necessary for the Services to function properly, and cannot be declined or disabled unless you delete and block them through your web browser settings. Other cookies, which are used for functional, performance, analytics and marketing purposes, are optional. These include web and app analytics tools and tools that provide us with insights on the performance of our ads and campaigns.
You can also opt-in to or opt-out from the use of optional cookies through the “Cookie Settings” feature available on our website. If you choose to opt-out of certain cookies, this will typically generate a new cookie which will preserve your choice, and indicate it to our Services in your next visits so that the cookies you opted-out of will not be utilized. You can also manage your cookies preferences, and accept, remove or entirely block cookies, through your browser settings. Please note that certain web browsers may transmit “Do Not Track” signals to websites with which the browser communicates, telling the website not to follow its online movements. Because of differences in how web browsers interpret this feature and send those signals, and lack of standardization, we currently do not respond to such “Do Not Track” signals.
Please note that if you get a new device, install a new browser, erase or otherwise alter your browser’s cookie file (including upgrading certain browsers), you may also clear the opt-out cookies installed once you opt-out, so an additional opt-out will be necessary to prevent additional tracking.
Service Communications: Tufin may contact you with important information regarding our Services. For example, we may notify you (through any of the means available to us) of changes or updates to our Services, billing issues, service maintenance or changes, password retrieval notices, etc. You will not be able to opt-out of receiving such service communications while using our Services, as they are integral to such use.
Notifications and Promotional Communications: We may send you notifications concerning new features, offerings, events, and special opportunities or any other information we think you will find valuable. We may provide such notices through any of the contacts means available to us (e.g., phone, mobile or email), through the Services, or through our marketing campaigns on any other websites or platforms.
If you do not wish to receive such promotional communications, you may notify us at any time by sending an email to firstname.lastname@example.org or by following the “unsubscribe”, “stop” or “change email preferences” instructions contained in the promotional communications you receive.
Tufin and its Service Providers implement systems, applications, and procedures to secure your personal data, 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 be aware that regardless of any security measures used or implemented, we cannot and do not guarantee the absolute protection and security of any personal data stored with us or with any third parties.
Individuals have rights concerning their personal data. Please contact us by e-mail at: email@example.com if you wish to exercise your privacy rights under any applicable law, including the EU or UK General Data Protection Regulation (GDPR), the Swiss Federal Act on Data Protection (FADP), or the California Consumer Privacy Act (CCPA) as amended from time to time, the Virginia Consumer Data Protection Act (VCDPA), the Colorado Privacy Act (CPA) and other similar US State Laws. Such rights may include – to the extent applicable – the right to know/request access to (specific pieces of personal data collected; categories of personal data collected; categories of sources from whom the personal data was collected; purpose of collecting personal data; categories of third parties with whom we have shared personal data), to request rectification or erasure of your personal data held with Tufin, or to restrict or object to such personal data’s processing (including the right to direct us not to sell your personal data to third parties now or in the future), or to port such personal data, or the right to equal services and prices (e.g. freedom from discrimination) (each to the extent available to you under the laws which apply to you). If you are a GDPR-protected individual, you also have the right to lodge a complaint with the relevant supervisory authority in the EU or the UK, as applicable.
When you ask us to exercise any of your rights, we may need to ask you to provide us certain credentials to make sure that you are who you claim you are, to avoid disclosure to you of personal data related to others and to ask you to provide further information to better understand the nature and scope of data that you request to access. If your request relates to personal data contained in Customer Data (i.e., personal data we process on our Customer’s behalf as its “data processor” or “service provider”, as further explained in Section 10 below), such Customer exclusively determines how the data may be processed, as well as if and how your request should be handled – so we advise that you submit your request directly to them. We may not be able to fulfill your request unless you have provided sufficient information that enables us to reasonably verify that you are the individual about whom we collected the personal data, and if such data is processed on behalf of any of our Customers – to which Customer it particularly relates, so that we may forward it to them for their further handling. Such additional information may be then retained by us for legal purposes (e.g., as proof of the identity of the person submitting the request, or proof of request fulfillment). We may redact from the data which we will make available to you, any personal data or confidential information related to others.
In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, Tufin commits to resolve DPF Principles-related complaints about our collection and use of your personal information. EU and UK individuals and Swiss individuals with inquiries or complaints regarding our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF should first contact Tufin at firstname.lastname@example.org.
Additionally, in compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, Tufin commits to cooperate and comply respectively with the advice of the panel established by the EU data protection authorities (DPAs) and the UK Information Commissioner’s Office (ICO) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF.
Please note that under certain conditions (as described under the DPF Principles) you can invoke a binding arbitration by delivering a notice to Tufin via email@example.com. Please also note that Tufin is being subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).
Certain data protection laws and regulations, such as the EU GDPR, UK GDPR, the FADP and CCPA, typically distinguish between two main roles for parties processing personal data: the “Data Controller” (or under the CCPA, the “Business”), who determines the purposes and means of processing; and the “Data Processor” (or under the CCPA, the “Service Provider”), who processes the data on behalf of the Data Controller. Below we explain how these roles apply to our Services and Solutions, to the extent that such laws and regulations apply.
Tufin is the “Data Processor” of Customer Data. Such data is being processed by Tufin on behalf of the Customer (who is the “Data Controller” of such data; and our Service Providers who process such Customer Data on our behalf are the “sub-processors of such data). Accordingly, Tufin processes Customer Data strictly in accordance with our Customer’s reasonable instructions and as further stipulated in our data processing addendum and other commercial agreement with such Customer.
Our Customers are solely responsible for determining whether and how they wish to use our Services, and for ensuring that all individuals using the Services on the Customer’s behalf or at their request, as well as all individuals whose personal data may be included in Customer Data processed through the Services, have been provided with adequate notice and given informed consent to the processing of their personal data, where such consent is necessary or advised, and that all legal requirements applicable to the collection, recording, use or other processing of data through our Services are fully met by the Customer, including specifically in the context of an employment relationship. Our Customers are also responsible for handling data subject rights requests under applicable law, by their Users and other individuals whose data they process through the Services.
Requirements under US State Privacy Laws: This policy describes the categories of personal information we may collect and the sources of such information (in Section 1 above), and our retention (Section 4) and deletion practices (Section 9). We also included information about how we may process your information (in Sections 2 through 7), which includes for “business purposes” under the California Consumer Privacy Act (CCPA), as amended/Virginia Consumer Data Protection Act (VCDPA)/Colorado Privacy Act (CPA) and similar state laws, as applicable. We do not sell or “share” your personal information for the intents and purposes of the CCPA or CPRA, nor disclose personal information that we “control” to any third party for their direct marketing purposes. We may disclose personal data to third parties or allow them to collect personal data from our Services as described in Section 5 above, if those third parties are our Customers (with respect to Customer Data processed on their behalf), or our authorized Service Providers or business partners who have agreed to our contractual limitations as to their retention, use, and disclosure of such personal data, or if you integrate the services of third parties with our Services, or direct us to disclose your personal data to third parties, or as otherwise described in Section 5 above. You may also designate, in writing or through a power of attorney, to request to exercise your privacy rights on your behalf. The authorized agent may submit a request to exercise these rights be emailing us. Note that we will not discriminate against you by withholding our Services from you or providing a lower quality of service to you for requesting to exercise your rights under the law. If you have any questions or would like to exercise your rights under the CCPA/CPRA/VCDPA/CPA or other similar state laws, you can contact firstname.lastname@example.org or our DPO at email@example.com.
Children’s Privacy: Our Services are not intended for use by children under the age of 18. We do not knowingly collect personal data from minors under the age of 18 and do not wish to do so. In the event that it comes to our knowledge that a minor is using the Services, we will prohibit and block such user from accessing the Services (to the extent reasonably possible) and will make all efforts to promptly delete any personal data stored with us with regard to such user.
EU Representative: Tufin has designated Tufin Software Germany GmbH as its representative in the European Union, for data protection matters pursuant to Article 27 of the GDPR. Tufin Software Germany GmbH may be contacted only on matters related to the processing of personal data. To make such an inquiry, please send an email to firstname.lastname@example.org.
UK Representative: Tufin has designated Prighter as its representative in the United Kingdom for data protection matters pursuant to Article 27 of the UK GDPR. Inquiries regarding our UK privacy practices may be sent to: Prighter (Attn: Tufin), Kemp House 160 City Road, EC1V 2NX, London, United Kingdom.