Last Updated: May 10, 2021

At Agari, we care about our customers’, employees’, and end-users’ privacy, and have implemented a series of processes, policies, and measures to comply with the General Data Protection Regulation (GDPR). This Privacy Data Sheet describes the processing of personal data (or personally identifiable information) by Agari’s Phishing Response service in the provision of such services to its enterprise customers.

When providing Agari’s services to customers, we are processing their staff’s personal data on behalf of such customers and are therefore acting as data processor. We have set up the following mechanisms, processes and policies, to comply with the GDPR:

Overview of Agari Phishing Response™ Capabilities

Agari Phishing Response provides an end-to-end automated phishing playbook that integrates with Microsoft Office 365 to handle employee phishing reports, triage them, discover similar phishing campaign emails, perform forensic analysis, and then automate the remediation process. Agari has established detailed policies and procedures illustrating its data flows and processing practices and we document any decision-making reasoning relating to personal data. This includes:

  • Internal data protection policies, including details of:
      • Categories of processing carried out per controller
      • Applicable processing purposes
      • Data sharing and data retention practices
      • Security measures
  • Staff training
  • Annual internal audits of processing activities

The following paragraphs describe which personal data Agari Phishing Response processes to deliver its services, the location of that data and how it is secured in accordance with privacy principles, laws and regulations.

1 Personal Data Processing

Agari Phishing Response™
The table below lists the personal data used by Agari Phishing Response to carry out its services and describes why Agari processes such data.

Personal Data Purpose of Processing
Customer contact info for product admins and users Creating an account

  • Data collected are for customer product enablement, product use notifications, training and support only
Email "mail from" header Message scoring

  • Data used to determine the authenticity and reputation of the underlying identity assertion
Email Friendly From header Message scoring

  • Data used to determine the authenticity and reputation of the underlying identity assertion
Email “rcpt to” header/Email Friendly To header Message scoring

  • Data used to determine the authenticity and reputation of the underlying identity assertion
Email subject Message scoring

  • Data used to assist in message identification, these data can be suppressed at the customer’s discretion.
Email Attachment Filename (1) Message scoring

  • Data used to assist in message identification and threat classification, these data can be suppressed at the customer’s discretion.
Uniform Resource Identifier (URI) (2) Message scoring

  • Data used to assist in message identification and threat classification and can be used to improve Agari services. This data access to Agari can be suppressed at the customer’s discretion.
Email Attachment Metadata (file format and presence of macros/malicious code) Message scoring

  • Data used to determine the authenticity and reputation of the underlying identity assertion
Email Attachment Hash (e.g. encrypted MDS or SHA1 format) Message scoring

  • Data used to determine the authenticity and reputation of the underlying identity assertion
IP addresses Message scoring

  • Data used to determine the authenticity and reputation of the underlying identity assertion
Email Attachment (1) All Email Attachments

  • Triage and analysis - Email Attachment is processed to triage email as malicious/span/benign/simulation.

Malicious Email Attachments

  • If Agari detects any potential malicious content within a Customer email, Agari tags that Customer email’s Email Attachment as malicious (“Malicious Email Attachment”). Agari will further process, analyze and store the Malicious Email Attachment to provide the Service subject to the Data Retention provisions in Section 4 below. For clarity, Agari does not store Email Attachments of customer emails that Agari has not tagged as malicious.
Email Content (3) All Email Content

  • Triage and analysis - Email Content is processed to triage email as malicious/spam/benign/simulation.

Malicious Email Content

  • If Agari detects any potential malicious content within a Customer email, Agari tags that Customer email’s Email Content as malicious content (“Malicious Email Content”). Agari will further process, analyze and store the Malicious Email Content to provide the Service subject to the Data Retention provisions in Section 4 below. For clarity, Agari does not store Email Content of customer emails that Agari has not tagged as malicious.

(1) - If attachment analysis is enabled
(2) - If URI analysis is enabled
(3) - If Email Content analysis is enabled

Customer Support Data
Agari may receive and process PII that is provided by an Agari customer when they make a support request to Agari (“Customer Support Data”). Agari only processes this data to assist the customer in resolving the issue and to improve Agari’s services and customer support function.

Outside of the necessary requester contact information, Agari does not intentionally collect or process PII via a customer support request. Agari instructs customers to provide the minimum amount of personal data necessary to adequately provide the support request. Nonetheless, a customer may provide unsolicited personal data in the request or supporting attachments.

Personal Data Purpose of Processing
Customer Support Data
The below is representative though not exhaustive list of the information a customer may provide to Agari in a support request that may contain PII: name, email address, phone number of employee making request, authentication information (not including passwords), information regarding support issue, software and/or hardware configuration files provided to enable support request, error-tracking files)
  • Provide customer support
  • Review and improve the quality of customer support service
  • Improve Agari Services
Customer Support Case Attachment
The below is representative though not exhaustive list of the information a customer may provide to Agari in a support request that may contain PII: device configuration, command line interface , product identification numbers, serial numbers, host names, sysDescr (has device location), IP addresses, operating system (OS) feature sets, OS software version, browser type and version, hardware version, installed memory, installed flash, boot versions, MAC address
  • Provide customer support
  • Review and improve the quality of customer support service
  • Improve Agari Services

2 Cross Border Transfers

When a new customer purchases a subscription to Agari Phishing Response, that customer’s information (both the data relating to the customer’s employees who are in contact with Agari to procure and administer the products on behalf of customers and the data processed through Agari’s provision of its services to customers) is always created, processed, and stored in North America.

Agari Phishing Response is hosted at Amazon Web Service’s US-West 2 (OR) Cloud Region and is deployed in an active-active manner across 3 separate Availability Zones. For information regarding AWS compliance/certification please refer to documentation online at https://aws.amazon.com/compliance. Certifications and SOC reports are listed on this webpage and corresponding links under “Assurance Programs”.

For information regarding GDPR impacts to cross border data transfers, please see the section on GDPR.

3 Access Control

Personal Data Who has Access Purpose of Access
Customer contact info for product admins and users Customers Granting and managing access to their own Agari Phishing Response account.
Customer contact info for product admins and users Agari Employees – Sales Administration, Licensing Operations, Engineering and Support staff only Creating an account and validating license entitlements and general product support and operations
Email message header data, attachment file names, URIs, IP addresses, Email Attachments and Email Content Customers Security administration and operations
Email message header data, attachment file names, URIs, IP addresses, Malicious Email Attachments and Malicious Email Content Agari Employees – Sales Administration, Licensing Operations, Engineering and Support staff only Providing message trust scores and general product support and operations
Customer Support Data Customers Submitting customer support requests
Customer Support Data Agari Employees – Sales Administration, Licensing Operations, Engineering and Support staff only Providing customer support

4 Data Retention

Customer Account Data -

Customer account data is retained for as long as customer is an active Agari Phishing Defense customer. In the event that a customer terminates its subscription, Agari will retain such Customer Account Data until customer requests in writing that Agari removes all stored contact information, including potential PII, from all instances of Agari’s product and customer relationship management platforms.

Email Message Meta-Data, Malicious Email Attachments and Malicious Email Content -

Customer Email Message Metadata (which includes Email “mail from” header, Email Friendly From header, Email “rcpt to” header/Email Friendly To header, Email Subject, Email Attachment Filename (if enabled), Uniform Resource Identifier (URI) (if enabled), Email Attachment Metadata, IP addresses, and Email Attachment Hash), Malicious Email Attachments (if enabled) and Malicious Email Content (if enabled) is retained for scoring and reporting purposes and is expired out of Agari’s “active” data stores  is retained for scoring and reporting purposes and is expired out of Agari’s “active” data stores after 60 days. In the event that a customer terminates its subscription, customer can request in writing that Agari removes all stored data in this category from all instances of Agari’s application and backup systems, failing this, Agari effect such removal within 30 days following termination of the Customer subscription.

Customer Support Data - 

Support Data is retained for as long as the customer is an active Agari Brand Protection customer. In the event a customer terminates their subscription, Agari will retain Customer Support Data until the customer requests in writing that Agari remove all Customer Support Data, including potential PII from Agari systems and third party customer support platforms, or, if earlier, within a period of 30 days following termination of the Customer subscription. Agari retains related support data as necessary to ensure support of recurring issues and to comply with audit policies related to business records of services provided to customers.

5 Personal Data Security

Agari has governance measures in place, and has built its processing practices around the principles of data protection by design and by default. This includes: data minimization, pseudonymization (where possible), allowing end-users to monitor the processing, and enhanced and up-to-date security features, such as encryption, confidentiality, integrity, resilience of processing systems, and ability to restore personal data in a timely manner in the event of an incident. Agari’s technical and organizational measures and risk mitigation plans are audited, tested and re-evaluated on an annual basis to ensure the appropriateness of its systems, networks, and business practices on an ongoing basis. Agari has disaster recovery procedures set up to restore personal data in case of any security incident.

Personal Data Type of Encryption
Customer contact info for product admins and users Encrypted in transit and encrypted at rest.*
Email Message Metadata, Malicious Email Attachments (if enabled), and Malicious Email Content (if enabled)* Encrypted in transit and encrypted at rest.*
Customer Support Data Encrypted in transit and encrypted at rest.*

* Encryption is provided using then current best practices as defined by Amazon Web Services.

Agari will notify its customers without undue delay after learning of a data breach, if required by law, and has mechanisms by which it can detect and report data breaches.

6 Agari Phishing Response data ingest process

Agari Phishing Response provides unprecedented insight into the traffic coming into your enterprise. To realize this value, customers configure their Secure Email Gateways to copy all incoming messages to the Agari Phishing Response sensor. The sensor component receives the full email message including the body and any attachments present. The sensor extracts the metadata (email headers), attachment filenames, and URIs, forwards these into the Agari Phishing Response pipeline, and then deletes the message. The sensor can be hosted either on Customer premises (within the customer enterprise’s internal network) or by Agari (hosted sensors).

On Premises Sensor

Customers have complete control over the sensor including full “root” level access to the operating system and host application. Agari employees cannot access an On Premises sensor without the permission of the customer

Hosted Sensors

Agari Phishing Response hosted sensors are provisioned in a dedicated and separate Amazon Web Services account. Hosted sensors are not “multi-tenant.” Each customer gets their own Virtual Private Cloud (VPC), their own Elastic Load Balancer (ELB), and their own EC2 Autoscale Group (ASG). The underlying AWS IaaS is multi-tenant. Agari engineers cannot access the hosted sensor EC2 instances using the root account, and only a subset of Agari engineers have access to the hosted sensor environment. All hosted sensor actions are logged locally and can be reviewed with the customer.

Agari Phishing Response can also receive information about email threats by reporting from within the organization using a plug-in to their email client such as the “Report Message add-in for MicrosoftOffice365” In such cases, the entire email message is forwarded to Agari.

Personal Data Type of Encryption
Email message While being processed by an Agari hosted sensor, all message data is encrypted both in transit and at rest using encrypted Elastic Block Storage (EBS) volumes.

7 Third Party Service Providers

Agari’s agreements with its sub-processors reflect the obligations and commitments it has and makes to its customers. Agari conducts prior due diligence on sub-processors before contracting with them.

Agari may provide URLs and Malicious Email Attachments to its third-party security service providers Bitdefender, Crowdstrike Hybrid Analysis, DomainTools, Neustar, RiskIQ and Virus Total in order to provide additional security analytics as part of the Service. In the APR portal, Customers have the ability to opt-out of disclosing this data to those third-party security service providers at any time. For clarity, Agari never provides the email body content of emails (except any URLs and Malicious Email as noted above) to these third-party security service providers.

The below table lists Agari’s third party sub-processors that may process Customer personal information.

Sub-processor Potential Customer Data Processed Purpose of Processing Data Center Location Link to Security / Privacy Program
Amazon Web Services Any Customer Data provided to Agari Data Center for all Services North America https://aws.amazon.com/compliance
Datadog Customer contact information Product Logging, Monitoring and Performance Platform United States https://www.datadoghq.com/security/
Sentry Customer contact information Product Performance Logging, Monitoring and Analytics United States https://sentry.io/security/
Pendo Customer email addresses Product Usage and Feedback United States https://www.pendo.io/data-privacy-security/
Salesforce Customer contact information Customer Relationship Management (CRM) United States https://trust.salesforce.com/en/
ZenDesk Customer contact information Support Ticket Platform United States https://www.zendesk.com/company/privacy-and-data-protection/
Microsoft Office365 Customer contact information Support Ticket processing and communication United States https://www.microsoft.com/en-us/trust-center/privacy
Slack Customer contact information Support Ticket processing and communication United States https://slack.com/trust
Gainsight Customer contact information Customer Success platform United States https://www.gainsight.com/security/
https://www.gainsight.com/policy/
Bitdefender URI and Malicious Email Attachments (if enabled) Security Service Provider United States https://www.bitdefender.com/site/view/legal-privacy.html
Crowdstrike URI and Malicious Email Attachments (if enabled) Security Service Provider United States https://www.crowdstrike.com/why-crowdstrike/crowdstrike-compliance-certification/
Domain Tools URI and Malicious Email Attachments (if enabled) Security Service Provider United States https://www.domaintools.com/company/privacy-policy
Neustar URI and Malicious Email Attachments (if enabled) Security Service Provider United States https://www.home.neustar/privacy/gdpr-what-you-need-to-know
RiskIQ URI and Malicious Email Attachments (if enabled) Security Service Provider United States https://www.riskiq.com/privacy-policy/
Virus Total/td> URI and Malicious Email Attachments (if enabled) Security Service Provider United States https://support.virustotal.com/hc/en-us/articles/115002168385-Privacy-Policy

cp privacy datasheet

AWS SOC reports can be requested through a Business Development representative if they are not publicly available for download.

8 GDPR (General Data Protection Regulation)

Agari’s relationship with controllers

In providing the Agari services, Agari only processes personal data upon the documented instructions of its customers. To that end, Agari has template data processing agreements ready for use with its customers, which include the following provisions:

  • Subject matter and duration of processing
  • Nature and purpose of processing
  • Type of personal data and category of data subject in question
  • Obligations and rights of our customers (as data controllers).

Agari imposes confidentiality obligations on its authorized personnel who process the personal data. Agari has implemented measures to assist its customers in complying with data subjects’ rights and requests.

Data Transfers to countries outside the EEA

We share data both with our affiliated companies within the Agari group and certain external third parties who are based outside the European Economic Area (“EEA”). Any such processing will involve an export of data outside of the EEA. We endeavor to ensure that people to whom we provide personal data hold it subject to appropriate safeguards and controls. Whenever we transfer our customers’ employees’ personal data out of the EEA to countries that have not been deemed to provide an adequate level of protection for personal data by the European Commission, we ensure a similar degree of protection is afforded to it by implementing the following safeguards:

For example, our cloud storage provider is Amazon Web Services and we have entered into GDPR-compliant data processing terms, which incorporate by reference Model Contractual Clauses.

Based on Agari’s understanding of GDPR, in consultation with other large, multinational organizations doing business in the EU, data containing personal data as defined by GDPR, including email addresses of individuals, may lawfully be transferred and reside outside the EEA for the purposes of processing such data to legitimately protect their organizations from cyberattacks.

It is Agari’s belief and assumption that it meets all current applicable data protection requirements as laid out by the GDPR for the purposes of cross border transfers of personal data.

For further information on Agari’s data protection practices, please contact privacy@agari.com.