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:
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:
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.
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 product enablement, product use notifications, training and support only
|Email Headers||Triage, analysis, and phishing campaign detection
– Data used to identify phishing campaigns related to employee phishing reports and to triage employee phishing reports as malicious/spam/benign/simulation.
|Email Content||Triage and analysis
– Data used to triage employee phish reports as malicious/spam/benign/simulation and to analyze malicious content in phishing campaigns.
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.
|Personal Data||Who has Access||Purpose of Access|
|Customer contact info for product admins and users||Customers||Granting and managing access to their own 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 and phish campaign content||Customers||Security administration and operations|
|Email message header data and phishing campaign content||Agari Employees – Sales Administration, Licensing Operations, Engineering and Support staff only||Providing message trust scores and general product support and operations|
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 -
Customer email message metadata 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 email message data 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.
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 at rest.|
|Email message headers, content, attachment filenames, and URIs*||Encrypted in transit and 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.
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 premises (within the enterprise’s internal network) or by Agari (hosted sensors).
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
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.|
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 attachments, which are reported to APR as potentially malicious email content, to its third-party security service providers Virus Total, LastLine, and CrowdStrike Hybrid Analysis 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 attachments as noted above) to these third-party security service providers.
Agari utilizes third party cloud hosting provider Amazon Web Services (AWS) to provide a highly secure and reliable cloud platform. Agari’s service is hosted within the AWS North America Region. For information regarding AWS compliance/certification please refer to documentation online at https://aws.amazon.com/compliance.
Agari utlizes Pendo (www.pendo.io) Product Analytics to enhance the usability of our products. Although Pendo’s cloud service has no access to our customers’ data, it can see the usernames (email addresses) of our customer users who have access to our web applications. Pendo’s data centers are US based and their GDPR Process and Approach is available online.
AWS SOC reports can be requested through a Business Development representative if they are not publicly available for download.
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:
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.
Per sections 5 and 7 of this document, 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 firstname.lastname@example.org.