Last Updated: April 25, 2018
Agari Data, Inc., a Delaware corporation (“Agari”) is committed to protecting your privacy. By accessing the
Agari respects your privacy and is committed to protecting your Personal Data. We want to be transparent with you
about how we collect and use your Personal Data in making available our website(s) (“Site
designed to describe:
meet our duties of Transparency under the “General Data Protection Regulation
Who we are and how to contact us
Who we are
Agari Data, Inc. is the Controller (for the purposes of the GDPR) of your Personal Data (referred to as either
“Agari”, “we”, “us” or “our” in this Privacy
Our address is: 950 Tower Lane, Foster City, CA, 94404, USA.
The Agari group of companies is made up of different legal entities, including one based in the UK, called Agari
Data UK Ltd. Agari Data UK Ltd’s address is Venture House, 2 Arlington Square, Downshire Way, Bracknell, RG12
How to contact us
You can contact us by emailing: email@example.com.
Your rights relating to your Personal Data
By law you have the right to:
How to exercise your rights
If you want to exercise any of the rights described above, please contact us at: firstname.lastname@example.org.
Typically, you will not have to pay a fee to access your Personal Data (or to exercise any of the other rights).
However, except in relation to Consent Withdrawal, we may charge a reasonable fee if your request is clearly
unfounded, repetitive or excessive, or, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to
access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that
Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you
for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if
your request is particularly complex or you have made a number of requests. In this case, we will notify you and
keep you updated.
Data, please contact us at: email@example.com.
We will reply to your complaint as soon as we can.
If you feel that your complaint has not been adequately resolved, please note that the GDPR gives you the right
to contact your local data protection supervisory authority, which for the UK, is the Information Commissioner’s Office.
- Request access to your Personal Data. This enables you to receive a copy of the Personal
Data we hold about you and to check that we are lawfully processing it.
- Request correction of the Personal Data that we hold about you. This enables you to have
any incomplete or inaccurate information we hold about you corrected.
- Request erasure of your Personal Data. This enables you to ask us to delete or remove
Personal Data where there is no good reason for us continuing to process it. You also have the right to ask
us to delete or remove your Personal Data where you have exercised your right to object to processing (see
- Object to processing of your Personal Data. This right exists where we are relying on a
Legitimate Interest as the legal basis for our processing and there is something about your particular
situation, which makes you want to object to processing on this ground. You also have the right to object
where we are processing your Personal Data for direct marketing purposes.
- Request the restriction of processing of your Personal Data. This enables you to ask us to
suspend the processing of Personal Data about you, for example if you want us to establish its accuracy or
the reason for processing it.
- Request the transfer of your Personal Data. We will provide to you, or a third party you
have chosen, your Personal Data in a structured, commonly used, machine-readable format. Note that this
right only applies to automated information which you initially provided consent for us to use or where we
used the information to perform a contract with you.
- Withdraw consent. This right only exists where we are relying on consent to process your
Personal Data (“Consent Withdrawal”). If you withdraw your consent, we may not be able to
provide you with access to the certain specific functionalities of our Site. We will advise you if this is
the case at the time you withdraw your consent.
Marketing Communication Preferences
You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing
message sent to you or by contacting us at any time at: firstname.lastname@example.org.
Where you opt out of receiving these marketing messages, this will not apply to Personal Data provided to us as a
result of emails relating to purchases, subscription renewals and customer announcements relating to
product/services such as technical notifications, service updates or other administrative communications.
GDPR Privacy Data Sheets
What Personal Data we collect
All the Personal Data we collect, both from you and from third parties about you, is outlined in the table
|Category of Personal Data collected
||What this means
||First name, surname, last name, username or similar identifier and title.
||Your work address, billing address, email address and telephone numbers.
|Marketing and Communications Data
||Your preferences in receiving marketing from us and our third parties and your communication
||Inferred or assumed information relating to your behaviour and interests, based on your online activity.
This is most often collated and grouped into “segments” (e.g., there may be a segment for Information
Security Managers, based in the UK and working in Financial Services).
||Internet protocol (IP) address, your login data, browser type and version, time zone setting and
location, browser plug-in types and versions, operating system and platform and other technology on the
devices you use to access this website or use our services.
We also collect, use and share “Aggregated Data” such as statistical
or demographic data for any purpose. Aggregated Data may be derived from your Personal Data, but once in
aggregated form it will not constitute considered Personal Data for the purposes of the GDPR as this data does
not directly or indirectly reveal your identity. However, if we combine or connect Aggregated Data with your
Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data
No Special Categories of Personal Data
We do not collect any “Special Categories of Personal
Data” about you (this includes details about your race or ethnicity, religious or philosophical
beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health
and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
How we use your Personal Data and why
We will only use your Personal Data for the purposes for which we collected it as listed below, unless we
reasonably consider that we need to use it for another reason and that reason is compatible with the original
explain the legal basis which allows us to do so.
What is our “legal basis” for processing your Personal Data?
In respect of each of the purposes for which we use your Personal Data, the GDPR requires us to ensure that we
have a “legal basis” for that use. Most commonly, we will rely on one of the following legal bases:
Generally we do not rely on your Consent as a legal basis for using your Personal Data.
We have set out below, in a table format, the legal bases we rely on in respect of the relevant Purposes for
which we use your Personal Data.
- Where we need to perform a contract we are about to enter into or have entered into with you (“Contractual
- Where it is necessary for our legitimate interests and your interests and fundamental rights do not override
those interests (“Legitimate Interests”). More detail about the specific legitimate
interests pursued in respect of each Purpose we use your Personal Data for is set out in the table below.
- Where we need to comply with a legal or regulatory obligation (“Compliance with Law”).
- Where we have your specific consent to carry out the processing for the Purpose in question
||Category(ies) of Personal Data involved
||Why do we do this
||Our legal basis for this use of data
||To keep our website, our services and associated systems operational and secure.
We have a legitimate interest in ensuring the ongoing security and proper operation of our services,
website and associated IT services and networks.
||To track issues that might be occurring on our systems.
It is in our legitimate interests that we are able to monitor and ensure the proper operation of our
Sites and associated systems and services.
Marketing and Communications Data
||To form a view on what we think you may want or need, or what may be of interest to you.
This is how we decide which services and offers may be relevant for you.
We have a legitimate interest in providing you with updates on our Sites and related offers where you
have purchased or shown interest in similar services from us.
What happens when you do not provide necessary Personal Data?
Where we need to process your Personal Data either to comply with law, or to
perform the terms of a contract we have with you and you fail to provide that data when requested, we may not be
able to perform the contract we have or are trying to enter into with you (for example, to provide you with the
functionalities of the Site).
In this case, we may have to stop you using our Site have with us but we will notify you if this is the case at
Personal Data from Third Party Sources
In addition to the Personal Data that we collect directly from you (as described in the section immediately above
this one), we also collect certain of your Personal Data from third party sources. These sources are broken down
in the table below, together with a description of whether they are publicly available or not.
|Third party data source
||Category(ies) or other types of personal data received.
Marketing and Communications Data
|Lead Generation Service Providers
How we keep your Personal Data secure
We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost,
used or accessed in an unauthorized way, altered or disclosed.
We limit access to your Personal Data to those employees and other staff who have a business need to have such
access. All such people are subject to a contractual duty of confidentiality.
We have put in place procedures to deal with any actual or suspected Personal Data breach. In the event of any
such breach, we have systems in place to work with applicable regulators. In addition, in certain circumstances
(e.g., where we are legally required to do so) we may notify you of breaches affecting your Personal Data.
How long we store your Personal Data.
We will retain Customer Data in accordance with a Customer’s instructions, including any applicable terms in the
Customer Agreement and as required by applicable law. We will retain Other Information pertaining to you
Our policy on children.
This Site is not intended for children below 16 and we do not knowingly collect data relating to such
Third party links
This Site may include links to third-party websites, plug-ins and applications. Clicking on those links or
enabling those connections may allow third parties to collect or share your Personal Data. We do not control
these third-party websites and are not responsible for their privacy statements. When you leave our Site, we
EU-U.S. Privacy Shield
Agari complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce
regarding the collection, use, and retention of Personal Data transferred from the EU to the United States. We
have certified to the Department of Commerce that we adhere to the Privacy Shield Principles. If there is any
Principles shall take precedence. To learn more about the Privacy Shield program, the Privacy Shield Principles
and to view our certification, please visit www.privacyshield.gov.
As described in the Privacy Shield Principles, Agari is accountable for Personal Data that
it receives and subsequently transfers to third parties. If third parties that process Personal Data on our
behalf do so in a manner that does not comply with the Privacy Shield Principles, we are accountable, unless we
prove that we are not responsible for the event giving rise to the damage.
In compliance with the Privacy Shield Principles, Agari commits to resolve complaints about our collection or use
first contact us at: email@example.com.
Agari 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 Personal Data transferred from the EU. Please contact us to be
directed to the relevant DPA contacts.
As further explained in the Privacy Shield Principles, binding arbitration before a Privacy Shield Panel will
also be made available to you in order to address residual complaints not resolved by any other means. Agari is
subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC).