This PRIVACY NOTICE FOR CALIFORNIA RESIDENTS supplements the information contained in the privacy policy of Vulcan Cyber Ltd.'s (“Vulcan” or “we”) to be found at the following link: https://help.vulcancyber.com/en/articles/6201897-vulcan-cyber-ltd-privacy-policy-privacy-policy (“Privacy Policy”) and applies solely to visitors, users, and others who reside in the State of California (“consumers” or “you”) in connection with the use of our Services (as defined in the Privacy Policy). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws. Any terms defined in the CCPA have the same meaning when used in this notice.
1. PII We Collect
We collect PII (as defined in the Privacy Policy), which for the purposes hereof additionally include information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. In particular, we have collected the following categories of PII from consumers within the last twelve (12) months:
Category | Examples | Collected |
A. Identifiers | A real name, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name or other similar identifiers | [YES] |
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) | A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some PII included in this category may overlap with other categories. | [NO] |
C. Protected classification characteristics under California or federal law | Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). | [NO] |
D. Commercial information | Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | [NO] |
E. Biometric information | Genetic, physiological, behavioural, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. | [NO] |
F. Internet or other similar network activity | information on a consumer's interaction with a website, application, or advertisement. | [YES] |
G. Geolocation data | Physical location or movements. | [NO] |
H. Sensory data | Audio, electronic, visual, thermal, olfactory, or similar information. | [NO] |
I. Professional or employment-related information | Current or past job history or performance evaluations. | [NO] |
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). | Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. | [NO] |
K. Inferences drawn from other personal information. | Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behaviour, attitudes, intelligence, abilities, and aptitudes. | [NO] |
We obtain the categories of PII listed above from the following categories of sources:
Directly from you. For example, through information we ask from you when you subscribe and engage our Services/open an account on our website.
Directly and indirectly from you when using our Services or visiting our website. For example, usage details collected automatically in the course of your interaction with our platform or website.
2. Use of PII
We may use or disclose PII we collect for one or more of the following business purposes as further detailed in the Privacy Policy:
To provide you with email alerts and other notices concerning our Services, or updates to your insurance application process.
To improve our Services to you.
To provide, support, personalize, and develop our websites, products, and Services.
To create, maintain, customize, and secure your account with us.
To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
As necessary or appropriate to protect the rights, property or safety of us, our clients or others.
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
As described to you when collecting your Personal Information or as otherwise set forth in the CCPA.
To detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and prosecute those responsible for that activity.
Performing services on behalf of the business or service provider, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider.
Debugging to identify and repair errors that impair existing intended functionality.
Undertaking internal research for technological development and demonstration.
Undertaking activities to verify or maintain the quality of the Services, or enhance the Services.
To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us is among the assets transferred.
We will not collect additional categories of PII or use PII we collected for materially different, unrelated, or incompatible purposes without providing you notice.
3. Sharing PII
We may disclose your PII to a third party for a business purpose. When we disclose PII for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that PII confidential and not use it for any purpose except performing the contract.
We share your PII with the following categories of third parties:
Service providers and contractors.
Third parties to whom you or your agents authorize us to disclose your PII in connection with our Services.
In the preceding twelve (12) months, we have disclosed the categories of PII set forth in the table under Section 1 above for a business purpose.
We disclose your PII for a business purpose to the following categories of third parties:
Service providers and contractors.
Third parties to whom you or your agents authorize us to disclose your PII in connection with our Services.
In the preceding twelve (12) months, we have not sold any PII.
Your Rights and Choices
The CCPA provides consumers (California residents) with specific rights regarding their PII. This section describes your CCPA rights and explains how to exercise those rights.
Access to Specific Information Right
You have the right to request that we disclose certain information to you about our collection and use of your PII over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
The categories of PII we collected about you.
The categories of sources for PII we collected about you.
Our business or commercial purpose for collecting that PII.
The categories of third parties with whom we share that PII.
The specific pieces of PII we collected about you (also called a data portability request).
If we sold or disclosed your PII for a business purpose, two separate lists disclosing: (a) sales, identifying PII categories that each category of recipient purchased; and (b) disclosures for a business purpose, identifying PII categories that each category of recipient obtained.
Deletion Request Right
You have the right to request that we delete any of your PII we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your PII from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service providers to:
Complete the transaction for which we collected PII, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
Debug products to identify and repair errors that impair existing intended functionality.
Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
Comply with a legal obligation.
Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Exercising Your Rights
To exercise your rights under the CCPA, please submit a verifiable consumer request to us by either: (a) sending an e-mail to us at security@vulcan.io; or (b) submitting a request through https://vulcan.io/contact-us.
Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your PII. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access 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 PII or an authorized representative.
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 PII if we cannot verify your identity or authority to make the request and confirm the PII relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use PII provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
4. Response Timing and Format
We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to the registered email associated with the account. 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 the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your PII that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
5. PII Sales Opt Out And Opt In Rights
You have the right to direct us to not sell your PII at any time (the “right to opt-out”). We do not sell PII of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the “right to opt-in”) from either the consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer who is between 13 and 16 years of age. Consumers who opt-in to PII sales may opt-out of future sales at any time. To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by visiting the following our webpage or sending us a message: https://vulcan.io/contact-us.
Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize PII sales. However, you may change your mind and opt back in to PII sales at any time by visiting our website and sending us a message. We will only use PII provided in an opt-out request to review and comply with the request.
6. Non-Discrimination
We will not discriminate against you for exercising any of your CCPA rights.
7. Other California Privacy Rights
California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our websites or Services that are California residents to request certain information regarding our disclosure of PII to third parties for their direct marketing purposes. To make such a request, please send an email to security@vulcan.io.
8. Changes to Our Privacy Notice
We reserve the right to amend this Privacy Notice at our discretion and at any time. The date this Privacy Notice was last updated is identified at the bottom of this page. You are responsible for periodically visiting our website and this Privacy Notice to check for any changes. Your continued use of our websites following the posting of changes constitutes your acceptance of such changes.
9. Contact Information
If you have any questions or comments about this Privacy Notice, our Privacy Policy, the ways in which we collect and use your PII, your choices and rights regarding such use, or wish to exercise your rights under California law, you may contact us via email at security@vulcan.io.
Last Date Updated: April 7, 2022