Keragon Privacy Policy

Last updated on 30th December 2022

This Privacy Policy explains how Keragon (“we”, “us”) collects, uses, shares, and protects the personal information we collect about individuals (“you”, “yours”) when you use the websites we operate and the services we provide.

This Privacy Policy does not apply to our processing of the personal information or personal health information of our business customers’ consumer or end customer. We process that consumer or end customer information on behalf of our business customers in our capacity as a service provider / processor. Our processing of that information is governed by our agreement with our business customers.

Please read this Privacy Policy before using our Service or submitting any personal information to Keragon and contact us if you have any questions. By using the Service or otherwise providing personal information to us, you agree to the practices described in this Privacy Policy. If you do not agree to this Privacy Policy, please do not access the Service or otherwise provide personal information to us.

This Privacy Policy constitutes an integral part of our Terms of Service, and all capitalized terms not defined above have the meaning set forth there: https://keragon.com/legal/terms.

1. Summary

In providing Keragon’s Service, including those described on Keragon’s website (collectively and individually, our “Services”) we collect the information that our customers and those that interact with us provide to us. We process that information on behalf of our customers – as a “service provider” (under California law) or a “processor” (under the GDPR).

Sometimes, we collect other information that we use in our own corporate capacity, such as to send communications to our customers (or prospective customers and users of our Service), or to improve internal aspects of our Services, e.g., to improve the speed or efficiency of our Services.

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2. What information Keragon collects in its corporate capacity & why

a. Information from website browsers

If you’re just browsing Keragon’s website, we collect the same basic information that most websites collect. We use common internet technologies, such as cookies and web server logs. This is stuff we collect from everybody that visits our website, whether they have an account or not.

The information we collect about all visitors to our website includes the visitor’s browser type, language preference, referring site, additional websites requested, and the date and time of each visitor request. We also collect potentially personally-identifying information like Internet Protocol (IP) addresses.

We may also provide a way for visitors to give us contact information – such as an email address or phone number, billing information, or other information that we use in our corporate capacity, in which case we will use that information as set out in this Privacy Policy, and generally, to operate our business and provide, develop and evaluate our Services.

b. Why we collect this information

We collect this information to better understand how our website visitors use Keragon, and to monitor and protect the security of the website. If you provide us contact information, we may use it to communicate with you.

c. Information from users with accounts

If you create an account, we require some basic information at the time of account creation. You will create your own username, and will be required to sign in with a third-party identity provider tied to a valid email address. You also have the option to give us more information if you want to, and this may include “User Personal Information.”

We collect various User Personal Information, as set forth below. “User Personal Information” is any information about one of our users which could, alone or together with other information, personally identify him or her. Information such as a user name, an email address, a real name, and a photograph are examples of “User Personal Information.” User Personal Information includes Personal Data as defined in the General Data Protection Regulation, which therefore includes online identifiers such as IP addresses, cookie identifiers and user account identifiers, as well as log information such as page views, time stamps and other information connected to how users access our website and access and use our Services. User Personal Information does not include aggregated, non-personal information, or deidentified information. We may use aggregated, non-personally identifying or deidentified information to operate, improve, and optimize our website and service.

We collect User Personal Information from you when you use our Services, and we may connect it to log data and other information about how you use our Services. For instance, we may track whether our customers use certain of our Services at certain times, in certain ways, or from certain countries, and we may analyze that information to help us provide better or more efficient Services. (For instance, if we see many IP addresses from a particular country, we may increase our server capacity in those countries; if we see significant interaction with certain web pages or platform features, we may incorporate that knowledge into our Service offerings.)

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3. Why we collect this information

We need User Personal Information to create your account, and to provide the services you request, including to provide the Keragon service, or to respond to support requests.
We use User Personal Information, including your user name, to identify you on Keragon.
We use User Personal Information to fill out your profile.
We may use your email address to communicate with you in connection with Services we provide to you, and for marketing purposes unless you have opted out through an “unsubscribe” we provide in our emails.
We may use User Personal Information and other data to make recommendations for you, to maximize the value you get from our Service. These recommendations are automated decisions, but they have no legal impact on your rights.
We may use User Personal Information to improve our Services and analyze how customers interact with our Services and how website visitors interact with our website.
We use User Personal Information for internal purposes, such as to maintain logs for security reasons, for training purposes, and for legal documentation.
We limit our use of User Personal Information to the purposes listed in this Privacy Policy, and we reserve the right to add additional uses at any time. If you are a customer of ours, you may also view certain information we have about you in your “user profile.”

Our legal basis for processing information

Under certain international laws (including the GDPR), Keragon is required to notify you about the legal basis on which we process User Personal Information. As to the User Personal Information of which it is a “controller” (e.g., the information it uses to communicate with its own customers) Keragon processes User Personal Information on the following legal bases:

When you create a Keragon account, you provide your user name and an email address. We require those data elements for you to enter into the Terms of Service agreement with us, and we process those elements on the basis of performing that contract. We also process your user name and email address on other bases. Keragon does not collect or process a credit card number, but our third-party payment processor does.
When you fill out the information in your user profile, you may have the option to provide User Personal Information, including but not limited to your full name, your location, your company, and a URL to your company’s website. We process this information on the basis of consent. All of this information is entirely optional, and you have the ability to access, modify, and delete it at any time (while you are not able to delete your email address on its own, you can delete your entire account and all its associated data).
Generally, the remainder of the processing of personal information we perform is necessary for the purposes of our legitimate interests. For example, for security and operational purposes, we must keep logs of IP addresses that access Keragon, and for our own legal and auditing purposes we need to keep certain customer records.

If you would like to request erasure of data we process on the basis of consent, or otherwise object to our processing of User Personal Information, please email privacy@keragon.com.

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4. Information about Children

If you are a child under the age of 16, you may not have an account on Keragon. Keragon does not knowingly collect information from or direct any of our content specifically to children under 16. If we learn or have reason to suspect that you are a user who is under the age of 16, we will unfortunately have to close your account. Please see our Terms of Service for information about account termination. Other countries may have different minimum age limits, and if you are below the minimum age for providing consent for data collection in your country, you may not use Keragon without obtaining your parents’ or legal guardians’ consent.

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5. Information You Submit As Part of Your Use of the Services

You may also submit through our Services various information, including personal information (of yourself or others), such information embedded in code. Except as disclosed above, we do not use such information for our own commercial purposes (for instance, sublicensing or resale), beyond uses related to providing and operating our Services. Please note that various public licenses may apply to code that you submit through our Services: our Terms of Service (not this Privacy Policy) describes those licenses, and your and our respective rights.

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6. How we share the information we collect

We do not share, sell, rent, or trade User Personal Information with third parties for their commercial purposes, except where you have specifically told us to.

We do share certain aggregated, non-personally identifying information with others about how our users, collectively, use Keragon, or how our users respond to our other offerings, such as our conferences or events.

We do share User Personal Information with our service providers who process it on our behalf to provide or improve our service. Our vendors perform services such as payment processing, network data transmission, security providers, tech and customer support and hosting providers, marketing and data enhancement and hygiene services, and accounting, auditing and legal services providers.

We do share aggregated, non-personally identifying information with third parties. For example, in the event of a security incident, we may share the number of times a particular endpoint was accessed.

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7. Our use of cookies and tracking

a. Cookies

Keragon uses cookies to make interactions with our service easy and meaningful. We use cookies (and similar technologies, like HTML5 localStorage) to remember your preferences, and provide information for future development of Keragon. We also use cookies to identify a device, for security reasons. We may use third party cookies and similar technologies to market to you – for instance, to “retarget” people who have visited our website, or to determine whether our emails are being opened or read. By using our website, you agree that we can place these types of cookies on your computer or device. If you disable your browser or device’s ability to accept cookies, you will not be able to log in or use Keragon’s services. However, you may learn about (and if desired, opt out of) online interest-based advertising and retargeting by visiting the website of the Digital Advertising Alliance, an industry-leading organization.

b. Tracking and analytics

We use a number of third party analytics and service providers to help us evaluate our users’ use of Keragon; compile statistical reports on activity; and improve our content and website performance. We only use these third party analytics providers on certain areas of our website, and all of them have signed data protection agreements with us that limit the type of personal information they can collect and the purpose for which they can process the information. In addition, we use our own internal analytics software to provide features and improve our content and performance.

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8. Links to other websites

The Service contains links to websites and applications other than the Service, including websites and applications operated by affiliates and other third parties. Keragon does not determine and we are not responsible for the privacy practices or content of websites and applications operated by third parties. Your browsing and interaction on any third-party website or service, including those that have a link on Keragon’s website, are subject to that third party’s terms and conditions and policies. We encourage you to read the privacy statements and other terms and conditions of third-party websites and applications linked to the Service every time you leave the Service to access such third-party websites.

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9. Correcting, updating or deleting your information

You may update or change the personal information you have provided to us by logging into the Service.

We have established internal policies for the deletion of data from customer accounts following termination of a customer’s subscription to the Service. We will also respond to requests to delete personal information that may be held within our systems, to the extent possible and with the limitation that some information may need to be retained (see the “Data Retention” section of this Privacy Policy for details). Note that if you remove or request removal or deletion of information that you posted in a public area of the Service, copies may remain viewable in cached and archived pages of the Service, or if other Users have copied or saved that information. Therefore, in some cases, we may not be able to delete or remove your personal information.

To request deletion, removal, correction or updates of your personal information, contact us at privacy@keragon.com.

Moreover, if you are a Keragon User and would like to opt-out of marketing communications from Keragon please contact us at privacy@keragon.com or follow the unsubscribe instructions included in the marketing emails. Users in the EU and some other jurisdictions have more specific and additional rights related to their personal information: see respective sections below for more details.

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10. Data retention

Keragon will retain your personal information for a period of time consistent with the original purpose of collection or as long as necessary to comply with our legal obligations, maintain accurate accounting, financial and other operational records, resolve disputes, and enforce our agreements.

We determine the appropriate retention period for personal information on the basis of the amount, nature, and sensitivity of the personal information being processed, the potential risk of harm from unauthorized use or disclosure of the personal information, whether we can achieve the purposes of the processing through other means, and on the basis of applicable legal requirements (such as applicable statutes of limitation).

After expiry of the applicable retention periods, your personal information will be deleted.

Please also contact us if you have any questions or need specific information about retention periods.

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11. How Keragon secures your information

Keragon takes measures it believes are reasonable and necessary to protect User Personal Information from unauthorized access, alteration, or destruction; and to maintain data accuracy. However, no method of transmission, or method of electronic storage, is 100% secure. Therefore, we (like most websites and platforms) cannot guarantee its absolute security.

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12. Incident management and data breach notification

If Keragon becomes aware of and determines that an incident involving personal information qualifies as a breach of security leading to the misappropriation, accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal information that compromises the security, confidentiality or integrity of such personal information, Keragon will report such breach to the Keragon account holder within 48 hours.

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13. Keragon’s global privacy practices

We store and process the information that we collect in the United States in accordance with this Privacy Policy (our subprocessors may store and process data outside the United States). However, we understand that we have users from different countries and regions with different privacy expectations, and we try to meet those needs even when the United States does not have the same privacy framework as other countries’.

We provide the same standard of privacy protection — as described in this Privacy Policy — to all our users around the world, regardless of their country of origin or location, and we are proud of the levels of notice, choice, accountability, security, data integrity, access, and recourse we provide.

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14. How we respond to compelled disclosure

Keragon may disclose personally-identifying information or other information we collect about you to law enforcement in response to a valid subpoena, court order, warrant, or similar government order, or when we believe in good faith that disclosure is reasonably necessary to protect our property or rights, those of third parties or the public at large.

In complying with court orders and similar legal processes, Keragon strives for transparency. When permitted, we will make a reasonable effort to notify users of any disclosure of their information, unless we are prohibited by law or court order from doing so, or in rare, exigent circumstances.

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15. The CCPA and GDPR

When we process or receive information from a customer, we act as a “service provider” for purposes of the California Consumer Privacy Act (CCPA) and as a “data processor” for purposes of the General Data Protection Regulation, to the extent those laws apply. Therefore, any requests about or relating to personal information or personal health information or personal data that we hold for our customers should be directed to those customers – not to us.

If your data has been submitted to us by or on behalf of a Keragon customer and you wish to exercise any rights you may have under applicable data protection laws, please inquire with the relevant Keragon customer directly. Because we may only access customer’s data upon their instructions, if you wish to make your request directly to us, please provide us the name of the Keragon customer who submitted your data to us. We will refer your request to that customer and will support them as needed in responding to your request in accordance with our contract with the relevant customer.

By contrast, if you have engaged with us as a customer (or in another commercial way) and you wish to exercise your legal rights to delete or access certain of your information, please contact us at privacy@keragon.com.

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16. Notice to California residents

Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to ask us for a notice identifying the categories of personal information which we share with our affiliates and/or third parties for marketing purposes and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to: legal@keragon.com.

Moreover, we are required by the California Consumer Privacy Act of 2018 (“CCPA”) to provide this CCPA Notice to California residents to explain how we collect, use and share their personal information, and the rights and choices we offer California residents regarding our handling of their personal information, which the CCPA currently defines as “information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.”

This CCPA Notice does not apply to individuals with whom Keragon engages in the individuals’ capacity as representatives of businesses that may provide services to Keragon, or to which Keragon may provide its Services.

a. Personal Information Collection, Use, and Disclosure: We describe the sources through which we collect personal information, the types of personal information collected and the purposes for which we use and share this information in this Privacy Policy.

b. California Privacy Rights: To the extent provided for by law and subject to applicable exceptions, California residents have the following privacy rights in relation to the personal information we collect:

Right to request access to information about categories of personal information Keragon has collected about you, specific pieces of personal information Keragon has collected about you, categories of sources from which the personal information is collected, business or commercial purpose for collecting personal information, and categories of third parties with whom the business shares personal information.
Right to request deletion of any personal information collected about you by us.
Right to opt-out of the sale of personal information. Please note that we do not sell personal information we collect from you, in accordance with the definition of sell in the CCPA and its supplemental regulations.
Right against discrimination because you exercised the rights available to you.
Right to protection against waiver of rights.

You can exercise the rights described above, by sending an email to legal@keragon.com. You may exercise these rights by yourself or via an authorized agent who meets the agency requirements of CCPA.

Once you exercise your rights, you agree to receive communication from us seeking information from you in order to verify your identity as the consumer from whom we have collected the personal information and such other information as reasonably required to enable us to fulfill your request. We will not fulfill your request unless you have provided sufficient information for us to reasonably verify that you are the consumer from whom we collected personal information, as well as sufficient details necessary to help us handle the request.

Note: The Service does not respond to browser “Do Not Track” (DNT) signals and operates as described in this Privacy Policy whether or not a DNT signal is received. If we do so in the future, we will describe how we do so in this Privacy Policy.

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17. Notice to European users

If you are a User in the European Economic Area (“EEA”) or the United Kingdom (“UK”), the following provisions apply to you, in addition to the other policies in this Privacy Policy. Keragon Inc is the controller for your personal data.

a. Legal Bases For Processing

We are required to identify the legal bases for processing personal data about you. We process personal data as follows:

1. Contractual Necessity: We process the following categories of personal data as a matter of “contractual necessity”, meaning that we need to process the data to perform under our Terms of Service with you, which enables us to provide you with the Services. When we process data due to contractual necessity, failure to provide such personal data will result in your inability to use some or all portions of the Services that require such data.

Essential Account Data
Essential First-Party Cookies
Billing Data
Connection Data
Online Form, Email and Chat Data used for support services
Usage Data required for billing purposes
Account information for third-party services (e.g., if a User logs into the Services using a third party such as Google).

2. Legitimate Interest: We process the following categories of personal data when we believe it furthers our legitimate interests or those of third parties, or your legitimate interest. We will rely on our legitimate interests for processing personal data only after balancing our interests and rights against the impact of the processing on individuals.

Profile Data
Online Form, Email and Chat Data
Usage Data

These legitimate interests include:

Providing the Services to Users
Facilitating usage of our Service
Responding to your inquiries, comments, feedback or questions
Managing our relationship with Users, which includes sending administrative information to Users relating to our Service and changes to our terms and conditions, and policies, and asking Users to leave a review or take a survey
Providing personalized and customized content and information to Users
Gaining insights about and making improvements to our business, products and services
Administering and protecting our business and the Service, preventing fraud, criminal activity, or misuse of our Service, and ensuring the security of our IT systems, architecture and networks (including troubleshooting, testing, system maintenance, support and hosting of data)
Providing information to current and prospective users of our products and services
Compliance with legal obligations and legal process and protecting our rights, privacy, safety or property, and/or that of our affiliates, you or other third parties

3. Consent: In some cases, we process personal data based on the consent you expressly grant to us at the time we collect such data, such as in relation to the collection of information through the use of cookies and similar technologies other than strictly necessary technologies. When we process personal data based on your consent, it will be expressly indicated to you at the point and time of collection.

4. Other Processing Grounds: From time to time, we may also need to process personal data to comply with a legal obligation.

b. Your Rights Regarding Your Personal Data

You have certain rights with respect to your personal data, including those set forth below, subject to certain conditions and exceptions. For more information about these rights, or to submit a request, please email privacy@keragon.com. In some cases, we may also need you to provide us with additional information, which may include personal data, if necessary to verify your identity and the nature of your request.

Access: You can request more information about the processing of personal data we hold about you and request a copy of such personal data. You can also access certain of your personal data by accessing your account settings or contacting us at privacy@keragon.com.
Rectification: If you believe that any personal data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data. You can also correct some of this information directly by accessing your account settings or contacting us at privacy@keragon.com.
Erasure: You can request that we erase some or all of your personal data from our systems by sending a request to privacy@keragon.com.
Withdrawal of Consent: If we are processing your personal data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. However, please note that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your personal data, if such use or disclosure is necessary to enable you to utilize some or all of our Services.
Portability: You can ask for a copy of your personal data in a machine-readable format. You can also request that we transmit the data to another controller where technically feasible, if the processing of your data is based on your consent or on contractual necessity, and if the processing is carried out by automated means.
Objection: You can contact us to let us know that you object to the further use or disclosure of your personal data for certain purposes by sending a request to privacy@keragon.com.
Restriction of Processing: You can ask us to restrict further processing of your personal data by sending a request to privacy@keragon.com.
Right to File Complaint: You have the right to raise a complaint about Keragon’s practices with respect to your personal data to your local regulator. If you are a resident of the United Kingdom and believe that we maintain your personal data within the scope of the applicable laws relating to personal data in the UK, you may direct questions or complaints to the UK supervisory authority, the Information Commissioner’s Office.

c. Transfer of Personal Data

Keragon offers its Services to customers in various geographic regions, including the United States, the EEA and the UK. However, as described above, some personal data may nonetheless be collected, transferred to and stored by us in the United States and by our service providers that are based in the United States as necessary for the purpose of providing the Services and for the business purposes described in this Privacy Policy. Laws in the U.S. may be less stringent or otherwise different from the laws where you reside. Where applicable or required by law, we will ensure that the recipient of your personal data offers an adequate level of protection and security, for instance by entering into appropriate standard contractual clauses or an alternative mechanism for the transfer of data as approved by the European Commission (Art. 46 GDPR) or other applicable regulators. Moreover, we transfer some of your personal data as a matter of “contractual necessity” (for further information on the type of personal data concerned, please read the respective section above).

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18. Changes to the Privacy Policy

We may, in our sole discretion, modify or update this Privacy Policy from time to time. When we post changes to this Privacy Policy, we will also revise the “Last Updated” date appearing at the top of the Privacy Policy. Any changes to this Privacy Policy are effective immediately after we post them. If we make any material changes to this Privacy Policy, we will endeavor to notify you by email or by posting a prominent notice on the Service prior to the change becoming effective. We encourage you to review this page periodically for the latest information on our privacy practices. Your continued use of the Service after the publication of any updated Privacy Policy shall constitute your agreement to be bound by such changes to this Privacy Policy. Your only remedy, if you do not accept the terms of this Privacy Policy, is to discontinue use of the Service.

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19. Contact us

If you have questions or to file complaints about the way Keragon is handling your User Personal Information, please contact us at privacy@keragon.com.

The data controller is Keragon Inc, 177 Huntington Ave Ste 1703 PMB 61327, Boston, Massachusetts, United States.

CHANGELOG

v1.0 - Public version of Keragon’s Privacy Policy - 30th Dec 2022

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