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Privacy Policy

Effective: September 1, 2022

This Privacy Policy describes how Hook Security collects, uses, and discloses information associated with an identified or identifiable individual (referred to in this Privacy Policy as “Personal Data”) and what choices you have around this activity. If you have any questions, please don’t hesitate to contact us.

When we refer to “Hook Security”, we mean Hook Security Inc., as explained in more detail in the “Identifying the Data Controller and Processor” section below.

Table of Contents:

Applicability of This Privacy Policy

Information We Collect And Receive

How We Process Your Information and our Legal Bases for Doing So

How We Share and Disclose Information

Data Retention

Security

Age Limitations

Changes To This Privacy Policy

Data Protection Officer

Identifying The Data Controller And Processor

Your Rights

Your California Privacy Rights

Data Protection Authority

Contacting Hook Security

Applicability of This Privacy Policy

This Privacy Policy applies to Hook Security’s online testing tools and platform, including the associated Hook Security mobile and desktop applications (collectively, the “Services''), hooksecurity.co, hooksecurity.testingcenter.net, and other Hook Security websites (collectively, the “Websites”) and other interactions (e.g., customer service inquiries, user conferences, etc.) you may have with Hook Security. If you do not agree with this Privacy Policy, then do not access or use the Services, Websites, or any other aspect of Hook Security’s business. For the avoidance of doubt, this is the only privacy policy that applies to Hook Security.

This Privacy Policy does not apply to any third-party applications or software that integrate with the Services through the Hook Security platform (“Third-Party Services”), or any other third-party products, services, or businesses that will provide their services under their own terms of service and privacy policy. In addition, a separate agreement governs delivery, access, and use of the Services (the “Customer Agreement”), including the processing of data such as messages, files, or other content submitted through Services accounts (collectively, “Customer Data”). The organization (e.g., your employer or another entity or person) that entered into the Customer Agreement (“Customer”) controls its instance of the Services (its “Workspace”) and any associated Customer Data. If you have any questions about specific Workspace settings and privacy practices, please contact the Customer whose Workspace you use. If you have an account, please refer to your enrollment notice for the contact information of your Workspace owner(s) and administrator(s). If you have received an invitation to join a Workspace but have not yet created an account, you should request assistance from the Customer that sent the invitation.

California Notice of Collection of Personal Information: We collect the information described below under “Information We Collect and Receive” for the business and commercial purposes described below under “Information Use.” To learn more about exercising your California Privacy Rights please review the “California Privacy Rights” section below.

Information We Collect And Receive

Hook Security will collect and receive information through operating the Services and Websites, and through other interactions with Hook Security. Such information will include Customer Data and other information and data (“Other Information”) including but not limited to:

  • Customer Data. Customers or individuals granted access to a Workspace by a Customer (“Authorized Users”) routinely submit Customer Data (such as messages, files, or other content submitted through Services accounts) to Hook Security when using the Services.
  • Other Information. Hook Security also collects, generates, and/or receives the following categories of Other Information:
  1. Workspace and account information: To create or update a Workspace account, you or our Customer (e.g. your employer) supply Hook Security with an email address, phone number, password, domain, and/or other account set up details with billing details such as credit card information, banking information, and/or a billing address.
  2. Usage information:
  • Services Metadata. When an Authorized User interacts with the Services, metadata is generated that provides additional context about the way that an Authorized User uses the Services. For example, Hook Security logs the Workspaces, channels, people, features, content, and links you view or interact with, the types of files shared, and what Third-Party Services are used (if any)
  • Log data. As with most websites and technology services delivered over the Internet, our servers automatically collect information when you access or use our Websites or Services and record it in log files. This log data may include your Internet Protocol (IP) address, the address of the web page you visited before using the Website or Services, browser type and settings, the date and time the Services were used, information about browser configuration, and plugins, and your language preferences.
  • Device information. Hook Security collects information about devices accessing the Services, including the type of device, what operating system is used, device settings, application IDs, unique device identifiers and crash data. Whether we collect some or all of this Other Information often depends on the type of device used and its settings.
  • Location information. We receive information from you, our Customers, and other third parties that help us approximate your location. We may, for example, use a business address submitted by your employer (who is our Customer) or an IP address received from your browser or device to determine an approximate location to assist with localization or for security purposes.
  1. Cookie information: Hook Security uses a variety of cookies and similar technologies in our Websites and Services to help us collect Other Information. For more details about how we use these technologies, and your opt-out controls and other options, please visit our Cookie Policy.
  2. Third-Party Services information: A Customer can choose to permit or restrict Third-Party Services for its Workspace and Hook Security can receive personal data from such Third-Party Services. Typically, Third-Party Services are software that integrates with our Services, and a Customer can permit its Authorized Users to enable and disable these integrations for its Workspace. Hook Security may also develop and offer Hook Security applications that connect the Services with a Third-Party Service. Once enabled, the provider of a Third-Party Service may share certain information with Hook Security. When a Third-Party Service is enabled, Hook Security is authorized to connect and access Other Information made available to Hook Security in accordance with our agreement with the provider of the Third-Party Service and any permission(s) granted by our Customer (including, by its Authorized User(s)). Examples of information that Hook Security may receive in this manner include whether you successfully created a new account or interacted with a third-party application in a way that is attributable to Hook Security usage activity. We do not, however, receive or store passwords for any of these Third-Party Services when connecting them to the Services.
  3. Contact information: In accordance with the consent process provided by your device or other third-party API, any contact information that an Authorized User chooses to import, forward, or upload to the Services (for example, when sending emails to the Services) is collected when using the Services.
  4. Third-Party Data: Hook Security may receive data about organizations, industries, lists of companies that are customers, Website visitors, marketing campaigns, and other matters related to our business from parent corporation(s), affiliates and subsidiaries, our partners, or others that we use to make our own information better or more useful. This data may be combined with Other Information we collect and might include aggregate-level data, such as which IP addresses correspond to zip codes or countries. Or it might be more specific: for example, how well an email campaign performed in a certain geographic region.
  5. Audio and video metadata: Hook Security may receive, capture, and store metadata derived from your use of features such as certain video content, and additional related data such as data regarding the date and time of your video engagement.
  6. Additional information provided to Hook Security: We also receive Other Information when submitted to our Websites or in other ways, such as responses or opinions you provide if you participate in a focus group, contest, activity, or event, the feedback you provide about our products or services, the information you provide if you apply for a job with Hook Security, enroll in a certification program or other educational program hosted by Hook Security or a vendor, request support, interact with our social media accounts or otherwise communicate with Hook Security.

Generally, no one is under a statutory or contractual obligation to provide any Customer Data or Other Information (collectively, “Information”). However, certain Information is collected automatically and, if some Information, such as Workspace setup details, is not provided, we may be unable to provide the Services.

How We Process Your Information and our Legal Bases for Doing So

Customer Data will be used by Hook Security in accordance with a Customer’s instructions, including to provide the Services, any applicable terms in the Customer Agreement, a Customer’s use of Services functionality, and as required by applicable law. Hook Security is a processor of Customer Data and the Customer is the controller. Customers may, for example, use the Services to grant and remove access to a Workspace, assign roles and configure settings, access, modify, export, share, and remove Customer Data, and otherwise apply its policies to the Services.

Hook Security uses Other Information to operate our Services, Websites, and business. More specifically, Hook Security uses Other Information for the following purposes:

Compliance With A Legal Obligation:

Hook Security processes Other Information when we comply with a legal obligation including, for example, to access, preserve or disclose certain information if there is a valid legal request from a regulator, law enforcement, or others. For example, a search warrant or production order from law enforcement to provide information in relation to an investigation, such as your profile picture or IP address.

We use Workspace and account information, Usage information, Cookie information, Third-Party Services Information, Contact information, Third-Party data, Audio and video metadata, and Additional information provided to Hook Security for compliance with a legal obligation.

Legitimate Interests:

We rely on our legitimate interests or the legitimate interests of a third party where they are not outweighed by your interests or fundamental rights and freedoms ("legitimate interests").

We use Workspace and account information, Usage information, Cookie information, Third-Party Services Information, Contact information, Third-Party data, Audio and video metadata, and Additional information provided to Hook Security for the following legitimate interests:

  • To provide, update, maintain and protect our Services, Websites, and business.
    This includes the use of Other Information to support the delivery of the Services under a Customer Agreement, prevent or address service errors, security or technical issues, analyze and monitor usage, trends, and other activities, or at an Authorized User’s request.
  • It is in our and your interests to provide, update, maintain and protect our Services, Websites, and business.
  • To develop and provide search, learning, and productivity tools and additional features.
    Hook Security tries to make the Services as useful as possible for specific Workspaces and Authorized Users. For example, we may:
  • improve search functionality by using Other Information to help determine and rank the relevance of content, channels, or expertise to an Authorized User;
  • make Services or Third-Party Service suggestions based on historical use and predictive models;
  • identify organizational trends and insights;
  • customize a Services experience; or
  • create new productivity features and products.
  • It is in our interest and in the interest of Customers and Authorized Users to continuously improve and develop the customer support we provide.
  • To investigate and help prevent security issues and abuse.
    We may use a variety of tools such as device fingerprinting to prevent issues and abuse. We may process, including in an automated fashion, Other Information to better understand how Hook Security is used or to prevent spam or abuse.
  • It is in our interest to keep the Service secure and to detect, prevent, and address abuse (such as spam) and to investigate and take action in respect of suspicious activity on the Services.
  • To aggregate or de-identify information.
    In some cases, we aggregate or de-identify information we have associated with you and use the resulting information, for example, to improve the Services.
  • It is in our interest to research and improve the Services;
  • It is in the interests of Customers and Authorized Users to practice data minimization and privacy by design in respect of their information.
  • Share information with others including law enforcement and respond to legal requests.
  • It is in our interest and the interest of the general public to prevent and address fraud, unauthorized use of Hook Security, violations of our terms, or other harmful or illegal activity; to protect ourselves, our users, or others, including as part of investigations or regulatory inquiries; or to prevent death or imminent bodily harm.
  • Transfer, store or process your information outside the European Economic Area.
    As the Websites and Services operate globally, with Customers around the world, we need to share the information we collect globally. We carry out necessary transfers outside the European Economic Area, including to Australia, Canada, Japan, India, South Korea, Argentina, and the United States, to provide, update, maintain and protect our Services, Websites, and business.

We use Workspace and account information, Third-Party Services Information, Third-Party data, and Additional information provided to Hook Security for the following legitimate interests:

  • To communicate with you by responding to your requests, comments, and questions.
    If you contact us, we may use your Other Information to respond.
  • It is in our, our Customers’ and Authorized Users’ interests to facilitate communication (for example to answer questions from Customers).
  • To send service emails and other communications.
    For example, we may:
  • send you service, technical and other administrative emails, messages, and other types of communications; or
  • contact you to inform you about changes in our Services, our Services offerings, and important Services-related notices, such as security and fraud notices. 
  • These communications are considered part of the Services and you may not opt out of them. It is in our Customers' and Authorized Users’ interests to address service-related issues.

We use Workspace and account information and Usage information for the following legitimate interests:

  • For billing, account management and other administrative matters.
    Hook Security may need to contact you for invoicing, account management, and similar reasons and we use account data to administer accounts and keep track of billing and payments.
  • It is in our interest to facilitate the effective provision and administration of the Websites and Services.

We use Workspace and account information for the following legitimate interest:

  • To send marketing emails and other communications.
    We sometimes send emails about new product features, promotional communications or other news about Hook Security. These are marketing messages so you can control whether you receive them. If you have additional questions about a message you have received from Hook Security please get in touch through the contact mechanisms described below.
  • It is in our interest to promote the Websites and Services and send our direct marketing.

How We Share and Disclose Information

This section describes how Hook Security may share and disclose Information, as described in the section entitled 'Information We Collect and Receive' above. Customers determine their own policies and practices for the sharing and disclosure of Information to third parties. Hook Security does not control how a Customer or any third party chooses to share or disclose Information.

  • The Customer’s Instructions. Hook Security may share and disclose Information in accordance with a Customer’s instructions and with appropriate consent, including any applicable terms in the Customer Agreement and the Customer’s use of Services functionality and in compliance with applicable law and legal process. Some sharing at a Customer’s request may incur additional fees.
  • To enable Hook Security to follow our Customers’ instructions, Hook Security provides several administrator controls to allow Customers to manage their Workspaces. For example, we follow our Customers’ instructions to enable or disable Authorized User's use of various features of the Services.
  • Customers may also provide their Authorized Users with the ability to adjust the audience and visibility of certain Customer Data. To learn more, visit our Help Center to understand what choices and settings are available.
  • Displaying the Services. When an Authorized User submits Information, it may be displayed or discoverable to other Authorized Users in the same or connected Workspaces. For example, an Authorized User’s email address may be displayed with their profile, or other profile and organizational information may be displayed to Authorized Users. 
  • Collaborating with Others. The Services provide different ways for Authorized Users working in independent Workspaces to collaborate on email interoperability. Information, such as an Authorized User’s profile and organizational information, may be shared, subject to the policies and practices of the Workspace(s) you use. For example, depending on the settings of your Workspace, to enable connections with other Authorized Users, your profile may be shared or searchable or discoverable by Authorized Users or other users outside of Workspace(s) you belong to, or shared via email when you invite an Authorized User or other users to collaborate. In many instances, Hook Security includes either administrator controls or user controls, depending on the use case, with respect to external collaboration. Authorized Users may also decide to expand the visibility of certain content and Customer Data, such as files.
  • Customer access. Owners, administrators, Authorized Users, and other Customer representatives and personnel may be able to access, modify, or restrict access to Information. This may include, for example, your employer using features of the Services to access or modify your profile details, or to export logs of Workspace activity. 
  • Third-Party service providers and partners. We may engage third-party companies or individuals as service providers or business partners to process Information and support our business. These third parties may, for example, provide virtual computing and storage services, assist Hook Security with verifying Owners and Customers, or we may share business information to develop strategic partnerships with Third-Party service providers to support our common customers. In this respect, depending on the Third-Party service provided, Hook Security may share your Information. Additional information about the subprocessors we use to support the delivery of our Services may be requested by contacting customer support services.
  • Third-Party Services. A Customer may enable, or permit Authorized Users to enable Third-Party Services. We require each Third-Party Service provider to disclose all permissions for information accessible through the Services, but we do not guarantee that they do so. When Third-Party Services are enabled by a Customer or an Authorized User, Hook Security may share Information with Third-Party Services. Third-Party Services are not owned or controlled by Hook Security and third parties that have been granted access to Information may have their own policies and practices for its collection, use, and sharing. Please check the permissions, privacy settings, and notices for these Third-Party Services or contact the provider for any questions.
  • Organizers and sponsors of Events/Webinars. If you attend an event or webinar organized by Hook Security, we may share your profile and organizational information with the event or webinar sponsors when you register, have your badge scanned, or join a breakout room. If required by applicable law, you may consent to such sharing via the registration form or by allowing your attendee badge to be scanned at a sponsor booth. In these circumstances, your information will be subject to the sponsors’ privacy statements. For more information, please refer to the terms provided when you register for such an event or webinar.
  • Professional advisers. We may share your Information with professional advisers acting as service providers, processors, controllers, or joint controllers - including lawyers, bankers, auditors, and insurers who provide consultancy, banking, legal, insurance, and accounting services, and to the extent, we are legally obliged to share or have a legitimate interest in sharing your Information containing personal data.
  • During a Change to Hook Security’s Business. If Hook Security engages in a merger, acquisition, bankruptcy, dissolution, reorganization, sale of some or all of Hook Security’s assets or stock, financing, public offering of securities, acquisition of all or a portion of our business, a similar transaction or proceeding, or steps in contemplation of such activities, some or all of the Information described in the ‘Information We Collect and Receive’ section may be shared or transferred, subject to standard confidentiality arrangements.
  • Aggregated or De-identified Data. We may disclose or use aggregated or de-identified Information for any purpose. For example, we may share aggregated or de-identified Information with prospects or partners for business or research.
  • Law Enforcement and Regulators. If we receive a request for information, we may disclose Other Information if we reasonably believe disclosure is in accordance with or required by any applicable law, regulation, or legal process. This may at times include information that Hook Security Inc. processes on behalf of Hook Security in its role as a subprocessor, including pursuant to the terms of any data protection agreement between Hook Security and its Customers.
  • To enforce our rights, prevent fraud, and for safety. To protect and defend the rights, property, or safety of Hook Security, its users, or third parties, including enforcing its contracts or policies, or in connection with investigating and preventing illegal activity, fraud, or security issues, including preventing death or imminent bodily harm.
  • With Consent. Hook Security may share Information with third parties when we have consent to do so or as otherwise permitted in this Privacy Policy. For Workspaces registered to corporate entities, Hook Security may share Information with the consent of the Workspace's primary owner or authorized corporate officer, or their designee. For workplaces created without a formal affiliation, Hook Security may require user consent.

Data Retention

Hook Security will retain Customer Data in accordance with a Customer’s instructions (including to perform any applicable terms in the Customer Agreement and through the Customer’s use of Services functionality) and as required by applicable law. The deletion of Customer Data and other use of the Services by the Customer may result in the deletion and/or de-identification of certain associated Other Information. For more detail, please review the Help Center or contact the Customer.

Hook Security may retain Other Information pertaining to you for as long as necessary for the purposes described in this Privacy Policy (such as to provide the Services, including any optional features you use, and to provide customer support). This may include keeping your Other Information after you have deactivated your account for the period of time needed for Hook Security to pursue legitimate business interests, conduct audits, comply with (and demonstrate compliance with) legal obligations, resolve disputes, and enforce our agreements.

Security

Hook Security takes the security of data very seriously. Hook Security works hard to protect Information you provide from loss, misuse, and unauthorized access or disclosure. These steps take into account the sensitivity of the Information we collect, process, and store, and the current state of technology. To learn more about current practices and policies regarding the security and confidentiality of the Services, please visit our Security Center (to be published online in December 2022). Given the nature of communications and information processing technology, Hook Security cannot guarantee that Information during transmission through the Internet or while stored on our systems or otherwise in our care will be absolutely safe from intrusion by others. When you click a link to a third-party site, you will be leaving our site and we don’t control or endorse what is on third-party sites.

Age Limitations

Hook Security does not allow the use of our Services and Websites by anyone younger than 16 years old, to the extent prohibited by applicable law. If you learn that anyone younger than 16 has unlawfully provided us with personal data, please contact us and we will take steps to delete such information.

Changes To This Privacy Policy

Hook Security may change this Privacy Policy from time to time. Laws, regulations, and industry standards evolve, which may make those changes necessary, or we may make changes to our services or business. We will post the changes to this page and encourage you to review our Privacy Policy to stay informed. If we make changes that materially alter your privacy rights, Hook Security will provide additional notice, such as via email or through the Services. If you disagree with the changes to this Privacy Policy, you should deactivate your Services account. Contact the Customer if you wish to request the removal of Personal Data under their control.

Data Protection Officer

To communicate with our Data Protection Officer, please email sittadel@hooksecurity.co.

Identifying The Data Controller And Processor

Data protection law in certain jurisdictions differentiates between the “controller” and “processor” of information. In general, the Customer is the controller of Customer Data. In general, Hook Security is the processor of Customer Data and the controller of Other Information. Different Hook Security entities provide the Services in different parts of the world.

  • Hook Security Inc., a U.S. company based in Greenville, South Carolina is the controller of Other Information and a processor of Customer Data relating to Authorized Users who use Workspaces established for Customers in the US and Canada.

Your Rights

Individuals in the European Economic Area, the United Kingdom, Brazil, and across the globe have certain statutory rights in relation to their personal data. Subject to any exemptions provided by law, you may have the right to request access to your personal information, as well as to seek to update, delete, or correct this information. You can do this using the settings and tools provided in your Services account. If you cannot use the settings and tools, contact the Customer who controls your workspace for additional access and assistance.

To the extent that Hook Security’s processing of your Personal Data is subject to the General Data Protection Regulation (GDPR) or other applicable laws requiring a legal basis for processing Personal Data, such as the UK Data Protection Act and the Brazilian General Data Protection Act (Lei Geral de Proteção de Dados), Hook Security primarily relies on its legitimate interests, described above, to process your Personal Data. Where we rely on legitimate interests to process your Personal Data, you can object to that processing by contacting us as described in the “Contacting Hook Security” section below. In response to your objection, we will stop processing your information for the relevant purposes unless we have compelling grounds in the circumstances or the processing is necessary in the context of legal claims. Hook Security may also process Other Information that constitutes your Personal Data for direct marketing purposes and you have a right to object to Hook Security’s use of your Personal Data for this purpose at any time.

Your California Privacy Rights

This section provides additional details about the personal information we collect about California consumers and the rights afforded to them under the California Consumer Privacy Act or “CCPA.”

In addition to the information provided above in the ‘Information We Collect And Receive’ section, we collect the following categories of personal information from you, your employer, data analytics providers, data brokers, and Third-Party Services:

  • Identifiers/contact information;
  • Commercial information;
  • Internet or electronic network activity information;
  • Financial information;
  • Geolocation information;
  • Professional or employment-related information; and
  • Inferences are drawn from any of the above categories.

We collect this information for the business and commercial purposes described in the ‘How We Process your Information and our Legal Bases for Doing So’ section above. We share this information as described in the ‘How We Share and Disclose Information section above. Hook Security does not sell (as such term is defined in the CCPA or otherwise) the personal information we collect (and will not sell it without providing a right to opt-out). Please note that we do use third-party cookies for our advertising purposes as further described in our Cookie Policy.

Subject to certain limitations, the CCPA provides California consumers the right to request to know more details about the categories or specific pieces of personal information we collect (including how we use, disclose, or may sell this information), to delete their personal information, to opt-out of any “sales” that may be occurring, and to not be discriminated against for exercising these rights.

California consumers may make a request pursuant to their rights under the CCPA by contacting us at support@hooksecurity.co. We will verify your request using the information associated with your account, including your email address. Government identification may be required. Consumers can also designate an authorized agent to exercise these rights on their behalf. Authorized agents must submit proof of authorization.

Data Protection Authority

Subject to applicable law, you also have the right to (i) restrict Hook Security’s use of Other Information that constitutes your Personal Data and (ii) lodge a complaint with your local data protection authority. If, however, you believe that we have not been able to assist with your complaint or concern, and you are located in the European Economic Area or the United Kingdom, you have the right to lodge a complaint with the competent supervisory authority. If you work or reside in a country that is a member of the European Union or that is in the EEA, you may find the contact details for your appropriate data protection authority on the following website. If you are a resident of the United Kingdom you may contact the UK supervisory authority, the Information Commissioner’s Office.

Contacting Hook Security

Please also feel free to contact Hook Security if you have any questions about this Privacy Policy or Hook Security’s practices, or if you are seeking to exercise any of your statutory rights. 

Hook Security will respond within a reasonable timeframe. You may contact us at support@hooksecurity.co or at our mailing address below:

502 East Main Street

℅ Hook Security Inc. 

Lakeland, FL 33801