Privacy Policy
This Privacy Policy ("Privacy Policy") provides data subjects with information on the processing of their personal data (any information relating to them) by Positive Technologies ("Positive" or "we" or "us" or "our"). We protect companies and government entities ("Customers") from non-tolerable events using the latest cybersecurity technology through our own legal entities and our authorized partners ("Partners"). We also believe in the importance of education, which is why we conduct training and offer educational courses and programs for individuals and representatives of legal entities ("Participants"). For the purposes of this Privacy Policy, by Participants we also mean the participants of various events that we hold.
This Privacy Policy contains important information about the collection and use of personal data, the legal grounds for the processing of personal data, the disclosure of personal data to third parties, and the use of cookies by Positive. The Privacy Policy also covers the processing of personal data on our website https://global.ptsecurity.com/ ("Website").
This Privacy Policy is based on the provisions of data protection laws applicable in the country of your residence.
1. Controller
This Privacy Policy applies when we act as a data controller with regard to your personal data.
Data subjects can contact us with any questions relating to the processing of their personal data under this Privacy Policy by email: privacy@ptsecurity.com.
2. Categories of processed personal data
We may process the following personal data depending on the circumstances of our interaction with you. The table below sets out the categories of personal data we process.
| Category of data | Description |
| Data required to provide our services to Customers, Partners, and Participants | Full name, phone number, email address, identifiers in messengers and social networks, job title, structural unit and current place of employment, personal identifiers; data on technical means (devices) such as IPs; information automatically received from our services, including cookies, and information received as a result of your actions, including information about comments, requests, feedback, and questions you send us |
| Marketing data | Full name, phone number, email, identifiers in messengers, job title, and structural unit and current place of employment |
| Feedback data | Full name, phone number, email, identifiers in messengers, and information about comments, requests, reviews, and questions you send us |
| Data automatically collected by our Website | Cookies |
3. Purposes and legal basis for processing
We only process your personal data when we have a legal basis as follows:
3.1. Performance of an agreement. We may process your personal data to provide you with our services under an agreement between you/your company.
3.2. Legitimate Interest. We may process your personal data when we (or a third party) have an interest in using your personal data in a certain way that is necessary and justified considering the potential risks.
3.3. Consent. When required by applicable laws, we will process your personal data based on your consent.
3.4. Legal obligations. When we must process your personal data to comply with the law.
3.5. Other. We can also process your personal data to exercise our legal rights or on other legal bases provided by applicable law.
The table below sets out:
- Positive's purposes for processing personal data
- Positive's legal basis for each purpose under the law
- Categories of personal data that Positive uses for each purpose
| Purpose of processing | Legal basis | Categories of personal data used |
| To provide our services to our Customers, Partners, and Participants | Contract / Legitimate interest | Data required to provide our services to Customers, Partners, and Participants |
| To market, promote, and advertise our services | Consent / Legitimate interest | Data required to provide our services to Customers, Partners, and Participants; marketing data |
| To process feedback from you | Contract / Legitimate interest / Consent | Feedback data |
| To improve our services, including to train ML models | Legitimate interest | All data |
| To comply with legal obligations and law enforcement requests | Legal obligation / Legitimate interest | All data |
| To establish, exercise, or defend legal claims | Legitimate interest / Other | All data |
| To detect and prevent fraud | Legitimate interest | All data |
| To provide security | Legitimate interest | All data |
| To conduct research, contests, and surveys | Contract / Legitimate interest / Consent | Data required to provide our services to Customers, Partners, and Participants; marketing data, feedback data |
We do not process your personal data for other purposes that are not covered by this Privacy Policy.
4. Recipients and sources of personal data
4.1. We disclose certain personal data to the following recipients to the extent required or permitted by law and/or based on their legitimate and reasonable requests:
- Payment service providers
- ales and marketing service providers
- Service providers otherwise assisting in the provision of our services and achievement of other purposes mentioned in Section 3 of the Privacy Policy
- Affiliate entities of Positive that are part of the same group of companies
- Governmental and regulatory bodies, including law enforcement authorities, in connection with enquiries, proceedings, or investigations by such parties or to enable Positive to comply with its legal and regulatory requirements
4.2. We obtain personal data in any information you provide to us directly or through information provided by third parties. Below is a list of ways in which we collect your personal data.
Personal data collected from you directly, including:
- When you use our Website
- When you contact us for any enquiries, complaints, or for any other reason.
Personal data collected from other sources, including:
- Through third parties, including in a manner that is permitted
5. Transfers to third countries
We may transfer the personal data of data subjects to third countries that do not provide the same level of data protection as in the country of your residence. When doing so, we ensuret the implementation of security measures to protect your personal data in an appropriate manner.
You can obtain more information on the methods of transfer to third countries by Positive by sending us a request using the contact details specified in Section 1 of this Privacy Policy.
6. Storage periods
We store personal data for as long as it is required to achieve the purposes of the processing specified in Section 3 of this Privacy Policy unless there are specific periods defined by law.
If you wish to have personal data removed from our databases, please contact us by sending a request using the contact details specified in Section 1 of this Privacy Policy.
7. Basic rights of data subjects
Your rights and their descriptions are available in this table. Please note that the list of available rights may vary depending on the law as regards the relationship between you and Positive.
| Right | Description |
| Access | You can ask us to confirm whether or not we process your personal data. If we process your personal data, you can access the personal data and ask us to explain certain details of its processing. |
| Rectification | You can ask us to correct inaccurate personal data concerning you. If it complies with the purposes of processing, you can ask us to rectify incomplete or inaccurate personal data. |
| Erasure ("right to be forgotten") | You can ask us to erase personal data concerning you under applicable law. For example, this applies if (1) the personal data is no longer necessary in relation to the purposes for which they were processed, (2) you withdraw consent to processing and there is no other legal ground for its processing, (3) the personal data has been unlawfully processed. |
| Restriction on processing | You can ask us to mark the stored personal data to limit its processing in the future under applicable law. This applies if (1) you contest the accuracy of the personal data, (2) you ask us to restrict the use of the personal data when its processing is unlawful, (3) you need personal data to protect your rights when our services no longer need the personal data, (4) you have objected to processing based on the legitimate interests pursued by us or a third party. |
| Objection to processing | You can object on grounds relating to your particular situation at any time to the processing of personal data concerning you based on the legitimate interests pursued by Positive or a third party. We shall no longer process the personal data unless we demonstrate compelling legitimate grounds for its processing that override your interests, rights, and freedoms, or for the establishment, exercise, or defense of legal claims. |
| Portability | When the processing is based on your consent or in an agreement with you, you can receive the personal data that you have provided to us in a structured, commonly used and machine-readable format and can freely transmit the data to another controller. Where technically feasible, the data subject can also ask us to transmit the personal data directly to another controller. |
To exercise these rights, you can contact us using the contact details specified in Section 1 of this Privacy Policy.
8. Withdrawal of consent
Where processing is based on consent (or explicit consent), you have the right to withdraw consent at any time. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal. We can continue to process your personal data if we have another legal basis to do so. To withdraw consent, you can contact us using the contact details specified in section 1 of this Privacy Policy.
9. Right to submit a complaint to a supervisory authority
You have the right to submit a complaint to a supervisory authority for data protection in the country of your residence.
10. Cookies
| Type of cookies | Description |
| Strictly necessary | These cookies are necessary for the functioning of our websites and cannot be disabled. They are usually activated only in response to your actions similar to requesting services, such as setting a privacy level, logging in, or filling out forms. You can configure your browser to block these cookies or notify you about their use, but it is possible that some sections of our websites will no longer work or not work correctly. |
| Targeting | These cookies are configured through our websites by our advertising partners. They can be used by these companies to collect data about your interests and display relevant advertisements for you on other websites. If you do not approve of the use of these cookies, you will not be shown our targeted advertising on various websites. |
| Operational | These cookies allow us to count the number of visits and traffic sources to evaluate and improve the performance of our websites. Thanks to these cookies, we know which pages are the most and least popular, and we see how visitors navigate through our websites. |
| Functional | These cookies allow us to provide improved functionality and personalization, for example, for online chats and videos. They can be configured by us or third-party providers whose services are contained on our pages. If you do not approve of the use of these cookies, it is possible that some or all of these functions will not work properly. |
To opt out of the use of certain cookies, you have the right to use the features of our Website intended for this purpose. You also have the right to use your browser settings to disable the use of cookies. Detailed instructions on how to disable cookies are available at the following external links:
11. Children's privacy
We do not knowingly or intentionally collect personal data through our services from children under 18 (eighteen) years of age. If you are under 18 (eighteen) years of age or another age recognized in your jurisdiction as sufficient for the use of our services, do not attempt to register on or use our services, and do not provide us any personal data about yourself unless you have parental consent. If you are a parent or guardian and you are aware that your child has violated this Privacy Policy and provided us personal data, please contact us using the contact details specified in Section 1 of this Privacy Policy. If we become aware that a minor has provided us personal data or we otherwise process their personal data in violation of the Privacy Policy, we will take steps to remove that information.
12. Changes to this Privacy Policy
We may periodically amend this Privacy Policy at our sole discretion. If so, we may notify data subjects about these changes by an appropriate method. If there is no explicit notification, data subjects may read the up-to-date version of this Privacy Policy.
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