Last Updated: January 6, 2020
Particularly Important Information
Who we are: For the purpose of applicable data protection legislation, the data controller of your Personal Data is Tenable, Inc. of 7021 Columbia Gateway Dr., Ste. 500, Columbia, MD 21046, and our affiliates.
Privacy and Our Customers: This Policy does not apply to the extent we process Personal Data provided by our customers through the provision of services and use of our products. For detailed privacy information related to instances where a Tenable customer and/or a customer affiliate that uses Tenable products and services is the controller, please reach out to the respective customer directly. We are not responsible for the privacy or data security practices of our customers, which may differ from those set forth in this Policy. For more information, please also see section 14 below.
Changes to this Policy: We will post any modifications or changes to the Policy on our Site. We reserve the right to modify the Policy at any time, so we encourage you to review it frequently. The “Last Updated” legend above indicates when this Policy was last changed. If we make any material change(s) to the Policy, we will notify you via email and/or post a notice on our Site prior to such changes(s) taking effect. We encourage you to periodically review this Policy to stay informed about our collection, processing, and sharing of your Personal Data.
1. Purposes of Processing
What is Personal Data?
We may collect information about you as set out in this Policy and that may include Personal Data. Personal Data may include: name, title, company name, job function, postal address, email address, telephone number, browser and device information (including IP address), and information collected through cookies and other similar technologies.
Why do we need your Personal Data?
We will only collect and/or process your Personal Data in compliance with applicable data protection and privacy laws and in accordance with this Policy. In order to provide you with access to the Site, we may process your Personal Data in accordance with this Policy. If you create a profile or register with us, you will be asked to agree to provide certain information in order to access our services or view our content. By agreeing to do so you consent to your Personal Data being processed by us. This consent provides us with the legal basis to process your Personal Data. If you change your mind and wish to withdraw your consent to us processing your Personal Data, you may withdraw your consent at any time.There may also be instances where you are required to provide your information to purchase products or access the Tenable Community and Tenable University. In such cases, Tenable has a legitimate business interest to process your Personal Data. If you do not agree to our use of your Personal Data in line with this Policy, please do not use our Site.
2. Collecting Your Personal Data
We collect information about you in the following ways:
Information You Give Us. This may include:
- any Personal Data you provide to us, including name, postal address, email address, telephone number, and a username;
- any Personal Data that may be contained in any video, comment, or other submission you upload or post to the Site;
- any Personal Data you provide when you report a problem with our Site or when we provide you with technical support for your evaluation license;
- any Personal Data you provide when you make a purchase through our Site;
- any Personal Data you provide when you use our Site’s live chat feature; and
- any Personal Data you provide when you correspond with us by phone, email, or otherwise.
Information from Social Networking Sites. Our Site includes interfaces that allow you to connect with social networking sites (each a “SNS”). If you connect to a SNS through our Site, you authorize us to access, use and store the information that you agreed the SNS could provide to us based on your settings on that SNS. We will access, use and store that information in accordance with this Policy. You can revoke our access to the information you provide in this way at any time by amending the appropriate settings from within your account settings on the applicable SNS.
Information We Get from Others. We may also get information about you from other sources, for example, if you have agreed to share information with one of our partners, listed here: https://www.tenable.com/partners/channel-partner-directory, or through our e-commerce provider, content syndicators, or other associated business partners.
Information Automatically Collected. We automatically log information about you and your computer or mobile device when you access our Site. For example, when visiting our Site, we identify an initial public IP address to identify where you are located, we log your computer or mobile device operating system name and version, browser type, browser language, screen resolution, the website you visited before browsing to our Site, pages you viewed, how long you spent on a page, access times and information about your use of and actions on our Site. We collect this information about you by using cookies. Please refer to the sections on cookies, flash technology and pixel tags below.
Automated Decision Making and Profiling. We may use automated decision making and/or profiling in regard to your Personal Data for some services and products, for example, when logging into Tenable’s Community, Tenable will need to identify if you are a customer or not, or messaging may change depending on your prior visits to our site. You can request a manual review of the accuracy of an automated decision that you are unhappy with or limit or object to such automated decision making and/or profiling by contacting us at [email protected].
What are cookies?
We may collect information using “cookies.” Cookies are small data files stored on the hard drive of your computer or mobile device by a website. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer or mobile device until you delete them) to provide you with a more personal and interactive experience on our Site.
We use two broad categories of cookies: (1) first party cookies, served directly by us to your computer or mobile device, which are used only by us to recognize your computer or mobile device when it revisits our Site; and (2) third party cookies, which are served by service providers on our Site, and can be used by such service providers to recognize your computer or mobile device when it visits other websites.
Cookies we use
Our site uses the following types of cookies for the purposes set out below:
|Type of cookie||Purpose|
These cookies are essential to provide you with services available through our Site and to enable you to use some of its features. For example, they allow you to log in to secure areas of our Site and help the content of the pages you request load quickly. Without these cookies, the services that you have asked for cannot be provided, and we only use these cookies to provide you with those services.
These cookies allow our Site to remember choices you make when you use our Site, such as remembering your language preferences, remembering your login details and remembering the changes you make to other parts of our Site which you can customize. The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you visit our Site.
|Analytics and Performance Cookies||
These cookies are used to collect information about traffic to our Site and how users use our Site. The information gathered does not identify any individual visitor. The information is aggregated and anonymous. It includes the number of visitors to our Site, the websites that referred them to our Site, the pages they visited on our Site, what time of day they visited our Site, whether they have visited our Site before, and other similar information. We use this information to help operate our Site more efficiently, to gather broad demographic information and to monitor the level of activity on our Site.
We use Google Analytics for this purpose. Google Analytics uses its own cookies. It is only used to improve how our Site works. You can find out more information about Google Analytics cookies here: https://developers.google.com/analytics/resources/concepts/gaConceptsCookies. You can find out more about how Google protects your data here: www.google.com/analytics/learn/privacy.html. You can prevent the use of Google Analytics relating to your use of our Site by downloading and installing the browser plugin available via this link: http://tools.google.com/dlpage/gaoptout?hl=en-GB.
|Targeted and advertising cookies||
These cookies track your browsing habits to enable us to show advertising which is more likely to be of interest to you. These cookies use information about your browsing history to group you with other users who have similar interests. Based on that information, and with our permission, third party advertisers can place cookies to enable them to show adverts which we think will be relevant to your interests while you are on third party websites.
You can disable cookies which remember your browsing habits and target advertising at you by visiting http://www.youronlinechoices.com/ or http://optout.aboutads.info/. If you choose to remove targeted or advertising cookies, you will still see advertisements, but they may not be relevant to you. Even if you do choose to remove cookies by the companies listed at the above link, not all companies that serve online behavioral advertising are included in this list, and so you may still receive some cookies and tailored advertisements from companies that are not listed.
|Social Media Cookies||These cookies are used when you share information using a social media sharing button or “like” button on [our Site/Application(s)/Services] or you link your account or engage with our content on or through a social networking website such as Facebook, Twitter or Google+. The social network will record that you have done this.|
You can typically remove or reject cookies via your browser settings. In order to do this, follow the instructions provided by your browser (usually located within the “settings,” “help” “tools” or “edit” facility). Many browsers are set to accept cookies until you change your settings.
Further information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org and www.youronlinechoices.com.uk.
4. Pixel Tags
We may also use pixel tags (which are also known as web beacons and clear GIFs) on our Site to track the actions of users on our Site. Unlike cookies, which are stored on the hard drive of your computer or mobile device by a website, pixel tags are embedded invisibly on webpages. Pixel tags measure the success of our marketing campaigns and compile statistics about usage of the Site, so that we can manage our content more effectively. The information we collect using pixel tags is not linked to our users’ Personal Data.
5. Using Your Personal Data
We may use your Personal Data as follows:
- to operate, maintain, and improve our Site;
- to evaluate your registration on our Site or for an evaluation license;
- to deliver the services you request and manage your account, including to communicate with you regarding your account on our Site or your evaluation license;
- to respond to your comments and questions;
- to send information including technical notices, updates, security alerts, and support and administrative messages regarding our Site or your evaluation license;
- to send you marketing communications, including via e-mail in compliance with applicable laws, about upcoming promotions, newsletters, new products, services, webinars, training seminars and other news, including information about products and services offered by us and our affiliates;
- to link or combine user information with other Personal Data;
- as we believe necessary or appropriate (a) to comply with applicable laws; (b) to comply with lawful requests and legal process, including to respond to requests from public and government authorities; (c) to enforce this Policy; and (d) to protect our rights, privacy, safety or property, and/or that of you or others; and
- as described in the “Sharing of your Personal Data” section below.
6. Sharing Your Personal Data
We may share your Personal Data as follows:
Third Parties Designated by You. We may share your Personal Data with third parties where you have provided your consent to do so.
Our Third Party Service Providers. We may share your Personal Data with our third-party service providers who provide services such as data analysis, distribution partners, resellers, information technology and related infrastructure provision (such as Amazon Web Services), email delivery, auditing, and other similar services. We may also give information to one of our partners, located here https://www.tenable.com/partners/channel-partner-directory. These third parties are only permitted to use your Personal Data to the extent necessary to enable them to provide their services to us. They are required to follow our express instructions and to comply with appropriate security measures to protect your Personal Data.
Third Party Advertisers. We may share Personal Data with advertisers and advertising networks that require the data to select and serve relevant advertisements to you and others.
Affiliates. We may share some or all of your Personal Data with our affiliates, in which case we will require our affiliates to comply with this Policy. In particular, you may let us share Personal Data with our affiliates where you wish to receive marketing communications from them.
Corporate Restructuring. We may share Personal Data when we do a business deal, or negotiate a business deal, involving the sale or transfer of all or a part of our business or assets. These deals can include any merger, financing, acquisition, or bankruptcy transaction or proceeding.
Other Disclosures. We may share Personal Data as we believe necessary or appropriate: (a) to comply with applicable laws; (b) to comply with lawful requests and legal process, including to respond to requests from public and government authorities to meet national security or law enforcement requirements; (c) to enforce our Policy; and (d) to protect our rights, privacy, safety or property, and/or that of you or others.
7. Anonymous Data
When we use the term “anonymous data,” we are referring to data and information that does not permit you to be identified or identifiable, either alone or when combined with any other information available to a third party.
We may create anonymous data from the Personal Data we receive about you and other individuals whose Personal Data we collect. Anonymous data might include analytics information and information collected by us using cookies. We make Personal Data into anonymous data by excluding information (such as your name) that makes the data personally identifiable to you. We use this anonymous data for our own purposes, including the ability to analyze usage patterns in order to make improvements to our Site.
8. Third Party Sites
Our Site may contain links to third party websites and features. This Policy does not cover the privacy practices of such third parties. These third parties have their own privacy policies and we do not accept any responsibility or liability for their websites, features or policies. Please read their privacy policies before you submit any data to them. For example, we may link to social media pages through widgets on our Site or we may provide links to industry reports.
9. User Generated Content
You may share Personal Data with us when you submit user generated content to our Site, including via our Tenable Community and Tenable University. Please note that any information you post or disclose on our Site will become public information, and will be available to other users of our Site and to the general public. We urge you to be very careful when deciding to disclose your Personal Data, or any other information, on our Site. Such Personal Data and other information will not be private or confidential once it is published on our Site.
10. International Data Transfer
Your information, including Personal Data that we collect from you, may be transferred to, stored and processed by us and our affiliates and other third parties outside the country in which you reside, including, but not limited to the United States, where data protection and privacy regulations may not offer the same level of protection as in other parts of the world. By using our Site, you agree to this transfer, storing or processing. If you are located in the European Economic Area (“EEA”), your Personal Data may be processed outside of the EEA and in countries which are not subject to an adequacy decision by the European Commission. In this event, we will ensure that the recipient of your Personal Data offers an adequate level of protection, for instance by entering into standard contractual clauses for the transfer of data as approved by the European Commission, or ensuring that such recipient is certified under the U.S.-EU and/or U.S.-Swiss Privacy Shield Frameworks. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Policy.
EU-U.S. Privacy Shield and Swiss-U.S. Privacy Shield
Tenable complies with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of Personal Data transferred from the EU, UK, and Switzerland to the United States. We have certified to the Department of Commerce that we adhere to the Privacy Shield Principles. If there is any conflict between the terms in this Policy and the Privacy Shield Principles, the Privacy Shield Principles shall take precedence. To learn more about the Privacy Shield program, the Privacy Shield Principles and to view our certification, please visit www.privacyshield.gov.
As described in the Privacy Shield Principles, Tenable is accountable for Personal Data that it receives and subsequently transfers to third parties. If third parties that process Personal Data on our behalf do so in a manner that does not comply with the Privacy Shield Principles, we are accountable, unless we prove that we are not responsible for the event giving rise to the damage.
In compliance with the Privacy Shield Principles, Tenable commits to resolve complaints about our collection or use of your Personal Data. EU, UK, and Swiss individuals with inquiries or complaints regarding this Policy should first contact us at [email protected].
Tenable has further committed to refer unresolved Privacy Shield complaints to JAMS, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, if we have not resolved your complaint, or wish to file a complaint, you can file a complaint with JAMS online HERE or contact:
Attn: Kathleen Pierz, Practice Development Manager, Global Privacy Shield and Safe Harbor Coordinator
620 Eighth Ave. 34th Floor
New York, NY 10018
The services of JAMS are provided at no cost to you.
As further explained in the Privacy Shield Principles, binding arbitration before a Privacy Shield Panel will also be made available to you in order to address residual complaints not resolved by any other means. Tenable is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission.
Employee Personal Data under Privacy Shield
Tenable commits to cooperate with the panel established by the EU data protection authorities (“DPAs”), the UK Information Commissioner’s Office (“ICO”), and the Swiss Federal Data Protection and Information Commissioner (“FDPIC”) and comply with the advice given by the panel with regard to human resources data transferred from the EU, UK, and Switzerland in the context of the employment relationship. Please contact us to be directed to the relevant DPA contacts.
We seek to use reasonable organizational, technical, and administrative measures to protect Personal Data within our organization. Unfortunately, no transmission or storage system can be guaranteed to be completely secure, and transmission of information via the internet is not completely secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us using the details in Section 17 below.
We will retain your Personal Data for a period of time consistent with the original purpose of collection (see Section 5, “Using Your Personal Data”). We determine the appropriate retention period for Personal Data on the basis of the amount, nature and sensitivity of your Personal Data processed, the potential risk of harm from unauthorized use or disclosure of your Personal Data, and whether we can achieve the purposes of the processing through other means, as well as on the basis of applicable legal requirements (such as applicable minimum statutory retention requirements). After the expiration of the applicable retention periods, we will delete your Personal Data. If there is any data that we are unable, for technical reasons, to delete entirely from our systems, we will put in place appropriate measures to prevent any further use of such data.
13. Our Policy on Children
We respect the sensitive nature of children’s privacy online. Our Site is not directed to children under 18 and we do not knowingly collect Personal Data from children under the age of 18. You must be at least eighteen (18) years old to register, purchase or apply online for our products, services, promotions and other activities. If you are under the age of eighteen (18), please do not provide us with any type of information about yourself. Tenable is not liable for any information provided to us by a person under the age of eighteen (18).
If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us at [email protected]. We will delete such information from our systems as soon as reasonably practicable.
14. Your Rights
You have certain rights relating to your Personal Data, subject to local data protection laws. Depending on the applicable laws, and, in particular, if you are located in the EEA, these rights may include:
- Opt-out. You may contact us anytime to opt-out of: (i) direct marketing communications; (ii) automated decision-making and/or profiling; (iii) our collection of sensitive Personal Data; (iv) any new processing of your Personal Data that we may carry out beyond the original purpose; or (v) the transfer of your Personal Data outside the EEA. Please note that your use of some of the Site may be ineffective upon opt-out.
- You may request what access Tenable has about you at any time by contacting us directly.
- You can also contact us to update or correct any inaccuracies in your Personal Data.
- Your Personal Data is portable – i.e., you to have the flexibility to move your data to other service providers as you wish.
- Erase and forget. In certain situations, for example when the information we hold about you is no longer relevant or is incorrect, you can request that we erase your data.
If you wish to exercise any of the rights set forth above, please contact us using the details in Section 17 below. In your request, please make clear: (i) what Personal Data is concerned; and (ii) which of the above rights you would like to exercise. For your protection, we may only implement requests with respect to the Personal Data associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable and in any event, within one month of your request. Please note that we may need to retain certain information for recordkeeping purposes, legal purposes and/or to complete any transactions that you began prior to requesting such change or deletion.
Your Rights Relating to Customer Data
As described above, we may also process Personal Data submitted by or for a customer of our products and services. To this end, if not addressed in this Policy or in a separate disclosure, we process such Personal Data in our role as processor on behalf of a customer (and/or its affiliates) who is the responsible controller of the Personal Data concerned. We are not responsible for and have no control over the privacy and data security practices of our customers, which may differ from those set forth in this Policy. If your data has been submitted to us by or on behalf a Tenable customer and you wish to exercise any rights you may have under applicable data protection laws, please inquire with the applicable customer directly. If you wish to make your request directly to us, please provide to us the name of the Tenable 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 within a reasonable timeframe.
Your Preferences for Email Communications
If you prefer not to receive promotional materials, our email newsletter or other forms of communication, you may choose to opt-out or manage your email subscriptions by using the unsubscribe link at the bottom of the email you have received from Tenable or by using the following link: http://www.tenable.com/contact-tenable/tenable-email-subscription-manage.... Tenable will honor your requests to opt-out of specified emails and marketing materials. Please note that opting out of marketing communications does not opt you out of receiving important business communications related to your current relationship with us, such as communications about your subscriptions or event registrations, service announcements, or security information.
15. Your California Privacy Rights
The California Consumer Privacy Act of 2018 (“CCPA”) gives California residents certain rights as described below. For this section, we use the terms “personal information” and “sale” as those are defined in the CCPA.
- Request to know – You have the right to request a copy of the categories or specific pieces of personal information that Tenable collects, uses, shares or sells about you.
- Request to delete - You have the right to request that Tenable delete the personal information we have collected from you.
- You have the right to request to opt out from the sale of your personal information. Because Tenable does not sell your personal information, you do not need to exercise this right.
Your right to know and right to delete are subject to certain exceptions under the CCPA, for example as necessary to perform or evidence a transaction or contract, comply with a legal obligation, or when a consumer’s identity cannot be reasonably verified.
Exercising your CCPA Rights
To make a CCPA request, you can:
- Call us toll-free at 833-720-0398.
- Email us at [email protected] using “CCPA Request” in the subject line.
Your request must (1) provide sufficient information to allow us to verify that you are the person about whom we have collected personal information, and (2) describe your request in sufficient detail to allow us to understand, evaluate, and respond to it. We may not respond to requests that do not meet these criteria. We will only use personal information provided in your request to verify your identity and complete your request.
You may also authorize an agent (“Authorized Agent”) to exercise your CCPA rights on your behalf. To do this, you must provide your Authorized Agent with written permission to exercise your rights on your behalf, and we may request a copy of this written permission from your Authorized Agent when they make a request on your behalf.
We will not discriminate against you for exercising any of your CCPA rights and we will not deny you goods or services, charge you a different price, or provide you with a lesser quality of goods or services if you exercise any of your CCPA rights.
Other California Resident Rights
Under California law, a California resident who has provided Tenable with personal information is entitled to request certain information with respect to the types of personal information that Tenable has shared with third parties for their direct marketing purposes. In accordance with California law, Tenable will, in response to your written request, provide you with the means to choose not to have your information shared.
California residents may request further information about our compliance with this law by emailing [email protected]. Please note that we are only required to respond to one request per individual per year and are not required to respond to requests made by means other than through this e-mail address.
We are committed to resolve any complaints about our collection or use of your Personal Data. If you would like to make a complaint regarding this Policy or our practices in relation to your Personal Data, please contact us at [email protected]. We will reply to your complaint as soon as we can and in any event, within 45 days. We hope to resolve any complaint brought to our attention, however if you feel that your complaint has not been adequately resolved, and you are located in the EEA, you have the right to submit a complaint to our governing supervisory authority, the Ireland Data Protection Commission:
Ireland Data Protection Commission
21 Fitzwilliam Square South
+353 578 684 800
17. Contact Information
We welcome your comments or questions about this Policy. You may contact us in writing at [email protected].