Legal

Privacy Policy of LuJam Security Ltd

Policy Summary
Personal Data collected for the following purposes and using the following services:

    • Analytics

      • Google Analytics

        Personal Data: Cookies; Usage Data

    • Contacting the User

      • Mailing list or newsletter

        Personal Data: company name; email address; first name; last name

      • Contact form

        Personal Data: company name; email address; first name; last name; number of employees; phone number

      • Phone contact

        Personal Data: phone number

    • Handling payments

      • Stripe

        Personal Data: various types of Data as specified in the privacy policy of the service

    • Hosting and backend infrastructure

      • Amazon Web Services (AWS)

        Personal Data: various types of Data as specified in the privacy policy of the service

    • Interaction with external social networks and platforms

      • Twitter Tweet button and social widgets and Facebook Like button and social widgets

        Personal Data: Cookies; Usage Data

    • Managing contacts and sending messages

      • Sendgrid and Mailchimp

        Personal Data: email address

    • Managing support and contact requests

      • Zendesk

        Personal Data: various types of Data as specified in the privacy policy of the service

    • SPAM protection

      • Akismet

        Personal Data: various types of Data as specified in the privacy policy of the service

    • User database management

      • Pipedrive

        Personal Data: various types of Data as specified in the privacy policy of the service

Further information about Personal Data

    • LuJam Cloud

      Provider
      LuJam Cyber
      Purpose
      Cloud analytics for identifying malicious activity across multiple networks.
      Personal Data collected
      Email address, phone number, and user annotations.
      Protection
      All personal data is encrypted at rest, and is only used for alerting or presentation.
       
      All network data used by the LuJam Cloud is anonymized within the user’s network prior to uploading. All data is encrypted using SSL when being transferred across the Internet (both uploading data and downloading data).
       
      User passwords are salted as hashed in line with current security best practices.

    • Selling goods and services online

      The Personal Data collected are used to provide the User with services or to sell goods, including payment and possible delivery.
      The Personal Data collected to complete the payment may include the credit card, the bank account used for the transfer, or any other means of payment envisaged. The kind of Data collected by LuJam depends on the payment system used.
Contact information

    • Owner and Data Controller

      LuJam Security Limited
      Engine Shed
      Station Approach
      Temple Meads
      Bristol
      BS1 6QH
      United Kingdom
       
      Andy Ben-Dyke is the Data Protection Officer for LuJamSecurity. He can be contacted as shown below.

      Owner contact email: privacy@lujam.com

Full policy



Owner and Data Controller

LuJam Security Limited
Engine Shed
Station Approach
Temple Meads
Bristol
BS1 6QH
United Kingdom
 
Andy Ben-Dyke is the Data Protection Officer for LuJamSecurity. He can be contacted as shown below.

Owner contact email: privacy@lujam.com



Types of Data collected

Among the types of Personal Data that LuJam collects, by itself or through third parties, there are: Cookies; Usage Data; email address; first name; last name; company name; phone number; number of employees.

Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using LuJam.
Unless specified otherwise, all Data requested by LuJam is mandatory and failure to provide this Data may make it impossible for LuJam to provide its services. In cases where LuJam specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Any use of Cookies – or of other tracking tools – by LuJam or by the owners of third-party services used by LuJam serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy, if available.

Users are responsible for any third-party Personal Data obtained, published or shared through LuJam and confirm that they have the third party’s consent to provide the Data to the Owner.



Mode and place of processing the Data

Methods of processing

The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of LuJam (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.

Legal basis of processing

The Owner may process Personal Data relating to Users if one of the following applies:

  • Users have given their consent for one or more specific purposes. Note: Under some legislations the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;
  • provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
  • processing is necessary for compliance with a legal obligation to which the Owner is subject;
  • processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
  • processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.

In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Place

The Data is processed at the Owner’s operating offices and in any other places where the parties involved in the processing are located.
 
Depending on the User’s location, data transfers may involve transferring the User’s Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.
Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.
 
If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Owner using the information provided in the contact section.

Retention time

Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.

Therefore:

  • Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
  • Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.
The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.
 
Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.


The purposes of processing

The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following: Handling payments, Analytics, Hosting and backend infrastructure, Managing contacts and sending messages, Contacting the User, Managing support and contact requests, Interaction with external social networks and platforms, User database management and SPAM protection.

For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data”.



Detailed information on the processing of Personal Data

Personal Data is collected for the following purposes and using the following services:

  • Analytics

    The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.

    Google Analytics (Google Inc.)

    Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the Data collected to track and examine the use of LuJam, to prepare reports on its activities and share them with other Google services.
    Google may use the Data collected to contextualize and personalize the ads of its own advertising network.

    Personal Data processed: Cookies; Usage Data.

    Place of processing: US – Privacy Policy – Opt Out.

  • Contacting the User

    Mailing list or newsletter (LuJam)

    By registering on the mailing list or for the newsletter, the User’s email address will be added to the contact list of those who may receive email messages containing information of commercial or promotional nature concerning LuJam. Your email address might also be added to this list as a result of signing up to LuJam or after making a purchase.

    Personal Data processed: company name; email address; first name; last name.

    Contact form (LuJam)

    By filling in the contact form with their Data, the User authorizes LuJam to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form’s header.

    Personal Data processed: company name; email address; first name; last name; number of employees; phone number.

    Phone contact (LuJam)

    Users that provided their phone number might be contacted for commercial or promotional purposes related to LuJam, as well as for fulfilling support requests.

    Personal Data processed: phone number.

  • Handling payments

    Payment processing services enable LuJam to process payments by credit card, bank transfer or other means. To ensure greater security, LuJam shares only the information necessary to execute the transaction with the financial intermediaries handling the transaction.
    Some of these services may also enable the sending of timed messages to the User, such as emails containing invoices or notifications concerning the payment.

    Stripe (Stripe Inc)

    Stripe is a payment service provided by Stripe Inc.

    Personal Data processed: various types of Data as specified in the privacy policy of the service.

    Place of processing: US – Privacy Policy.

  • Hosting and backend infrastructure

    This type of service has the purpose of hosting Data and files that enable LuJam to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of LuJam. Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.

    Amazon Web Services (AWS) (Amazon)

    Amazon Web Services (AWS) is a hosting and backend service provided by Amazon Web Services, Inc.

    Personal Data processed: various types of Data as specified in the privacy policy of the service.

    Place of processing: See the Amazon privacy policy – Privacy Policy.

  • Interaction with external social networks and platforms

    This type of service allows interaction with social networks or other external platforms directly from the pages of LuJam.
    The interaction and information obtained through LuJam are always subject to the User’s privacy settings for each social network.
    This type of service might still collect traffic data for the pages where the service is installed, even when Users do not use it.
    It is recommended to log out from the respective services in order to make sure that the processed data on LuJam isn’t being connected back to the User’s profile.

    Twitter Tweet button and social widgets (Twitter, Inc.)

    The Twitter Tweet button and social widgets are services allowing interaction with the Twitter social network provided by Twitter, Inc.

    Personal Data processed: Cookies; Usage Data.

    Place of processing: US – Privacy Policy.

    Facebook Like button and social widgets (Facebook, Inc.)

    The Facebook Like button and social widgets are services allowing interaction with the Facebook social network provided by Facebook, Inc.

    Personal Data processed: Cookies; Usage Data.

    Place of processing: US – Privacy Policy.

  • Managing contacts and sending messages

    This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User.
    These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.

    Sendgrid (Sendgrid)

    Sendgrid is an email address management and message sending service provided by Sendgrid Inc.

    Personal Data processed: email address.

    Place of processing: US – Privacy Policy.

    Mailchimp (The Rocket Science Group, LLC.)

    Mailchimp is an email address management and message sending service provided by The Rocket Science Group LLC.

    Personal Data processed: email address.

    Place of processing: US – Privacy Policy.

  • Managing support and contact requests

    This type of service allows LuJam to manage support and contact requests received via email or by other means, such as the contact form.
    The Personal Data processed depend on the information provided by the User in the messages and the means used for communication (e.g. email address).

    Zendesk (Zendesk)

    Zendesk is a support and contact request management service provided by Zendesk Inc.

    Personal Data processed: various types of Data as specified in the privacy policy of the service.

    Place of processing: US – Privacy Policy.

  • SPAM protection

    This type of service analyzes the traffic of LuJam, potentially containing Users’ Personal Data, with the purpose of filtering it from parts of traffic, messages and content that are recognized as SPAM.

    Akismet (Automattic Inc.)

    Akismet is a SPAM protection service provided by Automattic Inc.

    Personal Data processed: various types of Data as specified in the privacy policy of the service.

    Place of processing: US – Privacy Policy.

  • User database management

    This type of service allows the Owner to build user profiles by starting from an email address, a personal name, or other information that the User provides to LuJam, as well as to track User activities through analytics features. This Personal Data may also be matched with publicly available information about the User (such as social networks’ profiles) and used to build private profiles that the Owner can display and use for improving LuJam.
    Some of these services may also enable the sending of timed messages to the User, such as emails based on specific actions performed on LuJam.

    Pipedrive (Pipedrive OÜ)

    Pipedrive is a User database management service provided by Pipedrive OÜ.

    Personal Data processed: various types of Data as specified in the privacy policy of the service.

    Place of processing: Estonia – Privacy Policy.



Further information about Personal Data

  • LuJam Cloud

    Provider
    LuJam Cyber
    Purpose
    Cloud analytics for identifying malicious activity across multiple networks.
    Personal Data collected
    Email address, phone number, and user annotations.
    Protection
    All personal data is encrypted at rest, and is only used for alerting or presentation.
     
    All network data used by the LuJam Cloud is anonymized within the user’s network prior to uploading. All data is encrypted using SSL when being transferred across the Internet (both uploading data and downloading data).
     
    User passwords are salted as hashed in line with current security best practices.

  • Selling goods and services online

    The Personal Data collected are used to provide the User with services or to sell goods, including payment and possible delivery.
    The Personal Data collected to complete the payment may include the credit card, the bank account used for the transfer, or any other means of payment envisaged. The kind of Data collected by LuJam depends on the payment system used.


The rights of Users

Users may exercise certain rights regarding their Data processed by the Owner.

In particular, Users have the right to do the following:

  • Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
  • Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
  • Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
  • Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
  • Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
  • Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.
  • Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User’s consent, on a contract which the User is part of or on pre-contractual obligations thereof.
  • Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

Details about the right to object to processing

Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.

Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.

How to exercise these rights

Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.



LuJam uses Trackers. To learn more, the User may consult the Cookie Policy.



Additional information about Data collection and processing

Legal action

The User’s Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of LuJam or the related Services.
The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.

Additional information about User’s Personal Data

In addition to the information contained in this privacy policy, LuJam may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.

System logs and maintenance

For operation and maintenance purposes, LuJam and any third-party services may collect files that record interaction with LuJam (System logs) use other Personal Data (such as the IP Address) for this purpose.

Information not contained in this policy

More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.

How “Do Not Track” requests are handled

LuJam does not support “Do Not Track” requests.
To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.

Changes to this privacy policy

The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within LuJam and/or – as far as technically and legally feasible – sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.
 
Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.


Personal Data (or Data)

Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.

Usage Data

Information collected automatically through LuJam (or third-party services employed in LuJam), which can include: the IP addresses or domain names of the computers utilized by the Users who use LuJam, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server’s answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User’s IT environment.

User

The individual using LuJam who, unless otherwise specified, coincides with the Data Subject.

Data Subject

The natural person to whom the Personal Data refers.

Data Processor (or Data Supervisor)

The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.

Data Controller (or Owner)

The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of LuJam. The Data Controller, unless otherwise specified, is the Owner of LuJam.

LuJam (or this Application)

The means by which the Personal Data of the User is collected and processed.

Service

The service provided by LuJam as described in the relative terms (if available) and on this site/application.

European Union (or EU)

Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.

Cookie

Cookies are Trackers consisting of small sets of data stored in the User’s browser.

Tracker

Tracker indicates any technology – e.g Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting – that enables the tracking of Users, for example by accessing or storing information on the User’s device.

Legal information

This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).

This privacy policy relates solely to LuJam, if not stated otherwise within this document.

Latest update: May 08, 2018