Welcome to Surance Ltd. (“Surance” or “us”). Surance is committed to your right to privacy. This Privacy Notice (“Privacy Notice”), is an integral part of our Terms of Use, which can be found at: [Insert Link] and governs the processing, use and transfer of data collected in connection with cyber insurance services and other tools, products and services offered by Surance (“Services”) including the Services provided on our mobile application (the “App”) or otherwise offered by Surance, including in partnership with third parties, such as insurance companies and agencies, to each person (“User” or “you”) accessing or using the App and/or Services.

 

If you choose to install the App, use, interact with or register for the Services or otherwise provide data to us or through the App and/or Services, you explicitly agree to the use of such data in accordance with this Privacy Notice. You may not use the App and/or Services or submit any data through the App and/or Services if you do not agree to any of the terms hereunder. If you do not agree with any of the terms hereunder, you must discontinue any use of the Services and uninstall the App from your device. This Privacy Notice shall not be construed in any manner to derogate from the Terms of Use or any other agreement made by and between Surance and you.

 

THE HIGHLIGHTS:

 

  • You are not required by law to provide us with any Personal Data. Sharing Personal Data with us is entirely voluntary.

  • Our Services are intended for Users over the age of 16 or equivalent minimum age for providing consent to processing of Personal Data in the relevant jurisdiction. Children under such age are not permitted to register to or use the Services by their own. If you are under such age you should cease to use the Services immediately. 

  • Our Services require the monitoring of household systems and networks data. In connection with such processing, Personal Data regarding members of User's household will also be collected and processed by us. Prior to using the Services, you are responsible to inform and obtain the consent of any members using the household's systems and networks to the processing of Personal Data as specified herein.

  • If any minors under the age of 16 are residing in your household, your consent to this Notice will also apply to any Personal Data regarding such minors.

  • You may be entitled to request to review, amend, erase or restrict the processing of your Personal Data, pursuant to applicable law. Please note that in case you request to erase or restrict the processing of your Personal Data, your use of the Services may be restricted.

  • We do not sell, trade, or rent Users' Personal Data to third parties. We only share Personal Data with third parties in connection with the provision of the Services to our Users, or other limited circumstances specified herein.

  • If you have any questions or requests regarding the processing of your Personal Data, or would otherwise like to contact us in connection with this Privacy Notice, please send us an email to: privacy@surance.io.

 

1. What is Personal Data, and what data is collected about me by Surance? 

“Personal Data”, means any information which identifies or can be used to identify a natural person, including, but not limited to, first and last name, phone number, email address, IP address, billing information, etc. 

 

Non-Personal Data

We collect non-Personal Data regarding Users concerning their use of the wired and wireless (WiFi) home networks and systems, and any devices connected to them (collectively, “Home Networks”) and the connected devices (smart TVs, game consuls, video streamers, etc.), such as latency, device identifiers, and other technical information regarding the devices used to access the Home Networks, such as model, operating system, etc

 

Personal Data 

1.1 In order to use the Services, you may be requested to create an account and provide us with certain Personal Data, such as name, email address, home address, etc. (the “Account”).

1.2. We also collect the following data in connection with the provision of the Services to you:

1.2.1. Geo location;

1.2.2. IP address and mobile device unique identifiers;

1.2.3. Phone numbers;

1.2.4. Networks data;

1.2.5. Data regarding devices connected to the Home Networks, and photographs of such devices;

1.3. We will recollect data abovementioned on a regular basis, in order to monitor ongoing use of the Home Networks. For example, Personal Data will be recollected every time your smart phone is connected with the Home Networks.

1.4. We may deploy certain other components on other devices in your home in order to connect to your Home Networks and monitor your network on a regular basis.

1.5. We do not knowingly collect or process any Personal Data included in Special Categories of Personal Data (as defined in the GDPR). In the event you become aware that such data has been collected by us, please inform us immediately.

 

2. Does Surance use cookies? 

Yes, we use data files such as cookies, pixel tags, “Flash cookies,” or other local storage files provided by your browser or associated applications (“Cookies”). We use these technologies in order to recognize you as a customer; customize our Services, risk prediction, pricing calculation; measure promotional effectiveness; help ensure that your account security is not compromised; mitigate risk and prevent fraud; and to promote trust and safety across our sites and Services. 

We use both session and persistent Cookies. Session Cookies expire and no longer have any effect when you are no longer connected to the Home Networks. Persistent Cookies remain on your device and/or the Home Networks until you erase them or they expire. 

 

You may at any time program the Home Networks to block cookies, but please be aware that such blocking may prevent us from providing some or all of the Services to you.

 

3. What will Surance do with my Personal Data?

3.1. Non-Personal Data. Non-Personal Data is used to provide our Services, and for click stream analysis in order to constantly improve and maintain our Services, including among others, in order to provide 3 ongoing protection of your Home Networks and connected devices and to identify any data breaches. We also process non-Personal Data for general business analytics, for ensuring the technical functioning of our network, to help prevent fraudulent use of our Services and for developing new services.

3.2. Personal Data. Personal Data is used only for the following limited purposes: 

3.2.1. Providing our Services to you, including implementing the Services' features and functionalities; 

3.2.2. To identify Users of the Home Networks and authenticate their authorizations; 

3.2.3. To verify that the Home Networks are not public or commercial; 

3.2.4. To discover and asses the risk to your Home Network. 

3.2.5. To identify cyber threats to the Home Networks, including cyber-attacks, malware penetration, unlawful destruction, loss, alteration, unauthorized disclosure of, or access to data transmitted through or stored on the Home Networks and address attacks remotely. 

3.2.6. To communicate with Users regarding customer service issues or to provide updates with respect to material changes to this Privacy Notice or our Terms of Use. 

3.2.7. Responding to questions or comments and to help resolve any problems. 

3.2.8. For the purposes of our legitimate interests, to the extent permitted under applicable law. 

3.2.9. To protect the security or integrity of our databases and the Services, to take precautions against legal liability and to enforce the Terms of Use. 

3.2.10. To comply with any applicable law or regulatory requirement, including guidance by competent supervisory authority, and assist law enforcement agencies and competent authorities. 

3.2.11. To improve your experience on the App and customize our Services to your interests.

3.3. Please note that we may also use Personal and non-Personal Data in connection with automatic analysis of our users' behavior. In certain jurisdictions such processing of Personal Data is defined as profiling, or automatic decision making. If relevant to you under applicable law, you may be entitled to object to such processing, and may do so by sending as a notice to: privacy@surance.io.

 

4. What can I do to control my Personal Data? 

4.1. Reviewing and amending your Personal Data. You may review the information in your Account on the App. You may also send us a request in connection with your Personal Data to: privacy@surance.io . In the event any Personal Data is incorrect or outdated, you may update and correct such data by providing us with appropriate notification or correcting the data directly on the App if applicable. 

4.2. Right of erasure and restriction. You may also be entitled request the erasure or the restriction of your Personal Data, and we will comply with such requests, to the extent required under applicable law. 

4.3. Personal Data Portability of Personal Data. To the extent applicable to you and to the Services, you may request the portability of your Personal Data, and we will comply with such requests, to the extent required under applicable law. 

4.4. Retention of Data. We reserve the right to retain any Personal Data for as long as reasonably necessary in order to: (i) fulfill the purposes described herein; (ii) in the defense or assertion of legal claims and liability; (iii) for the analyses and improvement of the Services; and (iv) to comply with 4 applicable law. Non-Personal Data and statistical anonymized data may be retained by us without limitation.

 

5. Will Surance Share My Personal Data?

5.1. Non-Personal Data, aggregate and statistical or otherwise anonymized or pseudo-anonymized data may be shared without limitation with third parties at our discretion. This information does not contain any Personal Data and is used to develop content and services for our Users and clients.

5.2. We share Personal Data only under the following limited circumstances:

5.2.1. With third parties who assist us in operating and providing the Services, conducting our business and expanding our business or servicing you, for example, service providers operating call centers who will contact Users in any case of an attack on Home Networks.

5.2.2. To comply with a legal requirement, for the administration of justice, to protect your vital interests or the vital interests of others, to protect the security or integrity of our databases or the Services, to take precautions against legal liability, or in the event of a corporate sale, merger, reorganization, dissolution or similar event.

 

6. What is the lawful basis under which 
Surance processes Personal Data? 

6.1. Certain processing activities conducted by us are based on the necessity of such activities for the performance of the contract or other agreements between us and our Users. For example, we need your Home Networks data to discover and asses any possible cyber-risks to your network, alert you  of such risks, and address them appropriately.

6.2. Other processing activities are based on the grounds that they are necessary for the purposes of our legitimate interests or the legitimate interests of a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subjects which require protection of Personal Data.

6.3. There may be certain processing activities based on your consent to this Privacy Notice. In connection with such activities, you may rescind your consent, by sending us an email to: privacy@surance.io.

Please note that in the event you rescind your consent to the processing of Personal Data, we may not be able to provide you with some or all of the Services.

 

7. Will Surance transfer my Personal Data internationally? 

 

 

Surance is an international company with offices in various jurisdictions. Our databases are located currently in Ireland, Singapore, Hong Kong, Canada and in Israel. Some of our processing activities are made in the State of Israel. The European Commission has decided that Israel ensures an adequate level of privacy and data protection, therefore, in accordance with the GDPR, the transfer of Personal Data to Israel is lawful and does not require any specific authorization. 

 

Any future transfer of Personal Data outside the EEA to a third country (other than Israel) shall be made in accordance with applicable law, including by providing adequate protections, or otherwise implementing appropriate safeguards to ensure the protection of our Users' rights.

 

8. Will I receive SPAM from Surance? 

We may send users of the Services, with information on new products, features, activities, services and periodic announcements or newsletters. By accepting this Privacy Notice you hereby provide us with your explicit, written consent to receive marketing communications. You may at any time choose to opt-out and to not receive these communications, by contacting us at unsubscribe@surance.io.

 

9. Persons under 16 
Our App is a general audience App which is not directed to persons under 16 years old. If a parent or guardian becomes aware that his or her child has provided us with Personal Data without their consent, he or she should contact us immediately. We do not knowingly collect or solicit Personal Data from people under 16 years old. If we become aware that a person under 16 years old has provided us with Personal Data, we will delete such data from our databases.

 

10. How does Surance protect your data? 

We implement appropriate measures to reduce the risks of damage, loss of information and unauthorized access or use of information in accordance with the applicable law. 

 

11. Questions or concerns regarding privacy 

If you have any questions or concerns regarding privacy issues, please send us a detailed 
to: privacy@surance.io and we will make every effort to resolve your concerns without delay.

 

Surance may, at any time and from time to time, modify this Privacy Notice. Modifications to this Privacy Notice will be posted on the App, and shall be effective as of the date in which they are posted on the App.