Notice to U.S. Residents
Last Updated: 17 August, 2023
This Notice to U.S. Residents includes state specific privacy notices and is intended to supplement our Privacy Policy. Capitalized terms used but not defined within this Notice have the meaning given to them in our Privacy Policy.
NOTICE TO CALIFORNIA RESIDENTS
This Notice to California Residents (“Notice”) explains how we collect, use, disclose, sell, share and retain personal information about California residents and the rights afforded to them under the California Consumer Privacy Act, as amended by California Privacy Rights Act (further “CCPA”). It is intended solely for, and is applicable only as to, California residents.
WatchGuard acts as a service provider for most of the personal information it receives or processes through the Services and follows the instructions of its customers that engaged WatchGuard with respect to how it processes your personal information. If you would like more information about how your personal information is processed by our customers, please contact those companies directly.
Notice at Collection of Personal Information
We currently collect, and in twelve (12) months prior to the Last Update Date of this Notice have collected, the following categories of personal information:
- Identifiers: such as name, email address, login details, account number, mailing address, phone number, details about your computers, devices, applications, and networks, including internet protocol (IP) address, cookie IDs and other online identifiers that are automatically assigned to your computer or device when you access the Internet.
- Internet or other electronic network activity information: such as your browsing history, search history, information regarding your interactions with internet websites, applications, and advertisements, our sites and Services (e.g., products or services you looked at or searched for online and the Services you used), details about your internet app, or network usage, including URLs or domain names of websites you visit, information about the applications installed on your device, or traffic data, pages that you visit before and after using the Services, the date and time of your visit, the amount of time you spend on each page, the links you click and pages you view within the Services, how you interact with the pages and forms and the difficulties you may be having with them, or other actions you take through use of the Services such as your preferences. This may also include our Services performance information, fault reports , crash logs, authentication logs, session data and aggregate or statistical information.
- Geolocation data: such as your IP address derived approximate physical location.
- Commercial information: including your purchases and engagement with our sites and Services, your contact preferences for marketing communications, data you provide when you contact WatchGuard for customer or technical support, which may include data about the state or condition of your device, or the content of your chats and other communications with WatchGuard.
- Financial information: including your credit card numbers and associated financial identifiers and billing address but only where you pay us directly for the Services.
- Audio and visual information: such as call recording data that may be used to verify your requests and enable WatchGuard to provide support services and investigate security incidents. We may also photograph or record WatchGuard events you participate in and publish such content on our website and social media accounts.
- Professional and employment-related information: such as your employer’s name, address, email and phone number, your job title and department, as well as information you provide when you apply for a job with us, such as your resume, desired pay, education and work history, and visa status. When you apply for a job with us you may also choose to provide your veteran status, disability status, and links to your website, blog, portfolio, or LinkedIn profile.
- Inferences: such as information gathered from your preferences or interests. We derive this information from the other types of personal information we collect, including internet or other electronic network activity information and commercial information.
We collect this personal information directly from you your devices or third-party sources as described in the Information You Provide to Us, Information We Collect Automatically, and Information We Collect from Other Sources sections of our Privacy Policy. Not all categories of personal information are collected from each source.
In addition to the purposes detailed in the Why We Collect and How We Use Your Information section of our Privacy Policy, we currently collect and have collected the above categories of personal information for the following business or commercial purposes:
- Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards.
- Helping to ensure security and integrity of our Services to the extent the use of your personal information is reasonably necessary and proportionate for these purposes.
- Debugging to identify and repair errors that impair existing intended functionality of our Services.
- Short-term, transient use, including, but not limited to, non-personalized advertising shown as part of your current interaction with us, provided that your personal information is not disclosed to another third party and is not used to build a profile about you or otherwise alter your experience outside the current interaction with us.
- Performing our Services, including maintaining or servicing your accounts with us, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, or providing similar services.
- Providing advertising and marketing services, except for cross-context behavioral advertising, to you provided that, for the purpose of advertising and marketing, our service providers and/or contractors shall not combine the personal Information of opted-out consumers that the service provider or contractor receives from us, or on our behalf with personal information that the service provider or contractor receives from, or on behalf of, another person or persons or collects from its own interaction with you.
- Undertaking internal research for technological development and demonstration.
- Undertaking activities to verify or maintain the quality or safety of our Services and devices that are owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance our Services and devices that are owned, manufactured, manufactured for, or controlled by us.
- Advancing our commercial or economic interests, such as by inducing another person to buy, subscribe to, or provide our Services, or enabling or effecting, directly or indirectly, a commercial transaction.
Sensitive Personal Information
We currently collect, and in the last twelve (12) months prior to the Last Update Date of this Notice have collected, the following categories of sensitive personal information:
- Social security, driver’s license, state identification card, or passport numbers are collected to ensure that proper documentation is in place if you are onboarded as one of WatchGuard employees or contractors.
- Racial or ethnic origin are collected if you are applying for a job with WatchGuard and choose to voluntarily provide such information along with your gender, veteran status, disability status, and links to your website, blog, portfolio, or LinkedIn profile.
- Debit card or credit card number in combination with security code are collected to process payments for your order if you chose to use our on-line store.
- WatchGuard account login in combination with password and credentials allowing access to your account are collected by WatchGuard to manage your account and to provide our Services.
- Precise geolocation. Depending on the Services you use, where you grant your permission, we will collect information about your device’s location using GPS, wireless, or Bluetooth technology to perform our Services. For example, when you use our Services to protect your mobile device, we may collect geolocation data of the device on which the product is installed. Some Services may also ask permission to access your location through the browser you are using on your computer. You can control access to precise location information through your mobile device or browser settings. This information is collected to enable WatchGuard to perform our Services, such as certain security features.
We currently collect and have collected the above categories of sensitive personal information for the following business or commercial purposes:
- Helping to ensure security and integrity of our Services to the extent the use of your personal information is reasonably necessary and proportionate for these purposes.
- Performing our Services, including maintaining or servicing your accounts with us, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, or providing similar services.
- Undertaking activities to verify or maintain the quality or safety of our Services.
We do not collect or process sensitive personal information for the purpose of inferring characteristics about individuals and do not process sensitive personal information or use it for purposes other than those allowed by the CCPA and its regulations. Consequently, we do not use or disclose sensitive personal information in a manner that requires us to offer a special right to limit our use of this data under the CCPA.
Information We Disclose for our Business and Commercial Purposes
The following table identifies the categories of personal information that we disclosed for a business purpose in the 12 months preceding the Last Updated Date of this Notice and, for each category, the categories of recipients to whom we disclosed personal information.
|
Category of Personal Information |
Categories of Third Parties |
|---|---|
|
Identifiers |
WatchGuard group companies; WatchGuard authorized resellers and distributors; contracted service providers, vendors, and consultants; sponsors of contests, events, or promotions for which you register; recipients of petitions you submit through our sites; your organization which is our business customer (if you use our services as an authorized user of one of our business customers); governmental authorities (where required by law). |
|
Internet or other electronic network activity information |
WatchGuard group companies; WatchGuard authorized resellers and distributors; contracted service providers, vendors, and consultants. |
|
General location data |
WatchGuard group companies; WatchGuard authorized resellers and distributors; contracted service providers, vendors, and consultants; your organization which is our business customer (if you use our services as an authorized user of one of our business customers); governmental authorities (where required by law). |
|
Commercial information |
WatchGuard group companies; WatchGuard authorized resellers and distributors; contracted service providers, vendors, and consultants; your organization which is our business customer (if you use our services as an authorized user of one of our business customers); governmental authorities (where required by law). |
|
Financial information and audio/visual information |
WatchGuard group companies; contracted service providers. |
|
Professional and employment-related information |
WatchGuard group companies; WatchGuard authorized resellers and distributors; contracted service providers, vendors, and consultants; sponsors of contests, events, or promotions for which you register; recipients of petitions you submit through our sites; your organization which is our business customer (if you use our services as an authorized user of one of our business customers); governmental authorities (where required by law). |
|
Inferences |
WatchGuard group companies; WatchGuard authorized resellers and distributors; contracted service providers, vendors, and consultants. |
We disclosed personal information for the following business or commercial purposes:
- Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards.
- Helping to ensure security and integrity of our Services to the extent the use of your personal information is reasonably necessary and proportionate for these purposes.
- Debugging to identify and repair errors that impair existing intended functionality of our Services.
- Short-term, transient use, including, but not limited to, non-personalized advertising shown as part of your current interaction with us, provided that your personal information is not disclosed to another third party and is not used to build a profile about you or otherwise alter your experience outside the current interaction with us.
- Performing our Services, including maintaining or servicing your accounts with us, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, or providing similar services.
- Providing advertising and marketing services, except for cross-context behavioral advertising, to you provided that, for the purpose of advertising and marketing, our service providers and/or contractors shall not combine the personal Information of opted-out consumers that the service provider or contractor receives from us, or on our behalf with personal information that the service provider or contractor receives from, or on behalf of, another person or persons or collects from its own interaction with you.
- Undertaking internal research for technological development and demonstration.
- Undertaking activities to verify or maintain the quality or safety of our Services and devices that are manufactured for or by us, and to improve, upgrade, or enhance our Services and devices that are owned, manufactured for or by us.
- Advancing our commercial or economic interests, such as by inducing another person to buy, subscribe to, or provide our Services, or enabling or effecting, directly or indirectly, a commercial transaction.
Any personal information or other information you choose to submit in communities, forums, or blogs on our websites may be read, collected, and used by others who visit these forums, depending on your account settings.
The following table identifies the categories of sensitive personal information that we disclosed for a business purpose in the 12 months preceding the Last Updated Date of this Notice and, for each category, the categories of recipients to whom we disclosed personal information.
|
Category of Sensitive Personal Information |
Categories of Third Parties |
|---|---|
|
Social security, driver’s license, state identification card, or passport numbers |
WatchGuard affiliates and service providers to run our employees’ or contractors’ background checks, provide medical insurance and perform other functions necessitated by employment or contractor engagement. |
|
Racial or ethnic origin |
WatchGuard affiliates and service providers to facilitate application process. Applicable only if you are applying for a job at WatchGuard and choose to provide such information. |
|
Debit card or credit card number in combination with security code |
WatchGuard affiliates and service providers for the purpose of performing our services and payment processing. |
|
WatchGuard account login in combination with password |
WatchGuard affiliates and service providers for the purpose of performing and securing our services. |
|
Precise geolocation |
WatchGuard affiliates and service providers for the purpose of performing and securing our services. |
We disclosed sensitive personal information for the following business purposes:
- Helping to ensure security and integrity of our Services to the extent the use of your personal information is reasonably necessary and proportionate for these purposes.
- Performing our Services, including maintaining or servicing your accounts with us, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, or providing similar services.
- Undertaking activities to verify or maintain the quality or safety of our Services.
We do not collect or process sensitive personal information for the purpose of inferring characteristics about individuals and do not process sensitive personal information or use it for purposes other than those allowed by the CCPA and its regulations. Consequently, we do not use or disclose sensitive personal information in a manner that requires us to offer a special right to limit our use of this data under the CCPA.
Information We “Share” and “Sell”
Under the CCPA, “sale” means the disclosure of your personal information by us to a third party in exchange for money or any other thing of value. We do not sell your personal information in the conventional sense (i.e., for money), but engage in online activities that may constitute a sale of personal information under the CCPA.
“Sharing” under the CCPA means our disclosure of your personal information to a third party in order to serve you behavioral or interest-based targeted advertising. Please note that CCPA’s definition of “sharing” does not cover disclosure of your personal information to third parties for our “business purposes”, such as improving and securing our Services or providing customer support.
Using the CCPA’s definitions of the terms above, please refer to following table that identifies the categories of personal information we sold or shared to third parties in the 12 months preceding the Last Updated Date of this Notice and, for each category, the categories of third parties to whom we sold or shared personal information:
|
Category of Personal Information |
Categories of Third Parties |
|---|---|
|
Identifiers |
WatchGuard distributors, resellers, and advertisers, event sponsors, network analytics providers. |
|
Internet or other electronic network activity information |
WatchGuard distributors, resellers, and advertisers, network analytics providers. |
|
General location data |
WatchGuard distributors, resellers, and advertisers, network analytics providers. |
|
Commercial information |
WatchGuard distributors, resellers, and advertisers, network analytics providers. |
|
Professional and employment-related information |
WatchGuard distributors, resellers, and advertisers, network analytics providers. |
|
Inferences |
WatchGuard distributors, resellers, and advertisers, network analytics providers. |
Please note that not every data point that falls into the categories above is necessarily shared with all of the third parties listed.
We sold or shared personal information to third parties for the following business or commercial purposes:
- Advancing our commercial or economic interests, such as by inducing another person to buy, subscribe to, or provide our Services, or enabling or effecting, directly or indirectly, a commercial transaction. This includes lead prospecting, conducting shared advertising and marketing campaigns with our business partners, providing advertising and marketing services, including for cross-context behavioral advertising.
We do not “sell” or “share” sensitive personal information.
Data Retention
We retain your personal information for as long as necessary to fulfill the purposes for which we collect it, such as to provide you with the Services you have requested, and for the purpose of satisfying any legal, accounting, contractual, or reporting requirements that apply to us. To find out how we determine the length of time during which we will process your personal information, please see the Storage and Retention of Your Personal Information section of our Privacy Policy.
California Residents Privacy Rights and How to Exercise Them
If you are a California resident, you have certain rights with respect to your personal information outlined below. We encourage you to exercise your rights and will not discriminate against you for doing so. You can submit privacy rights requests by emailing us at [email protected] or by calling us at 1-877-232-3531, unless instructed otherwise below.
Opt Out of “Sale” or “Sharing”. You have the right to opt out of the “sale” or “sharing” of your personal information, as defined by the CCPA. To learn how CCPA defines “sales” and “sharing” of personal information, please refer to Information We “Share” and “Sell” section above. If you would like to opt out of CCPA “sales” and “shares” of your personal information that was collected through cookies and similar technologies used on our website, please opt out through our Cookie Preference Center. You may also opt out through user-enabled privacy controls, such as a browser plugin, privacy setting or other mechanism, that communicate or signal your choice to opt-out of the sale or sharing of your personal information. If you have enabled privacy controls on your browser (such as a plugin), we will also treat that as a valid request to opt out. Please see Opt-Out Preference Signals section of our Privacy Policy for more information.
After opting out, you may continue to see non-targeted advertisements on our Services. You may also continue to see advertising that could be based on personal information processed before you opted out. Please note that opt out action needs to be repeated from each browser you use to access our webpages. You will also need to repeat the process if at any point you clear the cookies from a particular browser.
Access. This Policy outlines the categories of personal information we may collect, the categories of sources from which the personal information is collected, the business or commercial purposes for collecting, selling, or sharing personal information, and the categories of third parties to whom we disclose personal information. You can request us to provide specific pieces of personal information we process currently or have processed in the past.
Correction. If you believe that any personal information we hold about you is incorrect, you may submit a request as described above and we will make sure the information we process about you is accurate. You can also change or update some information, like your contact details, through your account page.
Deletion. Per your request, we will delete personal information we hold about you. Please note that under some circumstances (e.g., where you are still an active user of our Services) we may have to delay full deletion of information about you as we need it to fulfill our obligations to you. We may also be required to retain limited information about you after completing your request for the purposes of legal compliance.
Our Request Verification Process
Where necessary, we will comply with your request upon verification of your identity and, to the extent applicable, the identity of the California resident on whose behalf you are making such request. Our verification process may differ depending on whether you maintain a password-protected account with us. If we need additional information to verify your identity, we will let you know.
You can also designate an agent to make requests to exercise your rights under CCPA as described above. We will take steps both to verify the identity of the person seeking to exercise their rights as listed above, and to verify that your agent is authorized to make a request on your behalf, such as through providing us with a signed written authorization or a copy of a power of attorney.
Notice Regarding California Residents We Know to Be Under the Age of 16
We do not knowingly collect, share or sell personal data of minors under 16 years of age.
Shine the Light Law
If you are a California resident, California Civil Code § 1798.83 permits you to request information regarding the disclosure of your personal information by us to third parties for the third parties' direct marketing purposes (as those terms are defined in that statute). To make such a request, please send an email to [email protected] with the subject line “Shine the Light Request” or write to us.
ACCESSIBILITY
We are committed to ensuring this Notice is accessible to individuals with disabilities. If you wish to access this Notice in an alternative format, please contact us as described below.
CHANGES TO THIS NOTICE
WatchGuard may change this Notice from time to time. If we make any changes to this Notice, we will post an amended version and change the Last Updated date above or if we make a material update, we may provide you with notice prior to the update taking effect, such as by posting a conspicuous notice on our website or by contacting you using the email address you provided. Please review this Notice periodically.
HOW TO CONTACT US
If you have any questions about this Notice, please email: [email protected].
By registered mail:
WatchGuard Technologies, Inc.
Attn: Legal Department
255 S. King St.
Suite 1100
Seattle WA
98104 USA
Please note that you may also submit your requests or complains directly to our DPO at [email protected].
NOTICE TO NEVADA RESIDENTS
Nevada law allows Nevada residents to opt-out of the sale of certain types of personal information. Subject to several exceptions, Nevada law defines "sale" to mean the exchange of certain types of personal information for monetary consideration to another person. We do not currently sell personal information as defined in the Nevada law. However, if you are a Nevada resident, you can still submit a verified request to opt out of sales and we will record your instructions and incorporate them in the future if our policy changes. You can send opt-out requests to [email protected].