Last Updated: February 2020

This privacy policy (“Privacy Policy”) governs how we, White Source Ltd. (“WhiteSource” “we”, “our” or “us”) use, collect and store information pertaining to you (“User”, “you”) in the following use cases:

1. When you browse or visit of one of our following websites: https://app.whitesourcesoftware.com, https://app-eu.whitesourcesoftware.com, https://bolt.whitesourcesoftware.com, https://renovate.whitesourcesoftware.com, https://saas.whitesourcesoftware.com, https://vuln.whitesourcesoftware.com, https://www.whitesourcesoftware.com and any other sub-domain operated by us (“Website”);
2. When you create an account and/or log in to our Platform or use our Services (as these terms are defined in our Terms of Service, available at https://www.whitesourcesoftware.com/terms-of-service/);
3. When you request a free trial;
4. When you commence direct communications with us (for example through our help desk chat or Contact Us page on the Website);
5. When we use your log data;
6. When you submit your resume for one of the positions offered on our Website;
7. When we use the personal data of our service providers and our suppliers (e.g., contact details).
8. When we acquire your Personal Data from third-party sources (such as lead-generation companies).

We greatly respect your privacy, which is why we make every effort to provide a platform that would live up to the highest of user privacy standards. Please read this Privacy Policy carefully, so you can fully understand our practices in relation to Personal Data. “Personal Data” means any information that can be used, alone or together with other data, to uniquely identify any living human being. Please note that this is a master privacy policy and some of its provisions only apply to individuals in certain jurisdictions. For example, the legal basis in the table below is only relevant for GDPR-protected individuals.

Table of contents:

1. What Personal Data we Collect, Why we Collect it, and How it is Used
2. Period of Storage of Collected Information
3. How we Protect your Personal Data
4. How we share your Personal Data
5. Information About You that we Get from Third-Parties
6. Additional Information Regarding Transfers of Personal Data
7. Your Rights; How to Delete your Account;
8. Analytic Tools;
9. Links to and Interaction with Third Party Products;
10. Specific Provisions Applicable Under California Law;
11. Use by Children
12. Contact Us

This Privacy Policy may be updated from time to time and therefore we ask you to check back periodically for the latest version of the Privacy Policy, as indicated below. If there will be any significant changes made to the use of your Personal Data in a manner different from that stated at the time of collection, we will notify you by posting a notice on our Website or by other means.

1. WHAT PERSONAL DATA WE COLLECT, WHY WE COLLECT IT, AND HOW IT IS USED

1. 2. PERIOD OF STORAGE OF COLLECTED INFORMATION

• Retention Personal Data. Your personal data (as described above) will be stored until we: (i) no longer need the information and proactively delete it or (ii) you send a valid deletion request. Please note that we will retain it for a longer or shorter period in accordance with data retention laws.

• Additional Information on Data Retention. Other circumstances in which we will retain your personal data for longer periods of time include: (i) where we are required to do so in accordance with legal, regulatory, tax or accounting requirements, or (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges, or (iii) if we reasonably believe there is a prospect of litigation relating to your personal data or dealings. We have an internal data retention policy to ensure that we do not retain your personal data perpetually. Regarding retention of cookies, you can read more in our cookie policy (available in the link provided above).

3. HOW WE PROTECT YOUR PERSONAL DATA

We have implemented appropriate technical, organizational and security measures designed to reduce the risk of accidental destruction or loss, or the unauthorized disclosure or access to such information appropriate to the nature of the information concerned. However, please note that we cannot guarantee that the information will not be exposed as a result of unauthorized penetration to our servers. Nevertheless, we make commercially reasonable efforts to make the collection and security of such information consistent with this Privacy Policy and all applicable laws and regulations. As the security of information depends in part on the security of the computer, device or network you use to communicate with us and the security you use to protect your user IDs and passwords, please make sure to take appropriate measures to protect this information.

4. HOW WE SHARE YOUR PERSONAL DATA 

In addition to the recipients described in the table above, we may share your personal data as follows:

• To the extent necessary, with regulators, to comply with all applicable laws, regulations and rules, and requests of law enforcement, regulatory and other governmental agencies or if required to do so by court order;
• If, in the future, we sell or transfer some or all of our business or assets to a third party, we will (to the minimum extent required) disclose information to a potential or actual third-party purchaser of our business or assets, or in the event of bankruptcy or a comparable event, we reserve the right to transfer or assign Personal Data in connection with the foregoing events.
• Where you have provided your consent to us sharing the Personal Data (e.g., where you provide us with marketing consents or opt-in to optional additional services or functionality).
• Where we receive requests for information from law enforcement or regulators, we carefully validate these requests before any Personal Data is disclosed.

For more information on the recipients of your personal data, please contact us at: dpo@whitesourcesoftware.com

5. INFORMATION ABOUT YOU THAT WE GET FROM THIRD-PARTIES 

• If you access our Services through connected third party applications (such as Google, GitHub, GitLab or Microsoft), we will receive certain information (including Personal Data, as described in Section 1) about you from the provider of such third party applications. The scope of information we receive depends on your third party application privacy settings.
• If you access our Services from a third-party application or connect our Services to a third-party application, you should also read that third-party application’s terms of service and privacy policy.
• If you are unclear about what information a third-party application is sharing with us, please go to the third-party application to find out more about their privacy practices.

6. ADDITIONAL INFORMATION REGARDING TRANSFERS OF PERSONAL DATA

• Internal transfers: We ensure transfers with the affiliated companies of WhiteSource will be covered by an agreement entered into by members of the WhiteSource group which contractually obliges each member to ensure that personal data receives an adequate and consistent level of protection wherever it is transferred to. 

• External transfers: Where we transfer your personal data outside of the EU/EEA, for example to third parties who help provide our products and services, we will obtain contractual commitments and or assurances from them to protect your Personal Data or rely on adequacy decisions issued by the European Commission. Some of these assurances are well recognized certification schemes, which you can read more about here: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en; and

• Where we receive requests for information from law enforcement or regulators, we carefully validate these requests before any personal data is disclosed.

7. YOUR RIGHTS; HOW TO DELETE YOUR ACCOUNT  

• Rights. The following rights (which may be subject to certain exemptions or derogations), shall apply to individuals who are protected by the GDPR. Some of these rights may also apply under your applicable law:

• You have a right to access personal data held about you. Your right of access may normally be exercised free of charge, however we reserve the right to charge an appropriate administrative fee where permitted by applicable law;
• You have the right to request that we rectify any personal data we hold that is inaccurate or misleading;
• You have the right to request the erasure/deletion of your personal data (e.g., from our records). Please note that there may be circumstances in which we are required to retain your personal data, for example for the establishment, exercise or defense of legal claims;
• You have the right to object, to or to request restriction, of the processing;
• You have the right to data portability. This means that you may have the right to receive your personal data in a structured, commonly used and machine-readable format, and that you have the right to transmit that data to another controller;
• You have the right to object to profiling;
• You have the right to withdraw your consent at any time. Please note that there may be circumstances in which we are entitled to continue processing your data, in particular if the processing is required to meet our legal and regulatory obligations. Also, please note that the withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal;
• You also have a right to request certain details of the basis on which your personal data is transferred outside the European Economic Area, but data transfer agreements and/or other details may need to be partially redacted for reasons of commercial confidentiality;
• You have a right to lodge a complaint with your local data protection supervisory authority (i.e., your place of habitual residence, place or work or place of alleged infringement) at any time or before the relevant institutions in your place of residence. We ask that you please attempt to resolve any issues with us before you contact your local supervisory authority and/or relevant institution.

You can exercise your rights by contacting us at dpo@whitesourcesoftware.com. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly or inform you if we require further information in order to fulfill your request. When processing your request, we may ask you for additional information to confirm your identity and for security purposes, before disclosing the Personal Data requested to you. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive. In the event that your request would adversely affect the rights and freedoms of others (for example, would impact the duty of confidentiality we owe to others) or if we are legally entitled to deal with your request in a different way than initial requested, we will address your request to the maximum extent possible, all in accordance with applicable law.

• Deleting your account. you ever decide to delete your Account, you may do so by emailing dpo@whitesourcesoftware.com. If you terminate your Account, any association between your Account and information we store will no longer be accessible through your Account. However, in certain portions of the Services, any public activity on your Account relating to such Services will remain stored on our servers (or on third party servers) prior to deletion and will remain accessible to the public.

8. ANALYTIC TOOLS

Google Analytics. The Website uses a tool called “Google Analytics” to collect information about use of the Website. Google Analytics collects information such as how often users visit this site, what pages they visit when they do so, and what other sites they used prior to coming to this Website. We use the information we get from Google Analytics to maintain and improve the Website and our products. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Google’s ability to use and share information collected by Google Analytics about your visits to this Website is restricted by the Google Analytics Terms of Service, available at http://www.google.com/analytics/terms/us.html/, and the Google Privacy Policy, available at http://www.google.com/policies/privacy/. You may learn more about how Google collects and processes data specifically in connection with Google Analytics at http://www.google.com/policies/privacy/partners/. You may prevent your data from being used by Google Analytics by downloading and installing the Google Analytics Opt-out Browser Add-on, available at https://tools.google.com/dlpage/gaoptout/.

AdRoll. The Website uses a tool called AdRoll by which we may occasionally collect User data by placing a cookie on a User’s browser for targeted advertising policies. You can opt out of receiving targeted ads served by us or on our behalf by clicking here: https://app.adroll.com/optout/safari. Please note that, if you delete your cookies or upgrade your browser after having opted out, you will need to opt out again. Further, if you use multiple browsers or devices you will need to execute this opt out on each browser or device. If you opt-out we may collect some data about your online activity for operational purposes (such as fraud prevention) but it won’t be used by us for the purpose of targeting ads to you. For more information regarding AdRoll’s use of data collected you can read the AdRoll Service Privacy Notice available at: https://www.nextroll.com/privacy, and the general terms governing the use of AdRoll are available at: https://www.nextroll.com/terms.

For more information regarding opting out of getting targeted, you can visit http://www.aboutads.info/ (DAA), http://optout.networkadvertising.org/?c=1 (NAI) or http://www.youronlinechoices.com/ (EDAA (Europe only)).

9. LINKS TO AND INTERACTION WITH THIRD PARTY PRODUCTS

The Website may enable you to interact with or contain links to your third party account and other third party websites, and services that are not owned or controlled by us (each, a “Third Party Service”). We are not responsible for the privacy practices or the content of such Third Party Services. Please be aware that Third Party Services may collect Personal Information from you. Accordingly, we encourage you to read the terms and conditions and privacy policy of each Third Party Service that you choose to use or interact with.

10. SPECIFIC PROVISIONS APPLICABLE UNDER CALIFORNIA LAW
    • Access Requests. California Civil Code Section 1798.83 (and other, similar state statutes) permits our customers who are California residents (or residents of states with similar statutes) to request certain information regarding our disclosure of Personal Data to third parties for their direct marketing purposes. To make such a request, please send an email to dpo@whitesourcesoftware.com. Please note that we are only required to respond to one request per customer each year.
    • Deletion Of Content From California Residents. If you are a California resident under the age of 18 and a registered user, California Business and Professions Code Section 22581 permits you to remove content or Personal Data you have publicly posted. If you wish to remove such content or Personal Data and you specify which content or Personal Data you wish to be removed, we will do so in accordance with applicable law.  Please be aware that after removal you will not be able to restore removed content. In addition, such removal does not ensure complete or comprehensive removal of the content or Personal Data you have posted and that there may be circumstances in which the law does not require us to enable removal of content.
    • Our California Do Not Track Notice. We do not currently respond or take any action with respect to web browser “do not track” signals or other mechanisms that provide consumers the ability to exercise choice regarding the collection of personal information about an individual consumer’s online activities over time and across third-party web sites or online services. We may allow third parties, such as companies that provide us with analytics tools, to collect personal information, subject to applicable law, about an individual consumer’s online activities over time and across different web sites when a consumer uses the Services.

11. USE BY CHILDREN 

We do not offer our products or services for use by children. If you are under 18, you may not use the Website, or provide any information to the Website without the involvement of a parent or a guardian. We do not knowingly collect information from, and/or about children.

12. CONTACT US 

If you have any questions, concerns or complaints regarding our compliance with this notice and the data protection laws, or if you wish to exercise your rights, we encourage you to first contact us at dpo@whitesourcesoftware.com.