This Policy details our commitment to protecting the privacy of individuals who visit our Websites (“Website Visitors”), who register to use the products and services which we market for subscription (available at www.compass-security.com (the “Service(s)”, or who attend or register to attend sponsored events or other events at which the CSNC Group participates (“Attendees”). For the purposes of this Policy, the term, “Websites”, shall refer collectively to www.compass-security.com as well as the other websites that the CSNC operates and that link to this Policy.
2 Scope Of This Policy
In addition to the Websites that link to this Policy, this Policy applies to the following:
- Compass Security Group Websites: *.compass-security.com
- The Hacking Lab (*.hacking-lab.com / *.hacking-lab-ctf.com)
- Filebox Solution: *.filebox-solution.com
- CSNC group Mobile Applications ("Apps"): HackyEaster / ConFoxy, Filebox Client and other Apps provided by CSNC
In this Policy, personal information means information relating to an identified or identifiable natural person. An identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, and online identifier or to one or more factors specific to his/her physical, physiological, genetic, mental, economic, cultural or social identity. The use of information collected through our Service shall be limited to the purpose of providing the Service for which the Subscribers has engaged.
Our Websites may contain links to other websites and the information practices and the content of such other websites are governed by the privacy statements of such other websites. We encourage you to review the privacy statements of any such other websites to understand their information practices.
3 Information That You Provide To Us
Account and Registration Information:
We ask for and may collect personal information about you such as your name, address, phone number, email address, gender and birthdate information.
We refer to any information described above as “Account Information” for the purposes of this Policy. By voluntarily providing us with Account Information, you represent that you are the owner of such personal data or otherwise have the requisite consent to provide it to us.
We ask for and may collect personal information from you when you submit web forms on our Websites or as you use interactive features of the Websites, including, participation in surveys, contests, promotions, sweepstakes, requesting customer support, or otherwise communicating with us.
We ask for and may collect personal information such as your name, address, phone number and email address when you register for or attend a sponsored event or other events at which any member of the CSNC Group participates.
Mobile Application: When you download and use our Services, we automatically collect information on the type of device you use, and operating system version. These data is collected by our Apps (in addition to the "Account Information"):
- Hacky-Easter: Score, Solutions
- ConFoxy: Photos and comments
- Filebox Client: File content as exchanged by the FileBox owners and communication partners
4 Information That We Collect From You on our Websites
Cookies and Other Tracking Technologies:
We collect analytics information when you use the Websites to help us improve them:
- www.compass-security.com and blog.compass-security.com use Matomo/Piwik in anonymized mode.
- Hacking-Lab uses Hacking-Lab Analytics based on browser fingerprinting technologies for fraud detection. Hacking-Lab stores IP-addresses, nicknames, usage times, browser and operating system properties.
- We are using Google Analytics on certain websites. Please refer to section 7 in this document.
As is true with most websites and services delivered over the Internet, we gather certain information and store it in log files when you interact with our Websites and Services. This information includes internet protocol (IP) addresses as well as browser type, internet service provider, URLs of referring/exit pages, operating system, date/time stamp, information you search for, locale and language preferences, identification numbers associated with your devices, your mobile carrier, and system configuration information.
5 Information Collected From Other Sources
Social Media Buttons:
Our Websites provides a link to social media websites like Facebook or Twitter. We do not use Social Media Plugins. Your interactions with these features are governed by the privacy statement of the companies that provide them.
6 How We Use Information That We Collect
We may use the information we collect about you (including personal information, to the extent applicable) for a variety of purposes, including to (a) provide, operate, maintain, improve, and promote the Services; (b) enable you to access and use the Services; (c) process and complete transactions, and send you related information, including purchase confirmations and invoices or job advertisements; (d) send transactional messages, including responses to your comments, questions, and requests; provide customer service and support; and send you technical notices, updates, security alerts, and support and administrative messages; (e) process and deliver contest entries and rewards; (f) monitor and analyze trends, usage, and activities in connection with the Websites and Services and for marketing or advertising purposes; (g) investigate and prevent fraudulent transactions, unauthorized access to the Services, and other illegal activities; and (h) for other purposes for which we obtain your consent.
If we send you promotional communications, such as providing you with information about products and services, features, surveys, newsletters, offers, promotions, contests, and events; and provide other news or information about us and our partners, we will ask you for your explicit consent (dual opt-in or similar method) before we will do so. You can opt-out of receiving marketing communications from us by contacting us at privacy(at)compass-security.com or following the unsubscribe instructions included in our marketing communications.
Legal Basis for Processing:
We collect personal information from you only where: (a) we have your consent to do so, (b) where we need the personal information to perform a contract with you (e.g. to deliver the CSNC Services you have requested), or (c) where the processing is in our or a third party’s legitimate interests based on the GDPR. In some cases, we may also have a legal obligation to collect personal information from you.
Where we rely on your consent to process the personal information, you have the right to withdraw or decline your consent at any time. Please note that this does not affect the lawfulness of the processing based on consent before its withdrawal.
If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information). Similarly, if we collect and use your personal information in reliance on our (or a third party’s) legitimate interests which are not already described in this Notice, we will make clear to you at the relevant time what those legitimate interests are.
If you have any questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided further below in Section 16.
7 Sharing Of Information Collected
Third-Party Service Providers:
We host some of our webservers at Metanet (Metanet, Josefstrasse 218, CH-8005 Zürich). We use the service "Server Housing". This means, the provider does not have access to personal information stored on our servers.
OST, Ostschweizer Fachhochschule, Oberseestrasse 10, 8640 Rapperswil (https://www.ost.ch), a public Swiss university with a strong background in information security is hosting our public lab. They are a IaS-Provider operating the Hacking-Lab infrastructure whereas the Hacking-Lab platform itself is operated by ourselves.
We use Google Analytics, a web analysis service of Google Ireland Limited ("Google") which is based on cookies. We may use this service on the basis of our legitimate interests (i.e. interest in the analysis, optimisation and efficient operation of our online offer in the sense of Art. 6 Para. 1 lit. f. of the GDPR).
We act in accordance with the GDPR principles. The information generated by the cookie about the use of the online offer by the user is usually transferred to a Google server in the USA and stored there. Detailed information on the data collected can be found here: "Information for visitors of websites and apps that are analysed with the help of Google Analytics": https://support.google.com/analytics/answer/6004245?hl=de&ref_topic=2919631 Google is certified under the Privacy Shield Agreement and thus offers a guarantee of compliance with European and Swiss data protection laws (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).
Google will use this information on our behalf to evaluate the use of our online services by users, to compile reports on activities within this online service and to provide us with other services related to the use of this online service and the Internet. Pseudonymous user profiles can be created from the processed data.
We use Google Analytics to display ads placed by Google and its partners within advertising services only to users who have shown an interest in our online services or who have certain characteristics (e.g. interests in certain topics or products determined on the basis of the websites visited) which we transmit to Google (so-called "remarketing" or "Google Analytics Audiences"). With the help of remarketing audiences, we would also like to ensure that our ads correspond to the potential interest of the users and do not appear annoying.
We use Google Analytics only with IP anonymization enabled. This means that the IP address of the user is shortened by Google within member states of the European Union or in other contracting states of the Agreement in the European Economic Area and Switzerland. Only in exceptional cases is the full IP address transmitted to a Google server in the USA and shortened there.
Your data from Google Analytics will be stored for a maximum of 14 months.
The IP address transmitted by the user's browser is not merged with other Google data.
Information about Google Analytics and the settings to protect your privacy can be found here: https://support.google.com/analytics/topic/2919631?hl=de&ref_topic=1008008
For more information about Google's use of data and about setting and objection options, please visit the following Google webpages: https://www.google.com/intl/de/policies/privacy/partners ("Use of data by Google when using the websites or apps of our partners"), https://policies.google.com/technologies/ads ("Use of data for advertising purposes"), https://adssettings.google.com/authenticated ("Manage information Google uses to display advertising").
We use the European mail delivery service "Sendinblue" to send our newsletters (www.sendinblue.com). This service is GDPR compliant and has entered into a data processing agreement with us, you can find more information here: https://www.sendinblue.com/gdpr/. By subscribing to the newsletter, you have to accept Sendinblue's terms and conditions for processing your data. The use of the newsletter service is independent of this website.
Compliance with Laws and Law Enforcement Requests; Protection of Our Rights:
In certain situations, we may be required to disclose personal information in response to lawful requests by public authorities, including to meet law enforcement requirements. We may disclose personal information to respond to subpoenas, court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims. We may also share such information if we believe it is necessary in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our Service Agreement, or as otherwise required by law.
The Websites may offer publicly accessible blogs, community forums, comments sections, discussion forums, or other interactive features (“Interactive Areas”). You should be aware that any information that you post in an Interactive Area might be read, collected, and used by others who access it. To request removal of your personal information from an Interactive Area, contact us at privacy(at)compass-security.com. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.
CSNC Group Sharing:
We may share information, including personal information, with any member of the CSNC Group.
With Your Consent:
We may also share personal information with third parties when we have your consent to do so.
8 International Transfer Of Information Collected
CSNC is a Switzerland based, global company. We store personal information about Website Visitors and Subscribers in Switzerland or in a member of the EU or in Canada. To facilitate our global operations, we may transfer and access such personal information from around the world, including from other countries in which the CSNC Group has operations for the purposes described in this Policy. We may also transfer your personal information to our third party subprocessors as in section 7, who may be located in a different country to you. However, we only process your personal data in countries which are part of the EU or apply the same level of data protection as defined in the GDPR.
Whenever CSNC shares personal information with a CSNC entity it will do so on the basis of its CSNC Binding Data Protection Rules which establish adequate protection of such personal information and are legally binding on the CSNC Group.
If you are visiting our Websites please note that you are agreeing to the transfer of your personal information to the jurisdictions in which we operate. By providing your personal information, you consent to any transfer and processing in accordance with this Policy.
9 Communications Preferences
We offer those who provide personal contact information a means to choose how we use the information provided. You may manage your receipt of marketing and non- transactional communications by clicking on the “unsubscribe” link located on the bottom of our marketing emails or you may send a request to privacy(at)compass-security.com.
10 How Long We Retain Your Personal Information:
11 Your Privacy Rights
The security of your personal information is important to us. We follow the GDPR standards to protect the personal information submitted to us. If you have any questions about the security of your personal information, you can contact us at privacy(at)compass-security.com.
Upon request we will provide you with information about whether we hold, or process personal information about you. To request this information please contact us privacy(at)compass-security.com.
In addition, you will have the following rights:
- Right of erasure: You have a right to erasure of personal information that we hold about you – for example, if it is no longer necessary in relation to the purposes for which it was originally collected. Please note, however, that we may need to retain certain information for record keeping purposes, to complete transactions or to comply with our legal obligations.
- Right to object to processing: You have the right to request that CSNC stop processing your personal information and/or to stop sending you marketing communications.
- Right to restrict processing: You have the right to request that we restrict processing of your personal information in certain circumstances (for example, where you believe that the personal information we hold about you is inaccurate or unlawfully held).
- Right to data portability: In certain circumstances, you may have the right to be provided with your personal information in a commonly used format and to request that we transfer the personal information to another data controller without hindrance.
To make a request to have personal information maintained by us returned to you or removed, please email us. Requests to access, change, or remove your information will be handled within thirty (30) days.
If you would like to exercise such rights, please contact us at the contact details in Section 16 below. We will consider your request in accordance with applicable laws. To protect your privacy and security, we may take steps to verify your identity before complying with the request.
You also have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.
12 Children’s Personal Information
We do not knowingly collect any personal information from children. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce this Policy by instructing their children never to provide personal information through the Websites or Services without their permission. If you have reason to believe that a child under the age of 14 has provided personal information to us through the Websites or Services, please contact us at privacy(at)compass-security.com and we will use commercially reasonable efforts to delete that information.
13 Business Transactions
We may assign or transfer this Policy, as well as your account and related information and data, including any personal information, to any person or entity that acquires all or substantially all of our business, stock or assets, or with whom we merge.
14 Supplemental Terms and Conditions for Certain Regions
Personal information (as the term is defined in the Personal Information Protection and Electronic Documents Act of Canada (“PIPEDA”)) will be collected, stored, used and/or processed by the CSNC Group in compliance with the CSNC Group’s obligations under PIPEDA.
15 Changes To This Policy
If there are any material changes to this Policy, you will be notified by our posting of a prominent notice on the Websites prior to the change becoming effective. Based on the severity and impact on your personal rights, your consent might be required for certain changes. In this case, we will notify you and ask for your consent.
In cases of minor changes which do not have an impact on your privacy, we will announce the changes on the websites. We encourage you to periodically review this page for the latest information on our privacy practices. Your continued use of the Websites or the Services constitutes your agreement to be bound by such changes to this Policy. Your only remedy, if you do not accept the terms of this Policy, is to discontinue use of the Websites and the Services.
16 Contact Us
If you have questions regarding this Policy or about the CSNC Group’s privacy practices, please contact us by email at privacy(at)compass-security.com, or at:
Compass Security Network Computing AG
Phone: +41 58 510 36 00
17 Choice of Law/Forum Selection
The exclusive place of jurisdiction for disputes arising from the Use of Terms is Rapperswil-Jona, Canton of St Gallen (Switzerland).
English Version Controls:
English translations of this Policy are provided for convenience only. In the event of any ambiguity or conflict between translations, the German version is authoritative.