Last revised: February 5, 2018.
We are Cyclonis Limited, a company incorporated under the laws of Ireland with company registration number 57494, whose registered office is 3 Castle Street, Dublin, Ireland ("we", "us", or "our").
We are dedicated to establishing a trusting relationship with our users, based on respect for personal identity and information and by promoting the use of fair information practices. We want to demonstrate our commitment to our users' privacy and establish our users' trust in our ability to protect their information and data.
PART B - INFORMATION COLLECTION
We collect information from our users at several different points on our products and services, in accordance with the Data Protection Legislation and other applicable data protection laws, strictly for the purposes necessary to our business and our users' convenience.
All information will be obtained fairly. The information we collect will be adequate, relevant and not excessive in relation to the purposes for which it was obtained.
In order to use our products and services, a user must first complete the registration form. During registration a user is required to provide contact information (such as name and email address) and select a user name and password. We will also collect the user’s internet protocol (IP) address and hardware ID.
If the user accesses our products or services through a third party provider, we may receive this information from them, along with other personal data, for example the user ID.
We collect and use the information a user directly provides to us or one of our trusted partners, such as the information you provide when you access or use our products and services, information about how you access or use our products and services, and information you provide when communicating with us, including for with customer support.
Your username and a uniquely generated authentication password are sent and received during each communication for security, authentication and verification purposes and to help resolve disputes.
If you click the "Check for updates" button on the user interface, Cyclonis Password Manager sends us the Cyclonis Password Manager version number and language, a unique ID that identifies your copy of Cyclonis Password Manager, and the IP address of the computer on which Cyclonis Password Manager is installed. The Cyclonis Password Manager version number and unique ID are used to identify the specific updates to transmit and to allow a specific copy of Cyclonis Password Manager to be de-activated for the security and safety of our users, products and services, or our systems. No geolocation or other identifying information (such as IP address) is analysed or stored by Cyclonis Password Manager, other than in ordinary server logs, which are purged regularly.
Our servers use log files to analyse trends, administer and improve our products and services, track the different locations a user may use our products and services in the aggregate, and gather broad demographic information for aggregate use. This information may include IP addresses, geolocation information, hardware ID, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. We do not link this automatically collected data to other information we collect about you.
We may use Local Shared Objects (LSOs), such as Flash, to store content information and preferences. Third parties with whom we partner to provide certain features on our website, in our products or services or to display advertising based upon your web browsing activity may use LSOs to collect and store information. Various browsers may offer their own management tools for removing HTML5 LSOs. To manage Flash LSOs, please click here.
What is a Cookie?
Cookies are small text files sent from a server and stored to a user’s computer or other device. When a user visits a website or application more than once, the browser sends Cookies back to the website or application, allowing the website or application to recognise the user and remember things like their personalised details and preferences. More information about Cookies and details of how to manage or disable them can be found on aboutcookies.org.
Yes. We may obtain information about your general internet usage by using Cookies that are typically stored on the hard drive of your computer or other device.
What types of Cookies do we use?
Preferences: We use temporary “session” cookies which enables your browser to remember which pages on our website have already been visited and the language you have selected. This information may be used to help us to improve, administer and diagnose problems with our website and servers.
Third Party Cookies
Some Cookies that have been set on our services may not be related to or controlled by us and may originate from one of our partners, affiliates or service providers. We do not control the use of these Cookies and cannot access them due to the way Cookies work, as Cookies can only be accessed by the party which originally set them.
You should check the applicable third party’s website for more information about these Cookies.
You can change your browser or application settings so your device warns you each time a Cookie is sent, or to turn off all Cookies. Each web browser or application is different, so please look at your browser or application "help" menu to learn how to modify your Cookies preferences. However, if you disable Cookies you will not have access to certain features that may make your browsing of our website and use of our services smoother, and some of our services may not be available to you.
We may place ads for our products on various third-party websites and platforms, and as a result, you may see ads for our products when visiting Google, YouTube, Facebook and/or a variety of other websites and platforms. We may ask the proprietors of these websites/platforms to present our ads to particular demographic groups, for example, women over 25 years of age, or all visitors to a website who are in Ireland. The third-party websites/platforms may use information they already have about you, or may place cookies or similar tracking technologies in your browser or application, in order to decide what ads you will see, including potentially our ads. If you have questions or concerns about the ads you see on any of these third-party websites/platforms or if you have questions generally about their privacy practices, we encourage you to consult the privacy policies of those sites or inquire with the proprietors of those sites.
PART C – INFORMATION USE
Your personal data will be kept only for clear and legal purposes. All personal data will be processed fairly and in keeping with the purposes for which it was obtained.
We use your information for the following purposes:
We may communicate with users to assist with enquiries and to provide users with better customer service. To do so, we may reply via email, in-app message, or phone. If you contact us directly for any reason, and if we are able to provide support or service to you, we will use the information you have provided in order to respond to you, to assist with enquiries you have and to maintain our records.
On occasion it is necessary to send out a service related announcement. For instance, if one of our products or services is temporarily suspended for maintenance or we want to notify you about changes to our products and services, we might send users an email or other communication. These communications are not promotional in nature.
Generally, spamming means the use of electronic messaging systems to send unsolicited messages. We have a zero tolerance policy for abuse through spamming.
PART D - INFORMATION SHARING WITH OTHERS
The information we collect from you may be transferred to third parties in connection with operating our business. It may also be processed by these third parties and/or by our and their respective employees and service providers. We will take steps to ensure that these third parties will only process data in accordance with our instructions, and take appropriate security measures to protect your data.
By submitting your information, you agree to this transfer, storing or processing of your personal data by us.
We may disclose your information to the following third parties:
Where required or authorised by law, we reserve the right to release personal data without your consent and/or without consulting you, when we believe that this is appropriate to comply with our legal obligations, to protect the security of our products, services, systems and related technologies, to prevent and minimise the effects of fraud, and otherwise to protect our legitimate interests and/or the legitimate interests of our staff, users or members of the public.
International Data Transfers
PART E - THIRD PARTY LINKS AND CONTENT
Periodically, our site may request information from users via surveys. Participation in these surveys is completely voluntary and the user therefore has a choice whether or not to disclose this information. The requested information typically includes contact information (such as name and address) and demographic information (such as post code or zip code). Survey information will be used for purposes of monitoring or improving the use and satisfaction of our products and services. Though we may use an intermediary to conduct these surveys, they may not use customers' personal data for any secondary marketing purposes.
PART F – SECURITY AND PROTECTION OF YOUR INFORMATION
While we take these steps to maintain the security of your information, you should be aware of the many information security risks that exist and take appropriate care to help safeguard your information. The nature of the internet is such that we cannot guarantee the security of the information you transmit to us electronically, and any transmission is at your own risk. We store information you provide to us on secure servers and deploy appropriate technical and organisational security measures in the storage and disclosure of your personal data to try to prevent unauthorised access or loss.
We also rely on you to maintain security of your account with us. Due to our security features, we will not have access to your master password, or account information and passwords stored in your encrypted vault. You are responsible for safeguarding your account by keeping track of your account information, master password, or any other password, and using a strong master password and limiting its use to this account.
PART G – SOME FINAL TERMS
We retain your personal data for no longer than is necessary with regard to the purposes for which it was collected or lawfully further processed, or for so long as may be necessary in light of our legal obligations.
You have rights under the Data Protection Acts 1988 and 2003, and, from 25 May 2018, the General Data Protection Regulation (2016/679) (“Data Protection Legislation”). You may access personal data held about you, and may request that it is updated, corrected or that any inaccuracies in your personal data are deleted. You may also request that we cease processing that is causing you harm. You may bring any complaints to the Irish Data Protection Commissioner. Further information on your data privacy rights is available on the website of the Irish Data Protection Commissioner at http://www.dataprotection.ie.
You may withdraw your consent to our processing of your personal data at any time. You can access, correct or delete certain personal data and update your privacy preferences by contacting customer support. Alternatively, you can contact us via our Contact Us form.
Despite this, we retain the right to collect, process and maintain information provided by and collected about you, and disclose this information to the extent required to comply with our reasonable business and legal obligations. If you choose not to provide certain information to us or if you withdraw your consent to our processing of your personal data, we may not be able to continue to provide you with the products or services you require and/or it may affect our ability to better respond to your needs.
If you make an access request to us you acknowledge that applicable law may permit us to charge a fee in order to meet our costs in providing you with details of the information we hold about you.