Privacy Policy

Last updated: February 26, 2021

This Privacy Policy of BastionZero, Inc. doing business as Commonwealth Crypto, Inc.(collectively, the “Company,” “our,” “we,” or “us”) describes how we collect, use, disclose and otherwise process Personal Information when individuals (collectively, “you” or “your”) access and use our website and Service.

It also states how you can control the collection, correction, and/or deletion of your information. We will not use or share your information with anyone except as described in this Privacy Policy.

Please note that our website may contain links to third-party websites/digital platforms that are provided for your convenience. We are only responsible for the privacy practices and security of our own products, services, and digital platforms. We recommend that you check the privacy and security policies and procedures of every other website/digital platform that you visit.

“Personal Information” refers to any information relating to an identified or identifiable natural person, such as an identification number, or physical, physiological, mental, economic, cultural, or social identifiers, and any information that describes or is capable of being associated with, or could reasonably be linked, directly or indirectly, with you. Personal Information may include the following: name, address, date of birth, gender, and contact data (i.e., e-mail address, telephone number, and employer name).

By providing your Personal Information to us in the ways described in this Privacy Policy, you agree that you are authorized to provide that information and are accepting this Privacy Policy and any supplementary privacy statement that may be relevant to you. If you do not agree to our practices, please do not register, subscribe, create an account, or otherwise interact with our website or services.

1.0 Information That We Collect

1.1

‍Personal Information that You Disclose to Us. We collect Personal Information that you voluntarily provide to us when expressing an interest in obtaining information about us or our products and services or when using our website and Service, and when otherwise interacting with us.

The Personal Information that we collect depends on the context of your interactions with us. You may be providing Personal Information when (i) submitting questions and seeking information from us; (ii) subscribing to our marketing material; (iii) requesting product and/or Services support; (iv) providing services to us; (v) applying for a job at the Company; or (vi) otherwise communicating with us via phone calls, chats, emails, web forms, social media, and other methods of communication.

When working with us or using our Service, you may be prompted to create an account that may hold Personal Information such as your name, mailing address, email address, or credit card information.

Our Service entails the following, Simple remote access for servers, containers, and clusters, with no single point of compromise (the “Service”). We use your Personal Information to provide and improve the Service. We collection information regarding how you use the service, including the actions you take to connect to the servers, containers, and clusters. We use this information to improve and scale our services.

1.2 Information That We Collect Automatically

1.2.1 Website Technical Information.

We may collect Technical Information about you when you visit our website, which your web browser automatically sends whenever you visit a website on the Internet. "Technical Information" is information that does not, by itself, identify a specific individual but which could be used to indirectly identify you. our servers automatically record this information, which may include your Internet Protocol ("IP") address, browser type, browser language, and the date and time of your request. Gathering Technical Information helps us ensure our website and other services work correctly and support our customer analytics efforts.

1.2.2 Email Communication.

We use pixel tags and cookies in our marketing emails so that we can track your interaction with those messages, such as when you open the email or click a URL link that is embedded within them. When recipients click on one of those URLs, they pass through a separate web server before arriving at the destination page on a company website. We use tools like pixel tags and cookies so that we can determine interest in particular topics and measure and improve the effectiveness of our communications.

1.2.3 Usage Data.

“Usage Data” is data generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit). Usage Data may include information such as your device’s (e.g., desktop or laptop computer, tablet, mobile phone) IP address, browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When you access the Service by or through a mobile device, we may collect certain information automatically, including, but not limited to, the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.

We may also collect information that your browser sends whenever you visit our Service or when you access the Service by or through a mobile device.

1.2.4 Tracking Technologies and Cookies.

We use Cookies and similar tracking technologies to track the activity on our Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze our Service. The tracking technologies we use may include:

‍Cookies or Browser Cookies

A Cookie is a small file placed on your computer, table or mobile device. You can instruct your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if you do not accept Cookies, you may not be able to use some parts of our Service. Unless you have adjusted your browser setting so that it will refuse Cookies, our Service may use Cookies.

Web Beacons

Certain sections of our Service and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).

Cookies can be "Persistent" or "Session" Cookies. Persistent Cookies remain on your personal computer or mobile device when you go offline, while Session Cookies are deleted as soon as you close your web browser. You can learn more about cookies here: http://www.allaboutcookies.org.

We use both Session and Persistent Cookies for the purposes set out below:

Necessary / Essential Cookies

Type: Session Cookies

Administered by: Us

Purpose: These Cookies are essential to provide you with services available through our website and to enable you to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that you have asked for cannot be provided, and we only use these Cookies to provide you with those services.

Cookies Policy / Notice Acceptance Cookies

Type: Persistent Cookies

Administered by: Us

Purpose: These Cookies identify if users have accepted the use of cookies on our website.

Functionality Cookies

Type: Persistent Cookies

Administered by: Us

Purpose: These Cookies allow us to remember choices you make when you use our website, such as remembering your login details or language preference. The purpose of these Cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you use our website, webapp, and ZLI (command line interface).

Tracking and Performance Cookies

Type: Persistent Cookies

Administered by: Third-Parties

Purpose: These Cookies are used to track information about traffic to our website and how users use our website, webapp, and ZLI (command line interface). The information gathered via these Cookies may directly or indirectly identify you as an individual visitor. This is because the information collected is typically linked to a pseudonymous identifier associated with the device you use to access our website, webapp, and ZLI (command line interface). We may also use these Cookies to test new pages, features or new functionality of our website, webapp, and ZLI (command line interface) to see how our users react to them.

2.0 How We Use Your Personal Information

2.1

We use Personal Information as necessary to create your Service account, enable you to sign up for and use our service, manage payments, and provide customer support. This processing is necessary to perform our contracts with our customers.

2.2

We also use Personal Information as necessary for the following legitimate business purposes:

2.2.1 To provide and maintain our Service: including to monitor the usage of our Service.

2.2.2 To manage your account: to manage your registration as a user of the Service.

The Personal Information you provide can give you access to different functionalities of the Service that are available to you as a registered user.

2.2.3 For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services you have purchased or of any other contract with us through the Service.

2.2.4 To contact you: to contact you by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.

2.2.5 To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information.

2.2.6 To manage your requests: To attend and manage your requests to us.

2.2.7 For other purposes: We may use your Personal Information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and your experience.

3.0 Personal Information That We Share With Third Parties

The Company will not rent or sell your Personal Information to others but may disclose Personal Information in the following situations:

3.1

With Service Providers: We may share your Personal Information with service providers to monitor and analyze the use of our Service, for payment processing, to contact you. These service providers collect, store, use, process and transfer information about your activity on our Service in accordance with their Privacy Policies.

3.2

For business transfers: We may share or transfer your Personal Information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of our business to another company.

3.3

With Affiliates: We may share your Personal Information with our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include our parent company and any other subsidiaries, joint venture partners or other companies that we control or that are under common control with us.

3.4

With business partners: we may share your information with our business partners to offer you certain products, services or promotions.

3.5

With other users: when you share Personal Information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside. If you interact with other users or register through a Third-Party Social Media Service (i.e., any website or any social network website through which a user can log in or create an account to use the Service), your contacts on the Third-Party Social Media Service may see your name, profile, pictures and description of your activity. Similarly, other users will be able to view descriptions of your activity, communicate with you and view your profile.

3.6

With your consent: we may disclose your Personal Information for any other purpose with your consent.

3.7

Other Potential Sharing of your Personal Information:

3.7.1 Business Transactions: if the Company is involved in a merger, acquisition or asset sale, your Personal Information may be transferred. We will provide notice before your Personal Information is transferred and becomes subject to a different Privacy Policy.

3.7.2 Law Enforcement: under certain circumstances, the Company may be required to disclose your Personal Information if required to do so by law or in response to valid requests by public authorities (e.g., a court or a government agency).

3.7.3 Other legal requirements: the Company may disclose your Personal Information in the good faith belief that such action is necessary to comply with a legal obligation; protect and defend the rights or property of the Company; prevent or investigate possible wrongdoing in connection with the Service; protect the personal safety of users of the Service or the public; or protect against legal liability.

4.0 Retention Of Your Personal Information

We will retain your Personal Information only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

We will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.

5.0 Transfer Of Your Personal Information

Your information, including Personal Information, is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Information will take place to an organization or a country unless there are adequate controls in place including the security of your data and other Personal Information.

6.0 Payments

We may provide paid products and/or services within the Service. In that case, we may use third-party services for payment processing (e.g., payment processors).

We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your Personal Information is governed by their Privacy Policies. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands such as Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

7.0 How We Secure Your Personal Information

The Company uses technical and physical safeguards to protect the security of your Personal Information from unauthorized disclosure. We also make commercially reasonable attempts to ensure that only necessary people and third parties have access to Personal Information. Nevertheless, such security measures cannot prevent all loss, misuse, or alteration of Personal Information, and we are not responsible for any damages or liabilities relating to any such incidents to the fullest extent permitted by law.

8.0 Handling Of Personal Information That We Receive From Children

Our website and Service are directed toward a general audience. We do not knowingly collect information about children under the age of 16, or minors otherwise defined in local law or regulation, without verifiable parental consent. If we learn that someone under 16 has provided Personal Information through our website, we will use reasonable efforts to remove that information from our databases.

If you have reason to believe that a child under the age of 16 has provided us with Personal Information, please contact us with sufficient detail to enable us to delete that information.

9.0 California Residents' Specific Privacy Rights

The California Consumer Privacy Act (“CCPA”) provides California residents with specific rights regarding their Personal Information. If you are a resident of California, you have the following rights:

9.1

The right to notice. You have the right to be notified which categories of Personal Information are being collected and the purposes for which the Personal Information is being used.

9.2

The right to request. You have the right to request that we disclose information to you about our collection, use, sale, disclosure for business purposes and share of Personal Information. Once we receive and confirm your request, we will disclose to you:

9.2.1 The categories of Personal Information we collected about you

9.2.2 The categories of sources for the Personal Information we collected about you

9.2.3 Our business or commercial purpose for collecting or selling that Personal Information

9.2.4 The categories of third parties with whom we share that Personal Information

9.2.5 The specific pieces of Personal Information we collected about you

9.2.6 If we sold your Personal Information or disclosed your Personal Information for a business purpose, we will disclose to you:

- The categories of Personal Information categories sold

- The categories of Personal Information categories disclosed

9.3

The right to say no to the sale of Personal Information (opt-out). You have the right to direct us to not sell your Personal Information. To submit an opt-out request please contact us.

9.4

The right to delete Personal Information. You have the right to request the deletion of your Personal Information, subject to certain exceptions. Once we receive and confirm your request, we will delete (and direct our Service Providers to delete) your Personal Information from our records, unless an exception applies. We may deny your deletion request if retaining the information is necessary for us or our Service Providers to:

9.4.1 Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.

9.4.2 Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

9.4.3 Debug products to identify and repair errors that impair existing intended functionality.

9.4.4 Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.

9.4.5 Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).

9.4.6 Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.

9.4.7 Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.

9.4.8 Comply with a legal obligation.

9.4.9 Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

9.5

The right not to be discriminated against. You have the right not to be discriminated against for exercising any of your consumer's rights, including by denying goods or services to you; charging different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties; providing a different level or quality of goods or services to you; and suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

9.6

Do Not Sell My Personal Information. If we sell your Personal Information, you have the right to opt-out of such sale. Once we receive and confirm a verifiable consumer request from you, we will stop selling your Personal Information. To exercise your right to opt-out, please contact us. The service providers we partner with (for example, our analytics or advertising partners) may use technology on the Service that sells Personal Information as defined by the CCPA law. If you wish to opt out of the use of your Personal Information for interest-based advertising purposes and these potential sales as defined under CCPA law, you may do so by following the instructions below. Please note that any opt out is specific to the browser you use. You may need to opt out on every browser that you use.

9.7

Website: You can opt out of receiving ads that are personalized as served by our Service Providers by following our instructions presented on the Service:

- The NAI's opt-out platform: http://www.networkadvertising.org/choices/

- The EDAA's opt-out platform http://www.youronlinechoices.com/

- The DAA's opt-out platform: http://optout.aboutads.info/?c=2&lang=EN

The opt out will place a cookie on your computer that is unique to the browser you use to opt out. If you change browsers or delete the cookies saved by your browser, you will need to opt out again.

9.8

Online Tracking and Do Not Track Signals. We may, and we may allow third-party service providers to, use cookies or other tracking technologies to collect information about your browsing activities over time and across different websites following your use of the Site. our Site currently does not respond to “Do Not Track” (“DNT”) signals and operates as described in this Privacy Policy whether or not a DNT signal is received. If we do respond to DNT signals in the future, we will describe how we do so in this Privacy Policy.

10.0 BastionZero app for Slack

To request access to, transfer of, or deletion of your data that is associated with the BastionZero app for Slack, contact support@bastionzero.com.

11.0 Changes To This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the "Last updated" date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

12.0 Contact Us

If you have any questions about this Privacy Policy, you can contact via email at privacy@bastionzero.com.

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