KnowBe4 Privacy Shield Policy
KnowBe4 Inc. ("KnowBe4") has adopted this Privacy Shield Policy ("Policy") to establish and maintain an adequate level of Personal Data privacy protection. This Policy applies to the processing of Personal Data that KnowBe4 obtains from Customers located in the European Union and Switzerland.
The Federal Trade Commission (FTC) has jurisdiction over KnowBe4's compliance with the Privacy Shield.
All KnowBe4 employees who handle Personal Data from Europe and Switzerland are required to comply with the Principles stated in this Policy.
Capitalized terms are defined in Section 14 of this Policy.
This Policy applies to the processing of Individual Customer Personal Data that KnowBe4 receives in the United States concerning Individual Customers who reside in the European Union and Switzerland. KnowBe4 provides products and services to businesses and consumers.
This Policy does not cover data from which individual persons cannot be identified or situations in which pseudonyms are used. (The use of pseudonyms involves the replacement of names or other identifiers with substitutes so that identification of individual persons is not possible.)
KnowBe4 has designated an Information Security Committee to oversee its information security program, including its compliance with the EU Privacy Shield program and Swiss Safe Harbor. The Information Security Committee shall review and approve any material changes to this program as necessary. Any questions, concerns, or comments regarding this Policy also may be directed to privacyshield@KnowBe4.com.
KnowBe4 will maintain, monitor, test, and upgrade information security policies, practices, and systems to assist in protecting the Personal Data that it collects. KnowBe4 personnel will receive training, as applicable, to effectively implement this Policy. Please refer to Section 7 for a discussion of the steps that KnowBe4 has undertaken to protect Personal Data.
III. RENEWAL / VERIFICATION
KnowBe4 will renew its EU Privacy Shield certification annually, unless it subsequently determines that it no longer needs such certification or if it employs a different adequacy mechanism.
Prior to the re-certification, KnowBe4 will conduct an in-house verification to ensure that its attestations and assertions with regard to its treatment of Individual Customer Personal Data are accurate and that the company has appropriately implemented these practices. Specifically, as part of the verification process, KnowBe4 will undertake the following:
KnowBe4 will prepare an internal verification statement on an annual basis.
KnowBe4 provides various solutions to its Customers who purchase its products. KnowBe4 collects Personal Data from Individual Customers when they purchase its products, register with our website, log-in to their account, complete surveys, request information or otherwise communicate with us. For example, KnowBe4 individual customers may choose to seek live support or post to a message board.
The Personal Data that we collect may vary based on the Individual Customer's interaction with our website and request for our services. As a general matter, KnowBe4 collects the following types of Personal Data from its Individual Customers: contact information, including, a contact person's name, work email address, work mailing address, work telephone number, title, and company name, as well as possible future payment information (which might include credit card and/or bank account information). Individual customers have the option to log into their accounts online and to request service online, including through a live support option; we will collect information that they choose to provide to us through these portals.
When Individual Customers use our services, we will collect their IP address browser type, version operating system type and version. We also may collect Personal Data from persons who contact us through our website to request additional information; in such a situation, we would collect contact information (as discussed above) and any other information that the person chooses to submit through our website.
The information that we collect from Individual Customers is used for selling the products and services they buy from us, managing transactions, reporting, invoicing, renewals, other operations related to providing services and products to the Individual Customer.
For certain products, KnowBe4 serves as a service provider. In our capacity as a service provider, we will receive, store, and/or process Personal Data. In such cases, we are acting as a data processor and will process the personal information on behalf of and under the direction of our partners and/or agents. The information that we collect from our Individual Customers in this capacity is used for managing transactions, reporting, invoicing, renewals, other operations related to providing services to the Individual Customer, and as otherwise requested by our partner and/or agent.
KnowBe4 uses Personal Data that it collects directly from its Individual Customers and for its partners indirectly in its role as a service provider for the following business purposes, without limitation:
Except as otherwise provided herein, KnowBe4 discloses Personal Data only to Third Parties who reasonably need to know such data only for the scope of the initial transaction and not for other purposes. Such recipients must agree to abide by confidentiality obligations.
KnowBe4 may provide Personal Data to Third Parties that act as agents, consultants, and contractors to perform tasks on behalf of and under our instructions. For example, KnowBe4 may store such Personal Data in the facilities operated by Third Parties. Such Third Parties must agree to use such Personal Data only for the purposes for which they have been engaged by KnowBe4 and they must either:
KnowBe4 also may disclose Personal Data for other purposes or to other Third Parties when a Data Subject has consented to or requested such disclosure. Please be aware that KnowBe4 may be required to disclose an individual's personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements. KnowBe4 is liable for appropriate onward transfers of personal data to third parties.
KnowBe4 does not store Sensitive Data from its Individual Customers.
VII. DATA INTEGRITY AND SECURITY
KnowBe4 uses reasonable efforts to maintain the accuracy and integrity of Personal Data and to update it as appropriate. KnowBe4 has implemented physical and technical safeguards to protect Personal Data from loss, misuse, and unauthorized access, disclosure, alternation, or destruction. For example, electronically stored Personal Data is stored on a secure network with firewall protection, and access to KnowBe4's electronic information systems requires user authentication via password or similar means. KnowBe4 also employs access restrictions, limiting the scope of employees who have access to Individual Customer Personal Data.
Further, KnowBe4 uses secure encryption technology to protect certain categories of personal data. Despite these precautions, no data security safeguards guarantee 100% security all of the time.
KnowBe4 personnel may access and use Personal Data only if they are authorized to do so and only for the purpose for which they are authorized.
This Policy may be amended from time to time, consistent with the Privacy Shield Principles and applicable data protection and privacy laws and principles. We will make employees available of changes to this policy either by posting to our intranet, through email, or other means. We will notify Customers if we make changes that materially affect the way we handle Personal Data previously collected, and we will allow them to choose whether their Personal Data may be used in any materially different manner.
XII. QUESTIONS OR COMPLAINTS
EU Individual customers may contact KnowBe4 with questions or complaints concerning this Policy at the following address:
XIII. ENFORCEMENT AND DISPUTE RESOLUTION
In compliance with the US-EU Privacy Shield Principles, KnowBe4 commits to resolve complaints about your privacy and our collection or use of your personal information. EU individuals with questions or concerns about the use of their Personal Data should contact us at: privacyshield@KnowBe4.com.
If a Customer's question or concern cannot be satisfied through this process KnowBe4 has further committed to refer unresolved privacy complaints under US-EU Privacy Shield to an independent dispute resolution mechanism operated by American Arbitration Association (“AAA”) Dispute Resolution Services Worldwide. – Case Filing Services http://www.adr.org/drs by email [firstname.lastname@example.org], by fax at (877) 495-4185, or mail at American Arbitration Association Case Filing Services, 1101 Laurel Oak Road, Suite 100, Voorhees, NJ 08032. If you are faxing or mailing AAA to lodge a complaint, you must include the following information: KnowBe4, the alleged privacy violation, your contact information, and whether you would like the particulars of your complaints shared with KnowBe4. For information about AAA or the operation of AAA’s worldwide dispute resolution process, please visit AAA http://www.adr.org/drs or request this information from AAA at any of the addresses listed above. The AAA dispute resolution process will be conducted in English.
Finally, as a last resort and in limited situations, EU individuals may seek redress from the Privacy Shield Panel, a binding arbitration mechanism.
XIV. DEFINED TERMS
"Individual Customer" means an Individual customer or client of KnowBe4 from EU or Switzerland. The term also shall include any individual agent, representative, of an individual customer of KnowBe4 and all employee of KnowBe4 where KnowBe4 has obtained his or her Personal Data from such Individual Customer as part of its business relationship with KnowBe4.
"Data Subject" means an identified or identifiable natural living person. An identifiable person is one who can be identified, directly or indirectly, by reference to a name, or to one or more factors unique to his or her personal physical, psychological, mental, economic, cultural or social characteristics. For Customers residing in Switzerland, a Data Subject also may include a legal entity.
"Employee" means an employee (whether temporary, permanent, part-time, or contract), former employee, independent contractor, or job applicant of KnowBe4 or any of its affiliates or subsidiaries, who is also a resident of a country within the European Economic Area.
"Europe" or "European" refers to a country in the European Union.
"Personal Data" as defined under the European Union Directive 95/46/EC means data that personally identifies or may be used to personally identify a person, including an individual's name in combination with country of birth, marital status, emergency contact, salary information, terms of employment, job qualifications (such as educational degrees earned), address, phone number, e-mail address, user ID, password, and identification numbers. Personal Data does not include data that is de-identified, anonymous, or publicly available. For Switzerland, the term "person" includes both a natural person and a legal entity, regardless of the form of the legal entity.
"Sensitive Data" means Personal Data that discloses a Data Subject's medical or health condition, race or ethnicity, political, religious or philosophical affiliations or opinions, sexual orientation, or trade union membership.
"Third Party" means any individual or entity that is neither KnowBe4 nor an KnowBe4 employee, agent, contractor, or representative.
Version 1 – September 26, 2016