Effective Date: August 7, 2021
Effective Date: August 7, 2021
This MUTTII Privacy Statement (“Privacy Statement”) describes how MUTTII and its affiliates (together, “MUTTII” or “we”) collect and process information about you.
We appreciate that you trust us when you provide us with your information. Protection of information is our top priority because we want to keep your trust.
We design all of our products and services with data protection in mind.
We work hard to keep your information secure. We regularly monitor and update our security practices to help better protect your privacy.
In this Privacy Statement, (i) to “process” personal data means to perform any operation on the information, whether or not by automated means, such as collection, recording, organizing, storing, adapting, use, disclosure, combining, erasing or destroying and (ii) “personal data” means data that identifies, directly or indirectly, an individual natural person.
Please read this Privacy Statement carefully.
IF YOU DO NOT AGREE WITH ANY PART OF THIS PRIVACY STATEMENT, THEN PLEASE DO NOT PROVIDE YOUR PERSONAL DATA TO US OR USE THE SERVICES.
1. Where This Privacy Statement Applies
This Privacy Statement applies to our “Services”, which means public portions of MUTTII’s websites, including, but not limited to MUTTII.com (https://www.MUTTII.com), and registered users of these websites and our Core Products and our MUTTII Cyber Cloud (https://www.MUTTII.com/cloud/).
Our right to process personal data also is described in our agreements (“Customer Agreements”) with our business customers (“Customers”).
In our Customer Agreements, MUTTII is typically contractually prohibited from accessing the personal data that Customers store and otherwise process through MUTTII’s Services.
If a provision of a Customer Agreement conflicts or otherwise is inconsistent with a provision of this Privacy Statement, then the term of the Customer Agreement will prevail to the extent of the conflict or inconsistency.
This Privacy Statement does not apply to information that is collected by any third-party website or service that you access through the Services.
2. Data Controller
The data controller (i.e., the person who or entity that determines the purpose and means of processing) for the personal data collected pursuant to this Privacy Statement is MUTTII Canberra, Australia.
Please note that when we collect personal data pursuant to a Customer Agreement, we typically act as a data processor on behalf of our customer.
3. Cross-Border Data Transfers
Use of the Services sometimes involves cross-border transfers of personal data.
For cross-border transfers of personal data, MUTTII uses appropriate safeguards to require that your personal data be protected in accordance with this Privacy Statement and applicable data protection laws. These safeguards include implementing the European Commission’s Standard Contractual Clauses (Art. 46 GDPR) and other valid mechanisms for transfers of personal data among our affiliates and data processors.
MUTTII complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework administered by the US Department of Commerce (together, “Privacy Shield”). Please see our Privacy Shield Policy (https://www.MUTTII.com/company/privacyshield/) for more information.
4. Changes To This Privacy Statement
The Effective Date of this Privacy Statement is set forth at the top of this webpage. As we add new features to the Services, differ our operations or are required by applicable laws, we may amend this Privacy Statement. If we make a material change to the Privacy Statement that reduces your privacy rights, we will notify you in advance through the Services. Your continued use of the Services after the Effective Date constitutes your acceptance of the amended Privacy Statement. The amended Privacy Statement supersedes all previous versions.
5. Information We Collect
Personal data you choose to give us
When you use the Services, we collect the personal data that you give us when using the Services. This includes:
- When you create an account, you provide us with a username and password, business or personal information, such as name, address, email address, phone number and other information that you choose to provide us.
- When you make a purchase, you provide us with your order information and, if applicable, financial account information. (We do not collect payment card information - it is collected and processed by a third-party payment card processor.)
- When you participate in surveys or focus groups, you give us your insights into our products, services or other initiatives, as well as other information which you may decide to give us.
- When you fill out an on-line form to register to use our products and services, attend one of our webinars, marketing, training, sports and other events or request information from us, we collect the information in the form and other information you may give us. This may include information such as first name, last name, place of work, job title, country, email, phone number, size of t-shirt, etc.
- If you contact our customer service team, we collect the information you give us during the interactions. Sometimes, we monitor or record these interactions for training purposes and for quality assurance. If we are recording your interaction, we will provide a notice as required by applicable law.
Personal Data MUTTII Does Not Seek To Collect
MUTTII does not need special categories of personal information (also known as “sensitive personal information or data”), as defined by the General Data Protection Regulation (GDPR), to provide the Services. MUTTII avoids collecting sensitive personal data from you through the Services or otherwise. Unless MUTTII specifically requests it, please do not provide sensitive personal data to MUTTII. If you choose to provide MUTTII with unsolicited sensitive personal data, MUTTII will process it only as necessary to establish, exercise or defend legal claims. In the rare circumstances in which MUTTII does seek to collect sensitive personal data, MUTTII will do so in accordance with data protection laws and/or ask for your consent.
Information We Receive From Others
We receive information about you from others, including our vendors, service providers, resellers and other business partners. We also receive information about you from the third parties that help us operate the Services, such as for fraud detection, digital forensics, marketing services (such as when we acquire information on potential leads) and similar functions.
MUTTII Collects The Following Usage Data
Services usage information: We collect information about which features you use and how you use them, including: date/time stamps associated with purchase, installation, updates and your usage; integrations; how often you use the Services and in which circumstances; Services performance metrics; features you use and the results of their operations; information about disabled features; and information about errors and crashes and activities which led to them.
Service operation information: Depending on the Services you use, we collect information that is necessary to provide such Services and that forms an integral part of such Services. For example, we collect the list of software installed on your machine, together with version and manufacturer information as part of providing you vulnerability assessment and patch management functionality of certain Services. As another example, we collect information about names of potentially malicious files together with their hashes and full paths to such files or blocked website URLs as part of providing you antivirus and URL filtering functionality of certain Services.
Device information: We collect information from and about the Device that you use to access the Services, including: hardware and software information Device or component ID, type and architecture, Device-specific and operating system settings, characteristics and configuration, device location, identifiers associated with cookies or other technologies that may uniquely identify your Device or browser; and information about your wireless or mobile network connection, like your internet vendor and signal strength.
Activity and audit logs: An activity log is a list of user activities. MUTTII’s servers automatically collect and store in logs your search queries, Internet Protocol (IP) address, browser type and language, time zones, date and time of your request and referral URLs and certain cookies that identify your browser or MUTTII account. Some logs include metadata which may contain your personal data like names of files and folders if you give them such names.
We may link personal data and Usage Data or different types of Usage Data. We also may link personal data that we collect with publicly available personal data, such as personal data available in public databases. If the linked information directly or indirectly identifies an individual natural person, we will treat it as personal data.
MUTTII Customer Experience Program
MUTTII collects certain information through the MUTTII Customer Experience Program (“CEP”).
Unless you consent to MUTTII processing your personal data as part of CEP, MUTTII will only collect pseudonymized Usage Data as part of CEP. MUTTII gathers such pseudonymized Usage Data to improve MUTTII products and services. MUTTII achieves the pseudonymization by associating such data with a randomly generated number (pseudonym) instead of the personal ID associated with your MUTTII account. MUTTII cannot identify you by the pseudonym without you providing additional information to MUTTII for identification purposes.
If you consent to MUTTII processing your personal data as part of CEP, MUTTII will connect your personal data to your CEP Usage Data. The personal data MUTTII connects to your CEP Usage Data is limited to your MUTTII account ID and account information. As in this case MUTTII links personal data and Usage Data, MUTTII treats the CEP Usage Data linked to your personal data as personal data. Your consent to MUTTII processing your personal data as part of CEP allows MUTTII to provide you more specific feedback and guidance about MUTTII products, services, and features operation. You can consent to MUTTII processing your personal data as part of CEP by checking the corresponding box in the product settings.
Information Collected Through Data Collection Technology
Other Information With Your Consent
We collect other information when you give us permission at the time of collection for the purposes disclosed to you at that time.
6. Cookies And Other Data Collection Technology
Cookies are small text files that are sent to or accessed from your web browser or your computer’s hard drive. A cookie typically contains the name of the domain (internet location) from which the cookie originated, the “lifetime” of the cookie (i.e., when it expires) and a randomly generated unique number or similar identifier. A cookie also may contain information about your computer, such as user settings, browsing history and activities conducted while using the Services.
Cookies set by MUTTII are called “first party cookies”. Cookies set by other parties are called “third-party cookies”. Third-party cookies enable MUTTII to provide third-party features or functionality on or through the website (such as interactive content and analytics). Third- party cookies recognize your browser when it visits the Services and also when it visits certain other websites and services.
Cookies also are typically categorized as “session” cookies or “persistent” cookies. Session cookies are erased when your web browser is closed. For example, a session cookie tracks how you navigate through the Services so that you do not need to re-enter the same information during the same visit to the Services. Persistent cookies store your preferences and other information for your current and future visits – they are still stored in your browser when you reopen your browser. For example, we may use persistent cookies to record your choice of language and country location.
MUTTII also uses other types of data collection technology, such as web beacons (also called a pixel tag or clear GIF). A web beacon is a piece of computer code that enables us to monitor user activity and website traffic.
To learn more about cookies, web beacons and other data collection technology, visit www.allaboutcookies.org.
How We Use Data Collection Technology
Data collection technology helps us improve your experience of the Services by, for example, storing your website language preferences, so you do not have to select it each time you use the Services, compiling statistics about use of the Services, helping us analyze technical and navigational information about the Services, and detecting and preventing fraud.
The Services use the following cookies:
- Strictly necessary cookies, which are required for the operation of the Services, such as to enable you to register or log in to the Services.
- Functionality cookies, which are used to recognize you when you return to the Services.
- Analytical/performance cookies, which allow us to recognize and count the number of visitors to our website, to learn how users navigate the Services and to help us to improve how the Services function.
- We also use Google Analytics, which is a Google service that aggregates information about use of the Services and reports website trends. Google Analytics does not directly identify individual users.
- Advertising and targeting cookies, which are used to deliver tailored information about our products and services that may be of interest or value to you and marketing and promotional emails (with your consent where required by applicable law).
You can control and manage cookies using the Privacy Preference centre, if MUTTII makes it available in your region, or directly in your browser. Most browsers allow viewing, managing, deleting, or blocking cookies. Please be aware that if you delete or block cookies directly in your browser then some of your preferences can be lost, as well as some functionality may no longer be available, including the ability to opt-out and mange cookies via the Privacy Preference centre as this function itself uses cookie for keeping your preferences.
You may find the guidelines on how to control cookies for common browsers at the links below:
- Google Chrome
- Mozilla Firefox
- MacOS Safari
Our Statement on Do Not Track Signals
Some web browsers (including Safari, Internet Explorer, Firefox, and Chrome) incorporate a "Do Not Track" ("DNT") or similar feature that signals to websites that a user does not want to have his or her online activity and behaviour tracked. If a website that responds to a particular DNT signal receives the DNT signal, the browser can block that website from collecting certain personal data about the browser’s user. Not all browsers offer a DNT option, and DNT signals are not yet uniform. For this reason, many website operators, including MUTTII, do not respond to DNT signals.
7. How We Process Personal Data
MUTTII processes personal data:
- To set up and maintain your account.
- To provide the products and services that you purchase.
- To notify you about updates and new versions.
- To communicate with you and respond to your inquiries.
- To prevent and investigate fraud and other misuses of the Services.
- To protect our rights and property.
- To operate, manage and secure the Services.
- To promote our products and services, including through targeted advertising.
- To conduct training on our products and services.
- To deliver online or offline events.
- To respond to your questions and resolve issues with our products and services.
- To provide the ability for blog, forum and other postings, including by participating in discussions and feedback exchange.
- To complete transactions requested by you.
- To improve the performance and reliability of our products and services through the CEP and other quality assurance and improvement programs.
- To help us offer and improve our customer service.
MUTTII Processes Usage Data:
- To ensure the technical functionality and security of our products and services.
- To analyze trends and statistically monitor how a specific product or service is used and which features are most popular, such as through the CEP.
- To improve our products and services and develop new ones.
- For auditing and similar compliance purposes.
- To review compliance with applicable legal terms and policies.
- For Customer preferences analysis and research.
8. How We Share Information
MUTTII may share personal data collected through the Services as follows:
With our affiliates: We provide personal data to our affiliates that process personal data for purposes consistent with those described in this Privacy Statement or notified to you when your personal data are collected. For example, we may share your contact information as part of an attendee lists with our affiliates.
With our vendors and services providers: We share information with our vendors, including customer service, marketing, and security testing service providers. MUTTII will ensure that any vendor with which we share personal data agrees to safeguard it. Please also see Section 13 below for more information about how MUTTII uses Google’s services.
With resellers: We share personal data with our resellers and other third parties that promote, resell and/or white label the Services and receive personal data from them.
As part of a corporate transaction: We may share and transfer personal data if we are involved in a merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy or other change of ownership or control by MUTTII or any affiliated company (in each case, whether in whole or in part).
When required by law: MUTTII or MUTTII’s affiliates may use servers and other equipment to provide the Services that are in countries where litigants, law enforcement, courts, and other agencies of the government may have the right to access personal data stored within their jurisdictions upon terms and conditions provided by local law. MUTTII also may provide access to your personal data to government authorities if MUTTII suspects or believes that your data contains child pornography or other prohibited content or data or that the data is used for illegal purposes. MUTTII reserves the right to disclose personal data to any competent law enforcement body, regulatory, government agency, court or other third party when we believe disclosure is necessary. When reasonably possible, MUTTII will provide notice of any required or requested disclosure and reasonably cooperate to limit such disclosure to the extent allowed by law.
For other lawful disclosures: We also share information (i) if disclosure would mitigate MUTTII’s liability in an actual or threatened lawsuit; (ii) as necessary to protect legal rights of MUTTII, users, Customers, vendors, business partners or other interested parties; (iii) to pursue available remedies or limit the damages; (iv) to enforce our agreements; and (v) to respond to an emergency.
MUTTII may aggregate information collected through the Services and remove identifiers so that the information no longer identifies or can be used to directly identify an individual, household or device (“Aggregated Information”). MUTTII may share Aggregated Information with third parties and does not limit third parties’ use of the Aggregated Information.
9. Your Choices About Your Personal Data
This section contains specific privacy notices for individuals located in the European Union and for California residents.
If you are located in the EU:
Data controller: The data controller (i.e., who determines the purpose and means of processing your personal data) for the personal data collected pursuant to this Privacy Statement is MUTTII, Canberra, Australia.
Lawful bases for processing: We need to inform users about the legal bases for our processing of their personal data. Our legal bases depend on the context in which the personal data are processed.
- Most of the time, the reason we process your information is to perform the contract that you have with us to use our products and services.
- We also process your personal data when the processing is in our legitimate business interests and not overridden by privacy or other fundamental rights and freedoms. For example, we may process personal data to respond to queries, to improve our offerings continuously, for marketing our new products and features, for fraud detection and legal compliance purposes. We may have other legitimate interests and if appropriate, we will make them clear at the relevant time.
- From time to time, we may ask for your consent to use your personal data for certain specific and explicit reasons – for example to participate in CEP. We will provide you with relevant information for the processing and you may withdraw your consent at any time by contacting us at data-protection-office@MUTTII.biz or by navigating through the particular Settings menu.
- In some cases, we may also have a legal obligation to collect personal data. If we ask you to provide personal data to comply with a legal requirement, we will make this clear at the relevant time. We will advise you whether providing your personal data is mandatory. We will also inform you on the possible consequences if you do not provide your personal data.
If you have questions about or need further information concerning the legal basis on which we process your personal data, please contact our Data Protection Officer at dataprotection-office@MUTTII.biz.
Your data protection rights: For personal data for which we are the data controller and for which applicable law grants you data protection rights, please contact our Data Protection Officer at data-protection-office@MUTTII.biz. If you would like to submit a request to review your personal data, to correct, update, suppress, restrict or delete personal data about you which you have previously provided to us or if you would like to receive an electronic copy of your personal data, including for purposes of transmitting it to another company (i.e., right to portability), to object to processing based on legitimate interest, including the absolute right that we stop using your data for direct marketing, to withdraw previously given consent or object to automated decision making and profiling, please reach to us in each case, when these rights are provided to you by law.
- You have the right to access the personal data that we hold about you, including the description of the processing purposes: If you would like to access the personal data that MUTTII maintains about you, please contact MUTTII at data-protectionoffice@MUTTII.biz. If you are a registered user, you can review certain personal data that you provided to MUTTII by logging in to your account. If you are not a registered user, MUTTII may take reasonable steps to verify your identity before providing access to personal data. We may not allow you to review certain data for legal, security or other reasons.
- You have the right to receive a copy of your personal data: If you would like to receive an electronic copy of your personal data for purposes of transmitting it to another company, please contact us at data-protection-office@MUTTII.biz. If you are a registered user, you can download certain personal data that you provided to MUTTII by logging in to your account. If you are not a registered user, MUTTII may take reasonable steps to verify your identity before providing your personal data to you. We may not allow you to review certain data for legal, security or other reasons.
- You have the right to correct or delete personal data, to restrict or object to some of our processing of your personal data, including your absolute right that we stop processing your data for direct marketing. The easiest way to correct or delete certain personal data that you have provided to the Services is to log in to your account and enter the necessary changes in your profile settings. Otherwise, please contact MUTTII at data-protection-office@MUTTII.biz.
- You have the right to withdraw previously given consent for processing of your personal data for that specific purpose. You may withdraw your consent at any time by contacting us at data-protection-office@MUTTII.biz or by navigating through the particular Settings menu.
Note that MUTTII does not carry out automated decision-making and profiling creating legal effects or significantly affecting data subjects.
In your request, please make clear what personal data you would like to have changed or to what processing you object, whether you would like to have your personal data deleted or what other limitations you would like to put on our use of your personal data. We will respond your request as soon as reasonably practicable and in accordance with data protection regulations.
We may reject some requests, including if the request is unlawful, duplicative or if it may infringe on privacy rights of a third party.
Please note that we often need to retain certain data for recordkeeping purposes and/or to complete any transaction that you began prior to requesting a change or deletion (e.g., when you make a purchase, you may not be able to change or delete the personal data provided until after the completion of such purchase). Our databases and other records may have residual data which will not be removed. If you have additional questions regarding the correction or deletion of the personal data we hold about you, please contact us at dataprotection-office@MUTTII.com.
If our products and services are made available to you by a Customer pursuant to a Customer Agreement, your eligibility to receive incentives and rewards, if any are offered, may be adversely affected by your election to remove personal data about you. Please contact the Customer for further information.
Marketing Emails: If you do not wish to receive marketing-related emails from us, please click the unsubscribe link in one of our marketing emails or:
- for corporate users: https://promo.MUTTII.com/UnsubscribePage.html
- for home users: https://www.MUTTII.com/en-us/my/subscriptions/
Accountability: you have a right to lodge a complaint with the appropriate data protection authority if you have concerns about how we process your personal data. Please see https://edpb.europa.eu/about-edpb/board/members_en.
If you are a resident of the United Kingdom, please note that MUTTII is registered at the Information Commissioner’s Office (ICO) (https://ico.org.uk/ESDWebPages/Search). You have the right to lodge a complaint to ICO. For more details, please see https://ico.org.uk/make-a-complaint/.
For California Residents
This California Privacy Rights Notice (“California Privacy Notice”) explains privacy rights available to residents of the State of California as required by the California Consumer Privacy Act of 2018 (“CCPA”).
If this California Privacy Notice and any provision in the rest of our Privacy Statement conflict, then this California Privacy Notice controls for the processing of Personal Information of residents of the State of California. In CCPA, California residents are referred as “consumers” and we refer to them in this California Privacy Notice as “California Consumers” and “Personal Information” means information that identifies, relates to, describes, is capable of being associated with or could reasonably be linked, directly or indirectly, with a particular California Consumer or household.
It is important not to confuse the reading order with the navigation order. The ability to navigate (i.e., move by keyboard between interactive controls) in a way that preserves meaning is covered. Meaningful Sequence is concerned solely with the reading order, and so cannot normally be tested without assistive technology. Screen readers render content in a serialised manner.
Note: Sequence is not important for some content. For example, it does not normally affect meaning whether side navigation is read before or after the main content. So while matching the visual and reading order is a way to ensure this requirement is met, a difference in visual order and reading order is not a failure where the sequence does not affect the meaning.
10. Links To Other Websites And Services
The Services may include links to third-party websites and services that are not operated by us. When you click these links, you will be directed away from the Services. A link to a third-party website or service does not mean that we endorse it or the quality or accuracy of information presented on it. If you decide to visit a third-party website or service, you are subject to its privacy practices and policies, not ours. This Privacy Statement does not apply to any personal data that you provide to these other websites and services.
11. Protection & Retention Of Personal Data
We take precautions intended to help protect personal data that we collect and store for ourselves and our customers. We also expect that you will use appropriate security measures to protect your information. For more information on what security measures MUTTII applies, please check: https://www.MUTTII.com/en-us/security/cloud/dataprocessing-terms/.
We may suspend your use of all or part of the Services without notice if we suspect or detect any breach of security. If you believe that information you provided to us is no longer secure, please notify us immediately at data-protection-office@MUTTII.com.
We keep your personal data only as long as we need it for legitimate business purposes and as permitted by applicable law. In practice, this means that we delete or anonymize personal data in your account to which we have access not later than after three (3) years of continuous inactivity unless we must keep it to comply with applicable law or because an issue, claim or dispute is not yet resolved.
12. Children’s Privacy
Our products and services are not directed to or intended for use by minors. If we learn that we have received any information directly from a child under age 16 without his or her parent’s verified consent, we will use that information only to respond directly to that child (or his or her parent or legal guardian) to inform the child that he or she cannot use the Services.
13. G Suite1 Terms And Conditions
MUTTII utilizes certain Google APIs to provide backup and recovery services for your data in the following G Suite products: Gmail, Google Contacts, Google Calendar, Google Drive, Google Team Drives (collectively, “Google User Data”). In order to provide such backup and recovery Services to you, MUTTII requires read-only access to the lists of users and Team Drives in your G Suite organizational structure as well as reading and writing access to all other Google User Data.
MUTTII stores the Google User Data in data centres operated by MUTTII or MUTTII’s data centre providers.
MUTTII does not share the Google User Data with third parties without appropriate consent except as follows:
- For Corporate Transactions: We may share and transfer Google User Data if we are involved in a merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy or other change of ownership or control by MUTTII or any affiliated company (in each case, whether in whole or in part)
- When Required by Law: MUTTII or MUTTII’s affiliates may use servers and other equipment to provide the Services that are located in countries where litigants, law enforcement, courts, and other agencies of the government may have the right to access Google User Data stored within their jurisdictions upon terms and conditions provided by local law. MUTTII may also provide access to your Google User Data to government authorities if MUTTII suspects or believes that the Google User Data contains child pornography or other prohibited content or data or that the Google User Data is being used for illegal purposes. MUTTII reserves the right, consistent with data privacy and other user data protection requirements applicable to the jurisdiction where Google User Data is stored, and if mandated by applicable law, regulation, legal process, or governmental order, to disclose Google User Data, but only to the extent required to satisfy those laws, regulations or orders. Unless prohibited by law or other order, MUTTII will provide you with reasonable notice of any such required or requested disclosure and reasonably cooperate to limit such disclosure to the extent allowed by law.
- disclosure to the extent allowed by law. • For other Lawful Disclosures: We also share Google User Data (i) if disclosure would mitigate MUTTII’ liability in an actual or threatened lawsuit; (ii) as necessary to protect legal rights of MUTTII, users, Customers, vendors, business partners or other interested parties; (iii) to pursue available remedies or limit the damages; (iv) to enforce our agreements; and (v) to respond to an emergency.