This privacy policy (“Privacy Policy”) governs how we, Bright Security Inc. (“Bright Security” “we”, “our” or “us”) use, collect and store Personal Data that we collect or receive from or about you (“User”, “you”) such as in the following use cases:

(i) When you browse or visit our website, www.brightsec.com (“Website”);

(ii) When you make use of, or interact with, our Website;

a. When you request a product demo;

b. When we process your job application;

c. When you contact us (e.g. customer support, submit a request, chat box);

(iii) When you make use of Bright Securit’s software application platform (“Platform“);

a. When you sign-up for an account and when you log-in in order to use the Platform;

b. When you purchase a subscription plan;

(iv) When you attend to marketing events, exchange business cards with us or otherwise provide us with your Personal Information for marketing purposes;

(v) When you interact with us on our social media profiles (e.g. Facebook, Twitter, LinkedIn, Github);

(vi) When we acquire your Personal information from third-party sources

(vii) When we use the Personal Data of our customers, service providers and/or partners (e.g. contact details)

Please read this Privacy Policy carefully, so you can understand our practices and your rights in relation to personal data. “Personal Data” or “Personal Information” means any information that can be used, alone or together with other data, to uniquely identify any living human being and any information deemed as Personally Identifiable Information by privacy laws.

Important note: Nothing in this Privacy Policy is intended to limit in any way your statutory right, including your rights to a remedy or means of enforcement.

Table of contents:

1. What information we collect, why we collect it, and how it is used

2. How we protect and retain your Personal Data

3. How we share your Personal Data

4. Additional information regarding transfers of Personal Data

5. Your privacy rights. How to delete your account

6. Use by children

7. Interaction with third party product

8. Log files

9. Analytic tools

10. Specific provisions applicable under California privacy law

11. Contact us

This Privacy Policy may be updated from time to time and, therefore, we ask you to check back periodically for the latest version of the Privacy Policy. If we implement significant changes to the use of your Personal Data in a manner different from that stated at the time of collection, we will notify you by posting a notice on our Website or by other means.

1. WHAT INFORMATION WE COLLECT, WHY WE COLLECT IT, AND HOW IT IS USE

Specific Personal Data we collect	Why is the Personal Data collected and for what purposes?		Legal basis (GDPR only, if applicable)		Third parties with whom we share your Personal Data	Retention period	Consequences of not providing the Personal Data
When you browse or visit our website
Cookies For more information, please read our cookies policy	Marketing, analytics, statistics.		Legitimate interest (e.g. essential cookies)		· Linkedin · Google · Facebook · Hubspot · Woopra · Segment · Intercom	For more information, please read our cookies policy	· Certain non-essential Website features may not be available· Read more about the purposes of each cookie here
When you make use of, or interact with our Website
When you request a product demo
· First and last name · Email address · Phone number · Company name · Job Title · Country · Any other data you decide to provide/supply us with	· To schedule and set up a demo · To answer your additional questions and requests · To customize your experience		· Performance of a contract to which the data subject is a party or in order to take steps at the request of the data subject prior to entering into a contract · Legitimate interest (e.g. to provide a demo)·		· Google · Facebook · Linkedin · Hubspot · Woopra · Segment · Intercom	Non-users (inquiries without signing up for platform use) – 1 year from the date of data collection or up to 1 month from receiving a written request for data deletion Marketing opt-in users – 1 year from the date of given consent or up to 1 month from receiving a written revocation of consent or data	· Cannot schedule and provide you with a demo · Cannot answer your questions and requests · Cannot customize your experience
	To send you marketing communications		Consent				Cannot send you marketing communications
When we process your job application
· First and last name · Email address · CV · Any other data you decide to provide/supply us with	· To process your application · To analyze your application · To communicate with you in connection with your job application		· Performance of a contract to which the data subject is a party or in order to take steps at the request of the data subject prior to entering into a contract · Legitimate interest (e.g. to analyze your application)		· Hubspot · Segment · Woopra	Applicants – up to 6 months from date of finalization of the application process (if unsuccessful) or up to 1 month from receiving a written request for data deletion	· Cannot analyze your application · Cannot assess you as a candidate · Cannot communicate with you in connection with your job application
	· To communicate hiring news and/or notify you about open positions		· Legitimate interest (e.g. to inform you of the engagement possibility)				Cannot send you hiring news and/or notifications
When you contact us (e.g. customer support, submit a request, chat box)
· Email address · Your message · Any other data you decide to provide/supply us with	· To provide you customer service and support · To answer your questions and requests		· Performance of a contract to which the data subject is a party or in order to take steps at the request of the data subject prior to entering into a contract · Legitimate interest (e.g. to provide support and respond to your question or request)		· Intercom · Hubspot	Non-users (inquiries without signing up for platform use) – 1 year from the date of data collection or up to 1 month from receiving a written request for data deletion Active users – 1 year from the business relation end date (either due to cancellation, missed payment or other breach of contractual obligations) or up to 1 month from receiving a written request for data deletion Inactive users – 1 year from the last activity date on the Bright Security platform or up to 1 month from receiving a written request for data deletion	· Cannot assist or help you · Cannot answer your questions and requests
When you make use of Bright Security’s Platform
When you sign-up for an account and when you log-in in order to use the Platform
· First and last name · Email address · Company name	· To be able to create an account · To be able to log in · To grant you access to the Platform		· Performance of a contract to which the data subject is a party or in order to take steps at the request of the data subject prior to entering into a contract · Legitimate interest (e.g. to allow you to sign-up the Platform)		· Intercom · Hubspot	Active users – 1 year from the account deletion/ cancellation or up to 1 month from receiving a written request for data deletion Inactive users – 1 year from the last activity date on the Bright Security platform or up to 1 month from receiving a written request for data deletion Marketing opt-in users – 1 year from the date of given consent or up to 1 month from receiving a written revocation of consent or data	· Cannot create an account · Cannot allow you to log-in · Cannot use the Platform
	To send you marketing communications						Cannot send you marketing communications
When you purchase a subscription plan to our Platform
Payment information (e.g. credit card details and billing information)		To grant you access to the services in the Platform available for paid subscriptions		· Performance of a contract to which the data subject is a party or in order to take steps at the request of the data subject prior to entering into a contract · Legitimate interest (e.g. process of payments)	· Intercom · Hubspot · Stripe	Active customers – 1 year from the business relation end date (either due to cancellation, missed payment or other breach of contractual obligations) or up to 1 month from receiving a written request for data deletion Inactive customers – 1 year from the last activity date on the Bright Security platform or up to 1 month from receiving a written request for data deletion	Cannot use the services in the Platform available for paid subscriptions
When you attend a marketing event and provide us with your Personal Data and/or you give us your business card
· Full Name· Email Address· Company name· Job title· Phone number· Any other data you decide to provide/supply us with		· To establish a first business connection and/or discussion· To send you marketing communications		· Consent· Legitimate interest (e.g. to establish a business connection – soft opt-in)	· Intercom · Hubspot	Marketing opt-in recipients (hard or soft opt-in) – 1 year from the date of given consent/opting-in or up to 1 month from receiving opt-out notification, a written revocation of consent or request for data deletion Marketing recipients based on legitimate interest – up to 1 year from the date of data collection	· Cannot establish a first business connection/discussion· Cannot send you marketing communications
When you interact with us on our social media profiles (e.g. Facebook, Twitter, LinkedIn, Github)
· First and last name · Email address · Phone number · Company name · Job Title · Country · Any other data that you decide to supply/provide us and/or publicly available on your social media account	· To answer your questions and requests · To establish a first business connection and/or discussion		· Performance of a contract to which the data subject is a party or in order to take steps at the request of the data subject prior to entering into a contract· Legitimate interest (e.g. to respond to your question or request)			Non-users (inquiries without signing up for platform use) – 1 year from the date of data collection or up to 1 month from receiving a written request for data deletion	· Cannot reply or respond to your question or request· Cannot establish a business connection
When we use the Personal Data of our customers/service providers/partners (e.g. contact details)
· First and last name · Email address · Phone number · Company mane · Job title · Country · Billing information · Any other data you decide to provide/supply us with	· To communicate with our customers/service providers/partners · To perform the applicable agreements · To send contract related communications		· Performance of a contract to which the data subject is a party or in order to take steps at the request of the data subject prior to entering into a contract · Legitimate interest (e.g. send contract related communication) · Compliance with a legal obligation (e.g. tax laws, bookkeeping laws, etc.)		· Hubspot	Active customers – 1 year from the business relation end date (either due to cancellation, missed payment or other breach of contractual obligations) or up to 1 month from receiving a written request for data deletion; Inactive customers – 1 year from the last activity date on the Bright Security platform or up to 1 month from receiving a written request for data deletion Business partners/service providers – 1 year from the business relation end date (either due to cancellation, expiration, missed payment or other breach of contractual obligations) or up to 1 month from receiving a written request for data deletion; The Exception to this is legally mandated business-relevant documentation (tax documents, bookkeeping records, etc.) which shall be preserved for 7 years from the business relation end date unless required otherwise by the applicable legislation	· Cannot perform the applicable agreement · Cannot communicate with our customers/service providers/partners · Cannot send contract related communications

Finally, please note that some of the abovementioned Personal Data will be used for detecting, taking steps to prevent, and prosecution of fraud or other illegal activity, to identify and repair errors, to conduct audits, and for security purposes. Personal Data may also be used to comply with applicable laws, with investigations performed by the relevant authorities, law enforcement purposes, and/or to exercise or defend legal claims. In certain cases, we may or will anonymize or de-identify your Personal Data and further use it for internal and external purposes, including, without limitation, to improve the services and for research purposes. “Anonymous Information” means information which does not enable identification of an individual user, such as aggregated information about the use of our services. We may use Anonymous Information and/or disclose it to third parties without restrictions (for example, in order to improve our services and enhance your experience with them).

2. HOW WE PROTECT AND STORE YOUR PERSONAL DATA

2.1 Security. We have implemented appropriate technical, organizational and security measures designed to reduce the risk of accidental destruction or loss, or the unauthorized disclosure or access to such information appropriate to the nature of the information concerned. However, please note that we cannot guarantee that the information will not be exposed as a result of unauthorized penetration to our servers. As the security of information depends in part on the security of the computer, device or network you use to communicate with us and the security you use to protect your user IDs and passwords, please make sure to take appropriate measures to protect this information.

2.2 Retention of your Personal Data. In addition to the retention periods mentioned above, please note that in some circumstances we may store your Personal Data for longer periods of time, for example (i) where we are required to do so in accordance with legal, regulatory, tax or accounting requirements, or (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges, or (iii) if we reasonably believe there is a prospect of litigation relating to your Personal Data or dealings. We have an internal data retention policy to ensure that we do not retain your Personal Data perpetually. Regarding retention of cookies, you can read more in our cookie policy at: https://www.brightsec.com/cookies-policy/.

3. HOW WE SHARE YOUR PERSONAL DATA

In addition to the recipients described above, we may share your Personal Data as follows:

3.1 With our business partners with whom we jointly offer products or services. We may also share Personal Data with our affiliated companies

3.2 To the extent necessary, with regulators, courts or competent authorities, to comply with applicable laws, regulations and rules (including, without limitation, federal, state or local laws), and requests of law enforcement, regulatory and other governmental agencies or if required to do so by court order;

3.3 If, in the future, we sell or transfer some or all of our business or assets to a third party entity, or in the event of bankruptcy or a comparable event, we reserve the right to transfer, disclose or assign your Personal Data in connection with the foregoing events, including, in connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or to another company;

3.4 Where you have provided your consent to us sharing the Personal Data (e.g., where you provide us with marketing consents or opt-in to optional additional Services or functionality); and/or

3.5 Where we receive requests for information from law enforcement or regulators, in which case we carefully validate these requests before any Personal Information is disclosed.

4. ADDITIONAL INFORMATION REGARDING TRANSFERS OF PERSONAL INFORMATION

4.1 Storage: We store the Personal Data with the following storing companies: Hubspot, AWS United States East region

4.2 Internal transfers: Internal transfers within Bright Security group will be covered by an internal processing agreement entered into by members of the Bright Security group (an intra-group data processing agreement) which contractually obliges each member of the Bright Security group to ensure that Personal Data receives an adequate and consistent level of protection wherever it is transferred to.

4.3 External transfers: Where we transfer your Personal Data outside of Bright Security group (for example to third parties who provide us with our products or services), we will generally obtain contractual commitments to protect your Personal Data. When Bright Security engages in such transfers of personal information (internal and external), it relies on (i) Adequacy Decisions as adopted by European Commission on the basis of Article 45 of Regulation (EU) 2016/679 (GDPR) (for example, when we access from Israel), or (ii) Standard Contractual Clauses issued by the European Commission. Bright Security also continually monitors the circumstances surrounding such transfers in order to ensure that these maintain, in practice, a level of protection that is essentially equivalent to the one guaranteed by the GDPR.

5. YOUR PRIVACY RIGHTS. HOW TO DELETE YOUR ACCOUNT.

5.1 Rights: The following rights (which may be subject to certain exemptions or derogations) shall apply to certain individuals (some of which only apply to individuals protected by the GDPR):

o You have a right to access Personal Data held about you. Your right of access may normally be exercised free of charge, however we reserve the right to charge an appropriate administrative fee where permitted by applicable law;

o You have the right to request that we rectify any Personal Data we hold that is inaccurate or misleading;

o You have the right to request the erasure/deletion of your Personal Data (e.g. from our records). Please note that there may be circumstances in which we are required to retain your Personal Data, for example for the establishment, exercise or defense of legal claims;

o You have the right to object, to or to request restriction, of the processing;

o You have the right to data portability. This means that you may have the right to receive your Personal Data in a structured, commonly used and machine-readable format, and that you have the right to transmit that data to another controller;

o You have the right to object to profiling;

o You have the right to withdraw your consent at any time. Please note that there may be circumstances in which we are entitled to continue processing your data, in particular if the processing is required to meet our legal and regulatory obligations. Also, please note that the withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal;

o You also have a right to request certain details of the basis on which your Personal Data is transferred outside the European Economic Area, but data transfer agreements and/or other details may need to be partially redacted for reasons of commercial confidentiality;

o You have a right to lodge a complaint with your local data protection supervisory authority (i.e., your place of habitual residence, place or work or place of alleged infringement) at any time or before the relevant institutions in your place of residence. We ask that you please attempt to resolve any issues with us before you contact your local supervisory authority and/or relevant institution.

5.2 You can exercise your rights by contacting us at [email protected] with the words “Data Subject Rights Request”. You may use an authorized agent to submit a request on your behalf if you provide the authorized agent written permission signed by you. To protect your privacy, we may take steps to verify your identity before fulfilling your request. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly in accordance with applicable law or inform you if we require further information in order to fulfil your request. When processing your request, we may ask you for additional information to confirm or verify your identity and for security purposes, before processing and/or honoring your request. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive. In the event that your request would adversely affect the rights and freedoms of others (for example, would impact the duty of confidentiality we owe to others) or if we are legally entitled to deal with your request in a different way than initial requested, we will address your request to the maximum extent possible, all in accordance with applicable law.

5.3 Deleting your account: Should you ever decide to delete your account, you may do so by emailing [email protected] with the word “Data Rights Request”. If you terminate your account, any association between your account and Personal Data we store will no longer be accessible through your account. However, given the nature of sharing on certain services, any public activity on your account prior to deletion will remain stored on our servers and will remain accessible to the public.

6. USE BY CHILDREN

We do not offer our products or Services for use by children and, therefore, we do not knowingly collect Personal Data from, and/or about children under the age of eighteen (18). If you are under the age of eighteen (18), do not provide any Personal Data to us without involvement of a parent or a guardian. For the purposes of the GDPR, we do not intend to offer information society services directly to children. In the event that we become aware that you provide Personal Data in violation of applicable privacy laws, we reserve the right to delete it. If you believe that we might have any such information, please contact us at [email protected].

7. INTERACTION WITH THIRD PARTY PRODUCTS

We enable you to interact with third party websites, mobile software applications and products or services that are not owned or controlled by us (each a “Third Party Service”). We are not responsible for the privacy practices or the content of such Third Party Services. Please be aware that Third Party Services can collect Personal Data from you. Accordingly, we encourage you to read the terms and conditions and privacy policies of each Third Party Service.

8. LOG FILES

We use log files. We use such information to analyze trends, administer the Website, track users’ movement around the Website, and gather demographic information.

9. ANALYTIC TOOLS

· Google Analytics. The Website uses a tool called “Google Analytics” to collect information about use of the Website. Google Analytics collects information such as how often users visit this Website, what pages they visit when they do so, and what other websites they used prior to coming to this Website. We use the information we get from Google Analytics to maintain and improve the Website and our products. We do not combine the information collected through the use of Google Analytics with Personal Information we collect. Google’s ability to use and share information collected by Google Analytics about your visits to this Website is restricted by the Google Analytics Terms of Service, available at https://marketingplatform.google.com/about/analytics/terms/us/, and the Google Privacy Policy, available at http://www.google.com/policies/privacy/. You may learn more about how Google collects and processes data specifically in connection with Google Analytics at http://www.google.com/policies/privacy/partners/. You may prevent your data from being used by Google Analytics by downloading and installing the Google Analytics Opt-out Browser Add-on, available at https://tools.google.com/dlpage/gaoptout/.

10. SPECIFIC PROVISIONS APPLICABLE UNDER CALIFORNIA PRIVACY LAW

10.1 Other California Privacy Rights: California Civil Code Section 1798.83 permits our customers who are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please send an email to [email protected]. Please note that we are only required to respond to one request per customer each year.

10.2 Our California Do Not Track Notice (Shine the Light): Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers, but we may allow third parties, such as companies that provide us with analytics tools, to collect personally identifiable information about an individual consumer’s online activities over time and across different web sites when a consumer uses the Services..

11. CONTACT US

If you have any questions, concerns or complaints regarding our compliance with this notice and the data protection laws, or if you wish to exercise your rights, we encourage you to first address our DPO Amir Drenger at [email protected].