Privacy Policy

Effective date: January 1, 2021

Thanks for entrusting Ripka Technologies S.L. ("PacketSafari", "we", "our", "us") with your PCAPs, your analyses, and your personal information. Holding on to your private information is a serious responsibility, and we want you to know how we're handling it.

All capitalized terms have their definition in PacketSafari Terms of Service, unless otherwise noted here.

The short version

We use your personal information as this Privacy Statement describes. No matter where you are, where you live, or what your citizenship is, we provide the same high standard of privacy protection to all our users around the world, regardless of their country of origin or location.

Of course, the short version and the Summary below don't tell you everything, so please read on for more details.

Summary

Privacy Statement

What information we collect

"User Personal Information" is any information about one of our Users which could, alone or together with other information, personally identify them or otherwise be reasonably linked or connected with them. Information such as a username and password, an email address, a real name, an Internet protocol (IP) address, and a photograph are examples of "User Personal Information."

User Personal Information does not include aggregated, non-personally identifying information that does not identify a User or cannot otherwise be reasonably linked or connected with them. We may use such aggregated, non-personally identifying information for research purposes and to operate, analyze, improve, and optimize our Website and Service.

Information users provide directly to us

Registration information

We require some basic information at the time of account creation. When you create your own username and password, we ask you for a valid email address.

Payment information

If you sign on to a paid Account with us we collect your full name, address, and credit card information or PayPal information. Please note, PacketSafari does not process or store your credit card information or PayPal information, but our third-party payment processor does.

Profile information

You may choose to give us more information for your Account profile, such as your full name, an avatar which may include a photograph, your biography, your location, your company, and a URL to a third-party website. This information may include User Personal Information. Please note that your profile information may be visible to other Users of our Service.

Information we automatically collect from your use of the Service

Transactional information

If you have a paid Account with us, we automatically collect certain information about your transactions on the Service, such as the date, time, and amount charged.

Usage information

If you're accessing our Service or Website, we automatically collect the same basic information that most services collect, subject, where necessary, to your consent. This includes information about how you use the Service, such as the pages you view, the referring site, your IP address and session information, and the date and time of each request. This is information we collect from every visitor to the Website, whether they have an Account or not. This information may include User Personal information.

Cookies

As further described below, we automatically collect information from cookies (such as cookie ID and settings, but also JWT tokens and local storage) to keep you logged in, to remember your preferences, to identify you and your device and to analyze your use of our service.

Google Analytics

a. On the basis of our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online offer within the meaning of Art. 6 (1)(f) GDPR) Google Analytics, a web analysis service of Google Inc. (Google). Google uses cookies. The information generated by the cookie about the use of the online offer is generally transferred to a Google server in the US and stored there. b. For cases where personal data is transferred outside the EU and EEA, e.g. to the USA, the following standard contractual clauses apply: https://privacy.google.com/businesses/processorterms/mccs/ c. Google will use this information on our behalf to evaluate the use of our online offerings to our users. Google will compile reports, and provide us with insights to other services associated with the online offer which might be of interest to the user. d. Pseudonymous user profiles can be created from the processed data. e. We use Google Analytics to display the ads placed by Google and its partners (so-called remarketing or Google Analytics Audiences) only to the users that have shown an interest to our online offer, or who have certain characteristics e.g. interests in certain topics or products that are determined by the web pages visited. f. We use Google Analytics only with IP anonymization enabled. This means that Google will reduce the IP address of users within Member States of the European Union, or in other states party to the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the US and shortened there. g. The IP address transmitted by the user's browser is not merged with other Google data. Users can prevent the storage of cookies by setting their browser software accordingly. Users can also prevent Google from collecting the data generated by the cookie and relating to their use of the online offer and from processing this data by downloading and installing the browser plug-in available under the following link: http://tools.google.com/dlpage/gaoptout?hl=en. h. Further information on data use by Google, possible settings and objections can be found on Google's websites: https://www.google.com/intl/de/policies/privacy/partners (Data use by Google when using our partners' websites or apps), http://www.google.com/policies/technologies/ads (Data use for advertising purposes), http://www.google.de/settings/ads (Manage information that Google uses to show you advertising).

Device information

We may collect certain information about your device, such as its IP address, browser or client application information, language preference, operating system and application version, device type and ID, and device model and manufacturer. This information may include User Personal information.

Information we collect from third parties

PacketSafari may collect User Personal Information from third parties. For example, this may happen if you sign up for training or to receive information about PacketSafari from one of our vendors, partners, or affiliates. PacketSafari does not purchase User Personal Information from third-party data brokers.

What information we do not collect

We do not intentionally collect "Sensitive Personal Information", such as personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person's sex life or sexual orientation. If you choose to store any Sensitive Personal Information on our servers, you are responsible for complying with any regulatory controls regarding that data.

If you are a child under the age of 13, you may not have an Account on PacketSafari. PacketSafari does not knowingly collect information from or direct any of our content specifically to children under 13. If we learn or have reason to suspect that you are a User who is under the age of 13, we will have to close your Account. We don't want to discourage you from learning to analyse PCAPs, but those are the rules. Please see our Terms of Service for information about Account termination. Different countries may have different minimum age limits, and if you are below the minimum age for providing consent for data collection in your country, you may not have an Account on PacketSafari.

We do not intentionally collect User Personal Information that is stored in your PCAPs or other free-form content inputs. Any personal information within a user's PCAPs is the responsibility of the PCAPs owner.

How we use your information

We may use your information for the following purposes:

• We use your Registration Information to create your account, and to provide you the Service.
• We use your Payment Information to provide you with the Paid Account service or any other PacketSafari paid service you request.
• We use your User Personal Information, specifically your username, to identify you on PacketSafari.
• We use your Profile Information to fill out your Account profile and to share that profile with other users if you ask us to.
• We use your email address to communicate with you, if you've said that's okay, and only for the reasons you've said that's okay. Please see our section on email communication for more information.
• We use User Personal Information to respond to support requests.
• We use User Personal Information and other data to make recommendations for you, such as to suggest projects you may want to follow or contribute to. We learn from your public behavior on PacketSafari --such as the analyses you read-- to determine your analysis interests, and we recommend similar projects. These recommendations are automated decisions, but they have no legal impact on your rights.
• We may use User Personal Information to invite you to take part in surveys, beta programs, or other research projects, subject, where necessary, to your consent.
• We use Usage Information and Device Information to better understand how our Users use PacketSafari and to improve our Website and Service.
• We may use your User Personal Information if it is necessary for security purposes or to investigate possible fraud or attempts to harm PacketSafari or our Users.
• We may use your User Personal Information to comply with our legal obligations, protect our intellectual property, and enforce our Terms of Service.
• We limit our use of your User Personal Information to the purposes listed in this Privacy Statement. If we need to use your User Personal Information for other purposes, we will ask your permission first. You can always see what information we have, how we're using it, and what permissions you have given us in your user profile.

Our legal bases for processing information

To the extent that our processing of your User Personal Information is subject to certain international laws (including, but not limited to, the European Union's General Data Protection Regulation (GDPR)), PacketSafari is required to notify you about the legal basis on which we process User Personal Information. PacketSafari processes User Personal Information on the following legal bases:

• Contract Performance:

  • When you create a PacketSafari Account, you provide your Registration Information. We require this information for you to enter into the Terms of Service agreement with us, and we process that information on the basis of performing that contract. We also process your username and email address on other legal bases, as described below.
  • If you have a paid Account with us, we collect and process additional Payment Information on the basis of performing that contract.

• Consent:

  • We rely on your consent to use your User Personal Information under the following circumstances: when you fill out the information in your user profile; when you decide to participate in a PacketSafari training, research project, beta program, or survey; and for marketing purposes, where applicable. All of this User Personal Information is entirely optional, and you have the ability to access, modify, and delete it at any time. While you are not able to delete your email address entirely, you can make it private. You may withdraw your consent at any time.

• Legitimate Interests:

  • Generally, the remainder of the processing of User Personal Information we perform is necessary for the purposes of our legitimate interest, for example, for legal compliance purposes, security purposes, or to maintain ongoing confidentiality, integrity, availability, and resilience of PacketSafari's systems, Website, and Service.

• If you would like to request deletion of data we process on the basis of consent or if you object to our processing of personal information, please contact us.

How we share the information we collect

We may share your User Personal Information with third parties under one of the following circumstances:

With your consent

We share your User Personal Information, if you consent, after letting you know what information will be shared, with whom, and why. Additionally, you may direct us through your actions on PacketSafari to share your User Personal Information. For example, if you join an Group, you indicate your willingness to provide the owner of the Group with the ability to view your activity in the Group access log.

With service providers

We share User Personal Information with a limited number of service providers who process it on our behalf to provide or improve our Service, and who have agreed to privacy restrictions similar to the ones in our Privacy Statement by signing data protection agreements or making similar commitments. Our service providers perform payment processing, customer support ticketing, network data transmission, security, and other similar services. While PacketSafari processes all User Personal Information in the United States or Europan Union, our service providers may process data outside of the United States or the European Union. If you would like to know who our service providers are, please see our page on Subprocessors.

For security purposes

If you are a member of an Group, PacketSafari may share your username, Usage Information, and Device Information associated with that Group with an owner and/or administrator of the Group, to the extent that such information is provided only to investigate or respond to a security incident that affects or compromises the security of that particular Group.

For legal disclosure

PacketSafari strives for transparency in complying with legal process and legal obligations. Unless prevented from doing so by law or court order, or in rare, exigent circumstances, we make a reasonable effort to notify users of any legally compelled or required disclosure of their information. PacketSafari may disclose User Personal Information or other information we collect about you to law enforcement if required in response to a valid subpoena, court order, search warrant, a similar government order, or when we believe in good faith that disclosure is necessary to comply with our legal obligations, to protect our property or rights, or those of third parties or the public at large.

Change in control or sale

We may share User Personal Information if we are involved in a merger, sale, or acquisition of corporate entities or business units. If any such change of ownership happens, we will ensure that it is under terms that preserve the confidentiality of User Personal Information, and we will notify you on our Website or by email before any transfer of your User Personal Information. The organization receiving any User Personal Information will have to honor any promises we made in our Privacy Statement or Terms of Service.

Aggregate, non-personally identifying information

We share certain aggregated, non-personally identifying information with others about how our users, collectively, use PacketSafari, or how our users respond to our other offerings, such as our conferences or events.

We do not sell your User Personal Information for monetary or other consideration.

Repository contents

Access to private PCAPs

If your PCAP is private, you control the access to your Content. If you include User Personal Information or Sensitive Personal Information, that information may only be accessible to PacketSafari in accordance with this Privacy Statement. PacketSafari personnel do not access private PCAP content except for

• security purposes
• to assist the PCAP owner with a support matter
• to maintain the integrity of the Service
• to comply with our legal obligations
• if we have reason to believe the contents are in violation of the law, or
• with your consent

However, while we do not generally search for content in your PCAPs, we may scan our servers and content to detect certain tokens or security signatures, known active malware, known vulnerabilities in dependencies, or other content known to violate our Terms of Service, such as violent extremist or terrorist content or child exploitation imagery, based on algorithmic fingerprinting techniques (collectively, "automated scanning"). Our Terms of Service provides more details on private PCAPs.

Please note, you may choose to disable certain access to your private repositories that is enabled by default as part of providing you with the Service (for example, automated scanning needed to enable Dependency Graph and Dependabot alerts).

PacketSafari will provide notice regarding our access to private repository content, unless for legal disclosure, to comply with our legal obligations, or where otherwise bound by requirements under law, for automated scanning, or if in response to a security threat or other risk to security.

Public PCAPs

If your PCAP is public, anyone may view its contents. If you include User Personal Information, Sensitive Personal Information, or confidential information, such as email addresses or passwords, in your public repository, that information may be indexed by search engines or used by third parties.

Please see more about User Personal Information in public PCAPs.

Other important information

Public information on our Service

Many of PacketSafari services and features are public-facing. If your content is public-facing, third parties may access and use it in compliance with our Terms of Service, such as by viewing your profile or PCAPs or pulling data via our API. We do not sell that content; it is yours. However, we do allow third parties, such as research organizations or archives, to compile public-facing PacketSafari information. Other third parties, such as data brokers, have been known to scrape PacketSafari and compile data as well.

Your User Personal Information associated with your content could be gathered by third parties in these compilations of PacketSafari data. If you do not want your User Personal Information to appear in third parties' compilations of PacketSafari data, please do not make your User Personal Information publicly available.

If you would like to compile PacketSafari data, you must comply with our Terms of Service regarding information usage and privacy, and you may only use any public-facing User Personal Information you gather for the purpose for which our user authorized it. For example, where a PacketSafari user has made an email address public-facing for the purpose of identification and attribution, do not use that email address for the purposes of sending unsolicited emails to users or selling User Personal Information, such as to recruiters, headhunters, and job boards, or for commercial advertising. We expect you to reasonably secure any User Personal Information you have gathered from PacketSafari, and to respond promptly to complaints, removal requests, and "do not contact" requests from PacketSafari or PacketSafari users.

Similarly, PCAPs on PacketSafari may include publicly available User Personal Information collected as part of the collaborative process. If you have a complaint about any User Personal Information on PacketSafari, please contact us.

Groups

You may indicate, through your actions on PacketSafari, that you are willing to share your User Personal Information. If you collaborate on or become a member of a Group, then its Account owners may receive your User Personal Information. When you accept an invitation to a Group, you will be notified of the types of information owners may be able to see.

Please note, PacketSafari may share your username, Usage Information, and Device Information with the owner(s) of the Group you are a member of, to the extent that your User Personal Information is provided only to investigate or respond to a security incident that affects or compromises the security of that particular Organization.

Please contact the Account owners for more information about how they might process your User Personal Information in their Group and the ways for you to access, update, alter, or delete the User Personal Information stored in the Account.

Additional services

Third party applications

There are no third party applications at this time.

How you can access and control the information we collect

If you're already a PacketSafari user, you may access, update, alter, or delete your basic user profile information by editing your user profile or contacting PacketSafari Support. You can control the information we collect about you by limiting what information is in your profile, by keeping your information current, or by contacting PacketSafari Support.

If PacketSafari processes information about you, such as information PacketSafari receives from third parties, and you do not have an account, then you may, subject to applicable law, access, update, alter, delete, or object to the processing of your personal information by contacting PacketSafari Support.

Data portability

As a PacketSafari User, you can always take your data with you. You can download your PacketSafari, or you can contact us to request information we have about you.

Data retention and deletion of data

Generally, PacketSafari retains User Personal Information for as long as your account is active or as needed to provide you services.

If you would like to cancel your account or delete your User Personal Information, you may do so in your user profile. We retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements, but barring legal requirements, we will delete your full profile (within reason) within 90 days of your request. You may contact PacketSafari Support to request the erasure of the data we process on the basis of consent within 30 days.

After an account has been deleted, certain data, such as contributions to other Users' analyses and comments about others' PCAPs, will remain. However, we will delete or de-identify your User Personal Information, including your username and email address, from the author field of analyses and comments by associating them with a ghost user.

Our use of cookies and tracking

Cookies

PacketSafari only uses strictly necessary cookies. Cookies are small text files that websites often store on computer hard drives or mobile devices of visitors.

We use cookies solely to provide, secure, and improve our service. For example, we use them to keep you logged in, remember your preferences, identify your device for security purposes, analyze your use of our service, compile statistical reports, and provide information for future development of PacketSafari. We use our own cookies for analytics purposes, but do not use any third-party analytics service providers.

By using our service, you agree that we can place these types of cookies on your computer or device. If you disable your browser or device's ability to accept these cookies, you will not be able to log in or use our service.

We provide more information about on our PacketSafari Subprocessors and Cookies PacketSafari page that describes the cookies we set, the needs we have for those cookies, and the expiration of such cookies.

DNT

"Do Not Track" (DNT) is a privacy preference you can set in your browser if you do not want online services to collect and share certain kinds of information about your online activity from third party tracking services. PacketSafari responds to browser DNT signals and follows the W3C standard for responding to DNT signals. If you would like to set your browser to signal that you would not like to be tracked, please check your browser's documentation for how to enable that signal. There are also good applications that block online tracking, such as Privacy Badger.

How we secure your information

PacketSafari takes all measures reasonably necessary to protect User Personal Information from unauthorized access, alteration, or destruction; maintain data accuracy; and help ensure the appropriate use of User Personal Information.

PacketSafari enforces a written security information program. Our program:

• aligns with industry recognized frameworks;
• includes security safeguards reasonably designed to protect the confidentiality, integrity, availability, and resilience of our Users' data;
• is appropriate to the nature, size, and complexity of PacketSafari's business operations;
• includes incident response and data breach notification processes; and
• complies with applicable information security-related laws and regulations in the geographic regions where PacketSafari does business.

In the event of a data breach that affects your User Personal Information, we will act promptly to mitigate the impact of a breach and notify any affected Users without undue delay.

Transmission of data on PacketSafari is encrypted using SSH, HTTPS (TLS), and PCAPs content is encrypted at rest.

No method of transmission, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee its absolute security.

Our global privacy practices

Ripka Technologies S.L. is the controller responsible for the processing of your personal information in connection with the Service.

Our address is:

• Ripka Technologies S.L., Calle Reina 10 - Bajo, Valencia, Spain.

We store and process the information that we collect in the United States or European Union in accordance with this Privacy Statement, though our service providers may store and process data outside the United States or European Union. However, we understand that we have Users from different countries and regions with different privacy expectations, and we try to meet those needs even when the United States does not have the same privacy framework as other countries.

We provide the same high standard of privacy protection--as described in this Privacy Statement--to all our users around the world, regardless of their country of origin or location, and we are proud of the levels of notice, choice, accountability, security, data integrity, access, and recourse we provide. We work hard to comply with the applicable data privacy laws wherever we do business, working with our Data Protection Officer as part of a cross-functional team that oversees our privacy compliance efforts. Additionally, if our vendors or affiliates have access to User Personal Information, they must sign agreements that require them to comply with our privacy policies and with applicable data privacy laws.

In particular:

• PacketSafari provides clear methods of unambiguous, informed, specific, and freely given consent at the time of data collection, when we collect your User Personal Information using consent as a basis.
• We collect only the minimum amount of User Personal Information necessary for our purposes, unless you choose to provide more. We encourage you to only give us the amount of data you are comfortable sharing.
• We offer you simple methods of accessing, altering, or deleting the User Personal Information we have collected, where legally permitted.
• We provide our Users notice, choice, accountability, security, and access regarding their User Personal Information, and we limit the purpose for processing it. We also provide our Users a method of recourse and enforcement.

Cross-border data transfers

PacketSafari processes personal information both inside and outside of the United States and European Union and relies on Standard Contractual Clauses as the legally provided mechanism to lawfully transfer data from the European Economic Area, the United Kingdom, and Switzerland to the United States.

How we communicate with you

We use your email address to communicate with you, if you've said that's okay, and only for the reasons you've said that's okay. For example, if you contact our Support team with a request, we respond to you via email.

By design, the PCAPs may contain sensitive information. We are not able to change how you captured the PCAPs.

Depending on your email settings, PacketSafari may occasionally send notification emails about changes in PCAPs/analyses , new features, requests for feedback, important policy changes, or to offer customer support. We also send marketing emails, based on your choices and in accordance with applicable laws and regulations. There's an "unsubscribe" link located at the bottom of each of the marketing emails we send you. Please note that you cannot opt out of receiving important communications from us, such as emails from our Support team or system emails, but you can configure your notifications settings in your profile to opt out of other communications.

Our emails may contain a pixel tag, which is a small, clear image that can tell us whether or not you have opened an email and what your IP address is. We use this pixel tag to make our email more effective for you and to make sure we're not sending you unwanted email.

Resolving complaints

If you have concerns about the way PacketSafari is handling your User Personal Information, please let us know immediately. We want to help. You may contact us with the subject line "Privacy Concerns". We will respond promptly -- within 45 days at the latest.

Dispute resolution process

In the unlikely event that a dispute arises between you and PacketSafari regarding our handling of your User Personal Information, we will do our best to resolve it. Additionally, if you are a resident of an EU member state, you have the right to file a complaint with your local supervisory authority.

Changes to our Privacy Statement

Although most changes are likely to be minor, PacketSafari may change our Privacy Statement from time to time. We will provide notification to Users of material changes to this Privacy Statement through our Website at least 30 days prior to the change taking effect by posting a notice on our home page or sending email to the primary email address specified in your PacketSafari account.

Contacting us

Questions regarding PacketSafari's Privacy Statement or information practices should be directed to our contact us with the subject line "Privacy Concerns".