Was updated on March 11, 2024

SOC Prime, Inc. (“SOC Prime”, “we”, “our”, or “us”, ) recognizes the importance of protecting the privacy of your personal information, and we have prepared this Privacy Policy to provide you with information about our privacy practices - how we collect, process, use, and disclose the information you provide to us, or which we otherwise collect while you participate in the SOC Prime Threat Bounty Program (“Program”). Please read this Privacy Policy carefully before using our Program.
By continuing to interact with our Program in any manner, you expressly consent to us processing your personal data as described in this Privacy Policy.
“You” means you individually. “Website” collectively means SOC Prime websites located at: https://developer.socprime.com

1. Background to the General Data Protection Regulation (‘GDPR’)

The General Data Protection Regulation 2016/679 of the European Parliament and of the Council (“GDPR”) replaces the EU Data Protection Directive of 1995 and supersedes the laws of individual Member States that were developed in compliance with the Data Protection Directive 95/46/EC. Its purpose is to protect the “rights and freedoms” of natural persons (i.e. living individuals) and to ensure that personal data is not processed without their knowledge, and, wherever possible, that it is processed with their consent.

2. Privacy notice

2.1 Information We Collect

SOC Prime may collect personally identifiable information provided by you through voluntary registration at the Website:

• First name, Last name, Email, Password (after email confirmation)
• Expertise area and years of experience in cyber security
• Professional profiles on social media
• Displayed author’s name - real name or pseudonym that will be used as an identification of the author(s) ("author" field of the Rule) under the Detection Rule License (DRL) 1.0
• Certain financial information from you to process payment of Program Rewards, including your first name, your last name, address, form W-9 or W-8BEN, PayPal, financial account information, or other billing information
• Country
• Photo or picture that will be used as an additional identification of the Program participant
• Other information that you voluntarily provide to us to receive technical or other Program-related assistance.

Non-service related information: If you interact with us at events, webinars, or via other marketing activities and you give us your contact details or as to be contacted in one way or another, we will process that information for this purpose.
Information from other sources: We may obtain information, including your personal data, from our Website or Program and combine or associate it with the information from third parties and sources (our partners, advertisers, and integrated services) and we will treat the combined information as personal data in accordance with this Privacy Policy.
We may collect non-personal identification information about you whenever you interact with our Website.
Non personally identifiable information may include the browser name, the type of device, and technical information about your means of connection to our Website, such as the operating system and the Internet service providers utilized and other similar information.
We will endeavor to keep your information accurate and up to date, and not keep it for longer than is necessary. We do not collect your sensitive personal data.

2.2 Why does SOC Prime need to collect, process, and store personal data?

We collect your personal data to improve your personalized experience with the Program. In any event, we are committed to ensuring that the information we collect and use is appropriate for this purpose, and does not constitute an invasion of your privacy.
The personal data we collect includes the following purposes:

• For registration on the Website and in the Program
• To offer you the most suitable and convenient payment method
• To provide customer support and help about our Program when you contact us
• To contact you about your account, changes to our Website Terms, this Privacy policy, Cookie policy or other documents, and any other issues regarding the Program
• Details of your experience to advise you on content matching your professional profile
• For troubleshooting and testing of the Program to ensure that it is secure, reliable, and of a high standard and to prohibit illegal activity
• To process payment for Program Rewards
• Maintaining and improving our Program
• To respond to legal requests, court orders, or lawful requests from government agencies
• For sending you analytical, statistical information, information about private webinars for developers
• For onboarding
• Analyze IP address data for trends and statistics.
• We use Credly to issue digital badges serving as online representations of achievements and skills.

2.3 Our legal basis for collecting and processing personal data.

We will only collect and process personal data about you where we have lawful bases. Lawful bases include consent (where you have given consent), contract (where processing is necessary for the performance of a contract with you (e.g. to deliver payment for you)), and “legitimate interests”. By signing up to an account you gave us consent, which expresses consent to us processing your personal data as described in this Privacy Policy. SOC Prime does not collect personal information classified under the GDPR as ‘special categories’.
If you choose not to provide the information we request, you can still visit our Website, but you may be unable to login into your account, or access certain options, offers, and the Program. Where we rely on your consent to process personal data, you have the right to withdraw or decline your consent at any time and where we rely on legitimate interests, you have the right to object. If you have any questions about the lawful basis upon which we collect and use your personal data, please contact our Data Protection Officer.

2.4 Legitimate interests.

The legitimate interests of processing mean that such processing is performed for a task carried out in the public interest or in the exercise of official authority vested in the controller, or on grounds of the legitimate interests of a controller or a third party. SOC Prime may process your personal data for the purposes of our legitimate interests or for the legitimate interests of third parties, provided that such processing shall not outweigh your rights and freedoms. For example, we may process your personal data to:

• Protect you, us, or others from threats (such as security threats or fraud);
• Comply with laws that apply to us;
• Enable or administer our business, such as for quality control, consolidated reporting, and customer service;
• Understand and improve our business or customer relationships generally.

3. Consent

By consenting to this Privacy Policy, you are giving us permission to process your personal data specifically for the purposes identified. Specifically, you expressly consent to us processing your personal data as described in this Privacy Policy, which provides transparency to you as to how your data is collected and used and serves as a Privacy Policy as required by GDPR.
You may withdraw consent at any time on your profile page or by sending a request to our Data Protection Officer (DPO) to: dpo@socprime.com.
You are not eligible to register and provide us with personal information if you are 16 and under without your parent/guardian's permission.

4. How Can You Opt-Out of Use and Disclosure of Your Information?

SOC Prime will only use your personal data for the purposes described in this Privacy Policy or as subsequently authorized by you. You can avoid having your personal data disclosed in the following ways: a) do not provide us with your personal data; b) do not access or request the Program; or c) email us at support@socprime.com to request that we deactivate your account and delete your personal information.
Following the registration process, we also allow you the option to opt-out of receiving emails from SOC Prime. Once you have opted-in, you may also remove yourself from emailing lists at any time through the edit profile page or by following the instructions at the end of any email you receive from SOC Prime.

5. Data Processors

We may use the Program of various service providers and partners contracted to SOC Prime (Data Processors) in order to process your data more effectively. When they no longer need your data to fulfill the Program, they will dispose of the details in line with SOC Prime’s procedures.
SOC Prime selects only suppliers that can provide technical, physical, and organizational security that meet our requirements in terms of all the personal data they will process on SOC Prime’s behalf. We will ensure that all security arrangements are outlined in the contract with the external processor.
To facilitate payments in connection with the Program, we may collect certain financial information from you to process transactions, including your name, email address, address, financial account information, and other billing information.
Suppliers from outside the EU will only be selected under the following conditions, in addition to the conditions noted elsewhere in this procedure:

• if the supplier or the state in which it resides has been positively identified in an adequacy decision by the EU Commission; or
• where there are organizational and technical safeguards, established between SOC Prime and the supplier to secure the rights and freedoms of data subjects at least equal to those afforded within the EU; or
• where the arrangement has been approved by the supervisory authority.

SOC Prime maintains a list of processors (https://my.socprime.com/privacy-faq/, clause 6) who process personal data as a part of the Program, which SOC Prime updates, as needed.

We use Hotjar in order to better understand your needs and to optimize the Program and experience. Hotjar is a technology service that helps us better understand your experience (e.g. how much time you spend on which pages, which links you choose to click, what you do and don’t like, etc.) and this enables us to build and maintain our Program with your feedback. Hotjar uses cookies and other technologies to collect data on your behavior and your devices. This includes a device's IP address (processed during your session and stored in a de-identified form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), and the preferred language used to display our Website. Hotjar stores this information on our behalf in a pseudonymized user profile. Hotjar is contractually forbidden to sell any of the data collected on our behalf.

For further details, please see the ‘about Hotjar’ section of Hotjar’s support site.

Use of Intercom Service We apply third-party analytics services to help understand your usage of our Program. In particular, we provide a limited amount of information you have submitted (such as sign-up data and some personal information like your email address) to Intercom, Inc. (“Intercom”) and utilize Intercom to collect data for analytics purposes when you visit our Website. As a data processor acting on our behalf, Intercom analyzes your use of our Website and/or product and tracks our relationship using cookies and similar technologies so that we can deliver an improved service for you. For more information on Intercom's use of cookies, please visit https://www.intercom.com/terms-and-policies#cookie-policy. We may also use Intercom as a medium for communications, either through email or through messages within the Program. The Intercom Messenger Apps and Apps in Inbox products may also provide you with access to other third-party applications such as Stripe. You should consult these third parties' privacy notices for further information on their use of your personal data. As part of our service agreement, Intercom collects your publicly available contact and social information, such as your email address, gender, company, job title, photos, website URLs, social network handles, and physical addresses, to enhance your user experience. For more information on the privacy practices of Intercom, please visit https://www.intercom.com/terms-and-policies#privacy. Intercom’s services are governed by Intercom’s Terms of Service that can be found at https://www.intercom.com/terms-and-policies#terms. If you would like to opt-out of having this information collected by or submitted to Intercom, please contact us at support@socprime.com.

Digital Badges by Creedly.

SOC Prime utilizes the services of Credly, a 3rd party data processor located in the United States, to assist in creating and managing digital badges, that serve as online representations of achievements and skills. To issue you a digital badge, your personal information (email address and name) will be shared with Credly. You will receive an email notification from Credly with instructions for claiming the digital badge. To claim your badge, you are asked to sign in to an existing account or register for a Credly account as part of this process. You will be asked to accept the Credly Terms and the Credly Privacy Policy (https://info.credly.com/privacy-policy). At this point, Credly becomes the Data Controller of your personal data. To learn how Credly handles your information, read their privacy policy.
To allow us to issue you a digital badge, we will ask you to provide us with your consent in our formal communication through your email. Please make sure you follow the link and accept a new updated Privacy Policy.

6. Your account, retention, and deletion of the personal data

We may provide you with tools and preference settings that allow you to access, correct, delete, withdraw and modify information associated with your personal data.
SOC Prime will retain your personal data for as long as necessary to carry out the Program to you and will store the personal data for 5 years from the moment the account is terminated or not used. Then all your personal data collected through the platform will be deleted, as required by applicable law. Alternatively, you at any time may request that we no longer use your information then please contact us at: support@socprime.com In some cases, we choose to retain certain information in a depersonalized or aggregated form. We also may retain certain information about you as required by law or for legitimate interests’ purposes as set above after you delete your account.

7. Children's Online Privacy Protection

Children are not eligible to participate in the Program. Minors should not submit any personal information to SOC Prime if they are 16 and under without parent/guardian's permission. SOC Prime does not knowingly collect personal information from persons who are under 16 years of age.
If you learn that a child under 16 has provided us with personal information without consent please contact our Data Protection Officer by email: dpo@socprime.com.

8. Your rights as a data subject

At any point, while we are in possession of or processing your personal data, you, the data subject, have the following rights:

• Right of access – you have the right to request a copy of the information that we hold about you.
• Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
• Right to be forgotten – in certain circumstances, you can ask for the data we hold about you to be erased from our records.
• Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
• Right of portability – you have the right to have the data we hold about you transferred to another organization.
• Right to object – you have the right to object to certain types of processing such as direct marketing.
• Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.
• Right to judicial review: in the event that SOC Prime refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain as outlined below.

As a data subject, you are entitled to exercise all the rights, indicated above through a Subject access request procedure. For this purpose, please send your request to our Data Protection Officer (DPO) to the email: dpo@socprime.com. In the subject of your letter please indicate the exact title of the right you are concerned about (Right of access, Right of rectification, Right to be forgotten, Right to restriction of processing, Right of portability, Right to object, Right to object to automated processing, including profiling, Right to judicial review).
It will ensure that you receive the answer to your request from our DPO. DPO provides you the requested information in electronic format within one month from the date of receipt.

9. Cookies

Cookies are small pieces of information that a website transfers to an individual's hard drive for record-keeping purposes. Their purpose is to let us know when you visit our Website and save the preferences you set. Your browser can be set to notify you when you are sent a cookie, giving you the chance to decide whether or not to accept it. To control third-party cookies, you can also adjust your browser settings.
The information we collect and analyze is used to improve the Program. Some of the cookies we use are essential for the Website to work. We want to be sure you understand that accepting a cookie in no way gives us access to your computer or any personal information about you. The cookies collect information in an anonymous form. The cookie-related information is not used to identify you personally and the pattern data is fully under our control. To find out more about cookies, visit our Cookie Policy.

10. The right to lodge a complaint with a supervisory authority

In the event that you wish to make a complaint about how your personal data is being processed by SOC Prime (or third parties), or how your complaint has been handled, you have the right to lodge a complaint directly with SOC Prime’s Data Protection Officer or with the supervisory authority in the Member State where you live, work, or where the infringement took place.

11. Links to Third Party Sites

We may place links on our Website. When you click on a link to a third-party website from our Website, your activity and use on the linked website is governed by that website’s policies, not by those of SOC Prime. We encourage you to visit their websites and review their privacy and user policies.

12. Data Protection Officer

The Data Protection Officer is responsible for ensuring that this Privacy policy is made available to data subjects prior to SOC Prime collecting/processing their personal data. Our Data Protection Officer can be contacted directly here: Email:dpo@socprime.com

13. Changes to this Privacy Policy

We may change this Policy anytime by updating this page and encourage you to review our Privacy Policy to stay informed. If we make significant changes to our Privacy Policy or change the scope/purpose of collecting and processing of personal data, we will use reasonable efforts to notify you of such changes. If you do not provide us with consent to these changes SOC Prime has a right to close your account and discontinue the use of our Program and Website. If you continue to use our Program after Privacy Policy changes go into effect, you consent to the revised policy.

14. Contacting us

If you have questions about this Privacy Policy, please feel free to contact us at: legal@socprime.com

15. Definitions (drawn from the GDPR)

Data controller – the natural or legal person, public authority, agency, or other body which alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.
Data processor - a natural or legal person, public authority, agency, or other body that processes personal data on behalf of the controller.
Personal data – any information relating to an identified or identifiable natural person ('data subject'); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
Special categories of personal data – 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.
Data subject – any living individual who is the subject of personal data held by an organization.
Processing – any operation or set of operations that is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Profiling – is any form of automated processing of personal data intended to evaluate certain personal aspects relating to a natural person, or to analyze or predict that person’s performance at work, economic situation, location, health, personal preferences, reliability, or behavior. This definition is linked to the right of the data subject to object to profiling and a right to be informed about the existence of profiling, of measures based on profiling, and the envisaged effects of profiling on the individual.
Data subject consent - means any freely given, specific, informed, and unambiguous indication of the data subject's wishes by which he or she, by a statement or by clear affirmative action, signifies agreement to the processing of personal data relating to him or her.
Child – the GDPR defines a child as anyone under the age of 16 years old, although this may be lowered to 13 by Member State law. The processing of the personal data of a child is only lawful if parental or custodian consent has been obtained. The controller shall make reasonable efforts to verify in such cases that consent is given or authorized by the holder of parental responsibility for the child (Article 8, 1 – first paragraph GDPR).
Third party – a natural or legal person, public authority, agency, or body other than the data subject, controller, processor, and persons who, under the direct authority of the controller or processor, are authorized to process personal data.