Cyberscout is a family of global companies that provides personal cyber assistance and identity management services for consumers and individuals worldwide. These services may include identity monitoring, fraud resolution, personal cyber services, and other specific assistance provided to data subjects. (hereinafter referred to collectively as 'consumer services').
Cyberscout also provides cyber incident and data breach support and remediation. This means we assist organizations that have experienced an incident that may impact the personal data in the organization’s care, custody, and/or control. (hereinafter referred to collectively as ‘commercial services').
Cyberscout provides its services primarily via employers, insurance providers, financial institutions, or other third-party entities. Cyberscout does not advertise and solicit business directly from any individuals, consumers, or data subjects and is a business-to-business entity. This means that services are generally made available to data subjects through institutions that have paid Cyberscout to be able to refer individuals like you to Cyberscout for assistance with your personal cyber, data exposure, fraud, or identity theft situation. Cyberscout accepts all responsibility for Cyberscout data handling and practices, but does not accept responsibility for the unrelated data handling and practices of the clients that have referred data subjects to us.
Cyberscout strives to give the data subject control of the data collection and data sharing processes. Cyberscout’s policies are to inform data subjects any time we may be about to collect any personal information, regardless of whether it is online, in person or over the telephone. This means that any time an individual is asked to reveal personal information to Cyberscout or an affiliate, we'll do our best to inform you:
- why we need to collect the information;
- what we intend to do with it;
- who, if anybody, we intend to share it with and why.
At that time, we give the data subject the option to either:
- affirmatively consent to that collection of information and proceed with providing it to us for its intended purpose to assist the individual or help them to redeem a service or product; or
- stop and discontinue providing us with personal information at the risk that the relevant assistance, service or product may not be able to be provided to you.
Cyberscout is made up of both United States (US) based entities (Cyberscout US) and entities outside of the US (Cyberscout International). As a result of the Court of Justice of the European Union Decision 2016/1250, Cyberscout wants to be clear that personal data generated in the European Union (EU) or European Economic Area (EEA) (collectively referred to as EU/EEA)is NOT transferred, processed, accessed, and/or stored in the US or by Cyberscout US based staff.
Further, all Cyberscout International data covering non- EU/EEA jurisdictions, are transferred, processed, accessed, and/or stored in the EU/EEA unless data localization requirements in a specific jurisdiction require local storage.
-If you, as a data subject, are located in the EU/EEA, your data is stored in the EU/EEA. Any access to data and servicing of EU/EEA customers is specifically performed by Cyberscout Ventures Limited (Ireland).
-If you, as a data subject, are located outside of the EU/EEA and outside of North America, your data is stored in the EU/EEA, unless the data localization requirements of your jurisdiction require storage of personal data on local servers. Any access to data and servicing of EU/EEA customers is specifically performed by Cyberscout Ventures Limited (Ireland).
In order to ensure continuity of services and support, personal data covering both EU/EEA and non- EU/EEA data may be transferred, processed, accessed, serviced, and/or stored by Cyberscout Inc. (Canada) in rare situations. This is specifically permitted under the European Commission’s finding that Canada provides an adequate level of data protection. Such sharing of Cyberscout Ventures Limited (Ireland) information with Cyberscout Inc. (Canada) would be limited to and only occur in emergency situations that restrict access to EU/EEA based systems or operations. Examples include but are not limited to extreme weather situations, internet service interruptions, sickness, holidays, and other circumstances. Otherwise all Cyberscout Ventures Limited (Ireland) and other Cyberscout International companies’ data is stored in Ireland or on E.U. based servers if not required to be stored locally. Any onward transfer of EU/EEA data from Cyberscout Inc. (Canada) to any third countries or parties , including any Cyberscout US entities is strictly prohibited.
Cyberscout Ventures Limited (Ireland) is responsible for servicing Cyberscout’s markets outside of North America, including all E.U. and Swiss clients and customers. Cyberscout Ventures Limited (Ireland) is specifically subject to the powers and regulatory authority of the Irish Data Protection Commission. Each Cyberscout International entity is further subject to the specific regulatory powers of their local based Data Protection Authority.
All data collected from individuals to provide consumer services or commercial services are stored and/or transferred using secure methods and encryption.
Any and all information collected is provided (1) by an institution you have a relationship with that has asked us to assist their data subjects when requested or help them with a data breach; or (2) directly by you during interviews with a case manager or during the online or telephone enrollment process. The information provided by your institution to Cyberscout will only be used to verify your eligibility for Cyberscout services or to help your institution notify you if they have suffered a data breach.
The information provided by you to Cyberscout may be used to help populate letters, communications, fraud victim affidavits, and documents provided to you to verify, sign and execute accordingly. You are in control of any ‘sharing’ of this information with third parties by Cyberscout. This sensitive and personal information contained in the form of letters and communications would be sent by you directly to law enforcement, fraud departments, collection agencies, government agencies/bureaus, regulators, attorneys, authorities, and/or any other necessary third parties required to help resolve your personal cyber, fraud, or identity theft situation.
The types of information we may need to collect to assist you may include a variety of personal data types and is highly dependent upon the specific assistance that you may require. For instance, just a few examples could include:
- Policy number and First and last name to verify data subject program eligibility and provide services;
- Basic bank details to assist with resolving banking and account fraud;
- Personal facts and circumstances related to a cyber-bullying incident;
- IP address or internet provider to deal with personal denial of service attack;
- Any other information necessary to assist you with any consumer services you have chosen to receive
The EU General Data Protection Regulation (GDPR) defines a controller as the natural or legal person, public authority, agency or other body which, alone or jointly with others, that determines the purposes and means of the processing of personal data. Controllers make decisions about processing activities.
In your relationship with Cyberscout, you as the data subject are a Data Controller or a ‘Joint Controller.’ This DOES NOT mean that Cyberscout is in any way released from its duties and responsibilities as a Data Controller under the GDPR and/or other applicable law(s). What this means is that Data Subjects have control over the data collected by Cyberscout as well as the ability to direct the specific purpose and uses of any such data.
You have full control of what information, if any you provide about yourself to Cyberscout, and how that data is to be used because in your relationship with Cyberscout: you are a Joint Data Controller. However, in our efforts to service you Cyberscout may utilize third-party vendors or agents and their solutions to provide you with certain services and support. While most services and the data collected in carrying out that service is managed in house by Cyberscout, some services must be provided by outside vendors. These limited situations are when Cyberscout is required to share data in order to help provide these services. Cyberscout limits the purposes of this sharing with its vendors to providing services. No personal data is shared for marketing or resale purposes by our vendor(s) and any such activity would be a violation of Cyberscout’s agreements with any and all such vendor(s).
Cyberscout International, specifically Cyberscout Ventures Limited (Ireland), only shares data with authorized third-party vendors located in (1) the E.U.; (2) non-E.U. countries that the European Commission have found to provide an adequate level of data protection. Cyberscout requires all vendors to enter into a valid data processing agreement.
Cyberscout will always do our best to inform you of when and why data will need to be shared. At any time individuals may opt-out of having their data shared with third parties by simply refraining from using Cyberscout services that involve onward transfer or sharing. When data subjects are presented with a request to provide and submit personal information, they can opt out of this sharing or decide with whom it should be shared. The data subject controls this decision based on conversations and interaction with Cyberscout representatives.
Cyberscout does not share or sell any of the personal data provided to Cyberscout with any third-party organizations for the purposes of marketing, upselling, or further reselling your data. Information is only shared when necessary, to provide data subjects with consumer services they have enrolled in through Cyberscout or their institution.
Cyberscout may be required to disclose an individual’s personal information in response to a lawful request by public authorities including but not limited to meeting national security or law enforcement requirements and/or requests.
To support delivery of our services, Cyberscout International may engage and use various third-party vendors acting as data processors who may have access to certain personal data. (hereinafter referred to collectively as ‘sub-processors’) Please visit the Cyberscout International Sub-Processor Page for important information about the identity, location and role of each Cyberscout International sub-processor. Prior to engaging any sub-processors, Cyberscout performs a privacy impact assessment/data protection impact assessment, in addition to a full due diligence review to evaluate the sub-processor’s privacy, security and confidentiality practices. Finally after completion of this due diligence review, Cyberscout executes an agreement with any sub-processors that implements appropriate security and data protection obligations and controls.
Category 1: Strictly necessary cookies. These cookies are essential to allow us to provide services that you have requested. Category 1 cookies used by Cyberscout websites: Login status cookies identify you as being logged in to our website. Load balancing cookies may be used to distribute traffic across our web servers to ensure that our websites perform well and give you the best possible experience. Subscription cookies allow us to ensure that you can access resources that you have registered for.
Category 3: Functionality cookies. These cookies allow us to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more relevant features. Some examples of Category 3 cookies used by Cyberscout websites:
- User preference cookies remember settings you’ve applied to this site such as layout, default views, search filters.
- Login cookies may be used to communicate your login details across pages of this website. This data is encrypted and not shared with third parties.
- User-profile data, such as email addresses, address and contact information: Cyberscout uses a third-party solution to collect this information for Cyberscout and Cyberscout purposes only. The user-profile data collected by Cyberscout is collected by Marketo on Cyberscout’s behalf and is provided directly to Cyberscout. This data is not shared with third parties and is used to better provide additional services like newsletters and use of user specific online tools and resources.
Category 4: Advertising Cookies. These cookies are set through Cyberscout’s website by our advertising partners. Category 4 cookies are used by Cyberscout’s advertising partners to build a profile of a user’s interests and show relevant adverts on other sites where they have the ability to do so. The specific personal data captured could include the user’s browser, IP address, and device used. These cookies contain a unique key that is able to distinguish individual users’ browsing habits or store code that can be translated into a set of browsing habits or preferences using information stored elsewhere. Cookies may also be used to limit the number times a user sees a particular ad on a website and to measure the effectiveness of a particular campaign.
These cookies are not persistent and have an expiration, varying by advertising partner and based on the last time Cyberscout’s website was visited by the user. Some examples of Category 4 cookies that may be used by Cyberscout websites include:
- Cookies placed by advertising networks to collect browsing habits in order to target relevant adverts to the user. The site the user is visiting need not actually be serving adverts, but often this will also be the case.
- Cookies placed by advertising networks in conjunction with a service implemented by the website to increase functionality, such as commenting on a blog, adding a site to the user’s social network, providing maps or counters of visitors to a site.
Cyberscout acknowledges the individual’s right to access their personal data no matter where in the world an individual may reside. If a data subject or their associated institutions have not provided Cyberscout with personal data in the past, we don't have information about the data subject. However, if a data subject or an institution that uses Cyberscout would like to:
- Know what information Cyberscout has about you
- Have any data we may have about you erased
- Correct any inaccurate data we may have about you
- Receive clarification or lodge a complaint about our data uses
PLEASE CONTACT US VIA EMAIL:
Cyberscout Global Privacy Office
ATTN: Custodian of Personal Records
We will need your legal name, mailing address, telephone number and email address, or be ready to provide such when requested by Cyberscout, so that we may locate your record(s) (if any), conduct proper identity verification prior to complying with any request or inquiry, and communicate with you regarding the status of your request.
If you would rather send your inquiry, request or complaint via standard mail/post to the nearest Cyberscout offices, you may submit to the relevant address below:
- United States mailing address: 7580 N Dobson Rd, Suite 201 Scottsdale, AZ 85256 USA
- Canada mailing address: 1080 Côte du Beaver Hall, Suite 700, Montreal, Quebec H2Z 1S8 Canada
- United Kingdom mailing address: 10 John Street, London WC1N 2EB United Kingdom
- Ireland mailing address: 2B Galway Technology Centre, Mervue Business Park, Mervue, Galway, Ireland
- Asia Pacific mailing address: 7F, No. 214, Dun Hua North Road, Taipei 10546 Taiwan
Please allow for a slower response time via submissions submitted by post.
Cyberscout does its best to provide clear, up to date, and transparent information around its privacy and data sharing practices. If you have additional questions not covered by this policy, please feel free to contact us for more information via email at Records@Cyberscout.com
This policy applies to all non-US Cyberscout entities, including Cyberscout Inc. (Canada), Cyberscout Ventures Limited (Ireland); Cyberscout Limited (U.K.); Cyberscout Pty Ltd (Australia); Cyberscout Sdn Bhd (Malaysia); and Cyberscout Pty Ltd., and Taiwan Branch (Taiwan). All of the above companies shall be collectively referred to in this policy as 'Cyberscout International.'