TypingDNA Privacy Policy
TypingDNA SRL1 and TypingDNA Inc.2 (referred to
collectively and individually as “TypingDNA”, “we” or
“us”) realize that our platform,
https://www.typingdna.com/
(the “Website”) and any related services (the “Services”) we
offer, including mobile applications, can only work if we build a
relationship of trust with our users.
We control the purpose for which, and the manner in which, Personal
Information (as defined below) about individuals accessing the Website,
trying or using our Services and/or respectively being targeted by us for
marketing purposes in relation to our provision of the Services is
processed. We are therefore the data controller under applicable data
privacy laws.
Pursuant to Art. 26 of the General Data Protection Regulation3
(“GDPR”), TypingDNA SRL and TypingDNA Inc. are joint controllers
with respect to Personal Information collected via the Website or
otherwise processed by us in relation to the Website and/or our Services.
Our contact details are set out at the end of this privacy policy (“Privacy Policy”).
This Privacy Policy outlines the categories of Personal Information the
Website collects from you, that you provide to us, or that you authorize
to be provided to us or that we collect from third party resources for
marketing or other legitimate purposes in relation to our Services, the
purposes for which your Personal Information might be used and the
safeguards we put in place in the course of our relationship with you to
protect your Personal Information.
By continuing to use our Website and/or our Services, you expressly
consent to our processing of your Personal Information (as defined below)
as described in this Privacy Policy, and to being bound by the provisions
hereof.
Who we are and the Services we provide
We are a technology company developing passive authentication and typing
biometrics API (Application Programming Interfaces). Our mission is to
improve security without compromising user experience. Our technology is
the most available online biometric technology – it works with any
keyboard, on any device and does not need more than one previous sample to
start working. We provide typing biometrics authentication as a service,
an API that anyone can use for 2 Factor Authentication (2FA) and fraud
prevention purposes.
TypingDNA provides a number of products and Services, as follows:
-
Typing biometrics authentication API based on keystroke dynamics
- our typing biometrics authentication API (also known as keystroke
dynamics) is suitable for securing login, enforcing reset passwords, and
online biometric authentication. This solution assists in:
-
identifying fraudsters – it recognizes the user’s true identity on
the spot;
-
seamless authentication - typing biometrics enables frictionless
keystroke authentication in the background of any typed text;
-
text characteristics - TypingDNA supports repetitive text (e.g.
login authentication credentials) and any text (e.g. writing an
email) recognition, so it can be used in any typing scenario.
-
Multi-factor authentication: a frictionless authentication
solution with typing biometrics, SMS or email-based OTP;
-
TypingDNA Authenticator: we use verification codes in your
browser, secured by the way you type.
Personal Information
So we are clear about the terminology we are using, “personal data" means
any information describing or relating to an identified or identifiable
individual (where an identifiable individual is an individual who can be
identified, directly or indirectly, in particular by reference to an
identifier such as a name, an identification number, location data, an
online identifier or to one or more factors specific to the physical,
physiological, genetic, mental, economic, cultural or social identity of
that individual).
When we use the phrase “Personal Information” in this Privacy
Policy, we mean collectively the following categories of personal data
that may be requested by us and provided by you; in various forms on our
Website (such as demo forms, registration forms, etc.), you may be asked
to enter Personal Information such as: first/last name, password, email
address, phone number, Skype ID, Internet Protocol (IP) address, location
data, country, gender, date of birth, nationality, state or province, age,
company name, company website, typing biometrics, device type, device
fingerprint, cursor movements, pointing devices movements (e.g. mouse,
touchpad, touchscreen, trackpad, others), payment details (e.g. bank
account number, credit card number, bank).
We may process your Personal Information under this Privacy Policy:
-
if you apply for a Demo version of our Services on the Website;
- if you register an account on the Website;
-
if you enter into any contract or other arrangement (whether via the
Website or otherwise) for the use (including testing and/or
development) of our Services;
-
if you are targeted by us for communication of marketing materials about us, the Website and/or our Services
(also referred to hereinafter as a “Prospect”): we collect and process such limited Personal Information about you from public resources (such as LinkedIn, ZoomInfo, Hunter) including your name/surname, email address, telephone number, company-, title/position, profession, the way you may potentially use our solution, information about other IAM solutions that you may use, professional interests, to allow us to assess a potential interest in our Services and to contact you for marketing purposes.
When you register on our Website to use our Services, or even a Demo
version thereof, you will need to provide personal information about
yourself during the account creation/demo session – this Personal
Information includes: name/surname, your organization/company details
(name and website), age, job title/position, email address, phone number,
line of work/industry and your typing biometric. We can also collect and
further process: your typing pattern (typing biometrics), Internet
Protocol (IP) address, location data, device type, device fingerprint,
cursor movements, pointing devices movements (e.g. mouse, touchpad,
touchscreen, trackpad, others).
We collect such Personal Information from you when you register on our
Website, subscribe to a newsletter, try a demo, respond to a survey, fill
out a form or enter information on our Website, or when you provide us
with feedback on our products or Services. If you are a Prospect, we
collect and process such further Personal Information about you (as stated
above) from public sources as mentioned above.
To help keep our databases current and to provide you the most relevant
content and experiences, we may combine information provided by you with
information from other sources, in accordance with applicable law. For
example, from these sources, we may learn about the size, industry, and
other information about the company you work for.
Also, we use automated systems to analyse your content using techniques
such as machine learning in order to improve our Services and the
Websites. This analysis may occur as the content is sent or received using
an online feature of the Website or any of our Services or apps, or when
the content is stored on our servers.
Please note that registered clients can use our Services to collect typing
biometrics from their own users. It is up to the client to decide where and how to store the typing
biometrics of its users (and to apply adequate data privacy and security
measures to ensure that such data is maintained confidential and secure
from unauthorized disclosure or modification). If the client stores the
typing biometrics of its own users, it is entirely that client’s
responsibility to handle such sensitive information with care and comply
with the applicable data privacy laws, in particular regarding the end
user’s consent to the collection, processing and usage of such information
by the client and (in certain cases) by TypingDNA. If we are required to
store the typing biometrics of our clients’ end users, such data is
anonymized at our level. We do not associate any biometric data with any
Personal Information from any end-user.
When we refer to “you” in this Privacy Policy, such reference is
limited strictly to individuals who have provided Personal Information
directly to us via our Website and/or otherwise through the use of the
Services, or to Prospects whom we identify and target for
marketing-related communications.
Anonymous and Aggregate Information
When we use the phrase “Anonymous Information” in this Privacy
Policy, we mean information rendered anonymous in such a way that it
cannot or can no longer be used to personally identify an individual.
Like many companies, we monitor the use of the Website by collecting
aggregate information. No personally identifiable data is collected
in this process. Typically, we collect information about the number of
visitors to the Website and the originating domain name of the visitor's
Internet Service Provider. Also, we may collect non-personal information
about your use of the Website and/or the Services such as, IP address, log
files, user activity, time stamps, etc. Finally, we may also collect
technical information transmitted by your device, including certain
software and hardware information (e.g. the type of browser and operating
system your device uses, language preferences, access time and the domain
name of the website from which you linked to Website etc.). This
information is typically used to improve the usability, performance and
effectiveness of the platform.
Important note: For the avoidance of doubt, any aggregate, non-personal
or technical information collected, which is or may be connected or
linked to the identities of the relevant users, shall be deemed as
‘personal data’ (as such term is defined in the applicable data privacy
laws) as long as such connection or linkage exists or may be made using
all the means reasonably likely to be used. In such situations, the
provisions in this Privacy Policy regarding personal data shall apply
mutatis mutandis to the aggregate, non-personal or technical data
mentioned herein. For clarity purposes, as an example, if we have sufficient information to link an IP address to a particular individual user
(e.g., through login details, cookies, or any other information or
technology) then that IP address is personal data, and is subject to the
full protections of data protection law and this Privacy Policy.
Websites and apps covered by this Privacy Policy
Domains and subdomains that contain typingdna.com are our websites and the TypingDNA Authenticator is one of our applications that is also subject to this Privacy Policy, except for the domains and subdomains that have their own privacy policy.
Source of Collection
TypingDNA requires that you submit certain Personal Information about
yourself, including your email address and other Personal Information as
stated above, when you apply for a Demo version of our Services and/or
register an account on the Website. This information is required for you
to be able to use the Website and therefore if you do not provide this
information you will not be able to use the Website.
In the course of registering for or using the Website and/or the Services,
we may prompt you to provide additional Personal Information about
yourself including your name, alternate email addresses, year of birth,
and your city, state or country of residence, and you will also be asked
to answer a few questions to help make the Website and/or the Services
more useful to you. When you communicate with us through our platform, we
may collect and store any information that is contained in your
communications with us. We do not automatically include or display
Personal Information in your shared profile data.
Purposes and legal basis of processing of Personal Information
We may collect and use the Personal Information we collect from you when
you register, make a purchase, sign up for our newsletter, respond to a
survey or marketing communication, surf the Website and otherwise use our
Services and/or apps, or use certain other site features in the following
ways:
-
to personalize your experience and to allow us to deliver the type of
content, products and services in which you are most interested;
-
to follow up after correspondence (live chat, email or phone inquiries)
and respond to or provide any services, support, or information you have
requested;
-
to better understanding how our Website, Services and apps are being
used so we can improve them and engage and retain users;
-
to research and improve our algorithms and our Services generally;
- to diagnose problems in our Website and/or our apps or Services;
-
to tailor the Website, an app or Service to your likely interests;
-
to send you business messages such as those related to payments or
expiration of your subscription;
-
to send you information about TypingDNA, our new app/Services releases,
special offers, and similar information;
-
to conduct market research about our customers, their interests, and the
effectiveness of our marketing campaigns
-
to reduce fraud, software piracy, and protect you as well as ourselves
from the same.
We will limit Personal Information that we collect and further process
about you only to what is limited for the purposes of processing mentioned
above (or other limited purposes which are consistent with the primary
purposes mentioned above). We will not use your Personal Information in a
manner which is incompatible with the purposes for which it has been
initially collected and/or authorized by you, unless we obtain your prior
consent. Examples of compatible processing purposes may include those that
reasonably serve customer relations, compliance and legal considerations,
auditing, security and fraud prevention and preserving or defending our
legal rights etc.
We collect, process, use and, as applicable, disclose Personal Information
related to you on the basis of the following legal grounds under the GDPR:
-
consent of the data subject (Art. 6(1) letter (a) GDPR):
by choosing to use the Website and/or any of our Services, you consent
to your Personal Information being collected and processed by us for the
purposes and as regulated in this Privacy Policy. You may vary or fully
revoke your consent at any time, by sending an email to
dataprivacy@typingdna.com. Withdrawal of consent will have an effect
only for the future and does not affect the legitimacy of data processed
until that date. Please note that you may be unable to use all or part
of the Website and/or the Services if you do not provide consent to the
processing of your Personal Information. We further note that we may
continue to use any part of your Personal Information for which we may
have other legal grounds for processing in accordance with the
applicable law.
By using the Website and/or signing up for any of the products or Services
offered by TypingDNA, you agree to the terms of this Privacy Policy.
This Privacy Policy is a legally binding agreement between you (and your
client, employer or another entity if you are acting on their behalf) as
the user of the Services and TypingDNA and its Affiliates. If we add any
new features or tools to our Services, they will also be subject to this
Privacy Policy.
We may use your Personal Information based on your explicit consent for
the following purposes: (i) to provide you with the Website (including any
related apps, Services and functionalities thereof); (ii) to improve the
quality of the Website and user experience; (iii) to fulfill any request
you make; (iv) to communicate with you; (v) to contact you regarding other
products and Services we offer if you have requested such information;
(vi) or as otherwise directed by you.
-
for the purposes of performing a contract to which you are party or
in order to take steps at your request prior to entering into a
contract
(Art. 6(1) letter (b) GDPR): if you have signed up to a contract for the
Services we provide or have otherwise requested that we make the
Services available to you, we will process your Personal Information for
the purposes of giving full effects to such contract, performing our
obligations under said contract and/or ensuring that you perform your
obligations under the same.
-
our legitimate interests (Art. 6 (1) letter (f) GDPR): if
we have identified you as a suitable Prospect for the purposes of
communicating with you about our (current or future) Services, we
process (limited) Personal Information (as stated above) about you on
the basis of our legitimate interest to market the Website and/our
Services. You may object to our processing of your Personal Information
for direct marketing purposes at any time. If a Prospect becomes a user
of the Website and/or the Services at any time, your Personal Data will
then be processed by us under ‘consent’ as the grounds of processing,
mentioned above.
To the extent necessary, we may also process your Personal Information to
protect legitimate interests of our own and of third parties such as (i)
to resolve disputes and/or troubleshoot problems; and (ii) to verify your
compliance with your obligations in our Terms of Use or other TypingDNA
policies. When we process your Personal Data to meet our legitimate
interests, we balance our legitimate interests against your fundamental
rights and freedoms and we implement appropriate safeguards to ensure that
your interests, rights and freedoms do not override our legitimate
interests. For more information about the balancing tests that we have
carried out, please contact us at dataprivacy@typingdna.com.
From time to time, you may be offered the opportunity to respond to
requests for additional information from TypingDNA, including but not
limited to surveys, polls, questionnaires, and feedback.
When we communicate with you regarding the products and Services we offer
or develop, you will be given the opportunity in each communication to
unsubscribe and prevent future communications of that sort. Please note
that emails we send you may include a technology (called a web beacon)
that tells us whether you have received or opened the email or clicked a
link in the email.
If you do not want us to collect this information from our marketing
emails, or if you wish to unsubscribe from direct marketing communications
from us, you may write to us at
dataprivacy@typingdna.com
requesting the same. We will cease using your Personal Information for
direct marketing purposes once you have requested us to do so.
Additionally, we may use your Personal Information to create Anonymous
Information including for use in future scientific research, product
development and market research, if you agree to let us do so.
Note: for the avoidance of doubt, TypingDNA does not use your Personal
Data (including, in particular, your typing pattern) for the purposes of
an automated decision-making process or for profiling.
Our organization acknowledges and adheres to the investigatory and
enforcement powers of the Federal Trade Commission (FTC). As part of our
commitment to protecting your privacy and upholding the highest standards
of information security, we are subject to the oversight and regulatory
authority of the FTC. This means that our practices regarding the
collection, use, and protection of personal information are designed to be
in compliance with applicable FTC guidelines and regulations.
In the event of any inquiries or complaints about our privacy practices,
the FTC is empowered to conduct investigations into our compliance with
privacy standards. We pledge to cooperate fully with any such
investigations and to take appropriate actions to rectify any issues that
may arise. Our commitment to your privacy is a top priority, and we strive
to maintain the highest levels of transparency and accountability in all
our operations.
Recipients of Personal Information
TypingDNA uses the Website to facilitate your engagement in and use of the
Website and/or the Services we provide.
We may disclose your Personal Information: (a) to third party
vendors/suppliers who help us provide the Website and/or the Services; (b)
to third parties to whom you ask us to send Personal Information,
including other users to whom you authorize us to provide certain details
of your Personal Information; (c) as required by law, such as to comply
with a subpoena or otherwise in response to a lawful request by public
authorities (including to meet national security or law enforcement
requirements), or similar legal process when we believe in good faith that
disclosure is necessary to protect our rights, protect your safety or the
safety of others, investigate fraud, or respond to a government request;
(d) to a parent company, any subsidiaries, joint ventures, or other
companies under common control with us (collectively,
“Affiliates”), in the event we have such Affiliates now or in the
future, in which case we will require our Affiliates to honor this Privacy
Policy, or (e) to a company that merges with us, acquires us, or purchases
our assets, or a successor in interest in bankruptcy, in which case such
company may continue to process your Personal Information as set forth in
this Privacy Policy.
We will share your Personal Information with third parties only in the
ways that are described in this Privacy Policy, only to the extent
necessary as per the applicable purpose of the disclosure and in strict
compliance with applicable data privacy laws (including by observing the
requirement to conclude compliant data processing agreements with any
third party processor carrying out their tasks on our behalf and upon our
instructions). We do not otherwise share or sell your Personal Information
with or to third parties. We may use and disclose Anonymous Information
without restriction.
We do not and will not share, disclose, sell, rent, or otherwise provide
Personal Information to other companies for the marketing of their own
products or services.
If you do not want us to disclose your Personal Information to a third
party, please write to us at
dataprivacy@typingdna.com
in this sense. We will take all measures which may be feasible to give
effect to such request, but may continue to disclose your Personal
Information to a third party acting as an agent/data processor performing
tasks on our behalf and under our instructions, only to the extent
strictly required for such operations.
International Transfers of Personal Information
We may need to disclose your Personal Information to TypingDNA, Inc. or to
third parties located outside the European Economic Area (EEA). This
kind of data disclosure may happen due to:
-
our intragroup data sharing practices (e.g., access by TypingDNA Inc. to
our customer lists for reporting purposes) or
-
if our servers (i.e. where we store data) or our suppliers and service
providers are based outside the EEA, or
-
if you use our services and products while visiting countries outside
this area.
TypingDNA complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF)
as set forth by the U.S. Department of Commerce. TypingDNA has certified
to the U.S. Department of Commerce that it adheres to the EU-U.S. Data
Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the
processing of personal data received from the European Union in reliance
on the EU-U.S. DPF. If there is any conflict between the terms in this
privacy policy and the EU-U.S. DPF Principles, the Principles shall
govern. To learn more about the Data Privacy Framework (DPF) Program, and
to view our certification, please visit
https://www.dataprivacyframework.gov/.
We will always ensure that suitable safeguards (such as standard
contractual clauses as approved by the European Commission) are in place
to protect your Personal Information and that the transfer of your
Personal Information complies with applicable data protection laws.
We acknowledge and accept our liability for any onward transfer of your personal data to third-party recipients, and will take all reasonable measures to ensure that these recipients uphold the same level of protection and compliance with data privacy obligations as we do.
In the event that a third-party recipient fails to process your data in compliance with applicable data protection laws or the terms of our agreements, we will take prompt action to address the situation and may be required to remedy the breach.
Please note that our liability for onward transfers may be limited or excluded in specific circumstances, such as when a third party fails to meet its obligations, and we have exercised reasonable efforts to ensure compliance. We will not be liable for damages resulting from unauthorized processing or misuse of personal data by third parties that are beyond our control or scope.
By using our services, you consent to the onward transfer of your personal data and acknowledge our responsibility to uphold your privacy rights in accordance with this Privacy Policy.
Rights with regard to Personal Information
You have a number of rights under the GDPR in relation to your Personal Information, as follows:
-
the right of access pursuant to Art. 15 GDPR: you have the right to obtain from us confirmation as to whether or
not Personal Information concerning you is being processed, and, where
that is the case, access to (including by obtaining a copy of) such
Personal Information and the manner in which, and the purposes for which
we process your Personal Information so that you can verify its accuracy
and the lawfulness of the processing;
-
the right to rectification pursuant to Art. 16 GDPR: you have the right to obtain from us the rectification of inaccurate
Personal Information concerning you, and the right to have incomplete
personal data completed, including by means of providing a supplementary
statement
-
the right to erasure pursuant to Art. 17 GDPR: the right to obtain from us the erasure of your Personal Information
delay where (a) your Personal Information is no longer necessary for the
purpose for which it was collected/processed; (b) you wish to withdraw
your consent to processing (except where we have another legal ground
for the processing that we may rely on); (c) where processing is based
on our legitimate interests and there are no overriding legitimate
grounds for processing; (d) where your Personal Information has been
unlawfully processed;
-
the right to restriction of processing pursuant to Art. 18 GDPR: you have the right to obtain from us the restriction of processing of
your Personal Information where (a) the accuracy of such Personal
Information is contested by you (for such period as will enable us to
verify the accuracy of your Personal Information); (b) the processing of
your Personal Information is unlawful, but you do object to the deletion
of such data and request restriction of its use instead; (c) you
consider that we no longer need your Personal Information for the
purposes of the processing, but require such Personal Information for
the establishment, exercise or defense of legal claims; (d) you have
objected to the processing of your Personal Data on grounds of
‘legitimate interest’ as per (iii) above, pending verification by us on
whether our legitimate grounds override your own.
-
the right to objection pursuant to Art. 21 GDPR: you have the right to object, on grounds relating to your particular
situation, at any time to processing of your Personal Information, which
is based on point our legitimate interests, including profiling based on
those provisions. We shall no longer process the personal data unless we
have compelling legitimate grounds for the processing which override
your interests, rights and freedoms or for the establishment, exercise
or defense of legal claims. You may object to the processing of your
Personal Information for direct marketing purposes at any time, without
giving reason.
-
the right to data portability pursuant to Art. 20 GDPR: you have the right to receive Personal Information concerning you,
and which you have provided to us, in a structured, commonly used and
machine-readable format, and to transmit such data to another data
controller (please note this applies only where our processing of your
Personal Information is based on your consent or on a contract, and the
processing is carried out by automated means)
-
the right to appeal to a competent data protection supervisory
authority (Art. 77 GDPR): you have the right to appeal to the competent data protection
supervisory authority - in Romania, such authority is the Romanian
National Authority for the Supervision of Personal Data Processing (www.dataprotection.ro). In compliance with the EU-U.S. DPF, TypingDNA commits to refer
unresolved complaints concerning our handling of personal data received
in reliance on the EU-U.S. DPF to ICR AAA DPF IRM SERVICE, an
alternative dispute resolution provider based in the United States. If
you do not receive timely acknowledgment of your DPF Principles-related
complaint from us, or if we have not addressed your DPF
Principles-related complaint to your satisfaction, please visit
https://go.adr.org/dpf_irm.html for more information or to file a
complaint. The services of ICR AAA DPF IRM SERVICE are provided at no
cost to you.
Your exercise of these rights is subject to certain exemptions to
safeguard the public interest (e.g. the prevention or detection of crime),
our interests (e.g. the maintenance of legal privilege) or rights and
freedoms of others, as provided by the GDPR.
While we will make good faith efforts to provide you with access to your
Personal Information, we may deny or limited access to such Personal
Information where: this would interfere with the execution or enforcement
of the law or with private causes of action (including the prevention,
investigation or detection of offences or the right to a fair trial); the
legitimate rights and interest of others would be violated through such
disclosure; this would prejudice the confidentiality necessary in
monitoring, inspection or regulatory functions connected with sound
management, or in future or ongoing negotiations involving us. We will of
course endeavour to offer you an adequate explanation of the necessity,
and reason for, restricting access in the circumstances mentioned
above.
If you exercise any of these rights, we will check your entitlement and
respond without undue delay, but not later than within a month. In complex
cases or at times of receiving numerous requests, this period may be
extended by two further months of which we will inform you.
To review or update your Personal Information including user information
to ensure it is accurate, please write to us at
dataprivacy@typingdna.com
informing us of any changes that may need to be made in respect of your
Personal Information and we will update such information on your behalf
and in our systems.
If you wish to delete your TypingDNA account, please write to us at
dataprivacy@typingdna.com
requesting that your account be deleted and we will proceed with this
deletion on your behalf and in our systems.
Please note that once you delete your account you will no longer be able
to enjoy the full functionality of the Website and/or (part or all) of the
Services we provide. Certain information is necessary in order for us to
provide the Website; therefore, if you delete such necessary information
you will not be able to use the Website and/or the Services.
Please remember, however, if we have already disclosed some of this
information to third parties, we cannot access that information any longer
and cannot force the deletion or modification of any such information by
the parties to whom we have made those disclosures. We will of course
comply with any legal obligation we may have to notify them of your
request.
Please note that even though you may request the deletion of your Personal
Information by us, we may be required (by law or otherwise, such as to
prevent fraud, resolve disputes, or troubleshoot problems) to keep this
information and not delete it, or to keep this information for a certain
time, in which case we will comply with your account deletion only after
we have fulfilled such requirements. When you delete your account,
Personal Information will be deleted from the active database, but
(limited) Personal Information may remain in our archives where legally
permitted.
If you have unsubscribed from receiving marketing information from us, we
will continue to maintain your Personal Data for any other purpose for
which we still have legal grounds for processing such Personal Data (such
as the performance of a contract, for the purposes of complying with a
legal obligation or when the processing is necessary for the purpose of a
legitimate interest of us). In certain cases, if no other legal grounds
exist, we will maintain limited Personal Data (such as your email address)
about you on record so as to be able to ensure for the future that such
marketing communications are no longer sent to you.
Please note that any processing of your Personal Data prior to the
deletion of your account with us, or your request that we no longer
contact you for direct marketing purposes will remain valid under the
legal grounds then prevailing.
You can exercise any of your rights as stated above, by sending us a
request to
dataprivacy@typingdna.com.
We will endeavor to respond to any such request as soon as possible, and
in any event within the legal deadline.
In accordance with our adherence to the Data Protection Framework (DPF)
Principles, and specifically as outlined in Annex I of these Principles,
our organization recognizes the right of individuals to invoke binding
arbitration as a means of resolving certain disputes. By engaging with our
services and providing your personal information, you acknowledge and
agree to this binding arbitration provision as a means of dispute
resolution, where applicable and in accordance with the terms set forth in
Annex I of the DPF Principles.
TypingDNA commits to arbitrate claims and follow the terms as set forth in
Annex I of the DPF Principles, provided that an individual has invoked
biding arbitration by delivering notice to our organization and following
the procedures and subject to conditions set forth in Annex I of the DPF
Principles.
Information Security
The security of your personal information is important to us. We use
appropriate technical and organizational methods to protect the Personal
Information submitted to, or otherwise processed by, us, both during
transmission and once we receive it from loss, misuse or unauthorized
access, disclosure, alteration and destruction, taking into account the
risks involved in the processing and the nature of the Personal
Information.
We take great care in implementing and maintaining the security of the
Website, the Services we provide and of your Personal Information. We have
put in place appropriate technical and organizational measures to protect
your Personal Information against accidental or unlawful destruction,
loss, alteration, unauthorized disclosure or access and against all other
unlawful forms of processing, in accordance with the law. In addition, we
employ industry standard procedures and controls to ensure the safety of
your personal data, such as: secure network typology which includes
Firewall systems; encrypted communication, authentication and access
control, external and internal audit tests, etc.
Your Personal Information (including typing biometrics) is stored on
virtual servers hosted by different cloud services and third party SaaS
(Software as a Service) providers, in a secured database behind secured
networks and is only accessible by a limited number of persons who have
special access rights to such systems and are required to keep the
information confidential. In addition, all sensitive information you
supply, and which is being transferred between the browser and the server
is encrypted via Secure Socket Layer (SSL) technology. We store sensible
data encrypted via AES256 (Advanced Encryption Standard 256).
We implement a variety of security measures when a user enters, submits,
or accesses their information to maintain the safety of your personal
information. We do not use vulnerability scanning and/or scanning to PCI
standards.
No method of transmission over the Internet, or method of electronic
storage, is 100% secure, however. Therefore, although we take reasonable
steps to safeguard information, we cannot be responsible for the acts of
those who gain unauthorised access or abuse the Website and we make no
warranty, express, implied or otherwise, that we will prevent such access.
Cookies & Other Anonymous Information
As you use the Website and/or the Services, certain Anonymous Information
may be collected and stored via cookies and similar technologies, such as
your Internet protocol address, domain names, browser type, click-stream
data, and access times.
A cookie is a small text file that is stored on a user’s computer for
record-keeping purposes. We use cookies on this Website. We do not link
the information we store in cookies to any Personal Information you submit
while on our site without your express consent.
We use cookies to:
- understand and save user's preferences for future visits;
-
compile aggregate data about site traffic and site interactions in order
to offer better Website experiences and tools in the future;
- improve and provide security in our applications;
- improve and provide the Service.
We may also use trusted third-party services that track this information
on our behalf.
- keep track of advertisements;
- help remember and process the items in the shopping cart.
We may use both session ID cookies and persistent cookies. We use session
cookies to make it easier for you to navigate our site. A session ID
cookie expires when you close your browser. A persistent cookie remains on
your hard drive for an extended period of time. We may also set persistent
cookies to store your passwords, so you do not have to enter it more than
once. Persistent cookies will enable us to track and target the interests
of our users to enhance the experience on our site.
You can choose to have your computer warn you each time a cookie is being
sent, or you can choose to turn off all cookies. You do this through your
browser settings. Since each browser is a little different, look at your
browser's Help Menu to learn the correct way to modify your cookies
preferences. If you disable cookies in your browser, some features will be
disabled. Some of the features that make your Website experience more
efficient may not function properly.
We may use the Anonymous Information we collect from you to customize the content and layout of the Website and/or the Services for you and improve our internal operations of the Service and the content of our Website. With your opt-in consent, we may combine this Anonymous Information with your Personal Information such that the information is no longer anonymous.
Google Analytics, Google Ads
These are services of Google Inc. ("Google"). Google Analytics uses so-called "cookies", text files that are stored on your computer and that allow an analysis of the use of the Website by you. The information generated by the cookie about your use of the Website and/or the Services (including your IP address) is transmitted to a Google server in the USA and stored there anonymously. Google will use this information to evaluate your use of the Website, to compile reports on website activity for website operators and to provide other services related to website activity and Internet usage. Google may also transfer this information to third parties if required by law or as far as third parties process this data on behalf of Google. Third parties, including Google, place ads on websites on the Internet. Third-party providers, including Google, use stored cookies to serve ads based on previous visits by a user to this website. You can prevent the installation of cookies by setting your browser software accordingly; however, please note that in this case you may not be able to use all features of this Website to the fullest extent. You can also visit the page to disable Google advertising. By using this Website, you consent to the processing of data about you by Google in the manner and for the purposes set out above.
Twitter Ads
The Website uses cookies and other similar technologies, such as Twitter
pixels to measure performance of our Twitter Ads campaigns.
Hotjar
Hotjar is an analytics and feedback tool that we use to understand how our
Website is used and improve usability. Hotjar sets cookies to help us
track behaviour across pages and to control visitor polls. The cookies
carry no personally identifiable information.
Hubspot
HubSpot offers a full platform of marketing, sales, customer service, and
CRM software – plus the methodology, resources, and support – for inbound
marketing. When you visit our Website, HubSpot's tracking code sets a
number of tracking cookies to track Website visitors and contacts. It
leaves behind a cookie on your computers that helps HubSpot identify them
on future visits.
Linkedin Insight Tag
The LinkedIn Insight Tag allows the collection of data on website visits,
including URL, referrer URL, IP address, device and browser properties
(user agent), and timestamp. IP addresses are shortened or hashed (if used
to reach members across devices). The tool permits the tracking of the
behaviour of users after they click on a LinkedIn ad and are redirected to
the website of the advertising or promoted company. Conversion measurement
allows the measurement, evaluation, and optimisation of the effectiveness
of LinkedIn ads for reasons of statistics and market research.
The personal data collected is transmitted to LinkedIn by the LinkedIn Insight
Tag and processed by LinkedIn for the purpose of conversion measurement.
LinkedIn may provide Us with anonymised reports on conversion measurement.
It cannot be ruled out that LinkedIn may link the transmitted personal
data with other personal data, e.g., from an existing LinkedIn account.
LinkedIn also uses data that does not identify you to improve the
relevance of ads and to reach members across devices. It is not excluded
that LinkedIn uses corresponding data for further purposes of its own.
The integration of the LinkedIn Insight Tag allows us to place target
group-oriented ads on LinkedIn and to obtain real-time information about
the professional goals and preferred content of the website visitors.
It cannot be ruled out that the data is transmitted to insecure third
countries such as the U.S.
The LinkedIn Insight Tag is also used to display LinkedIn ads to people
with whom we have already been in contact (“retargeting”).
If you click on a LinkedIn ad, a cookie for conversion tracking will be
stored on your computer.
If you access our website and the cookie has not yet expired, we will be
able to recognise that you have clicked on the ad and were thus redirected
to our website. LinkedIn as the service provider will receive this
information as well.
The lawful basis for the use of the LinkedIn Insight Tag is your consent
in accordance with Article 6 (1) (a) GDPR.
Further information how your data is processed at or by LinkedIn, please visit https://www.linkedin.com/legal/privacy-policy.
Third Party Websites and Services
The platform may contain links to websites hosted and operated by
companies other than us (“Third-Party Websites”) to which you can
export (part of) your Personal Information on the Website.
We do not disclose your Personal Information to these Third-Party Websites
without your explicit consent. Note that any information you disclose to
Third Party Websites is no longer under our control and no longer subject
to this Privacy Policy.
You should review the privacy policy practices of any such Third-Party
Website to understand how that Third-Party Website collects and uses your
Personal Information should you have decided to disclose your Personal
Information to them. We are not responsible for the content or performance
of these Third-Party Websites. We are in no way responsible or liable for
the manner in which a Third-Party Website treats any Personal Information
that you choose to provide to such a Third-Party Website and use of
Third-Party Websites is strictly at your own risk.
We may use a third-party tracking service such as Google Analytics to
track and analyze Anonymous Information from users of the platform. Such
third parties may use cookies to help track user behaviour. The use of
cookies by third parties is not covered by this Privacy Policy. We do not
have access or control over these cookies.
Changes to the Privacy Policy
We may update this Privacy Policy to reflect changes to our information practices. If we make any material changes, we will notify you by email (sent to the email address specified in your account) or by means of a notice on this Website prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices. Continued use of our platform following notice of such changes will indicate your acknowledgement of such changes and agreement to be bound by the terms and conditions of such changes.
Any changes to this Privacy Policy may affect our use or disclosure of Personal Information collected prior to the changes. If you do not agree to any of the changes, you must notify us prior to the effective date of the changes that you wish to terminate your account with us. Continued use of our platform following such notice of such changes shall indicate your acknowledgement of such changes and agreement to be bound by the terms and conditions of such changes.
Retention Period
We endeavour to ensure that Personal Information is kept as current as
possible and that irrelevant or excessive data are deleted or made
anonymous as soon as reasonably practicable. We retain Personal
Information about you only for as long as it serves a purpose of
processing mentioned in this Privacy Policy. This does not prevent us from
processing your Personal Information for longer periods of time, to the
extent such processing reasonably serves other purposes, including for
statistical analysis.
However, some Personal Information may be retained for varying time
periods in order to comply with legal and regulatory obligations and for
other legitimate business reasons. We will generally retain your Personal
Information only so long as it is required for purposes for which it was
collected. Where your Personal Information is no longer required, we will
ensure it is either securely deleted or stored in a way which means it
will no longer be used by the business.
Subject to the principles set out in the above paragraph, we may delete
your account 5 years after your last accessing of the Website and/or of
any of our (current or future) Services, if you do not wish an earlier
deletion of Personal Information. Note: we may continue to use Your typing
pattern if we have used such typing pattern to build the algorithm, to
further develop and improve the algorithm. If we do so, we undertake to
anonymise/de-personalise Your typing pattern in such a way that it can no
longer be linked to You and therefore no longer constitute Personal
Information about You.
Children
The Website and our Services are not directed to children and children are
not eligible to use our Website and/or any of our Services.
Protecting the privacy of children is very important to us. We do not
collect or maintain Personal Information from people we actually know are
under 18 years of age, and no part of our Website is designed to attract
people under 18 years of age or persons under the age of legal consent in
any jurisdiction (“Legally of Age”).
Do not attempt to access the Website and/or create an account and/or apply
for a demo version of our Services if you are not Legally of Age. If we
later learn that a user is not Legally of Age, we will take steps to
remove that user’s information from our databases and to prevent the user
from utilizing the Website and/or any of our Services.
If you are the parent of a legal guardian of a person that is not Legally
of Age who has registered on our Website, or who you believe has otherwise
provided Personal Information to us, please contact us using the details
set out at the end of this Privacy Policy to have the information deleted.
Information voluntarily provided by persons not Legally of Age via emails,
message boards, chat sessions etc. may be used by other parties to
generate unsolicited emails. We encourage parents and legal guardians to
inform children about how to use the Internet in a safe and responsible
manner.
Questions about this Privacy Policy & Exercising your rights as a Data
subject
If you have questions or comments about this Privacy Policy, or wish to
exercise any of your data subject rights under the GDPR, or otherwise make
any request as specified further in this Privacy Policy, please contact us
at:
dataprivacy@typingdna.com
If you are dissatisfied with our use of your Personal Information or our
response to any exercise of your rights under the GDPR, you have the right
to complain to the data protection authority:
https://www.dataprotection.ro/.
In order to ensure timely resolution, we encourage you to reach out to us
first with respect to any queries, questions or complaints you may have in
relation to our processing of your Personal Information. We will endeavour
to respond as soon as practicable.
Last Updated: December 2024
1 TypingDNA SRL, a Romanian limited liability company
headquartered in Romania, Oradea, Str. Santului 2E, 1st floor, registered
with the Trade Registry under no. J5/1153/2016, unique registration code
36172414;
2 TypingDNA Inc., a US, Delaware company headquartered in 77
Sands Street, Brooklyn, NY, 11201;
3 Regulation (EU) 2016/679 of the European Parliament and of
the Council of 27 April 2016 on the protection of natural persons with
regard to the processing of personal data and on the free movement of such
data;
4 The EEA consists of countries in the European Union,
Switzerland, Iceland, Liechtenstein and Norway