Privacy Policy

Last Updated: 1 January, 2020

This privacy policy (“Policy”) explains how your personal information is collected, used, and disclosed by WatchGuard Technologies, Inc. and its subsidiaries and affiliated companies throughout the world (“WatchGuard” or “we”). This Policy applies to the websites of WatchGuard, including www.watchguard.com and its other websites throughout the world. This Policy also applies to WatchGuard’s suite of products and services, including its Firebox network security appliances; network security services that run on those appliances or in the cloud; WatchGuard Cloud and Wi-Fi Cloud services; WatchGuard Dimension management service; our partner portal and related services; WatchGuard mobile applications; and other products and services (collectively, “Services”). However, this Policy does not apply to websites, products, or services that display or link to different privacy statements or that are operated by companies other than WatchGuard, or to business activities or practices of third parties, including our channel partners. This Policy also does not apply to information processed in the operation of Services but to which we do not have access; this is generally true, for example, as to network traffic processed by a Firebox appliance running in a customer’s network.

We collect and process personal information about you with your consent or as necessary to provide the Services you use, operate our business, meet our contractual and legal obligations, protect the security of our systems and our customers, or fulfill other legitimate interests.

ABOUT WATCHGUARD

WatchGuard has deployed nearly a million integrated, multi-function threat management appliances worldwide. Our signature red boxes are architected to be the industry’s smartest, fastest, and meanest security devices with every scanning engine running at full throttle. WatchGuard’s global headquarters are located at 505 Fifth Avenue South, Suite 500, Seattle, WA 98104.

INFORMATION COLLECTED

We collect information about you in various ways when you use our Services. We collect personal information you provide to us. For example, we collect your name, email address, social media identity, postal address, phone number, company name, fax number, demographics and other information you provide us on our Services. We also collect credit card numbers if you purchase our products on our websites or through other Services. Some Services may not be available or function correctly if you are not willing to provide personal information. We may also obtain information from other sources and combine that with information we collect on our Services.

If you apply for a job, we will collect your name, email, phone number, postal address, resume, desired pay, education history, whether you are over the age of 18, and visa status. You also may choose to provide your gender, ethnicity, veteran status, disability status, and links to your website, blog, portfolio and LinkedIn profile.

We gather certain information automatically to analyze trends and administer our websites and other Services. This information may include your Internet Protocol (IP) address (or the proxy server you use to access the internet), device and application identification numbers, your location, browser type and language, your internet service provider or mobile carrier, the pages, files, and videos you viewed, your searches, your operating system and system configuration information, and date and time stamps associated with your usage. When you visit our websites we also automatically receive the URL of the website from which you came and the website to which you go when you leave our website.

Cookies. We collect information using “cookies.” Cookies are small data files stored on your computer or mobile device by a website. Among other things, cookies help us improve our Services and your experience. We use cookies to see which areas and features are popular and to count visits to our websites and particular webpages. We also use cookies to display targeted content, promotions, or advertisements. You can find out more about the cookies used on our websites in our Cookie Policy.

Web Beacons. We collect information using web beacons, alone or in conjunction with cookies. Web beacons are clear electronic images that can recognize certain types of information on your computer, such as cookies, when you viewed a particular website or Service tied to the web beacon, and a description of a website or Service tied to the web beacon. For example, we or our marketing partners may place web beacons in marketing emails that notify us or our partner when you click on a link in the email that directs you to one of our websites. We use web beacons to understand usage and marketing campaign effectiveness, and to operate and improve our websites, Services, and email communications. You can find out more about our use of web beacons in our Cookie Policy.

Analytics. Third parties who provide us with analytics services for the Services may also automatically collect some of the information described above, including, for example, IP address, access times, browser type and language, device type, device identifiers and Wi-Fi information. Please consult the respective privacy policies and statements of these third parties for more information, including how Google Analytics, Marketo, Mouseflow, Salesforce, Widen, and Wistia use this data.

Advertising. Other third parties, including advertisers and ad-related services, may also automatically collect the above information about you through the Services and on other sites and services, including personally identifiable information about your online activities over time and across different websites, devices, online services, and applications when you use our Services. Some third parties help us and others associate your activities across the browsers and devices you use, for retargeting, cross-device advertising, analytics, and measurement purposes. Some third parties, such as Google AdWords, may also collect information on behalf of us and others for online advertising purposes and to provide to us and others statistics about users of our websites and other Services.

Device Feedback Data. Our Firebox appliances have a default setting to send us certain information upon activation and approximately weekly thereafter, including their IP address, country of location, serial number, and diagnostic data. If you have administrator privileges for a Firebox you have the option of changing this setting such that this data will not be sent.

In some cases, we may receive personal information from you about a third party. If you submit any personal information about another individual to us, you are responsible for making sure that you have the authority to do so and to allow us to use their personal information in accordance with this Policy.

USE OF INFORMATION WE COLLECT

We use personal information collected through our Services for purposes described in this Policy or disclosed to you in our Services or in connection with our Services. For example, we may use your information to:

• operate and improve our internal operations, systems, and Services;
• understand you and your preferences to improve your experience and enjoyment using our Services;
• respond to your comments, questions, and support queries, and provide customer service;
• provide the Services you request, whether you request them directly from us or from one of our channel partners;
• provide our channel partners with information to facilitate their provision of Services to you as resellers;
• send you and channel partners information related to Services such as confirmations, invoices, expiration and renewal notices, technical notices, Service updates and security feeds, security alerts, and support and administrative messages;
• communicate with you about new products and services, upcoming events, promotions, rewards, and other news about products and services offered by WatchGuard and our selected partners;
• process and deliver contest entries and rewards;
• to process your job application;
• link or combine information about you with other personal information we get from third parties, to help understand your needs and provide you with better and more personalized service;
• defend our legal rights and the rights of others;
• protect, investigate, and deter against fraudulent, unauthorized, or illegal activity; and
• comply with applicable law.

SHARING OF PERSONAL INFORMATION

We do not share your personal information with third parties, other than as follows:

• with your consent, for example, when you agree to our sharing your information with other third parties for their own marketing purposes subject to their separate privacy policies;
• with our channel partners such as resellers so they can provide Services to you;
• with third party vendors, consultants, and other service providers who work for us and need access to your information to do that work;
• to (i) comply with laws or to respond to lawful requests and legal process, (ii) to protect the rights and property of WatchGuard and our agents, customers, and others including to enforce our agreements, policies, and terms of use or (iii) in an emergency to protect the personal safety of WatchGuard, its customers, or any person;
• in connection with or during negotiation of any merger, financing, acquisition, bankruptcy, dissolution, transaction, or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets to another company.

We may also share aggregated or deidentified information.

Google Analytics

We use Google Analytics, a web analytics service provided by Google, Inc. Google Analytics uses Cookies or other tracking technologies to help us analyze how users interact with our website and Services, compile reports on their activity, and provide other services related to their activity and usage. The technologies used by Google may collect information such as your IP address, time of visit, whether you are a returning visitor, and any referring website. The technologies used by Google Analytics do not gather information that personally identifies you. The information generated by Google Analytics will be transmitted to and stored by Google and will be subject to Google’s privacy policies. To learn more about Google’s partner services and to learn how to opt-out of tracking of analytics by Google, click here.

SECURITY OF YOUR PERSONAL INFORMATION

WatchGuard takes reasonable steps to help protect your personal information in an effort to prevent loss, misuse, and unauthorized access, disclosure, alteration, and destruction.However, no security measure or modality of data transmission over the Internet is 100% secure. Although we strive to use commercially acceptable mans to protect your personal information, we cannot guarantee absolute security.

CHILDREN’S PRIVACY

Our websites and Services are not intended for children under 13 years of age. We do not knowingly collect, use, or disclose personal information from children under 13.

TRANSFERS OF YOUR PERSONAL INFORMATION

Personal information we collect may be stored and processed in your region, in the United States or in any other country where we or our affiliates, subsidiaries or service providers maintain facilities. We maintain primary data centers in the United States, Germany, and Japan. We take steps designed to ensure that the data we collect under this Policy is processed according to the provisions of this Policy and applicable law wherever the data is located.

When we transfer personal information from the European Economic Area and Switzerland to other countries, some of which have not been determined by the European Commission to have an adequate level of data protection, we use a variety of legal mechanisms, including contracts and the EU-US and Swiss-US Privacy Shield frameworks, in an effort to help ensure your rights and protections.

EU-US and Swiss-US Privacy Shield

WatchGuard complies with the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information transferred from European Economic Area and Switzerland to the United States, respectively, pursuant to Privacy Shield. WatchGuard has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.

To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/.

WatchGuard is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).

WatchGuard’s participation in the Privacy Shield applies to all personal data that is subject to our Policy and is received from the European Economic Area or Switzerland. We will comply with the Privacy Shield Principles in respect of such personal data.

Third parties engaged by WatchGuard to process personal data and any of our affiliates receiving personal data must: (i) comply with the Privacy Shield principles or another mechanism permitted by the applicable EU and Swiss data protection laws for transfers and processing of personal data; or (ii) agree to provide adequate protections for the personal data that are no less protective than those set out in this Policy.

We also may be required to disclose an individual’s personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.

WatchGuard has responsibility for the processing of personal information it receives and subsequently transfers to a third party. WatchGuard remains potentially liable under the Privacy Shield Principles if its agent processes such personal data in a manner inconsistent with the Principles, unless we prove that we are not responsible for the event giving rise to the damage.

In compliance with the EU-US and Swiss-US Privacy Shield Principles, WatchGuard commits to resolve complaints about your privacy and our collection or use of your personal information. European Union or Swiss individuals with inquiries or complaints regarding this Policy should first contact WatchGuard at: [email protected].

WatchGuard has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint. A binding arbitration option will also be made available to you in order to address residual complaints not resolved by any other means.

STORAGE AND RETENTION OF YOUR PERSONAL INFORMATION

We retain your personal information for as long as necessary to provide services requested by you, or for other essential purposes such as complying with our legal obligations, resolving disputes, and enforcing our agreements. Because these needs can vary for different data types in the context of different services, actual retention periods can vary significantly. The criteria used to determine retention include:

1. How long is the personal information needed to provide applicable services? This includes such things as maintaining and improving the performance of the Services, enabling system security measures, and maintaining appropriate business and financial records.

2. Do users provide, create, or maintain the data with the expectation we will retain it until they affirmatively remove it? In such cases, we may maintain the data until actively deleted by the user.

3. Is the personal information of a sensitive type? If so, a shortened retention time may be appropriate.

4. Are we subject to a legal, contractual, or similar obligation to retain the data? Examples can include mandatory data retention laws in the applicable jurisdiction, government orders to preserve data, or data that must be retained for the purposes of litigation.

YOUR INFORMATION CHOICES AND CHANGES

If you wish to ask for access, correction, or deletion of any of your personal information held by us or a change in the way we use your information (for which we reserve the right to charge you a fee, where permitted by applicable law), please contact WatchGuard Support. However, we may decline requests that are unreasonable, prohibited by law, or are not required to be honored by applicable law.

You can opt out of receiving promotional emails from WatchGuard by following the instructions in those emails. You can also manage your email contact preferences at our Subscription Center. If you opt out, we may still send you non-promotional emails, such as emails about your accounts or our ongoing business relations. You can also send requests about changes to your information or your contact preferences, including requests to opt-out of sharing your personal information with third parties, by emailing: [email protected].

Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to remove cookies from within your browser, or set your browser to block all cookies, all third-party cookies, or particular cookies. If you choose to remove or block cookies, this can disable or otherwise affect certain features or services of our websites.

There are web browser signals and other mechanisms (for example, “Do Not Track” settings) that can indicate your choice to disable tracking, and, while we and others give you choices described in this Policy, we do not currently honor these mechanisms.

YOUR EUROPEAN PRIVACY RIGHTS

We adhere to applicable data protection laws in the European Economic Area, which, if applicable to you, includes the following rights:

• If we are processing personal information based on your consent, you have a right to withdraw consent at any time for future processing;
• You have a right to request access to, rectification, or erasure of your personal information, or to transfer or receive a copy of your personal information in a usable format;
• You have a right to object to the processing of your personal information under certain circumstances; and
• You have a right to lodge a complaint with a data protection authority.

As applicable under French law, you can also send us specific instructions regarding the use of your personal information after your death, by contacting us at [email protected].

The legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.

We may process your personal information based on your consent such as when you ask us to send you certain kinds of marketing communications.

We may process your personal information if doing so is necessary for our legitimate interests and your rights as an individual do not override those legitimate interests. For example, when we process your personal information to carry out fraud prevention activities and activities to increase network and information security, identify usage trends, determine the effectiveness of promotional campaigns, expand our business activities and improve our services and the content and functionality of our website.

We may process your personal information to administer and fulfill contractual obligations to you.

We may process your personal information to comply with legal obligations to which we are subject. This may include any requirement to produce audited accounts, any legal obligation to share information with law enforcement agencies, public or governmental authorities, and to comply with legal process.

If you bring a claim against us or we bring a claim against you, we may process your personal information in relation to that claim.

You can read our GDPR Statement here.

NOTICE TO NEVADA RESIDENTS

Nevada law allows Nevada residents to opt-out of the sale of certain types of personal information. Subject to a number of exceptions, Nevada law defines “sale” to mean the exchange of certain types of personal information for monetary consideration to a person for the person to license or sell the information to additional persons. We do not currently sell personal information as defined in the Nevada law. However, if you are a Nevada resident, you still may submit a verified request to opt out of sales and we will record your instructions and incorporate them in the future if our policy changes. Opt-out requests can be sent to [email protected].

NOTICE TO CALIFORNIA RESIDENTS

The California Consumer Privacy Act (“CCPA”) requires that we provide California residents with a privacy policy that contains a comprehensive description of our online and offline practices regarding the collection, use, disclosure, and sale of personal information and of the rights of California residents regarding their personal information.

The CCPA defines “personal information” to mean information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Personal information does not include information that is publicly available, deidentified or aggregate information. For purposes of this “Notice to California Residents” section we will refer to this information as “Personal Information.”

Right to Know About Personal Information Collected, Disclosed, or Sold

Your Right. If you are a California resident, you have the right to request that we disclose what Personal Information we have collected about you. This right includes the right to request any or all of the following:

1. Specific pieces of Personal Information that we have collected about you;
2. Categories of Personal Information we have collected about you;
3. Categories of sources from which the Personal Information was collected;
4. Categories of Personal Information that we sold (if applicable) or disclosed for a business purpose about you;
5. Categories of third parties to whom the Personal Information was sold (if applicable) or disclosed for a business purpose; and
6. The business or commercial purpose for collecting or, if applicable, selling Personal Information.

The CCPA defines “sell” to mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a California resident’s Personal Information to another business or a third party for monetary or other valuable consideration.

How to Submit a Request to Know. You can submit a request to know by emailing us at [email protected] or by calling us at 1-877-232-3531.

Our Process for Verifying a Request to Know. We will comply with your request upon verification of your identity and, to the extent applicable, the identity of the California resident on whose behalf you are making such request. Our verification process may differ depending on whether you maintain a password-protected account with us.

If you maintain a password-protected account, we may verify your identity through existing authentication practices available through your account. Prior to disclosing the requested information, we will ask you to re-authenticate yourself with respect to that account.

If you do not maintain a password-protected account, or if you are an account-holder but we suspect fraudulent or malicious activity with your account, we will verify your identity as follows:

Request to Know Categories of Personal Information. We will verify your identity to a “reasonable degree of certainty” by verifying at least two data points that you previously provided to us and which we have determined to be reliable for the purpose of verifying identities.  

Request to Know Specific Pieces of Personal Information. We will verify your identity to a “reasonably high degree of certainty” by verifying at least three pieces of Personal Information previously provided to us and which we have determined to be reliable the purpose of verifying identities. In addition, you will be required to submit a signed declaration under penalty of perjury stating that you are the individual whose Personally Identifiable Information is being requested.

Collection of Personal Information. The following table presents the categories of Personal Information that we have collected, the categories of sources from which that information was collected, and the categories of third parties with whom we shared that Personal Information for the 12 months preceding the Effective Date of this Policy.

The CCPA defines “business purposes” to mean:

1. Auditing related to a current interaction with the consumer and concurrent transaction, including, but not limited to, counting ad impressions to unique visitors;
2. Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;
3. Debugging to identify and repair errors that impair existing intended functionality;
4. Short-term, transient use, provided that the personal information is not disclosed to another third party and is not used to build a profile about a consumer or otherwise alter an individual consumer’s experience outside the current interaction, including, but not limited to, the contextual customization of ads shown as part of the same interaction;
5. Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services;
6. Undertaking internal research for technological development and demonstration; and
7. Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device.

The CCPA defines “commercial purposes” to mean “to advance a person’s commercial or economic interests, such as by inducing another person to buy, rent, lease, join, subscribe to, provide, or exchange products, goods, property, information, or services, or enabling or effecting, directly or indirectly, a commercial transaction.”

For purposes of the below chart, we will refer to the business purposes by their above numbers and use the number 8 to reference the definition of commercial purposes.

Disclosure or Sale of Personal Information.

The following is a list of categories of Personal Information that we have sold to third parties in the 12 months preceding the Effective Date of this Privacy Policy:

• Cookies, beacons, pixel tags, mobile ad identifiers, or other similar technology
• Internet or other electronic network activity, including but not limited browsing history, search history, and information regarding a consumer’s interaction with an internet website, application, or advertisement
• Geolocation data

The following is a list of categories of Personal Information that we have disclosed for a business purpose in the 12 months preceding the Effective Date of this Privacy Policy:

• Name
• Email address
• Postal address
• Telephone number
• Driver’s license number; other type of state identification card number
• Social security number
• Credit and debit card number; other financial information (financial account number)
• Geolocation data
• Internet Protocol address
• Customer number, unique pseudonym or user alias (e.g., user name)
• Cookies, beacons, pixel tags, mobile ad identifiers, or other similar technology
• Internet or other electronic network activity, including but not limited browsing history, search history, and information regarding a consumer’s interaction with an internet website, application, or advertisement
• Records of products or services purchased, obtained or considered
• Medical information
• Imagery of the face (photographs)
• Biometric data

We do not sell the Personal Information of minors under 16 years of age without affirmative authorization.

Right to Request Deletion of Personal Information

Your Right. If you are a California resident, you have the right to request that we delete the Personal Information about you that we have collected or maintain. However, a business is not required to comply with a request to delete if it is necessary for the business to maintain the Personal Information in order to, for example, complete a transaction, detect security incidents, comply with a legal obligation, or otherwise use the Personal Information, internally, in a lawful manner that is compatible with the context in which the consumer provided the information.

How to Submit a Request to Delete. You can submit a request to know by emailing us at [email protected] or by calling us at 1-877-232-3531.

If you submit a request to delete online, you will be asked to confirm separately that you want your Personal Information deleted.

Our Process for Verifying a Request. We will comply with your request upon verification of your identity and, to the extent applicable, the identity of the California resident on whose behalf you are making such request. Our verification process may differ depending on whether you maintain a password-protected account with us. 

If you maintain a password-protected account, we may verify your identity through existing authentication practices available through your account. Prior to deleting the Personal Information, we will ask you to re-authenticate yourself with respect to that account.

If you do not maintain a password-protected account, or if you are an account-holder but we suspect fraudulent or malicious activity with your account, we will verify your identity either to a “reasonable degree of certainty” or a “reasonably high degree of certainty” depending on the sensitivity of the Personal Information and the risk of harm to you by unauthorized deletion.

We will verify your identity to a “reasonable degree of certainty” by verifying at least two data points that you previously provided to us and which we have determined to be reliable for the purpose of verifying identities.

We will verify your identity to a “reasonably high degree of certainty” by verifying at least three pieces of Personal Information previously provided to us and which we have determined to be reliable the purpose of verifying identities. In addition, you will be required to submit a signed declaration under penalty of perjury stating that you are the individual whose Personal Information is being requested.

If we are unable to verify your identity to the applicable standard, we will treat your request to delete as a request to opt-out of the sale of the personal information that you provided as part of processing the request to delete. See the following section for a description of the right to opt-out of the sale of personal information.

Notice of Right to Opt-Out of Sale of Personal Information

Your Right. If you are a California resident, you have the right to direct a business that sells (or may in the future sell) your Personal Information to stop selling your Personal Information and to refrain from doing so in the future.

The CCPA defines “sell” to mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a California resident’s Personal Information to another business or a third party for monetary or other valuable consideration.

We do not and will not sell Personal Information as it is defined in the CCPA.

Right to Non-Discrimination for the Exercise of a California Resident’s Privacy Rights

We will not discriminate against California residents if they exercise any of the rights provided in the CCPA as described in this section “Notice to California Residents.” As such, we will not deny goods or services to that California resident; charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; provide a different level or quality of goods or services to the California resident; or suggest that the California resident will receive a different price or rate for goods or services or a different level or quality of goods or services. However, we are permitted to charge a California resident a different price or rate, or provide a different level or quality of goods or services, if that difference is reasonably related to the value provided to us by the individual’s data.

Authorized Agents

California residents may use an authorized agent to submit a request to know or delete on your behalf.

If you use an authorized agent to submit a request to know or request to delete, we may require that (1) the authorized agent provide proof of your written permission and (2) you verify your identity directly with us. These requirements do not apply if you have provided the authorized agent with a power of attorney pursuant to California Probate Code §§ 4000 to 4465.

Shine the Light Law

If you are a California resident, California Civil Code § 1798.83 permits you to request information regarding the disclosure of your personal information by us to third parties for the third-parties’ direct marketing purposes (as those terms are defined in that statute).  To make such a request, please send an email to [email protected] or write us.

ACCESSIBILITY

We are committed to ensuring this Privacy Policy is accessible to individuals with disabilities. If you wish to access this Privacy Policy in an alternative format, please contact us as described below.

CHANGES TO THIS POLICY

WatchGuard may change this Policy from time to time. If we make any changes to this Policy, we will post an amended version and change the “Last Updated” date above. Please review this Policy periodically. Your continued use of our websites and Services after any such amendment signifies your acceptance thereof.

HOW TO CONTACT US

If you have any questions about this Policy, or if you wish to lodge a complaint about our privacy practices, please email: [email protected].