Website Privacy Policy

Last Updated: December 15th, 2020

At Constella Intelligence, Inc. (“Constella”, “we”, or “us”), we take your privacy seriously. This Online Privacy Policy (the “Privacy Policy”) explains how we collect, share, use, and protect your Personal Data (defined below) when you visit or use our online service, including our website, products and services offered at constellaintelligence.com and any other online services offered by Constella and its affiliates (collectively, our “Services”).

Some Services utilize data that we collect from available open sources on the surface, social, deep, and dark webs at high pace, and that we place into one or more of our proprietary databases (collectively, the “Datalake”). Data that we collect from such sources may or may not include your Personal Data. Any data that we ultimately place into the Datalake from these available open sources on the Internet is independent of your interactions with our Services.  Simply put, we have no control over whether the Datalake contains your Personal Data.  Our collection, use, processing, and protection of such data collected from the Internet are separately governed by the Datalake Privacy Notice. Please review the Datalake Privacy Notice for more information. The Datalake Privacy Notice supplements (and does not supersede) this Privacy Policy; however, in the event of any conflict between the Datalake Privacy Notice and this Privacy Policy, the Datalake Privacy Notice shall prevail with respect to any data (including Personal Data contained therein) collected by us from the Internet for the Datalake.

Please read this Privacy Policy to learn how we treat your personal information collected when you access or use our Services. By using or accessing our Services in any manner, you acknowledge that you accept the practices and policies outlined below, and you hereby consent that we will collect, use and share your information as described in this Privacy Policy.

Remember that your use of the Services is at all times subject to our Terms of Use, which incorporates this Privacy Policy and the Datalake Privacy Notice. Any terms we use in this Privacy Policy without defining them have the definitions given to them in the Terms of Use.

You may print a copy of this Privacy Policy by clicking here. If you have a disability, you may access this Privacy Policy in an alternative format by contacting privacy@constellaintelligence.com.

1. What this Privacy Policy Covers

This Privacy Policy covers how we treat Personal Data that we gather when you access or use our Services. “Personal Data” means any information that identifies or relates to a particular individual and also includes information referred to as “personally identifiable information” or “personal information” under applicable data privacy laws, rules or regulations. As noted above, this Privacy Policy doesn’t cover our practice of collecting data from available open sources on the Internet and any Personal Data that may be contained in such data. Please refer to our Datalake Privacy Notice for more information. Also, this Privacy Policy does not cover the practices of companies we don’t own or control, or people we don’t manage.

1. Categories of Personal Data We Collect

This section details the categories of Personal Data that we collect and have collected over the past 12 months:

Sources of Personal Data

We collect Personal Data about you from the following categories of sources:

• You:
  • When you provide such information directly to us (see the subsection titled “Information You Provide to Us” below).
  • When Personal Data about you is automatically collected in connection with your use of our Services (see the subsection titled “Information Collected Automatically” below).
• Third Parties:
  • Third parties may provide us with Personal Data about you. Third parties that share your Personal Data with us include:
    • Clients. We may receive information about you from some of our enterprise clients who purchase our Services, in order to assist those clients in offering identity theft protection, account monitoring, and other protection services to you.
    • Service providers. For example, we may use analytics service providers to analyze how you interact and engage with the Services, or third parties may help us to provide you with customer support.

Information You Provide to Us:

We receive and store any information that you provide to us.  For example, through the registration process and/or through your account settings, we may collect information such as your first name, last name, email address, phone number, and your company name, and your title. Certain information may be required to register with us, schedule a demo, contact us, or take advantage of portions of the Services or some of our features.

Information Collected Automatically

The Services use cookies and similar technologies such as pixel tags, web beacons, clear GIFs, and JavaScript (collectively, “Cookies”) to enable our servers to recognize your web browser and tell us how and when you visit and use our Services, to analyze trends, to learn about our user base and to operate and improve our Services. Cookies are small pieces of data – usually text files – placed on your computer, tablet, phone, or similar device when you use that device to access our Services. We may also supplement the information we collect from you with information received from third parties, including third parties that have placed their own Cookies on your device(s). Please note that because of our use of Cookies, the Services do not support “Do Not Track” requests sent from a browser at this time.

We use the following types of Cookies:   

• Essential Cookies. Essential Cookies are required for providing you with features or services that you have requested. For example, certain Cookies enable you to log into secure areas of our Services. Disabling these Cookies may make certain features and services unavailable.
• Functional Cookies. Functional Cookies are used to record your choices and settings regarding our Services, maintain your preferences over time and recognize you when you return to our Services. These Cookies help us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
• Performance/Analytical Cookies. Performance/Analytical Cookies allow us to understand how visitors use our Services such as by collecting information about the number of visitors to the Services, what pages visitors view on our Services and how long visitors are viewing pages on the Services. Performance/Analytical Cookies also help us measure the performance of our advertising campaigns in order to help us improve our campaigns and the Services’ content for those who engage with our advertising. For example, Google Inc. (“Google”) uses cookies in connection with its Google Analytics services. Google’s ability to use and share information collected by Google Analytics about your visits to the Services is subject to the Google Analytics Terms of Use and the Google Privacy Policy. You have the option to opt-out of Google’s use of Cookies by visiting the Google advertising opt-out page at www.google.com/privacy_ads.html or the Google Analytics Opt-out Browser Add-on at https://tools.google.com/dlpage/gaoptout/.

You can decide whether or not to accept Cookies through your internet browser’s settings. Most browsers have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies, as well as (depending on the sophistication of your browser software) allow you to decide on acceptance of each new Cookie in a variety of ways. You can also delete all Cookies that are already on your device. If you do this, however, you may have to manually adjust some preferences every time you visit our website, and some of the Services and functionality may not work.

To explore what Cookie settings are available to you, look in the “preferences” or “options” section of your browser’s menu. To find out more information about Cookies, including information about how to manage and delete Cookies, please visit allaboutcookies.org/ or ico.org.uk/for-the-public/online/cookies/ if you are located in the European Union.

• How We Use Your Personal Data

We process Personal Data to operate, improve, understand and personalize our Services. We use Personal Data for the following purposes:

• To offer products and services that are designed to protect against or deter fraudulent, illegal or harmful actions and to assist our clients with maintaining the safety, security and integrity of their products and information relating to their customers (which may include you). Please refer to our Datalake Privacy Notice for additional details.
• To offer products and services that are designed to: (i) map and cluster online data, and enable real-time visualizations and insights into that data; (ii) help turn vast amounts of complex online data into valuable, actionable intelligence; and (iii) fully immerse users in interactive visual representations of datasets.
• To meet or fulfill the reason you provided, directly or indirectly, the information to us.
• To communicate with you about the Services, including Service announcements, updates, or offers.
• To provide support and assistance for the Services.
• To create and manage your account or other user profiles.
• To personalize website content and communications based on your preferences.
• To process orders or other transactions.
• To respond to user inquiries and fulfill user requests.
• To improve and develop the Services, including testing, research, analysis, and product development.
• To comply with our legal or contractual obligations, resolve disputes, and enforce our Terms of Use.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• For any other business purpose stated when collecting your Personal Data, or as otherwise set forth in applicable data privacy laws such as the California Consumer Privacy Act (the “CCPA”).

We will not use the Personal Data we collect for materially different, unrelated, or incompatible purposes without providing you notice.

As noted in the list above, we may communicate with you if you’ve provided us with the means to do so. For example, if you’ve given us your email address, we may send you promotional email offers or email you about your use of the Services. Also, we may receive a confirmation when you open an email from us, which helps us improve our Services. If you do not want to receive communications from us, please indicate your preference by emailing us at privacy@constellaintelligence.com.

1. How We Share Your Personal Data

Categories of Third Parties with Whom We Share Personal Data

We disclose your Personal Data as described above to the following categories of third parties:  

• Clients
  • These are our clients who purchase our Services for the purpose of detecting or deterring fraudulent, illegal, or harmful actions and to maintaining the safety, security, and integrity of their products and information relating to their individual customers (which may include you). In most cases, our clients share specific types of Personal Data about you with us in the first place, and our clients are responsible for obtaining your consent for such sharing.  Our Services process such data with the goal of determining whether there is a correlation with the data records we have in the Datalake. We only share Personal Data for this purpose according to the specific criteria of the data search or requests as instructed by our clients. For clarity, we do not compile your Personal Data to create a profile.
• Service Providers
  • These are third parties that help us provide our Services, including payment processors, security and fraud prevention providers, hosting and other technology and communications providers, analytics providers, and staff augmentation and contract personnel.
• Acquirers
  • Your Personal Data may also be transferred to a third party if we undergo a merger, acquisition, bankruptcy, or other transaction in which that third party assumes control of our business (in whole or in part).

Disclosures of Personal Data for a Business Purpose

We disclose your Personal Data to service providers and other parties for the following business purposes:

• Auditing related to a current interaction and concurrent transactions, including, but not limited to, auditing compliance with this specification and other standards.
• Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
• Mapping and clustering online data, and enabling real-time visualizations and insights into that data.
• Debugging to identify and repair errors that impair existing intended functionality.
• Short-term, transient use of Personal Data that is not used by another party to build a consumer profile or otherwise alter your consumer experience outside the current interaction.
• Performing services on our behalf, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytics services, or providing similar services on behalf of the business or service provider.
• Undertaking internal research for technological development and demonstration.
• Undertaking activities to verify or maintain the quality or safety of a service or device that we own, manufacture (or that was manufactured for us), or control.

1. Data Security and Retention

We seek to protect your Personal Data from unauthorized access, use, and disclosure using appropriate physical, technical, organizational, and administrative security measures based on the type of Personal Data and how we are processing that data. For example, the Services use industry-standard Secure Sockets Layer (SSL) technology to allow for the encryption of Personal Data in our control. You should also help protect your data by appropriately selecting and protecting your password and/or other sign-on mechanism; limiting access to your computer or device and browser, and signing off after you have finished accessing your account with any online services.

We retain Personal Data about you for as long as necessary to provide our Services. In some cases, we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes, or collect fees owed, or is otherwise permitted or required by applicable law, rule, or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personally.

1. Personal Data of Children

As noted in the Terms of Use, we do not knowingly collect or solicit Personal Data about children under 16 years of age; if you are a child under the age of 16, please do not attempt to register for or otherwise use the Services or send us any Personal Data. If we learn we have collected Personal Data from a child under 16 years of age, we will delete that information as quickly as possible. If you believe that a child under 16 years of age may have provided Personal Data to us, please contact us at privacy@constellaintelligence.com.

• California Resident Rights

If you are a California resident, you have the rights set forth in this section. Please see the “Exercising Your Rights” section below for instructions regarding how to exercise these rights. Please note that we may process Personal Data of our customers’ end users or employees in connection with our provision of certain Services to our customers. If we are processing your Personal Data as a service provider, you should contact the entity that collected your Personal Data in the first instance to address your rights with respect to such data.

If there are any conflicts between this section and any other provision of this Privacy Policy and you are a California resident, the portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following rights apply to you, please contact us at privacy@constellaintelligence.com.

For the sake of clarity, the rights set forth in this Section VII do not cover data that may be contained in the Datalake.  Please refer to our Datalake Privacy Notice for more information on your rights with respect to data that may be contained in the Datalake.

Exercising Your Rights

Please follow the instructions and requirements described below and on our websites when submitting your requests. Requests that fail to comply with any of these instructions and requirements may result in delayed or no response.

To exercise the rights described below as a California resident, you must send us a request (1) that provides sufficient information (including, without limitation, email verification) to allow us to verify that (i) you are the person about whom we have collected Personal Data, (ii) you, as the requester, are the same person as the data subject for whose information you’re requesting (or such person’s parent/guardian), (2) that describes your request in sufficient detail to allow us to understand, evaluate and respond to it, (3) that declares, under the penalty of perjury, that you’re exercising your rights under the CCPA as a California resident solely for lawful purposes, and (4) in a way that does not and would not unduly burden or otherwise abuse our data request system and/or our Services. Each request that meets all of these criteria will be considered a “Valid Request.” We may not respond to requests that do not meet these criteria. We will use commercially reasonable efforts to determine whether a request may be for harmful, fraudulent, deceptive, threatening, harassing, defamatory, obscene, or otherwise objectionable purposes, and we reserve the right not to respond to such request. We will only use Personal Data provided in a Valid Request to verify your identity and complete your request. You do not need an account to submit a Valid Request.

We will work to respond to your Valid Request within 45 days of receipt. We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive or manifestly unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request.

You may submit a Valid Request using the following methods:

• Email us at: privacy@constellaintelligence.com.
• Submit a form at this address: constellaintelligence.com/contact-us/

You may also authorize an agent (an “Authorized Agent”) to exercise your rights on your behalf. To do this, you must provide your Authorized Agent with written permission to exercise your rights on your behalf, and we may request a copy of this written permission from your Authorized Agent when they make a request on your behalf.

Access

You have the right to request certain information about our collection and use of your Personal Data over the past 12 months. In response to a Valid Request, we will provide you with the following information:

• The categories of Personal Data that you requested and we have collected about you.
• The categories of sources from which that Personal Data was collected.
• The business or commercial purpose for collecting or selling your Personal Data.
• The categories of third parties with whom we have shared your Personal Data.
• The specific pieces of Personal Data that you explicitly requested and we have collected about you.

If we have disclosed your Personal Data to any third parties for a business purpose over the past 12 months, we will identify the categories of Personal Data shared with each category of third party recipient. If we have sold your Personal Data over the past 12 months, we will identify the categories of Personal Data sold to each category of third-party recipient.

Deletion

You have the right to request that we delete the Personal Data that we have collected about you. Under the CCPA, this right is subject to certain exceptions: for example, we may need to retain your Personal Data to provide you with the Services or complete a transaction or other action you have requested. If your deletion request is subject to one of these exceptions, we may deny your deletion request.

Personal Data Sales Opt-Out and Opt-In

We will not sell your Personal Data, and have not done so over the last 12 months. To our knowledge, we do not sell the Personal Data of minors under 16 years of age.

We Will Not Discriminate Against You for Exercising Your Rights Under the CCPA

We will not discriminate against you for exercising your rights under the CCPA. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights under the CCPA. However, we may offer different tiers of our Services as allowed by applicable data privacy laws (including the CCPA) with varying prices, rates or levels of quality of the goods or services you receive related to the value of Personal Data that we receive from you.

• Other State Law Privacy Rights

California Resident Rights

Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to prevent disclosure of Personal Data to third parties for such third parties’ direct marketing purposes; in order to submit such a request, please contact us at privacy@constellaintelligence.com.

Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services that you do not wish such operators to track certain of your online activities over time and across different websites.  Our Services do not support Do Not Track requests at this time. To find out more about “Do Not Track,” you can visit www.allaboutdnt.com.

Nevada Resident Rights

If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Data to third parties who intend to license or sell that Personal Data. We do not engage in such “sale” of your Personal Data covered by this Online Privacy Policy. If you have any questions regarding your sale opt-out right as a Nevada resident, please contact us at privacy@constellaintelligence.com with the subject line “Nevada Do Not Sell Request” and provide us with your name and the email address associated with your account.

1. European Union Data Subject Rights

EU Residents

If you are a resident of the European Union (“EU”), United Kingdom, Lichtenstein, Norway or Iceland, you may have additional rights under the EU General Data Protection Regulation (the “GDPR”) with respect to your Personal Data, as outlined below.

For this section, we use the terms “Personal Data” and “processing” as they are defined in the GDPR, but “Personal Data” generally means information that can be used to individually identify a person, and “processing” generally covers actions that can be performed in connection with data such as collection, use, storage and disclosure.

If there are any conflicts between this section and any other provision of this Privacy Policy, the policy or portion that is more protective of Personal Data shall control to the extent of such conflict.  If you have any questions about this section or whether any of the following applies to you, please contact us at privacy@constellaintelligence.com. Note that we may also process Personal Data of our customers’ end users or employees in connection with our provision of certain services to customers, in which case we are the processor of Personal Data. If we are the processor of your Personal Data (i.e., not the controller), please contact the controller party in the first instance to address your rights with respect to such data.

We may need to collect and process Personal Data in order to provide requested information, provide the Services to you, or because we are legally required to do so. Regarding Personal Data that may be collected in the use of the Constella website, Constella Intelligence, Inc., will act as the data controller. You can contact us at the following address: 289 S. San Antonio Road, Suite 110, Los Altos, CA 94022. We also have a branch Sucursal en España located at C/Acanto 22, 13th floor, 28045, Madrid (Spain).  Our email address: privacy@constellaintelligence.com.

In compliance with data protection regulations, the company has appointed a Data Protection Officer (DPO). For any questions regarding data protection or this Privacy Policy, you may contact our DPO at the following email address: privacy@constellaintelligence.com.

For the sake of clarity, the rights set forth in this Section IX do not cover data that may be contained in the Datalake.  Please refer to our Datalake Privacy Notice for more information on your rights with respect to data that may be contained in the Datalake.

INFORMATION OBTAINED FROM OUR WEBSITE

We collect information from you, including Personal Data, when you fill out a form. When registering on our website, you may be asked to enter your name or e-mail address. You also may, however, visit our website anonymously.

Purposes for the processing

We will use your Personal Data for providing the different Services you may contract with us to provide, schedule a demonstration of our software, administer promotions or surveys or any other website feature, send periodic emails, and respond to other requests or questions you may raise. Your personal data will also be used for the management of the contractual relationship between us.

Lawful basis for the processing

For the processing of your Personal Data, our legal basis depends on how you interact with the Services. We may base the processing of data on other legal bases, such as our legitimate interests as a company, the fulfillment of a legal obligation, or the management of our contractual relationship.

When we send marketing communications to our clients, the legal basis for such communications shall be the client’s explicit consent.

Do we disclose any information to third parties?

Except as stated under Section IV (How We Share Your Personal Data) above, we do not disclose or otherwise transfer to outside parties your personally identifiable information. We may also release your information when said release is appropriate to comply with the law, enforce our policies or the Terms of Use, protect our rights, property, or safety, or protect the rights, property, or safety of third parties.   

Constella will only disclose your Personal Data if any of the following lawful bases occur:

Consent:

We will not share or disclose your nonpublic information except to deliver Services to you or on your behalf unless you affirmatively opt-in to such sharing.

Constella will also process your Personal Data to send to you important information regarding the Services, your account status, changes to the Terms of Use, this Privacy Policy, or any other policies, agreements, or transactions relevant to your use of the Services.

Legal requirements:

Constella may share your information without your consent if the disclosure of such information is reasonably necessary to:

• Satisfy any applicable law, regulation, legal process, or valid governmental request; or
• Detect, prevent, or otherwise address fraud, security, or technical issues.

Retention periods

We will retain your Personal Data for as long as necessary in accordance with the purpose(s) for which it was collected and in accordance with applicable law. The criteria used to determine our retention periods include:

• the length of time during which we have a relationship with you;
• whether there is a legal obligation to which we are subject; and
• whether retention is advisable in light of the legal position to which we are subject (such as that relating to applicable limitations or statutes, pending litigation, or regulatory investigations).

How can you exercise your data protection rights?

If you would like to review, correct, update, suppress, delete or otherwise limit our use of your Personal Data that has been previously provided to us, or if you would like to request an electronic copy of your Personal Data for purposes of transmitting it to another company (to the extent you have a right to data portability under applicable law), you may make a request by contacting us using the information provided in the contact section of the website. We will respond to your request in a manner consistent with applicable law.

For your protection, we may only implement requests with respect to the Personal Data associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable and consistent with applicable law. Please note that once you exercise your rights to delete your data, we will duly block your data for as long as liability can be derived in accordance with applicable law.

You can exercise your rights by sending a request to the contact address above or to the following email address: privacy@constellaintelligence.com. You must include detailed information and documentation proving your identity in order to manage your request satisfactorily. We will process your request and give you an answer within the time limits set by current legislation.

1. Changes to this Privacy Policy

We’re constantly trying to improve our Services, so we may need to change this Privacy Policy from time to time, but we will alert you to any such changes by placing a notice on our website, by sending you an email, and/or by some other means. Please note that if you’ve opted not to receive legal notice emails from us (or you haven’t provided us with your email address), those legal notices will still govern your use of the Services, and you are still responsible for reading and understanding them. If you use the Services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes. The use of information we collect is subject to the Privacy Policy in effect at the time such information is collected.

1. Contact Information:

If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your Personal Data or your choices and rights regarding such collection and use, please do not hesitate to contact us at:

• privacy@constellaintelligence.com
• Constella Intelligence, Inc., 289 S. San Antonio Road, Suite 110, Los Altos, CA 94022

If you are located in the European Union, you may use the following information to contact our Data Protection Officer and our European Union-Based Member Representative:

• Our branch office in the European Union: Sucursal en España located at C/Acanto 22, 13th floor, 28045, Madrid (Spain)
• Data Protection Officer: privacy@constellaintelligence.com.

Annual Records

Last updated: July 1, 2021

The following chart provides statistics about our responses to requests from California residents over the past calendar year: