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DPA

Effecive: May 26, 2019

IronScales Inc. ("lronScales", "we" or "our") has certified with the EU-U.S. Privacy Shield and the Swiss-U.S. Privacy Shield with respect to the Personal Data (defined below) we receive and process from our Customers (defined below) or from IronScales Ltd. ("IronScales Ltd.").
IronScales complies with the principles of the EU-U.S. Privacy Shield Framework and the Swiss­U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of Personal Data transferred to the United States. IronScales has certified to the Department of Commerce that it adheres to the Privacy Shield Principles and our Privacy Shield certification will be available here.
If there is any conflict between the terms in this notice and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.

1. DEFINITIONS.
"Customer" means a prospective, current, or former customer, or client of IronScales and/or IronScales Ltd.
"Personal Data" means any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

2. SCOPE.

IronScales's participation in the Privacy Shield applies to Personal Data subject to EU and Swiss data protection law that (i) IronScales receives from IronScales Ltd. and/or (ii) IronScales collects and/or processes directly from Customers on behalf of IronScales Ltd. IronScales acts as a processor of the Personal Data we process on behalf of the Customers.

3. PURPOSES OF DATA PROCESSINGS.

IronScales provides its Customers with an advanced anti-phishing threat protection platform, and is made available to its Customers on a software as a service (SaaS) basis (the "Service").
IronScales will only process Personal Data we receive from our Customers for the purpose of providing the Service to the respective Customer. In order to fulfill this purpose, we may also process Personal Data to correct and address technical or service problems, to follow instructions of our Customers who submitted the Personal Data, or in response to contractual requirements, to comply with applicable laws, regulations and orders from public authorities or courts, to exercise or defense of legal claims (whether in court proceedings or in an administrative or out-of-court procedures) or to respond to contractual requirements.

OFFICE 365 ATP IS
NOT BUILT TO DEFEND
AGAINST MODERN
REAL-WORLD EMAIL THREATS.