Last edit: June 16, 2022
Martini Security, LLC (“Martini Security”,” “we” or “us”) are committed to protecting the privacy of its Website visitors (“you”) and customers (“you” or “customer”) and employees or agents of customers (“you” or “Individuals”). As a result, Martini Security has promulgated this privacy notice to inform its Website visitors, customers and Individuals about how Martini Security will collect, use, share or otherwise process any personal data or usage information.
This privacy notice applies to all sites owned and operated by Martini Security (collectively, “Websites,” individually referred to as a “Website,” meaning each and every Website owned and operated by Martini Security). This privacy notice also applies to Martini Security’s provision of certificate services and all dealings with natural-person representatives of our customers (the “Validation Services” or “certificates”).
Martini Security is a company established in the United States with principal offices at 100 S KING ST, STE 100-1006 Seattle, WA 98104-2885 and for the purpose of the EU General Data Protection Regulation (“GDPR”) and any other applicable data privacy laws, we are the data controller of personal information obtained through our Website. We are also a data controller in relation to the Individuals’ personal information that we receive from customers, either directly or through resellers.
If you have any concerns or questions regarding the personal data we process through our Website or through providing services to our customers, you may contact Martini Security’s Data Privacy Officer.
Information we receive:
Through our Website: Martini Security collects information such as the name, organization, and email address of Website visitors and customers who voluntarily submit that information via our Website, email, by creating an account or otherwise, in order to download software or to submit sales or technical support questions.
From customers: customers request certificates through their account on Martini Security’s Website (the “Account”) or through other contacts with Martini Security or its resellers.
When submitting a request, customers typically provide to Martini Security the following information about Individuals: name, email address, telephone number, address, government-issued identification (which may include additional information, depending on the identification used) and FRN/CORES ID. Specific information about personal data required for particular Martini Security services and products may be found in Martini Security’s Certification Practices Statement.
Where customers share personal information of Individuals with Martini Security, customers represent that they have collected and processed such information in accordance with data privacy laws, and that they have duly informed the Individuals that their personal information was provided to Martini Security. Martini Security will process such information following customer instructions as well as according to the industry standards that govern the issuance of digital certificates (“Industry Standards”). More information on the Industry Standards may be found through consulting Martini Security’s Certification Practices Statement.
Use of Information
We will use your information to:
Provide products and services including sales & support: As it is in our legitimate interest to market, sell, and provide our products and services, send order confirmations, respond to customer service requests, provide chat services with sales questions and technical support needs, and fulfill your order, including using the information to verify the identity of the customer or to contact the customer in order to discuss support, renewal, and the purchase of products and services.
Marketing: We will use your information as it is in our legitimate interests to send out promotional emails (subject to seek your consent where required by applicable law). These emails include beacons that communicate information about the email back to Martini Security, as further set out in Cookie Settings Such tracking allows Martini Security to gauge the effectiveness of its advertising and marketing campaigns.
Recipients can opt-out of receiving promotional communications from Martini Security by following the unsubscribe instructions provided in each email or by emailing [email protected].
Martini Security may use third parties, with which it has a confidentiality agreement, to send promotional emails on our behalf. However, Martini Security does not permit any third party to use customer information provided by Martini Security or obtained on Martini Security’s behalf for any other purpose. Anyone receiving an unsolicited email related to Martini Security’s products and services should forward the entire message and headers to [email protected].
Validation Services: Martini Security uses information provided by customers to perform Validation Services, in accordance with Industry Standards. Martini Security uses this information as follows: (1) to perform our contracts with customers that are natural persons; (2) based on the legitimate interest of Martini Security to provide services to customers that are legal entities; and (3) based on the legitimate interest of customers to have Martini Security issue certificates.
Please refer to Martini Security’s Certification Practices Statement for details on the terms, conditions, policies, and standards regarding the request and issuance of certificates.
Advisory emails: While a customer account is active, Martini Security will send advisory e-mails to customers to provide support and security updates in relation to our products and services, as this is necessary for the performance of our contracts with customers. Advisory emails are used to respond to inquiries, provide support and validation services, provide upgrade information and security updates, inform customers about expiring certificates, and inform the customer about ordered products and services. Because advisory emails contain essential information related to the use and security of Martini Security’s products and services, customers are not able to unsubscribe from advisory service emails while their customer account is active. Martini Security may also use third-party service providers to assist in sending these communications, subject to the same restrictions as mentioned in the “Marketing” subheading, above.
Technical usage information: As it is in our legitimate interests to ensure the proper functioning of our Website by personalizing its use, monitoring usage activity and trends, and keeping the Website safe and secure, when you visit the Website, we collect the information sent to us by your computer, mobile phone, or other access device. This information includes: your IP address; device information including, but not limited to, identifier, name, and type of operating system; mobile network information; and standard web information, such as your browser type and the pages you access on our Website.
Analytics: It is in our legitimate interest to analyze the information provided by our customers to track sales, demographics, product usage, and related analytics so that we can improve our product offerings and target marketing and sales resources. We create reports and data analyses that are reported internally and occasionally shared with third-party service providers, who are under a duty of strict confidentiality and who are not authorized to use the information provided by us for any other purpose than to provide services as directed by us.
Cookies & Tracking Technologies
Sharing with Third Parties
Martini Security will publicly disclose information embedded in an issued Certificate as necessary to provide the services contracted by the customer, in accordance with Industry Standards. See our Certification Practices Statement for information specific to the various services and products offered by Martini Security.
When performing its services, Martini Security uses third-party sources to confirm or supplement the information that it obtains from a customer, including information about Individuals. Martini Security uses such information from third-party sources exclusively for the purposes of its Validation Services, based on the legitimate interests of Martini Security and of the customer to provide services and have a Certificate issued.
Martini Security never sells or provides personal information to third parties for uses apart from assisting Martini Security in servicing our customers and Website visitors. We will share your personal information with third parties including these categories of recipients:
IT service providers that provide us with SaaS services including customer relationship management and other database and application software;
Marketing providers, advertisers, and advertising networks that require the data to send you advertisements about our products and select and serve relevant advertisements to you and others;
Analytics and search engine providers that assist us in the improvement and optimization of the Website;
Chat-based support software services that allow users to input information, including an email address, to request support and clarify their problem; and
Credit card and payment providers that help process payments for us (note that we do not store any provided credit card information).
Martini Security will share your information with law enforcement agencies, public authorities or other organizations if legally required to do so, including to meet national security or law enforcement requirements, or if we have a good faith belief that such use is reasonably necessary to:
comply with a legal obligation, process or request;
enforce our terms and conditions and other agreements, including investigation of any potential violation thereof;
detect, prevent or otherwise address security, fraud or technical issues; or
protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law.
Martini Security will also disclose your information to third parties:
in the event that we sell any business or assets, in which case we will disclose your data to the prospective buyer of such business or assets; or
if we or substantially all of our assets are acquired by a third party, in which case information held by us about our users will be one of the transferred assets.
If you choose to use our referral service to tell a friend about our Website, we will ask you for your friend’s name and email address. We will automatically send your friend a one-time email inviting them to visit the site. Martini Security collects this information for the sole purpose of sending this one-time email and tracking the success of the referral program.
If you believe that one of your contacts has provided Martini Security with your personal information, you may contact us at [email protected] to request that we remove this information from our database.
Our Website offers publicly accessible blogs or community forums. Any information you provide in these areas can be read, collected, and used by others who access them.
To request removal or your personal information from our blog or community forums, please contact us at [email protected]. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why, as well as additional contact information when applicable.
Social Media Widgets
The Website includes social media features, such as a Facebook “Like” button and widgets, as well as share buttons or interactive mini-programs. These features collect the user’s IP address, the pages visited on the Website and set cookies to enable the features to function properly. Social media features are either hosted by a third party or hosted directly on the Website. Interactions with these features are governed by the privacy notice of the corresponding social media company.
The security of your personal information is of the utmost importance to Martini Security. Martini Security only transmits personal information, including sensitive information (such as credit cards), using transport layer security (TLS, formerly referred to as secure sockets layer or SSL).
Unfortunately, no method of transmission over the Internet or electronic storage is 100% secure. While Martini Security strives to use commercially acceptable standards to protect personal information, Martini Security cannot guarantee absolute security. If you have any questions about the security of your personal information, please contact us at [email protected].
We take all necessary security and legal precautions to ensure the safety and integrity of the Individuals’ personal data that we receive from customers, including, as appropriate, (i) the pseudonymization of personal data; (ii) ensuring the ongoing confidentiality, integrity, availability, and resilience of processing systems and services; (iii) restoring the availability and access to personal data in a timely manner in the event of a physical or technical incident; and (iv) regularly testing, assessing, and evaluating the effectiveness of technical and organizational measures for ensuring the security of the processing.
Where We Store Your Data
Martini Security is based in the United States and our Website is hosted in the United States. Therefore, if you are located outside the United States, the information that you submit to us through our Website will be transferred to the United States.
Where you have a question, dispute, or complaint regarding Martini Security’s collection, storage, or use of your personal information, you may ask a question or make a complaint to Martini Security by sending it to [email protected].
Individual Rights over Personal Information
Generally, a customer or Individual can review, delete inaccuracies, and update personal information through their Martini Security account interface by accessing and editing their Account Profile through the Martini Security service platform they are using. Information and help in accessing and editing the Account Profile can be obtained by contacting Martini Security Support at [email protected] or through the phone numbers provided below.
In certain circumstances and where legally available or required in your jurisdiction, Individuals also have the following rights:
Access and portability: You have the right to know whether we process personal data about you, and if we do, to access data we hold about you and certain information about how we use it and who we share it with.
Correction, erasure, and restriction of processing: You have the right to require us to correct any personal data held about you that is inaccurate and have incomplete data completed or ask us to delete data (i) where you believe it is no longer necessary for us to hold the personal data; (ii) where we are processing your data on the basis of our legitimate interest and you object to such processing; or (iii) if you believe the personal data we hold about you is being unlawfully processed by us. You can ask us to restrict processing data we hold about you other than for storage purposes if you believe the personal data is not accurate (whilst we verify accuracy); where we want to erase the personal data as the processing we are doing is unlawful but you want us to continue to store; where we no longer need the personal data for the purposes of the processing but you require us to retain the data for the establishment, exercise or defense of legal claims or where you have objected to us processing personal data and we are considering your objection.
Customers and Individuals cannot edit a Martini Security Certificate directly. In order to update information in a Certificate, including personal information, customers or Individuals must submit a change request to the appropriate data authority, such as the FCC, correct the information and request a new certificate.
Objection: You have the right to object to our processing of data about you and we will consider your request. Please contact [email protected] with details of your objection, providing us with detail as to your reasoning so that we can assess whether we have a compelling or overriding interest in continuing to process such data or whether we need to process it in relation to legal claims.
Testimonials: With prior permission from the customer, Martini Security displays personal testimonials of satisfied customers on our Website in addition to other endorsements. Customers wishing to update or delete a testimonial should contact Martini Security at [email protected].
Marketing: You have the right to ask us not to process your personal data for marketing purposes. You can exercise your right to prevent such processing at any time by contacting us at [email protected].
Complaints: In the event that you wish to make a complaint about how we process your personal data, please contact us in the first instance at [email protected] and we will endeavor to deal with your request.
You can exercise these rights by sending an email to [email protected] or by mailing Martini Security at the address listed in this notice. Before we respond to your request, we will ask you to verify your identity. Note that these rights may not apply in their entirety in your jurisdiction and are subject to the applicable law of the jurisdiction where you reside. Where the exercise of a particular data subject right is not required by law, your request will be handled on a case-by-case basis.
How Long We Store Your Data
We will retain your information as follows:
Account data and data provided for Validation Services (including to send Advisory emails): As long as the account is active, while a certificate remains unexpired, and in accordance with industry standards, which requires us to maintain the data for 7.5 to 10.5 years (depending on the type of Certificate with which the data is associated) after account cancellation or Certificate expiration. In addition, after account cancellation, we will keep this for as long as necessary to defend against legal claims, resolve disputes, or enforcing customer agreements.
Data provided and collected for marketing and web experience customization purposes: until you notify us that you no longer want us to use your information for marketing and/or web experience customization purposes, by unsubscribing from any marketing email you receive, changing your cookie preferences through consulting our Cookie Settings, or by contacting [email protected].
After we no longer have a legitimate basis for retaining your personal data, we may store your information in an aggregated and anonymized format.
Our Website includes links to third-party websites whose privacy practices may differ from those of Martini Security. If you submit personal information to any of those websites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policies of those third-party websites before you submit any information to those websites.
Changes to This Privacy Notice
If we make material changes to our information practices, we will update this privacy notice and notify interested parties (e.g., by posting a notice on our home page or by emailing affected individuals). Visitors should check the Website regularly to be aware of changes. We encourage you to periodically review this page for the latest information on our privacy practices. Revisions to the privacy notice are effective 30 calendar days after being posted, or as required by applicable law.
Please contact the Martini Security Data Privacy Officer with any questions or concerns about this privacy notice or our data collection practices:
Martini Security Data Privacy Officer
Martini Security, LLC.
Attention: Data Privacy Officer
600 1st Ave
STE 102 #2056
Seattle, WA 98104
For assistance with technical difficulties, including problems with accessing or using your customer account, please email [email protected].