This table includes certain details of the Processing of Customer’s Personal Data as required by Article 28(3) GDPR (or as applicable, equivalent provisions of any other Data Protection Law).
Product
Data Subjects
Categories of Personal Data Processed
Processing Operations
Retention Period
Browser, E-mail Isolation and TAP URL Isolation
Employees and contractors.
E-mail addresses, user site cookies, and browser history, and browser registration information (data center location, browser user-agent string).
Isolation is a remote, web-based browser that protects against URL threats by stripping all active content from requested sites and rendering a safe version of the page back to the end user. Isolation policies determine what users and URLs are isolated and what content and user actions are allowed in Isolation.
Up to 365 days after collection.
CAD/CASB
Employees, contractors.
Cloud account holder metadata (e-mail addresses, names, position), file metadata and cloud account access logs.
Cloud Account Defense helps Customer detect suspicious activities around Customer’s cloud accounts and identify compromised cloud accounts.
Cloud App Security Broker uses policies to prevent the loss of Customer’s sensitive or confidential data contained in Customer’s cloud accounts. CASB IaaS Protection helps customer identify its IaaS resources, protect sensitive data within IaaS storage, and monitor and stop unauthorized logins to Customer’s Cloud accounts.
Up to 180 days from the end of Controller’s subscription maximum except for Threat Analytics, which is retained for up to 18 months after collection.
Cloudmark Active Filter, Authority, Content Categories, Insight Server, and Sender Intelligence; Cloudmark Spam Reporting Service
Employees, contractors, customers.
Telemetry data associated with E-mail, SMS, MMS, and RCS, including email addresses, IP addresses, phone numbers.
Cloudmark products leverage intelligent threat analysis to provide email and mobile messaging security against spam and malware.
30 days for messages reported by recipient as potentially harmful.
30 days for messages reported by recipient as not harmful.
Cloudmark Safe Messaging Cloud, Cloudmark Safe Messaging Cloud Hybrid
Employees, contractors, customers.
Telemetry data associated with E-mail, SMS, MMS, and RCS, including email addresses, IP addresses, phone numbers.
Cloudmark products leverage intelligent threat analysis to provide email and mobile messaging security against spam and malware.
30 days for messages reported by recipient as potentially harmful.
30 days for messages reported by recipient as not harmful.
Otherwise as negotiated by Controller.
Continuity
Employees, contractors, and any other individuals sending or receiving e-mails via Controller’s corporate e-mail system.
Any Personal Data included in an e-mail.
Continuity provides temporary storage of Customer inbound and outbound email within the on-demand, Web-based email. Continuity serves only as a secondary, emergency failover option in the event of failure of Customer’s email service, and not as a primary email archive solution or a primary failover solution.
Messages expire after 30 days.
Digital Discover, Digital Protection, and Digital Compliance
Employees, contractors, customers, or any other individuals posting to Customer’s social media accounts.
Corporate social media user account IDs, social media content, and option biographical information if included in corporate users’ account profile.
Scanning of social media platforms to find accounts affiliated with a customer for fake, fraudulent, and defamatory accounts related to the customer.
Analysis of static and interactive content. Connectors to the Archive service of social media as required for compliance.
Up to 90 days from the end of Controller’s subscription, maximum.
Email Data Loss Prevention (DLP)
Employees, contractors, and any other individuals sending or receiving e-mails via Customer’s corporate e-mail system.
Any Personal Data included in an e-mail.
Email DLP utilizes policies to prevent the loss of Customer’s sensitive or confidential data through email.
Up to 366 days after collection except for Threat Analytics, which are retained for up to 18 months after collection.
Email Encryption
Employees, contractors, customers and any other individual sending or receiving e-mails via Customer’s corporate e-mail system.
Any Personal Data included in an e-mail.
Email Encryption provides a fully integrated message encryption and decryption solution.
Encrypted message content is retained as determined by the Controller (up to 366 days).
Email Fraud Defense (EFD)
Employees, contractors, customers and any other individual sending or receiving e-mails via Customer’s corporate e-mail system.
Email hdr information, including email addresses, IP addresses, sender and recipient names.
EFD processes Domain-based Message Authentication, Reporting & Conformance (DMARC) aggregate reports and DMARC forensic message sample traffic for customer domains and evaluates the authenticity of senders based on sender authentication information, and to highlight traffic sent from unauthenticated and unauthorized sources.
Cloudmark forensic data is retained for 30 days after collection.
DMARC forensic data is retained for 90 days after collection.
Email Protection
Employees, contractors, and any other individuals sending or receiving e-mails via Controller’s corporate e-mail system.
Any Personal Data included in an e-mail.
Email Protection includes functions such as spam detection functions to identify and classify spam messages; virus protection functions to detect and filter messages containing known viruses; zero-hour anti-virus functions to detect and filter messages containing suspicious content; a quarantine folder to analysis and disposition of suspicious content.
Up to 30 days after collection except for Threat Analytics, which are retained for up to 18 months after collection.
Endpoint Data Loss Protection (Endpoint DLP)
Employees, contractors.
Email address, device identifier such as IP address, user information such as name and user ID, website information such as URL and page name, Application information such as application name, executable name, and window title.
Endpoint Data Loss Prevention deploys an endpoint agent onto designated laptop, desktop and server devices owned or controlled by data controller. These Agents capture metadata recorded from the activities of licensed Users and the telemetry and screen capture data is stored on Proofpoint’s multi-tenant Information and Cloud Security storage.
As in accordance with Controller’s selected retention period up to a maximum period of 366 days.
Essentials
Employees, contractors, customers.
Any Personal Data included in an e-mail.
- Scanning, filtering, and routing in transit of e-mails sent to and received from parties external to the customer, via the customer’s corporate e-mail system.
- If archive functionality is used, then see "Archive" above.
- If TAP sandboxing is used, see TAP below.
Up to 30 days after collection except for Threat Analytics, which are retained for up to 18 months after collection.
Insider Threat Management SaaS
Employees, contractors:
- ITM SaaS Administrators or analysts, using the web portal.
- Endpoint users, using data exporter’s endpoints on which the ITM SaaS agent has been installed.
Email address, device identifier such as IP address, user information such as name and user ID, website information such as URL and page name, Application information such as application name, executable name, and window title. Additionally, ITM has the capability to capture screen content, which is configured and controlled by the customer. Screen capture could include any additional personal data displayed on the user’s screen.
ITM deploys an endpoint agent onto designated laptop, desktop and server devices owned or controlled by data controller. The agents collect telemetry data about the activities of the device users, the data subjects. If enabled by data controller the agents can also capture screenshots of the users’ device activities. Customer solely determines whether to enable the screen capture capabilities, and the data retention period of such content. The telemetry and screen capture data is stored on Proofpoint’s multi-tenant ITM SaaS storage.
As In accordance with Controller’s selected retention period up to a maximum period of 366 days.
Internal Mail Defense (IMD)
Employees, contractors.
Any Personal Data included in an e-mail.
IMD leverages Email Protection and TAP features to protect Customer’s internal email communications against spam and malicious content.
Up to 30 days after collection except for Threat Analytics, which are retained for up to 18 months after collection.
Nexus People Risk Explorer
Employees, contractors.
Names, e-mail addresses, any Personal Data contained in Threat Analytics.
Proofpoint Nexus People Risk Explorer leverages people centric security data from Proofpoint’s Targeted Attack Protection, Security Awareness Training, Cloud Account Defense and Cloud Account Security Broker to provide insights into the types, severity and frequency of threats targeted at Customer and its employees.
Up to 90 days from the end of Controller’s subscription, maximum.
Anti-Phishing Suite: includes PhishAlarm and PhishAlarmAnalyzer:
Employees, contractors.
Name, e-mail address, any Personal Data included in an e-mail.
Routing and scanning suspicious emails reported by the end users with the PhishAlarm button. PhishAlarm Analyzer delivers highly responsive identification of phishing attacks in real time. Emails reported via PhishAlarm & PhishAlarm Analyzer are accessed and categorized and they are immediately available to Customer’s response teams.
Up to 30 days from the end of Controller’s subscription maximum; with the exception of Threat Analytics, which are retained for up to 18 months after collection.
Proofpoint Archive (previously, Enterprise Archive)
Employees, contractors, and customers.
Any Personal Data included in captured content (including e-mails, instant messages, social media content, associated message telemetry and attachments).
Archive is a cloud-based archiving solution designed for legal discovery, regulatory compliance and data access for Customer’s end users, and it provides a central, searchable repository that supports a wide range of content types.
As determined by the Controller.
Proofpoint Automate (previously, NexusAI for Compliance)
Employees, contractors, and customers.
Any personal data included in captured content (including e-mails, instant messages, social media content, associated message telemetry and attachments).
NexusAI for Compliance uses machine learning to evaluate supported archived messages (such as email, social media, collaboration platforms, and mobile messages) flagged for Customer’s review by Proofpoint’s Supervision (previously Intelligent Supervision) product.
Up to 24 hours from the end of Controller’s subscription, maximum.
Proofpoint Capture (previously, Content Capture)
Employees, contractors and customers.
Any personal data included in captured content (including e-mails, instant messages, social media content, associated message telemetry and attachments.
Content Capture captures content from supported messaging and Cloud storage platforms and delivers it compliance services such as e-discovery, archive and supervision.
Up to 90 days from the end of Controller’s subscription, maximum.
Proofpoint Patrol (previously, Content Patrol)
Employees, contractors and customers.
Any personal data included in captured content (including e-mails, instant messages, social media content, associated message telemetry and attachments.
Content Capture captures content from supported messaging and Cloud storage platforms and delivers it compliance services such as e-discovery, archive and supervision.
Up to 90 days from the end of Controller’s subscription, maximum.
Proofpoint Patrol (previously, Content Patrol)
Employees, contractors and customers.
Any personal data included in captured content (including e-mails, instant messages, social media content, associated message telemetry and attachments.
Content Patrol allows Customers to capture, monitor, remediate and generate compliance reports about their end users’ activities on Customer controlled social media accounts.
Up to 90 days from the end of Controller’s subscription, maximum.
Proofpoint Security Awareness Training (PSAT)
Employees, contractors.
Name, e-mail address, and additional data fields selected by the customer for upload to PSAT from customer’s Active Directory.
Personal data is used for the rollout of employee Cyber Security Awareness training and employee security assessments and reporting.
Up to 90 days from the end of Controller’s subscription maximum; however, during Controller’s subscription, Controller’s admins may make changes to and delete users.
Proofpoint Shadow (On-premises)
Employees, contractors, and customers.
The on-premises product processes source IPs, user names, email addresses, group membership, physical addresses for any address configured in Active Directory, employment information (e.g., start date, title) in the customer’s environment. In addition, the product processes connections to on-prem hosts (using hostnames or IPs) and external hosts (using IPs only), using various protocols like FTP, SSH, RDP, Telnet, Share (SMB), OS login.
If forensics is enabled, the product also processes file names users created, edited or removed, processes logged in users run and screenshots of users triggered incidents (by default not fetched. Fetched only if customer opted in).
An identity threat detection and response solution that stops bad actors from moving laterally through a customer’s environment by transforming endpoints into deceptions. Threat detection is accelerated by identifying the bad actor’s interaction with the endpoint deceptions.
Customers retain and store their own data pursuant to their record retention policies and/or guidelines.
Proofpoint Spotlight (On-premises)
Employees, contractors, and customers.
Employees, contractors, and customers The on-premises product processes source IPs, user names, email addresses, group membership, physical addresses for any address configured in Active Directory, employment information (e.g., start date, title) in the customer’s environment. In addition, the product processes connections to on-prem hosts (using hostnames or IPs) and external hosts (using IPs only), using various protocols like FTP, SSH, RDP, Telnet, Share (SMB), OS login.
An identity threat detection and response solution that automatically discovers, prioritizes, and remediates identity vulnerabilities in a customer’s corporate environment including structure misconfigurations in Active Directory and Azure AD, exposed credentials on customer endpoint devices, and shadow admin threats.
Customers retain and store their own data in Spotlight for up to 12 months.
Proofpoint Spotlight (SaaS)
Employees, contractors, and customers.
Source IPs, user names, email addresses, group membership, physical addresses for any address configured in Active Directory, employment information (e.g., start date, title) in the customer’s environment. In addition, the product processes connections to on-prem hosts (using hostnames or IPs) and external hosts (using IPs only), using various protocols like FTP, SSH, RDP, Telnet, Share (SMB), OS login.
An identity threat detection and response solution that automatically discovers, prioritizes, and remediates identity vulnerabilities in a customer’s corporate environment including structure misconfigurations in Active Directory and Azure AD, exposed credentials on customer endpoint devices, and shadow admin threats.
Proofpoint Spotlight (SaaS version) has not been released as a general audience offering at this time.
Proofpoint Track (previously, Compliance Gateway)
Employees, contractors and customers.
Any personal data included in captured content (including e-mails, instant messages, social media content, associated message telemetry and attachments.
Compliance Gateway acts as a central hub to filter and route message content to Customer’s archive, supervision and analytic systems.
Up to 14 days from the end of Controller’s subscription, maximum.
Secure E-Mail Relay (SER)
Employees, contractors, any recipients of bulk e-mails sent via Customer’s corporate e-mail system.
Name, e-mail address, any Personal Data included in an e-mail.
Secure Email Relay (SER) is a hosted, multi-tenant solution that puts Customer in control of applications that send email using Customer’s owned or controlled domains. It adds a layer of security to each application and distributes the email to the Internet in a DMARC-compliant fashion after Proofpoint AS/AV checks are performed. SER may only be used for delivery of emails that comply with applicable bulk or unsolicited message laws.
Up to 30 days from the end of Controller’s subscription, maximum.
SecureShare
Employees, contractors, any other individual invited to view a shared file.
Name, e-mail addresses.
SecureShare is a secure method for the sharing of files and temporary storage of such files.
Up to 180 days after collection.
Targeted Attack Protection (TAP)
Employees, contractors, customers, any other individual sending or receiving e-mails via Customer’s corporate e-mail system.
Name, e-mail address, any Personal Data included in an e-mail.
TAP identifies and protects against malicious URLs and malicious attachments in emails using a dynamic malware analysis engine.
Up to 30 days after collection except for Threat Analytics, which are retained for up to 18 months after collection.
Threat Response Auto-pull (TRAP)
Employees, contractors, customers, any other individual sending or receiving e-mails via Customer’s corporate e-mail system.
Name, e-mail address, any Personal Data included in an e-mail.
TRAP is an incident management platform that includes automation to analyze and remove unwanted emails.
Retention of closed incidents is established by Controller.
Full message MIME data purged every 30 days for closed incidents.
ThreatSimulator
Employees, contractors.
Name, e-mail address.
Personal data is used for simulated phishing campaigns. Customer may only conduct simulated phishing emails to domains owned or controlled by the Customer.
Upon customer request and within 90 days following such request.
Zero Trust Network Access (formerly Meta)
Employees, contractors.
User email address and name and (optional phone number) and intranet traffic events such as accept/drop events and DNS queries (customer has the option to enable or disable logging internet traffic events).
Meta overlays a zero-trust network on top of customer’s corporate network. Users access the corporate network by connecting to the Meta network layer through a VPN with their login credentials. Once logged into the Meta network each user is assigned a unique identity that connects to the data exporter’s underlying corporate network and access to assets within the data exporter’s corporate network is accessed based on the user’s unique identity.
Up to 90 days from the end of Controller’s subscription, maximum.
Product
Browser, E-mail Isolation and TAP URL Isolation
Data Subjects
Employees and contractors.
Categories of Personal Data Processed
E-mail addresses, user site cookies, and browser history, and browser registration information (data center location, browser user-agent string).
Processing Operations
Isolation is a remote, web-based browser that protects against URL threats by stripping all active content from requested sites and rendering a safe version of the page back to the end user. Isolation policies determine what users and URLs are isolated and what content and user actions are allowed in Isolation.
Retention Period
Up to 365 days after collection.
Product
CAD/CASB
Data Subjects
Employees, contractors.
Categories of Personal Data Processed
Cloud account holder metadata (e-mail addresses, names, position), file metadata and cloud account access logs.
Processing Operations
Cloud Account Defense helps Customer detect suspicious activities around Customer’s cloud accounts and identify compromised cloud accounts.
Cloud App Security Broker uses policies to prevent the loss of Customer’s sensitive or confidential data contained in Customer’s cloud accounts. CASB IaaS Protection helps customer identify its IaaS resources, protect sensitive data within IaaS storage, and monitor and stop unauthorized logins to Customer’s Cloud accounts.
Retention Period
Up to 180 days from the end of Controller’s subscription maximum except for Threat Analytics, which is retained for up to 18 months after collection.
Product
Cloudmark Active Filter, Authority, Content Categories, Insight Server, and Sender Intelligence; Cloudmark Spam Reporting Service
Data Subjects
Employees, contractors, customers.
Categories of Personal Data Processed
Telemetry data associated with E-mail, SMS, MMS, and RCS, including email addresses, IP addresses, phone numbers.
Processing Operations
Cloudmark products leverage intelligent threat analysis to provide email and mobile messaging security against spam and malware.
Retention Period
30 days for messages reported by recipient as potentially harmful.
30 days for messages reported by recipient as not harmful.
Product
Cloudmark Safe Messaging Cloud, Cloudmark Safe Messaging Cloud Hybrid
Data Subjects
Employees, contractors, customers.
Categories of Personal Data Processed
Telemetry data associated with E-mail, SMS, MMS, and RCS, including email addresses, IP addresses, phone numbers.
Processing Operations
Cloudmark products leverage intelligent threat analysis to provide email and mobile messaging security against spam and malware.
Retention Period
30 days for messages reported by recipient as potentially harmful.
30 days for messages reported by recipient as not harmful.
Otherwise as negotiated by Controller.
Product
Continuity
Data Subjects
Employees, contractors, and any other individuals sending or receiving e-mails via Controller’s corporate e-mail system.
Categories of Personal Data Processed
Any Personal Data included in an e-mail.
Processing Operations
Continuity provides temporary storage of Customer inbound and outbound email within the on-demand, Web-based email. Continuity serves only as a secondary, emergency failover option in the event of failure of Customer’s email service, and not as a primary email archive solution or a primary failover solution.
Retention Period
Messages expire after 30 days.
Product
Digital Discover, Digital Protection, and Digital Compliance
Data Subjects
Employees, contractors, customers, or any other individuals posting to Customer’s social media accounts.
Categories of Personal Data Processed
Corporate social media user account IDs, social media content, and option biographical information if included in corporate users’ account profile.
Processing Operations
Scanning of social media platforms to find accounts affiliated with a customer for fake, fraudulent, and defamatory accounts related to the customer.
Analysis of static and interactive content. Connectors to the Archive service of social media as required for compliance.
Retention Period
Up to 90 days from the end of Controller’s subscription, maximum.
Product
Email Data Loss Prevention (DLP)
Data Subjects
Employees, contractors, and any other individuals sending or receiving e-mails via Customer’s corporate e-mail system.
Categories of Personal Data Processed
Any Personal Data included in an e-mail.
Processing Operations
Email DLP utilizes policies to prevent the loss of Customer’s sensitive or confidential data through email.
Retention Period
Up to 366 days after collection except for Threat Analytics, which are retained for up to 18 months after collection.
Product
Email Encryption
Data Subjects
Employees, contractors, customers and any other individual sending or receiving e-mails via Customer’s corporate e-mail system.
Categories of Personal Data Processed
Any Personal Data included in an e-mail.
Processing Operations
Email Encryption provides a fully integrated message encryption and decryption solution.
Retention Period
Encrypted message content is retained as determined by the Controller (up to 366 days).
Product
Email Fraud Defense (EFD)
Data Subjects
Employees, contractors, customers and any other individual sending or receiving e-mails via Customer’s corporate e-mail system.
Categories of Personal Data Processed
Email hdr information, including email addresses, IP addresses, sender and recipient names.
Processing Operations
EFD processes Domain-based Message Authentication, Reporting & Conformance (DMARC) aggregate reports and DMARC forensic message sample traffic for customer domains and evaluates the authenticity of senders based on sender authentication information, and to highlight traffic sent from unauthenticated and unauthorized sources.
Retention Period
Cloudmark forensic data is retained for 30 days after collection.
DMARC forensic data is retained for 90 days after collection.
Product
Email Protection
Data Subjects
Employees, contractors, and any other individuals sending or receiving e-mails via Controller’s corporate e-mail system.
Categories of Personal Data Processed
Any Personal Data included in an e-mail.
Processing Operations
Email Protection includes functions such as spam detection functions to identify and classify spam messages; virus protection functions to detect and filter messages containing known viruses; zero-hour anti-virus functions to detect and filter messages containing suspicious content; a quarantine folder to analysis and disposition of suspicious content.
Retention Period
Up to 30 days after collection except for Threat Analytics, which are retained for up to 18 months after collection.
Product
Endpoint Data Loss Protection (Endpoint DLP)
Data Subjects
Employees, contractors.
Categories of Personal Data Processed
Email address, device identifier such as IP address, user information such as name and user ID, website information such as URL and page name, Application information such as application name, executable name, and window title.
Processing Operations
Endpoint Data Loss Prevention deploys an endpoint agent onto designated laptop, desktop and server devices owned or controlled by data controller. These Agents capture metadata recorded from the activities of licensed Users and the telemetry and screen capture data is stored on Proofpoint’s multi-tenant Information and Cloud Security storage.
Retention Period
As in accordance with Controller’s selected retention period up to a maximum period of 366 days.
Product
Essentials
Data Subjects
Employees, contractors, customers.
Categories of Personal Data Processed
Any Personal Data included in an e-mail.
Processing Operations
- Scanning, filtering, and routing in transit of e-mails sent to and received from parties external to the customer, via the customer’s corporate e-mail system.
- If archive functionality is used, then see "Archive" above.
- If TAP sandboxing is used, see TAP below.
Retention Period
Up to 30 days after collection except for Threat Analytics, which are retained for up to 18 months after collection.
Product
Insider Threat Management SaaS
Data Subjects
Employees, contractors:
- ITM SaaS Administrators or analysts, using the web portal.
- Endpoint users, using data exporter’s endpoints on which the ITM SaaS agent has been installed.
Categories of Personal Data Processed
Email address, device identifier such as IP address, user information such as name and user ID, website information such as URL and page name, Application information such as application name, executable name, and window title. Additionally, ITM has the capability to capture screen content, which is configured and controlled by the customer. Screen capture could include any additional personal data displayed on the user’s screen.
Processing Operations
ITM deploys an endpoint agent onto designated laptop, desktop and server devices owned or controlled by data controller. The agents collect telemetry data about the activities of the device users, the data subjects. If enabled by data controller the agents can also capture screenshots of the users’ device activities. Customer solely determines whether to enable the screen capture capabilities, and the data retention period of such content. The telemetry and screen capture data is stored on Proofpoint’s multi-tenant ITM SaaS storage.
Retention Period
As In accordance with Controller’s selected retention period up to a maximum period of 366 days.
Product
Internal Mail Defense (IMD)
Data Subjects
Employees, contractors.
Categories of Personal Data Processed
Any Personal Data included in an e-mail.
Processing Operations
IMD leverages Email Protection and TAP features to protect Customer’s internal email communications against spam and malicious content.
Retention Period
Up to 30 days after collection except for Threat Analytics, which are retained for up to 18 months after collection.
Product
Nexus People Risk Explorer
Data Subjects
Employees, contractors.
Categories of Personal Data Processed
Names, e-mail addresses, any Personal Data contained in Threat Analytics.
Processing Operations
Proofpoint Nexus People Risk Explorer leverages people centric security data from Proofpoint’s Targeted Attack Protection, Security Awareness Training, Cloud Account Defense and Cloud Account Security Broker to provide insights into the types, severity and frequency of threats targeted at Customer and its employees.
Retention Period
Up to 90 days from the end of Controller’s subscription, maximum.
Product
Anti-Phishing Suite: includes PhishAlarm and PhishAlarmAnalyzer:
Data Subjects
Employees, contractors.
Categories of Personal Data Processed
Name, e-mail address, any Personal Data included in an e-mail.
Processing Operations
Routing and scanning suspicious emails reported by the end users with the PhishAlarm button. PhishAlarm Analyzer delivers highly responsive identification of phishing attacks in real time. Emails reported via PhishAlarm & PhishAlarm Analyzer are accessed and categorized and they are immediately available to Customer’s response teams.
Retention Period
Up to 30 days from the end of Controller’s subscription maximum; with the exception of Threat Analytics, which are retained for up to 18 months after collection.
Product
Proofpoint Archive (previously, Enterprise Archive)
Data Subjects
Employees, contractors, and customers.
Categories of Personal Data Processed
Any Personal Data included in captured content (including e-mails, instant messages, social media content, associated message telemetry and attachments).
Processing Operations
Archive is a cloud-based archiving solution designed for legal discovery, regulatory compliance and data access for Customer’s end users, and it provides a central, searchable repository that supports a wide range of content types.
Retention Period
As determined by the Controller.
Product
Proofpoint Automate (previously, NexusAI for Compliance)
Data Subjects
Employees, contractors, and customers.
Categories of Personal Data Processed
Any personal data included in captured content (including e-mails, instant messages, social media content, associated message telemetry and attachments).
Processing Operations
NexusAI for Compliance uses machine learning to evaluate supported archived messages (such as email, social media, collaboration platforms, and mobile messages) flagged for Customer’s review by Proofpoint’s Supervision (previously Intelligent Supervision) product.
Retention Period
Up to 24 hours from the end of Controller’s subscription, maximum.
Product
Proofpoint Capture (previously, Content Capture)
Data Subjects
Employees, contractors and customers.
Categories of Personal Data Processed
Any personal data included in captured content (including e-mails, instant messages, social media content, associated message telemetry and attachments.
Processing Operations
Content Capture captures content from supported messaging and Cloud storage platforms and delivers it compliance services such as e-discovery, archive and supervision.
Retention Period
Up to 90 days from the end of Controller’s subscription, maximum.
Product
Proofpoint Patrol (previously, Content Patrol)
Data Subjects
Employees, contractors and customers.
Categories of Personal Data Processed
Any personal data included in captured content (including e-mails, instant messages, social media content, associated message telemetry and attachments.
Processing Operations
Content Capture captures content from supported messaging and Cloud storage platforms and delivers it compliance services such as e-discovery, archive and supervision.
Retention Period
Up to 90 days from the end of Controller’s subscription, maximum.
Product
Proofpoint Patrol (previously, Content Patrol)
Data Subjects
Employees, contractors and customers.
Categories of Personal Data Processed
Any personal data included in captured content (including e-mails, instant messages, social media content, associated message telemetry and attachments.
Processing Operations
Content Patrol allows Customers to capture, monitor, remediate and generate compliance reports about their end users’ activities on Customer controlled social media accounts.
Retention Period
Up to 90 days from the end of Controller’s subscription, maximum.
Product
Proofpoint Security Awareness Training (PSAT)
Data Subjects
Employees, contractors.
Categories of Personal Data Processed
Name, e-mail address, and additional data fields selected by the customer for upload to PSAT from customer’s Active Directory.
Processing Operations
Personal data is used for the rollout of employee Cyber Security Awareness training and employee security assessments and reporting.
Retention Period
Up to 90 days from the end of Controller’s subscription maximum; however, during Controller’s subscription, Controller’s admins may make changes to and delete users.
Product
Proofpoint Shadow (On-premises)
Data Subjects
Employees, contractors, and customers.
Categories of Personal Data Processed
The on-premises product processes source IPs, user names, email addresses, group membership, physical addresses for any address configured in Active Directory, employment information (e.g., start date, title) in the customer’s environment. In addition, the product processes connections to on-prem hosts (using hostnames or IPs) and external hosts (using IPs only), using various protocols like FTP, SSH, RDP, Telnet, Share (SMB), OS login.
If forensics is enabled, the product also processes file names users created, edited or removed, processes logged in users run and screenshots of users triggered incidents (by default not fetched. Fetched only if customer opted in).
Processing Operations
An identity threat detection and response solution that stops bad actors from moving laterally through a customer’s environment by transforming endpoints into deceptions. Threat detection is accelerated by identifying the bad actor’s interaction with the endpoint deceptions.
Retention Period
Customers retain and store their own data pursuant to their record retention policies and/or guidelines.
Product
Proofpoint Spotlight (On-premises)
Data Subjects
Employees, contractors, and customers.
Categories of Personal Data Processed
Employees, contractors, and customers The on-premises product processes source IPs, user names, email addresses, group membership, physical addresses for any address configured in Active Directory, employment information (e.g., start date, title) in the customer’s environment. In addition, the product processes connections to on-prem hosts (using hostnames or IPs) and external hosts (using IPs only), using various protocols like FTP, SSH, RDP, Telnet, Share (SMB), OS login.
Processing Operations
An identity threat detection and response solution that automatically discovers, prioritizes, and remediates identity vulnerabilities in a customer’s corporate environment including structure misconfigurations in Active Directory and Azure AD, exposed credentials on customer endpoint devices, and shadow admin threats.
Retention Period
Customers retain and store their own data in Spotlight for up to 12 months.
Product
Proofpoint Spotlight (SaaS)
Data Subjects
Employees, contractors, and customers.
Categories of Personal Data Processed
Source IPs, user names, email addresses, group membership, physical addresses for any address configured in Active Directory, employment information (e.g., start date, title) in the customer’s environment. In addition, the product processes connections to on-prem hosts (using hostnames or IPs) and external hosts (using IPs only), using various protocols like FTP, SSH, RDP, Telnet, Share (SMB), OS login.
Processing Operations
An identity threat detection and response solution that automatically discovers, prioritizes, and remediates identity vulnerabilities in a customer’s corporate environment including structure misconfigurations in Active Directory and Azure AD, exposed credentials on customer endpoint devices, and shadow admin threats.
Retention Period
Proofpoint Spotlight (SaaS version) has not been released as a general audience offering at this time.
Product
Proofpoint Track (previously, Compliance Gateway)
Data Subjects
Employees, contractors and customers.
Categories of Personal Data Processed
Any personal data included in captured content (including e-mails, instant messages, social media content, associated message telemetry and attachments.
Processing Operations
Compliance Gateway acts as a central hub to filter and route message content to Customer’s archive, supervision and analytic systems.
Retention Period
Up to 14 days from the end of Controller’s subscription, maximum.
Product
Secure E-Mail Relay (SER)
Data Subjects
Employees, contractors, any recipients of bulk e-mails sent via Customer’s corporate e-mail system.
Categories of Personal Data Processed
Name, e-mail address, any Personal Data included in an e-mail.
Processing Operations
Secure Email Relay (SER) is a hosted, multi-tenant solution that puts Customer in control of applications that send email using Customer’s owned or controlled domains. It adds a layer of security to each application and distributes the email to the Internet in a DMARC-compliant fashion after Proofpoint AS/AV checks are performed. SER may only be used for delivery of emails that comply with applicable bulk or unsolicited message laws.
Retention Period
Up to 30 days from the end of Controller’s subscription, maximum.
Product
SecureShare
Data Subjects
Employees, contractors, any other individual invited to view a shared file.
Categories of Personal Data Processed
Name, e-mail addresses.
Processing Operations
SecureShare is a secure method for the sharing of files and temporary storage of such files.
Retention Period
Up to 180 days after collection.
Product
Targeted Attack Protection (TAP)
Data Subjects
Employees, contractors, customers, any other individual sending or receiving e-mails via Customer’s corporate e-mail system.
Categories of Personal Data Processed
Name, e-mail address, any Personal Data included in an e-mail.
Processing Operations
TAP identifies and protects against malicious URLs and malicious attachments in emails using a dynamic malware analysis engine.
Retention Period
Up to 30 days after collection except for Threat Analytics, which are retained for up to 18 months after collection.
Product
Threat Response Auto-pull (TRAP)
Data Subjects
Employees, contractors, customers, any other individual sending or receiving e-mails via Customer’s corporate e-mail system.
Categories of Personal Data Processed
Name, e-mail address, any Personal Data included in an e-mail.
Processing Operations
TRAP is an incident management platform that includes automation to analyze and remove unwanted emails.
Retention Period
Retention of closed incidents is established by Controller.
Full message MIME data purged every 30 days for closed incidents.
Product
ThreatSimulator
Data Subjects
Employees, contractors.
Categories of Personal Data Processed
Name, e-mail address.
Processing Operations
Personal data is used for simulated phishing campaigns. Customer may only conduct simulated phishing emails to domains owned or controlled by the Customer.
Retention Period
Upon customer request and within 90 days following such request.
Product
Zero Trust Network Access (formerly Meta)
Data Subjects
Employees, contractors.
Categories of Personal Data Processed
User email address and name and (optional phone number) and intranet traffic events such as accept/drop events and DNS queries (customer has the option to enable or disable logging internet traffic events).
Processing Operations
Meta overlays a zero-trust network on top of customer’s corporate network. Users access the corporate network by connecting to the Meta network layer through a VPN with their login credentials. Once logged into the Meta network each user is assigned a unique identity that connects to the data exporter’s underlying corporate network and access to assets within the data exporter’s corporate network is accessed based on the user’s unique identity.
Retention Period
Up to 90 days from the end of Controller’s subscription, maximum.
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Last updated November 16, 2023.