Privacy Policy
This Privacy Policy describes how we handle and protect your personal data and the choices available to you. Additional information on our personal data practices may be provided in product settings, contractual terms, or notices provided prior to or at the time of data collection.
Please refer to our Products Policy describing specifics of personal data processing within our products and services.
Personal Data We Process
Personal data refers to any information relating to an identified or identifiable individual person (“Personal Data”).
We may collect data or ask you to provide certain data when you visit our websites, and use our products and services. The sources from which we collect Personal Data include:
- Data collected directly from you or your device relating to an identified or identifiable individual (“Data Subject”), and may include direct identifiers such as name, postal and email address, phone number, and online or indirect identifiers such as login account, login password, marketing preferences, social media account, and/or IP address;
- If we link other data with your Personal Data, we will treat that linked data as Personal Data; and
- We may also collect Personal Data from trusted third-party sources such as distributors, resellers, app stores, contact centers, and engage third parties such as marketing, survey, analytics or software suppliers to collect Personal Data to assist us.
We do not process special categories of personal data, such as data concerning health, race, ethnicity or political opinions, or deduce in any way this type of information from data, we collect within our products.
We organize the Personal Data we process into these basic categories: Billing Data, Account Data, and Product Data.
Billing Data includes your name, email address, masked credit card number, license information and in certain circumstances, your billing address and your phone number. In most circumstances, you purchase our products and services from a trusted third-party service provider, reseller, or app store. In those circumstances, your Billing Data is processed by the relevant third party and we only receive a subset of this data to keep proper business records. In these instances, see below an example of Billing Data.
Account Data includes information to set up and customize an account, such as your name, email address and username, and information connected with our services, such as product, license and device information. For some of our products or some of their functions creating an account is necessary. Account Data is also used for the customer management and engagement, revenue generation, and evaluation and optimization of operational, sales and business processes.
Why We Process Your Personal Data
We use your Personal Data for the following purposes and on the following grounds:
On the basis of fulfilling our contract with you or entering into a contract with you on your request, in order to:
- To process purchase of our products or services from us, our partners or our trusted third- party service providers’ online stores;
- To provision the download, activation, and performance of the product or service;
- To keep our products or services up-to-date, safe and free of errors, including implementation of new product features and versions;
- To verify your identity and entitlement to paid products or services, when you contact us for support or access our services;
- To process your purchase transactions;
- To update you on the status of your orders and licences;
- To manage your subscriptions and user accounts; and
- To provide you with technical and customer support. This may include remote access to your device to better solve the issue. For this purpose, we will process the information from your product and device (e.g. crash reports, usage data), your contact details as well as other information you will provide to us (e.g. description of the issue).
On the basis of your consent, in order to:
- To subscribe you to a newsletter or Anti-Hacker Project;
- To enable the provision of third-party ads in product messages;
- To enable the provision of personalized ads in support of certain free products; and
- To allow us to record our phone conversation when you contact our tech support by phone.
We will always ask for your consent before any processing which requires it and we will provide you with necessary information through our Consent Policy or otherwise as applicable.
In order to fulfill legal obligations, we process your Personal Data when it is necessary for compliance with a legal tax, accounting, anti-money laundering, legal order, sanction checks or other obligations to which we are subject.
On the basis of our legitimate interest we will use your Personal Data to:
- To communicate about possible security, privacy and performance improvements and products that supplement or improve our purchased products and to optimize the content and delivery of this type of communication;
- To evaluate and to improve the performance and quality of our products, services and websites, develop new products, train our employees and to understand usage trends, and analyze user acquisitions, conversions and campaigns;
- To maintain and develop threat intelligence resources, in particular to be able to detect and block malware;
- To make our systems and applications more secure;
- To maintain the effective performance of our business by ensuring necessary internal administrative and commercial processes (e.g. finances, controlling, business intelligence, legal & compliance, information security etc.); and
- To establish, exercise, or defend our legal rights.
Your interests are a key part of our decision making process and have been considered in all of the above mentioned processing activities. We believe we have achieved a fair balance between privacy and operations. In any case, you have the right to object, on grounds relating to our particular situation, to those processing operations.
Security and Threat Intelligence
We process Personal Data to support network and information security efforts. In line with EU data protection law, organizations have a recognized legitimate interest in collecting and processing Personal Data in a proportionate manner for the purposes of ensuring network and information security. This covers the ability of our networks or of our information systems to resist events, attacks or unlawful or malicious actions that could compromise the availability, authenticity, integrity and confidentiality of the data we store or transmit, or the security of the related services offered by, or accessible via those networks and systems.
Moreover, as a member of the security community, we also cooperate with other players across the security landscape, in particular by exchanging threat intelligence resources, and aid in research and development of new security solutions.
The Personal Data we process for the purpose listed above includes, without limitation, network traffic data related to cyber-threats such as:
- Sender email addresses (e.g., of sources of SPAM);
- Recipient email addresses (e.g., of victims of targeted email cyberattacks including phishing);
- Email header detail including addresses and intermediary systems (e.g., as configured by cybercriminals sending malicious email);
- Filenames and execution paths (e.g., of malicious or potentially harmful executable files);
- Samples (e.g., of malicious or potentially harmful executable files);
- URLs and associated page titles (e.g., of web pages broadcasting or hosting malicious or otherwise harmful content); and/or
- IP addresses (e.g., of web servers and connected devices involved in the generation, distribution, conveyance, hosting, caching or other storage of cyber-threats such as malicious or otherwise harmful content).
In-product and Email Messages
We have a legitimate interest for messaging our users about possible security, privacy and performance improvements and about products that supplement or improve the products already purchased.
If you are our customer, we feel a responsibility to inform you about security and utility improvements and possible problems to your device and software, and provide you with effective solutions relevant to these problems. Because of this, we have a legitimate interest to optimize the content and delivery of this type of communication to you so that you are likely to find them relevant and non-intrusive at the same time.
Product and business improvement
We have a legitimate interest to use necessary Personal Data to understand user conversions, acquisitions and campaign performance through various distribution channels, and users’ download, activation and interactions with our products. For example, we want to know how many users clicked on our offers, or purchased our product after seeing one of our ads. These analytics help us improve functionality, effectiveness, security and reliability of our products and business activities as well as helping us to develop new products. This processing includes using third-party tools.
How We Process Your Personal Data
We do our best to disconnect or remove all direct identifiers from the Personal Data that we use:
- For free versions, this disconnection or removal of identifiers begins when the products and services are initially activated. For paid users we keep Billing Data in a separate database and minimize its use for anything other than handling payments and our own financial management activities.
- For both paid and free versions, we continuously monitor for, minimize, disconnect and remove all direct identifiers during the normal performance of the products and services.
Processing of IP Addresses
For paid products including antivirus, virtual private network (“VPN”), and performance, your IP address is collected at the time at which your product or service is being provided, for the purpose of facilitating our billing process. Specifically, our third-party billing partner will collect your IP address for its billing process; we do not store the IP address from this process.
For free and paid products including antivirus, your IP address is also processed for the purpose of downloading the products, product authorization, fraud and malware detection.
Personalization
We use your answers from surveys, in which you can participate, and relevant Product Data to personalize communication and recommend our relevant products for you.
We do not take any decisions solely based on algorithms, including profiling, that would significantly affect you.
Payment processors
If you opt to pay for use of our services, we will use a third party payment processor to take payment from you. These third parties are properly regulated and authorized to handle your payment information and are prohibited from using your Personal Data for any other purposes other than arranging these services for us. However, they are independent controllers of your data with their own responsibility.
Service Providers
We may use contractors and service providers to process your Personal Data for the purposes described in this Privacy Policy and Products Policy. We contractually require service providers to keep data secure and confidential.
Such service providers may include contact centers, professional consultants (including to defend or to exercise our rights), and marketing/survey/analytics/software suppliers.
Sometimes these service providers, for example our distributors, resellers, and app store partners will be independent controllers of your data and their terms and conditions, end user license agreements (“EULA”) and privacy statements will apply to such relationships.