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Last updated: June 24, 2024
Adaware Software (7270356 Canada Inc.) is the developer and operator of the Adaware products suite and related services (the “Company”, “Adaware”, ”we” or “us”). This privacy policy (“Privacy Policy” or simply “policy”) governs our processing activities of personal data related to our products, services and websites that link to this Privacy Policy.
Data Subjects
When we refer to “you”, we mean one or more of the following: (i) visitors to our website (“Visitor” and “Website”, respectively); (ii) our customers who have downloaded, installed and used our software products and Services (“User”); and/or (c) a business customer, a business partner that has a contractual relationship with us or, a prospective customer that is yet to be engaged in a contract with us (“Partner”). Unless explicitly mentioned otherwise, the information in this Privacy Policy refers to any and all data subject types (“you” or “your’).
The Services
For the purpose of this Policy, the “Service(s)” means, the Websites, offers included therein, forms, products, including - without limitation - any software licensed by us or our affiliated companies, and any related features, forums, support services, account registration and operation, updates, enhancements, and additional services or features we may make available from time to time.
Applicable jurisdiction
We designed this Policy in accordance with best practices and the requirements of the EU General Data Protection Regulation (GDPR). If you are a resident of any other jurisdiction, we cannot guarantee that the language will fully conform to the specific requirements of your country of residence, and it is your free choice whether to accept our Policy or not use the Services. We offer the following specific privacy statements:
7270356 Canada Inc. is the data controller of the Personal Information processed in connection with the Services. The postal address is 7075 Robert-Joncas Place, Suite 142, Saint-Laurent, QC H4M 2Z2 Canada. We can be contacted at: mailto:[email protected] for general inquiries, or at mailto:[email protected] for privacy-related inquiries.
Changes and updates to the Policy
We reserve the right to modify this Privacy Policy at any time, such changes will be effective immediately upon the display of the revised Privacy Policy. The revision date will be reflected in the "Last Updated" heading. Upon material changes to this policy, we will notify you by email, or by means of a notice on our Website, and the revised privacy policy will be effective 7 days after such notification.
You are not legally obligated to provide us with Personal Information (see definition below), and you acknowledge that providing us with Personal Information is done freely by you. You also acknowledge that we cannot provide you with the relevant Services or process requests you make without such information. Some of the Services will require you to submit specific Personal Information in addition to other information already processed about you. In such a case, you can choose whether you want to use such additional Services or not. To better learn about your rights relating to your Personal Information, please refer below to the relevant section in this Policy.
Type of information*** ***
As part of operating the Websites and Services, we process data as described below, directly by us, or with the services or third-party services. This policy describes the processing operation of your personal information (“Personal Information”). Personal Information refers to information that identifies you as a natural person, or that may be used, either alone or in combination with other information, to personally identify you as a natural person. Such information may include, for example, a first and last name, an email address, phone number, a home or other physical address, and other contact information. In addition, in some jurisdictions (as the EU for example), and given the specific use we make with the information, an IP address, device ID and cookies could be considered as Personal Information as well. In the event we combine Personal Information with Non-Personal Information, the combined information will be treated as Personal Information for as long as it remains combined.
Visitor Information
Category: Support and Contact Information
If you contact us for support, feedback or other inquiries, requests, or questions either through an online form available on the Website, by sending us an email or by other means of communication we make available (such as submitting a bug report or filling out a survey, contacting support channels such as chat, phone or other methods of communication) you will be requested to provide us with your name, your email address, and the subject matter of your inquiry.
Purpose and lawful basis
We will use this information based on your consent and for our legitimate interest and solely for the purpose of responding to your inquiries and providing you with the support or information you have requested.
Retention
We retain such information for as long as needed to provide you with the inquiry requested or as required under applicable law, and depending on the context (for example, if you enrolled as a prospective Partner, for as long as commercially required for us to realise such information.
Category: Online identifiers and activity
We process IP addresses, cookies information (that upon your consent maintains activities across the websites, such as clicks, views and actions, remembers’ credentials for sign-in and information about the ad campaign or source from which you landed on the Website), pixel tags, user agent (namely, your browser’s type, version, language, and country).
Purpose and lawful basis
We process online information for several purposes, each with its respective lawful basis: (a) for our legitimate interest of providing and measuring the Services, the Websites, the functionalities and ensure compatibility; (b) for our legitimate interest of monitoring against fraud or spam and ensure Website maintenance; (c) based on your consent to the different purposes for which we use cookies (for example, analytics, analysing anonymous behaviour to adapt our future products offerings to our customers' preferences, for marketing purposes, attribution of a visitor to a media source and measurement of campaign success or failure) (d) our legitimate interest of generating a random user ID that will enable attribution of online activities to a symbol of a user in our systems and databases.
Retention
Retention of web technologies varies as per their type, functionality and operator (could be third-party service), and range from session to 3 years, or earlier, in case you actively delete cookies by using your browser’s settings.
Category: Device and technical details
This category includes the type of device from which you access the Website or the services (mobile/desktop), the type and version of your operating system.
Purpose and lawful basis
Based on our legitimate interest, we may process device information for compatibility purposes, and to uniquely connect your device with a licence key of a software product you purchased.
Category: Account information and activities (including user-generated information)
Certain functionalities and Services are available only upon registration and signing up for an account with us. If you choose to sign up and open an account, you will be requested to provide us with certain information such as your full name (or a nickname), and email address, you will be required to create a password, at which time you thereby represent and warrant that you are responsible for maintaining the confidentiality of your details and password.
We offer the option of signing up via your email or social media account. In case you choose this type of authentication, we will process a token that will give us access to your public information available via the media of your choice.
When using the account service, we will process your usage information, for example, if you upload or generate content to our forum, we will process the content, the activity metadata, the related account and the timestamp.
Please note that all information, discussions, opinions, blogs, postings, ideas, feedback and other communications and materials of any kind that you post, upload, submit or otherwise make available within the public forums, centres and communities on the Services (when those are made available) will be considered public information and will not in any way be treated as confidential.
Purpose and lawful basis
We reserve the right to make this part applicable only to “Users”.
We use this information for the purpose of performing our contract with you, providing you with the Services you have requested, and designating an account for you, including authenticating you and securing your access to your information via the account. The account and information processed respectively are also used to give you access to all your products, activities and information and to allow you to edit, rectify, manage and delete information.
We use your contact details to send you required information related to the Services and our business engagement (e.g. send you a welcome message, to notify you regarding any updates to our Services, send applicable invoices, and additional occasional communications related to the Services) as well as verify your identity. Upon consent, we will also send you marketing materials. You can remove your Personal Information from our mailing list and stop receiving promotional communications from us by following the unsubscribe link located at the bottom of each communication or by emailing us at mailto:[email protected]. Please note, that even if you unsubscribe, we reserve the right to send you service-related communications, including service announcements and administrative messages, relating either to your account or to your transactions of the Services.
**Retention **
If you wish to delete your account, please contact us at: mailto:[email protected]. Note that, even if we delete your account, we may keep certain records related to transactions you made - if any, when those are required to comply with applicable law or otherwise, required for the legitimate purposes of our business. For example, we will not delete any invoices sent to you as we need them for the purpose of managing our finances.
Category: Subscription
If you voluntarily subscribe to our email communications, you will be asked to provide us with your email address, or to give your consent to use your email address for communication of new products, features and offers we launch. You can unsubscribe at any time using the unsubscribe option within the body of the email sent to you or rather by contacting our Data Protection Officer at mailto:[email protected].
Purpose and lawful basis
We use your email address to send you information related to the Services, to keep you up to date with new Services, and to provide you with tips related to our Services. In case of your consent, we may share promotional and marketing emails.
Retention
We retain subscription information for as long as you do not actively request to delete such information.
Category: Job Application
When you apply for a job with us, we ask you to provide us with some basic information, including your name, email address, phone number, your CV file and/or other relevant professional information that you will choose to provide and may be relevant to your application.
Purpose and lawful basis
Based on your consent (which can be provided as action and submission of information), the information that you provide us will be used to process your application, including, to communicate with you, manage our recruiting process, and comply with laws and regulations. If you are later hired, the information may be used for employment and corporate management purposes.
***Users Information ***
In addition to Visitor information described above, the following may be processed about Users who download, install and/or purchase a product licence:
Category: Purchase Information
When you choose to purchase a product licence or to expand (or extend) a licence, we process certain information that is required to process your purchase and assign a licence key to your account as per your chosen product subscription. Such information includes billing information (first and last name, email address, city, country, zip code) and payment information (selected payment method and respective payment details). Those will be collected and processed directly by our payment processing vendor, http://upclick.com, whose privacy policy will apply to any personal information that you provide through the Adaware online stores, checkout pages and billing/payment processes. Upclick may also maintain Personal Information that you provide them in connection with the purchase process of Adaware software products and/or Services. We encourage you to review the upclick.com privacy policy, which can be found on the check-out page and here: https://www.upclick.com/privacy.html.
Upon any completed order, we generate and retain your product’s licence key number, and order ID to attribute the licence to your account and provide you with related services, respective to your selected product.
Purpose and lawful basis
Based on your consent we process such information as described above, including for subscription maintenance, billing, invoicing, maintaining the account and providing you with support when requested. Certain information is retained on a lawful basis and law requirement basis, for example, billing information and transaction data.
Retention
We retain purchase information for as long as you have a subscription with us, and for a period of 7 years from termination, as required by applicable tax laws.
Category: Installation information
This includes capturing the installation action, timestamp, operating system’s type (Mac/PC), device type (computer, mobile, tablet) and MAC address, language and version. We also learn about other antivirus products you have installed to ensure we can prevent clashes between permissions.
Purpose and lawful basis
We process this information in order to execute the installation, ensure compatibility and prevent duplications. We also use it to support your subscription period and to be able to offer you features, services and widgets that conform to your selected Products and subscriptions, or, that can supplement well your device’s security state and needs.
Retention
We retain this information for as long as the product is installed on your device and/or, for as long as required to process and operate the Services.
Category: Products’ usage information (online/offline)
When the Product is installed and you use it, we collect and process information related to the different Services and features provided to you, including online and offline information, as follows:
The lawful basis is our legitimate interest to process data that is required to fulfil your requests and desired action, such as installation information and other useful information that is required to provide and operate the Services. Some information will be processed based on your consent, which can be provided by taking action (such as activating additional offered tools and products as part of our offered products suite).
Category: Customer or technical support
When you contact our technical or customer support, we may provide this Service by phone, email or chat, either directly by us or through third party service providers. In this case we process your contact information, products information, and other information that is required to identify your purchase, licence or requests.
Purpose and lawful basis
This information is processed based on your consent (and voluntary contact and submission of details), and sometimes for our legitimate interest to authenticate you and associate your details with an Order ID or a Product Licence Key. We use this information to provide you with the requested Services to track the ticket, and retain a record of the request and/or Service provided and results.
Retention
We retain this information for as long as required to track the ticket or request, and in many cases, up to 7 years as may be required by several applicable local legislation (such as taxes, consumer protection and privacy legislation).
Business Customer Information
Category: Contact details
If you are a business Partner, or potential business partner, we may store certain contact information and job title information about you in our CRM systems. This includes full name, work title, work email address and name of the company in which or for which you work.
Purpose and lawful basis
We retain and process this information for CRM purposes and business needs, based on your consent, that may have been provided to a third party that introduced your details to us. If we enter into a contract, then this will be the lawful basis.
Retention
We retain this information for as long as it is relevant for our business purposes, and, if we enter into a contract, then for as long as such contract is valid, relevant, and/or for as long as required by applicable local legislation.
"Cookies" are minor text files that are placed in your computer's browser and store certain preferences and actions you make as a Visitor or a User (i.e., when you use online Services we provide, such as the Websites or the Search Services). In addition to cookies, we store to enable and operate certain online features, as described in this Privacy Policy.
We may permit third parties to use cookies or other technology to collect information about your online and application usage activities across our Services, this data may include Online Identifiers therefore we recommend you review our cookie policy carefully. This includes cookies dropped by the media provider from which you arrived at our Websites (referrer), such as Facebook ([https://www.facebook.com/about/privacy/previous](privacy policy) and [https://www.facebook.com/policy.php](data policy)), analytics and BI services such as [https://www.google.com/policies/privacy/partners/](Google Analytics) and https://mixpanel.com/legal/privacy-policy/. Pay attention that such third parties may host the data in a country different than your country of residence or the country from which you access the Services. In this case we will seek your consent upon landing on the relevant online Services.
For further information about the cookies we use and how you can make choices, please refer to our [https://www.adaware.com/cookie-policy/](Cookie Policy).
We may share Personal Information with third parties or any of our partners in the following events and with the following categories of third parties:
1. Third-Party service providers: We may share your information with third parties that perform services on our behalf or that provide their service to us, such as storage, hosting, features providers (for example malware detection engine, cloud provider), check-out and billing processors, analytics services, servers, service functionality, customer support, marketing, advertising and in certain occasions, monetizing. These third parties may be located in different jurisdictions and process data on our behalf in various locations around the world; We require each to maintain adequate measures of information and privacy protection as required by applicable law. The following are the third-party service provider categories, that may process Personal Information on our behalf, or with whom we share Personal Information for the purpose of providing the Services and keep developing them, distributing them and supporting them:
Storage, hosting and infrastructure services, for example, Asure by Microsoft.
Database infrastructure.
API and engines for security breaches and malware detection, including privacy violation detection (for example https://haveibeenpwned.com/, or Malwarebytes).
Features and enhancements that we integrate into the Services and operated by our affiliated companies or Partners. For example, VPN, AdBlock and similar products and Services.
Support and ticketing: Provided by service providers such as Zendesk, whose privacy policy be available via the relevant service.
A checkout and payment processing: provided by UpClick Inc., whose privacy policy and payment terms are available via the Products checkout page and your account with us.
Authentication and authorization such as social media, email authentication services.
CRM services.
BI and analytics, such as Google Analytics.
Google Adwords and Meta for campaign management, marketing and distribution purposes.**2. Business partners **who combine their technological features with us may have access to certain Personal Information about your usage, as collected from you, or as otherwise submitted by you or required for them to process and provide their features and services. In these cases, you will have their privacy policies available before using the combined services. For example, when you use the Private Search functionality embedded in the Products, our business partners will process your request and provide you with a search result page that matches your search query. Examples:
Media sources and marketers such as Google search and Bing search.
Malware detection engines
Search result services such as AirFind and Microsoft Bing (for information on their data collection, please visit their privacy statements, available at: http://dreamteam-apps.com/airfind-privacy-policy/ and https://go.microsoft.com/fwlink/?LinkId=521839.**3. Our affiliated companies. Certain CRM information (such as business information, account, and contact information) may become available and shared with certain companies within our corporate group, for the usage of the same purposes consented by you. **
**4. Legal Disclosure, Policy Enforcement, Third Party Rights: **We reserve the right to disclose your personal information if required by law and/or to comply with a court order or similar legal process or when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request. In certain situations, we may be required to disclose Personal Information in response to lawful requests by public authorities.
**5. Business Transitions: **If we become involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our website of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.
6. Special cases: We may share information upon your consent, or, in cases of fraud prevention or investigation.
Based on the country of your residence (for example, the European Union, the European Economic Area, the United Kingdom, California state or Israel), you may have the right, subject to verification by us, to reach out to ask and request information about the third party involved in each category.
We may store Non-Personal and Personal Information on our servers or our cloud providers, use or share Non-Personal Information in any of the above circumstances, as well as for the purpose of providing and improving our Service as detailed above. Furthermore, we reserve the right to use, disclose or transfer (for business purposes or otherwise) aggregated and processed data to third parties, including, inter alia, affiliates, for various purposes including commercial use. This information may be collected, processed and analysed by us and transferred in a combined, collectively and aggregated manner (i.e., your information is immediately aggregated with other users) to third parties.
We take appropriate technical, physical, administrative and managerial procedures, and employ security measures and safeguards to protect the personal information that is stored on our servers.
Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data; any transmission is at your own risk. Once we have received your information, we will use commercially reasonable and appropriate technical, physical, administrative and managerial procedures, security measures and safeguards to protect against the loss, misuse or alteration of information that we have collected from you at our site.
Where Adaware has given you (or where you have chosen) a password that enables you to access certain parts of the Adaware Sites, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. If you believe your password or account has been compromised, you should notify Adaware immediately.
We may store or process your Personal Information in Canada, the United States or in other countries. If you visit our Websites or use our Services from locations outside of the United States, please note that any information you provide to us through your use of our Websites or Service may be transferred to and processed in countries other than the country from which you accessed our Websites or Service, including the United States and Canada, where our central database is operated.
We will take the necessary steps to ensure that international transfers of Personal Information meet all requirements under applicable data protection laws.
When personal data collected within the European Economic Area (“EEA”) is transferred outside the EEA, we will take the steps necessary to ensure that the transfer of such data provides sufficient safeguards, and you may exercise your rights, where applicable, to receive information on such transfer mechanisms. Personal Information transferred outside the EEA is transferred for processing by AWS on its servers in the United States, and among the Company’s affiliates, in both cases pursuant to standard contractual clauses approved by the European Union. If you would like to understand more about these arrangements and your rights in connection therewith, please contact our Data Protection Officer at: mailto:[email protected].
We may transfer your personal information across national borders to other countries in compliance with applicable laws. For instance, as discussed under “Third Party Cookies,” our analytics provider stores data in the United States. If you are a European resident, we transfer your data based on the European Commission-based Standard Contractual Clauses or decision of adequacy.
Depending on your country of residency, and the type of your use of our Products and Services (Visitor or User) certain rights concerning your Personal Information may be available to you (pay attention that the majority of your rights can be exercised directly via your User Account, if you maintain one with us). When you want to make a request regarding your Personal Information, please contact us at mailto:[email protected] with your detailed request and sufficient information to allow us to verify you, your place of residence and your request, and we will process your verifiable request within the timeframe indicated in the applicable regulation. Please note, that when handling these requests, we may ask for additional information from you.
If you are a Visitor of the Website, some of the following rights may not apply to you, but you may choose to exercise your rights by refusing certain types of cookies, deleting cookies or setting your browser to refuse cookies.
(a) Right of access: You may ask us to access any Personal Data held about you. (b) Right to rectification: You have the right to ask us to correct the information we hold about you. (c) Right to erasure: You may ask us to delete your information or to stop using it. We can only do this when possible, and as allowed by applicable laws. Sometimes we need your information to complete a transaction based on an action you made, comply with the law or simply provide you with the Products and the Services. (d) Right to the restriction of processing: You may ask us to temporarily cease the processing of your Personal Data, or, for a specific purpose or function. Please note that this too might cause us to not be able to provide you with the Products and Services or part thereof; (e) Objection to processing: You may request us to stop processing your Personal Data. Similar exceptions as mentioned above will apply to such a case as well; (f) Right to data portability: You may contact us to request to export your Personal Data in a reusable format, or to transfer such data to another vendor offering related services; (g) Right to withdraw consent: Where you have given us your consent to use your information for a specific purpose, you may, at any time, decide to withdraw your consent and we will then stop using your information for that purpose, under the exceptions listed above; (h)** Right to lodge a complaint:** If You live in a country where the EU GDPR applies (e.g. the EU, EEA or UK), you may lodge a complaint with the authority responsible for protecting Personal Data in your country of residence, if you believe that your rights have not been respected by us. In such a case, you are welcome to reach out to us first so we will be able to help you with such a matter, at: mailto:[email protected].
Please note that if you request to delete Personal Information relating to you, you may no longer be able to keep using certain activities on the Website or utilise some or all of the Services.
Adaware further recognizes the particular importance of protecting the privacy of children and Adaware is committed to protecting children's privacy on the Internet. We do not generally target children and do not knowingly collect Personal Information from or about children under the age of sixteen (16). If we discover that a child under the age of sixteen (16) provided Personal Information through the Websites or Services or if we are contacted by a verifiable parent or legal guardian about his or her child's participation in the Services, We will delete the Personal Information about the child from our active user records.
If you have any questions about this privacy policy, please contact us at:
7075 Place Robert Joncas,
Ville Saint-Laurent,
Montreal, Quebec H4M 2Z5,
Canada
You may also contact our Data Protection Officer at: mailto:[email protected].