This privacy policy applies to all Bitdefender Home Solutions and their related support services, including the creation of an individual account on Bitdefender Central. The Anti-theft, Parental control, VPN services, Bitdefender Box, Premium Services and Digital Identity Protection have additional privacy policies which are detailed in Chapter 7.

The document explains the personal data we collect, how and where we may use it, how we protect it, who has access to it, with whom we share it, and how you may correct it.

1. General information

S.C. BITDEFENDER S.R.L. (hereafter mentioned as Bitdefender), with its official headquarters in 15A Sos. Orhideelor, Orhideea Towers Building, 9-12 floors, 6th District, Bucharest, Romania, registered in the Bucharest Trade Register with number J40/20427/2005, fiscal code RO18189442, e-mail privacy@bitdefender.com processes personal data in agreement with the European legislation on data protection (GDPR – Regulation EU 2016/679). Our Data Protection Officer can be found at the following contacts: Bitdefender’s Data Protection Office – dpo@bitdefender.com, Phone: 4021 -206.34.70

Bitdefender offers data security products and services. Our goal is to ensure information and network security by providing quality products and services in these areas while also respecting privacy and personal data of customers, Internet users and business partners.

For this purpose, we collect only that personal data absolutely necessary for the specified purposes, on a best efforts basis. We do not sell your data. For the collected information and data, we strive to apply adequate solutions to anonymize them, or at least to pseudonymize them.

Our main principle applied to the data we collect is anonymization of all technical data that can be used by Bitdefender only for the specified purposes below. In cases where perfect anonymization of technical data is not possible, the potential identification of a user could be possible only in very limited cases and only by highly skilled IT specialists.

Personal data according to the European legislation definition (GDPR - Regulation 2016/679) means:

any information relating to an identified or identifiable natural person ('data subject'); an identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identification number or to one or more factors specific to his physical, physiological, mental, economic, cultural or social identity;

In this context, Bitdefender processes personal data for the following main purposes:

1. To ensure network and information security by:
   • assuring correct and efficient operation of its products and services, according to the technical specifications, and for their improvement, including analyzing the reported IT security issues, delivering and customizing the related services to the users needs and developing new technologies;
   • support or counseling services for its users of Bitdefender Home Solutions;
2. To conclude and perform the contract with the user, including preliminary steps in this direction;
3. To make statistical analysis and market studies;
4. To perform marketing activities for Bitdefender's own needs.

2. Personal data collected

Bitdefender may collect personal information from its users from its Home Solutions in three different ways:

1. directly provided by a user or a Bitdefender Partner;
2. indirectly provided by its products or other sources, such as:
   • technical data sent by the Bitdefender products installed by users
   • publicly available information from data leaks.

2.1. Personal data directly provided by a user/partner

a) Currently, you may buy or renew the Bitdefender Home Solutions from an authorized partner, in which case the personal data collected with this activity is processed directly by that respective partner (which is a data controller for that data collection).

In certain countries, you may also buy Bitdefender Home Solutions directly by us with an online sale. In these cases Bitdefender will collect directly from you the necessary data for contracting with you (including payment), for fiscal obligations and certain technical data from your device (IP, browser info and a device identifier) for fraud prevention purposes.

The necessary data for payment is processed by:

• the payment services provider Adyen.com, which is a data controller for data on your credit card payment data (which is actually encrypted in accordance with PCI DSS standards). Read their full privacy policy here - https://www.adyen.com/policies-and-disclaimer/privacy-policy. Bitdefender will never have access to your full credit card details;
• PayPal, if you choose this method of payment, which is a data controller for all payment data, which takes place on their website. Their full privacy policy is available here https://www.paypal.com/webapps/mpp/ua/privacy-full.

b) When you create an account or login in Bitdefender Central (which is mandatory to activate and manage your services), we might ask your name, surname and/or email address for management of your Bitdefender products or services and so we can contact you with updates, notices, feedback messages and other types or transactional communications or for improvement of the information security of your devices, or to provide support.

c) In certain cases, when you download a trial version of our products, we will collect your email address, in order to have a contact method with you, to receive information such as updates, notices, feedback messages and other types or transactional communications or for improvement of the information security of your devices, or to provide support. We reserve the right to verify the existence of that email address, as a security check and to prevent fraud.

d) Also, when you access the Support Center, we may ask for a valid email address or a phone number to communicate with you in providing support. All these data are being used for contacting you, for contractual purposes, providing a specific user with a license to use our products, for solving a request or complaint you addressed to us or for offering technical support. Bitdefender may also ask for other data that could be considered personal data, if those are necessary for solving the information security problem you sought help on.

The legal basis for processing these data is performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract. The minimum data for creating an account with Bitdefender are a name and email address, without them it would be impossible for us to offer you our products and services. The minimum data for online sales are the mandatory fields in the checkout form, without providing them it would not be possible to buy the Bitdefender products and services from us.

These data used for online sale or licensing information is kept for the duration of the contract, plus five years after its expiration to be able to prove or defend any legal complaints on contractual issues.

The personal data processed in compliance with our tax and accounting obligations are collected on the legal basis when processing is necessary for compliance with a legal obligation. These data will be kept for a period of 10 years from 1st January of the year following the accounting period to which they relate.

The technical data used for fraud prevention purposes is collected by us for the legitimate interest or preventing fraud. In case your card supports 3D Secure 2, this information is collected by your issuing bank as a data controller, and we do not have access to it.

The data used for support services is kept for different periods of time, depending especially if the problem has been solved and the exact method of communication with the support services, but in no case the data will be kept for more than five years after the last communication took place. This period is necessary for Bitdefender to be able to defend any legal complaints on contractual issues that may arise.

As regards the use of these data for marketing purposes, the legal basis we use is legitimate interest for marketing communications with users of our Home Solutions (based on Recital 47 of GDPR and Romanian law 506/2004, art 12 (2) that is implementing the EU E-privacy directive), unless those persons have opted out.

Whenever we note that we use legitimate interest as a legal basis for a specific situation, we rely on internal legal analysis on how in these specific cases we have balanced out the legitimate interest to the interests or fundamental rights and freedoms of the data subject. The analysis is updated if we decide to collect more data, for another purpose or there are new developments that require a new assessment.

We may use these data for marketing purpose for a maximum period of contractual duration, plus five years after the contract is terminated, except if the data subject has opted out from these communications at any moment in time. After this time frame expires the data will be deleted or anonymized.

2.2. Technical data sent by Bitdefender product

- when you use Bitdefender products it is possible to share with us some technical details, such as data for identifying the device (UUID), the infected URL you reported or an IP addresses. If you use a Bitdefender product that integrates with your email server, some technical data of the infected files could be send to us, including data such as sender, recipient, subject or attachment. In most cases, these technical data may not lead to your direct or indirect identification, but in some very specific cases computer specialists might be able to identify a specific user. Therefore, we treat all such information as personal data and protect it as such.

This information is solely used for the purpose of information and network security by correct and efficient operation of the products and services, according to the technical specifications, and their improvement, including by analyzing the reported security issues. This includes delivering and customizing related services. Also, we may use this information for statistical purposes and improving the quality of our products.

The legal basis for processing these data is performance of a contract to which the data subject is part of.

These data are is being stored for a limited period, depending on its usefulness for the current information security needs. Based on the current speed of technology, we will not need them for over 10 years from the day of the collection.

2.3. Collecting Data from publicly available information (data leaks).

In the recent years, an increasing number of companies' databases have been involved in incidents leading to user details becoming publicly available. We are constantly analyzing these situations and the public data leaks in order to identify if the exposed records can be used to improve the information security of our users.

We use this information exclusively for the purpose of ensuring information security by notifying our users that their emails, passwords or other data might have been hacked in the past, so it is not safe to use them anymore.

The legal basis for this collection is legitimate interest of our users, of Bitdefender and of any third party to ensure network and information security, by not using credentials that have already been hacked. We do this based on Art 6 (1) f of GDPR and explanations on legitimate interest for information security in Recital 49 of GDPR. These data are is being stored for a limited period, depending on its usefulness for the current information security needs. The data subject may always ask us not to collect data about him from data leaks. Based on the current speed of technology, we will not need them for over 10 years from the day of the collection.

3. Protecting the Personal data

As a leader in information security services, confidentiality and data protection are of vital importance for us. Access to the collected personal data is restricted only to Bitdefender employees and data processors that need access to this information. All Bitdefender information security policies are ISO 27001 and SOC2 Type2 certified.

Bitdefender may use other companies to process the collected personal data. These companies are considered data processors and have strict contractual obligations to keep the confidentiality of the processed data and to offer at least the same level of security as Bitdefender. Data processors have the obligation not to allow third parties to process personal data on behalf of Bitdefender and to access, use and/or keep the data secure and confidential.

Bitdefender may transfer personal data in Romania, Ireland, as well as in European Union (EU) or any other jurisdiction, which offers adequate level of personal data protection according to European Union standards (art 45 GDPR) or other appropriate safeguards, including Standard Contractual Clauses (art 46.2 GDPR).

Due to confidentiality obligations and security requirements, the specific information regarding the name and details for each processor used will be provided only to competent authorities.

The following types of data processors are being used:

• hosting services in EU and USA;
• support channel communications in EU and USA;
• e-commerce support providers in EU and USA;
• marketing services (including email marketing) in EU and USA.

Access to certain sections of Bitdefender websites is protected by a username and password. We recommend not to reveal this password. Bitdefender will never ask for your account's password via any kind of messages or phone calls. We advise not to disclose your password to anyone asking you to do so. If possible, we also recommend to log out of your online services account after each session. We also advice to close the browser window after navigating or using Bitdefender services.

Unfortunately, transferring data over the Internet cannot be 100% secure. Consequently, despite our efforts to protect personal data, Bitdefender cannot assure or guarantee the security of the information transmitted by the user until the information is on our servers. Any information you transmit is done on your own risk.

4. Who has access to personal data

In principle, Bitdefender will not reveal any personal data about its users to third parties without the exceptions mentioned above.

Exceptionally, Bitdefender may reveal personal data to:

4.1. Competent authorities, upon their legal request according to the applicable laws or when this is necessary to protect the rights and interests of our clients and Bitdefender.

4.2. Bitdefender may allow limited access to its Partners, which are presented on Bitdefender's Partners webpage. Access will be allowed only to certain data related to its referred clients and just for the purpose of fulfilling the contractual obligations between Bitdefender and its Partner for selling or for support of Bitdefender products. All Partners have strict contractual obligations to keep the confidentiality of data and to offer at least the same level of security as Bitdefender. These Partners have the obligation not to allow third parties to access personal data processed on behalf of Bitdefender.

4.3. Bitdefender subsidiaries in your country may send some personal information to its main company - S.C. BITDEFENDER S.R.L, in Romania.

Also, when you use Bitdefender Home Solutions or access Bitdefender Central and you are asked to give information about yourself, you will reveal this information only to Bitdefender. The only exception is when the information is offered in partnership with another service (for example online payment with the payment processors mentioned above or to create an a Bitdefender account with Facebook login, Google+ login ,Microsoft login or Apple ID).

Each time when such a service is offered in partnership with another provider you will be properly notified. If you wish this data not to be accessed or used you can choose not to allow data transfer via this particular service.

If you choose to accept data sharing, it is important to mention that the service partners may have separate data collection and privacy policies. Bitdefender has no control and cannot offer guarantees regarding all the legal aspects that these independent confidentiality practices entail.

5. How to correct personal data related errors

When you create an account on Bitdefender websites or for one of our services, a confirmation email with your account details will be sent. The confirmation email will be sent to the email you supplied and it may describe the ways in which you can modify or delete the account you created. We advise you to keep this confirmation email since it contains useful information regarding access to our services. Any requested modification will be solved in maximum 15 days from when the written request of the user has been received.

6. Your personal data rights

According to European Union applicable data protection legislation (GDPR), data subjects shall have the right to access to data, rectification, erasure, restriction of processing, objection to processing and right to data portability.

For any data processing based on consent, you have the right to withdraw the consent at any time.

For exercising these rights, you may send a written request, dated and signed and send it to the above mentioned Bitdefender headquarters or via email to Data Protection Officer at privacy@bitdefender.com.

Data subjects are not subject to decisions based solely on automated processing, including profiling, which may produce legal effects or similarly significantly affects them.

You also have the right to lodge a complaint with a competent supervisory authority on data protection.

7. Additional information regarding personal data collection of certain Bitdefender services and products

7.1. Anti-theft services of Bitdefender products

This chapter complements the privacy policy with specific information regarding processing information which may be personal data and which is collected by Bitdefender for the anti-theft services.

Part of the Bitdefender products include the anti-theft service option designed for both mobile phones products as well as for tablets and laptops. Once activated and configured, the anti-theft option can track in real time via geo-localization the lost or stolen device. This Bitdefender service offers the localization option as well as other connected options such as remote blocking of the device, deleting the entire content of the device or taking photos of the person who is accessing the phone without authorization. More details are available here.

In case the anti-theft services are activated, Bitdefender may receive personal data such as geo-localization data either from GPS, GSM cells, Wi-Fi usage or IP address. The only purpose of processing these data is the functioning of the anti-theft service offered by Bitdefender. For the purpose of identifying the precise location, we may use third party services, as mentioned in Chapter 3.

All geo-localization information are kept for as long as the anti-theft service is active, but they will be deleted when the service is deactivated.

Anti-theft services may be remotely activated from your Bitdefender system account (known as Bitdefender Central). For this reason it is highly important for your privacy and personal data protection not to reveal your password to unauthorized persons. For more advice in this regard please see Chapter 3 of this document.

Thus, the owner of a Bitdefender account may have administration rights for Bitdefender services and products. Therefore on the devices where the anti-theft services are installed, he/she can operate commands remotely. In this regard, the entire responsibility of the account owner is to ensure that he/she can fulfill these actions from a legal standpoint and that he/she has the right to know the location, to take pictures remotely, to block or delete the device' content or to interact in any way with it. Therefore, we recommend to activate the anti-theft service exclusively on your own devices or on devices where you have the right to legally do so.

7.2. Parental control services

This chapter complements the privacy policy with specific details regarding processing information which may be personal data and which are collected by Bitdefender for the Parental Control services.

Some Bitdefender products include a parental control option. If you buy such products or activate this option you have the possibility to monitor your children's activity and to restrict access to certain applications, websites or Internet services. This is only possible on supported devices (for example computers or phones) for which you have installed and activated Bitdefender.

The parental control services option settings are managed from the web interface through which you access your Bitdefender account (known as Bitdefender Central). More details regarding the functionalities of this product are available on our dedicated webpage.

Before you can activate the parental control services, Bitdefender will ask certain data for creating a profile – name, age and sex of the person. The name will be used exclusively for device identification purposes and you do not have to give your child's full name. Age and sex are necessary only for determining the default level of online protection offered by this product, which can be also later changed or configured by the account administrator.

Where this Bitdefender parental control product is installed and an active profile is associated with the device, Bitdefender may collect, exclusively for the purpose of providing parental control services, including for display in the parent’s account, detailed information about the use of the device such as: visited websites, search engine keywords, used applications and software, phone contacts, and geo-localization information.

The collected information depends on the settings configured by the parent in Bitdefender Central. The only purpose of collecting this data is reporting to you, the parent. We do not use children information for their identification or monitoring Internet access by us.

We do not transmit to third parties the above mentioned information for marketing purposes or any other information which could lead to identifying your children.

When processing this data from your children's device, Bitdefender acts as a technical intermediary. Therefore, the responsibility of a notice to your children regarding the installation of this software and the way the personal data is processed is exclusively up to you. You are the only one who may activate this option and specify which type of personal information you wish to be collected.

The Bitdefender account owner has administration rights for Bitdefender products and services which includes parental control services. As such, he/she has full responsibility in assuring that he/she can undertake the surveillance activity from a legal point of view and that he/she has the right to know the location, to block the content or applications from that device. Therefore, we recommend to activate the parental control service exclusively on your minor children's devices or where you have the legal right to do so, based on the applicable law. We inform you that any illegal monitoring of online behavior or communications may be a crime. We do not recommend activating parental control services on devices used by persons who are over 16 years old, or otherwise in circumstances in which use of the parental control services is illegal.

7.3. VPN services

This chapter completes the rest of the privacy policy with specific details regarding processing information which may be personal data and which are collected by Bitdefender through its VPN services.

Applying the data minimization principle, we collect for this service only randomly generated or hashed user and device IDs, IP addresses and randomly generated tokens to establish VPN connection for the sole purpose of providing the VPN service. For this service, we use Aura as data processor who processes data on behalf of Bitdefender in accordance with Bitdefender's instructions and for the sole purpose of providing VPN services to users.

We may process device location solely for the purpose of offering Bitdefender VPN functionalities such notifications of unsafe Wi-Fi or the auto-connect feature. We do not store any details regarding your location or online activity nor do we share them with other entities.

7.4 Premium services

This chapter completes the rest of the privacy policy with specific details regarding processing information which may be personal data that are collected by Bitdefender for its Premium services.

As described and agreed by the Terms and Conditions for access to Bitdefender Premium Services, these services can’t be performed unless we have access to your devices. Thus depending on the services selected, Bitdefender may choose to provide the Premium Services using the following delivery channels: phone, live chat, email or remote access to your computer. During the delivery of the Services, Bitdefender may, at its sole discretion and without any obligation, capture in different forms (such as, but not limited to: voice recording, video recording, screen recording, written recording, database monitoring) the Services sessions for the purposes mentioned below.

In order to ensure and avoid any liability issues on our interaction with your devices, we must record all interactions for providing the Premium Services between our staff and these devices. We do this specifically to protect you and/or Bitdefender or its staff for any possible mismanagement in relation with your devices or your data. Please note that we may not provide the Services if you don’t accept these recordings.

You will be properly informed whenever we start a recording and it will always stop when we disconnect from your devices.

The purposes of these specific data processing activities (recording the interactions between our staff and your devices) are to prevent liability issues from any contractual party for these services and to ensure services improvement, including quality assessments.

The legal basis for this processing is legitimate interest of our users and of Bitdefender & its staff, based on Art 6 (1) f of GDPR. These data are being stored for a limited period – usually for maximum 12 month from the date of the communications, unless legal proceedings or liability issues are being raised on these communications in which case they will be stored until the end of such proceedings.

7.5 Bitdefender BOX

This chapter completes the rest of the privacy policy with specific details regarding processing information which may be personal data that are collected by Bitdefender Box.

If you use Bitdefender Box, the device will scan all the traffic in your network for malicious activity. This means that we will collect detailed technical data from all your smart devices that are connected to your network that will be used only for the purposes specified in Chapter 2.2. above.

In most cases, these technical data may not lead to your direct or indirect identification, but in some very specific cases computer specialists might be able to identify a specific user. Therefore, we treat all such information as personal data and protect it as such.

If a new device from other users is connected to your network, Bitdefender Box will also analyze network traffic from that device. As a network owner, it is your responsibility to inform the other users of your network that you use Bitdefender BOX for the protection of the network traffic and therefore their traffic will also be analyzed, as described above.

7.6 Bitdefender Digital Identity Protection

This chapter completes the rest of the privacy policy with specific details regarding processing information, which may be personal data that are collected by Bitdefender Digital Identity Protection.

When you are using Bitdefender Digital Identity Protection service, whether or not you are using only this service or along with a Bitdefender anti-malware Solution, we may ask you to provide us your name, e-mail address and telephone number, for the purpose of providing you information security by:

1. providing you information related to breaches of your personal data and sending you instant alerts about any new breaches (you get instant alerts if your personal information shows up in a new data breach),
2. providing you information regarding your digital footprint’s potential of damaging your online reputation or social media impersonation,
3. providing you the option of Continuous Identity monitoring in order to reduce false alarms or duplicated alerts we send you.

Bitdefender Digital Identity Protection searches for personal information in publicly available information to start mapping your digital footprint. The system correlates all pieces of information linked to your identity and checks whether they have been exposed in a data breach, on the public Internet or on the Dark Web and we provide you with information such as e-mails or phone numbers used by you correlated with the data you provided or other information correlated with your identity such as name, gender, date of birth, email addresses, phone numbers, addresses, usernames, jobs, education, URLs, references to public photos.

For detection of Social media impersonation, Bitdefender Digital Identity Protection uses the personal data you have provided to us (name, e-mail address and telephone number): in order to detect if someone has created an account pretending to be you in the main 25 social media networks. At the first signs of impersonation, you will receive the link to the suspicious profile and recommended instructions on how to report or remove it from that social media network.

For any breach of your data, Bitdefender Digital Identity Protection will alert you of the findings and you will be advised on the steps to take to reduce the risks of account take-over and new account fraud. Such findings may be references regarding e-mail, password, address, phone number, SSN, credit cards, travel documents, criminal records and medical records – without displaying the value of such data and as such we do not store or process the information, but only the sources / links to the potential data breaches.

We provide you this service by using PIPL as data processor who processes data on behalf of Bitdefender in accordance with Bitdefender's instructions and for the sole purpose of providing you Bitdefender Digital Identity Protection services. We also collect the remediation actions if and when the user selects an action to remediate a digital footprint data validation. For example, in a breach we will display you the recommendation to change the password for the breached account. Should you click on the respective link/button, we will register only that a change password action was taken and we share this information with PIPL. This process allows us to adjust the digital footprint we have provided you in the Bitdefender account and make sure we do not send multiple alerts if the situation has been resolved.

We store the received information for as long as you have the service active in order to display to you the status of Your information and to be able to properly notify or give you instant alert if a change regarding your Digital footprint has occurred or a data breach in which you are affected. Each time a new information appears, we will display it in the Digital Identity Protection section of your Bitdefender Account.

8. Publication date

The privacy policy has been adopted on the date mentioned in the title of the document and will be modified each time is necessary without prior or future notice of the changes. The new version will enter into force when published on the website and it will be marked accordingly. The present document is available at https://www.bitdefender.com/site/view/legal-privacy.html