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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.
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 email@example.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 – firstname.lastname@example.org, 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. For the collected information and data, we strive to apply adequate solutions to anonymize them, or at least to pseudonimyze 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:
Bitdefender may collect personal information from its users from its Home Solutions in three different ways:
– for example, when you login on your Bitdefender account (known as Bitdefender Central - https://login.bitdefender.net), we might ask your name, surname and/or email address so we can contact you with updates, notices, or to provide support.
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 entering into a contract or 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 data used for 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 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.
We may use these data for marketing purpose for a maximum period of contractual duration, plus three 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.
- 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.
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.
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.
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 certified.
Bitdefender may use other IT 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 host personal data in Romania, Ireland, as well as in European Union or any other jurisdiction which offers adequate level of personal data protection according to European Union standards, including companies that are certified under the US-EU Privacy Shield program.
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 processor are being used:
All our data processors in US are certified in the US-EU Privacy Shield program.
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.
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 (such as Facebook login, Google+ login or Microsoft Live login).
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.
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.
According to European Union applicable data protection legislation (GDPR), data subjects shall have the right to access to data, rectification, erasure, restriction on processing, objection to processing and right to data portability.
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 email@example.com
You also have the right to lodge a complaint with a competent supervisory authority on data protection.
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.
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 phone numbers, applications, websites or Internet services. This is only possible on 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.
Once you activated 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, traffic data monitoring of phone calls and messages, phone contacts, social media monitoring and geo-localization information.
Some Bitdefender parental control products – such as ones that include cyberbullying-prevention features - may check social media text and images in conversations of your children and may collect stored images and videos. We do that only to inform the parents that some activities are suspected to be dangerous, without sharing your children’s conversations with the parents. We employ privacy-enhancing technologies, so that we do not receive full images from the conversations, and we delete or anonymize private text conversations in a maximum of 2 hours after a conversation has ended. In certain jurisdictions, including the United States, we collect data for cyberbullying-prevention research from parental control products with or without an active cyberbullying-prevention subscription; parents may opt out from such data collection in the product control panel. We are constantly researching how to improve our technologies in order to meet the scope of the technology (flag suspicious content), and to reduce any kind of information being sent to us, by including all detection technologies in the device of the user.
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.
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 AnchorFree 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.