Privacy Policy

Last updated: January 19, 2022


Adaware Software (7270356 Canada Inc.) is the operator of the Adaware products suites and related services (the “Company”, ”we” or “us”). We respect your privacy rights and we are committed to protecting them. This privacy policy (“Privacy Policy” or simply “policy”) governs our products, services and websites that link to this Privacy Policy, and describes our practices of processing data from you. By “you”, we refer to either or all of the following: (i) visitors to our websites that links to this Privacy Policy (“Visitor” and “Website”, respectively); (ii) our customers using our software products and Services (“User”); and (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 (“Business Customer”). Unless explicitly mentioned otherwise, the information in this Privacy Policy refers to any and all data subject types (“you” or “your’).  

For the purpose of this policy, the “Service(s)” shall include any software licensed by the Company, including features offered by or within the installed software or additional software scripts available therein (either downloaded from one of our websites, pre-installed on your device, downloaded through a third party website, obtained on a physical medium, or otherwise), or services provided through and/or on top such software, services offered on our websites, communication forums, support services, account operation, updates, enhancements, new features, premium support, extended guarantees, online version and free versions of a software or additional services or features as we ay make available from time to time.

If you are a California resident, please also see our CCPA Notice .

Preliminary notes

Contact Information

If you have questions, comments or complaints regarding our Privacy Policy or data practices, please contact us at:

  • Adaware Software (7270356 Canada Inc.)
  • 7075 Robert-Joncas Place, Suite 142
  • Saint-Laurent, QC H4M 2Z2 Canada

Data Protection Officer

If you have any requests regarding the data collected under this Privacy Policy, including requests related to your privacy rights, please contact our Data Protection Officer at: [email protected] 

Please include sufficient details about your inquiry or request, in order to allow us to verify your request and address it.

Changes 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 last revision date will be reflected in the "Last Updated" heading. If we make material changes to this policy, we will make our best efforts to notify you, by email, or by means of a notice on our Website.

Collection and Use of Personal Information

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.

Not mandatory

You are not required by law to provide us with any information. You can always avoid providing us with certain Personal Information; however, you acknowledge that it may prevent us from providing you certain Services that correspond to the required information. 


Visitor Information

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 in a survey) 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 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.


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, analyzing anonymous behavior 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

Cookies retention varies as per their type, functionality and operator (could be third party service), and can range from session to 3 years, or earlier, in case you actively delete cookies by using your browser’s settings.


Device and technical details

This category includes the type of device from which you access the Website or the services (mobile/desktop), type and version of your operating system and your MAC address

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 license key of a software product you purchased.


Account information and activities (including user-generated information)

Ceratin functionalities and Services are available only upon signing up and registering. 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, 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 profile. 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 content to our forum, we will process the content, the account related and timestamp.

Please note that any and 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 various forums, centers and communities on the Adaware Sites or elsewhere on the Adaware Sites will be considered public information and will not in any way be treated as confidential information

Purpose and lawful basis

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, as per data protection regulation.

We use your contact details in order 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 [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: [email protected]. Note that, even if we will 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.


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 you or rather by contacting our Data Protection Officer at [email protected]

Purpose and lawful basis

We will use your email address in order to send you information related to our Services and to keep you up to date regarding new Services, as well as provide you with tips related to our Service, and in case of your consent, share promotional and marketing emails.

Retention

We retain subscription information for as long as you did not actively request to delete such information.


Users Information 

In addition to Visitor information described above, the following may be processed about Users that downloaded, installed and/or purchased a product license.

Purchase Information

When you choose to purchase a product license or to expand (or extend) a license, we will process certain information that is required to process your purchase and to assign a license 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, upclick.com, which privacy policy will apply for any personal information that you provide through the Adaware online stores. They also may maintain personal information that you provide them in connection with the purchase of Adaware software products and/or services. We encourage you to review the upclick.com privacy policy, which can be found in the check-out page and here: https://www.upclick.com/privacy.html

Upon any completed order, we generate and retain your product’s license key number, and order ID to attribute the license to your account and provide you with related premium services.

Purpose and lawful basis

Based on your consent we will be processing such information as described above, including subscription maintenance, billing, invoicing, maintaining the account and providing you with support when requested.

Retention

We retain purchase information for as long as you have asubscription with us, and for a period of 7 years from termination,as required by applicable taxes laws.


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 will 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 abe to offer you features, services and widgets that conform to your selected Products and subscriptions.

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.


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:

  • Antivirus Services - files and media information for purposes of detecting and preventing malicious activity or files. If you choose to use the feature of “Email protection” you will be requested to submit your email address and we will provide you with information regarding potential phishing attacks of your email address. Additionally, when the “Safe Browse” mode is on, we may flag and capture URL addresses that you visited or browse and are detected as potential risk.
  • Search services and safe browsing: the Product includes a search functionality that will be available to you from the Productäs dashboard. When you use this option, we will only use your search query to present search results for you based on such query. This Service is powered by 3rd party search provider (OneSearch, which Privacy Policy is available here: https://www.one-search.com/privacy-policy/). When you use the default search option on the product’s safe browser, your search query will be processed and transferred to our regular search vendors together with IP and cookie ID, so they can provide you with respected search results. The former may include contextual advertisements. 
  • Upon your choice and further activation actions:
    • VPN Services - when you choose to extend the trial version and install the full VPN product, we will process installation information, as described in this Privacy Policy, and may process certain data that is required for providing and processing the Services and technologies, as will be further detailed in the VPN product’s own privacy policy. 
    • PC Cleaner - when you choose to install this product, certain information and permissions will be processed in order to provide you with the respective Service. For more information, please refer to our PC Cleaner Privacy Policy
    • Driver Manager: when you choose to activate/install this feature certain information and permissions will be processed in order to provide you with the respective Service. For more information, please refer to our PC Cleaner Privacy Policy.
    • Adblock: when you use the Product’s own safe browning feature, the ad blocking feature will be on, in which case, we will monitor and process ceratin browsed URL to enable the blocking activity.

Purpose and lawful basis

The lawful basis is legitimate bass when we process data that is required to fulfill your request 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 an action (such as activating additional offered tools and products as part of our offered Products suite).


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 which case we will process your contact information, Products information, and other information that is required to identify your purchase, license 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 License 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

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 entered 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 entered into a contract, then for as long as such contract is valid, relevant, and/or for as long as required by applicable local legislation.

Web tracking technologies, including Cookies and Web Beacons

"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 (privacy policy and data policy), analytics and BI services such as Google Analytics and MixPanel. 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 which case we will seek your consent upon landing on the relevant online Services. 

For further informaton about the cookies we use and how you can make choices, please refer to our Cookie Policy.

Third-party services and Sharing Personal Information with others

We share Personal Information collected from you with third parties or any of our partners only in the following events:

1. Third-Party service providers: We may share your information with third parties that perform services on our behalf, 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. Examples:

      • 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 made available via the Products check out page and via your account with us.
      • Authentication and authorization such as social media, emails authentication services.
      • Hosting, storing and securing such as Amazon Web Services (AWS) for cloud computing, InvisionCommunity.com to host our forums (their privacy policies are available at: https://aws.amazon.com/privacy/ and  https://invisioncommunity.com/legal/privacy respectively). Please refer to the InvisionCommunity privacy policy to understand how they may collect data you post on the forums.

2. Business partners who combine their technological features with us may have access to certain Personal Information about your usage, as collected from you. In these cases, you will always be able to check their privacy policies 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, Adaware Software may be required to disclose personal data in response to lawful requests by public authorities.

5. Business Transitions: If we will 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 servers, 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 analyzed by us and transferred in a combined, collectively and aggregated manner (i.e., your information is immediately aggregated with other users) to third parties.

Security of Personal Information

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.

Transfers of Personal Information To Different Countries

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: [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.

Your rights and choices

Depending on your country of residency, and on the type of your use of our Products and Services (Visitor or a User) certain rights concerning your Personal Data may be available to you (pay attention that majority of your rights can be exercised directly via your User Account, if applicable). when you want to make a request regarding your Personal Information, please contact us at [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 Websites, some of the following rights would 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, to begin with. The following rights are applicable to residents of the EU, EEA or the UK. If you are a residence of Canada or California, the rights under (a), (b), (c), (g) will be applicable to you and will include the right to learn about third parties with which we share Personal Information as detailed in this Privacy Policy.

(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 to 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 an export of your Personal Data in a reusable format, or to directly 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: [email protected] 

Please note that if you request that Adaware delete personal information relating to you, you may no longer be able to continue to pursue certain activities at the Adaware Sites and/or to otherwise use the full functionality of the Adaware Sites.

  • Access the personal information that you provide us and that we maintain;
  • Restrict processing while we review any concerns you may have over the accuracy of the personal information we maintain;
  • Object to
    • Data processing based upon legitimate interests,
    • Data processing for research or statistics,
    • Direct marketing, and
    • Decisions based exclusively on automated processing, such as profiling, so long as the decision does not impact our ability to enter or perform our contract services for you or is not based on your explicit consent;
    • Withdraw your consent in instances where we must have your consent to contact you; and
    • Transfer, or port, your personal information that you provided us in a structured, commonly used, machine-readable format.

Children's Privacy

Adaware further recognizes the particular importance of protecting the privacy of children and Adaware is committed to protecting children's privacy on the Internet. Adaware does not generally target children and does not knowingly collect Personal Information from children under the age of thirteen (13). If Adaware would discover that a child under the age of thirteen (13) has provided Personal Information through the Adaware Sites or if Adaware is contacted by a verifiable parent or legal guardian about his or her child's participation on the Adaware Sites, Adaware will delete the Personal Information about the child from Adaware's active user records.

Contact Information

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

(+1) 514-448-1122


 You may also contact our Data Protection Officer at: [email protected]