How Can You Instruct Us Not to Sell Your Information?
There are several ways in which you can do this. First, there is this:
You can also easily access these settings at any time by clicking on the “Cookie Preferences” in the footer of our websites. Another way in which you can communicate your cookie preferences to us is change the cookie settings in your browser.
To specifically request that we do not “sell” your personal information in situations that do not involve cookies, you can use our online form at https://support.avg.com/support_dsr?l=en or send your requests to firstname.lastname@example.org.
Please note, however, that we do not maintain the data in a manner that would allow us to link the information to your email, so we are not able to opt you out directly.
Why Do We Provide the “Do Not Sell” Link?
If you are a California resident, the California Consumer Privacy Act (“CCPA”) provides you with the right to opt out of the “sale” of your personal information.
Under the CCPA, “personal information” includes information that is not necessarily tied to your identity as an individual directly, but may be associated with your device. This covers identifiers such as IP addresses, web cookies, web beacons and mobile Ad IDs, among others. In many cases, this type of information is not associated with you, but there are unique identifiers that could be. Similarly, the term “sell” is defined to include not just selling in exchange for money, but also sharing or transferring personal information (including information that does not directly identify an individual as described above) in exchange for anything of value, which covers a much broader set of situations and types of exchanges. At the same time, certain things are not considered “sales,” such as cases when (1) personal information is shared with a service provider that is contractually prohibited from using the personal information for any purpose beyond the service specifically requested (“service provider exception”), or (2) when the consumer has directed a company to disclose the personal information (“consumer directed exception”).
Do We “Sell” Your Personal Information?
However, the CCPA’s broad definitions of “personal information” and “sale” may deem the common flow of information in the digital analytics and advertising ecosystem to be a sale. Like most companies that operate commercial websites and apps, we utilize online analytics to measure the ways users engage with our websites and apps. The insights these analytical tools provide then in turn, inform how we detect and fix bugs, measure usage of our website and apps to better understand how users interact with them and perform online advertising. In order to conduct these analyses and to facilitate online advertising, we contract with third parties that collect device identifiers and place tags, cookies, beacons, and similar tracking mechanisms on our websites/apps and on third-party websites/apps. For instance, we may request that a third party facilitate the placement of our ads on a particular website after a consumer has previously visited our websites. That third party would generally do this by placing a cookie on a user’s browser, which can then identify when a consumer uses the same browser to visit other websites. Similarly, where our websites or apps provide space for advertisements, a third party may use identifiers, such as cookies for websites or a device’s AdID for mobile apps, to facilitate real-time bidding by advertisers. On mobile apps, you can opt out of this processing by upgrading to a paid version of the same product or by uninstalling the product. Please note that on our websites, regardless of your choice concerning the use of your personal information, you will still see some advertising when such advertising does not involve the sale of your personal information.
Where we can reasonably ensure via contract that the third parties described above can and will use a cookie or a device identifier solely to provide the specific service we have requested, and that they will not use or share the data for other purposes, we will not deem that sharing a “sale.” In most cases, we’ve determined that our data analytics providers that measure the ways users engage with our websites and apps meet this standard and, accordingly, we will not block the sharing of an identifier with those service providers, even when you choose to opt out through the “Do Not Sell” link.
In some cases, though, we are not in complete control of how such identifiers are ultimately used by certain third parties (for example, this sometimes happens in the online advertising ecosystem). As a result, when we have a case like this, we can’t determine that the sharing of information with third parties falls within the service provider exception under the law and we will treat that scenario as a “sale”.
How Do We Maintain Your “Do Not Sell” Choice?
For our websites, if you set a “Do Not Sell” preference (via the cookie setting) that preference is specific to the site that you are visiting. Please be aware that the setting will work only if your browser is set to accept cookies. Likewise, if you clear your browser cookies, the cookie-based “Do Not Sell” setting will be erased, and you will need to reset the setting.