• General Privacy Policy

General Privacy Policy

 

As the world’s most trusted antivirus software company, we aim to defend you against threats in cyberspace. To do so, we may have to collect your personal data to provide you with the best weapons and the most up-to-date security. We do not take your trust for granted so we’ve developed a Privacy Policy that covers how we collect, use, disclose, transfer, and store your personal data.

This Privacy Policy was last updated on December 19, 2019.

Who We Are

This General Privacy Policy (“Privacy Policy”) applies to products and services of Avast Software s.r.o. and its affiliates (collectively “we,” “us” or “our”).

If you live in the European Economic Area, the Controller of your personal data is Avast Software s.r.o., which has its principal place of business at 1737/1A Pikrtova, Prague 4, Czech Republic, 140 00.

Privacy Policy Contents

This Privacy Policy describes how we handle and protect your personal data and the choices available to you regarding collection, process, access, and how to update, correct and delete your personal data. Additional information on our personal data practices may be provided in product settings, contractual terms, or notices provided prior to or at the time of data collection. 

Please refer to our Products Policy describing specifics of personal data processing within our products and services available on each brand’s website (Avast, AVG, CCleaner).

This Privacy Policy is intended for you if you are a user of our products and services. If you are a business partner, the privacy notice that applies to you is located here: Business partner policy.

Personal Data We Process

Personal data refers to any information relating to an identified or identifiable natural person (“Personal Data”). 

We may collect data or ask you to provide certain data when you visit and use our websites, products and services. The sources from which we collect Personal Data include: 

  • Data collected directly from you or your device relating to an identified or identifiable natural person (“Data Subject”), and may include direct identifiers such as name, address, email address, phone number, and online or indirect identifiers such as login account number, login password, marketing preferences, social media account, payment card number, or IP address;
  • If we link other data relating to you with your Personal Data, we will treat that linked data as Personal Data; and 
  • We may also collect Personal Data from trusted third-party sources such as distributors, resellers, app stores, contact centers, and engage third parties such as marketing, survey, analytics or software suppliers to collect Personal Data to assist us.

We organize the Personal Data we process into these basic categories: Billing Data, Account Data, and Product Data.

Billing Data includes your name, email address, masked credit card number, license information and in certain circumstances, your billing address and your phone number. In most circumstances, you purchase our products and services from a trusted third-party service provider, reseller, or app store. In those circumstances, your Billing Data is processed by the relevant third party and we only receive a subset of this data to keep proper business records. In these instances, see below an example of Billing Data and what we use it for:

Billing data

What we use it for

Email address

To send you purchase receipts

Masked credit card number

To process the payment and billing records

License key

To identify a specific license for a follow-up actions such as renewal or troubleshooting

License type

To enable features based on the purchased license

Renewability

To check if a given subscription can be renewed

Date of expiry

To check whether an account is valid

Account Data includes information needed to set up and customize an account, such as your email address and username, and information connected with our services, such as license keys. For some of our products or some of their functions creating an account is necessary. See below an example of Account Data and what we use it for:

Account data

What we use it for

Email address

To send you communications regarding your license and support

Username

To manage your account and facilitate your login into the service

Subscription renewal date

To tell us until when the account is valid

Trial User

To add a trial period before the account is charged

An account is also necessary for some features of our Forum. You have the option to provide additional information within your account such as personal texts, disclose your birth date, identify your gender, instant messaging number, messenger username, or website name and address, disclose your physical location, and select an avatar or personalized picture. Any information you provide here will be visible to other users (including your total number of posts, and posts per day, the date and time you registered, your local time, and the date and time of your last activity).

Product Data includes two sub-categories: 

  • Device Data includes information about the operating system; hardware; city/country of device; error logs; browser; network; applications running on the device, including our products; and
  • Service Data includes information about our product usage and events relating to use of our product by you such as malware samples and detections, information concerning URLs of websites, usage statistics (activation, crashes, scans, errors), IP address.

These sub-categories differ for each product and service. If you want more detail about Device and Service Data we process on a product basis, please refer to our Products Policy available on each brand’s website (Avast, AVG, CCleaner).

Why We Process Your Personal Data

We use your Personal Data for the following purposes and on the following grounds:

On the basis of fulfilling our contract with you or entering into a contract with you on your request, in order to:

  • Process purchase of our products or services from us, our partners or our trusted third- party service providers’ online stores;
  • Provision the download, activation, and performance of the product or service;
  • Keep our products or services up-to-date, safe and free of errors;
  • Verify your identity and entitlement to paid products or services, when you contact us for support or access our services;
  • Process your purchase transactions;
  • Update you on the status of your orders and licences;
  • Manage your subscriptions and user accounts; and
  • Provide you with technical and customer support.

On the basis of your consent, in order to:

  • Subscribe you to a newsletter;
  • Enable the provision of personalized ads in support of certain free products;
  • Enable use of your personal data to create a de-identified data set that is provided to Jumpshot to build trend analytics products and services.

We will always ask for your consent before any processing that requires it and provide you with necessary information through our Consent Policy or otherwise as applicable. 

On the basis of legal obligations, we process your Personal Data when it is necessary for compliance with a legal tax, accounting, anti-money laundering, legal order, or other obligation to which we are subject.

On the basis of our legitimate interest we will use your Personal Data for:

  • Communications about possible security, privacy and performance improvements and products that supplement or improve our purchased products and to optimize the content and delivery of this type of communication;
  • Product development, research and to implement product features and improvements, as well as product updates;
  • Third-party analytics to evaluate and improve the performance and quality of our products, services and websites and to understand usage trends, and analyze user acquisitions, conversions and campaigns;
  • Allow interoperability within our applications;
  • Secure our systems and applications;
  • Allow effective performance of our business by ensuring necessary internal administrative and commercial processes (e.g. finances, controlling, business intelligence, legal & compliance, information security etc.); and
  • Establishing, exercising or defending our legal rights.

We have balanced the interests for the above mentioned processing operations. You have the right to object, on grounds relating to our particular situation, to those processing operations. For more details please see section Your Privacy Rights.

Balancing Legitimate Interests

Before relying on our legitimate interests, we balanced them against your interests and made sure they are compelling enough and will not cause any unwarranted harm. With respect to the purposes below we consider necessary to explain what our interests are in detail.

Systems, Apps and Network Security

We process Personal Data for network and information security purposes. In line with EU data protection law, organizations have a recognized legitimate interest in collecting and processing Personal Data to the extent strictly necessary and proportionate for the purposes of ensuring network and information security. This primarily covers the ability of a network or of an information system to resist events, attacks or unlawful or malicious actions that could compromise the availability, authenticity, integrity and confidentiality of stored or transmitted data, or the security of the related services offered by, or accessible via those networks and systems.

Both as an organization in our own right, and as a provider of cybersecurity technologies and services which may include hosted and managed cybersecurity technology services, it is necessary for the functionality of our systems, products and services and in our legitimate interests as well as in our users’, to collect and process Personal Data to the extent strictly necessary and proportionate for the purposes of ensuring the security of our own, and of our users’ networks, devices, and information systems. This includes the development of threat intelligence resources aimed at maintaining and improving on an ongoing basis the ability of networks and systems to resist unlawful or malicious actions and other harmful events (“cyber-threats”). 

The Personal Data we process for said purposes includes, without limitation, network traffic data related to cyber-threats such as:

  • Sender email addresses (e.g., of sources of SPAM);
  • Recipient email addresses (e.g., of victims of targeted email cyberattacks including phishing);
  • Reply-to email addresses (e.g., as configured by cybercriminals sending malicious email);
  • Filenames and execution paths (e.g., of malicious or otherwise harmful executable files attached to emails);
  • URLs and associated page titles (e.g., of web pages broadcasting or hosting malicious or otherwise harmful contents); and/or
  • IP addresses (e.g., of web servers and connected devices involved in the generation, distribution, conveyance, hosting, caching or other storage of cyber-threats such as malicious or otherwise harmful contents).

Depending on the context in which such data is collected, it may contain Personal Data concerning you or any other Data Subjects. However, in such cases, we will process the data concerned only to the extent strictly necessary and proportionate to the purposes of detecting, blocking, reporting (by removing any personally identifiable elements) and mitigating the cyber-threats of concern to you, and to secure your network, device and systems. When processing Personal Data in this context, we do not seek to identify a Data Subject.

In-product and Email Messages

We have a legitimate interest for messaging our users about possible security, privacy and performance improvements and products that supplement or improve purchased products.

If you are our customer, we feel a responsibility to inform you about security and utility improvements and possible problems to your device and software that go beyond our product that is installed and provide you with effective solutions relevant to these problems, which may include also our own solutions. We thus have legitimate interest to optimize the content and delivery of this type of communication to you so that you will be most likely to find them relevant and non-intrusive at the same time.

New Product Development

We have a legitimate interest to use necessary Personal Data to develop new products or features so that we are able to provide you with state-of-the-art security, privacy and performance products.

Third-party Analytics (user acquisition, user interactions) 

We have a legitimate interest to use necessary Personal Data for third-party analytics to understand user conversions, acquisitions and campaign performance through various distribution channels, and users’ download, activation and interactions with our products because these analytics help us maintain functionality, effectiveness, security and reliability of our products and business activities.

How We Process Your Personal Data

We do our best to disconnect or remove all direct identifiers from the Personal Data that we use:

  • For free versions, this disconnection or removal of identifiers begins when the products and services are initially activated. For paid users we keep Billing Data in a separate database and minimize its use for anything other than handling payments and our own finances. 
  • For both paid and free versions, we continuously monitor for, minimize, disconnect and remove all direct identifiers during the normal performance of the products and services.

Processing of IP Addresses

For paid products including antivirus, virtual private network (“VPN”), and performance, your IP address is collected at the time at which your product or service is being provided, for the purpose of facilitating our billing process. Specifically, our third-party billing partner will collect your IP address for its billing process; we do not store the IP address from this process.

For free and paid products including antivirus, your IP address is also processed for the purpose of downloading certain products and malware detection. 

Please refer to our Products’ Policy for specific use of IP address by our products and services.

No Automated Decision-Making, Including Profiling

We do not take any decisions involving the use of algorithms or profiling that significantly affects you.

How We Disclose Your Personal Data

We only disclose your Personal Data as described below, within our group, with our partners, with service providers that process data on our behalf and with public authorities, as required by applicable law. Processing is only undertaken for the purposes described in this Privacy Policy and the relevant Products Policy sections. If we disclose your Personal Data, we require its recipients to comply with adequate privacy and confidentiality requirements, and security standards.

Payment processors

If you opt to pay for use of our services, we will use a third party payment processor to take payment from you. These third parties are properly regulated and authorized to handle your payment information and are prohibited from using your Personal Data for any other purposes other than arranging these services for us. However, they are independent controllers of your data with their own responsibility.

These are our long-term payment processors:

Payment Processor

Link to Privacy Policy

Location

Digital River

https://www.digitalriver.com/privacy-policy/

US, Ireland

Softline

https://allsoftglobal.com/en/privacy-policy/

Cyprus

Nexway

https://www.nexway.com/legal-notice-privacy/

Germany, France, USA

Cleverbridge

https://www.cleverbridge.com/?scope=opprivacy

Germany, USA, Japan, Taiwan, Malta

DLocal (only for non-EEA customers)

https://dlocal.com/legal/privacy-policy/

US, UK, Malta

Net Distribution Services (only for non-EEA customers)

---

India

Paypal 

https://www.paypal.com/en/webapps/mpp/ua/privacy-full

US, Ireland

Google Play Store (for mobile apps)

https://policies.google.com/privacy

US, Ireland

Apple Store (for mobile apps)

https://www.apple.com/legal/privacy/

US, Ireland

Your Billing Data is processed by the payment processor from whom you purchased the product. Your data is processed according to the relevant processor’s privacy policy. 

Service Providers

We may use contractors and service providers to process your Personal Data for the purposes described in this Privacy Policy and Products Privacy Policy. We contractually require service providers to keep data secure and confidential. 

Such service providers may include in particular contact centers, professional consultants (including for defence or exercise of our rights), and marketing/survey/analytics/software suppliers.

Sometimes these service providers, for example, our distributors, resellers, and app store partners, will be independent controllers of your data and their terms and conditions, end user license agreements (“EULA”) and privacy statements will apply to such relationships.

Advertising Companies

To be able to offer our products and services for free, we serve third-party ads of advertising companies in our products for mobile devices. To enable the ad, we embed a software development kit (“SDK”) provided by an advertising company into the product, which then collects Personal Data in order to personalize ads for you. 

Please note that only few of our free products serve third-party ads. You will be asked for consent during the installation process of such product. For further information, including the exact scope of processed Personal Data and names of relevant products, please refer to our Consent Policy which includes the list of our advertising partners and their privacy policy.

Trend Analytics

We have partnered with our subsidiary, Jumpshot Inc., that uses stripped and de-identified data to build products and services that provide trend analytics for companies. For more information please refer to our Consent Policy.

Distributors, Resellers

We may provide your Personal Data to our partners for the purpose of distribution, sale or management of our products. Our partners may use your Personal Data to communicate with you and others about our products or services. In addition, you purchase our products directly from our distributor, a reseller, or an app store. Because your relationship in these cases is with that distributor, reseller or an app store, such third party will also process your Personal Data.

Cookies Providers

Our websites use cookies to personalize your experience on our sites, tell us which parts of our websites people have visited, help us measure the effectiveness of campaigns, and give us insights into user interactions and user base as a whole so we can improve our communications and products. While using our websites, you will be asked to authorize the collection and use of data by cookies according to the terms of the Cookie Policy.

Analytics Tool Providers

We use analytical tools, including third-party analytical tools, which allow us to, among other things, identify potential performance or security issues with our products, improve their stability and function, understand how you use our products, and websites, so that we can optimize and improve your user experience, as well as evaluate and improve our campaigns. We use Service and Device data for analytics.

While we generally prefer using our own analytical tools, we sometimes need to partner with other parties, which have developed and provide us with their own tools and expertise. Below, we list these partners and tools and their privacy policies.

Tool (provider)

Type of Analytics

Link to Privacy Policy

Location

   

https://support.google.com/analytics/answer/6004245

US, Ireland

Google Analytics (Google)

user behaviour

https://policies.google.com/privacy

 
   

https://support.google.com/analytics/answer/6366371?hl=en&ref_topic=2919631

 

Firebase Analytics (Google)

user behaviour (advanced features like A/B testing, predictions)

https://firebase.google.com/support/privacy/

US, Ireland

   

https://policies.google.com/privacy

 

Firebase Crashlytics (Google)

crash reporting

https://try.crashlytics.com/terms/privacy-policy.pdf

US, Ireland

   

https://policies.google.com/privacy

 

AppsFlyer (AppsFlyer)

user acquisition

https://www.appsflyer.com/privacy-policy/

Germany

Adjust (Adjust)

user acquisition

https://www.adjust.com/terms/privacy-policy/

Germany

HockeyApp (Microsoft)

crash reporting

https://privacy.microsoft.com/en-us/PrivacyStatement

US, Ireland

Mixpanel (Mixpanel Inc.)

user behaviour

https://mixpanel.com/legal/privacy-policy/

US

Please note that not all of our products use all of these third-party analytics tools. Analytics tolls that we use for diagnosing your product are necessary for service provision. You will find relevant tools listed under each product in our Products Policy. 

Public Authorities

In certain instances, it may be necessary for us to disclose your Personal Data to public authorities or as otherwise required by applicable law. No Personal Data will be disclosed to any public authority except in response to:

  • A subpoena, warrant or other process issued by a court or other public authority of competent jurisdiction;
  • A legal process having the same consequence as a court-issued request for data, in that if we were to refuse to provide such data, it would be in breach of local law, and it or its officers, executives or employees would be subject to liability for failing to honor such legal process;
  • Where such disclosure is necessary for us to enforce its legal rights pursuant to applicable law; or
  • A request for data with the purpose of identifying and/or preventing credit card fraud.

Mergers, Acquisitions and Corporate Restructurings

Like any other company, we too go through its own cycle of growth, expansion, streamlining and optimization. Its business decisions and market developments therefore affect its structure. As a result of such transactions, and for maintaining a continued relationship with you, we may transfer your Personal Data to a related affiliate.

If we are involved in a reorganization, merger, acquisition or sale of our assets, your Personal Data may be transferred as part of that transaction. We will notify you of any such deal and outline your choices in that event, when applicable.

Cross-Border Transfers of Personal Data among Avast Entities and to Third-Party Vendors

We are a global business that provides its products and services all around the world. In order to reach all of our users and provide all of them with our software, we operate on an infrastructure that spans the globe. The servers that are part of this infrastructure may therefore be located in a country different than the one where you live. In some instances, these may be countries outside of the European Economic Area (“EEA”). Regardless, we provide the same GDPR-level of protection to all Personal Data it processes.

At the same time, when we transfer Personal Data outside of the EEA, we always make sure to put in place appropriate and suitable safeguards, such as standardized contracts approved by the European Commission or specialized regimes such as Privacy shield, which legally bind the receiving party to adhere to a high level of protection, and to ensure that your data remains safe and secure at all times and that your rights are protected.

Situations where we transfer Personal Data outside of the EEA include provision of our products and services, processing of transactions and your payment details, and the provision of support services. Further, an outside-EEA transfer may also occur in case of a merger, acquisition or a restructuring, where the acquirer is located outside of the EEA (see the Mergers, Acquisitions and Restructurings section).

How We Protect Your Personal Data

We maintain administrative, technical, and physical safeguards for the protection of your Personal Data.

Administrative Safeguards

Access to the Personal Data of our users is limited to authorized personnel who have a legitimate need to know based on their job descriptions, for example, employees who provide technical support to end users, or who service user accounts. In the case of third-party contractors who process personal information on our behalf, similar requirements are imposed. These third parties are contractually bound by confidentiality clauses, even when they leave. Where an individual employee no longer requires access, that individual's credentials are revoked.

Technical Safeguards

We store your personal information in our database using the protections described above. In addition, we utilize up-to-date firewall protection for an additional layer of security. We use high-quality antivirus and anti-malware;software, and regularly update our virus definitions. Third parties who we hire to provide services and who have access to our users' data are required to implement privacy and security practices that we deem adequate.

Physical Safeguards

Access to user information in our database by Internet requires using an encrypted VPN, except for email which requires user authentication. Otherwise, access is limited to our physical premises. Physical removal of Personal Data from our location is forbidden. Third-party contractors who process Personal Data on our behalf agree to provide reasonable physical safeguards.

Proportionality

We strive to collect no more Personal Data from you than is required by the purpose for which we collect it. This, in turn, helps reduce the total risk of harm should data loss or a breach in security occur: the less data we collect, the smaller the overall risk.

Children’s Privacy

We have products and services designed specifically to assist you as a parent by providing child online protection features. In such cases, we will only collect and process Personal Data related to any child under 13 years of age, which you choose to disclose to us or otherwise instruct us to collect and process. Details about this processing is included in our Products Policy. Please refer to the specific applicable notices for this information.

How Long We Store Your Personal Data

We will hold your Personal Data on our systems for the following periods: 

  • For Billing Data, for as long as we have a legal obligation or for our legitimate interests in establishing legal rights; 
  • For Account Data, for as long as you maintain your account; 
  • For Product Data, only as long as necessary for the purposes of a particular product or service. We use rolling deletion periods which means we regularly delete collected data in the given periods starting from the collection of that respective data. The rolling deletion periods for Product Data are not longer than six years. You can find specific rolling deletion periods for each of our products and their purposes in our Products Policy. Please note that when you uninstall our product, processing for service provision, in-product messaging, third-party analytics and third-party ads, if applicable, dependent on the installed product shall cease. After the uninstallation, we will continue to process your Product Data for statistical purposes for up to six years, however, we have appropriate measures in place, including pseudonymization. 

Storage of Your Personal Data

The data we collect from you may be stored, with risk-appropriate technical and organizational security measures applied to it, on in-house as well as third-party servers in the Czech Republic, in the United States, as well as anywhere we or our trusted service providers and partners operate. 

In all cases, we follow generally accepted standards and security measures to protect the personal data submitted to us, both during transmission and once we receive it. 

Your Privacy Rights

You have the following rights regarding the processing of your Personal Data:

  • Right to information - Right to receive information about the processing of your Personal Data, prior to processing as well as during the processing, upon request.
  • Right of access - Aside from the information about the processing of your Personal Data, you have the right to receive a copy of your Personal Data undergoing processing.
  • Right to rectification - We should process accurate Personal Data; if you discover inaccuracy, you have the right to seek rectification of inaccurate Personal Data. 
  • Right to erasure ("right to be forgotten") - You have the right to erasure of your Personal Data, but only in specific cases stipulated by law, e.g., if there is no legally recognized title on our part for further processing of your Personal Data (incl. protection of our legitimate interests and rights).
  • Right to data portability - The right to receive Personal Data which you have provided and is being processed on the basis of consent or where it is necessary for the purpose of conclusion and performance of a contract, in machine-readable format. This right applies exclusively to Personal Data which processing is carried out by automated means.
  • Right to object - Applies to cases of processing carried out in legitimate interest. You have the right to object to such processing, on grounds relating to your particular situation, and we are required to assess the processing in order to ensure compliance with all legally binding rules and applicable regulations. In case of direct marketing, we shall cease processing Personal Data for such purposes after the objection. 
  • Right to withdraw consent - In the case of processing based on your consent, as specified in our Consent Policy, you can withdraw your consent at any time, by using the same method (if technically possible) you used to provide it to us (the exact method will be described in more detail with each consent when you provide it). The withdrawal of consent shall not affect the lawfulness of processing based on your consent before its withdrawal.
  • Right to restriction of processing - You have the right to restriction of processing of your Personal Data if: You are contesting the accuracy of your Personal Data, for a period enabling us to verify the accuracy of your Personal Data; the processing is unlawful and you oppose the erasure of the Personal Data and request the restriction of its use instead; we no longer need the Personal Data for the purposes of the processing, but they are required by you for the establishment, exercise or defence of legal claims; or you have objected to processing of your Personal Data, and there is a pending verification whether our legitimate grounds override your interests. 
  • Right to contact supervisory authority, court - You may contact and lodge a complaint with the supervisory authority – The Office for Personal Data Protection (Czech: Úřad na ochranu osobních údajů – www.uoou.cz) or your local authority or a relevant court.

The fulfillment of data subject rights listed above will depend on the category of Personal Data and the processing activity. In all cases, we strive to fulfill your request.

We will action your request within one month of receiving a request from you concerning any one of your rights as a Data Subject. Should we be inundated with requests or particularly complicated requests, the time limit may be extended to a maximum of another two months. If we fail to meet these deadlines, we would, of course, prefer that you contact us to resolve the situation informally.

Where requests we receive are manifestly unfounded or excessive, in particular because of their repetitive character, we may either: (a) charge a reasonable fee taking into account the administrative costs of providing the information or communication or taking the action requested; or (b) refuse to act on the request.

For the free versions, we do not and will not maintain, acquire or process additional information solely in order to identify the users of our free products and services. This is simply not necessary for the free versions of our products to be provided to you and function. 

This means, when you use a free version of our products and services, you may contact us with a request concerning your Personal Data. Please note, consistent with our privacy by design, privacy by default and minimization practices, we may not be able to identify you in connection with your Product Data about your specific free products and services. If such a situation occurs, please go to your product settings and explore your options. 

Your Choices in products

You can make certain choices about how your data is used by us by adjusting the privacy settings of the relevant product. Please check your product settings to set your privacy preferences there.

Privacy Portal

In order to make it easier for you to reach out to us and obtain the necessary information and action changes, corrections or deletions of your Personal Data, we have decided to provide you with a portal, which can show you the Billing Data and Account Data we have collected from you as well as your email preferences. 

Non-EU Jurisdictions

Residents of the Russian Federation

We collect and process Personal Data on the territory of the Russian Federation in strict compliance with the applicable laws of the Russian Federation.

We collect and process Personal Data (including sharing it with third parties) only upon the consent of the respective individuals, unless otherwise is provided for by the laws of the Russian Federation. You will be asked to grant your consent by ticking the respective box / or clicking “I accept” button or through similar mechanism prior to having access to the site, and/or when submitting or sharing the Personal Data we may request. We collect and use your Personal Data only in the context of the purposes indicated in the consent to processing of Personal Data.

We (directly or through third-party contractors specifically authorized by us) collect, record, systematize, accumulate, store, actualize (update and amend), extract Personal Data of the Russian Federation citizens with the use of databases located on the territory of the Russian Federation, except as otherwise permitted by Russian data protection legislation. We may process Personal Data of Russian citizens using databases located outside of the Russian Federation subject to compliance with Russian data protection legislation.

We undertake all the actions necessary to ensure security of your Personal Data.

You are legally entitled to receive information related to processing your Personal Data. To exercise this right, you have to submit a request to contacts indicated below in the Contact Us section.

You have the right to revoke the consent at any time by sending us an e-mail at contacts indicated below in the Contact Us section. Once we receive the revocation notice from you we will stop processing and destroy your Personal Data, except as necessary to provision the contract or service to you. However, please note once you have revoked your consent, we may not be able to provide to you the products and services you request, and may not be able to ensure proper work of our products.

We do not transfer your Personal Data to the countries that under Russian law are not deemed to provide adequate protection to the individuals’ rights in the area of data privacy.

We do not offer, sell or otherwise make available our products or services that have access to, collect and process (or allow us to do the same) Personal Data of third parties in the Russian Federation without the consent of such third parties.

If any provisions of this Policy contradict the provisions of this section, the provisions of this section shall prevail.

California Privacy Rights

This section applies to California, USA residents: 

Information Notice

Categories of collected personal information 

You can see all categories of collected personal information listed in the section Personal Data We Process.

Sources from which the personal information is collected

You can find information about the sources of data in the section Personal Data We Process.

Business or commercial purpose for collecting or selling personal information

You can find all purposes of processing your personal information listed in the section Why We Process Your Personal Data.

Categories of third parties with whom the business shares personal information

You can find all categories of recipients of personal information listed in the section How We Diclose Your Personal Data. We do not sell (as such term is defined in the California Consumer Privacy Act) your personal information we collect (and will not sell it without providing a right to opt out). Please note that we do use third-party cookies for our advertising purposes as further described in our Cookie Policy.

Your Rights

You have the right to:

  • know what personal information is being collected about you; 
  • know whether your personal information is sold or disclosed and to whom; 
  • say no to the sale of personal information (right to opt out);
  • request deletion of your personal information; information will be deleted if no exception applies (including our right to defend our lawful interests);
  • access your personal information; specific information shall be provided in a portable and, to the extent technically feasible, in a readily useable format but not more than twice in a 12-month period; 
  • equal service and price, even if you exercise your privacy rights.

Under California Civil Code § 1798.83, we are required to disclose to consumers the following information upon written request: (1) the categories of personal information that we have disclosed to third parties within the prior year, if that information was subsequently used for marketing purposes; and (2) the names and addresses of all such third parties to whom such personal information was disclosed. We hereby disclose that we have not disclosed any such personal information as defined by the California Civil Code § 1798.83 regarding any California resident during the one-year period prior to the effective date of this Privacy Policy.

Right To Opt Out Of Sale

If your personal information is subject to a sale you have the right to opt out from that sale through a link to a website which will be given to you at the moment of collection of personal information. We will respect your decision to opt out for at least 12 months before asking you again to authorize the sale of your personal information.

Request Submission

You can submit your requests using contacts indicated below in the Contact Us section. If you are a California resident under the age of 18, you may be permitted to request the removal of certain content that you have posted on our websites. You can also designate an authorized agent to exercise these rights on your behalf.

Contact Us

To exercise any of your rights, or if you have any other questions or complaints about our use of your Personal Data and its privacy, write our Privacy Team through the most convenient channel below:

We are registered as Avast Software s.r.o. and our registered address is Pikrtova 1737/1a, 140 00 Prague 4, Nusle, Postal Code 140 00, Czech Republic. You can always reach us by email at https://support.avast.com/en-usm. Please type “PRIVACY REQUEST” in the message line of your email so we can have the appropriate member of the AVG team respond.

If you prefer, you can send paper mail to AVAST Software s.r.o., Pikrtova 1737/1a, 140 00 Prague 4, Czech Republic. Be sure to write "Attention: PRIVACY" in the address so we know where to direct your correspondence.

Data Protection Officer

As required under the GDPR, we have a data protection officer (DPO) to monitor our compliance with the GDPR, provide advice where requested and cooperate with supervisory authorities. You can contact our data protection officer via dpo@avg.com.

Changes to this Privacy Policy

We reserve the right to revise or modify this Privacy Policy. In addition, we may update this Privacy Policy to reflect changes to our data practices. If we make any material changes we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on this website prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.


AVG User Products Policy

 

Antivirus

Antivirus for Desktop (Mac and Windows)

Official Product Name

AVG AntiVirus for Mac, AVG Internet Security for Mac, AVG Antivirus Free, AVG Internet Security (collectively as “Antivirus for Desktop”)

Core Functionality

The Antivirus for Desktop provides protection against malicious software by performing key tasks, such as pinpointing specific files for the detection of malwares, scheduling automatic scans, and securing your device against malware.

What are Product’s Main Features

  • CommunityIQ is a threat monitoring service for Windows and Mac which sends information about a threat detected in your device to our server, so we can observe how the threat spreads and block it. This is vital for the functioning of our Antivirus and our ability to keep your device secure. 
  • CyberCapture detects and analyses rare, suspicious files on your Windows. If you attempt to run such a file, CyberCapture locks the file from your PC and sends it to our Threat Lab where it is analysed in a safe, virtual environment. All files are uploaded over an encrypted connection, which means your data is inaccessible to hackers. 
  • File Reputation provides a real-time comparison with up-to-date list of malware database of executable files sourced from users of Windows who agree to participate in the service. FileRep processes files or their hashed versions to evaluate which are infectious and updating virus databases. 
  • Online Security is a browser plug-in which needs to be specifically activated which checks if the site isn’t malicious or phishing.
  • Browser Cleanup is a module inside Antivirus for Desktop (Windows) which inspects the browser extensions of most browsers, tries to identify malicious extensions and offers to remove them. Browser Cleanup is on by default. You may opt-in for processing of cookie data (internal identifier (GUID), product version, time information, source browser, cookie domain, cookie name, cookie value) for trend analytics purposes, we consequently provide this data set from a free version of this product to enable Jumpshot to build products and services. For more information please see our Consent Policy.
  • Web Shield scans data that is transferred when you browse the internet in real-time to prevent malware from being downloaded and run on your computer. By default, Web Shield is configured to provide optimal protection when switched on. If Web Shield function is active and you opt-in for processing of data (internal identifier (GUID), product version, time information, stripped URLs (unless cached), carefully selected aspects of certain pages without identifiers, selected requests) for trend analytics purposes, we consequently provide this data set in a stripped and de-identified form from a free version of this product to enable Jumpshot to build products and services. For more information please see our Consent Policy.
  • Antispam is an additional feature which may be activated by you in case you want to be protected against unwanted emails (spam). The software to function must collect information contained in emails, including their content, which were reported by you as spam in order to determine whether an email is spam or not. Please note that Antispam is service of MailShell which is licensed to us, and thus it is this third party which assesses the email and makes this decision. 

Personal Data We Process

While using Antivirus for Desktop, we collect and process the following Service and Device Data (in addition to Account Data and Billing Data, if relevant):

Service Data

What we use it for and for how long

Identifier of the content (message) being delivered

Service Provision (36 months)

  • To monitor service functionality 

In-product Messaging (6 months)

  • To inform users of problems that will not be solved by the currently installed product and to offer users a solution to the detected problem

Third-party Analytics (50 months)

  • To monitor messaging performance

IP address 

Service Provision (36 months)

  • To detect the approximate location of malicious software. For free Antivirus, IP address is replaced at activation with city/country. For free and paid Antivirus, it is a part of malware infection file replaced in 30 days with city/country

Malware samples

Service Provision (36 months)

  • For protection, detection, blocking, quarantining and deleting of malicious software

Detections 

Service Provision (36 months)

  • For protection, detection, blocking, quarantining and deleting of malicious software

URLs and referrers

Service Provision (36 months)

  • For protection, detection, blocking, quarantining and deleting of malicious software

Trend Analytics (36 months)

  • If Web Shield is activated and consent was granted, we share stripped and de-identified URLs with Jumpshot for trend analytics

Events and product usage

Service Provision (36 months)

  • To ensure continuous functionality (installations, versions, updates, settings) and map how users interact with our product 

In-product Messaging (24 months)

  • To inform users of problems that will not be solved by the currently installed product and to offer users a solution to the detected problem

Third-party Analytics (50 months)

  • To better understand our users’ behavior

New Product Development (36 months)

  • To introduce a new feature or product based on previous experience

Trend Analytics (36 months)

  • If Web Shield is activated and consent was granted, we share product version, time information and carefully selected pages aspects without identifiers with Jumpshot for trend analytics

Device Data

What we use it for and for how long

Internal online identifiers (GUID, Device ID)

Service Provision (36 months)

  • For ensuring continuous functionality and breaking down entries in database

In-product Messaging (24 months)

  • To inform users of problems that will not be solved by the currently installed product and to offer users a solution to the detected problem

Third-party Analytics (50 months)

  • To better understand our users’ behavior

New Product Development (36 months)

  • To introduce a new feature or product based on previous experience

Trend Analytics (36 months)

  • If Web Shield is activated and consent was granted, we share GUID with Jumpshot for trend analytics

Information concerning computer or device

Service Provision (36 months)

  • To check for compatibility issues in automated crash dumps

In-product Messaging (6 months)

  • To inform users of problems that will not be solved by the currently installed product and to offer users a solution to the detected problem

Third-party Analytics (50 months)

  • To better understand users’ behavior

New Product Development (36 months)

  • To introduce a new feature or product based on previous experience

Location

Service Provision (36 months)

  • To set up a proper product language version for Windows

In-product Messaging (6 months)

  • To inform users of problems that will not be solved by the currently installed product and to offer users a solution to the detected problem

Third-party Analytics (50 months)

  • To better understand users’ behavior based on approximate location

New Product Development (36 months)

  • To introduce a new feature or product based on approximate location

Applications - other security SW / antiviruses present

Service Provision (36 months)

  • To determine how Antivirus should behave (e.g. if it should be activated in Windows Security Centre or not, whether it should run in passive or active mode)

Applications on the device

Service Provision (36 months)

  • For formulating rules of how Antivirus should behave in relation to other SW installed (e.g. exceptions in scanning, filtering, notifications, applying Do not Disturb rules)

In-product Messaging (6 months)

  • To inform users of problems that will not be solved by the currently installed product and to offer users a solution to the detected problem

Other our products/licenses on the device and their status

Service Provision (36 months)

  • To recognize what features should be enabled or disabled, what product should be installed or uninstalled 

In-product Messaging (6 months)

  • To inform users of problems that will not be solved by the currently installed product and to offer users a solution to the detected problem

Internet and connection / Network data / Number of devices on Network

Service Provision (36 months)

  • For security prerequisites (e.g. DNS settings check, port restrictions enabling or disabling Security status check of devices on the network)

In-product Messaging (6 months)

  • To inform users of problems that will not be solved by the currently installed product and to offer users a solution to the detected problem

New Product Development (36 months)

  • To introduce a new feature or product based on previous experience

Browsers (installed, default)

Service Provision (36 months)

  • For opening content in given browser

In-product Messaging (6 months)

  • To inform users of problems that will not be solved by the currently installed product and to offer users a solution to the detected problem

Third-party Analytics (50 months)

  • To better understand users’ behavior

New Product Development (36 months)

  • To introduce a new feature or product based on previous experience

The third-party analytics tools we use for Antivirus for Desktop is Google Analytics. For further information regarding our third-party analytics partner, including its privacy policy, please refer to our Privacy Policy.

Antivirus for Mobile (Android)

Official Product Name

AVG AntiVirus Free for Android, AVG AntiVirus Pro for Android (collectively as “Antivirus for Mobile (Android)”) 

Core Functionality

Antivirus for Mobile (Android) provides people with essential mobile security with added privacy and performance-boosting features. Block malware, check the safety of installed apps, scan public Wi-Fi networks for possible security weaknesses, and locate your phone if it becomes lost or stolen — all with a single app.

What are Product’s Main Features

  • Security Scan scans your device and informs you about security risks.
  • Wi-Fi Security and Speed Check enables you to scan your network for vulnerabilities, and tests the speed of the network.
  • Web Shield scans all data that is transferred over the network in real-time to prevent malware. If Web Shield is activated and you opt-in for processing of Clickstream data (internal identifier (GUID), product version, approximate location, together with stripped URLs and information related to the URL of sites you visit online) for trend analytics purposes, we consequently provide this data set in a stripped and de-identified form from a free version of this product to Jumpshot to build its products and services.
  • Anti-theft is designed to protect your private mobile data and help you recover your device in case of loss or theft. 
  • App Locking is a paid feature, which protects your sensitive apps with a PIN, pattern, or fingerprint. 
  • App Insights provides information about how much time you spend using each app and allows you to view which permissions are required by each of your installed apps.
  • Boost RAM to kill any apps running in the background of your device. 
  • Clean Junk analyzes the space on your device and displays the amount of storage space that is being used by junk files. 
  • Data Usage monitors your data consumption and helps you avoid additional charges by notifying you when you approach the limit. 
  • Photo Vault allows you to protect access to your photos with a PIN code.

Personal Data We Process

While using Antivirus for Mobile (Android), we collect and process the following Service and Device Data (in addition to Account Data and Billing Data, if relevant):

Service Data

What we use it for and for how long

Identifier of the content (message) being delivered

Service Provision (36 months)

  • To monitor service functionality 

In-product Messaging (6 months)

  • To inform users of problems that will not be solved by the currently installed product and to offer users a solution to the detected problem

Third-party Analytics (50 months)

  • To monitor messaging performance

IP address

Service Provision (36 months)

  • To detect the approximate location of malicious software. For free Antivirus, IP address is replaced at activation with city/country. For free and paid Antivirus, it is a part of malware infection file replaced in 30 days with city/country

Malware samples 

Service Provision (36 months)

  • For the functionality of malware scanning

Detections 

Service Provision (36 months)

  • For the functionality of malware scanning

Information concerning URLs of websites visited (malicious and non-malicious) and referers (previous page with link to malware-hosting site)

Service Provision (36 months)

  • For Web Shield feature’s detection of malicious websites

Trend Analytics (36 months)

  • If Web Shield is activated and consent was granted, we share stripped and de-identified URLs with Jumpshot for trend analytics

Events and product usage

Service Provision (39 months)

  • To ensure continuous functionality (installations, versions, updates, settings) and map how users interact with our product

In-product Messaging (24 months)

  • To inform users of problems that will not be solved by the currently installed product and to offer users a solution to the detected problem

Third-party Analytics (50 months)

  • To better understand our users’ behavior and users’ acquisition

New Product Development (36 months)

  • To improve the user's overall experience by developing new features and products

Trend Analytics (36 months)

  • On the basis of granted consent, we share product version, time information and app IDs with Jumpshot for trend analytics

Device Data

What we use it for and for how long

Online identifiers (GUID, Device ID (Android ID), Advertising ID)

Service Provision (36 months)

  • To ensure functionalities of the product and its features

In-product Messaging (24 months)

  • To inform users of problems that will not be solved by the currently installed product and to offer users a solution to the detected problem

Third-party Analytics (50 months)

  • To better understand our users’ behavior

New Product Development (36 months)

  • To recognize reinstalls of the app on the same device

Trend Analytics (36 months)

  • On the basis of granted consent, we share GUID with Jumpshot for trend analytics

Third-party Ads (not stored after provision)

  • We process Advertising ID only for IronSource which allows it to place advertisements

Information concerning computer or device (carrier, OS version, OS build number, Hardware ID, device model, device brand, device manufacturer, device API level)

Service Provision (36 months)

  • To ensure functionalities of the product and its features

In-product Messaging (6 months)

  • To inform users of problems that will not be solved by the currently installed product and to offer users a solution to the detected problem

Third-party Analytics (50 months)

  • To better understand users’ behavior 

New Product Development (36 months)

  • To improve the user's overall experience by developing new features and products

Location (city/country, longitude and latitude)

Service Provision (36 months)

  • For Anti-theft functionality to locate a lost phone or track its locations per users request
  • Delivering geo-specific changes to app’s configuration (both local or remote)

In-product Messaging (6 months)

  • To inform users of problems that will not be solved by the currently installed product and to offer users a solution to the detected problem

Third-party Analytics (50 months)

  • To better understand users’ behavior based on approximate location

New Product Development (36 months)

  • To introduce a new feature or product based on approximate location

Trend Analytics (36 months)

  • If Web Shield is activated and consent was granted, we share approximate location with Jumpshot for trend analytics

Applications

Service Provision (36 months)

  • To define rules how Antivirus should behave 

In-product Messaging (6 months)

  • To inform users of problems that will not be solved by the currently installed product and to offer users a solution to the detected problem

Internet and connection

Service Provision (36 months)

  • For security prerequisites

In-product Messaging (6 months)

  • To inform users of problems that will not be solved by the currently installed product and to offer users a solution to the detected problem

Third-party Analytics (50 months)

  • To better understand users’ behavior 

New Product Development (36 months)

  • To introduce a new feature or product based on previous experience

These are the third-party analytics tools we use for Antivirus for Mobile (Android):

  • Google Analytics
  • Google Firebase and Crashlytics Analytics for Android
  • AppsFlyer

For further information regarding our third-party analytics partners, including their privacy policies, please refer to our Privacy Policy

The free version of Antivirus for Mobile (Android) serves relevant third-party advertisements. These are the advertising partners we use for this product:

  • Google AdMob
  • Amazon
  • Facebook Audience Network
  • InMobi 
  • Twitter MoPub
  • AppLovin
  • Unity Technologies
  • IronSource

For further information regarding our third-party ads partners, including their privacy policies, please refer to our Consent Policy

Antivirus for Mobile (iOS)

Official Product Name

AVG Mobile Security

Core Functionality

AVG Mobile Security (hereinafter as “Antivirus for Mobile (iOS)”) provides protection for your passwords, photos and Wi-Fi. The product consists of several free and paid features, such as Identity Protection and Secure Browsing, which are described in detail below.

What are Product’s Features

  • Identity Protection immediately receives a notification if any of your passwords are found leaked online to keep your identity safe. By choice, users can enter an email address and get back feedback on whether or not their credentials have leaked. The functionality also stores email addresses with respect to which no leak was detected to notify users if we learn that their credentials leaked at a later date.
  • Photo Vault locks your photos in an encrypted vault and secure them with a PIN, Touch ID, or Face ID so that only you have access to them.
  • Wi-Fi Security automatically scans Wi-Fi networks for vulnerabilities to verify that the network you’re connected to is safe. Receive alerts if any risk is detected.
  • Secure Browsing (available only for paid version) protects your privacy by making sure no one can spy on what you’re doing online with Secure Browsing VPN feature.

 

Personal Data We Process

While using Antivirus for Mobile (iOS), we collect and process the following Service and Device Data (in addition to Account Data and Billing Data, if relevant):

Service Data

What we use it for and for how long

Timestamps of your connections for Secure Browsing

Service Provision (36 months)

  • To manage the number of concurrent active connections, and handle abuse

New Product Development (36 months)

  • To improve the user's overall experience

The subnet of your originating IP address for Secure Browsing

Service Provision (36 months)

  • To plan for increased network demand and capacity

IP address of the VPN server you’re using for Secure Browsing

Service Provision (36 months)

  • To troubleshoot our service and plan for new network capacity

Amount of data transmitted for Secure Browsing

E.G. 5GB up or down

Service Provision (36 months)

  • To plan for new network capacity and server improvements

New Product Development (36 months)

  • To improve the user's overall experience

User’s email for Identity Protection

Service Provision (36 months)

  • To send a requested report to you on whether or not their credentials have leaked

New Product Development (36 months)

  • To improve the user's overall experience

Events and product usage (app metadata, number of identity protection checks, number and result of Wi-Fi scans, error logs and screen flow)

Service Provision (36 months)

  • To ensure continuous functionality (installations, versions, updates, settings)

Third-party Analytics (14 months)

  • To understand the user's behavior

New Product Development (36 months)

  • To improve the user's overall experience



Device Data

What we use it for and for how long

OS Version

E.g. iOS 13.1

Service Provision (36 months)

  • For user support and troubleshooting

Third-party Analytics (14 months)

  • To understand the user's behavior and product development planning

New Product Development (36 months)

  • To improve the user's overall experience

Mobile Security for iOS version

E.G. Mobile Security for iOS version 1.2.2

Service Provision (36 months)

  • For user support and troubleshooting

Third-party Analytics (14 months)

  • To understand the user's behavior and product development planning

New Product Development (36 months)

  • To improve the user's overall experience

These are the third-party analytics tools we use for Antivirus for Mobile (iOS):

  • Google Firebase Analytics and Crashlytics for iOS
  • AppsFlyer

For further information regarding our third-party analytics partners, including their privacy policies, please refer to our Privacy Policy

AntiTrack

Official Product Name

AVG AntiTrack (collectively as “AntiTrack”)

Core Functionality

As you browse the web, profiles of your behavior are compiled and linked to you via cookies and fingerprint-based tracking technologies. This data is then shared and sold by analytics and ad-tech firms. AntiTrack removes cookies and masks the device’s “fingerprint” to prevent third-parties from identifying you and following your behavior across the web. 

What are Product’s Features

  • AntiFingerprinting stops scripts from fingerprinting the user’s device and tracking their browsing behavior across the web. In particular, this feature relies on processing of browser version, hardware data, OS version, OS locale and AntiTrack version.
  • Privacy Score provides the user with an evaluation of how private they are based on various in-app configurations. In particular, this feature relies on processing of browser version, hardware data, OS version, OS locale, AntiTrack version, In-app settings (such as features that are turned on/off).
  • Clears your browsing history and cookies helps the user manage their browsing history and cookies by allowing them to manually clear them or schedule automatic clearing at their discretion. In particular, this feature relies on processing of browser version, hardware data, OS version, OS locale, AntiTrack version, In-app settings (such as features that are turned on or off).

Personal Data We Process

We process only the following Service and Device Data (in addition to Billing Data for paid version or Account Data if necessary):

Service Data

What we use it for and for how long

Usage Frequency

Service Provision (the earlier lifetime of the account and 6 years)

  • We collect usage frequency data, such as the amount you use the application, for feature enhancement, customer support and product maintenance

Number of Application Launches

Service Provision (the earlier lifetime of the account and 6 years)

  • For product maintenance and customer support

License Key

Service Provision (the earlier lifetime of the account and 6 years)

  • We send back the license key through the application for regulating access to the product, providing customer support, and administering product updates

Device Data

What we use it for and for how long

OS Version

Service Provision (the earlier lifetime of the account and 6 years)

  • For user support, troubleshooting, and product development planning

New Product Development (48 months)

  • When developing new features, we adjust the scope of the feature based upon the requirements and the functionality of certain operating systems

Third-party Analytics (50 months)

  • To better understand how users’ interact with certain aspects

OS Locale 

Service Provision (the earlier lifetime of the account and 6 years)

  • To segment updates by location

In-product Messaging (6 months)

  • To inform users of problems that will not be solved by the currently installed product and to offer users a solution to the detected problem

New Product Development (48 months)

  • In some cases we might not roll out a new feature or product to every demographic, in such a case we may use OS locale to segment this

Third-party Analytics (50 months)

  • To better understand how users’ interact with certain aspects

AntiTrack version


Service Provision (the earlier lifetime of the account and 6 years)

  • For user support, troubleshooting, and product development planning

In-product Messaging (6 months)

  • To inform users of problems that will not be solved by the currently installed product and to offer users a solution to the detected problem

Third-party Analytics (50 months)

  • To better understand how users’ interact with certain aspects

Install Date or Time

Service Provision (the earlier lifetime of the account and 6 years)

  • For license management

In-product Messaging (6 months)

  • To inform users of problems that will not be solved by the currently installed product and to offer users a solution to the detected problem

New Product Development (48 months)

  • To know when to market new features and or products

Crash Incidents

Service Provision (the earlier lifetime of the account and 6 years)

  • To ensure continuous functionality

Hardware Data (device model, RAM, GPU, CPU)

Service Provision (the earlier lifetime of the account and 6 years)

  • To install the product, provide application updates, customer support and make user experience improvements

The third-party analytics tools we use for AntiTrack is Google Analytics. For further information regarding our third-party analytics partner, including its privacy policy, please refer to our Privacy Policy.

TuneUp

Official Product Name

AVG TuneUp for Windows, AVG TuneUp for Mac (collectively as “TuneUp”)

Core Functionality

TuneUp is an ultimate tune-up program which speeds up and cleans your PC (Windows and Mac), updates installed apps, and fixes other problems.

What are Product’s Features

TuneUp for Windows:

  • Maintenance scans and deletes registry items, shortcuts, system and programs temp or unnecessary files, browser caches, history and cookies. 
  • Program Deactivators scans and disable installed third-party programs which have background, startup or scheduled tasks. 
  • Software, Disk or Browser Cleaner scans and temporarily hide or uninstall third-party programs, deletes unnecessary files from disk or browser history. 
  • Fix Problems scans and fixes common Windows problems which might put PC at risk (e.g. missing Windows updates, administrative shares on public folders).
  • Disk Doctor or Defrag scans for potential errors and fixes system drive or defrags your system drive.
  • Software Updater scans and update third-party programs and their versions installed on PC.

TuneUp for Mac:

  • Clutter Scan scans and deletes application caches, log files, trash, downloads folder, development junk. It looks for similar data on connected external drives as well. Only data on the amount of KB and cleaned is processed.
  • Find Duplicates scans for duplicate files in directories selected by you. Only data on the amount of KB and duplicate files found and cleaned is processed. 
  • Find Photos scans photos and evaluates their quality and similarity to help you decide which you want to keep. Only data on the amount of KB and photos found and cleaned is processed.
  • Uninstall Apps scans and removes applications and programs for which it necessary to process app name, size, version and last date of its usage.

 

Personal Data We Process

While using TuneUp, we collect and process the following Service and Device Data (in addition to Billing Data or Account Data if relevant):

Service Data

What we use it for and for how long

Events and product usage (such as product version, product language, license type, days to expiration, number of potential problems or detected junk)

Service Provision (up to 36 months)

  • To monitor service functionality

In-product Messaging (24 months)

  • To inform users of problems that will not be solved by the currently installed product and to offer users a solution to the detected problem

Third-party Analytics (50 months)

  • To better understand our users’ behavior

New Product Development (up to 36 months)

  • To improve users' overall experience by developing new features or products

Device Data

What we use it for and for how long

Internal online identifiers (GUID, Device ID)

Service Provision (up to 36 months)

  • To identify correct installation

In-product Messaging (24 months)

  • To inform users of problems that will not be solved by the currently installed product and to offer users a solution to the detected problem

Information concerning computer or device (OS version, OS language, CPU, RAM, disk, graphics, system and display resolution)

Service Provision (up to 36 months)

  • To be able to display the correct online content and to improve features

In-product Messaging (6 months)

  • To inform users of problems that will not be solved by the currently installed product and to offer users a solution to the detected problem

New Product Development (up to 36 months)

  • To improve users' overall experience by developing new features and products

Applications (our other products, installed applications on a user’s computer)

Service Provision (up to 36 months)

  • Our other apps to know which products users already have on their computer
  • Third-party applications or programs installed on users’ computers to improve Cleanup Sleep Mode, Software Cleanup and Software Updater functionality

In-product Messaging (6 months)

  • To inform users of problems that will not be solved by the currently installed product and to offer users a solution to the detected problem

New Product Development (up to 36 months)

  • To improve the users' overall experience by developing new features and products

The third-party analytics tool we use for TuneUp is Google Analytics. For further information regarding our third-party analytics partner, including its privacy policy, please refer to our Privacy Policy

Cleaner

Official Product Name

AVG Cleaner for Android (“Cleaner for Android”)

Core Functionality

Cleaner for Android detects and removes unnecessary files to free up storage space. Equally, it can stop running processes to optimize device performance.

What are Product’s Features

  • App Overview allows to browse installed and pre-installed applications, provides functionality to uninstall or stop. In particular, this feature relies on processing device provided stats about other apps. These stats are processed locally (on device) in order to provide the service. 
  • Media Overview provides an overview of files broken down by type (eg images, audio files, video). This feature do not need any specific data processing outside of operations made locally (on device).
  • Battery Saver allows users to select conditions where desired actions (system settings changes) should be applied by this product. For example one can automatically decrease screen brightness when at home. Location based condition require permission to get location data, however these data are never transmitted from device and all are processed locally.
  • Cloud Transfers allow users to backup their files to an external cloud storage. We are using Google Drive and Dropbox APIs to do so, e.g. user can login using their Google or Dropbox credentials to establish such connections. Note credentials are not visible to us.

 

Personal Data We Process

While using Cleaner Android, we collect and process the following Service and Device Data (in addition to Billing Data for paid version):

Service Data

What we use it for and for how long

Identifier of the content (message) being delivered

Service Provision (36 months)

  • To monitor service functionality

In-product Messaging (6 months)

  • To inform users of problems that will not be solved by the currently installed product and to offer users a solution to the detected problem

Third-party Analytics (14 months)

  • To monitor messaging performance

IP address

Service Provision (36 months)

  • Replaced with city/country for delivering geo-specific changes to app’s configuration (both local or remote)

In-product Messaging (6 months)

  • To inform users of problems that will not be solved by the currently installed product and to offer users a solution to the detected problem

Third-party Analytics (14 months)

  • To monitor messaging performance

Events and product usage

Service Provision (36 months)

  • To ensure continuous functionality (installations, versions, updates, settings) and map how users interact with our product

In-product Messaging (24 months)

  • To inform users of problems that will not be solved by the currently installed product and to offer users a solution to the detected problem

Third-party Analytics (14 months)

  • To better understand our users’ behavior and users’ acquisition

New Product Development (36 months)

  • To consider roadmap for type of features and products we want to develop in future

Device Data

What we use it for and for how long

Online identifiers (GUID, Device ID (Android ID), Hardware ID, Profile ID, Advertising ID)

Service Provision (36 months)

  • For counting users, ensuring functionality and stability

In-product Messaging (24 months)

  • To inform users of problems that will not be solved by the currently installed product and to offer users a solution to the detected problem

Third-party Analytics (14 months)

  • To better understand our users’ behavior 

New Product Development (39 months)

  • To recognize reinstalls of the app on the same device

Third-party Ads (not stored after provision)

  • We process Advertising ID only for IronSource which allows it to place advertisements

Information concerning computer or device (carrier, OS version, OS build number, hardware ID, device model, device brand, device manufacturer, device API level)

Service Provision (36 months)

  • To ensure functionalities of the product and its features

In-product Messaging (6 months)

  • To inform users of problems that will not be solved by the currently installed product and to offer users a solution to the detected problem

Third-party Analytics (14 months)

  • To better understand our users’ behavior

New Product Development (36 months)

  • To determine whether a new feature or product should be developed for subset of users

Location (city/country, longitude and latitude)

Service Provision (36 months)

  • Delivering geo-specific changes to app’s configuration (both local or remote)
  • Related to Battery Profile feature, as users can set being in a certain location as a trigger to automatically launch a Battery saving profile.

In-product Messaging (6 months)

  • To inform users of problems that will not be solved by the currently installed product and to offer users a solution to the detected problem

Third-party Analytics (14 months)

  • To better understand users’ behavior based on approximate location

New Product Development (36 months)

  • To introduce a new feature or product based on approximate location

Applications

Service provision (36 months)

  • To provide insights, such as usage stats to help identify unused apps (storage cleaning opportunity), drain impact (battery, data) to help identify apps that have significant effect on device resources, or notification stats to help identify “noisy” apps which can be “muted” by links to system settings

In-product Messaging (6 months)

  • To inform users of problems that will not be solved by the currently installed product and to offer users a solution to the detected problem

Third-party Analytics (14 months)

  • To better understand users’ behavior

Internet and connection

Service provision (36 months)

  • For functionality of our features, providing error messaging

In-product Messaging (6 months)

  • To inform users of problems that will not be solved by the currently installed product and to offer users a solution to the detected problem

Third-party Analytics (14 months)

  • To better understand users’ behavior

New Product Development (36 months)

  • To introduce a new feature or product based on previous experience

These are the third-party analytics tools we use for Cleaner for Android:

  • Google Firebase Analytics and Crashlytics for Android
  • AppsFlyer

For further information regarding our third-party analytics partners, including their privacy policies, please refer to our Privacy Policy

The free version of Cleaner for Android serves relevant third-party advertisements. These are the advertising partners we use for this product:

  • Google AdMob
  • Amazon
  • Facebook Audience Network
  • InMobi 
  • Twitter MoPub
  • AppLovin
  • Unity Technologies
  • IronSource

For further information regarding our third-party ads partners, including their privacy policies, please refer to our Consent Policy

Driver Updater

Official Product Name

AVG Driver Updater

Core Functionality

Driver Updater provides scan and potential update or fix of outdated drivers on a users’ PC to optimize it for better performance and avoid potential crashes or malfunctions.

 

Personal Data We Process

While using Driver Updater, data is processed by Slimware which licenses the product to us. For further information please see its privacy policy here.

We process only the following Service and Device Data (in addition to Billing Data):

Service Data

What we use it for and for how long

Events and product usage (such as product version, product language, license type, days to expiration, number of potential problems or detected junk)

In-product Messaging (24 months)

  • To inform users of problems that will not be solved by the currently installed product and to offer users a solution to the detected problem

Device Data

What we use it for and for how long

Internal online identifiers (GUID, Device ID)

In-product Messaging (24 months)

  • To inform users of problems that will not be solved by the currently installed product and to offer users a solution to the detected problem

Information concerning computer (such as OS version, OS language)

In-product Messaging (6 months)

  • To inform users of problems that will not be solved by the currently installed product and to offer users a solution to the detected problem

Applications (our other products, installed applications on a user’s PC)

In-product Messaging (6 months)

  • To inform users of problems that will not be solved by the currently installed product and to offer users a solution to the detected problem



SafePrice

Official Product Name

AVG SafePrice

Core Functionality

SafePrice is a browser extension available for Chrome, Firefox, Edge and Safari. Whenever you visit an online shop or product site, SafePrice will show relevant price comparison and discount coupons.

What are Product’s Features

  • Discount coupons and other promotional offers are typically provided by store owners to incentivize purchases. This means that these coupons are relevant to specific domains, and sometimes specific pages only. In order to be able to offer relevant coupons, we need to check the current page URL against a list of available offers.
  • Price Comparison looks for specific portions of the HTML code which allows it to identify basic information about the product you are shopping for – product name, SKU and current price. We then compare this information with a database of prices provided by our partners, and offer cheaper prices for the same product where available.

Information about available offers, coupons or cheaper prices is obtained from Ciuvo. We request this content based on the information obtained from the page, your language settings, country level location and search query within SafePrice. Once you click on the offer, your request will be processed by Ciuvo according to its privacy policy.

Personal Data We Process

While using SafePrice, we process the following Service and Device Data: 

Service Data

What we use it for and for how long

URL and referers

Service Provision (36 months)

  • To display discount coupons and price comparison offers relevant to the website that you are visiting

Search query

Service Provision (36 months)

  • If submitted by you, to search for relevant products and discount coupons

Product name and price

Service Provision (36 months)

  • To display price comparison offers relevant to the product that you are shopping for

User’s feedback (ratings, comments)

Service Provision (36 months)

  • To tell whether the offers you received are relevant and up-to-date, and collect product feedback

New Product Development (36 months)

  • To develop new products based on the user’s feedback

Device Data

What we use it for and for how long

Internal extension identifier (GUID)

Service Provision (36 months)

  • For ensuring continuous functionality and breaking down entries in database

New Product Development (36 months)

  • To measure product telemetry and calculate aggregated statistics

Information on computer or device (browser)

New Product Development (36 months)

  • To obtain usage statistics

Extension information (installation source and time, version and campaign ID)

Service Provision (36 months)

  • To make sure our offers are relevant and product features function as expected

New Product Development (36 months)

  • To obtain usage statistics, evaluate our marketing campaigns and perform feature A/B testing

Country

Service Provision (36 months)

  • To make sure our offers are relevant, and collect statistics on SafePrice usage by country

Language

Service Provision (36 months)

  • To make sure our offers are relevant, and collect statistics on SafePrice usage by language

SafePrice does not process Account or Billing Data. 

Online Security

Official Product Name

AVG Online Security

Core Functionality

Online Security is a browser extension (or plug-in) available for Chrome, Firefox, Edge and Safari. Whenever you visit a website we check if the site isn’t malicious or phishing. We are able to provide you with this functionality by processing URLs.

What are Product’s Features

  • Antivirus checks the links in search results so user knows if the page is trying to spread malware.
  • Anti-phishing identifies and blocks phishing sites trying to steal your data.
  • Anti-Tracking blocks annoying tracking cookies that collect data on your browsing activities.
  • Reputation rating allows users to rate websites. Participation is voluntary.
  • Bank Mode works only when Antivirus is installed and offers to user to open page in a safe sandbox environment on sensitive sites (banking).
  • Marking search results to show if the site is safe or not even before user visits it.

Personal Data We Process

While using Online Security, we process the following Service and Device Data: 

Service Data

What we use it for and for how long

URL, referrers and tab ids

Service Provision (24 months)

  • To check if URLs and the preceding referral domains or URLs (as applicable) are malicious or not to identify its source for threat analysis

User’s feedback (ratings, comments)

Service Provision (24 months)

  • To tell whether the site rating and classification you received are relevant and up-to-date

New Product Development (36 months)

  • To improve the product or its feature based on the user’s feedback

Usage data

(open extension, rated site, disabled trackers, change settings, site blocked)

New Product Development (24 months)

  • To measure user’s behavior in UI and how user interacts with the extension

Device Data

What we use it for and for how long

Internal extension identifier (GUID)

Service Provision (24 months)

  • To distinguish unique malware hits and evaluate it in our systems

New Product Development (24 months)

  • To measure product telemetry and calculate aggregated statistics

Information on computer or device (browser, OS)

New Product Development (24 months)

  • To obtain usage statistics

Extension information (installation source and time, version and campaign ID)

New Product Development (24 months)

  • To obtain usage statistics, evaluate our messages and perform feature A/B testing

Location / Country

Service Provision (24 months)

  • To detect country specific malware campaigns

New Product Development (24 months)

  • To measure product telemetry and calculate aggregated statistics

Language

Service Provision (24 months)

  • To make sure we communicate in right language

New Product Development (24 months)

  • To measure product telemetry and calculate aggregated statistics

Antivirus Status

Service Provision (24 months)

  • To being able to turn on Bank Mode on specific sites

Online Security does not process Account or Billing Data. 

Secure Browser

Official Product Name

AVG Secure Browser

Core Functionality

Secure Browser is a product currently offered for PC Windows and is available in Beta for Mac users. 

What are Product’s Features

  • Browser Security & Privacy Center is built in Security & Privacy Center which is a curated collection of some key security and privacy features, tools and settings, organized into one management console making it easier for you to control and manage your online privacy and security.
  • Anti-Phishing blocks malicious websites and downloads to help prevent your personal computer from becoming infected with viruses, spyware, and ransomware.
  • Privacy Cleaner cleans your browser history, cached images, cookies including both first-party and third-party cookies, and other junk with just one click, to keep your activity private and free up disk space. 
  • Stealth Mode prevents your browsing history from being stored and removes any tracking cookies (both first-party cookies and third-party cookies) or web cache you pick up during that browsing session.
  • Anti-Phishing V2 (Phalanx) blocks malicious websites and downloads to help prevent your personal computer from becoming infected with viruses, spyware, and ransomware.
  • Adblock stops Ads being shown in your browser using publicly available so called blocking lists. AdBlock usually does not remove ads, it already prevents them from being loaded and thus also speeds up browser experience.
  • Anti-Tracking prevents the user from being tracked across websites by avoiding tracking cookies to be created. This is done using publicly available so called blocking lists. Anti-Tracking usually does not remove the tracking cookies, instead it already prevents them from being loaded and created and thus also speeds up browser experience.
  • Anti-Fingerprinting prevents the user from being tracked across websites using browser fingerprinting techniques. As fingerprinting itself cannot be prevented or avoided, this feature prevents being tracked by altering the digital fingerprint of the users browser or PC combination in a way that 3rd party sites cannot re-identify it.

Personal Data We Process

By default, Security Browser processes locally on your system the following data:

  • Browsing history information; for example Secure Browser may store the URLs of pages that you visit, a cache of text, images and other resources from those pages. If the prerendering feature is turned on, a list of IP addresses linked to those pages may also be stored for some period of time;
  • Name, surname, email or passwords to help you fill out forms or signs in to sites you visit;
  • Permission that you have granted to websites;
  • Cookies or data from websites that you visit;
  • Data saved by add-ons;
  • Record of what you downloaded from websites.

These data is not sent to our environment. You can manage this data within Secure Browser under the “Advanced” section of the Settings page.

In our environment we process the following Service and Device Data while using Secure Browser: 

Service Data

What we use it for and for how long

IP address

Service Provision (36 months)

  • Replaced with country for delivering geo-specific changes to configuration (both local or remote)
  • For prerendering feature functionality, if activated

Events and product usage 

Service Provision (36 months)

  • To ensure functionality (installations, versions, updates, settings), map how users interact with the application and improve its design or flows

In-product Messaging (24 months)

  • To inform users of problems that will not be solved by the currently installed product and to offer users a solution to the detected problem

Third-party Analytics (up to 60 months)

  • To better understand our users’ behavior

New Product Development (36 months)

  • Findings about product have an effect on the design or layout of the new one

Device Data

What we use it for and for how long

Online identifiers (GUIDs, Device IDs)

Service Provision (36 months)

  • For ensuring continuous functionality and breaking down entries in database

In-product Messaging (24 months)

  • To inform users of problems that will not be solved by the currently installed product and to offer users a solution to the detected problem

Third-party Analytics (60 months)

  • To better understand our users’ behavior

New Product Development (36 months)

  • To introduce a new feature or product based on previous experience

Information concerning computer or device

Service Provision (36 months)

  • To check for compatibility issues in automated crash dumps

In-product Messaging (6 months)

  • To inform users of problems that will not be solved by the currently installed product and to offer users a solution to the detected problem

Third-party Analytics (60 months)

  • To better understand users’ behavior

New Product Development (36 months)

  • To introduce a new feature or product based on previous experience

Location

Service Provision (36 months)

  • Setting up a proper product language version for Windows

In-product Messaging (6 months)

  • To inform users of problems that will not be solved by the currently installed product and to offer users a solution to the detected problem

Third-party Analytics (50 months)

  • To better understand users’ behavior

New Product Development (36 months)

  • To introduce a new feature or product based on country

Third-party extensions installed in the browser 

Service Provision (36 months)

  • To define rules of how the Browser should behave in relation to extensions installed (e.g. exceptions in scanning, filtering, notifications, whitelisting, blacklisting)

Third-party Analytics (60 months)

  • To better understand users’ behavior

New Product Development (36 months)

  • To introduce a new feature or product based on user engagement and preferences

Our other products/licenses on the device and their status

Service Provision (36 months)

  • To recognize what features should be enabled or disabled, what product should be installed or uninstalled 

Third-party Analytics (60 months)

  • To better understand users’ behavior

Browsers (installed, default)

Service Provision (36 months)

  • To provide import functionality, improve user onboarding and product experience

Third-party Analytics (60 months)

  • To better understand users’ behavior

New Product Development (36 months)

  • To introduce a new feature or product based on previous experience

The third-party analytics tools we use for Secure browser are:

  • Google Analytics
  • Mixpanel

For further information regarding our third-party analytics partners, including their privacy policies, please refer to our Privacy Policy

Secure Browser serves advertisements in cooperation with Viglinks and AdMarketplace. For further information regarding our partners please refer to their privacy policies here and here

Secure VPN

We are a leading provider of security and privacy tools and therefore we are deeply committed to protecting and respecting your privacy. Our VPN Policy. (together with any other documents referred to in it) sets out the basis on which any data we collect from you, or that you provide to us, will be processed by us.

 


VPN Policy

 

Using a virtual private network (“VPN”) is like going undercover while you are on the Internet. We provide VPN services that allow you to be on the Internet anonymously and securely from anywhere in the world. While we respect your privacy and take strenuous measures to protect it, it does not mean that you are totally anonymous to us.

 

In this section of VPN Policy, we would like you to know what kind of personal data we collect from you or that you provide to us when you use our VPN services.

 

We treat this data differently than we do for other applications as it can be of such a sensitive nature, so we want you to understand clearly how we process it, on what legal bases, whether we transfer or disclose it, and how long we retain it, in accordance with relevant laws.

 

Personal Data Collection and Use

Personal data is understood as any information that relates to an identified or identifiable natural person, and includes the information you provide to us while using our VPN services.

 

More specifically, we may collect and process data about you in the following situations:

 

Account Creation and Management

If you create an account with us (note: this is necessary in order for you to use some of our applications or some of their functions), we will need some information about you. This is the data that is created and stored for the management of your account:

Account data

What we use it for

Email address

To send you purchase receipts, communications, and occasional product news

Username

To manage your account and facilitate your login into the service

License Key

To activate your subscription

Subscription renewal date

To tell us until when the account is valid

Trial User

To add a trial period before the account is charged

 

All of the above data is stored for as long as you use our service, as it is necessary for us to provide it. You can see all of this data by logging into our Privacy Preference portal.

 

Service Data from our VPN Servers

If you use our VPN service, we strictly collect the minimum amount of information needed to provide and operate our VPN service, as well as keep it running safely and efficiently. This is the data we collect to make sure our VPN infrastructure works (“Service Data”):

Service data

What we use it for

Timestamps of your connections

To manage the number of concurrent active connections, and handle abuse.

 

Example: We use them to stop brute force password cracking attempts on user accounts.

The subnet of your originating IP address.

 

E.g. We anonymize the last octet to protect your privacy: 92.143.234.000 We don’t collect exact IP addresses that could ID you.

To plan for increased network demand and capacity.

 

Example: Help us decide to add servers in a region if we see a rise in demand there, or help troubleshoot issues with a specific ISP.

IP address of the VPN server you’re using.

To troubleshoot our service and plan for new network capacity.

 

Example: Identify when an IP address suddenly doesn’t work for accessing certain services, and act to resolve the issue.

Amount of data transmitted

 

E.G. 5GB up or down

To plan for new network capacity and server improvements.

 

Example: We may deploy more capacity to meet demand and make sure speeds stay up for all users.

We store this data on servers for 30 days, after which time it is deleted on a rolling basis — so data created on Jan 3rd gets deleted on February 2nd, for example.

 

Data We Don’t Collect on our VPN Service. Period

We do not collect, store or log any of the following data:

  • Any complete originating IP address that could identify you.
  • Any DNS queries while connected. We rely on our own secure DNS servers, so your queries are also protected from exposure to 3rd parties.
  • Any activity logs: the applications you use, the services you use, the websites you connect to — basically anything you do online.

 

Service Data from our VPN Clients

In order to make sure our VPN clients do their job properly and improve them, we have to know how people, as a whole, interact with them. This data pertains to interactions taken in the app, and cannot be used to uncover what you’re using the VPN service for.

Client Data

What we use it for

OS Version

 

E.g. Windows 10

For user support, troubleshooting, and product development planning

 

Example: Which platforms do our users most like to use?

AVG Secure VPN version

 

E.G. Secure VPN for Android version 4.1

For user support, troubleshooting, and product development planning

 

Example: Is our latest update deploying well?

Application Events

 

E.g. Turned on auto-connection, Uninstalled, etc. You can opt out of this in the settings.

To plan product development

 

Example: Is a new client-side feature we introduced popular? Are people uninstalling after our latest release?

 

We delete this data on a rolling 2-year basis (i.e. data created on Jan 2, 2019, will get deleted on Jan 2, 2021).

 

Third-party Analytics In Our VPN Products

To analyze the application events mentioned section 1.4, and understand how our services function, or how stable or successful they are, we rely on our own analytics tools as much as possible. But sometimes, we need to rely on third-party tools that address specific issues in ways we don’t have the ability to replicate. Whenever possible, we anonymize, masque, or in other ways try to limit your exposure.

 

Here are the third-party tools we use, how we use them, and their privacy policies. You will find that these tools are also listed under the broader section Service Data of this privacy policy which covers all our products, however in the interest of full transparency, we cover here in detail how the relevant ones are used for our VPN products:

 

Google Firebase Analytics on iOS and Android

Firebase helps us to understand how people interact with certain aspects of our applications. While Firebase normally relies on Android Advertising ID or iOS Identifier for Advertisers, we’ve opted to use our own anonymizing identifiers instead. Therefore it doesn’t contain any information that could personally identify you. Still, you can opt out of providing us with this anonymized application performance data in our application settings.

 

Still, you can opt out of providing us with this anonymized application performance data in our application settings.

 

Google Fabric Crashlytics on iOS and Android

This Google service helps us to improve the application stability, pinpoint things that don’t work, and improve your experience. Its implementation doesn’t contain any information that can personally identify you.

 

Both Firebase Analytics and Crashlytics are subject to Google’s privacy policy.

 

AppsFlyer Analytics on iOS and Android

AppsFlyer helps us understand how effective our marketing campaigns are by letting us know which ones directed you to us. The data collected here is subject to AppsFlyer’s privacy policy.

 

You can opt out of AppsFlyer Analytics in the settings of our applications, or by opting out by following the instructions in their privacy policy.

 

Deprecated Analytics

If you’re still on older versions of our applications, the following analytics are embedded in them. We highly recommend that you upgrade to later versions as they no longer use these:

  • Facebook Analytics on older versions of our Android apps: we used to use this to know how many people opened an app, how much time they spent in it, and other information about how they interacted with them. You can find Facebook’s privacy policy here.
  • HockeyApp on older versions of our macOS and iOS apps: This was used to do beta distribution, crash reporting, user metrics, feedback, and more. This tool belongs to Microsoft and you can find their privacy policy here.

 

Where and How Long We Store Your Personal Data

Where We Store Your Data

When you use our service, you may be using servers located in a variety of different countries. However, there is a difference between use and storage. What little information that gets generated by your use of our infrastructure does not get stored outside of the Czech Republic.

 

There may be some instances where, as a matter of necessity, we need to transfer data outside of these two jurisdictions. When we process the data within our group, regardless of where we are, we always implement the same level of data protection afforded by the European General Data Protection Regulation to all personal data we process. Where we cooperate with third parties which are involved in data processing, we legally bind any party we deal with to adhere to those high levels of protection with standardized contracts approved by the European Commission, and to ensure your rights are protected in accordance with this privacy policy.

 

In all cases, we follow generally accepted standards and security measures to protect the personal data submitted to us, both during transmission and once we receive it. We always strive to protect your data to the maximum extent we can.

 

By using the service, you acknowledge this transfer, storing or processing.

 

How Long We Store Your Data

Concerning storage or retention periods, the specific terms applicable to the various types of data used for various purposes are noted in their respective sections. After these periods elapse, we will delete this data and no longer use it for that specific purpose.

 

These retention periods may be longer where it is necessary for us to comply with our legal obligations or legal orders, resolve disputes, and enforce our agreements, including in the court of law.

 

Disclosure of Your VPN information

As a rule, we do not disclose any information to other commercial parties, with the following exceptions:

 

The Avast Group

As we are part of the Avast Group, information may be shared with members of the Avast Group in order to execute on the provisions of this service, for direct marketing, or to help our product development. In all cases, they are subject to the terms of this Privacy Policy.

 

Provision of Services

It may be necessary to share some data with select parties to deliver the product or service you require — such as with a payment card provider who we use to process your credit card transaction, or to do perform website analytics. The information that is collected and shared with those parties is outlined above.

 

Legal Requirements

In the event we are served with valid subpoenas, warrants, or other legal documents (for example, documents concerning the sale of all or part of our business or a merger), or where applicable law compels us to comply, or when we are required to defend the rights or property of the Avast Group, including the security of our products and services, and the personal safety, property, or other rights of our customers and employees — we may share your personal data as collected above.

 

Whatever the Circumstance

“Avast does NOT store the originating IP addresses of our users when connected to our VPN service, and thus cannot identify users when provided the IP address of one of our servers. We are also completely unable to disclose any information about the applications people use, the services they employ, or the websites they visit while using our VPN. We simply do NOT store this information.”

 

Are you our business partner or a public relations contact? Find out more about how we use your personal data here.




Cookies Policy

 

This Cookies Policy applies to the websites of Avast Software s.r.o. and its affiliates (collectively as “we,” “us” or “our”). 

If you live in the European Economic Area, the Controller of your personal data is Avast Software s.r.o., which has its principal place of business at 1737/1A Pikrtova, Prague 4, Czech Republic, 140 00.

What Are Cookies and How We Use Them

Cookies are small text files that can be used by websites to make a user's experience more efficient. You can find more about cookies here.

We use cookies, and other similar technologies such as pixel tags and web beacons, to remember your preferences, to personalize your experience on our sites, tell us which parts of our websites people have visited, help us measure the effectiveness of campaigns, and give us insights into user interactions and user base as a whole so we can improve our communications and products. 

How We Use Third-party Cookies

You can find a list of the third-party cookies that we use on our sites along with other relevant information in the cookie table below. While we do our best to keep this table updated, please note that the number and names of cookies, pixels and other technologies may change from time to time.

Generally, we may receive reports based on the use of third-party technologies by their third-party providers on an individual as well as aggregated basis. We may also partner with a third party either to display advertising on our site or to manage our advertising on this site and other sites using information from the cookies.

How You Can Disable Cookies or Opt Out of Interest-based Targeting

If you do not wish to allow the use of cookies, you can disable them through your browser settings. In some browsers you can set up rules to manage cookies on a site-by-site basis, giving you more fine-grained control over your privacy. We do note, however, that not all browsers across all platforms may support this functionality.

Browser manufacturers provide help pages relating to cookie management in their products. Please see below the relevant links to the main browsers:

For other browsers, please consult the documentation that your browser manufacturer provides.

You can opt out of interest-based targeting provided by participating ad servers through:

In addition, on your iPhone, iPad or Android, you can change your device settings to control whether you see online interest-based ads in the following manner:

  • iOS devices: go to Settings > Privacy > Advertising > enable Limit Ad Tracking. Please note that if you use more than one device, you need to opt-out separately in each device.
  • Android devices: Please follow the instructions set forth at: https://support.google.com/ads/answer/2662922?hl=en. Please note that if you use more than one device, you need to opt-out separately in each device.

Please note that if you disable cookies, our websites may not function properly or at all or your access to our websites and their features may be affected or restricted.

Cookie Tables

Across all of our websites, we use these cookies:

Necessary cookies

We primarily use cookies to provide you with a consistent and accurate service. Other cookies can tell us which language you prefer and what your communications preferences are. They also provide you with features.

Cookie Name

Cookie Source (1st/3rd Party)

Retention Period

Avast

AVG

CCleaner

__hs_opt_out;

__hs_do_not_track; h-open; hs-messages-hide-welcome-message; __hsmem; __hstc; 

hubspotutk; __hssc; __hssrcs_ab_test; <id>_key; hs-messages-is

1st 

Up to 13 months

 ✓

apex__avastLocale

1st

Session

 ✓

apex__searchAttempts

1st

2 hours

 ✓

 ✓

apex__avastSCLocale

1st

365 days

 ✓

apex__avastNoPts

1st

Session

 ✓

apex__avastLastVisitedArticle

1st

Session

 ✓

 ✕

 ✕

apex__avastConsent

1st

14 days

 ✓

apex__avgLocale

1st

336 days

 ✕

 ✓

apex__language

1st

Session

 ✕

 ✓

hidemyassComLocale

1st

365 days

avgLocale

1st

365 days

 ✕

 ✓

geoip

1st

30 days

 ✕

 ✓

avastComLocale

1st

1 year

consentAccepted

1st

14 days

 ✕

couponfield

1st

 14 days

 ✕

 ✕

cookiebar

1st

14 days

AKA_A2

3rd - Akamai

1 hour

 ✓

RT

3rd - Akamai

7 days

 ✓

JSESSIONID

3rd

Session

 ✓

loc

3rd - Addthis.com

13 months

 ✓

uvc

3rd - Addthis.com

13 months

 ✓

Performance, Analytics and Research cookies

Cookies help us learn how well our websites and services perform. We also use cookies to understand, improve, and research products, features, and services, including to create logs and record when you access our websites from different devices, such as your computer or your mobile device.

Cookie Name

Cookie Source (1st/3rd Party)

Retention Period

Avast

AVG

CCleaner

__iniSrc

1st

Up to 72 hours

 ✓

 ✓

 ✓

FULL_trSrc

1st

2 hours

 ✓

__trSrc

1st

Up to 72 hours

 ✓

 ✓

 ✓

__utmzzses

1st

Session

 ✓

pgdwlid

1st

Up to 72 hours

UFCounter

1st

6 months

 ✓

UTM_SOURCE

1st

1 year

 ✓

UTM_AFFSOURCE

1st

Up to 60 days

 ✓

 ✕

cjEvent

1st

Up to 60 days

 ✓

_ga

3rd - Google Analytics

2 years

 ✓

_gaexp

3rd - Google Optimize

Test's length

 ✓

Web Beacon

3rd - Capterra

Not stored

 ✓

 ✕

 ✕

_hjClosedSurveyInvites

_hjDonePolls

_hjMinimizedPolls

_hjDoneTestersWidgets

_hjMinimizedTestersWidgets

_hjIncludedInSample

_hjShownFeedbackMessage

3rd - Hotjar

1 year

 ✓

optimizelyEndUserId; optimizelyRedirectData

3rd - Optimizely

6 months

 ✓

 ✕

 ✕

_vis_opt*

_vwo_uuid*

3rd - Visual Website Optimizer

365 days

 ✓

 ✕

 ✕

yabs-sid; i; yandexuid; yp; yuidss

3rd - Yandex

Session; 1 year; 1 year; 3650 days; 1 year

 ✓

 ✕

AMP_TOKEN

3rd - Google

Up to 1 year

 ✓

_gid

3rd - Google

1 day

 ✓

_hjid

3rd - Hotjar

356 days

 ✓

omCountDown*; omSeen*

3rd - Optin Monster

1 day; 1 month

 ✕

 ✕

 ✕

Web Beacon

3rd - A8 Fly

IronSource

Spiceworks

My Target - VKontakte

Not stored

 ✓

 ✕

✕ 

Web Beacon

3rd - Outbrain

Not stored

 ✕

 ✓

 ✕

Web Beacon

3rd - Commission Junction

Not stored

 ✓

 ✓

 ✕

Web Beacon

3rd - Bredband

Max Bounty

Roacmedia

GlobalWideMedia

BestValueVPN

Not stored

 ✕

 ✕

 ✕

Advertising cookies

We may use cookies to help us deliver marketing campaigns and track their performance. Similarly, our partners may use cookies to provide us with information about your interactions with their services, but use of those third-party cookies would be subject to the service provider’s privacy controls, such as privacy policies or opt-out mechanisms, which you may find below.

Cookie Name

Cookie Source (1st/3rd Party)

Retention Period

Avast

AVG

CCleaner

Privacy Controls

ppc-hma

1st

3 days

 ✕

 ✕

 ✕

See this policy

MUIDB; MUID

3rd - Bing

13 months

 ✓

 ✓

 ✕

Opt Out

sid

3rd - Seznam.cz Sklik

29 days

 ✓

 ✓

Privacy Policy

_ym_d; _ym_isad; _ym_uid

3rd - Yandex Metrica

1 year; 1 day; 1 year

 ✓

 ✕

Opt Out

_gat_UA-*

3rd - Google Analytics

1 minute

 ✓

Opt Out

NID; SID; IDE; ANID; DSID; FLC; AID; TAID; __gads; __gac; Conversion

3rd - Google Advertising Network

Google API

Up to 2 years

 ✓

Opt Out

_fbp

3rd - Facebook

120 days

 ✓

 ✕

Opt Out

fr

3rd - Facebook

120 days

 ✓

✓ 

 ✕

Opt Out

lidc; bcookie; BizoID; UserMatchHistory

3rd - LinkedIn Ad Analytics

1 day; 1 year; 6 months

 ✓

 ✕

✕ 

Opt Out

1P_JAR

3rd - Google

30 days

 ✓

Opt Out

_gcl_au

3rd - Google

120 days

 ✓

Opt Out

Web Beacon

3rd - Ginga

Not stored

 ✓

 ✕

 ✕

Privacy Policy

Web Beacon

3rd - SalesForce

Not stored

 ✓

 ✕

 ✕

Opt Out

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