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Our privacy policy
PERSONAL DATA POLICY
This Personal Data Policy is given by "HowToCatchACheater.info" Corporation, ("HowToCatchACheater.info"”, “we”, “our”).
This policy also applies to all subsidiaries of "HowToCatchACheater.info"
This Personal Data Policy describes the principles and
practices that apply to our processing of Personal Data in our
business operations.
As a public listed company, operating in a field of content
security, we seek to provide you with a safe and secure user
experience. We will seek to ensure that the Personal Data you
submit to us remains private, and that such Personal Data is
only used for the purposes set out in this policy, service
specific terms or notices, license terms and the agreement(s)
in place between you and us, as applicable in relation to data
collected.
Summary in Brief
- We will only collect Personal Data based on your
consent and/or where we have a valid reason to do so.
- We will process Personal Data in personally
identifiable format only where necessary to do so. We
process any data you have submitted in anonymous format
unless there is a valid reason to retain such data in
identifiable format. We will also purposefully restrict our
own visibility to your personal content that we are
processing on your behalf, so as to protect your
privacy.
- We will not disclose your Personal Data to third
parties, except as provided in this Personal Data Policy in
general and in the agreement(s) between you and us in
particular.
- We will take the actions that this Personal Data Policy
and the applicable mandatory laws require, so as to protect
the security of the Personal Data we collect from you.
The remainder of this policy describes our Personal Data
handling practices in more detail. However, please note that
due to the generic nature of this Personal Data Policy, some
sections herein may not apply to you, or may apply to you only
partially, depending on the services and software that you use
and on your other interaction with us.
DEFINITIONS
This Personal Data Policy contains terms that have a
specific meaning.
"Client", “you”, means a private user or a corporate user or
other data subject who purchases, registers for use or uses our
Services and who may have submitted personally identifiable
information through the following venues: i) through the use of
our Services (including web applications), ii) Websites, iii)
telephone, iv) email communications, v) registration forms or
vi) other similar connections.
"Personal Data" means any information on a private
individual and any information on his/her personal
characteristics or personal circumstances, where these are
identifiable as concerning him/her or the members of his/her
family or household. This may include, for example, name, email
and mailing address and telephone number, billing and account
information, contact information, and other information
incidental to the Services and provision thereof.
"Services" means any products or services of "HowToCatchACheater.info" such as software, web applications or any other
services or products manufactured or distributed by "HowToCatchACheater.info", including any related support services.
"Session Data" means, inter alia, Website usage information,
such as the type of Internet browser and operating system used,
the domain name of the site from which a person browsing the
Internet came, the date, time and duration of the visit, number
of visits, average time spent on the Website, pages viewed, and
number of cookies accumulated. Session Data is typically
collected via cookies.
“Subcontractors” means any subcontractor of "HowToCatchACheater.info", which "HowToCatchACheater.info" uses to provide its
Services.
“Technical data” means security related data, technical,
statistical and analysis data, data relating to software
applications and technical user environment, metadata on files
you are handling via our Services (i.e. type (e.g. digital
photo, text document etc.), size and number of files, header
information, dates of their creation, modification and
deletion), and other similar data.
"Website" means http://www."HowToCatchACheater.info".com
–site or any other website hosted by "HowToCatchACheater.info"
or under "HowToCatchACheater.info"’s control, and its respective
sub-sites together with the respective content available from
that site and sub-sites. For the purposes of clarity: whereas
Website(s) may contain links to third-party sites, this
Personal Data Policy does not cover data collected by such
third-party sites.
CONSENTS
Based on the fact that you are our Client, by reason of law
and/or on based on the following consents we have the right to
process Personal Data pertaining to you.
You acknowledge and consent that by communicating with "HowToCatchACheater.info" or its business partners relating to our
Services, by filling out a form or survey, registering to use
our Services, by submitting information in our web
applications, by entering a contest or sweepstakes, by
registering your email address with us or emailing us, we have
the right to process Personal Data pertaining to you. We may
also collect Personal Data from you at certain points on the
Website that state that Personal Data is being collected.
You further consent that "HowToCatchACheater.info" may
further disclose or transfer any of the Personal Data to its
affiliates, subcontractors, distributors and partners located
in the EEA or outside the EEA as set out below.
Please note that our respective agreements with you define
the consents in greater detail.
TYPES OF PERSONAL DATA PROCESSED
We collect Personal Data only when necessary.
We process any data you have submitted in anonymous format
unless there is a valid reason to retain such data in
identifiable format (e.g. license management or Service
maintenance and support). We will also purposefully restrict
our own visibility to your own data that we are processing on
your behalf so as to protect your privacy.
When you become our Client, we collect Personal Data that is
necessary to provide the Services to you, such as your contact
information and billing information, your name and email
address, mail address, telephone number, country, language and
age.
You also may need to choose a password or you might be
assigned with a unique identifier, which will be used to
identify you as an authorized user and to manage the
Services.
In order to process a purchase transaction, to manage and
provide you with the Services and to be better able to serve
you, we may also collect information about the relevant Service
purchase(s) such as number of purchased licenses, purchase
history, distribution partner tendering the Services to you,
device identification data, data on technical environment (e.g.
operating system) the Service is used in, and, in the case of
storage and sharing services, Service usage data.
When providing you with support services, we may need to
collect and process data on malware infections and relevant
email identification data in a personally identifiable format,
where you have provided such data to us.
Some of the above data may be provided to us by the
distribution partner or corporate entity tendering the Services
to you.
Information collected when visiting our Website is explained
in more detail in section 10 below.
HOW PERSONAL DATA IS USED
General
We use the Personal Data in order to:
a) identify the authorized users and check customer
qualifications, process and track your transactions based on
agreement(s) between you and us (such as issuing invoices,
administering accounts, shipping, collecting and processing
payments), and for license management purposes;
b) record your use and purchases of the Services as our Client
to enable us to communicate with you about the Services for
customer relationship management purposes;
c) manage the Services and the Website and diagnose technical
matters;
d) provide, maintain, enhance and ensure the functioning of the
Services;
e) provide help and assistance for the Services and provide you
with support Services;
f) send you information about the Services (e.g. to inform you
of new versions and features) via direct messaging or other
means of communication;
g) arrange competitions and send you surveys asking questions
about your customer experience;
h) personalize our Website for you;
i) pursue Service and business development;
j) effect a corporate transaction, in connection with the sale,
merger, spin-off, or other corporate reorganization of our
corporation, where the information is provided to the new
controlling entity in regular course of business; and
k) comply with, and as permitted by, any legal or regulatory
requirements or provisions.
Marketing Activities
From time to time, we may market, sell, extend promotions,
special offers and other information relating to i) the
Services as well as ii) services of those companies with which
we have a commercial relationship. We will only do so if you
have granted us permission to do so or we are otherwise able to
do so under applicable law. In addition, we will closely adhere
to applicable laws when undertaking the above activities. We
may utilize our subcontractors and partners to undertake the
above activities on our behalf. Upon your request, we will
immediately remove you from our direct marketing list.
Session Data
We use Session Data to better understand how our Website is
navigated, where and how many visitors arrive at specific
pages, the length and frequency of stays at our Website, the
variety of searches of our Website's database, and the types of
browsers and computer operating systems used by our visitors.
We use this information to improve our Website content and ease
of use and to personalize and improve your individual viewing
experiences on our Website. Please note that when processing
Session Data, we do not process it in personally identifiable
manner.
We may generate statistics and aggregate reports for
internal use and for sharing with "HowToCatchACheater.info"
group companies, partners and advertisers. These statistics and
aggregate reports will not contain any Personal Data.
TRANSFER OF PERSONAL DATA
To Whom We Transfer Personal Data
From time to time, we may disclose Personal Data relating to
you to those Subcontractors and "HowToCatchACheater.info" group
companies who provide the Services (or parts thereof) regarding
which you have entered into an agreement with "HowToCatchACheater.info". We will share with these companies only such Personal
Data that they necessarily need to work with. We transfer all
Personal Data electronically.
Where our Clients’ Personal Data needs to be disclosed to
our Subcontractors, We require, in our contracts with them,
that they use such information solely for the purpose of
providing services to "HowToCatchACheater.info", and under the
strict instructions of "HowToCatchACheater.info", and with
respect to that information, to act in a manner consistent with
this Personal Data Policy, your agreements with us and the
mandatory laws applicable to "HowToCatchACheater.info".
To ensure better availability and provisioning of Services
in various time zones and during different times of day, some
of these entities are located in countries outside the EEA.
Where personal data is transferred from EEA to outside EEA,
"HowToCatchACheater.info" will safeguard the security and
integrity of the transferred Personal Data by appropriate means
as required by the law. We will do this by imposing appropriate
technical and/or contractual safeguards with regard to relevant
Subcontractors and "HowToCatchACheater.info" group companies
(e.g. by using data transfer clauses approved by European
Union).
From time to time, we disclose Personal Data to our
distribution partners, from whom you have purchased the
Services. We will share with these companies only such Personal
Data that is necessarily needed by such distribution partners
for purposes of undertaking their agreed activities, but not
exceeding those listed above in section 4. The commercial
parties to whom we transfer Personal Data are also bound by
agreements and by legislation to safeguard the Personal
Data.
We may also disclose your Personal Data to ensure the
availability of the Services and the Website according to our
rights under the appropriate agreements, license terms or
applicable legislation; to protect ourselves against liability
or prevent fraudulent activity; or where it is necessary to
permit us to pursue available remedies or limit any damages
that we may sustain. Kindly note that we will take these kind
of activities only if and to the extent the applicable law
allows.
We may also disclose your Personal Data to effect a
corporate transaction, in connection with the possible sale,
merger, spin-off, or other corporate reorganization of "HowToCatchACheater.info", where the information is provided to the
new controlling entity in regular course of business.
We may also disclose your Personal Data to our insurers and
to governmental regulatory agencies if and when allowed by
applicable laws.
Please note that there are circumstances not covered by this
Personal Data Policy, where the use or disclosure of Personal
Data may be justified or permitted, or where we may be
obligated to disclose information without consent. Such
circumstances may include to comply with an order or warrant
issued by or an order made by a court, person or body with
authority in relevant jurisdiction to compel the production of
information, or to comply with the court rules relating to the
production of records.
To Whom We Do Not Transfer Personal Data
We will not sell, rent, or lease your Personal Data to any
third parties. Hence, for example, we do not sell your email
addresses or your name and personal demographic information to
mass marketers.
RETAINING PERSONAL DATA
We will retain your Personal Data in our databases in
accordance with our data retention policies and applicable
laws. This period may extend beyond the end of your
relationship with us, but it will be only as long as it is
necessary for us to retain such data. For example, we may need
or be required to retain information regarding your purchase of
the Services and your payment for the same. We may also need to
retain certain information to prevent fraudulent activity; to
permit us to pursue available remedies or to limit any damages
that we may sustain; to have sufficient information to respond
to any issues that may arise later; because of agreements
between you and us; or if the law requires it.
PROTECTING PERSONAL DATA
We apply strict security measures and physical,
administrative and technical safeguards to help protect the
confidentiality and integrity of the Personal Data when
transferring, storing or processing such data. We apply these
security measures and safeguards to reduce the risk of loss,
misuse or unauthorized access, disclosure or modification of
the Personal Data.
Your Personal Data will be stored in secured locations and on
servers controlled by us, located either at our offices or at
the offices of our Subcontractors, as described below. Only
authorized personnel on register with correct
user-identification and password are allowed and able to access
the relevant information systems. The data is physically
secured in an internal and/or external fully classed data
centers/facilities, with appropriate identification procedures.
Where our Clients’ Personal Data needs to be disclosed to our
Subcontractors, we require, in our contracts with them, that
they protect all Personal Data in a manner consistent with this
Personal Data Policy and applicable laws. If you choose to
contact us through the Website or via emails, you should be
aware that any information transmitted electronically via the
Internet might not be secure.
ACCESSING AND MODIFYING YOUR PERSONAL DATA
We seek to ensure that Personal Data is as accurate,
complete and current as is necessary for the purposes for which
we use such information. We encourage you to inform us if
details of your Personal Data are changed (such as change of
address or email address).
If you wish to correct your Personal Data, which you can
indicate as incorrect, you can do so by contacting us.
At any time, you have the right to ask us to provide a copy
of the Personal Data that you have supplied and that is
retained by us. We have the right to charge a small fee for
this service according to the applicable laws.
TECHNICAL DATA
Our Services may also collect certain technical data related
to your use of the Services. Technical data is collected and
processed by "HowToCatchACheater.info" for the purposes of
enabling us to provide you with the Services and for research
and development purposes. Technical data is processed
separately from personally identifiable data. Consequently,
technical data is processed in a non-personally identifiable
manner and "HowToCatchACheater.info" undertake efforts to render
as anonymous and/or obfuscate any Personal Data contained in
such data. Technical data is processed in a personally
identifiable manner only with your express consent or where we
are unable to deliver our relevant Services to you without
processing such data in personally identifiable format.
Depending on the type of Service, you may allow/disallow
some technical data being sent, while some of the technical
data needs to be sent for respective features of the Services
to function properly. "HowToCatchACheater.info" may further
disclose or transfer any of the technical data to its
affiliates, sub-contractors, distributors and partners.
WEBSITES
General
When you visit our Website, we collect Session Data about
you in non-personally identifiable format in a number of ways,
including tracking your activities through your IP address in
the Website or most-recently-visited URL. However, we do not
collect any personally identifiable information about you
unless you voluntarily submit such information to us, for
example by purchasing an "HowToCatchACheater.info" product,
filling out a form or survey, entering a contest or
sweepstakes, registering your email address with us or emailing
us.
Cookies
When you access our Website, it may seek to place cookies on
your computer to collect Session Data. A cookie contains a
unique identification number that identifies the Website
visitor's browser. Cookies help us recognize your browser when
you visit our Website again. Please note that unless a visitor
specifically informs us of his/her identity, we will not know
who the individual visitor is.
Most Internet browsers automatically accept cookies. You can
instruct your browser, by editing its options, to stop
accepting cookies or prompt you before accepting a cookie from
the sites you visit.
If you decide not to accept our cookies, you may not be able
to access our Website or use related Website services.
10.3 Third Parties Advertising on Our Website or Together
with Our Services
Separate from any permission you provide during the process
of your relation to us as a Client, we do not share any
Personal Data about you with third-party advertisers unless you
give us permission to do so. However, we may share
non-personally identifiable information collected via cookies
to our advertising or business partners. Such advertisers may
seek to use cookies to track Session Data about the ads you
have seen and types of things in which you appear interested.
For information about accessing the advertiser links, see
below.
10.4 Purchasing "HowToCatchACheater.info" Products and
Services
When purchasing our products and/or services from our
e-store; your associated Personal Data and associated payment
and billing information shall be processed by us as explained
above in this policy. However, we do not store your payment
card information submitted in our e-store. Such information
will be instead provided to the selected payment provider and
shall be processed under such payment provider's privacy
policies.
Depending on where you are located, the e-store may
alternatively be operated by our distribution partner. In such
case, this is indicated in the e-store and the processing of
your Personal Data disclosed in connection to the license
purchase is governed primarily by the terms and privacy
policies of such distribution partner as well as the applicable
laws relating to such license purchase
10.5 Links
For your convenience, our Website provides links to other
sites. When you click on one of these links, you are leaving
our Website and entering another site. We are not responsible
for such third-party sites. You should carefully review the
privacy statements of any other sites that you visit, because
those privacy statements will apply to your visit to such other
sites and may be significantly different from our policy.
We are not responsible for the privacy policies and
practices of any linked website.
11. CHANGES TO POLICY
We will change or supplement this Personal Data Policy from
time to time. We will post an appropriate notice of changes to
the Personal Data Policy in the Website. If we make significant
changes to our statement, we may also notify you by other
means, such as posting a notice on our home page or sending an
email. Personal Data Policy changes will apply to the
information collected from the date we post the revised
Personal Data Policy to the Website, as well as to existing
information held by us.
12. CONTACT INFORMATION FOR MATTERS RELATED TO PERSONAL
DATA
If you have any questions or concerns about the matters
discussed in this Personal Data Policy, please contact us |