(Updated: December 21, 2017)
Privacy and Confidentiality of Information
Information We Collect
Personal data, including (but not limited to) the users’ name, home address, email address, contact telephone number, and credit card or other billing information (“Personal Information”) may be either required to use some of the Services, or users may have the option of providing such information. Certain of the Services may also require you to have or to create a Google, Apple, Facebook, Twitter, Instagram or other similar third-party account (each, a “Third-Party Account”) and sign in with the respective Third-Party Account login. If you do so, you authorize PSafe to access and to use certain Third-Party Account information, as applicable, which may include (but not be limited to) public information in your profile on those Services. We may collect Personal Information about you from third parties and add this information to the information we have already collected from you via the Services. PSafe may confirm the provided Personal Information by consulting with public authorities, specialized companies or databases. The information that PSafe obtains from these entities will be treated confidentially.
If the user elects to activate the anti-theft functions in DFNDR / PSafe DFNDR / DFNDR Security, (i) PSafe will collect certain of the user’s Third-Party Account information (to the extent that such user has included such information in their Third-Party Account and that such information is transferred by the corresponding third party to PSafe upon activation with such Third-Party Account) and (ii) PSafe may access and/or store the GPS location (of the device on which anti-theft was activated) for purposes of providing the anti-theft functionality.
If the user elects activate the facial recognition function offered through DFNDR Vault, the DFNDR Vault application will collect data corresponding to the faceprint of the user (“Biometric Data”). The facial-scanning and Biometric Data storage software in DFNDR Vault is provided by a third party under license to PSafe. The Biometric Data is stored locally on the user’s device and encrypted for security purposes.
PSafe automatically collects and stores some information about user activity and also about the visitors to the Websites. Such information may include (without limitation) any activities the user carries out with the Services, the URL from which the user came, the URL that led the user to PSafe’s page on Google Play, the App Store (or other similar app store), the URL subsequently accessed, the browser the user is using, the user’s IP address(es), pages/URLs visited, among other information that may be stored and retained. In the case of PSafe’s apps for Android or iOS, as the case may be, the information may also include the “IMEIMD5” of the device, Google Advertising ID or IDFA, the version of Android or iOS on the device, device information (such as model and/or device name, processor ID or serial number (MD5), manufacturer, system version, screen DPI, connection type, functions used and dates/time of use, installed applications and installation dates/time/use/removal, SIM vendor and MCC), codes that indicate the country and language of the device (or applications), and Android ID (or equivalent for iOS). PSafe may collect and store information about the activities of the users of the Services, including (without limitation) information about their devices used to access the Services (such as PC, smartphone, etc.), configuration information about their systems, metadata for their files, and the dates and times associated with their transactions and other interactions with the Services.
PSafe may also collect and store information, including Personal Information, when provided by the user or a third-party that the user has authorized, including (without limitation) name, sex, and user ID on a third-party service (for example, if the user agrees to connect their Facebook and/or Google account with the PSafe service and/or product).
PSafe may collect and store Personal Information, including the user’s name and e-mail addresses (a) along with password and user name if users register on the Services; (b) if users send correspondence to PSafe (either letters or emails or through another electronic messaging tool).
If you participate in a contest, sweepstakes or other promotion, we will collect any information you provide in connection with that promotion. We also collect other types of Personal Information that you provide to us voluntarily. We may also collect Personal Information at other points on the Websites or in the Services that state that Personal Information is being collected. When you participate in one of our questionnaires or customer surveys, we may collect additional Personal Information from you.
Use of Personal Information by PSafe
We use the Personal Information we collect to offer services and features that can be tailored to users’ needs, and even allows us to customize the Services to make the users’ experiences with PSafe as useful and enjoyable as possible. We use the Personal Information we request as follows:
- To develop internal studies about the interests, behaviors and demographics of users in order to better understand their needs and interests and therefore offer better services or provide related information.
- To improve our commercial and promotional initiatives, and to analyze the pages visited and searches performed by users, in order to improve our content and product offerings and to personalize content (and its presentation), the Services.
- To send information or messages by email about new services, display advertising or promotions, or banners of interest to our users, or news about PSafe. Should the user prefer, the user may request, by sending an e-mail to firstname.lastname@example.org, at any to be excluded from the lists related to sending promotional or advertising information.
- Winners of any commercial promotions and/or contests conducted by PSafe, or people who participate in PSafe’s loyalty programs, expressly authorize PSafe to share their names, personal data provided to PSafe to participate in the promotion, contest or program, and images (photos), in the ways it sees fit, for the purpose of advertising and/or promotion, without the right to any compensation.
- To create anonymous information records by excluding information that makes the information personally identifiable to you. PSafe may use anonymous information for any purpose. To provide users’ personal information to the legal entities that act to resolving disputes between them, such as: insurance companies, arbitration courts or other relevant courts (to resolve such disputes).
Use of Biometric Data by PSafe
The DFNDR Vault application uses the Biometric Data obtained from a user who activates its the facial recognition function for the sole purpose of providing the user with the facial recognition unlock function when accessing the application. PSafe will not use the Biometric Data for any other purposes without your express consent.
How we Disclose Personal Information
- We may share some or all of users’ Personal Information with our parent company, subsidiaries, joint ventures, or other companies under common control.
- We may share users’ Personal Information with service providers or “outsourced” companies that improve or facilitate PSafe’s operations or provide services on our behalf such as (but not limited to) transport services, call centers, or loyalty programs, among others. Nevertheless, the user agrees that PSafe is not responsible for the misuse of the user’s personal information by these companies or websites. In some cases, these service providers collect information directly from the user (for example, in the case of requests to conduct surveys or studies). In such cases, the user will receive a notification about the participation of a service provider in such activities and the user will have complete discretion over what information the user wants to provide. To facilitate such situations, and to take care of any additional information directly provided to such service providers, such service providers will use the information in accordance with their own privacy policies.
- We reserve the right to disclose anonymous information publicly without restriction.
As more fully described below, it may happen that, by virtue of court orders or legal provisions, PSafe is compelled to disclose information to relevant authorities or third parties in certain circumstances.
How We Disclose Biometric Data
PSafe does not share the Biometric Data with any third party for any purpose. PSafe will not share the Biometric Data with any third party without your express consent.
The installation, permanence and existence of cookies on the user’s device is at the user’s sole discretion, and cookies can be deleted from the device whenever the user so desires. To learn how to remove cookies from the system, it is necessary to review the Help section (or similar) of the browser.
Additionally, cookies or other similar systems installed by third parties can be found on certain pages of the Websites.
Other Disclosures – Legal Requirements
PSafe cooperates with the relevant authorities and with third parties to ensure compliance with the law, for example in areas such as protection of industrial property rights and intellectual property, privacy and personal data protection, fraud prevention and others.
PSafe may disclose the Personal Information of its users upon request of the relevant court or government authorities for the purpose of investigations conducted by them, for example (but not limited to) criminal investigations or investigations related to piracy, IT or copyright. In these situations, PSafe will collaborate with the relevant authorities in order to safeguard the integrity and security of the community and of its members, except in cases of information confidentiality determined by current legislation.
PSafe may disclose any Personal Information about its users in order to comply with an applicable law and to cooperate with the relevant authorities, as it deems necessary and appropriate in connection with any investigation of an illicit act, infringement of rights (industrial or intellectual property), or other activity that is illegal or that might expose PSafe or its users to any legal liability. PSafe shall exercise this right in order to cooperate with the compliance and enforcement of the law, as may be permitted by current legislation.
Notification for inappropriate content
Should the user verify that any content the user deems to be improper was inserted by a third party in the Websites or Services, the user must send written notice to PSafe indicating the content deemed to be improper, providing sufficient information to enable the specific identification of the alleged improper material, to the e-mail email@example.com.
Your Choices Regarding Your Information
YOU CAN STOP ALL COLLECTION OF INFORMATION BY OUR APPLICATIONS BY UNINSTALLING THE RELEVANT APPLICATION.
We will communicate with you primarily in the form of emails. You can manage the frequency and/or opt out of receiving these communications by clicking the “Unsubscribe” link at the bottom of each email. Please note that even if you unsubscribe or opt-out, we may still send you services-related communications.
If you decide at any time that you no longer wish to accept cookies from the Websites and/or the Services for any of the purposes described above, then you can instruct your browser, by changing its settings, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. Consult your browser’s technical information. If you do not accept cookies, however, you may not be able to use all portions of the Websites and/or the Services or all functionality of the Websites and/or the Services.
Information Disclosed to Third Parties
A Note About Children
PSafe does not knowingly collect information of individuals under the age of 13. If we later learn that a user is under 13 years of age, we will take steps to remove that user’s Personal Information from our databases and to prevent the user from utilizing the Services. If you believe we might have Personal Information from an individual under the age of 13, please contact us at firstname.lastname@example.org.
Security of Your Personal Data: Credit Card and Bank Account Information
How We Respond to Do Not Track Signals
We do not currently respond to “do not track” signals or other mechanisms that might enable consumers to opt out of tracking on the Websites or Services.
A Note to Users Outside of the United States
Third-Party Cloud Storage Providers
PSafe Tecnologia S.A.
Caixa Postal 11592
Avenida Nossa Senhora de Copacabana 540, Loja A
Rio De Janeiro, RJ, Brazil