Who We Are
The Avast Privacy Policy (“Privacy Policy”) applies to Avast Software
s.r.o., Privax Limited, Piriform Software Limited, Avast Deutschland GmbH
(collectively "Avast"), and unless specified, its subsidiaries,
contractors, representatives, agents, and resellers while they are working
on our behalf (collectively “we,” “us” or “our”).
Privacy Policy Contents
The Privacy Policy provides an overview of how Avast and its subsidiaries,
via our websites, products and services, handle privacy, and how we protect
your personal data.
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What personal data we collect;
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How personal data is used and for what purposes;
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When and why personal data is transferred to third parties;
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How we maintain the accuracy, integrity and security of your
personal data;
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How your personal data is retained and destroyed;
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What individual rights are available to you as regards your
personal data;
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Who you can contact if you have any questions regarding the use of
your personal data;
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Product notices describing specifics of personal data processing
within our products .
This Privacy Policy describes how we handle 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.
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.
Please refer to our supplementary product and service privacy notices of
this Privacy Policy for additional detail specific to those products and
services.
This Privacy Policy is intended for you if you are a user of our products
and services. If you are a business partner or a media contact, the privacy
notice that applies to you is located here: Business partner and PR privacy
notices.
Personal Data We Process
Personal data refers to any information relating to an identified or
identifiable natural person (“Personal Data”).
When you visit and use our websites, products and services, we may collect
data or ask you to provide certain data, including Personal Data, for the
purposes of helping us manage our relationship with you or to perform our
products or services for you. “Personal Data” includes following types of
information:
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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;
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If we link other data with your Personal Data, we will treat that
linked data as Personal Data; and
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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, credit card number, and in
certain circumstances, your billing address and your phone number. In most
circumstances, our products and services are purchased 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.
Account Data includes your name, address, email address, phone number,
photo, date of birth, gender, and interests and this data is used to
register an account with Avast.
Product Data includes two sub-categories:
If you want more detail about the Personal Data we process on a product
basis, please refer to the relevant product and service privacy notices
accessible below.
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:
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Process purchase of our products or services from us, our partners
or our trusted third- party service providers’ online stores;
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Provision the download, activation, and performance of the product
or service;
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Keep our products or services up-to-date, safe and free of errors;
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Verify your identity and entitlement to paid products or services,
when you contact us for support or access our services;
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Process your purchase transactions;
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Update you on the status of your orders and licences;
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Manage your subscriptions and user accounts; and
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Provide you with technical and customer support.
On the basis of your consent, in order to:
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Subscribe you to a newsletter or the Avast forum;
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Enable the provision of personalized ads in support of certain free
products.
We will always ask for your consent before any processing that requires it.
You can withdraw your consent anytime by contacting us, using the
‘Unsubscribe’ link or using the product settings or other choices. Upon the
consent withdrawal, we will stop the processing. The withdrawal of consent,
however, does not affect the processing already carried out before the
withdrawal.
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:
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In-product messaging and cross-selling; we will communicate
commercial promotions for products and services provided by us;
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Product development, research and to implement product features and
improvements, as well as product updates;
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Third-party analytics to evaluate and improve the performance and
quality of our products, services and websites and to understand
usage trends;
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Allow interoperability within our applications;
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Secure our systems and applications;
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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
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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.
It Is Your Choice
You can make certain choices about how your data is used by us by adjusting
the privacy settings of the relevant product. The choices for paid versions
are:
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Cross-product direct marketing: – when we offer you another product
from a company within our group;
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Cross-product development – when we collect data from one product
and use it for the development of another product;
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Third-party Ads – when we offer any third-party products.
Please note, if you purchased a product from us and in your product
settings, you do not see one or more of these choices, it means your
Personal Data is not being used for this purpose.
Within all product versions – paid and free – it is possible to turn off
processing for third-party analytics purposes, such as purchase
optimization, crash reporting, and trend analytics.
Processing of IP Addresses
For paid products including antivirus, virtual private network, 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 supplementary product and service privacy notices at
the end of this Privacy Policy for specific use of IP address by our
products and services.
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:
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Sender email addresses (e.g., of sources of SPAM);
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Recipient email addresses (e.g., of victims of targeted email
cyberattacks including phishing);
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Reply-to email addresses (e.g., as configured by cybercriminals
sending malicious email);
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Filenames and execution paths (e.g., of malicious or otherwise
harmful executable files attached to emails);
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URLs and associated page titles (e.g., of web pages broadcasting or
hosting malicious or otherwise harmful contents); and/or
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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.
Marketing and Community Networking
We have a legitimate interest in promoting our commercial offerings and to
optimize the delivery of communications to that effect to our users that
are most likely to find them relevant. We will therefore collect and
process data to that end as explained below. However, where we are legally
required to obtain your consent to provide you with certain marketing
materials, we will only provide you with such marketing materials where we
have obtained such consent from you. If you do not want to continue
receiving any marketing materials from us, you can click on the unsubscribe
function in the communication or e-mail at any time.
In-product and Email Messages
We have a legitimate interest to use Personal Data to provide notices (we
call this in-product messaging) of our latest product announcements,
software updates, and product and service performance. If you have a paid
version and you do not want to see these notices, you can shut it off in
the product settings. If you have supplied us your email address, we will
also provide notices through this channel in the form of newsletters, blog
notification or refer-to-a-friend function. Please note, if you don’t want
to be on our marketing mailing list, you may unsubscribe anytime by using
an unsubscribe link we provide you in every marketing communication we send
you.
Personalized Ads
We have a legitimate interest to support free versions of our products,
including our mobile versions, such as mobile antivirus, by serving
relevant third-party ads. Your Personal Data is used by our advertising
partners to serve the third-party ads. If you do not want to see
third-party ads, you may, at any time, change to the paid version of the
product, which does not serve third-party ads.
These advertisements are delivered to you by our advertising partners, who
process your Personal Data in order to deliver interest-based advertising.
The only information we get in this particular scenario is the minimum
information necessary in order to manage our relationship with the
advertising partners and through that, track our revenue and manage our
finances. This information is relevant to a specific advertising partner
(although the report does not list the specific ad that was clicked on).
Across all of our free mobile products and services, the following
advertising partners may be present:
How We Process Your Personal Data
We do our best to disconnect or remove all direct identifiers from the
Personal Data that we use:
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For free versions of the antivirus, this disconnection or removal
of identifiers begins when the products and services are initially
activated. For paid users of the antivirus, we keep Billing Data in
a separate database and minimize its use for anything other than
handling payments and our own finances.
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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.
Please note, consistent with the above, our processing of your Personal
Data in most cases does not require identification:
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With the paid versions, while the products and services are active
and for a necessary retention period after that, we will maintain a
copy of your direct identification in order to handle payments,
respond to support queries, for anti-fraud purposes, and to
maintain proper records of transactions.
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For the paid versions, we are technically able to connect the
provision of products and services with the Billing Data. For the
free versions, when no registration or additional collection of
information concerning a user’s identity is required, for example,
with the free antivirus, we provide the products and services
without any direct identification of the user.
For the free versions, we shall 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 and you contact us with a request
concerning your Personal Data, e.g. for a copy or deletion of your Personal
Data, please understand we are not in a position to identify you in
connection with your specific free products and services and thus we will
not be able to satisfy some of your requests. Of course, where we are not
able to satisfy some of your requests because of this, we will always
inform you of this fact.
How We Disclose Your Personal Data
We only disclose your Personal Data as described below, within the Avast
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 product and service sections. If we disclose your
Personal Data, we require its recipients to comply with adequate privacy
and confidentiality requirements, and security standards.
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 Avast 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.
Service Providers
We may use contractors and service providers to process your Personal Data
for the purposes described in this Privacy Policy and the relevant product
and service sections accessible below. We contractually require service
providers to keep data secure and confidential.
Such service providers may include in particular contact centers,
professional consultants (including to defend or exercise 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. For further information,
including the exact scope of processed Personal Data, please refer to each
company’s privacy policy set in the table above.
Trend Analytics
We have partnered with our subsidiary, Jumpshot Inc., to use information
about where our products and services are used, including approximate
location, zip code, area code, time zone, together with the URL and
information related to the URL of sites you visit online. We collectively
call this information “Clickstream Data”.
Jumpshot uses this Clickstream Data to build products and services that
provide trend analytics for companies. All direct identifiers are removed
from Clickstream Data and, as a result, all that Jumpshot gets is an
aggregated, de-identified data set of online trends.
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:
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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;
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Where such disclosure is necessary for us to enforce its legal
rights pursuant to applicable law; or
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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 [insert
link to the Mergers, Acquisitions and Restructurings section].
Cookies, Analytics and Crash Reporting
Cookies
Our websites use cookies to acquire data that may be used to determine your
physical location via your IP address and automated geolocation techniques,
or to acquire basic information about the computer, tablet, or mobile phone
that you use to visit us. See description below. While using our websites,
you will be asked to authorize the collection and use of data by cookies
according to the terms of this Privacy Policy.
We use common information-gathering tools, such as cookies, pixel tags and
Web beacons, to collect information about your general internet usage. When
you visit our websites, a cookie file is stored on your browser or the hard
drive of your device. Technologies such as: cookies, beacons, tags and
scripts are used by us and our marketing partners, affiliates, or analytics
or service providers (e.g. payment processor, etc.). These technologies are
used in analyzing trends, administering the site, tracking your movements
around the site and to gather demographic information about our user base
as a whole. We may receive reports based on the use of these technologies
by these companies on an individual as well as aggregated basis. You
authorize us and agree that we may place cookies or tracking technologies
on your device.
We may partner with a third party either to display advertising on our site
or to manage our advertising on this site and other sites. Our third-party
partner may use technologies such as cookies to gather information about
your activities on this site and other sites in order to provide you
advertising based upon your browsing activities and interests. By
continuing to browse our websites, you are aware of the use of cookies, as
described in this Privacy Policy. If you do not wish to allow the use of
cookies, you can disable them through your browser settings. We do note,
however, that not all browsers across all platforms may support this
functionality. Furthermore, 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.
Across all of our websites, we may use the following cookies or tracking
technologies:
Purpose
|
Cookie
|
Cookie Provider
|
Party
|
functionality
|
Google API
|
Google
|
3
|
|
Analytics
|
|
|
|
Optimize
|
|
|
analytics & tracking
|
Hotjar
|
us
|
1
|
|
Optimizely
|
|
|
|
Visual Website Optimizer
|
|
|
|
sat_track
|
|
|
|
AdWords
|
Google
|
|
|
DCM
|
Google
|
|
|
Facebook
|
Facebook
|
|
|
LinkedIn
|
LinkedIn
|
|
|
MyTarget
|
Vkontakte
|
|
|
Outbrain
|
Outbrain
|
|
|
AXM
|
MediaMath
|
|
retargeting
|
Bing
|
Microsoft
|
3
|
|
Captera
|
Captera
|
|
|
Criteo
|
Criteo
|
|
|
Ginga
|
Signal
|
|
|
Softonic
|
Softonic
|
|
|
salesforce
|
salesforce.com
|
|
|
Sklik
|
Seznam
|
|
|
Twitter
|
Twitter
|
|
|
Ironsource
|
Ironsource
|
|
affiliate
|
Commission Junction
|
us
|
1
|
CMS
|
Hubspot
|
us
|
1
|
podcasts
|
SoundCloud
|
SoundCloud
|
3
|
|
apex_avastLocale
|
|
|
|
apex_AVGLocale
|
|
|
locale switcher
|
hidemyassComLocale
|
us
|
1
|
|
apex_language
|
|
|
|
AVGLocale
|
|
|
|
geoip
|
|
|
cooke consent accepted by user
|
consentAccepted
|
us
|
1
|
couponfield
|
coupon for cart
|
us
|
1
|
Please note that not all of our websites use all of these cookies.
Analytics and Crash Reporting
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. 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, their tools which
we use, as well as additional information on where and how we use them.
How We Protect Your Personal Data
Safeguards for Protection of 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 virtual private network (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
Our websites, products and services are not intended to be used by nor are
they directed to children under 13 years of age, and we do not knowingly
collect their information. Exceptions do apply where we provide you with
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 the privacy
notices of these specific products. Please refer to the specific applicable
notices for this important additional information.
How Long We Store Your Personal Data
We will hold your Personal Data on our systems for the longest of the
following periods:
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For Billing Data, for as long as we have a legal obligation or for
our legitimate interests in establishing legal rights; and
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For other data, only as long as necessary for its purpose.
For the sake of clarity where we are in the position of a data controller
processing your Personal Data for our own purposes, your Personal Data will
be deleted or anonymized when it is no longer needed for its originally
stated processing purposes, or any additional compatible purpose for which
we may lawfully further process such data.
Moreover, where we are in the position of a data processor processing your
Personal Data for the purposes and on the instructions of another data
controller or data processor, we will comply with the time limits agreed
with that other controller or processor unless we are compelled by
applicable laws and regulations to delete such data sooner, or to retain it
further.
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. The
current lists of our establishments worldwide and of our service providers
who process relevant Personal Data on our behalf are available upon
request.
No Automated Decision-Making, Including Profiling
We do not take any decisions involving the use of algorithms or profiling
that significantly affects you.
Your Privacy Rights
You have 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 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 Avast’s 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
public interest by us or our own legitimate interest, including
direct marketing purposes. 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 purpose after the objection.
-
Right to withdraw his or her consent - In the case of processing
based on your consent, 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.
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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 a relevant court.
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 privacy preference
portal.
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.
Avast Privacy Portal
Furthermore, we have
created for your convenience a portal
, which can show you the Billing Data and Account Data we have collected
from you as well as your email preferences. Currently, only Personal Data
collected directly by Avast Software s.r.o., AVG, and HMA!, is available
for viewing in the portal.
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 by
e-mail at: customerservice@avast.com with the headline “PRIVACY REQUEST” in
the message line.
You have the right to revoke the consent at any time by sending us an
e-mail at: customerservice@avast.com with the headline “PRIVACY REQUEST” in
the message line. 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
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 the personal information was disclosed. We hereby
disclose that we have not disclosed any such personal information regarding
any California resident during the one-year period prior to the effective
date of this Privacy Policy. California residents seeking additional
information on this requirement or our privacy practices in general may
write to us at customerservice@avast.com with the headline “PRIVACY
REQUEST” in the message line. They may also send paper mail to Avast
Software s.r.o., Pikrtova 1737/1a, 140 00, Prague 4, Czech Republic. Please
write "Attention: PRIVACY" in the address.
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. To make such a request, please contact us at dpo@avast.com.
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-us
. Please type “PRIVACY REQUEST” in the message line of your email so we can
have the appropriate member of the Avast 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@avast.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.
Specific Products for your PC
Avast and AVG AntiVirus & Internet security products & services
Our AntiVirus and Internet security products require the collection of
usage data to be fully functional. Some of the usage data we collect
include:
-
potential malware threats to
your device and the target of those threats, including copies of
files or emails marked as potential malware, file names,
cryptographic hash, vendor, size, date stamps, associated registry
keys, etc.;
-
information about how you use our products and their features,
including data about your particular device, installation and
uninstallation rates, language, technical parameters and
manufacturer of a device, device security information (password
attributes, encryption level), etc.;
-
information about where our products and services are used,
including approximate location, zip code, area code, time zone, the
URL and information related to the URL of sites you visit online;
and
-
we collectively call this information “Clickstream Data”
We use this Clickstream Data to provide you malware detection and
protection. We also use the Clickstream Data for security research into
threats. We pseudonymize and anonymize the Clickstream Data and re-use it
for cross-product direct marketing, cross-product development and third
party trend analytics.
Avast CommunityIQ
Avast CommunityIQ is a threat monitoring service. Information about a
threat detected in your device is sent to our server, so we can observe how
the threat spreads and block it. This is vital for the functioning of our
service and our ability to keep your device secure.
When you download our products and services, you will automatically be
opted into our CommunityIQ, and your device is able to provide
security-related information when needed. You may choose to opt out via
product settings. By remaining in our CommunityIQ, you actively help
yourself and others in the Avast community to experience a higher standard
of security.
Our security experts process the data acquired by our CommunityIQ to update
our databases of viruses and infected websites, and for historical and
statistical purposes to understand where the threat is coming from, the
levels of threat per country, how many persons visited the malicious
website and the number of people we protected. We process this data for the
purposes of antivirus functionality and to protect your device.
The data is collected from your entire submission process online. For both
desktop and mobile users, this includes URLs of visited websites, IP
Addresses, approximate geolocation of user or Internet Service Provider
(ISP), device IDs together with the information on the nature of the
detected threat. We collect this information to ascertain the source of the
infection.
Geolocation gives the approximate location, for example, the latitude and
longitude of the IP Address. However, if you access a malicious website
while using Wi-Fi, then your IP Address can be location data. Depending on
your ISP, your IP Address may indicate an exact location or the location of
the ISP office or your location at a country level.
We may provide a method for manual submission of suspected malware, or a
way to add more information about the source of an infection. Files and
information submitted through this process will be retained as long as is
necessary for security research and providing you protection.
Avast File Reputation Service
FileRep is a database of executable files sourced from users who
participate in the service. The files (or their hashes, that is,
de-identified versions of the files) are stored and evaluated for the
purpose of determining which are infectious and updating virus databases.
Your participation is voluntary, and the data is stored in a way that
limits its potential to be associated with individual users, for example,
by hashing so the data is anonymous. This means it can be personally
identifiable data if reversed by a “key”. However, the risks are lowered.
In participating, you actively help yourself and others to experience a
higher standard of security.
If you do not want to participate, you can opt-out by unticking the box
‘Enable reputation services’ in the general settings menu.
CyberCapture
CyberCapture is a feature in our AntiVirus that detects and analyses rare,
suspicious files. If you attempt to run such a file, CyberCapture locks the
file from your PC and sends it to the our Threat Lab where it is analysed
in a safe, virtual environment. You are notified when the analysis is
complete.
Currently, CyberCapture triggers when you run or download suspicious files
from the Internet that CyberCapture has not previously encountered. We plan
to expand this condition in the future to cover more sources.
CyberCapture is able to handle large files, but it may take longer to
deliver such files to the Threat Lab. All files are uploaded over an
encrypted connection, which means your data is inaccessible to hackers.
When CyberCapture is enabled, we collect information about you, your device
IDs, your operating system, for example, whether you are using Windows 10 or XP,
and we know your approximate location, usually at the country level.
CyberCapture is enabled by default in the latest version of our AntiVirus.
We strongly recommend that you keep CyberCapture enabled. If you would like
to disable CyberCapture, open the
product user interface
and go to Settings.
Avast CleanUp
CleanUp is offered as a Windows program. It removes unneeded files,
registry entries, broken shortcuts and other similar items. It also
provides system tuning features like program deactivator. For it to
function, we process and store the following:
-
originating IP Address; scanned systems history including data
about operating system, patch level;
-
system health, hardware information (including CPU), graphics card
information, hard drive information;
-
system data information, which is a list of computer software
installed, directory listing of software, registry name and
entries, registry hives and executables; and
-
other operational data, for example, errors and error messages.
We use this data for operational purposes, and to provide you with a fully
functional service.
Avast Secure Browser
In the default setting, our Secure Browser will process:
-
your IP Address;
-
the GUID number assigned to your installation of the Browser;
-
cookies usage data; and
-
browser extensions.
We use the data we collect to provide the Browser’s functionality, to
monitor performance and to improve our services. You can access and manage
key privacy features from the Secure Browser’s settings:
Browser Security & Privacy Center
The built in Security & Privacy Center 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
This blocks malicious websites and downloads to help prevent your personal
computer (PC) from becoming infected with viruses,spyware, and ransomware.
Privacy Cleaner
This 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
This 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.
Avast Secure Browser will also process the following data locally on your
PC:
-
your browsing history;
-
personal information and passwords;
-
a list of permissions;
-
thumbnail-sized screenshots of websites that you visit;
-
cookies or data from websites you visit;
-
data saved by browser extensions and add-ons;
-
data on what you downloaded from websites;
-
data imported from other browsers; and
-
bookmarks.
You can manage the data stored locally on your machine in the Browser
settings. Data stored locally on your machine is not collected by our
servers.
You can manage this information in several ways:
-
you can delete your browsing history, cookies and site data by
visiting the Security & Privacy Center and using the ‘Privacy
Cleaner’ tool;
-
you can stop our Secure Browser from accepting cookies from
publisher websites by ensuring that ‘Anti-Tracking’ is turned on
from within the Security & Privacy Center;
-
you can modify the cookie setting policy under the us Secure
Browser Settings by going to Settings/Advanced settings/Security
& Personal Privacy/Content settings;
-
you can review stored passwords using the Secure Browser default password manager in
the Secure Browser Settings. Go to Settings/Advanced
settings/Passwords and forms/Manage passwords; and
-
you can view and manage your stored Autofill information in the
Secure Browser Settings. Go to Settings/Advanced settings/Passwords
and forms/Autofill settings.
Avast Passwords
Avast Passwords is a feature that stores user passwords and notes under a
single master password or fingerprint and permits the user to log on to
multiple sites using a unitary sign-on credential.
On Windows, our Passwords forms an integral part of the AntiVirus, which
can be activated by the user by either performing a smart scan or by
opening the feature in the product menu. On other platforms (Android, iOS
and Mac) Passwords is a standalone program.
When activated, Passwords will check whether you have stored any passwords
via your browser and will suggest you move these passwords to Passwords, so
they can be stored securely.
When you choose to do so, Passwords will upload these passwords and remove
them from your browser. Please note that the browser check happens locally
on your device and none of your passwords are sent to our servers.
Your passwords and other personal data are stored locally on your devices
and encrypted by the Passwords app.
However, when you choose to activate the optional feature "Synchronisation
& Backup" to synchronise and backup your passwords across all your
devices, you are required to create an account. Your personal data, that
is, your passwords and notes, which may include credit card details, will
be backed up on our remote server in a securely encrypted form, readable
only via a “master key” on your device. Thus, it cannot be decrypted by us.
The data collected by our Passwords is necessary to provide the product
functionality.
Identity Guard/Passwords/HackCheck
This functionality works in a number of ways. It allows you to check
whether the passwords to your online accounts have been compromised. We are
able to do this by searching through the database of leaks which we know
about. You can do this through a number of our products which have this
functionality.
-
Hack Check – Hack Check is our website where you can check your
leaks simply by entering your email. You will then be sent the
results of the check to your email. Our service will then also send
you periodical emails as to whether we have learned that your
credentials have leaked. You can unsubscribe from receiving these
messages by clicking the unsubscribe link in the footer of these
emails.
-
Identity Guard – Identity Guard is a function within Avast Mobile
Security where you can enter an email address and get back feedback
on whether or not your credentials have leaked. The functionality
also stores e-mail addresses with respect to which no leak was
detected, and will notify you if we learn that your credentials
leaked at a later date.
-
Password Guardian – Password Guardian is a function within the
Passwords product. When you store your credentials in the Passwords
product, in an encrypted vault, we will notify you if we learn that
your credentials have leaked elsewhere.
Antispam
Antispam is a product functionality that is designed to protect you against
unwanted emails (spam). The software may collect information contained in
emails reported by you as spam or identified as spam by a third-party tool
(Mailshell). When you report an email as spam, the email is sent to the
third party. Your consent is required for each of these submissions if you
use the default setting.
We do not collect, use or store your personal data. We do not share your
software or device ID or any of our generated IDs with the third party. In
general, Mailshell does not have information about individual users or
devices and is not able to connect any information to you. If you wish to
know in detail what data Mailshell collects from you, please go to their
website.
Avast SafePrice
When you use SafePrice, information related to certain shops or products,
URLs, the installation GUID, a timestamp of the offer, purchase, product
name and number, merchant’s name, product links, prices and the categories
of your purchased items, location at country level will be collected or
transferred to us.
This information is used to retrieve available offers, for example, coupons
or cheaper prices from third parties partnering with us. We request offers
anonymously from those third parties and will not transfer or disclose your
personal data to them.
At this stage, you do not communicate with the third party, only with us,
and we do not forward any information to the third party except your
country level geolocation and language. We do not give them your personal
identifiers, so no emails and no names.
The third parties may use cookies in relation to the services they provide
on or via SafePrice. For example, when you click on an offer presented
within the product, a cookie may be placed on your computer. Third
party/third party's partner/service provider sites, offers and/or cookies
are not controlled by us and are not subject to this privacy policy.
In the end, you buy directly from the seller. We do not have access to your
credit card details as you deal directly with the third-party companies.
Avast BackUp
The Avast BackUp service is provided by a third party under contract with
us, and the privacy policy, terms of service, and EULA of the third party
apply to any information that users provide in connection with the Avast
BackUp service.
Avast BackUp provides backup and storage capabilities for personal data
that otherwise would reside only on your computer's hard drive. For the
BackUp to work, data on your hard drive must be transferred to a centrally
hosted site so that it can be "backed up."
If your hard drive contains personal information, that information will be
transferred to the host site for storage and subsequent retrieval.
Techniques used to protect this information during storage and transmission
are described below.
Avast Omni
Avast Omni is a connected device and suite of products aimed at providing
you comprehensive security in your home and for your entire family. It has
the following features:
-
Home Network Security - this is the feature aimed at protecting
your whole home network as well as your individual devices from
threats such as various types of malware, DDoS attacks or smart
home hacking. Upon activation, OMNI will become a hub of your
device network next to your router, through which all traffic from
your connected devices will be redirected. In order for it to work,
it needs to process
device data
and service data
about the network and devices connected to it and data concerning
traffic, including but not limited to: information concerning your
devices (such as device ID, OS and its version, model and
manufacturer), the network and connections made (are you connected
to WiFi or broadband, connection speed, etc.), URLs of the websites
you visit, as well as certain metadata concerning the files you
download or some fragments of the underlying network traffic
(although we will, under no circumstances, access the contents or
decrypt it); and
-
Parental Controls, which is a feature that functions in the same
way as our standalone
“Family Space”
product.
We process this data in order to provide you with the Omni’s functionality,
in particular, to detect threats to your network and devices. We further
use this data in order to understand how users use and interact with our
product through analytics conducted either by us or by our
analytical tool providers.
In order to use Omni, it is necessary that you create and manage your Omni
through an
Avast Account
. All of the above device data and service data will then be linked to your
Avast Account.
CCleaner Desktop Apps and Other Products
All Piriform desktop apps receive usage data via log files. We collect
usage data such as your device ID, your browser type and version, your
operating system, your IP Address and information on software you have
installed as necessary for the functioning of your Piriform desktop apps
and to check if you qualify for any installer or in-app promotions we may
market. The collecting and processing of your usage data is automatic once
you install the app.
CCleaner Mac
CCleaner for Apple Mac cleans and de-clutters your hard drive, makes your
operating system run faster and helps make your browsing on the internet
more private and secure.
Recuva
Recuva is a windows app that allows you to search your hard drives and USB
drives and recover any deleted files (if deleted with standard windows
deletion).
Speccy
Speccy is a windows tool that allows you to receive an audit of your
computer hardware and software. You may publish this information to an
online page if you wish to share. The audit does not include IP Addresses (
http://speccy.piriform.com/results/HSP0RYoxXz3SniCDtOLxcJN
).
Defraggler
Defraggler allows you to optimise your older hard drives so they run
faster.
Software as a Service (SaaS) Product
SaaS products allow you to connect to and use cloud-based apps via the
Internet.
CCleaner Cloud
CCleaner Cloud is offered as both a free and paid version. The platform
allows users and businesses to remotely manage their computers centrally
from the platform.
For free users, we collect personal data including your name, email
address, IP Address and computer events, for example when you install
software. This data is necessary to provide and improve our services by
connecting this data with the usage logs. For Professional and Business
users, we collect the same personal data as for the free user and
additionally, we may collect your company name, billing information and
mobile number. The data is necessary to complete the contract when you
subscribe to our services.
CCleaner Network
CCleaner Network is a business-only product that is installed locally on
your server and allows you to manage and clean your company’s computers. We
do not receive any data as this is a local-only closed network product.
Specific Products for your Mobile
Avast and AVG Products & Services
In the sections below, we look at what data is collected when you use AMS,
AVG AntiVirus and AVG Protection for Xperia, in addition to variations of
these apps developed specifically for tablets or alternative app stores.
When you first run these apps following installation, you have the option
to subscribe to use the paid version. If you stay on the free version, we
will serve third party ads; if you do not want to view third party ads, you
may choose the paid version. Whatever your choice, your service data is not
connected to your Billing Data, because there is no Billing Data for free
users and for paid customers, as described above, your Billing Data is
collected only by the app store where you purchased the product.
If you use the free version of our apps, the services are supported by
third party ads. Choosing to install the free version means data such as
your IP Address will be provided to the third party ad server.
In some instances, Avast Mobile Security (AMS) or AVG AntiVirus may come
preinstalled on your mobile device upon purchasing it from the store and
you can deactivate them within the product Settings – Personal Privacy.
Web Shields
Web Shield Lite is on by default and is only effective on some browsers and
Android operating system versions. When enabled in a supported
configuration, the app reads URLs from the browser in realtime and sends
them to our server via the URL information service. We check the URL
against our database of known threats and then display an alert if the URL
is a known threat.
Web Shield with Accessibility is off by default. You need to grant
Accessibility permission to activate this feature. While it is the same
service as Web Shield Lite, it is capable of checking URLs in more browsers
and operating systems. The list of supported browsers and operating systems
sometimes changes due to the development of or changes to third party
services.
We may use anonymous browsing data for third party trend analytics. All
users may turn off data sharing in product Settings – Personal Privacy.
Avast AntiTheft for Android
AntiTheft is a function within AMS. It is off by default. When you choose
to turn it on, you can request location on demand from my.avast.com or through SMS commands
from another phone. AntiTheft is designed to protect data residing on your
mobile phone in the event of theft.
For AntiTheft to function, we must collect and store information about your
phone and its approved users. The types of data we collect include the
following:
-
a list of approved SIM cards;
-
a phone number to notify you in the event of unauthorized SIM card
replacement;
-
a number where calls and messages can be forwarded in the event of
theft;
-
your mobile’s unique identifier or International Mobile Equipment
Identity (IMEI) when you activate AntiTheft.
We use this data to locate and identify your lost device, and to help you
report the lost device to police and cell phone carriers. If the phone was
stolen, it may block the thief from using the device. The collected data is
used to provide you the functionality.
Last Known Location is a feature within AntiTheft, also off by default.
When you activate the feature, we send more frequent location updates to
the server to help you track your device's last known location.
Avast Call Blocker
The Call Blocker feature is only available on Android versions below 9.0.
This paragraph does not apply to Android 9.0 and above. Call Blocker is a
feature of AMS which allows you to block unwanted callers. It is off by
default. When on, we build a database of SPAM callers by analysing patterns
of high volume callers across our user base.
When you (an AMS user) call a third party, or a third party calls you, we
will have the following record in our database: the third-party phone
number, the time of the call, and an anonymous key code number assigned to
this particular record. This allows us to count the number of calls made to
a specific recipient in order to evaluate whether the call is a spam or
not. Your GUID is disconnected from this data.
We do not collect the phone numbers of our users. Therefore, the data we
collect from you is anonymized and we are not able or intending to trace
the call record to you.
However, we are able to see the phone numbers of third parties who called
our AMS users in general or which phone numbers were called by our AMS
users.
The purpose of this data collection is to identify high volume callers;
therefore, we look at aggregations, not at individuals. You may shut off
this feature in your discretion via the product Settings.
Avast Wi-Fi Finder
Avast Wi-Fi Finder for Android provides information about free hotspots. It
is based on crowdsourced data, meaning that every user has to willingly
contribute to the database.
We use the data collected for sharing with other Wi-Fi Finder users. You
may turn off data collection by not using the WIFI sharing feature. We
collect this data:
-
the location of the device when you use “submit a hotspot”;
-
names of hotspots you submit to the database;
-
some technical information about the network (speed, signal
strength, security assessment, and frequency
-
mac address and IP Address of the device;
-
the install GUID and hardware identifier; and
-
hotspot passwords.
In some Android versions, we need your location permission to scan Wi-Fi
networks for security threats. Any time we’re given the location
permission, we may use it to refine our databases of Wi-Fi networks,
including the locations of Wi-Fi hotspots and dangerous networks.
Avast Battery Saver
The Battery Saver is an app that helps you monitor what apps are running in
the background, speed up your mobile device, and save the battery. We
collect AppInfo for the purpose of delivering this feature.
Battery Saver has a functionality, Smart Profile that can switch your
device setting automatically to preserve the battery upon an event you set
up, for example, when you come home. In doing this, you have to reveal your
location Wi-Fi or give us permission to use your Android mobile operating
system’s location so that the event can be triggered. This data is stored
locally on your device and is not transmitted to us.
We track the usage of this feature via Google Analytics, so we would know
the demographic and geographic statistics of our users who have enabled
Smart Profile. We do not have information on the individual user. As Google
is a third party, the third-party privacy policy applies.
Smart Profile is enabled by default, but you may disable this via product
settings.
AppInfo
AppInfo is an Avast library used in our product features such as App
Insights, for the purposes of displaying how much time is spent on the
device, broken down by app, by total data, and by day; enhancing our cloud
based threat detection; improving other Avast products; for Avast
marketing; for third party ads; and for analytics. To this end, it analyzes
device information such as: language; make and model; operating system
version; telecom provider; and city and country. Additionally, we observe
the list of currently installed apps; the time when an app is installed or
removed; the source of an installed app; Wi-Fi and carrier data consumption
per app; time that an app is in the foreground; battery and CPU consumption
per app; and which permissions are granted to each app. The specific scope
of information collected is dependent on permissions granted to the app. We
may share statistical data that has been anonymized and aggregated
geographically and so, cannot be used to identify individuals, with third
parties for trend analytics. You can always turn off the specific features
which use data from the AppInfo library in your settings, or change your
preferences for the processing of this data in the privacy settings.
Avast ApkRep
We use the ApkRep to build a database of Android apps sourced by users of
AMS. We collect and store hashes of app files together with the
installation GUID, as well as metadata about the apps (e.g. application
package name, application signing certificate information, source market
identifier and file size). We process this on the legal basis of our
legitimate interests in analysing your data to find infectious apps and to
update our virus databases, which is necessary to continuously improve AMS
to keep you secure.
Avast Android CleanUp, AVG Cleaner, AVG Cleaner for Xperia, and CCleaner
for Android (Piriform)
Avast Android CleanUp, AVG Cleaner, AVG Cleaner for Xperia, and CCleaner
for Android (Piriform) access your device storage to delete data that is
not in use. You will be asked to allow your Android operating system to
access your device storage. The feature sees what’s in your device, for
example the apps and files you have downloaded, ranging from your music
playlist to photos. However, everything takes place locally on your device
and nothing is transmitted to our servers.
Since we do not collect or store any personal data, any data collected is
anonymous.
We also offer you a Cloud service connection for you to back up your files
so nothing important gets deleted. You may sign-in to Google Drive, Dropbox
or Microsoft OneDrive directly from CleanUp. This feature is optional. If
you use this feature, you will be storing your files with a third party and
thus this is subject to the third party’s terms of service and privacy
policy.
Avast Family Space
Avast Family Space (for parents) and Avast Companion (for children) are
mobile applications available for Android and iOS. Family Space provides
the following functionality:
(i) location monitoring - this feature monitors the location of connected
devices using their GPS location. The administrator (parent) can create and
save locations such as “home”, “school”, “gym”, “friend’s house”, etc., and
receive alerts when the connected device (child’s device) arrives or
departs a saved location. This feature also allows the parent to see the
child's location on demand, receive scheduled updates about their current
location, and see their location history. The connected device also has the
option to share its location with the administrator’s device and with other
connected devices. The connected device may also request the information of
other users in the family. The parent may set permissions in the connected
device, which will enable or disable the sharing of information from the
child’s device. This particular feature and its functionality may, however,
be affected by the scope of permissions granted by the specific user. For
example, if the parent does not grant the permission to access their
location, the ability to share this information would be limited.
(ii) content filters - this feature blocks the connected device from
accessing blocked content (apps and websites). This setting is set by the
parent (administrator) through the application in their device. Filter
defaults are suggested based on the age range of the users of the connected
device, which can be selected and further modified by the administrator.
(iii) insights - this feature allows the administrator to monitor the
connected device’s access of named apps or devices. The feature also
provides activity summaries from the connected device and location history.
Additionally, administrators can set pause on internet access and set time
limits on the connected device.
Avast processes only the data necessary to provide this functionality. This
data is processed in Avast’s cloud service environment. This processing
includes the following categories of data for both the administrator’s
device and the connected device: (i) Account Data of the parent
(administrator), (ii) Information about the users of the connected device
which the administrator chooses to input into the application, such as
names, age range or photos, (iii) location data of the devices; (iv)
information concerning app usage history and content engagement, including
names of apps, names or categories of blocked content and time limits; (v)
device and network information.
AVG Alarm Clock
When you install Alarm Clock, which is an app that you can set to wake you
up, you will also receive by default, weather (via Open Weather), news (via
Taboola), and third party ads via regular ad SDKs. You may opt out of
receiving news and weather reports via Settings – My Day Dashboard.
Through Alarm Clock, we collect and process anonymous statistical data in
our own analytics system and we share pseudonymized or anonymised data with
third-party analytics and crash reporting. We collect only the personal
data necessary for us to enable our third-party providers to send you
relevant information. You may opt out of third party analytics through
Settings – Personal Privacy.
Open Weather
You receive weather information from Open Weather, our third-party service
provider. This service is on by default and we share your approximate
location data, so you will receive relevant weather forecasts, for example,
East Coast, USA. However, if you wish to have the weather forecast for a
specific location, for example, Brooklyn, New York, you have to turn on
this setting. Apart from Alarm Clock, you can receive Open Weather on your
charge screen when you install AntiVirus, Cleaner and Battery Saver.
Taboola
Alarm Clock will also show you news articles from Taboola, our third-party
news aggregator. We share some of your data with Taboola, such as your IP
Address, your device, browser and operating system, your hardware ID, news
websites you visited and your preferred language, for you to receive locale
specific news.
AVG Gallery
Gallery is a smart app that you can install in your Android to help you
organise your photos and videos into significant moments. Through Gallery,
we collect analytics data in our internal analytics system, and through
third party analytics like Google Analytics and third party crash reporting
(Crashlytics).
AVG Gallery Doctor
Gallery Doctor is a free app that helps you free up storage space in your
mobile by identifying bad & similar photos in your Android gallery. It
does not collect any personal data.
VPN Products Privacy 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 the Privacy 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.
1. 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:
1.1 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.
1.2 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.
1.3 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.
1.4 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?
|
Avast SecureLine VPN version
E.G. SecureLine 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).
1.5 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 Avast 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 policies.
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
.
2. Where and how long we store your personal data
2.1 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
2.2 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.
3. Disclosure of your VPN information
As a rule, we do not disclose any information to other commercial parties,
with the following exceptions:
3.1 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.
3.2 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.
3.3 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.
3.4 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.