Updated: March 06, 2024
PSafe Privacy Policy
PSafe, respects the privacy of its user´s information and safeguards its confidentiality. Also, may decide the means and purpose of processing personal data, in which case they are a “controller” of that data. We have developed this Privacy Policy to provide you with guidance regarding the types of information we collect, how we may utilize such information, as well as to inform you about your privacy rights and how the law safeguards your interests.
We advise you to carefully read this Privacy Policy to comprehend our practices concerning your Personal Information (“PI”) and how we will handle it. By visiting our Website or providing personal information to PSafe through any means, you accept and agree to the practices described in this Privacy Policy. Therefore, please check the policy periodically for updates.
This Policy is an essential part of the PSafe Terms of Use and License Agreement applying to (i) https://www.psafe.com and https://www.dfndrlab.com (and all respective subdomains) and all other website features, mobile applications, or online services owned or controlled by PSafe, and (ii) information you may submit to us through alternative channels, such as events you may attend (e.g., trade fairs) or job applications.
By accepting the Terms of Use or the License Agreement, the user accepts the policies contained in this Privacy Policy. Therefore, by using any of the Services, the user acknowledges having read and agreed to the terms and conditions of this Privacy Policy.
This Privacy Policy is presented in a layered format, allowing you to navigate to specific sections by clicking on the areas defined below.
I. IMPORTANT INFORMATION AND WHO WE ARE
II. INFORMATION WE COLLECT
III. HOW WE COLLECT YOUR PERSONAL INFORMATION
IV. THIRD-PARTY ANALYTICS PROVIDERS AND AD SERVERS; ONLINE TRACKING
V. USE OF PERSONAL INFORMATION BY PSAFE
VI. HOW WE DISCLOSE PERSONAL INFORMATION
VII. YOUR CHOICES REGARDING YOUR INFORMATION
VIII. DATA SECURITY
IX. NOTICE OF INAPPROPRIATE CONTENT
X. NOTICE TO USERS OUTSIDE OF THE UNITED STATES
XI. CALIFORNIA RESIDENTS – YOUR PRIVACY RIGHTS IN CALIFORNIA
XII. EUROPEAN RESIDENTS – YOUR PRIVACY RIGHTS IN EUROPE
XIII. BRAZILIAN RESIDENTS – YOUR PRIVACY RIGHTS IN BRAZIL
XIV. HOW TO EXERCISE YOUR RIGHTS
XV. CONTACT INFORMATION
XVI. UPDATES
PSafe continuously monitors its Privacy Policy and has a practice of reviewing it at least every 12 (twelve) months.
I. IMPORTANT INFORMATION AND WHO WE ARE
A. Objective
Our policy provides guidance on the collection, usage, sharing, and protection of your personal data. We are committed to ensuring the security and privacy of this information, maintaining transparency, and complying with data protection laws.
B. Scope
This policy applies to all personal data we collect, whether through our website, applications, services, or through direct interactions with users. It is applicable to all our data processing operations, regardless of the user’s location, and adheres to relevant data protection laws such as the General Data Protection Law (LGPD) in Brazil, the California Consumer Privacy Act (CCPA) in the United States, and the General Data Protection Regulation (GDPR)..
C. Compliance with Applicable Legislation
PSafe strictly adheres to the General Data Protection Law (LGPD), California Consumer Privacy Act (CCPA), General Data Protection Regulation (GDPR), and other relevant data protection legislations.
Aligned with our ethical practices and privacy policy, we do not sell personal data to third parties under any circumstances. Our commitment to privacy is reflected in our requirement that our partners also protect this data, ensuring users have control and visibility over their personal information
D. Children
The Services and Sites are not intended for children under the age of 16, and PSafe does not intentionally collect information from individuals under the age of 16. If PSafe discovers that it has inadvertently collected Personal Information from someone younger than 16 years old, we will take measures to remove that user’s Personal Information from our databases and prevent the user from using the Services.
If you are under 16 years old, do not register an account, make purchases, or submit any information about yourself, including your name, address, phone number, or email address. If you believe we may have personal information from an individual under the age of 16, please contact us at privacy@psafe.com
E. Changes to the Privacy Policy and Your Duty to Inform Us of Changes
This version was last updated on the date indicated at the top of this page, and historical versions can be obtained by contacting us. We reserve the right, at any time and without prior notice, to add, alter, update, or modify this Privacy Policy simply by publishing such addition, alteration, update, or modification on the Sites.
Any update or modification shall be effective immediately upon posting on the Sites. If we significal changes to this Privacy Policy, we will notify you by email or by posting a notice of such changes at https://www.psafe.com/privacy-policy/ and will amend the “Last Updated” date above. However, unless you provide your consent, PSafe will not use your Personal Information in a materially different manner from whats is stated in our Privacy Policy published at the time your Personal Information was collected. Please check this Privacy Policy regularly to ensure you are aware of any changes to our practices.
It is important that the Personal Information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us. You are responsible for maintaining the accuracy of the information you provide to us, such as your contact information. If you contact us with changes, we will make good-faith efforts to make the requested changes in our then-active databases as soon as reasonably practicable. Please note, however, that information may persist internally for our administrative purposes, and residual data may remain on backup media or for other reasons.
F. Third-Party Content, Links to Other Platforms, and PSafe Content Found Outside of the Sites or Services
This Privacy Policy only addresses our use and disclosure of information we collect from and/or about you on the Sites or through the Services. If you disclose information to third parties or authorize us to do so under this Privacy Policy, the usage and disclosure restrictions contained in this Privacy Policy will not apply to third parties. We do not control the privacy policies of third parties, and you are subject to the privacy policies of those third parties, where applicable.
The Sites and Services may contain content or links to other platforms not owned or controlled by us. We do not have control over, review, or assume responsibility for the privacy policies or content displayed on these other platforms. By clicking on such a link, you will leave our Sites or Services and go to another platform. During this process, another organization may collect your personal information or anonymous information. Please review the privacy policy of any new platform you visit.
Additionally, PSafe content (such as, among others, advertising) may be included on web pages and websites or platforms that are not associated with PSafe and over which we have no control. These third parties may collect data through the use of their own cookies, pixel tags, or other technologies, collect information independently, or request personal information. PSafe disclaims responsibility for the privacy practices or content of third parties.
II. INFORMATION WE COLLECT
Personal Information (“PI”) or personal data means any information about an individual from which that person can be identified.
We and our third-party service providers (such as, among others, Google Play and Apple Store) may collect, use, store, and transfer different types of Personal Information about you, which we categorize as follows:
- Identity Information: includes real name, nickname, username, email address, or similar identifier (including, if you have shared them with us, your user display name and/or user thumbnail image from online services).
- Contact information: this information includes billing address, postal code, shipping address, email address, and telephone numbers (and job title and company name, if applicable).
- Financial Information: includes details of bank account and payment card.
- Transaction Information: includes details about payments to and from you and other details of products or services that you have purchased from us.
- Technical Information: Internet Protocol (IP) address; operating system/version/language and platform; device type; device manufacturer; device model; screen size/density; RAM size, storage size, free/unused storage; connection type (e.g., WiFi, 4G, etc.); carrier identifiers (SIM code, mobile country code, mobile network code); installed applications/apks and their versions (including local file path), permissions, publishers, and installation sources; browser package name; and visited websites/URLs (if you have enabled anti-phishing).
- Online Identifiers: an online identifier or other persistent identifier that can be used to recognize a person, family, or device over time and across different services, including, among others, a device identifier (such as IMEI); cookies, beacons, pixel tags, advertising identifiers for mobile devices (including Google Advertising ID) or similar technology; customer numbers/internal IDs, unique pseudonyms or user aliases; phone numbers or other forms of persistent or probabilistic identifiers (i.e., identifying a person or device with a higher degree of certainty than not) that can be used to identify a specific person or device.
- Internet or Network Information: includes browsing history (URLs), search history, and details of a person’s interaction with a website, application, or Internet advertisement; also details of the connected WiFi network (if WiFi security has been enabled in some of our applications).
- Profile Information: personal email address and password, purchases or orders made by you, including your interests, preferences, product comments and responses to surveys.
- Usage Data: how you use our services and products, as well as the time of day you visited the services, among other information.
- Marketing and Communications Information: your preferences for receiving marketing from us and third parties, as well as your communication preferences.
Location Information information collected or inferred about your location using a variety of technologies, such as IP address and connected or nearby Wi-Fi networks, or precise location derived from GPS coordinates or telemetry data (including latitude/longitude).
We also collect, use, and share Aggregated Information, such as statistical or demographic information, for any purpose. Aggregated Information may stem from your Personal Information yet is not classified as Personal Information by law, as it does not directly or indirectly disclose your identity. For example, we may aggregate your Usage Data to compute the percentage of users accessing a specific website feature. However, if we combine or link an Aggregated Information in a manner that enables them to directly or indirectly identify you, we will handle the combined data as Personal Information.
We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, genetic and biometric data). We also do not collect any information about criminal convictions and offenses.
III. HOW WE COLLECT YOUR PERSONAL INFORMATION
We and our third-party service providers use different methods to gather data about you, which include:
- Direct interactions. You may choose to provide us with your identity, demographic, contact, financial, profile, or marketing and communications information by filling out forms or corresponding with us by mail, phone, email, or other means. This includes personal data you provide when:
- purchasing or subscribing to our products or services;
- creating an account through the Services;
- subscribing to emails or newsletters;
- requesting services (including demos) or other information;
- participating in a competition, promotion, or survey;
- registering for an event or attending an event in which we participate; or
- providing feedback on products, services, or websites.
- Technologies or Automated Interactions. As you interact with the webite or services, we may automatically gather Technical, Usage, and Location Information regarding your equipment, actions, and browsing patterns. We collect using cookies, pixel tags, embedded scripts, and other similar technologies. Please refer to information concerning our cookie policies in Section VII.B for further details.
- Cookies. are small data files that a website sends to your device while you are viewing the website and are stored on the device. Cookies can be used for various purposes, including monitoring website usage, personalize specific content according to your interests, ensuring you do not see the same advertisement repeatedly, speeding up your searches and purchases, and recognizing you when you return to the website and/or storing your username and password so you do not have to enter them again every time you visit. You can refuse or accept cookies by activating the appropriate setting on your browser. However, if you choose to disable cookies on your device, some features of the Sites, Services, or our content may not function properly.
- Pixel Tag. (also called transparent GIFs, 1×1 GIF web beacons, or Web bugs) are small graphic images or other web programming code that can be included on the Sites, Services, and in our email messages. Unlike Cookies, which are stored on the user’s device, Pixel Tags are embedded invisibly on web pages. Pixel Tags may be invisible to you, but any electronic image or other web programming code inserted into a web page or email can function as a pixel tag. Pixel Tags or similar technologies may be used for various purposes, including, but not limited to, counting visitors to the Sites, monitoring how users navigate the Sites or use the Services, counting how many sent emails were actually opened, or counting how many specific articles or links were actually viewed.
- Embedded Scripts. Embedded scripts are programming codes designed to collect information about your interactions with the Sites and Services, such as the links you click on. The code is temporarily downloaded to your device from our web server or a third-party service provider and remains active only while you are connected to the Sites or Services.
- Third parties or publicly available sources. We may receive personal data about you from various third parties. We may also supplement the information we collect with external records from third parties in order to provide you with information, services, or goods you have requested, to enhance our ability to serve you, and to tailor our content to you. We may combine the data we receive from these other sources with the information we collect through the Services. In such cases, we will apply this Privacy Policy to the combined information. Examples of third-party sources include:
- Technical information from analytics providers;
- Contact, financial, and transaction information from technical, payment, and delivery service providers.
- Identity, profile, and contact information from publicly available sources, including websites and internet forums.
- Activating additional features. You may provide us with additional personal information if you choose to activate optional features or services as outlined below:
- If you choose to activate anti-theft features in dfndr / PSafe DFNDR / DFNDR Security, PSafe may collect Location Information for the purpose of providing anti-theft functionality.
- If you opt to use the Identity Theft Report feature offered by dfndr security, we may collect your email address as detailed in the License Agreement.
- If you opt to utilize the Wi-Fi Security or Wi-Fi Theft Protection functions and their associated features, we may collect your Wi-Fi network categorizations and associated technical information (including, among others, network/device names, IP address, or inferred geolocation), as well as technical information about devices connected to the Wi-Fi network. This information is stored locally on your device only to facilitate the function’s use.
IV. THIRD-PARTY ANALYTICS PROVIDERS & AD SERVERS; ONLINE TRACKING
PSafe works with third parties (including advertising networks, advertising agencies, and analytics companies, collectively referred to as “Advertising Partners” and each as an “Advertising Partner”) to provide us with information regarding traffic on the Services, to serve ads, including our ads elsewhere online, and to provide us with insights about the use of the Services and the effectiveness of our ads.
These third parties may use Technical Information, Online Identifiers, Internet and Network Information, Profile Information, Usage Data, Marketing and Communications Information, Location Information, and related information to compile reports on user activity. For example, if you clicked on one of our ads that led you to our Sites or Services, our service provider(s) may inform us which ad you clicked on and where you were viewing the ad.
These third parties may set and access their own tracking technologies (including cookies, embedded scripts, and pixel tags) and may otherwise collect or have access to your technical information, online identifiers, internet and network information, profile information, usage data, marketing and communications information, location information, and related information about you. Cookies and pixel tags, including those set by third-party ad networks, may be used, among other things, to target ads, prevent you from seeing the same ads too often, conduct research on the usefulness of certain ads to you, and assist in providing analytics.
These third parties may also transfer information collected about you to other third parties when required by law or when such third parties process analytical information on their behalf. The ability of each of these third parties to use and share information collected about you is restricted by their respective Terms of Use and Privacy Policy. By using our Services, you consent to the processing of data about you by these third parties in the manner and for the purposes set out above. For a complete list of third-party analytics services, please contact us at privacy@psafe.com.
We may share technical information, online identifiers, internet and network information, profile information, usage data, marketing and communications information, location information, and related information about visitors with third-party advertising companies, analytics providers, and other vendors to help analyze how users use the Sites and Services. These analytics services may use their own software development kits (SDKs) to collect information such as the frequency and which features of the Sites and Services users use. We use this information to improve the Sites and Services.
The ability of analytics services to use and share information they collect is restricted by their respective terms of use and privacy policy, which you should refer to for more information on how these entities use this information and how you can opt out of receiving their information. use of such information.
While we may use a variety of service providers to perform advertising and analytics services, some of these companies may be members of the Network Advertising Initiative (“NAI”) or the Digital Advertising Alliance’s Self-Regulatory Program for Online Behavioral Advertising.
For additional information about targeted advertising and “opt-out” procedures for NAI members and participating companies in the DAA Self-Regulatory Program, you can visit:
- Deletion Tool NAI: https://www.networkadvertising.org/managing/opt_out.asp
- DAA Consumer Choice (for website users): https://optout.aboutads.info
- DAA AppChoices (for mobile app users): https://youradchoices.com/appchoices
- Option to delete EDAA (for European web-based data): https://www.youronlinechoices.eu
Please be advised that opting out through these mechanisms does not prevent you from receiving advertising. You will continue to receive generic ads while visiting the Services and other online locations. Some third parties may collect Personal Information about your online activities over time and across different websites.
Your browser settings may enable you to automatically transmit a “Do Not Track” signal to websites and online services you visit. However, there is no consensus among industry participants as to what “Do Not Track” means in this context. Like many websites and online services, the Websites and Services currently do not respond to or change their practices when they receive a “Do Not Track” signal from a visitor’s browser. To learn more about “Do Not Track,” you can visit https://www.allaboutdnt.com.
V. 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 (and our third-party service providers) use the Personal Information, including Usage Data, as follows:
- Delivery Service:
- To provide you with our Services and related customer support;
- To manage your registration and account creation on the Services, including verifying that your contact information is active and valid;
- To authenticate you as a user within our system;
- To provide you with information, products, or services that you have requested or agreed to receive;
- To enhance the administration of our Sites and Services;
- To process transactions that you initiate, process payments, and provide accurate billing and shipping.
- Compliance and Operations:
- To send administrative notifications via email, such as order confirmations, order status updates, security or support notices, and maintenance;
- For fraud prevention and compliance security, including enforcing our terms of service and this Privacy Policy, safeguarding our privacy, security, or property rights and/or yours or others’, and protecting against, investigating, or deterring fraudulent, harmful, unauthorized, unethical, or illegal actions;
- To fulfill our obligations and enforce our rights arising from any contracts entered into between you and us;
- To notify you about changes to our Sites or Services;
- To comply with applicable laws, legal requests, and legal processes, such as responding to subpoenas or requests from government authorities;
- To generate Anonymous Data by excluding information that makes it personally identifiable to you;
- To contact you regarding the use of the Sites or Services and, at our discretion, about changes in policies or features of our Sites or Services;
- To process your application (and perform other recruitment-related functions) if you apply for a job with us;
- To carry out other functions as described at the time of collection, with your consent, or as described in more detail in this Privacy Policy.
- Marketing:
- Sending newsletters, surveys, offers, and other promotional materials related to our Services and for other marketing purposes of PSafe;
- Marketing our products or Services, including recommending products or Services that may be of interest to you.
- Research and Development:
- To improve our websites and services;
- Presenting the content of our Sites and Services appropriately and effectively for you and your computer; and
- Improving the quality of the experience when you interact with our Sites and Services for internal business purposes.
In addition to the above, we may use Anonymous Data to analyze request and usage patterns enabling us to enhance the content of our services and improve navigation on the Services. We reserve the right to use Anonymous Data for any purpose and disclose Anonymous Data to third parties at our sole discretion.
A. EMAIL COMMUNICATIONS
You will receive our newsletters or marketing communications if you have requested information from us or if you have provided us with your data when participating in a competition or signing up for a promotion, and in each case, you consented to receive marketing communications at that time.
B. FEEDBACK
If you provide us with feedback, we may use and disclose that feedback in accordance with the terms of our Terms of Use and/or License Agreement, provided that we do not associate such feedback with your Personal Information. We may publish user comments from time to time, provided that we obtain your consent before publishing any feedback associated with your Personal Information. We will collect any information contained in such feedback and treat the Personal Information contained therein in accordance with this Privacy Policy, provided that we may contact you regarding such feedback.
C. COOKIES
A cookie is a data file that contains an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
Cookies can be categorized as”persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiration date, unless deleted by the user before the expiration date; a session cookie, on the other hand, will expire at the end of the user’s session, when the web browser is closed. Cookies typically do not contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored and obtained from cookies.
Cookies are used to better understand how individuals are using our Sites and Services; cookies will not be used for purposes unrelated to PSafe’s operations.
Most browsers allow you to refuse all or some browser cookies or to alert you when websites set or access cookies. The methods for doing so vary from browser to browser and from version to version. However, you can find information on how to block and delete cookies for some commonly used browsers through the links below:
- Chrome: https://support.google.com/chrome/answer/95647?hl=en;
- Edge: https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy;
- Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences;
- Internet Explorer: https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies;
- Opera: https://www.opera.com/help/tutorials/security/cookies/; and
- Safari: https://support.apple.com/guide/safari/manage-cookies-and-website-data-sfri11471/mac.
Please note that blocking all cookies will have a negative impact on the usability of many websites, and if you choose to block cookies, you may not be able to use all the features of our Websites or Services.
Additionally, cookies or other similar systems installed by third parties may be found on certain pages of the Sites or Services.
It is understood that this Privacy Policy covers the use of cookies by the Sites or Services and not the use of cookies by advertisers. PSafe does not control the use of cookies by third parties.
D. INFORMATION MADE PUBLIC
The Services may offer areas of public access, such as blogs or comment sections. This includes, among others, comments on PSafe’s blog. You must be aware that any information you provide in these areas may be read, collected, accessed, and used by other individuals who access them, including third parties.
VI. HOW WE DISCLOSE PERSONAL INFORMATION
We may share non-personally identifiable information, such as aggregated user statistics, at our discretion and without restrictions.
PSafe may disclose Personal Information, as disclosed at the time you provide your information, with your consent and as set forth in this Privacy Policy. For example, PSafe may share Personal Information in the following ways:
A. INTERNAL THIRD PARTIES
We may share some or all of users’ Personal Information with our headquarter, subsidiaries, joint ventures, or other companies under common control for various purposes, including for business, operational, and marketing purposes. PSafe may, and reserves the right to, share your information with any other company that is not currently but becomes a headquarter, subsidiary, or affiliate of PSafe.
You may have the opportunity to receive information and/or marketing offers from PSafe and our affiliated companies, partners, and agents. If you agree at that time to receive such communications, your Personal Information will be disclosed to that third party (or parties). For more information, please refer to the Marketing Communications section.
B. EXTERNAL THIRD PARTIES
Administrative and Legal Third Parties
PSafe collaborates with competent authorities and third parties to ensure compliance with the law, for example in areas such as protection of industrial and intellectual property rights, privacy, and personal data protection, fraud prevention, and others.
We may transfer and disclose information, including Personal Information, to third parties:
- To comply with a valid legal investigation, inquiry, or process, such as a search warrant, subpoena, statute, or court order, or if, in our opinion, such disclosure is required by law;
- To obtain or maintain insurance coverage, manage risks, seek professional advice, or establish, exercise, or defend legal claims, whether in court proceedings or in administrative or out-of-court proceedings;
- To protect the safety, interests, rights, property, or security of PSafe, you, or any third party;
- To respond to a breach or attempted breach of the security of our Sites or Services;
- To defend or enforce our legal rights under any of the Terms of Use, any policies applicable to the Services, or any other contract you may have with PSafe; or
- At the request of government authorities conducting an investigation.
We may also use Technical Information to identify users and do so in cooperation with copyright owners, Internet service providers, wireless service providers, or law enforcement agencies, at our discretion.
Third-Party Service Providers
We may share users’ Personal Information with service providers or “third-party” companies that enhance or facilitate PSafe’s operations or provide services on our behalf, such as (but not limited to) transportation services, call centers, or loyalty programs, among others. However, 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 purchases through application stores, or requests to conduct surveys or studies). In these cases, the user will receive notification of a service provider’s involvement in such activities, and the user will have complete freedom over which information to provide.
To facilitate such situations and to handle any additional information provided directly to these service providers, these service providers will use the information in accordance with their own privacy policies.
Third-Party Payment Processing
As of the date of this Privacy Policy, all online payments for the Services will be processed through Google Play (https://play.google.com/store) depending on the user’s device. We do not process, record, or store information from your credit card or bank account, and all transactions made on Google Play and the App Store are subject to their respective terms of service available at https://play.google.com/intl/en_us/about/play-terms.html.
For more information on how payments are handled or to understand the security and privacy of data provided by these platforms, please refer to https://www.google.com/intl/en/policies/privacy/ (for Android devices).
Promotions or Contests
Winners of any commercial promotions and/or contests held by PSafe, or individuals participating in PSafe’s loyalty programs, expressly authorize PSafe to share their names, personal data provided to PSafe for participation in the promotion, contest, or program, and images (photos), in the ways it deems fit, for advertising and/or promotional purposes, without entitlement to any compensation.
C. SHARING AMONG PSAFE COMPANIES; BUSINESS TRANSFERS
We may share and disclose some or all of users’ Personal Information in connection with or during the negotiation of any merger, financing, acquisition, or dissolution, transaction or process involving the sale, transfer, disposal, or disclosure of all or part of our business or assets.
In the event of insolvency, bankruptcy, or receivership, Personal Information may also be transferred as a business asset. If another company acquires our company, business, or assets, that company will possess the Personal Information collected by us and will assume the rights and obligations regarding users’ Personal Information as described in this Privacy Policy. These transfers and disclosures may be made without prior notice.
VII. YOUR CHOICES REGARDING YOUR INFORMATION
YOU CAN STOP ALL INFORMATION COLLECTION BY OUR APPS BY UNINSTALLING THE RELEVANT APP.
Additionally, you have several options regarding the use of information on our Sites and Services:
A. CANCELLATION
We will primarily communicate with you via 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 service-related communications, including notices of any updates to our Terms of Use or Privacy Policy.
You can also contact support@psafe.com to request an “exclusion” that removes your email from visibility in the Identity Theft Report searches, instead of permanently deleting it (to ensure that if the email address appears in subsequent Data Breach information obtained by PSafe, it cannot be searched again); please note that an email address subject to an “exclusion” request may remain searchable if you complete a standard email verification process related to that specific email address.
B. COOKIES
If you decide at any time that you no longer wish to accept cookies from the Sites and/or 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 sites you visit. Please refer to your browser’s technical information and review the information in Section V.C for further information on how to do this. However, if you do not accept cookies, you may not be able to use all portions of the Sites and/or Services or all functionalities of the Sites and/or Services.
C. ACCESS, UPDATE, CORRECT, OR DELETE INFORMATION
You can review, change, update, or correct your Personal Information by contacting us at privacy@psafe.com. You authorize us to use and disclose any new or modified information that you provide in accordance with this Privacy Policy.
You may request the deletion of your personal information that PSafe has obtained until the date of your deletion request from our systems. Please note that we may be required to maintain information for a certain period, in which case we will only proceed with the deletion of your dataafter we have fulfilled such requirements.
We may also retain an archived copy of your records as required by law or for legitimate business purposes. Certain users (e.g., residents of California) have additional rights detailed in Section XI below.
Please note, however, that if we have already disclosed some of your Personal Information to third parties, we may no longer have access to that Personal Information and we cannot force the deletion or modification of such information by the parties to whom we made such disclosures. When we delete Personal Information, it will be deleted from the active database, but it may remain in our files.
D. OPT-OUT OF SHARING PERSONAL INFORMATION
You may choose not to provide us with any Personal Information. In this case, you will still be able to access and use our Sites and Services, except the parts that require your Personal Information.
When we need to collect Personal Information by law, or under the terms of a contract, and you fail to provide such information when requested, we may have to cancel a product or service.
E. MARKETING COMMUNICATIONS
We provide you options regarding certain uses of Personal Information, especially in terms of marketing and advertising. As described in Section A, you have the ability to opt out of receiving communications.
Please note that you may continue to receive service-related communications and other non-marketing communications.
VIII. DATA SECURITY
PSafe uses commercially reasonable security measures to safeguard protect your personal information against accidental loss, unauthorized access, use, alteration, or disclosure. Additionally, we restrict the access to your personal information to employees, agents, service providers, and other third parties who have a commercial need to know.
However, please note that no system can be completely secure, and while PSafe makes every reasonable effort to protect the integrity of the information you provide, we do not guarantee or warrant the security of any information we collect. You use our services and provide us with your information at your own risk.
It is important to mention that the security of your information also depends on you, by being accountable for keeping the information safe, such as passwords. We ask that you do not share them with anyone.
Additionally, we have procedures in place to deal with any suspected Personal Information breach and will notify you when legally required to do so.
IX. NOTIFICATION FOR INAPPROPRIATE CONTENT
In case that a user discovers any inappropriate content, that has been posted by third parties on the Sites or Services, it should be sent a written notification to PSafe indicating the content, providing sufficient information to enable the specific identification of the material, to the email privacy@psafe.com.
X. A NOTE TO USERS OUTSIDE OF THE UNITED STATES
If you are a user from outside the US, by visiting the websites or using our services, you acknowledge and agree that your Personal Information may be processed for the purposes identified in this Privacy Policy. Additionally, your Personal Information might be stored in a database located in Brazil and/or the United States, through AWS Amazon Web Services. Additionally, processing will occur in the country where it was collected. By providing your data, you consent to such transfer.
XI. CALIFORNIA RESIDENTS – YOUR PRIVACY RIGHTS IN CALIFORNIA
This section applies only to residents of California. It describes how we collect, use, and share Personal Information of California residents in the operation of our business and your rights regarding this Information. For the purposes of this section, “Personal Information” has the meaning attributed to the California Consumer Privacy Act of 2018 (“CCPA”), but does not include information exempt from the scope of the CCPA.
Your Privacy Rights in California. If you are residing in California, you are entitled to the rights detailed below.. However, these rights are not absolute and, in certain cases, we may refuse your request as permitted by law.
| Your Rights | Explanation |
| Information | You may request the following information about how we collected and used your personal information during the last 12 months:
|
| Access | You may request a copy of the Personal Information we have collected about you during the last 12 months. |
| Deletion | You may ask us to delete the personal information we have collected from you. |
| Opt-Out of Sales | If we sell your personal information, you may opt-out. Additionally, if you instruct us not to sell your Personal Information, we will consider this as a request under the California “Shine the Light” law to stop sharing your personal information covered by that law with third parties for direct marketing purposes. |
| Activate | If we know you are under 16, we will ask for your permission (or, if you are under 13, the permission of your parents or guardians) before selling your Personal Information. |
| Non-Discrimination | You have the right to exercise the rights described above without discrimination. This means we will not penalize you for exercising your rights by taking actions such as denying you services; increasing the price/fee of services; decreasing the quality of service; or suggesting that we may penalize you as described above for exercising your rights. |
XII. EUROPEAN RESIDENTS – YOUR PRIVACY RIGHTS IN EUROPE
We are committed to complying with the rights of personal data subjects, as stipulated in Articles 13 to 22 of the GDPR.
| Your rights | Explanation |
| Right to Information (Art. 13 and 14) | You have the right to receive clear and transparent information about the processing of your personal data, including the purposes of processing, categories of data involved, retention period, and other relevant information. |
| Access (Art. 15) | You can request a copy of the Personal Information we have collected about you in the last 12 months, including:
|
| Rectification (Art. 16) | You can ask us to rectify your personal data that is processed by the Organization. |
| Erasure (Art. 17) | You can request the deletion of your personal data, and it will be deleted when:
|
| Processing Restriction (Art. 18) | You may request restriction of processing when one of the following situations applies:
|
| Data portability (Art. 20) | You may request to receive your data in a structured format, and you may request that your data be transmitted directly from one data controller to another, whenever technically feasible. |
| Opposition (Art. 21) | You may object to the processing of your personal data at any time for reasons related to your particular situation, including profiling based on those provisions. |
| Automated Decisions and Profiling (Art. 22) | You have the right not to be subject to decisions based solely on automated processing, including profiling, which have legal effects on you or significantly affect you. |
XIII. BRAZILIAN RESIDENTS – YOUR PRIVACY RIGHTS IN BRAZIL
The rights of the personal data subject is stipulated in LGPD, article 18, which are:
| Your Rights | Explanation |
| Confirmation and Access | You may request PSafe to confirm the existence of processing of your Personal Data so that, if positive, you may access them, including by requesting copies of the records we have about you. |
| Correction | You may request the correction of your Personal Data if they are incomplete, inaccurate, or outdated. |
| Anonymization, Blocking, or Deletion | You may request (a) the anonymization of your Personal Data, so that they can no longer be related to you and, therefore, cease to be Personal Data; (b) the blocking of your Personal Data, temporarily suspending the possibility of processing them for certain purposes; and (c) the deletion of your Personal Data, in which case all your Personal Data will be erased without the possibility of reversal. |
| Portability | You may request PSafe to provide your Personal Data in a structured and interoperable format for transfer to a third party, provided that such transfer does not violate the intellectual property or trade secrets of the Company. |
| Information about Sharing | You have the right to know which public and private entities PSafe shares your Personal Data with.
We will keep an indication of our relationships with third parties that may involve the sharing of Personal Data in the “data sharing” section of this Policy. In any case, if you have any questions or want more details, you have the right to request this information from us. Depending on the case, we may limit the information provided to you if its disclosure may violate PSafe’s intellectual property or trade secrets. |
| Revocation of Consent | If you have consented to any purpose of processing your Personal Data, you may always choose to withdraw your consent. However, this will not affect the legality of any processing carried out prior to the revocation. If you withdraw your consent, we may be unable to provide you with certain services, but we will notify you when this occurs. |
| Information about the Possibility of Not Consenting | You have the right to receive clear and complete information about the possibility and consequences of not providing consent when requested by PSafe. Your consent, when necessary, must be freely given and informed. Therefore, whenever we ask for your consent, you will be free to deny it – in these cases, it may be that some services cannot be provided. |
| Objection | The law authorizes the processing of Personal Data even without your consent or a contract with us. In these situations, we will only process your Personal Data if we have legitimate reasons to do so, such as when it is necessary to ensure security in our services. If you do not agree with any purpose of processing your Personal Data, you may object by requesting its interruption. |
XIV. HOW TO EXERCISE YOUR RIGHTS
You can exercise your privacy rights as follows:
Right to information, access, and deletion.
You can request the exercise of your rights to information, access, and deletion by:
- sending us an email to dpo@psafe.com
We must confirm your identity and place of residency to process your requests to exercise your rights. If you do not provide us with sufficient details, we may not be able to process your request respond to it.
To facilitate the provision of information about the processing of personal data, a Privacy Portal. You can access it to ask your questions.
Personal information we collect, use, and share
The chart presented below provides a summary of how we collect, use, and share Personal Information, in accordance with the legal categories outlined in the CCPA.
| Statutory category of personal Information (PI) |
PI we collect | Source of the PI | Purpose for collection | Categories of Third Parties to whom we “disclose” the PI for a business purpose | Categories of Third Parties to whom we “sell” the PI |
| Identifiers | · Identity Information
· Contact Information · Profile Information |
· You
· Advertising Partners · Public Sources · Business partners · Our Clients
|
· Service Delivery
· Research & Development · Marketing · Compliance & Operations |
· Internal Third Parties
· Advertising Partners · Third Party Service Providers · Administrative & Legal Third Parties · Business Transferees |
· None |
| Commercial Information | · Identity Information
· Contact Information · Transaction Information · Marketing and Communications Information |
· You
· Our Clients · Advertising Partners · Third Party Service Providers
|
· Service Delivery
· Research & Development · Marketing · Compliance & Operations |
· Internal Third Parties
· Third Party Service Providers · Administrative & Legal Third Parties · Business Transferees |
· None
|
| Financial Information | · Financial Information | · You
· Public sources · Business partners · Our Clients
|
· Service Delivery
· Research & Development · Marketing · Compliance & Operations |
· None | · None |
| Online Identifiers | · Technical Information
· Usage Data · Identity Information |
· You
· Our Clients · Automatic Collection
|
· Service Delivery
· Research & Development · Marketing · Compliance & Operations |
· Internal Third Parties
· Third Party Service Providers · Professional Administrative & Legal Third Parties · Business Transferees |
· Advertising Partners (to facilitate online advertising)
|
| Internet or Network Information | · Technical Information
· Usage Data |
· You
· Our Clients · Automatic Collection |
· Service delivery
· Research & development · Marketing · Compliance & Operations |
· Internal Third Parties
· Third Party Service Providers · Administrative & Legal Third Parties · Business Transferees |
· Advertising partners (to facilitate online advertising)
|
| Geolocation Data | · Geolocation Data |
· Automatic Collection (when enabled by user) |
· Service delivery
· Research & development · Marketing · Compliance & Operations |
· Internal Third Parties
· Third Party Service Providers · Administrative & Legal Third Parties · Business Transferees |
· Advertising partners (to facilitate online advertising) |
| Inferences | May be derived from your:
· Technical Information · Usage Data · Online Identifiers · Location Information and/or Geolocation Data · Profile Information |
· You
· Automatic Collection |
· Service delivery
· Research & development · Marketing · Compliance & Operations |
· Internal Third Parties
· Third Party Service Providers · Administrative & Legal Third Parties · Business Transferees |
· Advertising Partners (to facilitate online advertising) |
| Protected Classification Characteristics | · We do not intentionally collect this Information, but it may be inferred from or revealed in Identity Data or other Information we collect | · None |
XV. CONTACT INFORMATION
If you have any inquiries or concerns regarding our Privacy Policy, our data collection or processing, or should you wish to report any security breaches, we encourage you to reach out to us via the email address listed below.
E-mail: privacidade@psafe.com.
PSafe’s Data Protection Officer (DPO):
If necessary, you can also contact our Data Protection Officer/DPO:
Data Protection Officer (DPO) Responsible: Maurício José Ribeiro Rotta
GEP Soluções em Compliance – dpo@psafe.com.
XVI. ATUALIZAÇÕES
As we are commited to improve our services his Privacy Policy may undergo updates to reflect improvements. We recommend making periodic visits to this page to ensure that you stay informed about any modifications.
| Version | Publication Date | Responsible |
| 1.0 | 07/20/2022 | GEP Soluções em Compliance |
| 2.0 | 03/06/2024 | GEP Soluções em Compliance |