Privacy Policy – RealDefense LLC and its subsidiaries

This Privacy Policy describes how RealDefense LLC and its subsidiaries collect and use your personal data that you provide in connection with products and services in the RealDefense family, including:

• MyCleanID, MyCleanPC, MyCleanMac, MyPassLock, GetMyDrivers, VirusFix, CyberDefender, BitDefender, Hotspot Shield, System Mechanic, System Mechanic Ultimate Defense, System Mechanic Professional, System Mechanic Business, System Checkup, Privacy Guardian, Malware Killer, ByePass, System Shield Antivirus and Antispyware, Search and Recover, DriveScrubber, ioloVPN, ioloSafeSearch, STOPzilla, SUPERAntispyware, and other downloadable software RealDefense or its subsidiaries market and provide from time to time (the “Software”);
• MyCleanID, MyCleanPC, MyCleanMac, MyPassLock, GetMyDrivers, VirusFix, CyberDefender, MyHackedEmail, WarrantyStar, MyHeroTech, USTechSupport and other similar online technical support services RealDefense or its subsidiaries market and provide from time to time (the “Services”); and
• RealDefense websites including realdefen.se, iolo.com, iolovpn.com, superantispyware.com, stopzilla.com, mycleanid.com, mycleanpc.com, mycleanmac.com, mypasslock.com, getmydrivers.com, virusfix.com, cyberdefender.com, myhackedemail.com, warrantystar.com, myherotech.com, ustechsupport.com, support.com, and other websites RealDefense or its subsidiaries operate from time to time (the “Sites”).

In this Privacy Policy, the above are referred to collectively as the “Products”. This policy describes the choices available to you regarding our use of your personal data and how you can access and update this data. Products include software and services that we own and operate directly, as well as software and services that we market or provide from or on behalf of third parties.

If you have any questions regarding this Privacy Policy, please contact us via submitting your questions here. By using any of the Products you agree to be bound by this policy. If you do not agree to the terms of this Privacy Policy, please do not provide us with any personal information and do not use the Products.

The Products are intended for a general audience. We do not knowingly collect personal information from children under the age of 13. We will delete any personal information collected that we later determine to be from a user younger than the age of 13. If you are a parent or guardian of a child under the age of 13 and you believe he or she has disclosed personal information to us, please contact Customer Service using the contact information below.

The Sites are provided to users from the United States. If you are from outside the United States and visit the Sites, please be aware that the data protection laws in the United States may differ from those of the country where you are located, and your personal information may be subject to access requests from governments, courts, or law enforcement in the United States according to the laws of the United States. In addition, such data may be stored on servers located outside your resident jurisdiction and in jurisdictions that may have less stringent privacy practices than your own. By using the Sites or providing us with any information, you consent to the transfer to, and processing, usage, sharing, and storage of your information, including personal information, in the United States as set forth in this Privacy Policy.

If you are a California resident, you have certain rights as provided in the California Consumer Privacy Act (“CCPA”). For the CCPA-specific provisions of this Privacy Policy, please see Section IX below.

I. INFORMATION COLLECTED ON THE SITE

RealDefense may obtain various types of personal data about users of the Products and non-customer Site visitors. This data may include:

• Contact information (name, address, phone number, and email address);
• Information about products ordered or provided;
• Payment information, including credit card number, cardholder name, credit card verification number, and expiration date;
• Information collected through Internet-based and e-commerce activities such as information obtained from log files, cookies, clear gifs (e., web bugs), images, and scripts;
• Customer service and demographic data such as gender, income level, and information about your prior experiences with RealDefense’s products.
• Information collected from our third-party service providers; and
• Other transaction-related data.

We also use certain tracking technologies described below to collect, store, or accumulate certain non-personally identifiable information concerning your use of this Site, including your browsing history, preferences, internet addresses, unique identifiers, device types, device location, and other similar information.

II. INFORMATION COLLECTED THROUGH SOFTWARE AND SERVICES

When providing the Products we may also collect the following information about your computer or other device, including:

• Device information, such as the operating system version, processor type, disk space, memory space, and number of drivers;
• Information about software on your computer, including the version of certain software programs and when they were installed and/or upgraded; and
• Information collected from logs, configuration files, registry keys, and other system or software-level information.

The data collected under this Section II is generally anonymous and aggregated. However, if RealDefense needs to have further information to diagnose certain kinds of problems or to monitor your computer for certain events, RealDefense will ask you for permission to collect this additional information. You may authorize or revoke any authorization to identify you during software installation, or by using the control panel in the particular Product.

III. IDENTITY PROTECTION SERVICES

We provide certain Services that allow you to review your credit reports and scores and receive alerts regarding changes to your reports (the “Credit Monitoring Services”). As part of the Credit Monitoring Services, we, or our partner Identity and Credit Services, Inc. (“IDCS”), may ask you for the following types of information:

• Contact information (such as name, address, phone number, and email address);
• Sensitive personal information (such as date of birth, driver’s license number and social security number);
• Other personal information to verify your identity; and
• Certain financial information (such as credit card number).

You will have the opportunity to decline to provide such information when requesting these Services. However, this information is required in order to verify your identity, charge you the agreed upon fees for our Products, and to provide our Products to you, including communicating with third parties as necessary to provide them, such as identification verification companies, consumer reporting agencies, payment validation companies, law enforcement agencies, or other authorized parties. Without such information, we may not be able to provide some or all features of the Products.

By using the Credit Monitoring Services, you authorize IDCS and its agents and employees to obtain various information and reports about you (or about your child that you have enrolled, if applicable) to provide the Products, including, but not limited to, address history reports, name and alias reports, and criminal reports or sex offender reports.

By using the Credit Monitoring Services, you agree that you are providing written instructions and your consent in accordance with the Fair Credit Reporting Act authorizing RealDefense and RealDefense’s service providers, including but not limited to IDCS, to obtain your consumer report information, including your credit information, from the personal credit report maintained by one or more of the three nationwide credit reporting agencies (Equifax, Experian and TransUnion), or any other credit bureau from which RealDefense and its service providers obtains consumer information.

IV. RETAINING, STORING, AND ACCESSING YOUR PERSONAL DATA

With respect to the MyCleanID Identity Protection Service, you may correct, amend, delete, or update your personal information by logging into your account at mycleanid.com.

If you need to make any other changes to your account, or to change information related to any of the other Products, via submitting your questions here.

We will retain your information for as long as your account is active and as needed to provide the Products. We will retain and use your information as reasonably necessary to conduct our business, comply with our legal obligations, resolve disputes, and enforce our agreements.

V. INFORMATION USAGE

You hereby agree that RealDefense may use the personal data you submit in order to:

• Accomplish its business purposes, including to deliver or provide the Products, establish or maintain customer and business relationships, improve the Products, provide access to Internet-based and e-commerce activities, perform accounting functions, and conduct other activities as necessary or appropriate in connection with the Products.
• Market its products and services to you, and the products and services of its third-party partners, including to send you information about products, services, or promotions.
  • Opt-Out: You may opt out of these promotional communications by following the instructions in each message, or via submitting your questions here.
• Send you service updates, announcements, and alerts related to the Products, including notices of security incidents, downtime, or planned maintenance. You may not opt-out of these service communications. If you do not wish to receive them, you have the option of deactivating your account and ceasing your use of the Products.

In addition, RealDefense may sell, transfer, or disclose personal data to our service providers under written contracts as needed for such service providers to perform services on our behalf, including to fulfill our obligations to you. Service providers and business partners that are provided information under this section will not use personal data for any other purposes. If RealDefense has knowledge that a RealDefense business partner or service provider is processing your personal data in a way that is contrary to this Privacy Policy, RealDefense will take reasonable steps to prevent or stop such processing. In such case, you agree that RealDefense will not be held liable for the misuse of your data.

RealDefense may sell, transfer, or disclose personal data, including your contact information, to its affiliates, licensees, partners, and other third parties as appropriate in accordance with the terms of written agreements for legitimate business or marketing purposes.

Real Defense will, in its sole discretion, disclose your personal data to third parties in certain additional limited cases: (1) when we have reason to believe that disclosing this information is necessary to identify, contact, or bring legal action against someone who may be causing injury to or interference with the rights of RealDefense or its customers and vendors; (2) when we believe in good faith that the law requires us to do so; (3) to a subsequent owner, co-owner, or operator of a Site or applicable database or in connection with a merger, consolidation, or restructuring, or the sale of substantially all of our interests and/or assets, or other corporate change, including during the course of any due diligence process; and (4) in situations involving threats to the physical safety of any person.

We do not share your credit card information with unaffiliated third parties unless you authorize us to do so, or if it is necessary to fulfill our responsibilities, including, but not limited to, delivering a Product that you order.

Some of our pages use framing techniques to serve content to/from our partners while preserving the look and feel of our Site. Please be aware that if you provide any personal information to those partners, the privacy policies of those partners would apply. We advise you to review the policies of any such partners.

VI. INFORMATION SECURITY

Your data is of the utmost importance to us. We use Secure Sockets Layer (SSL) and other transmission technologies to encrypt your personal data so it cannot be read in transit. In addition, we use secure technology, privacy protection controls, and restrictions on employee access to safeguard your personal information in storage.

Please note, however, that although we employ industry-standard security measures to safeguard the security of your personal information, no transmissions made on or through the Internet are guaranteed to be secure. Therefore, we cannot ensure the absolute security of any information you transmit to us, and you use our Site and provide us with your information at your own risk.

VII. TRACKING TECHNOLOGIES

Because of the manner in which we offer our Products, we cannot provide them to customers who do not permit our use of cookies or whose browsers are set to reject cookies.

We and our marketing partners, affiliates, or analytics or service providers, use technologies such as cookies, beacons, tags, browser and device fingerprinting, network traffic monitoring, active scripting, recognition technologies and scripts, to analyze trends, administer the Site, tracking users’ 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 and aggregated basis.

We may not control those tracking technologies and are not responsible for them. However, you consent to potentially encountering third-party tracking technologies in connection with use of our Site and accept that our statements under this Privacy Policy do not apply to the tracking technologies or practices of such third parties.

Currently, we use or allow the use of technologies from Google, DoubleClick, Adobe, Yahoo!, and Rakuten Advertising to report on the behavior of users to our site and customers of our Products. Each of these companies has its own privacy policy that applies to their collection of information from you. We advise you to review the applicable policies and the various opt-out mechanisms available. Please contact us at the address below for links to those policies, or you can find them on the respective websites.

There may be other tracking technologies now and later devised and used by us in connection with the Site. Further, third parties may use tracking technologies in connection with our Site, which may include the collection and storing of information about your online activities over time and across third-party websites or online services.

We may partner with one or more third parties to either display advertising on the Site or to manage our advertising on other sites. Our third-party partner(s) may use tracking technologies to gather information about your activities on the Sites and other websites to provide you targeted advertising based upon your browsing activities and interests. If you wish not to have this information used for the purpose or serving you targeted ads, you may be able to opt-out by visiting: http:/www.networkadvertising.org/managing/opt-out http:/www.aboutads.info/choices

Statements regarding our practices do not apply to the methods for collecting information used by these third parties or the use of the information that such third parties collect. We do however work with third parties to make efforts to have you provided with information on their practices and any available opportunity to exercise choice. We make no representations regarding the policies or practices of third party advertisers or advertising networks or exchanges or related third parties.

VIII. OTHER SERVICES

If you click on a link to a third-party site, you will leave the Site you are visiting and be redirected to the site you selected. Because we cannot control the activities of third parties, we do not accept responsibility for any use of your personal data by such third parties, and we do not guarantee that they will adhere to the same privacy policies as RealDefense. We encourage you to review the privacy policies of any other service provider from whom you request services. If you visit a third-party site that is linked to a Site, you should read that third-party site’s privacy statement before providing any personal data.

If you use a forum on any of the Sites, you should be aware that any personal data you submit there can be read, collected, or used by other users of these forums, and could be used to send you unsolicited messages. We are not responsible for the personal data you choose to submit in these forums. You may remove your post along with your personal data you submit within these forums by contacting us here.

Our Site(s) may include social media features, such as the “Share This” button that allows you to like us on Facebook or share our content on Twitter. These features may collect your IP address and which page you are visiting on our Sites, and they may set a cookie to enable the feature to function properly. Social media features are either hosted by a third party or hosted directly on our Sites. Your interactions with these features are governed by the privacy statement of the applicable company.

IX. CALIFORNIA CONSUMER PRIVACY ACT

1. Categories of Personal Information We Collect Along with the information in the Privacy Policy as a whole, the CCPA requires us to describe the information we collect in certain “categories.” The categories we collect include:
   • Identifiers (such as real name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, or other similar identifiers);
   • Commercial information (such as transaction data);
   • Financial data (such as credit card information);
   • Internet or other network or device activity (such as browsing history and information on interaction with a website, application, or advertisement);
   • Geolocation data (at an IP-based or city/state/zip level);
   • Inference data about you drawn from the data in this section (based on user profile information);
   • Legally protected classifications (such as age and gender);
   • Other information that identifies or can be reasonably associated with you (e.g., information you voluntarily provide as you use the Products, such as additional profile information or user-generated content).
2. The Sources From Which the Categories of Personal Information Are Collected We collect personal data directly from information you provide to us; indirectly from our affiliates, service providers, and other vendors; and indirectly through your interactions with websites or advertisements.
3. Business Purposes for Our Collection of Personal Information The following is a list of the business purposes for our collection of information.
   • Complete a purchase or provide the Products you have requested, including invoicing and accounting;
   • Respond to your request for information and provide you with more effective and efficient customer service;
   • Provide you with updates and information about the Services;
   • Contact you by email, postal mail, or phone regarding our Products and third- party products, services, surveys, research studies, promotions, special events and other subjects that we think may be of interest to you;
   • Customize the advertising and content you see via the Products;
   • Help us better understand your interests and needs, and improve the Products, including through research and reports, and test and create new products, features, and services;
   • Secure our websites and applications, and resolve technical issues being reported;
   • Comply with any procedures, laws, and regulations which apply to us where it is necessary for our legitimate interests or the legitimate interests of others; and
   • Establish, exercise, or defend our legal rights where it is necessary for our legitimate interests or the legitimate interests of others.
4. Sharing of Categories of Personal Information We may share categories of personal information to accomplish the various business purposes above and as described throughout this Privacy Policy.
5. CCPA Rights Disclosure If you are a California resident, the CCPA allows you to make certain requests about your personal information. Specifically, the CCPA allows you to request us to:
   • • Inform you about the categories of personal information we collect or disclose about you and the categories of sources of such information;
     • Inform you about the business or commercial purpose for collecting personal information and the categories of third parties with whom we share/disclose personal information (which is also disclosed in this Privacy Policy);
     • Provide you with the specific pieces of personal information we collect about you; and
     • Delete personal information we have about you.
   Please note that certain information may be exempt from such requests under California law. For example, we need certain information in order to provide the Products to you. You may only make such a request twice within a twelve-month period. Requests are generally free; however, we may charge a reasonable fee or deny your request if it is manifestly unfounded, excessive, or repetitive. To make a CCPA request, please contact us here. We will request information, which at a minimum will include your name and email address, to verify your identity. We may request additional information to verify your identity before responding to a request. Under the CCPA, you may have an authorized agent submit a request on your behalf, and we will collect certain authorization and verification information from the agent and you in such circumstances. The CCPA further provides you with the right to receive information about the financial incentives that we offer to you, if any, and the right not to be discriminated against for exercising your rights under applicable law. If you would like further information regarding your legal rights under California law, please contact us here.
6. California Do Not Sell Notice and Information Request If you are a California resident, the CCPA provides you with the right to opt out of the “sale” of your “personal information.” We may allow some of our advertising partners to collect certain pieces of information from our site visitors, such as device identifiers, cookies, advertising IDs, IP addresses, and usage activity, so that we and our partners can deliver ads that are more relevant to you. This type of information sharing with our advertising partners may be considered a “sale” under the CCPA. If you want to opt out of these activities, please contact us here. Please note that some or all of the Products may not function if you choose to opt out of such activities.If you are a California resident, California Civil Code Section 1798.83 you to request and obtain from us once a year, free of charge, information about the personal information (if any) we disclosed to third parties for the third parties’ direct marketing purposes in the preceding calendar year. If applicable, this information would include a list of the categories of personal information that was shared and the names and addresses of all third parties with which we shared information in the immediately preceding twelve calendar months. If you are a California resident and would like to make such a request, please submit your request in writing to:General Counsel RealDefense LLC 150 S Los Robles Ave Suite 400 Pasadena, CA 91101 Attn: California Privacy Rights

X. MISCELLANEOUS

You can access, update or correct your information, or otherwise ask us questions about this Privacy Policy by contacting RealDefense as follows:

Customer Escalation Team RealDefense LLC 150 S Los Robles Ave Suite 400 Pasadena, CA 91101

We may update this Privacy Policy from time to time to reflect changes to our information practices. When we make changes to this Privacy Policy, we will revise the “Posted” and “Effective” dates at the beginning of this Privacy Policy. If the changes to the Privacy Policy are material, we will notify you a notice on the Site or via email if we have your email address on file.