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SURVEY PRIVACY POLICY
January 2021
IN BRIEF
In this privacy policy, we at F‑Secure explain how we handle personal data in
our surveys.
We collect survey data on our customers’ experience of working with us and our
products and services. We use your responses to improve our products, services,
and for other collaboration with our customers.
IN FULL
F‑Secure deploys customer surveys to acquire feedback on security services. We
use this feedback to increase our customer understanding and consequently to
improve our products and services, as well as the way that we operate on the
market.
This service-specific policy focuses on the items we believe are the most
relevant for you. Such items are in particular 1) the type of personal and
private data that the service collects, 2) what we use it for, 3) our
justification, 4) typical disclosures, and 5) for how long we store it. More
information on such topics as well as on other aspects (data subject rights,
contact information, etc.) of the processing of your personal data is also
available via the embedded links.
WHAT DATA DO WE COLLECT?
We prepopulate our survey with the data that we have on you. This typically
includes your email address, phone number, name, language, country, and other
customer relationship data. We may additionally ask for some more information,
such as age and gender, to help categorize responses. In the survey we ask about
your experience with us.
CHOICES
We collect this data only where you consent to it by responding to our survey.
You do not have to respond to us. However, we would very much appreciate that
you do so, so that we know what you value to better serve you.
OPERATOR PARTNERS
In some cases, we also conduct surveys on our operator partners’ end customers.
To effectively approach you as an operator partner’s end customer and to get
usable results, the operator provides us with baseline data on intended survey
recipients. Such data typically includes email addresses, names, phone numbers,
contact IDs, number of activated licenses, details on the offer (e.g. fixed or
mobile, number of paid licenses). We share your responses with the operator for
analysis and as feedback for future improvements. The operator processes and
stores such data according to their practices.
* If the operator manages the communication preferences and/or holds all
identifying data for the recipient, the operator is responsible for removing
those end customers who have opted out.
* If F‑Secure manages the communication preferences relating to distributed
security services for the recipient, F‑Secure is responsible for removing the
recipients who have opted out.
The Operator is the first point of contact for any additional queries from the
survey recipient.
TRANSFERS AND DISCLOSURES
We share our customers’ contact data with our affiliates and subcontractors to
enable our affiliates and subcontractors to contact customers for conducting
surveys and to provide visibility of survey results to the relevant affiliates.
The affiliates and subcontractors agree to process personal data solely as
instructed by F‑Secure. They are not allowed to use survey data for any other
purposes. They are themselves responsible for cookie practices on their sites.
Learn more
SALES AND DELIVERY
We exchange (both disclose and receive) some of your personal data with our
distribution partners (resellers of corporate IT services, operators, webstores,
etc.), who market, distribute, administer, and support our services. We provide
these companies access to such personal data that they may need for their agreed
activities. The logic of this data sharing is to provide a seamless customer
experience. This includes activities such as customer management, service
support, incident management and problem resolution, direct marketing, and
invoicing.
Our distribution partners are likely to have a pre-existing customer
relationship with you or — in the case of our corporate services — with your
employer. Such partners and corporate customers process your personal data as an
independent entity, based on their applicable privacy policies. Regardless, our
distribution partners and corporate customers must also comply with the
agreements and legislation when handling your personal data. Each such entity is
by default independently responsible for its own treatment of personal data, for
its own purposes.
SUBCONTRACTING
We may transfer or disclose some of your personal data to F‑Secure group
companies and our subcontractors who help us create the services.
Where our clients’ personal data needs to be transferred or disclosed to our
subcontractors, we require, in our contracts with them, that they use such
information solely for providing their agreed services (for example, to solve a
support case, to send it to logistics partners for product delivery, or to send
marketing mails on our behalf). We require our subcontractors to process data
pertaining to you in a manner that is consistent with our statements herein.
INTERNATIONAL TRANSFERS
F‑Secure operates globally. Consequently, some of our affiliates,
subcontractors, distributors, and partners are located outside the European
Economic Area to ensure the global reach and availability of our services. The
locations of F‑Secure affiliates can be viewed from F‑Secure’s public web pages
When we transfer personal data outside the European Economic Area, we secure
such transfers of personal data according to the requirements of the law. We do
this by imposing appropriate technical and contractual safeguards on relevant
subcontractors and F‑Secure group companies, for example by using data transfer
clauses that are approved by the European Union — the fixed content of such
clauses is available here.
We only do global or cross-border data transfers for a good reason and after
assessing the resulting privacy risk.
We store more sensitive customer data within Finland or the European Economic
Area and keep it under our own control.
OTHER USES AND DISCLOSURES
There are circumstances not covered by this privacy policy where the use or
disclosure of personal data may be justified or permitted, or where we may be
obligated by applicable laws to disclose information without acquiring your
consent or independent of service provisioning.
One example includes complying with a court order or a warrant issued by the
authorities in the relevant jurisdiction to compel the production of
information.
Similarly, there may be other circumstances where there is a justifiable
legitimate interest to disclose limited sets of information to a third party.
Examples of such disclosures include cases where we need to protect ourselves
against liability or to prevent fraudulent activity, where we analyze your use
of our products to ensure that our products are working the way you would expect
them to and that we are able to react to adverse experiences, where it is
necessary to solve or contain an ongoing problem, or where we need to meet the
legitimate information requirements of our insurers or governmental regulatory
agencies. In any such action, we will act according to the applicable laws.
We may also need to transfer your personal data as part of a corporate
transaction, such as a sale, merger, spin-off, or other corporate reorganization
of F‑Secure, where the information is provided to the new controlling entity in
the regular course of business. F‑Secure group discloses and transfers data
internally as required by our then current operational model. We do, however,
limit the disclosures internally to only those group companies, units, teams,
and individuals who have a need to know such information for the intended
purposes of processing it.
We weigh each disclosure requirement carefully and take the possibility of such
disclosure requests into account when deciding where and how we store your
personal data.
SOURCES
While we collect the majority of the above-mentioned data directly from you or
your device, we also receive data from our affiliates, distribution partners
(such as operators and retailers), and corporate entities from whom you have
purchased the services. Such entities may be our resellers, but also include our
external webstore partners. We also acquire some basic personal data (order data
on purchases) and aggregate analytical data from app stores in which our
services are sold. Such other sources may further include subcontractors who
have provided you with support for our services, or advertising partners who
have assisted us in conducting our marketing activities.
We do this to create a seamless customer experience and to have the necessary
information for solving support cases.
Typical examples of third-party sources are:
* information on your purchase made in our external webstore,
* we acquire your credentials from previous sign-in data from our operator
reseller partner, so that we can provide our service to you directly,
* we acquire your contact data from corporate decision-maker registries for
marketing purposes, and
* when you use your social media account to register to our services, we
collect the email address from your account to enable us to authenticate your
registration and to contact you.
THIRD PARTIES
Our services are provided in conjunction with our partners and our services and
websites may embed or interoperate with third-party services. This privacy
document only applies to personal data as long as that data is within F‑Secure’s
realm of influence. Where your personal data is processed by other entities for
their independent purposes, such other party is responsible for processing your
personal data in a justified manner in accordance to their policies as well as
for fulfilling your rights under data protection laws.
The most prevalent such scenarios are the following:
* Webstore. Our webstore is partially run by a third-party reseller. While the
data you enter in the registration phase is handled under F‑Secure policies,
our webstore providers’ policies apply to the actual purchase and related
activities.
* Device location queries. When you query the location of your device via our
services, the provider of maps needs to process the related geographical
data. On the publication date of this policy, F‑Secure uses Google maps in
our device location and search features. Google privacy policies shall apply
accordingly to your use of the features.
RETENTION
If you are our consumer customer, your survey responses are stored in our
customer registry for six (6) months from the response date of the respective
survey – unless you request that it be deleted sooner. The purpose for retention
is to ensure enough time for conducting a successful survey and analyzing the
data. After this, the results will be anonymized and continue to be stored as
aggregate results.
If you are our corporate customer or partner, your survey responses are stored
in our customer registry in accordance to its retention rules.
Learn more
This text complements the service-specific retention times. The default rule
under the law is that personal data should be deleted or anonymized once it is
no longer needed for its purpose.
However, some personal data needs to be nonetheless stored for longer periods of
varying lengths due to varying reasons.
Typical reasons why we deviate from the primary retention times include the
following examples:
* grace periods and backups (e.g. keeping your personal data stored for a
designated time after the end of your subscription, so that we can safeguard
the data against erroneous deletion);
* applicable laws require us to store the data (e.g. to keep track of the
purchase and payment of our services);
* to pursue available remedies or to limit any damages that we may sustain
(e.g. due to an ongoing dispute or investigation);
* to solve or contain a recurring problem or to have enough information to
respond to future issues (e.g. your support ticket related to a problem that
was not permanently corrected during your customership);
* to prevent fraudulent activity (e.g. to enforce a ban on our community);
* your personal data is incorporated to other data for a secondary purpose
(e.g. retaining logs);
* other similar circumstances, where there continues to be a legitimate need
for the ongoing storage of personal data.
The final removal of your account may be delayed to avoid disturbing the other
interactions you have with us. This is the case when you have an F‑Secure
account (e.g. you have subscribed to our consumer services with your email
address) and also i) have an F‑Secure Community account or ii) you continue to
subscribe to our marketing messages. The F‑Secure Community account deletion
policy is set out in its terms of service. You can opt out from our marketing
messages at any time.
If you have purchased our service via one of our operator partners, account
deletion is controlled by said operator partner. Upon the partner notifying us
that your subscription has been terminated, F‑Secure subsequently removes the
account. This removal leads to the deletion or anonymization of any personal
data related to the account.
If we have received your information when providing you with technical support,
the information is stored as long as the respective support case remains
unsolved. Once solved, the information is gradually deleted or anonymized within
two years from closing the case.
Analytics data collected with the user’s consent is retained for statistical
purposes and is not deleted on removal of personal data and the user account.
After termination of the account, analytics data cannot be linked to any
personally identifiable user.
Data that does not contain personal data (e.g. aggregate analytical data) is
retained as long as such data continues to be useful for the purpose it was
collected.
SECURITY
Information on the security practices that we employ to keep your data secure.
Learn more
We apply strict security measures to protect the confidentiality, integrity, and
availability of your personal data when transferring, storing, or processing it.
We use physical, administrative, and technical security measures to reduce the
risk of loss, misuse, or unauthorized access, disclosure, or modification of
your personal data.
All personal data is stored on secure servers operated by F‑Secure or our
partners with access limited to authorized personnel only.
YOUR RIGHTS
Information on your statutory rights and how to contact us.
Learn more
You have the right to the data that we have on you. In particular, you have the
following rights to the personal data that we hold on you:
* Access and rectification. You have the right to ask us what personal data we
have on you and to get a copy of the data that we can identify pertaining to
you in this context. Should you find any errors (e.g. obsolete information)
in such data, we urge you to contact our customer care to resolve the issue.
Some of our service portals allow you to update your customer information.
For such, you should update any changes to your personal data, for example
change of address or email address. If you cannot update the changes
yourself, you may inform us of the necessary changes.
* Objection. You are entitled to object to certain processing of personal data,
including for example the processing of your personal data for marketing
purposes or when we otherwise base our processing of your data on a
legitimate interest. In the latter case, you need to establish a legally
valid rationale for your objection.
* Right to be forgotten. You also have the right to request us to cease storing
your personal data and erase it. In this case you need to establish a legally
valid rationale for your request.
* Portability. You also have the right to ask for personal data that you
yourself have provided — pursuant to a contract or your consent. You may
request the data in a structured, commonly used, and machine-readable format
and further that the data is transmitted to another controller, where
technically feasible.
* Withdrawing consent. In cases where the processing is based on your consent,
you have the right to withdraw your consent at any time via relevant
settings. For identifiable service analytics data, you can find the settings
in the service user interface. You also have the right to opt out from our
marketing communications via the preference center accessible through the
link.
* Restriction. If you establish that the data we have on you is incorrect or we
have no legal right to use it, you may request that we cease any further
processing of your personal data, and merely keep it in store until the issue
is resolved.
You can exercise your rights via our customer care function. The links to
contact us are in the “Contact information” section.
Note that there may be situations where our confidentiality obligations, our
right of professional secrecy, and/or our obligations to provide our services
(e.g. to your employer) may prohibit us from disclosing or deleting your
personal data or otherwise prevent you from exercising your rights. Your above
rights are also dependent on the legal grounds based on which we process your
personal data.
If you have any complaints about how we process your personal data, or would
like further information, please contact us at any time. If you feel that we are
not enabling your statutory rights, you have the right to lodge a complaint with
a supervisory authority. In most cases, this authority is the Finnish Data
Protection Ombudsman (www.tietosuoja.fi).
CONTACT INFORMATION
If you have any questions or concerns about the matters discussed in our privacy
policies, please contact:
F‑Secure Corporation
Tammasaarenkatu 7
PL 24
00181 Helsinki
Finland
How to contact us:
* If you are a client of our consumer line of products, please contact us
via our consumer support channels.
* If you are a client of our corporate line of products, please contact us
via corporate support channels.
* You can contact F‑Secure’s Data Protection Officer by sending a message to
privacy@f-secure.com. If you wish to exercise your rights as a data subject,
please use the above links instead.
GENERAL
Information on definitions and change management.
Learn more
DEFINITIONS
This is what we mean when we make certain references within this policy.
“Client”, “you”, refers to a private or corporate user or any other data
subjects who buy, register for use, or use our services, whose devices and data
traffic are protected by our services, and who may have submitted personally
identifiable information to us. This information may have been submitted through
the use of our services, websites, telephone, email, registration forms, or
other similar channels.
“Personal data” refers to any information on private individuals that is
identifiable to them or their family or household members. This information may
include names, email and mailing addresses, telephone numbers, billing and
account information, and other, more technical information that can be linked to
you, your device, or the behavior of either, that we process while providing our
services.
“Services” refer to any services or products that are manufactured or
distributed by F‑Secure, including software, web solutions, tools, and related
support services.
“Website” refers to the f-secure.com website or any other website that F‑Secure
hosts or controls, including subsites and browser-based service portals.
CHANGES
This version of the policy clarifies, updates, and replaces the previous
version. To continue keeping this document up to date, we will make changes and
additions to this from time to time also in the future.
We will publish the changed policy document on our website or at another
interaction point where it has previously been made available. If the changes
are significant, we may also notify you by other means. Any changes will apply
starting from the date that we publish the revised policy document.
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