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PRIVACY POLICY



Posted: March 23, 2022

Effective: March 23, 2022

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, 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,
   stopzilla.com, mycleanid.com, mycleanpc.com, mycleanmac.com, mypasslock.com,
   getmydrivers.com, virusfix.com, cyberdefender.com, myhackedemail.com,
   warrantystar.com, myherotech.com, ustechsupport.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.

 1.  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 (i.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.

 2.  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.

 3.  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.

 4.  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, please contact us 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.

 5.  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.

 6.  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.

 7.  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:
     https:/www.networkadvertising.org/managing/opt-out
     https:/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.

 8.  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.

 9.  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
 10. MISCELLANEOUS
     You can access, update or correct your information, or otherwise ask us
     questions about this Privacy Policy via submitting your questions here, or
     by contacting RealDefense as follows:
     
     
     
     Customer Escalation Team
     RealDefense LLC
     150 S Los Robles Ave
     Suite 400
     Pasadena, CA 91101
     Email: privacy@realdefen.se
     
     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.

 11. FURTHER INFORMATION FOR NON-US VISITORS
     This Privacy Policy as a whole provides you with information about how we
     use, process, store, protect, and delete your data under various
     circumstances. In this section we provide some additional information
     specifically for non-US visitors or users of our Products.
     1. What are your data protection rights?
        
        We would like to make sure that you are fully aware of all your data
        protection rights. Every user is entitled to the following:
        
        The right to access: You have the right to request copies of your
        personal data. We may charge you a small fee for this service.
        
        The right to rectification: You have the right to request that we
        correct any information you believe is inaccurate. You also have the
        right to request us to complete information you believe is incomplete.
        
        The right to erasure: You have the right to request that we erase your
        personal data, under certain conditions.
        
        The right to restrict processing: You have the right to request that we
        restrict the processing of your personal data, under certain conditions.
        
        The right to data portability: You have the right to request that we
        transfer the data that we have collected to another organization, or
        directly to you, under certain conditions.
        
        If you make a request, we have one month to respond to you. If you would
        like to exercise any of these rights, please contact us at
        privacy@realdefen.se.
     
     2. What are cookies?
        Cookies are text files placed on your computer to collect standard
        internet log information and visitor behavior information. When you
        visit our websites or use our Products, we may collect information from
        you automatically through cookies or similar technology.
        
        For further information, visit allaboutcookies.org.
     
     3. How do we use cookies?
        We use cookies in a range of ways to improve your experience on our
        website and while using our Products, including keeping you signed in
        and helping us understand how you use our Products.
     4. What types of cookies do we use?
        There are a number of different types of cookies our website and
        Products use.
        
        
        
         * Functionality: we use these cookies so that we recognize you on our
           website and remember your previously selected preferences. These
           could include what language you prefer and your location. A mix of
           first-party and third-party cookies are used.
         * Advertising: we use these cookies to collect information about your
           visit to our website, the content you viewed, the links you followed,
           and information about your browser, device, and your IP address. We
           sometimes share some limited aspects of this data with third parties
           for advertising purposes. We may also share online data collected
           through cookies with our advertising partners. This means that when
           you visit another website, you may be shown advertising based on your
           browsing patterns on our website.
     
     5. How to manage cookies
        You can set your browser not to accept cookies, and the website listed
        above tells you how to remove cookies from your browser. However, as
        described above, our Products will not function correctly if you do not
        accept cookies.
     6. How to contact the appropriate authority
        Should you wish to report a complaint or if you feel that we have not
        addressed your concern in a satisfactory manner, you may contact the
        regulatory authority for privacy matters in your country.






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