Last updated Dec 2022
ReputationDefender, part of Gen Digital Inc. and NortonLifeLock Ireland Limited (“we”, “us”, or the “Company”), is committed to protecting the privacy of individuals who visit the Company’s Website (“Visitors”) and of those individuals and businesses who purchase or use ReputationDefender products and services (“Customers”).
We do not, and will not without consent, sell, lease, or rent your information to third parties for monetary or other valuable consideration.
If you are in the European Economic Area, and unless stipulated otherwise contractually, the Controller of your personal data is:
NortonLifeLock Ireland Limited
Ballycoolin Business Park
2. THE INFORMATION WE COLLECT
- In some areas of the Site (such as when you set up an account or provide information for the Company to contact you or when you ask for additional information) and in connection with our services, we may give you an opportunity to provide to us Personal Information, including your name, address, email address, telephone number, username[s], credit card number, billing information, and other information which, either alone or in combination, can be used to identify you (“Personal Information”). (We do not consider information that has been aggregated and anonymized so as not to be identifiable to be Personal Information.)
- In addition, in order to effectively deliver our services and products, we may from time to time afford you the opportunity to provide descriptive, behavioral, preferential, and/or lifestyle information about yourself, but it is solely up to you whether you furnish such information.
- We may collect your Personal Information from third-party sources and platforms (such as online review sites, social media, or other sites on the Internet), including if you request that we do so by signing up for one of our Services that involves collecting or tracking your Personal Information.
- We will retain your information for at least as long as your account is active, or otherwise as needed to provide you services. We may also keep your information for longer periods of time consistent with our normal business practices and record-keeping requirements. If you wish to cancel your account or request that we no longer use your information to provide you with our services or request that we no longer maintain your information, please contact us at email@example.com. We will respond to your request within 30 days. We will automatically delete your personal data thirty six (36) months after termination of your contract with us.
- We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. We also collect analytical data related to the performance of this Site via tracking technologies. This data is in no way associated with your Personal Information. (See “Cookies and Tracking Technologies” below.)
3. OUR USE AND DISCLOSURE OF INFORMATION
We may use your Personal Information for various purposes, depending on the type of information we have collected from and about you and the specific Services you use, in order to:
- Respond to your requests for Services or information;
- Provide you with updates and information about our Services;
- Verify your identity, and for fraud prevention;
- Process your payments (as explained above, such payments will be processed by our third-party payment processor, not by us);
- Help us better understand your interests and needs, in order to improve the Services;
- Engage in analysis, research, and reporting regarding the use of our Services;
- Contact you regarding our products, services, surveys, or promotions, or those of companies we have partnered with;
- Tailor the content and information that we may send or display to you, market, or retarget content or marketing to you;
- Provide, manage, and improve the Services and test and create new products, features, and services;
- Understand and resolve any technical and security issues reported on our Sites;
- Comply with the law and protect the safety, rights, property, or security of Company, the Services, and the general public;
- Enforce any legal terms that govern your relationship with us or your use of the Services;
- For any other purpose, with your consent.
Aggregate/De-identified/Anonymous data. We may aggregate, de-identify and/or anonymize any information collected through the Services so that such information is no longer linked to your Personal Information (such as your name, address, phone number, or email address). We may use aggregated and anonymized information for any purpose, including, without limitation, for research, and marketing purposes.
4. HOW WE DISCLOSE OR SHARE YOUR INFORMATION
- We also may disclose information (a) in response to a subpoena, warrant, court order, levy, attachment, order of a court-appointed receiver, or other comparable legal process, including subpoenas from private parties in a civil action, (b) where necessary to defend or protect our rights, or (c) in order to protect ourselves, our customers, or any third party from crime or potential crime.
- We disclose information to your agent or legal representative (such as the holder of a power of attorney that you grant, or a guardian appointed for you).
- We share information with companies that provide public relations and marketing services for us. Such information will be used to customize, measure, and improve our products, services, and advertising.
- We share your information with our parent, subsidiaries, and joint ventures to help coordinate the services we provide to you, enforce our terms and conditions, and promote trust and safety.
- The implementation of our Services, by its very nature, may require using your Personal Information to locate other information about you. Such use may include, but not be limited to, using your information to search publicly accessible Internet sites as well as searching private information databases and sites.
- The implementation of Services you have requested, by its very nature, may require revealing your Personal Information in order to post review responses, post on social media sites, etc. For example, we may have to disclose your name to a review website in order to post a response to a review.
5. SPECIAL OFFERS AND UPDATES
Using your name and email address, we will occasionally send you information on products, services, discounts, and promotions related to Gen Digital. You can sign up for these emails on our registration page during the registration process. Out of respect for your privacy, we present you with the option not to receive these types of communications each time we send you such communications. Please see “Choice and Opt Out” for more information.
6. PUBLIC FORUMS
The Site offers publicly accessible blogs. You should be aware that any information you provide in these areas may be read, collected, and used by others who also access them. To request removal of your Personal Information from our blog, contact us at firstname.lastname@example.org.
7. SOCIAL MEDIA AND FACEBOOK CONNECT
- You can log into the Site using sign-in services such as Facebook Connect or another Open ID provider. These services will authenticate your identity and provide you the option to share certain Personal Information with us, such as your name and email address, to pre-populate our sign-up form.
8. SOCIAL MEDIA WIDGETS
9. UPDATING INFORMATION
Upon request, we will provide you with information about whether we hold any of your personal information. You may review, correct, update, change, or delete your Personal Information on your ReputationDefender account profile at any time. Simply log into your ReputationDefender account, go to your User Profile, review your Personal Information and, if you wish, edit it with the options provided. If you are unable to edit your Personal Information by logging into your account, please contact us for assistance. Customer Service is available to assist with this between 6:00 a.m. and 6:00 p.m. Pacific Time, or you may email email@example.com. If you wish your personal information to be deleted from our database, you may email your request to firstname.lastname@example.org. The process of removing information may take up to 30 days.
10. PERSONAL INFORMATION OF THIRD PARTIES THAT WE RECEIVE FROM OUR CUSTOMERS AND CLIENTS
The implementation of our Services may involve our receipt of information from our customers, such as information about their own customers or persons with whom they have a business or other relationship. When we use or disclose this information, we do so on behalf of our customers; if you are a customer, our use of this information is governed by the agreement(s) we have in place with you.
11. INFORMATION SECURITY
The security of your personal information is important to us. In turn, where applicable, we use security protocols and practices designed to safeguard the information we collect, including what is collected on this Site. However, no internet website, application, or security protocols can guarantee 100 percent protection. Therefore, if you provide information to us, you do so at your own risk.
12. COOKIES AND TRACKING TECHNOLOGIES
- As is true of most websites, we gather certain information automatically. This information may include Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, date/time stamp, and/or clickstream data to analyze trends in the aggregate and/or administer the site.
- We use both session cookies and persistent cookies. We use session cookies to make it easier for you to navigate the Site and to track whether or not you are logged into the Site. A session cookie expires when you close your browser. A persistent cookie remains on your hard drive for an extended period of time. You can remove persistent cookies by following directions provided in your Internet browser’s “help” file. Click here for more information on how to remove persistent cookies.
- We set a persistent cookie to store how you came to the Site and which packages and discounts we are able to offer you upon your registration. Persistent cookies also enable us to track and target the interests of our users to enhance their experience on the Site.
- You may adjust your browser settings to refuse or to remove or clear cookies by following the directions provided in your browser settings. If you reject cookies, you will still be able to view the Site, but your ability to use some areas of the Site will be limited. You will be unable to log into the Site if you reject cookies.
- In some of our products and services we may use analytics tools provided by third-parties (such as Google Analytics) to identify potential security and performance issues, understand how you use our products so we can improve the product functionality as well as your user experience, and to evaluate and improve our campaigns and communications with you. Specific analytics tools may vary depending on the operating system of the device.
- We employ, and our third-party advertising partners employ, a software technology called clear gifs (a.k.a. “Web Beacons” or “Tracking Pixels”), that helps us better manage content on the Site by informing us which content is effective. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to learn about the interactions of our users with the Site and our outbound emails. In contrast to cookies, which are stored on a user’s computer hard drive, clear gifs are embedded invisibly on Web pages and are about the size of the period at the end of this sentence. We tie the information gathered by clear gifs to our customers’ Personal Information. We use clear gifs in our HTML-based emails to let us know which emails recipients have opened. This allows us to gauge the effectiveness of certain communications and the effectiveness of our marketing campaigns.
- We may sometimes work with third-party platforms to deliver or retarget ads to you; for instance, when you have visited our Site and we would like to re-connect to show you additional content about our services. This type of advertising is called “interest based” or “personalized” advertising. If you would like to opt out of receiving such advertising, you may visit the opt out web pages operated by the following industry organizations: the DAA – here, or the NAI – here.
13. CALIFORNIA CONSUMER PRIVACY ACT RIGHTS (For California Residents)
If you are a California resident, you have certain rights to request that we disclose what Personal Information we collect from you, to delete that information, and to opt-out of the sale of your Personal Information, subject to certain restrictions. You also have the right to designate an agent to exercise these rights on your behalf. This section describes how to exercise those rights and our process for handling those requests. (To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.)
a. Right to request access to your personal information
California residents have the right to request that we disclose what categories of your Personal Information that we collect, use, or sell. You may also request the specific pieces of Personal Information that we have collected from you. However, we may withhold some Personal Information where the risk to you or our business is too great to disclose the information. Sometimes, we act only as a “service provider” to our clients (for instance, if they provide information to us for analytics, processing, or other data management services), in which case any consumer requests for opt out, deletion, or access to data must be made through that client. Therefore, we will forward any such requests to the named client, as feasible.
b. Right to request deletion of your personal information
You may also request that we delete any Personal Information that we have collected from you, such as if you have been a customer of ours. (Note that this is different from your right to “opt out” of us selling your Personal Information, which is described below; also note that we do not generally collect Personal Information directly from consumers.) However, we may retain Personal Information for certain important purposes, such as (a) to protect our business, systems, and users from fraudulent activity; (b) to address technical issues that impair existing functionality (such as de-bugging purposes); (c) as necessary for us, or others, to exercise their free speech or other rights; (d) to comply with law enforcement requests pursuant to lawful process; (e) for scientific or historical research; (f) for our own internal purposes reasonably related to your relationship with us; or (h) to comply with legal obligations. Additionally, we need certain types of Personal Information so that we can provide our Services to you. If you ask us to delete it, you may no longer be able to access or use our Services.
c. How to exercise your access, opt out, and (if applicable) deletion rights
For security purposes (and as required under California law), we may need verify your identity—in part by requesting certain information from you—when you request to exercise your California privacy rights of “access” or “deletion.” For instance, if you request categories or specific pieces of Personal Information that we have received about you, you may need to confirm your possession of an identifier (such as an email address) or to provide a piece of identification that confirms you are the person you claim to be.
d. Right to nondiscrimination
We will not deny, charge different prices for, or provide a different level of quality of goods or services if you choose to exercise these rights.
e. Authorized agents
You may also designate an agent to make requests to exercise your rights under CCPA as described above. We will take steps both to verify your identity to verify that your agent has been authorized to make a request on your behalf through providing us with a signed written authorization or a copy of a legally sufficient power of attorney. We likewise may require that you verify your own identity, depending on the type of request you make.
14. LINKED SITES
15. CHOICE AND OPT OUT
- As also described above, we provide you the opportunity to “opt out” of having your Personal Information used for certain purposes when we ask for this information. For example, if you purchase a product/service but do not wish to receive any additional marketing material from us, you can indicate your preference in the Site’s account area.
- If you no longer wish to receive our newsletter and promotional communications, you may opt out of receiving them by following the instructions included in each newsletter or communication or by emailing us at email@example.com. We also offer an opportunity to opt out of certain communications on the Site via our user account area.
16. CHANGES TO PRIVACY STATEMENT
- You are also responsible for regularly reviewing the Privacy Statement and related documents. We reserve the right to modify this Privacy Statement at any time.