Contents

  1. Introduction
  2. Definitions
  3. Your Consent
  4. Customer Data
  5. Disclosure of Customer Data To Third Parties
  6. Data Integrity and Security
  7. Data Access and Corrections
  8. Other Websites
  9. Changes to this Privacy Policy
  10. Questions About Our Privacy Policy

PRIVACY POLICY

1st March 2010 Edition

  1. Introduction

    2. 1.1 Prevx Limited, a company registered in England and Wales with company number 04181251 and address at 3 New Park Place, Pride Park, Derby, Derbyshire, DE24 8DZ, United Kingdom. PREVX's Data Protection Registration number is Z718134X.

    1.2 This Privacy Policy describes the Prevx current policies and practices with regard to data concerning Prevx's Customers collected by Prevx, including persons who use the Website and who download, purchase and use Prevx's Products.

    1.3 Prevx is committed to respecting the legal requirements that exist in the European Union regarding data privacy, including the United Kingdom Data Protection Act 1998 and Privacy and Electronic Communications (EC Directive) Regulations 2003.

  2. Definitions

    3. 2.1 In this Privacy Policy, the following words shall have the corresponding meanings:-

    1. "Customer" means any person (including individuals, firms and companies and other organisations) who is a customer of Prevx, including persons who browse, register on or otherwise use our Website, or who downloads, purchases, licenses, and/or uses our Products;
    2. "Customer Data" means all data and information we collect, hold and/or process concerning our Customers and individuals who are their contacts or representatives;
    3. "Personal Data" means Customer Data that falls within the meaning of personal data under the Data Protection Act 1998, being data which relates to a living individual, who can either be identified from that data alone, or from that data in combination with any other information in our possession (for example, the name, age, e-mail address or mailing address of an individual);
    4. "Prevx", "we", "us", and "our" means Prevx Limited;
    5. "Products" means the Prevx anti-malware product, the Prevx SafeOnline product, and all other software, services, and other products we offer for supply, download and/or license from time to time
    6. "you" or "your" means the Customer in respect of whom we collect, hold or process any data from time to time;
    7. "Website" means all and any website(s) operated by Prevx from time to time, including our website http://www.prevx.com, our purchasing web pages and our support forums, and to all information and services obtainable through our website(s), as the same change from time to time.
  3. Your Consent

    4. This Privacy Policy is included in and is part of our Website and Supply Terms. By agreeing to those terms and/or using our Website, or downloading, purchasing and using our Products, you are consenting to the collection, use and disclosure of Customer Data relating to you as set forth in this Privacy Policy.

  4. Customer Data

    5. We describe in detail below each type of Customer Data we collect, how we collect it, and what we do with it.

    4.1 Customer Transaction Data

    1. What it comprises

      2. This Customer Data comprises all data you provide or we otherwise collect or generate when you register with our Website, or purchase any Products from us, or when we or you communicate with the other in any way (such as support requests), including individual or corporate names, addresses, e-mail addresses, card or other payment details, passwords and usernames, purchase and payment history and transaction records, contact details for any individuals who are the representatives for any Customer who is a business or other organisation, support and help and other messages and communications exchanged, telephone call recordings, and forum posts.

    2. How we collect it

      3. Prevx collects, generates, processes such Customer Data when you register with or use our Website or purchase any Products from us or communicate with us, including where you complete any registration or purchase forms, submit any forum posts, or submit any order or message to us.

    3. What we use it for

      4. Prevx uses such Customer Data for the following purposes:-

      1. Administration and Performance

        2. To manage and administer our relationship with you, including your registrations with us, transactions with us, and communications with us, to perform all orders and contracts with you, to provide the Products, information and services you request, and to respond to your comments, questions and support requests, and to monitor compliance with and enforce the terms of our relationship and any contracts with you and our software licenses granted to you.

      2. News

        3. To send you news and status messages concerning Prevx and the status of its Website, Products and services.

      3. Events

        4. To send you details of promotional events where you have specifically registered for the same.

      4. Marketing

        5. We may use your Customer Data, including your e-mail and postal address, to send you marketing messages concerning our Products. However, if that Customer Data is Personal Data, we will not do so unless you have consented to the same, or not opted-out of this, and you may withdraw your consent to such use at any time using any e-mail address published on our Website or writing to us at Webmaster, Prevx Limited, 3 New Park Place, Pride Park, Derby, DE24 8DZ, UK.

      5. Web Forum

        6. Where you submit posts to any public website forum we operate then by doing so you agree that we may publish those posts.

      6. Analysis and Improvement

        7. We may also use such Customer Data to carry out analysis and research in relation to our overall business performance, and to facilitate reviews, developments and improvements to the content and functionality of our Website and the Products we offer, to better understand our customers and markets, to improve our products and services.

      7. Telephone Calls

        8. We may monitor and record telephone calls for the purpose of security and training.

    4.2 Product Collected Data

    1. What it comprises

      2. The Prevx Products, when running on your computer(s), collect information on an anonymous basis from your computers as part of the proper functioning of our Products ("Product Collected Data"), and send this information over the internet to servers and databases operated by Prevx (the Prevx Community Database) for use in connection with the anti-malware and other security features provided of our Products. This information includes information concerning the software running on and internet connectivity of the user's computer, such as data about programs scanned, website URLs checked, and threats and attempted intrusion events detected. This has been designed with data protection in mind, and so does not collect any personally identifying or transaction related information. If Prevx links any Product Collected Data to your personal name we will treat it as Personal Data. Please note, we don't upload any of your data files and software programs on your computer without your consent; our software creates a special cryptographically secure hash value from the file or program being inspected and compares this value with our online database to verify whether the program or file is a known good or bad program or file within our anti-malware database; but we may ask you to upload a suspicious file or program we have not identified before for analysis.

    2. How we collect it

      3. The Product Collected Data is collected automatically by the Prevx software, for instance when it runs a scan on your computer or you visit a web-page.

    3. What we use it for
      1. Provide Product

        2. We use such Product Collected Data to provide our Product to you. Our Product sends to our remote servers and databases (where it is retained) details of the files and software on your computer for purposes of checking whether that file or software is known or suspected malware against our database, and examining that software where it is suspected, and keeping a record of the status of your computer so as to identify any new previously unseen software that tries to run. Our Product also sends details of visited website URLs to our database to verify the legitimacy of the URLs.

      2. Improve our Database

        3. We also use the software, URL and threat information we obtain from your computer to improve the performance of our databases and systems, to provide additional statistical information which is used in the verification of software, files and websites. The Product Collected Data is aggregated into our community database and used to make determinations on good and bad programs.

      3. Statistics

        4. We use the Product Collected Data to produce general statistics on attacks, threats, their propagation and overall measures of the level of internet abuse and crime. These statistics may be used by us in our malware research, publicity, marketing and promotional materials. We use the Product Collected Data for analyzing and publishing overall threat activity on the internet, researching threats, compiling statistics and to further refine and improve the performance of the Prevx Products.

      4. Analysis

        5. We may also use the Product Collected Data to carry out analysis and research in relation to our overall Product performance and in relation malware and dangerous websites, and to facilitate reviews, developments and improvements of our Products.

    4.3 Click-Stream Data

    1. What it comprises

      2. This data comprises tracking of your use of our Website (including purchases you make and registrations), including for example which pages you view and which links you use. This information about your use of this Site is called "click-stream data." Click-stream data does not identify you personally. If Prevx links any click-stream data to your personal name we will treat it as Personal Data.

    2. How we collect it

      3. We use technology running on our Website server computers to monitor and capture click-stream data.

    3. What we use it for

      4. Click-stream data is used to analyse the performance of our Website, to improve our Website, to help us determine what is important to you, and what is not, to help us decide what content and features to add and what to discard, and to help us determine whether our Website is easy to use or whether we need to redesign certain pages and links.

    4.4 Cookies

    1. What they comprise

      2. We may finally obtain information about you by installing our own markers on your computer. These markers are commonly called "cookies", and are small pieces of information that are transferred from our website to and stored by your browser in a small text file on your computer. Their use is very common by many online services. They enable us to know you by a computer-generated, unique identifier, and are used to store and track information about Website usage and to remember you and your settings when you next visit.

    2. What we use them for

      3. We may use cookies in two ways:-

      1. per-session cookies are used while you are logged on to our Website to record temporary data relating to your visit to our Website, to manage the delivery of web pages to you and any registration and ordering processes, and to help us monitor traffic through the Website;
      2. logon and usage cookies store some data between visits to our Website in order to allow you to log on to your account more easily, and using them we are able to personalise your experience, and create a database of your previous choices and preferences, and in situations where those choices or preferences need to be collected again, they can be supplied by us automatically, saving you time and effort. For example, after you purchase a product once, if you need to purchase it again your previous selection of options will be retained and can be re-entered more quickly.
    3. De-activating Cookies

      4. If you do not want to use "cookies" most Internet browsers programs will permit you to turn them off. Should you do this, you will still be able to access most of our Website as normal, but some processes that depend on cookies may not work properly. Your computer may be specially configured to reject cookies: please refer to your browser for more information.

  5. Disclosure of Customer Data To Third Parties

    6. 5.1 Purposes of disclosure and recipients

    We do not share Customer Data with any third parties except as provided below or as required by law, and where we share Personal Data with third parties this will be in accordance with Clause 5.2 below:-

    1. Marketing Purposes

      2. We may share Customer Data with third parties for use by those third parties to market their products and services to you. However, if such Customer Data is Personal Data, we will not do so without consent of the individual to whom the Personal Data relates, and you may withdraw your consent to such use at any time using any e-mail address published on our Website or writing to us at Webmaster, Prevx Limited, 3 New Park Place, Pride Park, Derby, DE24 8DZ, UK.

    2. Payment Processing

      3. Your Customer Data may be processed by third parties who provide order processing services to us, and we may transfer Customer Data to third party payment processors in order to process payments for orders (such as credit and debit card processing companies). If we use a third party order processing service, they will collect and send your data to us securely, which will then be incorporated into our databases.

    3. Prevx Contractors

      4. We may have your Customer Data processed by third-parties throughout the world who act for or on behalf of Prevx; for example, we may use cloud computing or remote database hosting services which may be located anywhere in the world, and we may engage contractors anywhere in the world for the purposes of providing support or back-office services to us, including website hosting, order processing, order fulfilment, application and database hosting, data processing services, or that help us market our products and services. These companies will process and hold information about you in order to perform their functions. These companies are not authorized to use the information they process for us for any other purpose than those to which we have notified you under this Privacy Policy.

    4. Legal Requirements

      5. We may share or transfer your Customer Data to a government authority where required to comply with a legal requirement, for the administration of justice, or where reasonably required to protect your or your company's vital interests.

    5. Corporate Transfer

      6. We may transfer your Customer Data to any company that purchases or otherwise acquires our business in the event of a corporate sale, merger, reorganization, dissolution or similar event.

    6. Statistics

      7. We may use your Customer Data along with other data to provide statistics on an anonymous basis to our contractors, marketing partners (including banks and other institutions who may promote our products to their customers), and other companies and organisations we deal with, for a range of purposes, including assessing and reporting on the overall performance of our Product and Website, assessing and reporting on overall Product take-up and usage, assessing and reporting on malware and unsafe websites and associated threats and risks in general or for any group of customers.

    5.2 Data Protection Act Requirements

    Before disclosing any Personal Data to a third party, Prevx will contractually require the third party to take adequate precautions to protect that Personal Data against unauthorized use or disclosure and to process it only in accordance with our instructions or for the purposes for which it was disclosed. If we have any Personal Data processed outside the European Union, we will comply with the requirements of the Data Protection Act 1998 and all other applicable data protection laws within the European Union in connection with such processing.

  6. Data Integrity and Security

    7. Prevx will take commercially reasonable measures to maintain the integrity and security of Customer Data. We keep Customer Data only for as long as reasonably necessary for the purposes for which it was collected or to comply with any applicable legal reporting or document retention requirements. Our servers and our databases are protected by industry standard security technology, such as industry standard firewalls and password protection. Although we cannot guarantee against any loss, misuse, unauthorized disclosure, alteration or destruction of data, we try to prevent such unfortunate occurrences.

  7. Data Access and Corrections

    8. 7.1 If you register for the MyPrevx console on our Website, this will give you options to update certain elements of the Customer Data we hold about you.

    7.2 In relation to Personal Data, individuals to whom such Personal Data relates have the following legal rights under the Data Protection Act 1998: a right (subject to exceptions in the Act) to be told what Personal Data relating to them is held by us (we may charge a fee of £10 to cover our costs in dealing with this); a right to stop marketing messages; a right to stop usage which is causing substantial distress; and a right to ask for the rectification, erasure or blocking of any Personal Data which is inaccurate or not up to date. If you wish to exercise any of these legal rights, please write to us at Webmaster, Prevx Limited, New Park Place, Pride Park, Derby, DE24 8DZ, UK. We reserve the right to ask any person that sends us a request in relation to these legal rights for proof of identity and (where relevant) proof of authority to act if the person making the request is not the individual to whom the data relates. We will respond to requests in a prompt and proper manner. Requests to correct or delete Personal Data are subject to any applicable legal reporting or document retention obligations imposed on Prevx Limited.

  8. Other Websites

    9. Prevx and its Affiliates operate many different types of Websites for different purposes and in different countries where different laws may apply. If you visit any Website operated or used by Prevx, please take a moment to review the Privacy Policy posted on that site to learn what personal information may be collected through that site and how it is processed. Our Website may contain hyperlinks to websites that are not operated by Prevx or one of its Affiliates. These hyperlinks are provided for your reference and convenience only and do not imply any endorsement of the activities of these third-party websites or any association with their operators. Prevx does not control these websites and is not responsible for their data practices. We urge you to review the privacy policy posted on any website you visit before using the website or providing any personal information about yourself.

  9. Changes to this Privacy Policy

    10. Prevx is continually improving and adding new functionality and features to its Website and Products. These ongoing improvements, as well as changes in the law or changes in technology, may require changes to this Privacy Policy. Prevx reserves the right to update or modify this Privacy Policy at any time without prior notice. We will notify changes to this Privacy Policy by posting an updated or modified version of this Privacy Policy on our Website. Your continued use of our Website or Products following any such change constitutes your agreement that Customer Data collected from or about you after the revised Privacy Policy is posted will be subject to the terms of the revised Privacy Policy. Prevx will not apply changes to this Privacy Policy to any Customer Data collected before the revised Privacy Policy was posted on the Website.

  10. Questions About Our Privacy Policy

    11. If you have any questions about this Privacy Policy or concerns about the way we process Customer Data, please notify us using any e-mail address published on our Website or write to us at Prevx Limited, 3 New Park Place, Pride Park, Derby, DE24 8DZ, UK.