We may also supplement this Policy with other privacy notices in the Seguru Services. This Policy applies only to information collected by us through the Seguru Services and does not apply to services that link to other privacy policies, including any third-party websites or services you connect to from our Seguru Services, such as social-networking platforms or connected third-party applications. Seguru is not responsible for the privacy practices or content of such third parties. We encourage you to read the privacy statements of those third parties.
We collect and process personal information about you with your consent and/or as necessary to provide the products you use, operate our business, meet our contractual and legal obligations, protect the security of our systems and our customers, or fulfill other legitimate interests.
Personal Data Collected
As used in this Policy, “Personal Data” means information relating to you as an identified or identifiable individual. You provide Personal Data directly into the Seguru Services. For example, as part of activating an account with Seguru, we collect your email address. If you create the account using one of the available social networking or third-party platform connection options (a “social sign-in” like Google, or Facebook), we will collect your associated email address and related profile information from the social sign-in provider. You may also provide us with additional email addresses to ensure that you retain access to your account even if you no longer have access to your primary email address.
If you wish to receive alerts via text messages, you must provide your mobile phone number.
Third-Party Social Sign-Ins
You can sign in to our Seguru Services using third-party social sign-ins (e.g., Google, or Facebook). These social sign-in providers will share certain Personal Data with us as described in their sign-in notices or in their privacy policies, which might include information such as your name, profile picture, age range, gender, and other public information. We encourage you to review prior to signing in through the applicable service.
Cookies, Analytics, and Tracking
When you use the Seguru Services through the Site, some information such as Internet protocol (IP) address, device or browser information, logs, or clickstream information is automatically collected about your usage and activity to address technical support issues and understand how you use the Site. Seguru may use certain tracking technologies such as cookies, web beacons, or third-party analytics tools to obtain such information. You may find out more about the various tracking tools used on the Site and the choices you have by following the Cookie Preferences link on the Site footer. Our App utilizes tracking technologies from third-party service providers we have engaged to provide services on our behalf. In some cases, these are analytics providers that provide services such as application analytics and crash reporting. In other cases, these are advertising or campaign measurement providers. These providers may also automatically collect some of the information described above, including, for example, usage information, IP address, access times, browser type and language, device type, device identifiers, and Wi-Fi information. These providers may also automatically collect the above information about you through the App and on other sites and services, including personally identifiable information about your online activities over time and across different websites, devices, online services, and applications when you use our App. Some third parties help us and others associate your activities across the browsers and devices you use, or that your household uses, for retargeting, cross-device advertising, analytics, and measurement purposes. The third-party analytics and advertising providers we use include: Google Analytics, and CrashlyticsApsalar. Some third-party providers allow you choices about their collection or use of your information. Some of these providers may also be members of the Network Advertising Initiative (NAI) or Digital Advertising Alliance (DAA), which each provide a simple way to opt out of ad targeting from participating companies.
If you would like us to invite another individual to join the Seguru Services, you may provide us their email address so that we may send them an invitation on your behalf to visit the Seguru Services. When using the App, the App may also access your device contacts if you enable those permissions.
Certain features of the Seguru Services may collect approximate geolocation data, including through IP address, and other location-based technologies. Additional information about these features is provided below, along with the settings screens for the features in the App.
How Personal Data Is Used
Seguru will use Personal Data as described in this Policy and as disclosed to you in the Seguru Services, which include for the following purposes:
- Creating and maintaining your mobile security account and otherwise providing, operating, hosting, maintaining, connecting, and improving the Seguru Services.
- Responding to your comments and questions and providing customer service.
- Updating you on new features and functionality of the Seguru Services, as well as other news and information about products and services offered by Seguru, other affiliated companies, and our selected partners.
- Providing you information via email or another form of electronic notification related to your use, requests, and purchases, such as transaction confirmations, invoices, technical notices, and other notices about security, privacy, and administrative issues relating to your use of the Seguru Services.
- Personalizing your Seguru Services experience, content, marketing, and recommendations, including to target content and services to more closely match your interests or location.
- Creating anonymized data sets from Personal Data to improve our and our affiliates’ products and services.
- Enforcing our terms and conditions or protecting our business, partners, or users.
- Protecting against, investigating, and deterring fraudulent, unauthorized, infringing, or illegal activity.
Choices You Have Regarding Personal Data
Profile and Transaction Information
Through the settings pages within the App, you can update profile information associated with your account at any time, such as contact information, privacy and sharing settings, and alerts and connected applications. Our Site may offer publicly accessible blogs or community forums. You should be aware that any information you choose to share in these areas may be read, collected, and used by others.
If you otherwise wish to ask for access, correction, or deletion of any of your information held by us, or a change in the way we use your information, please contact us at: email@example.com. We reserve the right to charge you a fee, as permitted by applicable law, and may decline requests that are unreasonable, prohibited by law, or are not required to be honored by applicable law.
The Seguru Services provide features that require you’re an approximate location via the IP address on your mobile device through the App. Features such as Find Nearest Secure Server only detect your approximate location when searching for a server to connect to and do not continuously collect your approximate location.
Connections with Other Services
Other third-party services you have chosen to connect with the Seguru Services may be enabled or disabled through selections in the Site or the App. You usually can also enable or disable connections through the third-party services themselves. Certain third-party services we may feature through our Seguru Services give you social-media options to interact with buttons or widgets that let you “like” information or post information about your activities publicly from the Seguru Services to third-party sites and platforms or privately within your network. By connecting your Seguru Services account with third-party services, you enable third-party services to access the times that the App logs you in or out. Their use of this information is governed by their user terms with you and their privacy policies.
Email and Marketing Choices
You can manage your email preferences through the selections within the Site or the App by updating your email subscription settings. You can also unsubscribe from promotional emails by: (1) following the unsubscribe instructions in our emails; or (2) emailing us at firstname.lastname@example.org. You may update your email preferences from time to time. Please note that even if you unsubscribe from promotional email messages, we may still need to contact you with important transactional information related to your account and your use of the Service. For example, even if you have unsubscribed from our email messages, we will still send you emails relating to security, billing, or account services such as password reset.
Push and Text Message Alerts
You may manage the push message alerts regarding security alerts and other alert information specific to your account sent by the Seguru Services to your mobile device through the settings page in the Site or within the App. Similarly, you may manage text message alerts through the settings page within the App, and you may always opt out of text message alerts by replying STOP to any text message sent by Seguru.
Cookies, Analytics, and Tracking
You also have choices regarding some of the technologies used to track your use of the Seguru Services. You may find out more about the various tracking tools used on the Site and the choices you have by following the Cookie Preferences link in the footer of the Site. Note that the settings are limited to the particular browser installed on a particular device. So if you use Seguru Services with different browsers or different devices, including a mobile device, you may have to disable the tracking cookies in the browsers of all relevant devices. It may not always be possible to disable cookies in the App, and disabling cookies on the Site will not disable tracking technologies on the App. We may not recognize or respond to every type of “do not track” signal or other mechanisms that provide consumers the ability to exercise choice regarding the collection of Personal Data about an individual consumer’s online activities over time and across third-party websites or online services, but we give you certain choices about how we collect Personal Data as described in this Policy. For more information on how we collect Personal Data for these purposes, see the “Cookies, Analytics and Tracking” section above.
How Seguru Shares Personal Data
The Seguru Services may share your Personal Data as described in this Policy and as follows:
- With your consent.
- With third parties to the extent that you have enabled a connection between your Seguru Services account and a third-party service.
- With other Seguru users or the public through your public profile in accordance with your privacy settings.
- When we believe it is appropriate to investigate, prevent, or take action regarding illegal or suspected illegal activities; to protect and defend the rights, property, or safety of Seguru, our users, or others; and in connection with the enforcement of our terms and contracts.
- In connection with a corporate transaction, such as a divestiture, merger, acquisition, consolidation, or asset sale, or in the unlikely event of bankruptcy. We may assign or transfer your information as part of the transaction.
- With third-party vendors, consultants, and other service providers that are working on our behalf and need access to your information to provide specific services to us as part of the Seguru Services, such as hosting, email messaging, or SMS providers.
- In an aggregated form that does not directly identify you.
- As required by law and when we believe that disclosure is necessary to protect our rights and/or comply with a judicial proceeding, court order, or legal process served to us.
Rights for Certain Users
Seguru adheres to applicable data protection laws in the European Economic Area (EEA), which, if applicable to you, include the following rights:
- Where processing of Personal Data is based on your consent, you have a right to withdraw consent at any time for future processing.
- You have a right to request access to, rectification, or erasure of your Personal Data, or to transfer or receive a copy of your Personal Data in a usable format.
- You have a right to object to the processing of your Personal Data under certain circumstances.
- You have a right to lodge a complaint with an applicable data protection authority.
Seguru OÜ is the controller of your Personal Data for the Seguru Services, and Seguru OÜ located at Suur-Karja 13-41, 10130 Tallinn Estonia, is our data protection representative for the EEA and Switzerland, which you may contact at email@example.com. The data protection officer for Seguru OÜ is Sean Arries (firstname.lastname@example.org).
If applicable under French law, you can also send us specific instructions regarding the use of your personal information after your death by contacting us at email@example.com.
The services hereunder are not intended for use by the citizens of the Russian Federation who reside in Russia. If you are a Russian citizen residing in Russia, you are hereby notified that any Personal Data that you input into the services will be solely at your own risk and responsibility. You explicitly agree that we may accumulate your Personal Data and will process this data in the United States and in other countries, and that you will not hold Seguru accountable for any potential nonobservance of the Russian Federation legislation.
Security and Retention of Personal Data
We maintain data handling and storage practices and procedures that are designed to promote the integrity and confidentiality of the personally identifiable information. No method of transmission over the Internet or method of electronic storage is completely secure, however. Therefore, while we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.
We retain your Personal Data for as long as necessary to provide the Seguru Services and for other essential purposes such as complying with our legal obligations, resolving disputes, and enforcing our agreements. Because these needs can vary for different data types in the context of different services, actual retention periods can vary significantly. The criteria used to determine retention include (1) the length of time Personal Data is needed to provide the applicable services (such as maintaining and improving the performance of the Seguru Services, enabling system security measures, and maintaining appropriate business and financial records); (2) if users have provided, created, or maintained Personal Data with the expectation that we will retain it until they affirmatively remove it (in which case we may maintain the data until actively deleted by the user); (3) whether the Personal Data is of a sensitive type (a shortened retention time may be appropriate); and (4) whether we are subject to a legal, contractual, or similar obligation to retain the data (such as mandatory data retention laws in the applicable jurisdiction, government orders to preserve data, or data that must be retained for the purposes of litigation).
Updates and Questions
We may update this Policy from time to time without notice to you other than posting the revised policy on the Seguru Services or by providing such notice about or obtaining consent to changes as may be required by applicable law. If we change our Policy, we will post those changes to this Policy and change the effective date above. We encourage you to periodically review this page for the latest information on our privacy practices.
If you have any questions about this Policy, or to file any complaint regarding this policy, please contact us at the following address:
10140 Tallinn Estonia
Seguru will investigate and attempt to resolve complaints and disputes regarding the collection, use, and disclosure of personal information by referencing the privacy principles stated in this Policy. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please the Estonian Data Protection Inspectorate (http://www.aki.ee/en) (free of charge).