BullGuard Privacy Policy

About this policy

This policy describes how we will use your personal data when you use our website at www.bullguard.com (the “site”) or use or buy our products and services.

We have provided this policy to ensure that you understand what personal data we may collect and hold about you, what we may use it for and how we keep it safe. You have legal rights to access the personal data that we hold about you and to control how we use it which are also explained.

You can read and print this whole policy or click on the links below to see specific information about:
  Who we are and how you can contact us

We are BullGuard Limited, a company registered in England and Wales under registration number 04392368. Our registered office address is at 9 Devonshire Square, London, EC2M 4YF.

You can contact us:
  • in writing at BullGuard Limited, Data Team, 9 Devonshire Square, London, EC2M 4YF
  • by emailing to data@bullguard.com

Personal data we collect about you

We may collect:
  • Personal data you provide to us. You may give us information about yourself by filling in forms on the site or by corresponding with us by phone, e-mail, chat or otherwise. This includes information you provide when you register and use a BullGuard account, purchase and manage products, use the help centre or technical support centre, participate in forums or other social media functions on the site and if you report a problem with the site or a product. The information you provide may include your name, address, e-mail address, phone number and financial and credit card information.

  • Personal data we collect when you use our site and products. We may collect:
     
    • technical information, including the Internet protocol (IP) address used to connect your computer or mobile device to the Internet, your login information, browser type and version, devices used or which connect to your network from time to time, time zone setting, browser plug-in types and versions, operating system and platform;
    • information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from the site (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page;
    • electronic “pings” emitted by your mobile device each time it lands on a different page during the mobile security and antivirus product download and installation process.

  • Personal data we receive from other sources. We work closely with third parties (including, for example, business partners and sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them.

The information that we collect about you as described above falls into two broad categories: Personally Identifiable Information (“PII”) which is information that can be used to identify you as an individual and Non-Personally Identifiable Information (“NPII”) which is information that cannot be used to identify you as an individual. In general, information listed under the headings “Personal data you provide to us” and “Personal data we receive from other sources” will be PII whilst “Personal data we collect when you use our site and products” will be NPII. Where “Personal data we collect when you use our site and products” contains any PII we will anonymise the information for statistical and analytics purposes. With the exception of your IP address, which we will link to your BullGuard account for the purpose of identifying your geographic location, we never correlate NPII with PII that we hold.

What we use your personal data for

We use your personal data in the following ways:
 
  • PII (remember – this is the “personal data you provide to us” and the “personal data we receive from other sources”)

    We will use this information:
     
    • to provide you with the information, products and services that you request;
    • to provide you with marketing information in accordance with your marketing preferences (see “How we use your personal data for marketing”);
    • to provide you with reminders and renewal notifications relating to the BullGuard products and services that you use;
    • to notify you about changes to our products or to our services or terms;
    • to ensure that content from the site is presented in the most effective manner for you and for your device;
    • to allow you to participate in interactive features of our service, when you choose to do so;
    • to manage and administer our business;
    • to review and improve our products and services.

  • NPII (remember – this is “personal data we collect when you use our site and products”)

    We will use this information:
     
    • test, develop and improve our products;
    • to produce analytical, statistical and tracking data;
    • to understand how the site is accessed and used;
    • to administer the site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
    • to improve the site to ensure that content is presented in the most effective manner for users;
    • as part of our efforts to keep the site safe and secure;
    • to measure or understand the effectiveness of advertising served to users of the site and to target relevant advertising to users by demographic;
    • In the case of electronic “pings” collected during downloading of mobile products, to capture statistical information about the total number of devices landing on each page and the device types and languages used and to identify general user trends which can help us to ensure that the download and installation process for our mobile products is as efficient as possible and to quickly identify the existence of any technical fault preventing users from downloading and/or installing mobile products.


When we need your consent to use your personal data

Whilst we always want you to be aware of how we are using your personal data, this does not necessarily mean that we are required to ask for your consent before we can use it. In the day to day running of our business we may use your personal data without asking for your consent because:
 
  • we are entering into and carrying out our obligations under a contract with you;
  • we need to use your personal data for our own legitimate purposes (such as the administration and management of our business and the improvement of our services) and our doing so will not interfere with your privacy rights.

We ask for consent only for marketing purposes. Please refer to the section on “How we use your personal data for marketing” to read about marketing consents.

Personal data you are legally obliged to provide

You are not under a legal obligation to provide us with any of your personal data but please note that if you elect not to provide us with your personal data we may be unable to provide our products or services to you.

Your rights to know what personal data we hold and to control how we use it

You have a legal right to know what personal data we hold about you - this is called the right of subject access. You can exercise this right by sending us a written request at any time. Please mark your letter “Subject Access Request” and send it to us by post or email using the details in the “Who we are and how you can contact us” section.

You also have rights to:
 
  • prevent your personal data being used for marketing purposes (see “How we use your personal data for marketing” for further details);
  • have inaccurate personal data corrected, blocked or erased;
  • object to decisions being made about you by automated means or to your personal data being used for profiling purposes (see “Automated decision making and profiling” ;
  • object to our using your personal data in ways that are likely to cause you damage or distress;
  • restrict our use of your personal data;
  • require that we delete your personal data;
  • require that we provide you, or anyone that you nominate, with a copy of any personal data you have given us in a structured electronic form such as a CSV file.

You can find full details of your personal data rights and the circumstances in which you are able to exercise them on the Information Commissioner’s Office website at www.ico.org.uk.

You may also find it useful to refer to the section on “Accessing and managing your data and preferences through your BullGuard account”.

Automated decision making and profiling

We do not make use of automated decision making or profiling.

You are entitled to ask that we do not make automated decisions about you or use your personal data for profiling purposes. Please refer to the section on “Your rights to know what personal data we hold and to control how we use it” .

When we will share your personal data with others

We may share your personal information with any other companies that are part of the BullGuard group.

We may also share your information with selected third parties outside of the BullGuard group including with:
 
  • any business partners, suppliers and sub-contractors we work with to provide you with the products and services you have requested from us;
  • advertisers and advertising networks that require the data to select and serve relevant adverts to you and others;
  • analytics and search engine providers that assist us in the improvement and optimisation of the site;
  • credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you.

We may also share your personal data with third parties on a one-off basis, for example if:
 
  • we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
  • If BullGuard Limited or substantially all of its assets are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets;
  • if we are under a duty to disclose or share your personal data in order to comply with any legal obligation or in order to enforce or apply our terms and conditions and other agreements entered into with you or to protect the rights, property, or safety of BullGuard Limited and its staff, our customers or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

When we share your information with a third party it will be for a specific purpose which has been expressly agreed between us and the third party. We do not permit third parties to use your information for any purpose other than the purpose specifically agreed between us and them.

How we keep your personal data safe

We take every care to ensure that your personal data is kept secure. The security measures we take include:
 
  • only storing your personal data on our secure servers;
  • using specialist third party payment providers to process payments made through our site (read more in the section on “Making payments through our site”;
  • ensuring that our staff receive regular data security awareness training;
  • keeping paper records to a minimum and ensuring that those we do have are stored in our locked offices;
  • maintaining up to date firewalls and anti-virus software to minimise the risk of unauthorised access to our systems;

Please remember that you are responsible for keeping your passwords secure. If we have given you (or you have chosen) a password which enables you to access certain parts of our website (or log in to your BullGuard account), you are responsible for keeping this password confidential. Please do not to share your passwords with anyone.

Unfortunately, sending information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of personal data sent to our website; you send us personal data at your own risk. Once we have received your personal data, we will use strict procedures and security features (some of which are described above) to try to prevent unauthorised access.

Making payments through our site

All our payments are made through payment processors over a secure connection. Only the payment processors store your full payment card number or account information. During the order process you will be directed on to pages hosted by our payment processor. Such pages will maintain the look and feel of the site, but will have trademark of the payment processor displayed. They will also offer you automatic renewal of subscriptions and provide you with reminder notifications if your card has expired.

How we use your personal data for marketing

We will add your details to our marketing database if:
 
  • you buy our products or use them during a free trial;
  • you have told a third party that you would like them to pass us your contact details so that we can send you updates about our products;
  • you have registered for a BullGuard account and have indicated during the sign up process that you are happy to receive marketing communications;

If your details are included on our marketing database we will send you marketing communications by email or SMS.

If you wish to change your marketing preferences at any time you can do so by:
 
  • clicking on the unsubscribe or opt out link that appears in each of our marketing emails;
  • updating your preference settings via your BullGuard account;
  • contacting us using the detail set out in the “Who we are and how you can contact us” section of this policy.

We never share your contact details with third parties for marketing purposes but we do partner with a third party advertising network to display advertising on the site and to manage our advertising on other websites. Our advertising network partner uses cookies and web beacons to collect information about your activities on the site and on other websites and uses this to provide you with targeted advertising based on your interests. Please note that opting out of receiving targeted advertising will not prevent you from receiving generic advertising.

Accessing and managing your data and preferences through your BullGuard account

You can view and update some of your personal data and preference settings through your BullGuard account and we encourage you to take the time to log in to your account periodically for this purpose. If you have any questions about how to manage your data and settings through your account please contact using the details set out in the “who we are and how to contact us” section of this policy.

Creating a BullGuard profile and using our forums

When you create a profile on a BullGuard forum your username will be displayed on the site. You will be given the option of either displaying or hiding your email address and allowing other forum users to contact you via email. When using the BullGuard forums, please be aware that any personal information you submit there can be read, collected and used by other forum users and could be used to send you unsolicited messages. You are responsible for the information that you choose to submit on the BullGuard forums.

If you would like to request the removal of your personal information from the BullGuard forums please contact us using the details in the “Who we are and how to contact us” section of this policy. Please note that we are not always able to remove all information; if this is the case you will be informed of what information cannot be removed and why.

When we will send your personal data to other countries

Your personal data may be transferred to, and stored at, a destination outside the European Economic Area ("EEA") by us or by our sub-contractors. Where we, or our sub-contractors, use IT systems or software that is provided by non-UK companies, your personal data may be stored on the servers of these non-UK companies outside the EEA. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

How long we keep your personal data

We only keep your personal data for as long as we actually need it. In practice this means that we will keep your personal data for as long as your BullGuard account is active or for so long as we need to retain your personal data so that we continue to provide you with services you have requested from us, comply with our legal obligations, resolve disputes or enforce agreements.

We will keep your data for up to 5 years from the closing of your account or the expiry of your product license or conclusion of any dispute proceedings (whichever is the last to occur).

If you close your BullGuard account or if it expires BullGuard will retain any data that you backed up to BullGuard's servers for at least 30 days from closure or expiry of your account.

Please note that we may anonymise your personal data or use it for statistical purposes. We keep anonymised and statistical data indefinitely but we take care to ensure that such data can no longer identify or be connected to any individual.

What about … cookies & web beacons

The site uses cookies to distinguish you from other users of the site and web beacons to assess which pages you access when browsing the site. This helps us to provide you with a good experience when you browse the site and also allows us to improve the site. We also allow selected third parties to use cookies and web beacons on the site. For more detailed information on the use of cookies and web beacons on the site including information about the purposes for which we and third parties use them see our Cookies policy.

What about … social media

The site contains social media features such as the Facebook Like button and Share options. These features may collect your IP address and details of which page you are visiting and may set a cookie to enable the feature to work properly. Social media features are either hosted by a third party or hosted directly on our sites. Your interactions with the features are governed by the privacy policy of the company providing them.

What about … links to third party sites

Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

How you can make a complaint

If you are unhappy with the way we have used your personal data please contact us to discuss this using the contact details set out in the “Who we are and how to contact us” section of this policy.

You are also entitled to make a complaint to the Information Commissioner’s Office which you can do by visiting www.ico.org.uk. Whilst you are not required to do so, we encourage you to contact us directly to discuss any concerns that you may have and to allow us an opportunity to address these before you contact the Information Commissioner’s Office.

How we keep this policy up to date

We will review and update this policy from time to time. This may be to reflect a change in the products or services we offer or to our internal procedures or it may be to reflect a change in the law.

The easiest way to check for updates is by looking for the latest version of this policy on the site.

Each time we update our policy we will update the policy version number shown at the end of the policy and the date on which that version of the policy came into force.

This is policy version 2018-A, which came into effect on 17.05.2018.
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