PRIVACY POLICY - Website / Shop / Account

We process different data when you visit our websites and create or use your account. This data may be directly or indirectly of a personal nature, i.e. it may involve other data sources.

We collect much of this data in a pseudonymized or anonymized form. Pseudonymized means that the personal data can no longer be attributed to a specific data subject without additional information. Anonymized means that the data subject can no longer be identified.

Visiting our websites

BullGuard offers a variety of product and user-optimized websites to provide you with a browsing experience tailored to your needs. We also use tools from various national and international providers. Some of the tools we use, how they work, and the type of data that are processed are explained below.

Basic processing when visiting our websites

By visiting our websites, whether by entering one of our URLs or clicking/tapping a link, you send personal data to us that our webservers process. To implement this service in a sensible manner, we use service providers on the basis of data processing agreements.

Purpose	· Provision of our internet presence · To generate revenue · Marketing and public relations · Customer engagement · Evaluations
Legal basis	· Provision of our websites: Art. 6(1)(f) GDPR — Our legitimate interest lies in the provision of our websites · Provision of promotional pages: Art. 6(1)(b) GDPR — Contract initiation and performance · Storage of metadata: Art. 6(1)(f) GDPR — Legitimate interest: IT security
Data categories	· Website visited · IP address · Request method · Requested URL · Response status · User agent (browser type and version, operating system information) · Processing time · Time to receive the response from the upstream server
Recipient (category)	· Group employees · IT service providers · SaaS vendors
Transfer to third countries	USA — Safeguard: EU Standard Contractual Clauses
Retention period	Usually 2 days

Cookies and additional tracking tools

In addition to the following tools, we also use cookies and tracking tools (hereinafter jointly referred to as "cookies") on our websites. We divide cookies into several categories. If we want to load more than "necessary" cookies, this is done on the basis of your consent. They are managed via our cookie tool.

This means that if no cookie tool with the option to set the use of cookies appears when you visit a website for the first time, we only use cookies on this website that are required to correctly display the website.

Please bear in mind that you may have already agreed to the use of cookies. If this is the case, no cookie tool will be displayed.

You will find all further information on this topic under Cookies.

Advertising partners

Please note that cookies can also be set by third parties or read by us. These are sometimes necessary for billing advertising partners, affiliate publishers, or for granting cashback and vouchers, for example. We process these cookies to fulfil our contractual obligations towards you or third parties as necessary.

In doing so, we act as an advertiser. We may process personal data to carry out an affiliate marketing campaign. This allows us to track which third-party website, app, or other technology provider referred potential customers to our websites and apps ("referrer"), and pay them a commission for these referrals.

In doing so, we are pursuing the legitimate interest of conducting an online advertising campaign that is remunerated according to performance.

We work together with various service providers within the framework of order processing and/or joint responsibility.

Criteo

Provider	Criteo SA, 32 Rue Blanche, 75009 Paris, France
Description	We use the Criteo network to enhance our marketing and advertising activities.
Purpose	· Marketing · Evaluations
Legal basis	Art. 6(1)(a) GDPR — Consent
Recipient (category)	· Group employees · SaaS vendors
Transfer to third countries	Possibly, based on Art. 44 et seq. GDPR
Retention period	Until such time as consent is withdrawn

Processor

The following list is not exhaustive:

Google Analytics

Tool	Google Analytics
Provider	Google Ireland Ltd., Google Building Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland
Description	Google Analytics is a key tool from Google for the analysis and optimization of website usage.
Purpose	· Operational process · Optimization of websites · To generate revenue · Evaluations
Recipient (category)	· Group employees · SaaS vendors
Transfer to third countries	USA — Safeguard: EU Standard Contractual Clauses
Retention period	In accordance with legal requirements

Google Tag Manager

Tool	Google Tag Manager
Provider	Google Ireland Ltd., Google Building Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland
Description	Google Tag Manager allows us to centrally manage the use of cookies and other tracking tools.
Purpose	· Operational process · Provision of websites and their functions · Evaluations
Recipient (category)	· Group employees · SaaS vendors
Transfer to third countries	USA — Safeguard: EU Standard Contractual Clauses
Retention period	None

Hotjar

Provider	Hotjar Ltd., Dragonara Business Centre 5th Floor, Dragonara Road, Paceville St Julian's STJ 3141, Malta
Description	Hotjar is an analysis tool that enables us to measure website use (such as by using heatmaps) and tailor our pages to your needs.
Purpose	· Marketing · Operational process · Evaluations
Recipient (category)	· Group employees · SaaS vendors · Ad networks
Transfer to third countries	USA — Safeguard: EU Standard Contractual Clauses
Retention period	Until such time as consent is withdrawn

OneTrust

Provider	OneTrust Technology Ltd. 82 St John St, Farringdon, London, EC1M 4JN, UK
Description	We use the OneTrust tool for consent and cookie management on our website.
Purpose	· Marketing · Implementation of legal obligations · Evaluations
Recipient (category)	· Group employees · SaaS vendors
Transfer to third countries	UK — Safeguard: EU adequacy decision
Retention period	Up to 2 years

SurveyMonkey

Provider	SurveyMonkey Inc. 1 Curiosity Way, San Mateo, CA 94403, USA
Description	At some points in our offers or in the communication with us, we are interested in your opinion. For this reason, we use SurveyMonkey as a tool to conduct surveys and satisfaction evaluations. This is done on the basis of your consent.
Purpose	· Marketing · Customer engagement · Evaluations
Recipient (category)	· Group employees · SaaS vendors
Transfer to third countries	USA — Safeguard: EU Standard Contractual Clauses
Retention period	Until such time as consent is withdrawn or an objection filed

Zendesk

Provider	Zendesk, Inc, 1019 Market Street, San Francisco, CA 94103, USA
Description	We use Zendesk's services as the technical basis for our support website and chat service.
Purpose	· Rendering of support services · Provision of the website · To generate revenue · Increase customer satisfaction · Evaluations
Recipient (category)	· Group employees · SaaS vendors
Transfer to third countries	USA — Safeguard: EU Standard Contractual Clauses
Retention period	In accordance with legal requirements

Description	We offer you newsletters on various topics. You can find an overview of our newsletters and your subscriptions here. You can withdraw your consent at any time, without this affecting the lawfulness of processing based on consent before its withdrawal, in your My BullGuard Account.
Purpose	· Provision of our newsletter · Marketing and public relations · Customer engagement · Evaluations
Legal basis	Art. 6(1)(a) GDPR — Consent
Recipient (category)	· Group employees · SaaS vendors
Transfer to third countries	USA — Safeguard: EU Standard Contractual Clauses
Retention period	Until such time as consent is withdrawn

Data upload

Description	You can send us suspicious files, files that trigger a false alarm in our software, and website addresses (URLs) by uploading them to us. We then analyze these files. Our signature database or the whitelist is then updated depending on the results. It is also possible to send us files by email.
Purpose	· Provision of the service · To perform a contract · Marketing · Customer engagement · IT security · Evaluations
Legal basis	Art. 6(1)(b) GDPR — Contract performance
Recipient (category)	· Group employees · IT service providers
Transfer to third countries	· USA — Safeguard: EU Standard Contractual Clauses · India — Safeguard: EU Standard Contractual Clauses
Retention period	Normally 30 days

Third-party services that you wish to use

On our websites we offer you functions from third parties. The necessary data transfer, e.g. your IP address, only takes place when you activate the module, the placeholder, or the link by clicking it. In this moment we establish a connection to the service provider and transmit the necessary data.

Social media

Like button

In our offers you will find "Like" buttons. These are standard links, which are only activated when you click them. You will then be redirected to the service provider's page. The browser data and the IP address are transmitted for this purpose. This also tells the service provider that you have visited our website.

For this data processing, we and the service provider carry joint responsibility. However, we are only jointly responsible for the collection of the data and until the transmission is completed. We have no influence on the further processing by the service provider and are therefore not jointly responsible.

Fan pages

We operate "fan pages" on some social media platforms. We are partly responsible for this together with the service provider. In doing so, our responsibility is limited to providing you with information and therefore data on visits to our site is collected by the service provider. In some cases there is the possibility that we receive an evaluation of the user behavior. We have no influence on the further processing by the service provider and are therefore not jointly responsible.

Facebook

Provider	Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland
Purpose	· Marketing and public relations · Customer engagement · To generate revenue · Evaluations
Legal basis	Art. 6(1)(f) GDPR — Legitimate interest: Provision of user-requested content
Transfer to third countries	USA — Safeguard: EU Standard Contractual Clauses
Retention period	In accordance with legal requirements
Service provider's privacy policy	https://www.facebook.com/policy.php

Google Search and Google Maps

Tool	Google Search and Google Maps
Provider	Google Ireland Ltd., Google Building Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland
Description	We are represented as a company in Google search and in Google's map service.
Purpose	· Marketing and public relations · Customer engagement · To generate revenue · Evaluations
Legal basis	Art. 6(1)(f) GDPR — Legitimate interest: Provision of user-requested content
Transfer to third countries	USA — Safeguard: EU Standard Contractual Clauses
Retention period	In accordance with legal requirements
Service provider's privacy policy	https://policies.google.com/?hl=en&gl=en

Provider	LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2 Ireland
Purpose	· Marketing and public relations · Customer engagement · Employee recruitment · To generate revenue · Evaluations
Legal basis	Art. 6(1)(f) GDPR — Legitimate interest: Provision of user-requested content
Transfer to third countries	USA — Safeguard: EU Standard Contractual Clauses
Retention period	In accordance with legal requirements
Service provider's privacy policy	https://www.linkedin.com/legal/privacy-policy?trk=homepage-basic_footer-privacy-policy

Twitter

Provider	Twitter Inc., 1355 Market Street, Suite 900 San Francisco, CA 94103, USA
Purpose	· Marketing and public relations · Customer engagement · To generate revenue · Evaluations
Legal basis	Art. 6(1)(f) GDPR — Legitimate interest: Provision of user-requested content
Transfer to third countries	USA — Safeguard: EU Standard Contractual Clauses
Retention period	In accordance with legal requirements
Service provider's privacy policy	https://twitter.com/en/privacy

YouTube

Provider	Google Ireland Ltd., Google Building Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland
Purpose	· Marketing and public relations · Customer engagement · To generate revenue · Evaluations
Legal basis	Art. 6(1)(f) GDPR — Legitimate interest: Provision of user-requested content
Transfer to third countries	USA — Safeguard: EU Standard Contractual Clauses
Retention period	In accordance with legal requirements
Service provider's privacy policy	https://policies.google.com/?hl=en&gl=en

Other providers

Trustpilot

Tool	Trustpilot
Provider	Trustpilot A/S, Pilestraede 58, 5. Etage, DK-1112 Copenhagen K, Denmark
Description	Trustpilot is a consumer review website. You can review our products and services on this platform.
Purpose	· To generate revenue · Customer engagement · Marketing and public relations · Evaluations
Legal basis	Art. 6(1)(f) GDPR — Legitimate interest: Provision of user-requested content
Transfer to third countries	None
Retention period	In accordance with legal requirements
Service provider's privacy policy	https://legal.trustpilot.com/for-reviewers/end-user-privacy-terms

Google reCAPTCHA

Tool	Google reCAPTCHA
Provider	Google Ireland Ltd., Google Building Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland
Description	To ensure data security when entering data, we use Google reCAPTCHA in certain cases. This tool helps us to prevent data input from automatic or machine systems.
Legal basis	Art. 6(1)(f) GDPR — Legitimate interest: IT security
Purpose	· IT security
Transfer to third countries	USA — Safeguard: EU Standard Contractual Clauses
Retention period	In accordance with legal requirements
Service provider's privacy policy	https://policies.google.com/privacy?fg=1

User accounts

Your My BullGuard Account

We offer you a customer account to administer your data and products. You can find this function under the corresponding icon or via the address: https://myaccount.bullguard.com/login.

When you buy a product through our online shop, a customer account is automatically created for you. In addition, you may voluntarily create a corresponding account with us at any time.

This account references your email address and a password that you set.

Please note that your customer account is kept active until you choose to delete it by submitting a request to our Support Team. We reserve the right, within the contractual agreements and according to applicable laws and regulations, to delete customer accounts at any time.

When you create or use an account, you do so in accordance with our End User License Agreement and our Terms and Conditions.

Purpose	· Operational process · Customer engagement / user management · To generate revenue · Evaluations
Legal basis	Art. 6(1)(b) GDPR — Contract performance
Recipient (category)	· Group employees · Service providers · IT service providers
Transfer to third countries	USA — Safeguard: EU Standard Contractual Clauses
Retention period	Until the account is deleted

Product download

You can download all the products on our website as a registered or non-registered customer. Depending on the product you download, we may process personal data. You can find further information under Products.

Purpose	· Operational process · Customer engagement / user management · To generate revenue · Evaluations
Legal basis	Art. 6(1)(b) GDPR — Contract performance
Recipient (category)	· Employees · IT service providers
Transfer to third countries	USA — Safeguard: EU Standard Contractual Clauses
Retention period	In accordance with legal requirements

Online shop

The online shop linked to on our website is operated by, and is the sole responsibility, of cleverbridge AG, Cologne. cleverbridge acts as our reseller.

Provider	cleverbridge AG, Gereonstr. 43-65, 50670 Cologne, Germany
Purpose	· Operational process · Distribution / sales processing · To generate revenue · Evaluations
Legal basis	Art. 6(1)(b) GDPR — Contract initiation and performance
Recipient (category)	· Group employees · Service providers · IT service providers · SaaS vendors
Transfer to third countries	USA — Safeguard: EU Standard Contractual Clauses
Retention period	In accordance with legal requirements
Service provider's privacy policy	https://shop.bullguard.com/1316/?scope=opprivacy&id=LZYNAzMBox

Changes to this Privacy Policy

This Privacy Policy is revised on an ad-hoc basis to adapt it to current developments in relation to our company, our products and services, legal requirements, and social developments.

Version: 2021.06.28

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