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Last updated on 25.05.2018
1.1. The Right Holder is the data controller. The User unconditionally and entirely accepts the terms and conditions of the Policy as soon as he/she starts using the Services. If the User disagrees with the Policy or with any of its terms and conditions, he/she has no right to use the Services. The User understands that the Services are intended to people who attained legal age to consent to such services according to their local law, so, when starting to use the Services, the User confirms that he/she has 1) attained this legal age in accordance with the laws of the country of which he/she is a national, or 2) that the User's agreement to the Policy is given with the permission and in the presence of the User's parents or other legal representatives. Unless the User has not expressly agreed to the contrary, the Right Holder proceeds on the basis that the User has reached the age of majority.
For personal data collected from Users located in the EU, where children are at least 13 years old and below the age of 16, the Right Holder will collect or process personal data about them with the consent or the authorisation of the holder of parental responsibility over the child. If the Right Holder becomes aware that it has unknowingly collected personal data from a child under the age of 13, or under the age of 16 without the consent or the authorisation of the holder of the parental responsibility, the Right Holder will make reasonable efforts to delete such personal data from its records.
2. Personal data of the User.
2.1. The prerequisite to provide the Services to the User is the receiving of the User's personal data by the Right Holder, and their future processing.
2.2. The personal data provided by the User when creating accounts for the use of the Services or while using the Services may include, for example, comments he/she made while using the Services, name, contacts details, email address, and country of the User which the User specified when registering.
2.3. Personal data is also transmitted to the Right Holder by the User's devices through the software installed on those devices while the User is using the Services. Such personal data includes, for example, the User's IP address. Other information such as cookie data, the contents and configuration of the User's hardware and software, and information about actions taken while the Services were being used may also be collected.
3. Purpose and legal basis of the processing.
3.1. The Right Holder processes the User's personal data on the following legal basis:
3.2. The Right Holder collects only personal data that is needed to:
3.3. For example, if the User contacts the technical support service or contacts via the email, the Right Holder shall process data provided by the User in the course of such request. The Right Holder does not collect and process personal data that is statutorily referred to special categories of personal data.
3.4. In addition, the User understands and accepts that information about the composition and configuration of his/her hardware and software configuration will be needed in order for the Right Holder to pinpoint any technical problems the User has experienced as a result of using the Services and to develop the most effective recommendations for eliminating such problems.
3.5. The User understands and accepts that when using the Services to upload files for online anti-virus scanning, the full path to the uploaded files on the User's device is revealed to the Right Holder. The Right Holder can store and use at its discretion any files uploaded by the User for online anti-virus scanning; this includes the Right Holder adding such information to its virus databases.
4. Accuracy of the personal data.
4.1 The Right Holder proceeds on the basis that the personal data provided by the User is reliable and up to date. The Right Holder expects the User to inform it of any changes to his/her personal data such as changes to contact information. The Right Holder is not liable for consequences arising from the User providing unreliable or outdated personal data.
5. Personal data security.
5.1. The Right Holder takes all necessary and sufficient technical and organisational measures to ensure that personal data are securely processed and to prevent User's personal data from being available to third parties without the User's consent, and from being deleted accidentally or in the result of illegal actions.
5.2. The same security measures shall be implemented by other companies providing services on the Right Holder's behalf and which process personal data on its behalf.
5.3. The laws of the Russian Federation in the field of personal data security may differ from the laws of the User's country of residence.
6. Storage period.
The Right Holder will store Users' personal data as long as reasonably necessary and only for as long as required to fulfil the relevant purposes of the processing of their personal Data.
7. User's rights.
7.1. Subject to local law, the User has the following rights to:
If the User wants to discuss or exercise such rights, he/she may contact the Right Holder via email address firstname.lastname@example.org
7.2. The Right Holder, upon receipt of such requests, has the right to take appropriate actions and request, from the person (who sent the request), information needed to ascertain that this person is the subject of the personal data requested. This action is intended to protect User's personal data from disclosing to third parties and to prevent any attempts to get access to personal data of other Users.
7.3. Because personal data statutorily includes data needed for the User technical identification in order to use the Right Holder's Software and Services, if the User sends a demand to stop processing or to delete his/her personal data, agreements and contract (and other types of cooperation) concluded with the User shall be terminated the same day the User's personal data is stopped to be processed or deleted in view of User's confirmation of will. Termination of agreements and contracts in view of User's confirmation of will means that the User is not able to use the Right Holder's Software and Services starting from the date of such termination. This also means that the Right Holder does not have any responsibilities to compensate the User for the unused period of the agreement, contract or services.
8. Sharing with third parties.
8.1. The Right Holder may share the User's personal data with third parties under the following circumstances:
Also, the User understands and accepts that despite the fact that the Right Holder uses secure protocols for receiving/transmitting data, the content of the files uploaded for online anti-virus scanning may be intercepted and read by third parties at the moment such files are uploaded (before the Right Holder receives the files) without the User's or the Right Holder's knowledge. Therefore, the Right Holder is not liable for the safety of the information contained in files uploaded by Users for online anti-virus scanning.
The User understands and accepts that prior his/her personal data is received by the Right Holder, such personal data is transmitted through communication channels that are not controlled by the Right Holder, therefore, the Right Holder is not liable for the safety of such transmission process.
9. Transfer of personal data.
The Right Holder collects personal data of the Users located in the European Union from the Russian Federation based on such User's explicit consent to transfer. In accordance with the clauses 45-49 of the GDPR, the User located in the European Union is informed of the possible risks of this transfer for his/her personal data due to the absence of any adequacy decision and appropriate safeguards. Prior to such consent, the User must also be informed that without his/her consent, the Right Holder will not be able to provide the Service.
10.1. Cookies are small text files that are temporarily stored on the User's computer through the web browser and allow websites, for example, to identify the User's computer during repeated website visits or to follow the User's activity. Cookies do not contain any personal data and are required for the collection of statistical data.
10.3. Types of cookies the Right Holder uses.
Among the above categories, cookies can be of two types: session and persistent cookies.
The Right Holder can change the terms of this Policy and will provide notification to the Users within a reasonable time prior to the change taking effect. A new version of the Policy comes into force as soon as it is published at company.drweb.com/policy, unless stated otherwise by the new version of the Policy.
12. Right Holder's representative
The Right Holder has appointed, as its representative in the EU, Doctor Web SARL, 9-11 Allée de l'Arche, 92671 Courbevoie cedex, France.
13. The Right Holder's contact information
Registered address: 2-12А, 3rd street Yamskogo polya, Moscow, Russia, 125124
Reg. # 1047796021723 / TIN 7714533600
Doctor Web is a Russian cybersecurity company focused on threat detection, prevention and response technologies.
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