Effective as of March 1, 2013

1. Privacy Statement

At Radialpoint, we are committed to protecting your personal information. We have created this document to help you understand how we collect, manage and use your personal information. This privacy policy applies to the access and use of our websites, products and services.

2. What we mean by…

In order to render this document as concise as possible, we decided to summarise some of the terms that we use from time to time. As a result, the following words and expressions, whenever used in this document, will have the meaning explained below:

We refer to “Company” as the legal entity with which you may have an agreement for the provision of products and/or services, and as part of which you are being provided with Radialpoint software and services.

When we refer to “Personal Information” in this document, we mean the information that either uniquely identifies a physical person or enables us to do so, as further explained below. Such information may include the person’s name, address, contact information (such as telephone numbers or email addresses), age, gender, and so forth.

When we use “Radialpoint”, “us”, “we”, “our”, or other similar words, we refer to Radialpoint SafeCare Inc. and its affiliated companies.
The terms “you”, “your”, “yours”, or other similar words refer to the persons who access or use our software and services, including our websites. This may include other persons to whom you may have given access to or allowed the use of your device, our software or services through your account, without our knowledge.

3. Why we need to collect your Personal Information

Your Personal Information is necessary for us to be able to better understand your needs and preferences, and to provide you with our software and services. Additionally, we may rely on your Personal Information to contact you regarding your account, upcoming changes, improvements, software updates and upgrades, new offers and promotions, as well as to improve the effectiveness of our offerings, to conduct research, analysis and other business related activities. In any event, your Personal information will not be used, made available or otherwise disclosed for purposes other than those specified herein, unless we obtain your prior consent or are required by law to do so.

4. What kind of Personal Information may be concerned

Radialpoint provides various software and services, any combination of which could be made available to you by Company. We will access and collect Personal Information only to the extent necessary to ensure that you are able to access and use our software and services. We may also collect and store Personal Information that you choose to provide to us, at your sole discretion, without us requiring you to do so.
In this section, we have tried to explain in which events your Personal Information may be accessed, collected, used and processed, including the types of Personal Information that may be required, depending on your access and use of our software and services.

General

In order to be able to identify and associate your account with you, we need to collect Personal Information specific to you. This includes your name, contact information, including your mailing address, your account information stored with Company, such as your account number, your subscription details, as well as other unique identifiers attributed to you by us or by Company. Also, when you contact us, whether by phone, chat, email, through our websites or otherwise, we may keep a record of your communication to help solve issues that you might be facing, but also for training, quality assurance and statistical purposes, as well as to improve our products and services.
When our software is installed on your device, we may, from time to time, send to your device information about updates and upgrades to our software. In some cases such updates or upgrades may be installed automatically without your knowledge. This helps us ensure that you are using the most recent software, which generally provides you with most up-to-date functions and security protection.
Please note that we may use your Personal Information to aggregate various performance, analytical and statistical data. When we do so, we put our efforts to ensure that your Personal Information is anonymised.

Premium Technical Support

Device client software
As part of our premium technical support services, we are providing you with our device client software, which has several very important purposes. Not only it enables us to better understand your needs and prevent problems that you may be experiencing with the device on which it is installed and running, but it also provides you with valuable information about the status of your device and your account. Additionally it allows you to request live support from technical support agents when you need it.
By default, our device client software will constantly run on your device and perform various background tasks, which help maintain your device in working condition. When running, it collects various data regarding your device, including its technical specifications, information regarding its operating system, downloaded and/or installed software, updates and upgrades, the availability and the status of your security software, backups and firewalls, various unique identifiers, system and software error messages, network connections status, connected peripherals and other connected devices, and so forth. This information enables us to prevent many common issues that you may be experiencing, but also to quickly identify problems for which you may be requesting our support.

Chat sessions

When you request live chat assistance from technical support agents, chat sessions are being recorded for quality assurance and training purposes, as well as to improve our products and services. As a result, all information exchanged during such chat sessions may be collected and used by us as part of our internal processes.

Live call sessions

Similarly, when you request live assistance from technical support agents by telephone, conversations may be recorded for quality assurance and training purposes, as well as to improve our products and services. As a result, all information exchanged during such recorded calls may be collected and used by us as part of our internal processes.

Remote control

If you request live support from one of the technical support agents, the agent may need to take remote control of your device in order to resolve the issues that you are experiencing. However, an agent will not access your device without you giving the agent your authorisation to log into your device to fix the problems.
If an agent takes remote control over your device, he or she may have access to any information stored on your device. However, technical support agents are trained not to access more information than what is absolutely necessary to resolve the issues for which you are requesting agent’s support. While support agents do not access unnecessary information, it is your responsibility to remain in front of your device screen to observe the actions of the agent while he or she performs the services on your device. Note that you will have the opportunity to end the live support session at any time by clicking on the appropriate button. In any case, it is your responsibility to ensure that all of your files, especially those containing your Personal Information, are secure to prevent any type of data loss or corruption.

Mobile application
As part of our premium technical support services, we may also provide you with our mobile application. In order for it to function properly, the following permissions will be requested from your OS: internet connection, receive notification that the boot is completed, read the state of your mobile device, access network information, manage the list of accounts (e.g. Google, Facebook, etc.), access those accounts, use tokenised account credentials, access Bluetooth and fine location (whether through wi-fi, GPS or other means), access wi-fi information, as well as read low-level logs on the device. The above list refers to permissions requested by our app from the OS. However, only the following information will be collected and processed by us: access points (APN), default browser, hardware data (memory, CPU, internal storage size and external storage size), operating system version, settings (full disk encryption, USB debugging, etc.), installed software (including installation data, last time run and version number), average running process, Bluetooth status, wi-fi status, as well as start-up applications.

Security Services

As part of our security services, if made available to you, we may, from time to time, send to your device(s) a file containing an updated list of viruses or other malicious software and codes.
Internet Security
If the Internet Security feature is included as part of our security services provided to you, we may gather the website URL addresses when you attempt to visit them and run them through our database of websites in order to identify whether the website you are about to visit has been flagged as containing malicious code or software that could undermine your privacy or the security of your device. However we do not store the URL addresses of websites that you visit.

Security Portal

In some cases, we may grant you access to Security Portal, our website allowing you to manage your security services account. For this purpose, additional Personal Information may be collected and processed by us, such as your email address and password associated with our security services, as well as some unique device identifiers necessary for the Security Portal to generate and send reports and alerts, including for the purposes of the Parental Control feature (please refer to the appropriate section below).

Security Portal may also invite you to input additional information about yourself, which will enable us to provide you customised experience while using our services. However, this information is optional, and should be entered at your discretion. Such information includes your name, contact information and description of your devices. If you choose to provide us with this additional information, we will collect and store it in accordance with this privacy policy.

Parental Control

In some cases, our security services comprise the Parental Control feature. This feature allows you to monitor the activity of your child using his of her device (such as computers or mobile phones, as applicable). As part of our Parental Control feature, the following information may be collected and processed: the operating system user account name, various email addresses used for online messaging, as well as the list of accessed websites and the list of applications on the device. This information will be collected and made available to you, entirely or in a summarised form, in the Security Portal.
Please note that the Parental Control feature is destined to be used exclusively for the purposes of monitoring the activity of your minor child, to ensure his or her safety. Monitoring the activity of a person without his or her prior express consent may violate such person’s privacy, and may result in your legal accountability. Therefore it is your responsibility to ensure that you do not use the Parental Control feature to monitor the activity of any person other than your minor child. In cases where you are required by law to obtain such minor child’s prior consent, it is your responsibility to ensure that such consent is properly obtained before you engage in the monitoring activity.

Online Backup

Our online backup services enable you to store the content of your device (in whole or in part) on our servers or those of our partners. This means that you will be providing us with the content of your device, including your Personal Information that it may contain. While we will not generally access or use any of this content, we reserve the right to access and screen your content to ensure that it complies with the terms and conditions applicable to its use.
In addition, the access to our online back-up services, depending on the solution provided to you, may require you to create an online backup account, for which you may be required to provide an email address and create a password associated with your online backup account.

Our websites

Most of our websites may be accessed and used without personal identification. In these cases, no Personal Information will be collected. However, we use web beacons to collect anonymous website usage information which describes how our visitors use and navigate our websites. This means that unless a visitor specifically discloses his or her identity to us by contacting us through our websites or by creating an account on them, thus providing us information through an online form, we will not know who the individual visitor is.
In some cases, you may have access to our secure websites, which enable you to manage your account, store your information, and so forth. When accessing and using our secure websites, you may be requested to identify yourself by providing answers to specific questions, which may include your Personal Information. Once logged in, you may be requested to provide us with additional information based on your usage of each website.
Please note that additional terms and conditions may apply to access and use of our websites, including disclaimers or warranty and limitations of liability. For more information, please refer to our website Terms of Use at www.radialpoint.com/en-terms/.

Cookies and Web Beacons

In some cases, we use cookies and web beacons to extend functionalities of our software, services and websites, as well as to personalise your experience. We invite you to visit www.radialpoint.com/en-cookies/ to learn more about these technologies, and to better understand how and why we rely on them.

IP addresses

An IP address is a sequence of numbers that is assigned to your device or network when you are connected to a network. In most cases, an IP address does not specifically identify an individual. We collect IP addresses as part of all our services for a variety of internal purposes, such as system administration, to report aggregate information to our business partners or to audit the number of visits to different pages on our websites. When you’re receiving our security services, we collect the IP address of your device and your gateway for the purpose of identifying the device affected by viruses or malware, and to enable us to provide your device with the appropriate security protection against viruses or malware.

Payments

In some cases, Company may enable you to pay for your subscription purchases using our secure payments systems. In order to complete your transaction you may be requested to provide your payments information, such as your name, billing address, email address and your card information. Your data will be transmitted to our payments partner for processing, in compliance with the payments card industry security standards.

Surveys

Occasionally we may conduct surveys on our websites. To participate, you may be asked to provide certain information, such as your age, gender, postal/zip code and other Personal Information. This information will be stored in our records. We may publish the results of the survey, but only in aggregate with other participants’ responses. Note that if we decide to share results of surveys with third parties, other than with Company, we will not include information that would allow them to personally identify you.

Marketing

We may occasionally contact you with specific email, text and other electronic or digital messages at Company’s request. Such communication may include information and advertisements from Company and its partners. We will not share your email addresses or other Personal Information to third parties for marketing purposes other than as set forth herein. It is your right to opt out from all such communications at any time by contacting us at <ahref=”mailto:privacy@radialpoint.com”>privacy@radialpoint.com.

5. Who may have access to your Personal Information

At Radialpoint, we recognise and respect the importance of protecting your Personal Information. Keeping your Personal Information in strict confidence is an integral part of our commitment to service excellence. We do not sell or rent your Personal Information to any third party. However, in order to provide you with our software or services, we may share your Personal Information with our affiliated companies, parent entities and subsidiaries, for internal business purposes, as well as with Company and our specific partners, acting on our behalf.
As many other service providers, we use third party partners’ assistance in some aspects of our business operations, which in some cases involves processing or handling of your Personal Information. However, before we do so, we take appropriate measures to ensure that your Personal Information remains safe and secure, and is used only in a way that is consistent with our privacy policy.
We protect your Personal Information even within our organisation. It may be accessible only to those employees, agents, representatives and consultants of Radialpoint who need to know such information as part of their duties. We also ensure that our employees, agents, representatives and consultants perform their duties in a way compatible with the terms and conditions described in this document.
Finally, as our services are provided to you in the name of Company, we may share your Personal Information with the latter for the purpose of ensuring your identity, your account and subscription status, and other. Once we do, Company will use your Personal Information in accordance with its own privacy policy.

6. How we protect your Personal Information

We work diligently to maintain physical, electronic and procedural safeguards that comply with industry best practices to guard your Personal Information against unauthorized access or use. Your Personal information is stored in secure data centers, access to which is restricted to authorised personnel only. We employ industry-leading technologies to store sensitive information and protect it while in transit over the internet. Additionally, our websites use industry standard Secure Socket Layer (SSL) technology to protect your information using both server authentication and data encryption.

7. Where your Personal Information may be processed

Radialpoint is a Canada-based company which, together with its partners and affiliated companies, operate in many countries. As a result, we may store or process your Personal Information in many places around the world. This means that your Personal Information may be stored, processed and used outside the State, province or country where you live.

8. Keeping your Personal Information accurate and up-to-date

In the provision of our services, we want to ensure that we provide you the best experience possible, and we rely heavily on the Person Information that you submit to us. Our software is built to facilitate the communication of the most recent information about your account and your devices. However, if you notice that the information that we have on you in our files is inaccurate, or your Personal Information changes (for example, you move or you change your phone number) we strongly encourage you to reach out to us and provide us with you most current information; not doing so may, in some cases, affect our capacity to deliver to you our services. Note that before updating your Personal Information, we may ask you to verify your identity before we can act on your request.

9. Retention of your Personal Information

Your Personal Information will be stored in accordance with our retention policies and processes. We will keep your information only for as long as it is necessary for us to fulfill our obligations. Thereafter, we will put necessary efforts to delete your Personal Information from our systems, unless we are required to keep it for legitimate business or legal purposes.

10. Privacy of children under 14

Our software and services are not intended for access and use by children under the age of 14. Except for the Parental Control feature (described above) which may be provided as part of our security services, we do not knowingly collect any information from children under 14 years of age.
If you are under 14 years of age, please do not submit any information about yourself to us. If we discover that a child under the age of 14 has provided us with Personal Information, we will deploy reasonable efforts to delete that child’s Personal Information from our systems.

11. What if we transfer or sell our business

Radialpoint is proud to operate its business. However if we ever decide to sell or transfer our business (whether entirely or partially), we may be required, during the process, to disclose to the actual or prospective investors the information that we may have about you. And if such transfer or sale occurs, we will use all reasonable efforts to ensure that your Personal Information continues to be used in a way that is consistent with our privacy policy.

12. Legal disclosure

We may be required to disclose any and all information that we have on you to legal authorities. Such disclosure may be required by law, a court order, or by other legal obligations that we may have in any jurisdiction. Additionally, we may disclose your information to competent law enforcement agencies or other appropriate entities if we have reasonable grounds to believe that you’re using our software or services in violation or in a manner that violates applicable laws or regulations.

13. Consent

You may give us your consent for the collection, use and disclosure of your Personal Information in several ways. It can be express (for example, by phone, chat, email, by accepting the terms of our End-User Licence Agreement, or other similar means) or implied (for example, when you provide us with your Personal Information necessary for the performance of specific services). In some cases, your consent may be given by your authorised representative (such as a legal guardian or a person having a power of attorney).
When you provide us with your Personal Information, we assume that you consent to our collection, use and disclosure of your Personal Information for the purposes identified or described in this privacy policy. Occasionally, we may also request your consent to access or collect additional Personal Information which may be necessary to enable us to render our services to you, even if not specifically identified in this document. We will treat such Personal Information in accordance with the terms of this privacy policy and the applicable laws.
It is your right to direct us to stop collecting, using or sharing your Personal Information at any time, subject to contractual and legal restrictions and reasonable advance written notice. However note that if you withdraw your consent, we may no longer be able to provide you our software or services, in whole or in part. If you still desire us to withdraw your consent, please contact us at the address written below.

14. Openness and accountability

Within Radialpoint, our Director of Security is responsible for our security and privacy-related matters, including the application of this privacy policy. He and his team oversee training of our staff to ensure security compliance and to raise privacy awareness.
Transparency and integrity are among the key values at Radialpoint. We will gladly answer any questions or concerns that you may have regarding your privacy or the security of your Personal Information, or if you wish to request a correction of your Personal Information in our custody or control. Don’t hesitate to reach us by visiting the “contact us” section of our website.
If for any reason you consider our response to be unsatisfactory or incomplete, please don’t hesitate to contact our Director of Security by email at privacy@radialpoint.com, or by mail at the following address:

Office of the Director of Security
Radialpoint
2050 de Bleury Street, Suite 300
Montreal, QC, H3A 2J5, Canada

You should also contact our Director of Security if you wish to request access to your Personal Information within our possession or control. Note however that in some cases it could impossible for us to provide you access to your Personal Information. This may occur when providing such access would be likely to impact the privacy or the security of a third party, reveal confidential information of Radialpoint or cannot be disclosed for other valid reasons. In these events we will advise you in writing of the grounds of our decision.
At last, if we are unable to resolve an issue to your satisfaction, you may choose to request assistance from the privacy authorities, such as the Privacy Commissioner of Canada, who may be contacted at 1-800-282-1376, or by visiting www.priv.gc.ca.

15. Updates to this privacy policy

Because we are continuously implementing new technologies and improving our processes, software and services, we may change this privacy policy from time to time, without prior notice. The most current version of this privacy policy is available at www.radialpoint.com/en-privacy/ However, if major changes are implemented in our privacy practices, a relevant notice will be posted on our corporate website, at www.radialpoint.com. The revised terms will take effect when they are made available on our website. Your access or use of our software or services after such posting will signify your acceptance of the new terms and conditions.
Where applicable, we will also provide you with instructions on how to opt in to or opt out from our new services or communications. Note that some aspects of our services may not be available to you if you choose to opt out.

This privacy policy has been last updated on March 1, 2013.
© 2013 Radialpoint SafeCare Inc. All Rights Reserved.