(Updated: July 20, 2022)

Privacy Policy

PSafe Tecnologia Ltda., CNPJ No. 12.501.419/0001-06, and its affiliates (“PSafe”, “we” or “us”), respects the privacy of its users’ information and protecting the privacy and confidentiality of our users’ Personal Information is a top priority. We have created this privacy policy (“Privacy Policy”) to advise you about our information practices, such as the types of information we collect and how we may use that information, and to inform you about your privacy rights and how the law protects you. We urge you to read this Privacy Policy carefully to understand our policies and practices regarding your Personal Information and how we will treat it. By visiting any part of our Websites (as defined below) or otherwise providing PSafe with Personal Information by any means, you accept and agree to the practices described in this Privacy Policy and your continued use of the Websites (following the posting of a revised privacy policy) means that you accept and agree to the terms of the revised privacy policy, so please check the policy periodically for updates.

This Privacy Policy is an integrated part of the PSafe’s Terms of Use and License Agreement, and applies to (i) https://www.psafe.com/, https://enterprise.psafe.com, and https://www.dfndrlab.com (and all respective sub-domains), and all other websites features, mobile applications, or online services that are owned or controlled by PSafe and that post a link to this Privacy Policy (the “Websites”); (ii) all products, programs, and software and the services offered through each (collectively, the “Services”); and (iii) information you may submit to us through another channel such as events you may attend (for example, trade shows) or applying for a job. By accepting either of the Terms of Use or License Agreement, the user accepts the policies contained in this Privacy Policy. So, when using any of the Services, the user acknowledges that the user has read and agreed to the terms and conditions of this Privacy Policy.

This Privacy Policy is provided in a layered format so you can click through to the specific areas set out below.

I. IMPORTANT INFORMATION AND WHO WE ARE
II. INFORMATION WE COLLECT
III. HOW WE COLLECT YOUR PERSONAL INFORMATION
IV. THIRD-PARTY ANALYTICS PROVIDERS & AD SERVERS; ONLINE TRACKING
V. USE OF PERSONAL INFORMATION BY PSAFE
VI. HOW WE DISCLOSE PERSONAL INFORMATION
VII. YOUR CHOICES REGARDING YOUR INFORMATION
VIII. DATA SECURITY
IX. NOTIFICATION FOR INAPPROPRIATE CONTENT
X. A NOTE TO USERS OUTSIDE OF THE UNITED STATES
XI. CALIFORNIA RESIDENTS – YOUR CALIFORNIA PRIVACY RIGHTS
XII. CONTACT INFORMATION

I. IMPORTANT INFORMATION AND WHO WE ARE

A. APPLICATION OF THIS PRIVACY POLICY
This Privacy Policy applies to all Websites and Services, whether accessed via computer, mobile device, or otherwise. Note, however, this Privacy Policy does not apply to use of unaffiliated websites that link to our Websites. Once you enter another website (whether through an advertisement, service, or content link), be aware that we are not responsible for the privacy practices of such other websites.

B. PURPOSE OF THIS PRIVACY POLICY
This Privacy Policy aims to give you information on how PSafe collects and uses your Personal Information through your use of the Websites, including any information you may provide through the Services or Websites when you sign up for an account, sign up to receive information or communications from us, purchase a product or service, or request further services or information from us.

It is important that you read this Privacy Policy together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or using Personal Information about you so that you are fully aware of how and why we are using your information. This Privacy Policy supplements the other notices and is not intended to override them.

C. CHILDREN
The Services and Websites are not designed for, or directed to, children under the age of 16 and PSafe does not knowingly collect information of individuals under the age of 16. If PSafe discovers that it has inadvertently collected Personal Information from anyone younger than the age of 16, we will take steps to remove that user’s Personal Information from our databases and to prevent the user from utilizing the Services. If you are under 16, please do not register an account, make any purchases, or send any information about yourself to us, including your name, address, telephone number or e-mail address. If you believe we might have Personal Information from an individual under the age of 16, please contact us at [email protected].

D. CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES
This version was last updated on the date reflected at the top of this page and historic versions can be obtained by contacting us.

We reserve the right, at any time and without notice, to add to, change, update or modify this Privacy Policy, simply by posting such change, update or modification on the Websites. Any such change, update or modification will be effective immediately upon posting on the Websites. If we make material changes to this Privacy Policy, we will notify you by email or by posting a notice of such changes at https://www.psafe.com/privacy-policy/ and we will change the “Updated” date above. However, unless you consent, PSafe will not use your Personal Information in a manner materially different than what was stated in our posted Privacy Policy at the time your Personal Information was collected. Please check this Privacy Policy regularly to ensure you are aware of any changes in our practices.

It is important that the Personal Information we hold about you is accurate and current. Please keep us informed if your Personal Information changes during your relationship with us. You are responsible for maintaining the accuracy of the information you submit to us, such as your contact information. If you contact us with changes, we will make good faith efforts to make requested changes in our then-active databases as soon as reasonably practicable. Note, however, that information may persist internally for our administrative purposes and that residual data may remain on backup media or for other reasons.

E. THIRD-PARTY CONTENT, LINKS TO OTHER PLATFORMS, AND PSAFE CONTENT FOUND OUTSIDE THE WEBSITES OR SERVICES
This Privacy Policy addresses only our use and disclosure of information we collect from and/or about you on the Websites or through the Services. If you disclose information to others, or authorize us to do the same under this Privacy Policy, the use and disclosure restrictions contained in this Privacy Policy will not apply to any third party. We do not control the privacy policies of third parties, and you are subject to the privacy policies of those third parties where applicable.

The Websites and Services may contain content or links to other platforms that are not owned or controlled by us. We have no control over, do not review and are not responsible for the privacy policies of or content displayed on such other platforms. When you click on such a link, you will leave the Websites or Services and go to another platform. During this process, another entity may collect Personal Information or Anonymous Information from you. Please review the privacy policy of any new platform you visit.

In addition, PSafe content (such as, but not limited to, advertising) may be included on web pages and websites or platforms that are not associated with PSafe and over which we have no control. These third parties may collect data through the use of their own cookies, pixel tags or other technology, independently collect information or solicit Personal Information, and may have the ability to track your use of their platforms, websites and services. PSafe is not responsible for the privacy practices or the content of any third party.

II. INFORMATION WE COLLECT
Personal Information or personal data means any information about an individual from which that person can be identified. It does not include information where the identity has been removed (“Anonymous Data”).

We and our third-party service providers (such as, but not limited to, Google Play and the Apple Store) may collect, use, store and transfer different kinds of Personal Information about you that we have grouped together as follows:

• Identity Information includes real name, alias, username, email address, or similar identifier (including, if you have shared them with us, your user display name and/or user picture thumbnail from online services).
• Contact Information includes billing address, postal code, delivery address, email address and telephone numbers (and job title and company name, if applicable).
• Financial Information includes bank account and payment card details.
• Transaction Information includes details about payments to and from you and other details of products or services you have purchased from us.
• Technical Information includes internet protocol (IP) address; operating system / version / language and platform; device type; device manufacturer; device model; screen size / density; RAM size, storage size, free/unused storage; connection type (e.g., WiFi, 4G, etc.); carrier identifiers (SIM code, mobile country code, mobile network code); installed applications / apks and their versions (including local file path), permissions, publishers, and installation sources; browser package name; and websites/URLs visited (if you have enabled anti-phishing).
• Online Identifiers include an online identifier or other persistent identifier that can be used to recognize a person, family or device, over time and across different services, including but not limited to, a device identifier (such as IMEI); cookies, beacons, pixel tags, mobile ad identifiers (including Google Advertising ID), or similar technology; customer number / internal IDs, unique pseudonym, or user alias; telephone numbers, or other forms of persistent or probabilistic identifiers (i.e., the identification of a person or a device to a degree of certainty of more probably than not) that can be used to identify a particular person or device.
• Internet or Network Information includes browsing history (URLs), search history, and information regarding a person’s interaction with an Internet website, application, or advertisement; also connected WiFi network details (if WiFi security has been enabled in certain of our apps).
• Profile Information includes your email address and password, purchases or orders made by you, your interests, preferences, product feedback, and survey responses.
• Usage Data includes information about how you use our Services, products and services, including all of the areas within our Services that you visit or use and the time of day you visited the Services, among other information.
• Marketing and Communications Information includes your preferences in receiving marketing from us and our third parties and your communication preferences.
• Location Information includes information gathered or inferred about your location using a variety of technologies, such as IP address, and connected or nearby Wi-Fi networks, or precise location derived from GPS coordinates or telemetry data (including latitude/longitude).

We also collect, use and share Aggregated Information such as statistical or demographic information for any purpose. Aggregated Information may be derived from your Personal Information but is not considered Personal Information in law as this information does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Information with your Personal Information so that it can directly or indirectly identify you, we treat the combined information as Personal Information that will be used in accordance with this Privacy Policy.

We do not collect any Special Categories of Personal Information about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

III. HOW WE COLLECT YOUR PERSONAL INFORMATION
We and our third-party service providers use different methods to collect information from and about you including through:

• Direct interactions. You may choose to give us your Identity, Demographic, Contact, Financial, Profile, or Marketing and Communications Information by filling in forms or by corresponding with us by mail, phone, email, or otherwise. This includes Personal Information you provide when you:
  • purchase or subscribe to our products or services;
  • create an account through the Services;
  • subscribe to emails or newsletters;
  • request services (including demos) or other information;
  • enter a competition, promotion or survey;
  • register for an event or participate in an event in which we participate; or
  • give us feedback about products, services, or the Websites.
• Automated technologies or interactions. As you interact with the Websites or Services, we may automatically collect Technical, Usage, and Location Information about your equipment, browsing actions and patterns. We collect this Personal Information by using cookies, pixel tags, embedded scripts and other similar technologies. Please see information about our cookie policies in Section VII.B for further details.
• Cookies.  Cookies are small data files that a website sends to your Device while you are viewing the website that are stored on the Device. Cookies can be used for many purposes, including to monitor use of websites, to customize content specific to your interests, to ensure that you do not see the same advertisement repeatedly, to speed up your searches and purchases and to recognize you when you return to websites and/or store your user name and password so you do not have to re-enter it each time you visit websites. You may refuse to accept cookies by activating the appropriate setting on your browser. However, if you choose to disable cookies on your Device, some features of the Websites, Services, or our content may not function properly.
• Pixel Tag. Pixel Tags (also referred to as clear GIFs, 1×1 GIFs Web beacons, or Web bugs) are small graphic images or other web programming code that may be included on the Websites, Services, and in our e-mail messages. In contrast to Cookies, which are stored on a user’s Device, Pixel Tags are embedded invisibly in web pages. Pixel Tags may be invisible to you, but any electronic image or other web programming code inserted into a web page or e-mail can act as a pixel tag. Pixel Tags or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to the Websites, to monitor how users navigate the Websites or use the Services, to count how many e-mails that were sent were actually opened or to count how many particular articles or links were actually viewed.
• Embedded Scripts. Embedded scripts are programming code designed to collect information about your interactions with the Websites and Services, such as the links you click. The code is temporarily downloaded onto your Device from our web server or a third-party service provider, and is active only while you are connected to the Websites or Services.
• Third parties or publicly available sources. We may receive Personal Information about you from various third parties. We also may supplement the information we collect with outside records from third parties in order to provide you with information, services or goods you have requested, to enhance our ability to serve you, and to tailor our content to you. We may combine the information we receive from those other sources with information we collect through the Services. In those cases, we will apply this Privacy Policy to the combined information. Examples of third-party sources include:
  • Technical Information from analytics providers;
  • Contact, Financial and Transaction Information from providers of technical, payment and delivery services.
  • Identity, Profile, and Contact Information from publicly available sources, including websites and forums on the internet.
• Activating additional features. We may receive additional Personal Information about you if you elect to activate optional features or services as set forth below
  • If you elect to activate the anti-theft functions in dfndr / PSafe DFNDR / DFNDR Security, PSafe may collect Location Information for purposes of providing the anti-theft functionality.
  • If you elect to use the Identity Theft Report function offered through dfndr security, we may collect your email address as detailed in the License Agreement.
  • If you elect to use the Wi-Fi Security or Wi-Fi Theft Protection functions and their associated features, we may collect your categorizations of Wi-Fi networks and associated technical information (including, but not limited to, network/device names, IP address, or inferred geolocation), as well as technical information about devices connected to the Wi-Fi network. This information only is stored locally on your device to facilitate your use of the function.

IV. THIRD-PARTY ANALYTICS PROVIDERS & AD SERVERS; ONLINE TRACKING
PSafe works with certain third parties (including ad networks, ad agencies, and analytics companies, collectively “Advertising Partners” and each an “Advertising Partner”) to provide us with information regarding traffic on the Services, to serve advertisements, including our advertisements elsewhere online, and to provide us with information regarding the use of the Services and the effectiveness of our advertisements. These third parties may use Technical Information, Online Identifiers, Internet and Network Information, Profile Information, Usage Data, Marketing and Communications Information, Location Information and related information to compile reports on user activity. For example, if you clicked on one of our advertisements that led you to our Websites or Services, our service provider(s) may be able to tell us which advertisement you clicked on and where you were viewing the advertisement. These third parties may set and access their own tracking technologies (including cookies, embedded scripts, and pixel tags) and may otherwise collect or have access to your Technical Information, Online Identifiers, Internet and Network Information, Profile Information, Usage Data, Marketing and Communications Information, Location Information and related information about you. Cookies and pixel tags, including those set by third-party network advertisers, may be used to, among other things, target advertisements, prevent you from seeing the same advertisements too many times, conduct research regarding the usefulness of certain advertisements to you, and assist in providing analytics.

These third parties may also transfer information collected about you to other third parties where required to do so by law, or where such third parties process analytics information on their behalf. Each of these third party’s ability to use and share information collected about you is restricted by their respective Terms of Use and Privacy Policy. By using our Services, you consent to the processing of data about you by these third parties in the manner and for the purposes set out above. For a full list of third-party analytics services, please contact us at [email protected].

We may share Technical Information, Online Identifiers, , Internet and Network Information, Profile Information, Usage Data, Marketing and Communications Information, Location Information and related information about visitors with third-party advertising companies, analytics providers and other vendors to help analyze how users use the Websites and Services. These analytics services may use their own software development kits (SDKs) to collect information such as how often and what features of the Websites and Services users use. We use this information to improve the Websites and Services. The analytics services’ ability to use and share information collected by them is restricted by their respective terms of use and privacy policy, which you should refer to for more information about how these entities use this information, and how you can opt-out of their use of such information.

While we may use a variety of service providers to perform advertising and analytics services, some of these companies may be members of the Network Advertising Initiative (“NAI”) or the Digital Advertising Alliance (“DAA”) Self-Regulatory Program for Online Behavioral Advertising.

For additional information regarding targeted advertising, and the “opt-out” procedures of NAI members and DAA Self-Regulatory Program participating companies, you may visit:

• NAI Opt-Out Tool: https://www.networkadvertising.org/managing/opt_out.asp
• DAA Consumer Choice (for website users): http://optout.aboutads.info
• DAA AppChoices (for mobile app users): https://youradchoices.com/appchoices
• EDAA opt-out (for European web-based data): http://www.youronlinechoices.eu

Please note that opting out through these mechanisms does not opt you out of being served advertising. You will continue to receive generic ads while visiting the Services and elsewhere online. Some third parties may collect Personal Information about your online activities over time and across different websites.

Your browser settings may allow you to automatically transmit a “Do Not Track” signal to websites and online services you visit. However, there is no consensus among industry participants as to what “Do Not Track” means in this context. Like many websites and online services, the Websites and Services currently do not respond to or alter their practices when they receive a “Do Not Track” signal from a visitor’s browser. To find out more about “Do Not Track,” you may wish to visit https://www.allaboutdnt.com.

V. USE OF PERSONAL INFORMATION BY PSAFE
We use the Personal Information we collect to offer services and features that can be tailored to users’ needs, and even allows us to customize the Services to make the users’ experiences with PSafe as useful and enjoyable as possible. We (and our third-party service providers) use the Personal Information, including Usage Data, as follows:

• Service Delivery:
  • to provide you with our Services and related customer service;
  • to process your registration and account creation with the Services, including verifying your contact information is active and valid;
  • to identify you as a user in our system;
  • to provide you with information, products or Services that you have requested or agreed to receive;
  • to provide improved administration of our Websites and Services;
  • to process transactions you initiate, process payments and provide accurate billing and shipping.
• Compliance & Operations:
  • to send you administrative e-mail notifications, such as order confirmations, order status updates, security, or support and maintenance advisories;
  • for compliance fraud prevention and safety, including enforcing our terms of service and this Privacy Policy, protecting our rights privacy, safety, or property and/or that of you or others, and protecting against, investigating or deterring fraudulent, harmful, unauthorized, unethical or illegal activity;
  • to carry out our obligations and enforce our rights arising from any contracts entered into between you and us;
  • to notify you about changes to our Websites or Services;
  • to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities;
  • to create Anonymous Data by excluding information that makes the information personally identifiable to you;
  • to contact you with regard to your use of the Websites or Services and, in our discretion, changes to the policies or functionality for our Websites or Services;
  • to process your application (and perform other recruitment-related functions) if you apply for employment with us;
  • to perform other functions as described at the time of collection, with your consent, or as further described in this Privacy Policy.
• Marketing:
  • to send newsletters, surveys, offers, and other promotional materials related to our Services and for other marketing purposes of PSafe;
  • to market our products or Services, including recommending products or Services that might be of interest to you.
• Research & Development:
  • to improve our Websites and Services;
  • to present the contents of our Websites and Services in a suitable and effective manner for you and for your computer; and
  • to improve the quality of experience when you interact with our Websites and Services for internal business purposes.

In addition to the above, we may use Anonymous Data to analyze request and usage patterns so that we may enhance the content of our services and improve navigation on the Services. We reserve the right to use Anonymous Data for any purpose and disclose Anonymous Data to third parties in our sole discretion.

A. EMAIL COMMUNICATIONS
You will receive newsletters or marketing communications from us if you have requested information from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have consented receiving marketing communications at that time.

B. FEEDBACK
If you provide feedback to us, we may use and disclose such feedback in accordance with the terms in our Terms of Use and/or License Agreement, provided we do not associate such feedback with your Personal Information. We may publish user feedback from time to time, provided that we will obtain your consent prior to publishing any feedback that is associated with your Personal Information. We will collect any information contained in such feedback and will treat the Personal Information in it in accordance with this Privacy Policy, provided that we may contact you in regards to such feedback.

C. COOKIES
A cookie is a data file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server. Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiration date, unless deleted by the user before the expiration date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed. Cookies do not typically contain any information that personally identifies a user, but Personal Information that we store about you may be linked to the information stored in and obtained from cookies.

Cookies are used to better understand how individuals are using our Websites and Services; cookies will not be used for other purposes unrelated to the operations of PSafe.

Most browsers allow you to refuse all or some browser cookies, or to alert you when websites set or access cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain information about blocking and deleting cookies for some commonly used browsers via the links below:

• Chrome: https://support.google.com/chrome/answer/95647?hl=en;
• Edge: https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy;
• Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences;
• Internet Explorer: https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies;
• Opera: https://www.opera.com/help/tutorials/security/cookies/; and
• Safari: https://support.apple.com/guide/safari/manage-cookies-and-website-data-sfri11471/mac.

Please note that blocking all cookies will have a negative impact upon the usability of many websites and if you choose to block cookies, you may not be able to use all the features on our Websites or Services.

Additionally, cookies or other similar systems installed by third parties can be found on certain pages of the Websites or Services.

It is understood that this Privacy Policy covers the use of cookies by the Websites or Services and not the use of cookies by advertisers. PSafe does not control the use of cookies by third parties.

D. PUBLICLY POSTED INFORMATION
The Services may offer publicly accessible areas such as blogs or comment threads. This includes, but is not limited to, comments to the PSafe blog. You should be aware that any information you provide in these areas may be read, collected, accessed, and used by others who access them, including third parties.

VI. HOW WE DISCLOSE PERSONAL INFORMATION
We may share non-personally identifiable information, such as aggregated user statistics, in our discretion and without restriction.

PSafe may disclose Personal Information, as disclosed at the time you provide your information, with your consent, and as set forth in this Privacy Policy. For example, PSafe may share Personal Information as follows:

A. INTERNAL THIRD PARTIES
We may share some or all of users’ Personal Information with our parent company, subsidiaries, joint ventures, or other companies under common control for a variety of purposes, including for business, operational, and marketing purposes. PSafe may, and reserves the right to, share your information with any other company that is not presently, but becomes, a PSafe parent, subsidiary, or affiliate.

You may be presented with an opportunity to receive information and/or marketing offers from PSafe and our affiliated businesses, partners and agents. If you agree at that time to receive such communications, your Personal Information will be disclosed to that third party (or parties). For more information, please refer to the Marketing Communications section.

B. EXTERNAL THIRD PARTIES

Administrative & Legal Third Parties

PSafe cooperates with the relevant authorities and with third parties to ensure compliance with the law, for example in areas such as protection of industrial property rights and intellectual property, privacy and personal data protection, fraud prevention and others.

We may transfer and disclose information, including Personal Information, to third parties:

• to comply with a valid legal inquiry, investigation, or process such as a search warrant, subpoena, statute or court order, or if in our opinion such disclosure is required by law;
• to obtain or maintain insurance coverage, manage risks, obtain professional advice, or establish, exercise or defend legal claims, whether in court proceedings or in an administrative or out-of-court procedure;
• to protect the safety, interests, rights, property or security of PSafe, you, or any third party;
• to respond to a breach or attempted breach of the security of our Websites or Services;
• to defend or assert our legal rights pursuant to any of the Terms of Use, any policies applicable to the Services, or any other agreement you may have with PSafe; or
• at the request of governmental authorities conducting an investigation.

We may also use Technical Information to identify users, and may do so in cooperation with copyright owners, Internet service providers, wireless service providers, or law enforcement agencies in our discretion.

Third-Party Service Providers

We may share users’ Personal Information with service providers or “outsourced” companies that improve or facilitate PSafe’s operations or provide services on our behalf such as (but not limited to) transport services, call centers, or loyalty programs, among others. Nevertheless, the user agrees that PSafe is not responsible for the misuse of the user’s personal information by these companies or websites. In some cases, these service providers collect information directly from the user (for example, in the case of purchases through app stores, or requests to conduct surveys or studies). In such cases, the user will receive a notification about the participation of a service provider in such activities and the user will have complete discretion over what information the user wants to provide. To facilitate such situations, and to take care of any additional information directly provided to such service providers, such service providers will use the information in accordance with their own privacy policies.

Third-Party Payment Processing

As of the date of this Privacy Policy, all online payments for the Services are handled by either Google Play (https://play.google.com/store) or the App Store (https://www.apple.com/ios/app-store/), depending on the user’s device. We do not process, record or maintain your credit card or bank account information, and all transactions conducted on Google Play and the App Store are subject to their respective terms of service available at https://play.google.com/intl/en_us/about/play-terms.html and https://www.apple.com/legal/internet-services/itunes/us/terms.html.  For more information on how payments are handled, or to understand the data security and privacy afforded such information, please refer to https://www.google.com/intl/en/policies/privacy/ (for Android devices) or https://www.apple.com/legal/privacy/en-ww/ (for Apple devices).

Promotions or Contests

Winners of any commercial promotions and/or contests conducted by PSafe, or people who participate in PSafe’s loyalty programs, expressly authorize PSafe to share their names, personal data provided to PSafe to participate in the promotion, contest or program, and images (photos), in the ways it sees fit, for the purpose of advertising and/or promotion, without the right to any compensation.

C. SHARING BETWEEN PSAFE COMPANIES; BUSINESS TRANSFERS
We may share and disclose some or all of users’ Personal Information in connection with or during negotiation of any merger, financing, acquisition or dissolution, transaction or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets. In the event of an insolvency, bankruptcy, or receivership, Personal Information may also be transferred as a business asset. If another company acquires our company, business, or assets, that company will possess the Personal Information collected by us and will assume the rights and obligations regarding users’ Personal Information as described in this Privacy Policy. These transfers and disclosures may be carried out without notice to you.

VII. YOUR CHOICES REGARDING YOUR INFORMATION

YOU CAN STOP ALL COLLECTION OF INFORMATION BY OUR APPLICATIONS BY UNINSTALLING THE RELEVANT APPLICATION.

In addition, you have several choices regarding the use of information on our Websites and Services:

A. OPTING OUT
We will communicate with you primarily in the form of emails. You can manage the frequency and/or opt out of receiving these communications by clicking the “Unsubscribe” link at the bottom of each email. Please note that even if you unsubscribe or opt-out, we may still send you services-related communications including notices of any updates to our Terms of Use or Privacy Policy.

You also may contact [email protected] to register an “opt-out” request that removes your email from visibility in Identity Theft Report searches, rather than permanently deleting it (to ensure that if the email address appears in information from subsequent Data Breaches obtained by PSafe, it does not become searchable again); note that an email address which is subject to an “opt-out” request may remain searchable if you complete a standard email verification process related to that specific email address.

B. COOKIES
If you decide at any time that you no longer wish to accept cookies from the Websites and/or the Services for any of the purposes described above, then you can instruct your browser, by changing its settings, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. Please consult your browser’s technical information and review the information in Section V.C for more information on how to do so. If you do not accept cookies, however, you may not be able to use all portions of the Websites and/or the Services or all functionality of the Websites and/or the Services.

C. ACCESSING, UPDATING, CORRECTING OR DELETING INFORMATION
You may review, change, update, or correct your Personal Information by contacting us at [email protected]. You authorize us to use and disclose any new or modified information that you provide in accordance with this Privacy Policy.

You may request deletion of your Personal information that PSafe has obtained through the date of your request be deleted from our systems, please contact [email protected] and we will use commercially reasonable efforts to honor your request, but please note that we may be required to keep such information and not delete it (or to keep this information for a certain time, in which case we will comply with your deletion request only after we have fulfilled such requirements). We may also retain an archived copy of your records as required by law or for legitimate business purposes. Certain users (e.g., residents of California) have additional rights detailed in Section XI below.

Please remember, however, if we have already disclosed some of your Personal Information to third parties, we cannot access that Personal Information any longer and cannot force the deletion or modification of any such information by the parties to whom we have made those disclosures. Certain information is necessary in order for us to provide the Services; therefore, if you delete such necessary information you may not be able to use the Services. Please note that even though you may request the deletion of your Personal Information by us, we may be required (by law or otherwise, such as to prevent fraud, resolve disputes, troubleshoot problems, or enforce our Terms of Use and/or Privacy Policy) to keep this information and not delete it (or to keep this information for a certain time) in which case we will comply with your deletion request only after we have fulfilled such requirements. When we delete Personal Information, it will be deleted from the active database, but may remain in our archives.

D. CHOOSING NOT TO SHARE PERSONAL INFORMATION
You may choose not to provide us with any Personal Information. In such an event, you may still be able to access and use our Websites and Services; however, you may not be able to access and use those portions of the Websites or Services that require your Personal Information.

Where we need to collect Personal Information by law, or under the terms of a contract we have with you and you fail to provide that information when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with Services). In this case, we may have to cancel a product or Services you requested from us but we will notify you if this is the case at the time.

E. MARKETING COMMUNICATIONS
We strive to provide you with choices regarding certain Personal Information uses, particularly around marketing and advertising. You can opt-out of such communications as outlined in Section A, above.

Please note that you may continue to receive service-related and other non-marketing communications.

VIII. DATA SECURITY
PSafe uses commercially reasonable security measures to help protect your personal information from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know.

However, please note that no system can be completely secure and although PSafe will use all reasonable endeavors to protect the integrity of the information you provide, we do not ensure or warrant the security of any information we collect. You use our Services and provide us with your information at your own risk.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

We have put in place procedures to deal with any suspected Personal Information breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

IX. NOTIFICATION FOR INAPPROPRIATE CONTENT
Should the user verify that any content the user deems to be improper was inserted by a third party in the Websites or Services, the user must send written notice to PSafe indicating the content deemed to be improper, providing sufficient information to enable the specific identification of the alleged improper material, to the e-mail [email protected].

X. A NOTE TO USERS OUTSIDE OF THE UNITED STATES
If you are a non-U.S. user of the Websites or Services, by visiting the Websites or using the Services and providing us with information, you acknowledge and agree that your Personal Information may be processed for the purposes identified in the Privacy Policy. In addition, your Personal Information will be stored in a database, located in Brazil and/or the United States (via Amazon Web Services) and may be processed in the country in which it was collected and in other countries where laws regarding processing of Personal Information may be less stringent than the laws in your country. By providing your data, you consent to such transfer.

XI. CALIFORNIA RESIDENTS – YOUR CALIFORNIA PRIVACY RIGHTS
This section applies only to California residents. It describes how we collect, use and share Personal Information of California residents in operating our business, and their rights with respect to that Personal Information. For purposes of this section, “Personal Information” has the meaning given in the California Consumer Privacy Act of 2018 (“CCPA”) but does not include information exempted from the scope of the CCPA.

Your California privacy rights. As a California resident, you have the rights listed below. However, these rights are not absolute, and in certain cases we may decline your request as permitted by law.

• Information. You can request the following information about how we have collected and used your Personal Information during the past 12 months:
  • The categories of Personal Information that we have collected.
  • The categories of sources from which we collected Personal Information.
  • The business or commercial purpose for collecting and/or selling Personal Information.
  • The categories of third parties with whom we share Personal Information.
  • Whether we have disclosed your Personal Information for a business purpose, and if so, the categories of Personal Information received by each category of third party recipient.
  • Whether we’ve sold your Personal Information, and if so, the categories of Personal Information received by each category of third party recipient.
• Access. You can request a copy of the Personal Information that we have collected about you during the past 12 months.
• Deletion. You can ask us to delete the Personal Information that we have collected from you.
• Opt-out of sales. If we sell your Personal Information, you can opt-out. In addition, if you direct us not to sell your Personal Information, we will consider it a request pursuant to California’s “Shine the Light” law to stop sharing your personal information covered by that law with third parties for their direct marketing purposes .
• Opt-in. If we know that you are younger than 16 years old, we will ask for your permission (or if you are younger than 13 years old, your parent’s or guardian’s permission) to sell your Personal Information before we do so.
• Nondiscrimination. You are entitled to exercise the rights described above free from discrimination. This means that we will not penalize you for exercising your rights by taking actions such as denying you services; increasing the price/rate of services; decreasing service quality; or suggesting that we may penalize you as described above for exercising your rights.

With respect to Deletion and Opt-Out requests, note that our applications collect certain data automatically and share it with advertising networks to customize the ads you see within the applications. If you submit such a request, we will cease sharing the data that we have collected to date; however, If you do not uninstall the application(s) after submitting such a request, or if you reinstall the applications(s) in the future, the application(s) will share the data collected during future uses.

How to exercise your rights

You may exercise your California privacy rights described above as follows:

• Right to information, access and deletion. You can request to exercise your information, access and deletion rights by:
  • emailing us at [email protected]
  • contacting us via postal mail at the following address:
    PSafe Tecnologia Ltda.
    Caixa Postal 10900
    Avenida Nossa Senhora de Copacabana 540, Loja A
    AC Copacabana
    Copacabana, 22020-970
    Rio de Janeiro, RJ, Brazil

• Right to opt-out of the “sale” of your Personal Information. We do not sell your Personal Information in the conventional sense (i.e., for money). However, like many companies, we use services that help deliver interest-based ads to you. California law classifies our use of these services as a “sale” of your Personal Information to the companies that provide the services. This is because we allow them to collect information from our website users (e.g., online identifiers and browsing activity) so they can help serve ads more likely to interest you.   You can request to opt-out out of this “sale” of your personal information here: Do Not Sell My Personal Information.

We will need to confirm your identity and California residency to process your requests to exercise your information, access or deletion rights. We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.

Personal information that we collect, use and share

The chart below summarizes how we collect, use and share Personal Information by reference to the statutory categories specified in the CCPA, and describes our practices during the 12 months preceding the effective date of this Privacy Policy. Categories in the chart refer to the categories described above in the general section of this Privacy Policy.

Statutory category of personal Information (PI)	PI we collect	Source of the PI	Purpose for collection	Categories of Third Parties to whom we “disclose” the PI for a business purpose	Categories of Third Parties to whom we “sell” the PI
Identifiers	·  Identity Information ·  Contact Information ·  Profile Information	·  You ·  Advertising Partners ·  Public Sources ·  Business partners ·  Our Clients	·  Service Delivery ·  Research & Development ·  Marketing ·  Compliance & Operations	·  Internal Third Parties ·  Advertising Partners ·  Third Party Service Providers ·  Administrative & Legal Third Parties ·  Business Transferees	·  None
Commercial Information	·  Identity Information ·  Contact Information ·  Transaction Information ·  Marketing and Communications Information	·  You ·  Our Clients ·  Advertising Partners ·  Third Party Service Providers	·  Service Delivery ·  Research & Development ·  Marketing ·  Compliance & Operations	·  Internal Third Parties ·  Third Party Service Providers ·  Administrative & Legal Third Parties ·  Business Transferees	·  None
Financial Information	·  Financial Information	·  You ·  Public sources ·  Business partners ·  Our Clients	·  Service Delivery ·  Research & Development ·  Marketing ·  Compliance & Operations	·  None	·  None
Online Identifiers	·  Technical Information ·  Usage Data ·  Identity Information	·  You ·  Our Clients ·  Automatic Collection	·  Service Delivery ·  Research & Development ·  Marketing ·  Compliance & Operations	·  Internal Third Parties ·  Third Party Service Providers ·  Professional Administrative & Legal Third Parties ·  Business Transferees	·  Advertising Partners (to facilitate online advertising)
Internet or Network Information	·  Technical Information ·  Usage Data	·  You ·  Our Clients ·  Automatic Collection	·  Service delivery ·  Research & development ·  Marketing ·  Compliance & Operations	·  Internal Third Parties ·  Third Party Service Providers ·  Administrative & Legal Third Parties ·  Business Transferees	·  Advertising partners (to facilitate online advertising)
Geolocation Data	·  Geolocation Data	·  Automatic Collection (when enabled by user)	·  Service delivery ·  Research & development ·  Marketing ·  Compliance & Operations	·  Internal Third Parties ·  Third Party Service Providers ·  Administrative & Legal Third Parties ·  Business Transferees	·  Advertising partners (to facilitate online advertising)
Inferences	May be derived from your: ·  Technical Information ·  Usage Data ·  Online Identifiers ·  Location Information and/or Geolocation Data ·  Profile Information	·  You ·  Automatic Collection	·  Service delivery ·  Research & development ·  Marketing ·  Compliance & Operations	·  Internal Third Parties ·  Third Party Service Providers ·  Administrative & Legal Third Parties ·  Business Transferees	·  Advertising Partners (to facilitate online advertising)
Protected Classification Characteristics	·  We do not intentionally collect this Information, but it may be inferred from or revealed in Identity Data or other Information we collect				·  None

XII. CONTACT INFORMATION
If you have any questions or concerns about our Privacy Policy or our Data collection or processing practices, or if you want to report any security violations to us, please contact us at the address or email address listed below.

PSafe Tecnologia Ltda.
Caixa Postal 10900
Avenida Nossa Senhora de Copacabana 540, Loja A
AC Copacabana
Copacabana, 22020-970
Rio De Janeiro, RJ, Brazil
Email: [email protected]

PSafe’s DPO is GEP Soluções em Compliance ([email protected]).