Privacy Policy

At MacPaw, We care about the privacy of Your data and are committed to protecting it. This Privacy Policy explains what information We collect about You and why, what We do with that information, and how We handle that information. We’ll also explain what choices You have with respect to the information.

Applicability Of This Privacy Policy

This Privacy Policy applies to CleanMyMac X application and CleanMyMac X for Business application (the “Product” or the “Products”), MacPaw.com (the “Site”) and all interactions (e.g., customer service inquiries, user conferences, etc.) You may have with MacPaw with regard to Your use of the Product(s) and/or Site. If You do not agree with the Privacy Policy, do not access or use the Product (s) and/or the Site. The data controller of Your personal information is MacPaw Way Ltd., registration number 428214 (hereinafter “We”, “Us”, “Our” or “MacPaw”).

MacPaw has contracts with all Data Processors that it uses in compliance with applicable data protection legislation, and ensures that all Data Processors are compliant with the applicable data protection legislation.

This Privacy Policy does not apply to third party services. Where third party services are used, and the third party is not a Data Processor, no Relevant Data (as defined below) is shared with them, or the Relevant Data has been anonymised such that the GDPR does not apply. Information collected by third parties is governed by their privacy practices and data transfer contractual commitments. To find more, please jump into section “Data Storage and Transfers” below.

In addition, a separate agreement governs delivery, access and use of the Product (s) (the “User Agreement”). User Agreement is the integral part of this Privacy Policy.

This Privacy Policy applies to Relevant Data received and processed only.

Definitions

Capitalised terms used in this Privacy Policy and not otherwise defined shall have the meanings provided below:

Data Processor means a natural or legal person, public authority, agency or other body which processes Personal Data on behalf of MacPaw.

Relevant Data means Personal Data and Special Categories of Data covered by this Privacy Policy and as defined in the applicable data protection legislation.

Personal Data - any information relating to an identified or identifiable natural person.

Special Categories of Data means Personal Data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data and data concerning health or a person’s sex life or sexual orientation. By default, the Special Categories of Data are not processed in any way by the Product or Site.

Processing/Processed - any operation on Personal Data, whether automated or not.

Other capitalised terms have the same meaning as in the applicable Terms of Service.

Information We Collect and Receive

We collect Information that, alone or in combination with other data, could be used to identify You (Personal Data). Some of the Information We collect is stored in a manner (using anonymisation instruments) that cannot be linked back to You (Non-Personal Data).

MacPaw may collect, generate and/or receive the following Information:

• Contact details, namely, email and name. This information might be needed to conclude an agreement with You, provide You with Our Services, updates and communicate with You.
• Location information. This is the geographic area where You use Your computer and mobile devices (as indicated by an Internet Protocol [IP] address or similar identifier) when interacting with Our Site and/or Product (s). This information might be necessary to determine Your general geographic location, applicable legislation and provide You with customised, localised and personalised content.
• Log data. As with most websites and technology services delivered over the Internet, Our servers automatically collect data when You access or use Our Site and/or Product (s) and record it in log files. This log data may include browser type and settings, the date and time of use, information about browser configuration, language preferences, and cookie data. This information is needed to ensure security of Our systems, prevent, detect and investigate potentially prohibited or illegal activities, including fraud, and to enforce Our Terms of Service.
• Product (s) and Site Usage Data. This is information about the Site and/or Product (s) You use and how You use them, in-app usage events and actions, used by Us to understand your behaviour, analyze and optimize it . We may also obtain data from Our third-party partners and service providers to analyze how users use Our Site and/or Product (s). For example, We will know how many users access a specific page on the Site and which links they clicked on. We use this aggregated information to better understand and optimize the Site and/or Product (s). Please note that when we process Product (s) and Site Usage Data for behavioral advertisement, to measure the effectiveness of advertisement campaigns, we rely on your consent. When we process Product (s) and Site Usage Data for fraud prevention, correcting errors and bug fixing, as well as technical improvements, we rely on Our legitimate interests. To find more, please refer to the section “Lawful Basis for Personal Data Processing” below.
• Device information. These are data from Your computer or mobile device, such as the type of hardware and software You are using (for example, Your operating system and browser type), as well as unique device identifiers for devices that are using MacPaw Product (s), ect (as defined below in this Policy). This is needed to provide You with the best experience, ensure compatibility and update Our Services.
• MacPaw Account ID. This is Your unique identifier, which helps you to access MacPaw Products through your account from different devices. identifying your purchased subscriptions and granting access to our Services. MacPaw Account ID helps us to manage your access and subscription (s), identify fraudulent activity and fix the errors (if any). Please, take a note that we need your MacPaw Account ID to provide you with our Services. Also, we may use Your MacPaw Account ID to analyze the use of the Site and Product.

The detailed information on the basis for collection, storage and processing of each type of personal information is provided in Lawful Basis for Personal Data Processing section of Privacy Policy.

Information collected from CleanMyMac X for Business users

In case You are a user of CleanMyMac X for Business - You are automatically a user of CleanMyMac X. Therefore, MacPaw can collect, process and store Your data collected in accordance with and under this Policy for functionality of both Products to perform Our contract with You and for Our legitimate business interests, in operating Our Site, both Products and business.
In case you are a user only of CleanMyMac X - your data will be used only for the purposes of CleanMyMac X functionality.

Please, take a note that by using CleanMyMac X for Business we collect more data as will be listed below. The aim of collecting these data is the necessity to provide you with services of Product under the contract with you. Take note, that Your data can be accessed by representatives of the entity (employer, customer, other third party) providing You with a link to CleanMyMac X for Business (“Admin”). These data include:

• information about detected malwares
• device username
• device profile name
• device UUID
• device model
• device serial number
• contact details (e-mail and name)
• log data
• location information
• information about security setting on Your device(s) (such as system integrity protection status, FileVault status, Screen Lock Password Immediate status, Password Last Set Time, security policies);
• other information about your device (such as battery information, storage capacity, CPU, device profile information etc.).

By using the link to CleanMyMac X for Business provided by the entity and further using the CleanMyMac X for Business application You acknowledge and agree that You give Your explicit consent that such an entity will have access to Your data. Your relationship with such an entity and processing of Your data by it, does not fall within the scope of this Privacy Policy and shall be governed by You and such an entity separately.

Cookies

MacPaw uses cookies and similar technologies in Our Site and Services that help Us to provide, analyze, understand and enhance the use of Our Services, enforce Our Terms of Service, prevent fraud, improve Site performance, monitor visitor traffic and actions on Our Site, deliver and tailor Our marketing or advertising, and understand interactions with Our emails, marketing, and online ads on third party sites. The Site and Services may also include cookies and similar tracking technologies of third parties, which may collect information about You via the Site and Services and across other websites and online services. For more details about how We use these technologies, please see Our Cookie Policy.

How We Receive Your Data

We receive Your Data from You when:

• You interact with Our Site;
• You download the Product (s);
• You use the Product (s);
• You purchase a subscription to the Product (s);
• You contact Us;
• You provided Your personal details to Us in another way.

Third Party Data

MacPaw may receive data about Site visitors, marketing campaigns and other matters related to Our business from affiliates and subsidiaries, Our partners or others that We use to make Our own information better or more useful. This data may be combined with other Information We collect and might include aggregate level data, such as which IP addresses correspond to zip codes or countries. Or it might be more specific: for example, how well an online marketing or email campaign performed. Below you will find the list of Third Parties, our contractual commitments and legal basis we rely on .

Additional Information Provided to MacPaw

We also receive Personal Data when submitted to Our Site or if You participate in a focus group, contest, activity or event, request support, interact with Our social media accounts or otherwise communicate with MacPaw.

Payment Information

Our payment process is conducted by a third party payment service providers, namely:

PADDLE.COM MARKET LIMITED

Address: Judd House 18-29 Mora Street, GB/London EC1V8BT; or

Bright Market, LLC d/b/a FastSpring

Address: 801 Garden Street Suite 201, US/SANTS BARBARA 93101

and/or their affiliates (hereinafter - “Payment Service Providers”). Payment Service Providers are the merchants of record for all Our orders. Payment Service Providers provide all customer service inquiries and handle returns.

Payments information (this includes name, location, contact details, and billing information) provided by You may be stored and processed by Payment Service Providers. Please note that We do not retain any payment information provided by You. All such information is provided directly to the Payment Service Providers. All such information is subject to the privacy policies of Payment Service Providers which may be viewed at their websites: https://www.paddle.com/legal/privacy or https://fastspring.com/privacy/.

Payment Service Providers and Us have a legitimate interest to use provided data for product fulfillment, order processing, fraud prevention, and product support.

Technical Information received through the "Malware removal" module

Our “Malware Removal” module performs malware scans to identify malware, detect suspicious behavior of applications and improve Our detection techniques. For this purpose, We may collect Your technical data (files that generally do not contain Personal Data, like binary files, executable files, system files etc.) identified by the Product (s) as potentially infected, together with the information about the nature of identified threats. These files to be evaluated only for any threat or malware that may be present. We apply appropriate safeguards to retain and treat these files separately than any other data that may be classified as Personal Data, so it hinders any identification of users. We collect no more information than is required in order to provide full functionality of the said module. These files are being stored for a limited period, depending on its usefulness for the current information security needs.

The legal basis for processing these data is the performance of the contract which You are the party to.

No Special Categories of Personal Data

We do not collect and/or process any “Special Categories of Personal Data” 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 offenses.

Collection Information from Children

MacPaw does not knowingly collect personal information from children under the age of 13. If We determine We have collected personal information from a child younger than 13 years of age, We will take reasonable measures to remove that information from Our systems. If You are under the age of 13, please do not submit any personal information through the Site and/or Product (s). We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce this Policy by instructing their children never to provide personal information through the Site and/or Product (s) without their permission.

Using Your Information by MacPaw

We use, process, and store Your information as necessary to perform Our contract with You and for Our legitimate business interests, in operating Our Site, Product (s) and business including:

• to provide you with services of Product (s) due to their functionality;
• to help Us administer Our Site and/or Product (s), authenticate users for security and license managerial purposes, provide personalised user features and access, process transactions, conduct research, develop new features, and improve the features, algorithms, and usability of Our Site and/or Product (s);
• as required by applicable law, legal process or regulation;
• to calculate aggregate statistics on the number of unique devices using Our Site and/or Product (s);
• to provide You with first-class customer support services;
• to send emails and other communications. We may send You service, technical and other administrative emails, messages and other types of communications. We may also contact You to inform You about changes in Our Product (s), Our Product (s) offerings, and important Product(s)-related notices, such as security and fraud notices. These communications are considered part of the Product(s) and You may not opt out of them. In addition, We sometimes send emails about new product features, promotional communications or other news about MacPaw. We will only send You marketing information if You consent to Us;
• for billing, account management and other administrative matters. MacPaw may need to contact You for invoicing, account management and similar reasons and We use account data to administer accounts and keep track of billing and payments.
• to investigate and help prevent security issues, fraud and abuse.
• for functioning different features, like, for example, updater module in case with data on apps installed on the system.

If information is aggregated or anonymised so it is no longer reasonably associated with an identified or identifiable natural person, MacPaw may use it for statistical and other business purposes. For example, we collect anonymous information about your use of our Product(s), your interactions with us, as well as information regarding Your devices for analytics and optimization purposes.

Apart from that, upon Your consent, we may collect personalised information about your use of our Product(s), your interactions with us, as well as information regarding Your devices. This information may be used for personalization purposes, as well as for sharing personalized usage reports with You.

How We Share And Disclose Information

We only disclose Personal Data to third parties when:

• We share Your information among the MacPaw corporate group as needed for: data processing and storage; providing You with access to Our Services; providing customer support; making decisions about service improvements; content development; and for other purposes described in this Privacy Policy.

To find more about transfer mechanisms we rely on for intra-group Personal Data transfers, please jump below in section “Data Storage and Transfers”.

• We use service providers who assist Us in meeting business operations needs, including hosting, delivering, and improving Our Product(s). We also use service providers for specific services and functions, including email communication, customer support services, and analytics. These service providers may only access, process, or store Personal Data pursuant to Our instructions and to perform their duties to Us.

To find more about transfer mechanisms we rely on while transmitting your Personal Data to third parties, please jump below in section “Data Storage and Transfers”.

• We have Your explicit consent to share Your Personal Data (if required).
• We believe it is necessary to investigate potential violations of the Terms of Service, to enforce those Terms of Service, or where We believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, or potential threats against persons, property, or the systems on which We operate Our Site and/or Product(s).
• We determine that the access, preservation, or disclosure of Your Personal Data is required by law to protect the rights, property, or personal safety of MacPaw and users of Our Site and/or Product(s), or to respond to lawful requests by public authorities, including national security or law enforcement requests.
• We need to do so in connection with a merger, acquisition, bankruptcy, reorganization, sale of some or all of Our assets or stock, public offering of securities, or steps in consideration of such activities (e.g., due diligence). In these cases some or all of Your Personal Data may be shared with or transferred to another entity, subject to this Privacy Policy.
• We may disclose Non-Personal Data publicly and to third parties – for example, in public reports about word usage, to partners under agreement with Us, or as part of progress reports We may provide to users.

MacPaw does not share Your Personal Data with third parties for the purpose of enabling them to deliver their advertisements to You.

MacPaw does not sell or rent Your Personal Data.

Whenever in the course of sharing information We transfer Personal Data to countries outside of the European Economic Area and other regions with comprehensive data protection laws, We will ensure that the information is transferred in accordance with this Privacy Policy and as permitted by the applicable laws on data protection.

Third Parties’ Applications and Product

Some third-party applications and services that work with Us may ask for permission to access Your information. Those applications will provide You with notice and request Your consent in order to obtain such access or information. Please consider Your selection of such applications and services, and Your permissions, carefully.

Some third parties’ embedded content or plugins on Our Site and/or Product(s), such as Facebook “Like” buttons, may allow their operators to learn that You have visited the Site, and they may combine this knowledge with other data they have collected about Your visits to other websites or online services that can identify You.

Data collected by third parties through these apps and plugins is subject to each parties’ own policies. We encourage You to read those policies and understand how other companies use Your data.

E-mailing by MacPaw

From time to time, We may want to contact You with information about product announcements, software updates, and special offers. We also may want to contact You with information about products and services from Our business partners.

We only send marketing communications to users with Your prior consent.

All MacPaw account holders will continue to receive transactional messages related to Our Product(s), even if You unsubscribe from promotional emails. Transactional messages shall mean important communication with you that, for example, may concern Software setup, payment confirmation, any updates to Our Products and Licenses. The legal basis for sending you transactional messages is the performance of the contract, namely User Agreement.

Customer Surveys and Conducting Analytics Campaigns

When you use Our Services and products, we can also use your e-mail address to send you customer and satisfaction surveys. We will use the results of the surveys to improve our Products and Services and deliver You the customized content. The legal basis for this is your consent.

In some cases we may conduct analytical campaigns with the observed data. We may receive your Personal Data you directly provide Us when purchasing our Products or Services, or your Cookies data. This data helps us to analyse your customer experience and constantly improve our Products and Services. We justify such processing by reliance on legitimate interests.

Google Services. We use Google Analytics and Google Ads, a web analysis service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (“Google”). Google Analytics and Google Ads also uses cookies, i.e. text files that are stored on your computer and that enable your use of the website to be analyzed. The information generated by the cookie about your use of this Site is usually transmitted to a Google server in the USA and stored there. On our behalf, Google will use your Personal Data to evaluate your use of the Site, to compile reports on Site activity and to provide us, as website operator with other services related to website activity and internet usage. Please note, Google Services do not store and process your IP address. To find out more, please visit Data privacy and security page of Google Analytics service.

Consent and objection: The Google Analytics cookies are stored and thus your usage behavior is only tracked if you have previously consented to this tracking. You can revoke this consent at any time with future effect. Users can find details about the cookies used within our online offering, in particular information about the type and functionality of the cookies, the storage period and the respective provider, in the Cookie Consent Management Tool we use. You can also prevent the storage of cookies by setting your browser software accordingly. In addition, you can prevent Google from collecting the data generated by the cookies and relating to your use of the website and from processing this data by Google by downloading the browser plug-in available under the Google Add Extensions. The processing of your data using Google Analytics takes place in conjunction with the consent you have given. Your data generated by Google Analytics will be deleted after 24 months at the latest or as defined in Cookie Consent Management Tool.

Online marketing/Facebook pixel: We process Personal Data (in particular usage data and technical data) for the purposes of online marketing via the Facebook social network, which includes in particular the marketing of advertising space based on the potential interests of users and the measurement of their effectiveness. For this purpose, user profiles are created and stored in a file, with the help of which the user information relevant to the display of the advertising content is recorded. This information includes, for example, the content viewed, websites visited, online networks used and technical information such as the browser used, the computer system used and information about times of use. Please note, Facebook does not store and process your IP address.

The information stored in the profiles is usually stored in cookies or using similar technical means for a period of 2 years, unless other term is defined in the banner of our Cookie Consent Management Tool. These cookies can also be read on other websites that use the same online marketing process and analyzed for the purpose of displaying advertising content, as well as supplemented with further data and stored on the server of the online marketing process provider. In exceptional cases, clear data can also be assigned to the profiles. This is the case if the users are members of the Facebook social network and Facebook connects the users' profiles with the aforementioned information. However, the user can make additional agreements with Facebook, for example by giving consent during registration. We generally only receive access to aggregated information about the success of our advertisements.

With the help of the Facebook pixel we are able to determine the visitors to our online offering as a target group for the display of advertisements (so-called “Facebook Ads”). Accordingly, we use the Facebook pixel to display the Facebook ads we place only to those users on Facebook and, if necessary, within the services of partners cooperating with Facebook who have also shown an interest in our online offering or who have certain characteristics (e.g Interest in certain content or products) that we transmit to Facebook (so-called "Custom Audiences"). At the same time, we want to ensure that our Facebook ads correspond to the potential interest of the users and do not appear annoying. Based on the Facebook pixel Finally, it allows us to track the effectiveness of Facebook ads for statistical purposes. This allows us to see whether users were redirected to our website after clicking on a Facebook ad.

Furthermore, when using the Facebook pixel, we use the additional function “extended comparison”. Here, data such as email addresses or Facebook IDs of the users are sent to Facebook to form target groups (“Custom Audiences” or “Look Alike Audiences”) transmitted (encrypted). Further information on “extended comparison” can be found in Custom Audience Privacy Information.

We also use the “Custom Audiences from File” procedure. In this case, the email addresses of the newsletter recipients are uploaded to Facebook. The upload process is encrypted. The upload is used solely to determine recipients of our Facebook ads. We want to ensure that the ads are only shown to users who are interested in our information and services.

The service provider of the Facebook Pixel is: Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland, parent company: Facebook, 1 Hacker Way, Menlo Park, CA 94025, USA; Website: https://www.facebook.com; Data protection declaration by following this link.

The processing of your data in connection with the use of the Facebook Pixel takes place on the legal basis of Article 6 Paragraph 1 Sentence 1 Letter a) GDPR in conjunction with the consent you have given, which you can revoke at any time with effect for can be revoked in the future, in particular for expanded data comparison and target group formation via data upload. You can also object to the collection by the Facebook pixel and the use of your data to display Facebook ads at any time. To set which types of advertisements are shown to you within Facebook, you can visit the page set up by Facebook and follow the instructions there on the settings for usage-based advertising: https://www.facebook.com/settings?tab=ads . The settings are platform-independent, meaning they are applied to all devices, such as desktop computers or mobile devices. You also have the option of switching off cookies in your browser settings. However, this may limit the functions of our online offering. For more information, see the section on the use of cookies above. We are affiliated with Facebook Ireland Ltd. We are jointly responsible for the collection and transmission of the data that Facebook collects or transmits using the Facebook pixel and comparable functions that are carried out within our online offering for the following purposes: a) the creation of individualized or suitable advertisements, as well as for their optimization; b) the delivery of commercial and transaction-related messages (e.g. contacting users via Facebook Messenger); c) improving ads delivery and personalization of features and content (e.g. improving detection of which content or advertising information is likely to match users' interests). However, the processing that occurs after collection and transmission is the sole responsibility of Facebook.

We have concluded a special agreement with Facebook (“Controller Addendum”), which regulates in particular which security measures Facebook must observe, including those listed Facebook Data Security Terms, and in which Facebook has agreed to fulfill the rights of those affected (i.e. users can, for example, send information or deletion requests directly to Facebook).

The creation of reports and analyzes in aggregated and anonymized form does not take place within the framework of joint responsibility, but rather on the basis of an order processing contract and therefore under our responsibility (data processing conditions: https://www.facebook.com/legal/terms/dataprocessing). When transferring personal data outside EU and EEA, Facebook relies on EU-U.S. Data Privacy Framework, and data transfer supplement Meta European Data Transfer Addendum.The Facebook EU-U.S. DPF, UK Extension to the EU-U.S. DPF, and Swiss-U.S. DPF Certification can be found here.

Your rights (in particular to information, deletion, objection and complaint to the responsible supervisory authority) are not restricted by the agreements with Facebook.

Data storage, transfer, retention, and deletion

Data Storage and Transfers

MacPaw is the global product company and Our offices are located in the EU/EEA regions and USA. Information submitted to MacPaw will be processed and stored in different jurisdictions to ensure an effective and sufficient online offering of Our products and services. As part of Our business and collaborative efforts, we may transmit your data to Our teams within group departments of software development, IT services, and customer support (i.e., intra-group data sharing).

For example, (1) when You use the Product (s) on Your computing device, user content You save may be stored locally on that device and synced with Our servers, (2) when You post or transfer any Personal Data to or through Our Site and/or Product (s), and (3) when Your Personal data is processed by Our authorized third parties, on Our behalf.

If We commission Out authorised third parties with the collection, processing, and use of Personal Data within the scope of commissioned processing in accordance with Art. 28 GDPR, this will also take place exclusively in compliance with the statutory provisions on data protection, in particular, we have legally established privacy and confidentiality commitments with our authorised third parties concerning collection, usage and storage of Your Personal Data.

When we transmit your personal data beyond EU/EEA regions, we rely on Standard Contractual Clauses as approved by the European Commission (EU-US DPF) and confidentiality obligations, ensuring your data is handled with care and responsibility. To find more, please follow EU-U.S. DPF, UK Extension to the EU-U.S. DPF, and Swiss-U.S. DPF Certification that can be found here.

When this is permitted by law and is necessary for the purposes outlined herein, we share your data with the following recipients outside the EU and EEA:

· Facebook Ireland Ltd. – Social media provider. Your data is protected by the service provider entering into the Standard Contractual Clauses as approved by the European Commission (EU-US DPF). EU-U.S. DPF, UK Extension to the EU-U.S. DPF, and Swiss-U.S. DPF Certification can be found here. EU-U.S. DPF, UK Extension to the EU-U.S. DPF, and Swiss-U.S. DPF Certification can be found here.

· Google LLC (USA) – Communication service provider. Your data is protected by the service provider entering into the Standard Contractual Clauses as approved by the European Commission (EU-US DPF).

· Google LLC (USA), Google BigQuery – Marketing data handling provider. Your data is protected by the service provider entering into the Standard Contractual Clauses as approved by the European Commission (EU-US DPF).

· OWOX, Inc. (USA) – Marketing data integrations partner. Your data is protected by the service provider entering into the Standard Contractual Clauses as approved by the European Commission (EU-US DPF). EU-U.S. DPF, UK Extension to the EU-U.S. DPF, and Swiss-U.S. DPF Certification can be found here. EU-U.S. DPF, UK Extension to the EU-U.S. DPF, and Swiss-U.S. DPF Certification can be found here.

Functional Software, Inc. d/b/a Sentry - SaaS partner in development, maintenance and errors fixing. Services are provided by Functional Software, Inc. d/b/a Sentry, 45 Fremont Street, 8th Floor, San Francisco, CA 94105. Your data is protected by the service provider entering into the Standard Contractual Clauses as approved by the European Commission (EU-US DPF). EU-U.S. DPF, UK Extension to the EU-U.S. DPF, and Swiss-U.S. DPF Certification can be found here. EU-U.S. DPF, UK Extension to the EU-U.S. DPF, and Swiss-U.S. DPF Certification can be found here.

· Microsoft Corporation - Azure Hosted Cloud Server. Services are provided by One Microsoft Way, Redmond, Washington, 98052, United States. Your data is protected by the service provider entering into the Standard Contractual Clauses as approved by the European Commission (EU-US DPF). EU-U.S. DPF, UK Extension to the EU-U.S. DPF, and Swiss-U.S. DPF Certification can be found here. EU-U.S. DPF, UK Extension to the EU-U.S. DPF, and Swiss-U.S. DPF Certification can be found here.

We take Your security seriously and take reasonable steps to protect and secure Your Personal Data when transmitting it. In addition to contractual and organisational measures, we have implemented strong technical security measures To find more, please jump into section “Safeguards” below.

Duration of Information Storage

As the general rule, We retain Your Personal Data while You are a customer, no longer than is necessary for the purposes for which We process Your personal data (but in any way no longer than 7 years from the date of termination of your access to the Product.

We will delete Your Personal Data immediately upon Your written request when we rely on Your consent as a legal basis for processing. You can remove Your Personal Data from MacPaw at any time by emailing Us with the respective request: [email protected]. However, We may keep some of Your Personal Data for as long as reasonably necessary for Our legitimate business interests, including fraud detection and prevention and to comply with Our legal obligations including tax, legal reporting, and auditing obligations.

Safeguards

We take Your security seriously and take reasonable steps to protect and secure Your Personal Data. Following provisions of Art. 32 GDPR and taking into account state of the art, the implementation costs and the type, scope, circumstances, and purposes of the processing as well as the different probability of occurrence and severity of the risk for the rights and freedoms of natural persons, we have implemented adequate technical and organizational measures to protect Your Personal data against unauthorized, accidental, or unlawful destruction, loss, alteration, misuse, disclosure, access, and other unlawful forms of processing.

We limit access to Your Personal Data to a genuine business need-to-know basis. Lokalise personnel accessing your Personal Data act under our internal data protection rules and policies. Third parties will only process Your Personal Data in an authorized manner, following our instructions and subject to a confidentiality duty.

All staff and officers who handle Relevant Data are aware of this Policy and have been given training in how to correctly collect, process, store and delete Relevant Data. The MacPaw holds a log of when staff training was undertaken and updates it on an annual basis.

Non-sensitive details (Your email address etc.) are sent normally over the Internet, and this can never be guaranteed to be 100% secure. As a result, while We strive to protect Your Personal Data, We cannot guarantee the security of any Personal Data You transmit to Us, and You do so at Your own risk. Once We receive Your Personal Data, We make Our best effort to ensure its security on Our systems.

We use industry-standard encryption to protect Your Personal Data in transit. This is commonly referred to as transport layer security (“TLS”) or secure socket layer (“SSL”) technology. We also hash your Device information in order to better protect Your Personal Data.

Once We receive Your Personal Data, We protect it on Our servers using a combination of technical, physical, and logical security safeguards. The security of the Personal Data stored locally in any of Our Products installed on Your computing device requires that You make use of the security features of Your device. We recommend that You take the appropriate steps to secure all computing devices that You use in connection with Our Site and Product(s).

Data Breaches

We have developed a strong Incident Response Plan that, inter alia, in case of Data Breach will take all reasonable steps to investigate, contain and report a Data Breach to You.

If the data breach is likely to result in a high risk to Your rights and freedoms, we will communicate the personal data breach to You without undue delay, via e-mail and instruct You on mitigation measures. In case our communication channel with You will be compromised by the incident, we will notify by using media channels and this Site in particular.

Breaches of this Privacy Policy by staff, contractors, officers of the MacPaw will be dealt with under the MacPaw’s internal grievance and disciplinary policy and may lead to a disciplinary sanction.

Lawful Basis for Personal Data Processing

MacPaw uses, processes, and stores Personal Data, as necessary to perform Our contract with You, and based on Our legitimate interests in order to provide the Services in connection with the Product (s) and maintaining Products’ functionality, namely:

• Contact details - to fulfill the agreement concluded with You, provide You with Our Services and communicate with You;
• Location information - to properly perform the agreement with You, determine Your general geographic location, applicable data protection legislation and provide You with customised, localised and personalised content;
• Product (s) and Site Usage Data - to better understand, analyze and optimize the functionality of the Site and the Product(s);
• Log data (crash data and other diagnostic reports; cleanup logs: files path and size, system libraries versions, scan/removal duration, device information) - for identifying and fixing defects in Product's functionality. Logs and entire reports are important to analyze user problems, application misfunctions and crashes. Log data is mandatory and is frequently the main source, which helps to understand and resolve application issues.
• Device information: Operating System (OS) running on Your device, Your device username, Your device profile name; Your device UUID; Your device model; Your device serial number; Internet Protocol (IP) address, access times, browser type, and language, OS localization, CMM bundle IDs, CMM version, screen resolution, cid, battery info, RAM usage info, drive info, processor info, GPU info, disk info (type, total, free, backups), files metadata, applications preferences data, installed applications, network names and preferences, computer uptime in hours, malware (if any) - to identify and localize user issues (bugs) and to understand and localize user problems, for the Product (s) correct scanning and cleaning logic, actually, Product (s) functioning.
• Security setting on device information: system integrity protection status; FileVault status; screen lock password immediate status; password last set time - to identify the security level of the user’s device and ensure Product (s) functioning.
• MacPaw Account ID - for the performance of a contract with You and provide you with a functionality of the Product (s) and Site under the specific subscription purchased by you; to manage your access (including access from different devices); to track errors connected with activation of access to the Product(s); to identify fraudulent activity in the Product(s); and fix the errors (if any).
• We are collecting Your data when You’re contacting Our customer support team via call, email or another communication tool. The purpose of collecting is for helping You to solve any issue You have with Our Services. The legal basis of collecting is fulfillment of Our contractual or pre-contractual obligations to You. Additionally, We may record the calls. The purpose of call recording is (1) quality control of Our customer support services and personnel training; the legal basis of call recording is Our legitimate interests in retaining You as a customer and providing You with first-class customer support services; and (2) for the purposes of establishing, exercising, or defending against legal claims.

We rely on Your consent to process Personal Data:

• to send promotional emails,
• to place cookies on Your devices,
• for sending personalised usage reports, and
• for collecting the Personal Data, processed by mobile applications installed on the system.

In some cases, MacPaw may process Personal Data pursuant to legal obligation or to protect Your vital interests or those of another person.

Your Rights

You have the following rights in respect to Your personal information, including the right to access, correct, or delete Personal Data We process through Your use of the Site and/or Product(s). You can:

* Have Your Personal Data corrected or deleted. You may ask Us to correct information You think is inaccurate or completely delete all information that We hold about You by emailing: [email protected]

• Access Your Personal Data report by submitting a request at [email protected]. This report will include the Personal Data We have about You, provided to You in a structured, commonly used, and portable format.
• Object to Us processing Your Personal Data. It is Your right to lodge an objection to the processing of Your Personal Data by emailing: [email protected] if You feel the “ground relating to Your particular situation” applies. The only reasons We will be able to deny Your request is if We can show compelling legitimate grounds for the processing, which override Your interest, rights and freedoms, or the processing is for the establishment, exercise or defence of a legal claims.
• Withdraw consent on marketing emails, including when We use Your Personal Data to send You marketing emails. We only send marketing communications to You with Your prior consent, and You may withdraw Your consent at any time by clicking the “unsubscribe” link found within MacPaw emails and changing Your contact preferences. Please note You will continue to receive transactional messages related to Our Product(s), even if You unsubscribe from marketing emails.
• Withdraw consent. This right only exists where We are relying on consent as a legal basis to process Personal Data about You (“Consent Withdrawal”).
• Without prejudice to any other administrative or judicial remedy, You have the right to appeal to a supervisory authority if You consider that the processing of Personal Data relating to You is in breach of the applicable laws and regulations. If You’re based in the European Economic Area (EEA) and think that We haven’t complied with data protection laws, You have a right to lodge a complaint with Your local supervisory authority. You can find the list of supervisory authorities via this link.
• Request to know more details about the categories or specific pieces of Personal Data We collect (including how We use and disclose this Personal Data), to delete their Personal Data, to opt out of any “sales” that may be occurring, and to not be discriminated against for exercising these rights.

You may have other rights as may be provided by the applicable legislation.

Typically, You will not have to pay a fee to access Personal Data about You (or to exercise any of the other rights outlined above). However, except in relation to Consent Withdrawal, We may charge a reasonable fee if Your request is clearly unfounded, repetitive, or excessive, or, We may refuse to comply with Your request in these circumstances.

We may need to request specific information from You to help Us confirm Your identity and ensure Your right to access Personal Data about You (or to exercise any of Your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact You to ask You for further information in relation to Your request to speed up Our response.

We try to respond to all legitimate requests within one (1) month (i.e. 30 calendar days). Occasionally it may take Us longer than a month if Your request is particularly complex or You have made a number of requests. In this case, We will notify You and keep You updated.

California privacy rights

This section provides details about additional rights that are available to California consumers under the California Consumer Privacy Act (“CCPA”) and California’s Shine the Light law. Therefore, this section applies only to residents of California, United States.

For more details about the personal information we have collected and the categories of sources, please see sections “Information we collect and receive” and “How we receive your data” above. We collect this information for purposes described in section “Using your information by MacPaw” of this Privacy Policy. We may also share your information with certain categories of third parties as indicated in section “How we share and disclose information”.

a. CCPA (CPRA)

In addition to the rights listed above, CCPA provides you with the following rights:

1) Right to know what personal information is sold or shared and to whom. Under that title, you have the right to request that we disclose to you:

• The categories of personal information that we collected about you.
• The categories of personal information that we sold or shared about you and the categories of third parties to whom the personal information was sold or shared, by category or categories of personal information for each category of third parties to whom the personal information was sold or shared.
• The categories of personal information that we disclosed about you for a business purpose and the categories of persons to whom it was disclosed for a business purpose.

You may request such information by contacting us by e-mailing to [email protected]. Please reference California Privacy Rights in your subject line.

2) The Right to Opt Out of Sale or Sharing and limit Use of Personal Information. We may share certain information about you with our partners for purposes of targeted advertising or data analytics, which could in certain circumstances be characterized as “selling,” “sharing,” or “targeted advertising” under California laws. You have the right to opt-out of such sale/sharing of your personal information by contacting us via [email protected].

We will also strive to recognize and process your opt-out preference signal as soon as possible after receiving it.

3) The right not to be discriminated against. Under this title, you have a right not to be discriminated against for exercising any of your rights under the California Privacy Rights Act (CPRA).

b. Access rights under California’s Shine the Light

California also provides its residents with additional access rights. Under Shine the Light law, the residents may ask companies once a year what personal information they share with third parties for those third parties' direct marketing purposes. Learn more about what is considered to be personal information under the statute.

To obtain this information from us, please send an email message to [email protected], which includes “Request for California Shine the Light Privacy Information” on the subject line and your state of residence and email address in the body of your message. Please be aware that not all information sharing is covered by the “Shine the Light” requirements and only information on covered sharing will be included in our response.

Data Protection Officer

To communicate with Our Data Protection Officer, please use our dedicated email channel [email protected].

Changes to Our Privacy Policy

We may need to update this Privacy Policy to keep pace with changes in Our Site, Product(s), and Services, Our business, and laws applicable to Us and You. We will, however, always maintain Our commitment to respect Your privacy. We will notify You of any material changes that impact Your rights under this Privacy Policy by email (to Your most recently provided email address) or post any other revisions to this Privacy Policy, along with their effective date, in an easy-to-find area of the Site, so We recommend that You periodically check back here to stay informed of any changes. Please note that Your continued use of MacPaw after any change means that You agree with, and consent to be bound by, the new Policy. If You disagree with any changes in this Privacy Policy and do not wish Your information to be subject to it, You will need to stop using the Site and/or Product(s).

Contact Us

You may contact Us with any questions relating to this Privacy Policy by e-mailing to our customer support: [email protected], or to communicate with Our Data Protection Officer, please use our dedicated email channel [email protected].