Privacy Policy

(updated February 05, 2021)

PSafe Tecnologia S.A., 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 using this browser extension (“plug-in”), you accept and agree to the practices described in this Privacy Policy and your continued use of this plug-in (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 PSafe’s Terms of Use and License Agreement, as shown on www.psafe.com and/or www.enterprise.psafe.com.

I. IMPORTANT INFORMATION

A. APPLICATION OF THIS PRIVACY POLICY
This Privacy Policy applies to your use of this plug-in. We use the Personal Information we monitor through the plug-in to alert the general user to internet content that reliable sources have identified as “fake news.” In addition, if the user is an authorized user of our dfndr enterprise SaaS service, we also use the Personal Information we monitor and collect to protect the user from potential malware and phishing threats.

B. PURPOSE OF THIS PRIVACY POLICY
This Privacy Policy aims to give you information on how PSafe uses (and, in the case of authorized dfndr enterprise users, collects) your Personal Information through your use of this plug-in.

C. CHILDREN
This plug-in is not designed for, or directed to, children under the age of 16 (18 in Brazil) and PSafe does not knowingly collect information of individuals under the age of 16 (18 in Brazil). If PSafe discovers that it has inadvertently collected Personal Information from anyone younger than the age of 16 (18 in Brazil), 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 (18 in Brazil), please do not install the plug-in, 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 (18 in Brazil), please contact us at privacy@psafe.com.

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 may collect, use, store and transfer different kinds of Personal Information about you that we have grouped together as follows:

General users of this plug-in

• Technical Information: websites/URLs visited are monitored by the plug-in and verified against reliable sources to provide alerts against potential “fake news”; however no such information is collected by or sent to PSafe’s servers.

Authorized dfndr enterprise users

• Technical Information includes browser package name and websites/URLs visited.
• 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 customer number / internal IDs, unique pseudonym, or user alias, 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 probable than not) that can be used to identify a particular person or device.
• Internet or Network Information includes browsing history (URLs), proxy, and information regarding a person’s interaction with an Internet website, application.

For authorized dfndr enterprise users, we also may 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. 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
As mentioned above, we do not collect information from general users of the plug-in. For authorized dfndr enterprise users, we use different methods to collect information from and about you including through:

• Automated technologies or interactions. As you use your browser where our plug-in has been enabled, we may automatically collect Technical Information and Internet or Network Information (per the user types above).
• Embedded Scripts. Embedded scripts are programming code designed to collect information about your interactions in the browser where you have enabled the plug-in, such as the links you click. The code is temporarily downloaded onto your Device from our web server or a third-party service provider.

IV. USE OF PERSONAL INFORMATION BY PSAFE
The plug-in does not collect Personal Information of general users; it only temporarily analyzes information (as described above) to provide alerts about potential “fake news.” For authorized dfndr enterprise users, we use the Personal Information we collect through the plug-in to protect the user from potential malware and phishing threats. If you are a user of another PSafe product or you want to know how we process and protect your personal data in general please refer to the Privacy Policy on our website (www.psafe.com).

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. We reserve the right to use Anonymous Data for any purpose and disclose Anonymous Data to third parties in our sole discretion.

A. 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.

V. HOW WE DISCLOSE PERSONAL INFORMATION
Again, for general users, the plug-in only locally monitors Technical Information (described above) and does not collect (i.e., transmit or save) Personal Information. The following sections apply to users who also are authorized dfndr enterprise users, or to the extent that a general user chooses to share Personal Information with us (for example, by giving Feedback as described above).

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 to us, 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 and operational 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.

B. EXTERNAL THIRD PARTIES

Authorized Licensees

PSafe may share security alerts (that may include your Personal Information), related to potential malware and phishing threats collected through the plug-in, with the authorized representative of the authorized licensee of the dfndr enterprise SaaS service who has enabled your use of the same.

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.

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.

VI. YOUR CHOICES REGARDING YOUR INFORMATION
YOU CAN STOP ALL COLLECTION OF INFORMATION BY THIS PLUG-IN BY UNINSTALLING IT.

Certain users may have additional rights under the privacy laws of their jurisdictions (such as, but not limited to, California’s CCPA and Brazil’s LGPD).

VII. 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.

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.

VIII. A NOTE TO USERS OUTSIDE OF THE UNITED STATES
If you are a non-U.S. user of the plug-in, you acknowledge and agree that your Personal Information may be processed for the purposes identified in the Privacy Policy. In addition, your Personal Information (if collected by the plug-in) 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.

IX. 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 S.A.
Caixa Postal 10900
Avenida Nossa Senhora de Copacabana 540, Loja A
AC Copacabana
Copacabana, 22020-970
Rio De Janeiro, RJ, Brazil
Email: privacy@psafe.com
PSafe’s DPO is Mônica Paes (dpo@psafe.com).