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Privacy Policy

Last updated April 25, 2024

1. ABOUT OUR PRIVACY POLICY

ReputationDefender, part of Gen Digital Inc. and NortonLifeLock Ireland Limited (“we”, “us”, or the “Company”), is committed to protecting the privacy of individuals who visit the Company’s Website (“Visitors”) and of those individuals and businesses who purchase or use ReputationDefender products and services (“Customers”).

The Company has created this privacy statement (“Privacy Policy”) to describe and demonstrate our firm commitment to protect your privacy when you visit and use the Company’s websites and associated sub-domains (the “Site) and use our goods and services (collectively, the “Services”).

This Privacy Policy describes how the Company collects, uses, shares, and secures the personal information you provide. It also describes your choices and rights regarding the use, access, correction and other processing of your personal information.

If you have any questions regarding this Privacy Policy, please contact us at info@reputationdefender.com.

If you are in the European Economic Area, and unless stipulated otherwise contractually, the Controller of your personal data is:

NortonLifeLock Ireland Limited
Ballycoolin Business Park
Blanchardstown
Dublin 15
Ireland D15E86

2. THE INFORMATION WE COLLECT

  1. In some areas of the Site (such as when you set up an account or provide information for the Company to contact you or when you ask for additional information) and in connection with our services, we may give you an opportunity to provide to us Personal Information, including your name, address, email address, telephone number, username[s], credit card number, billing information, social handles and other information which, either alone or in combination, can be used to identify you (“Personal Information”).
  2. To effectively deliver our services and products, we may provide the opportunity to additionally share descriptive, behavioral, preferential, and/or lifestyle information about yourself, but it is solely up to you whether you decide to give us such information.
  3. We may collect your Personal Information from third-party sources and platforms (such as online review sites, social media, or other sites on the Internet), if you request that we do so by signing up for one of our Services that involves collecting, analyzing, or tracking your Personal Information.
  4. When you browse our websites and Services, we automatically collect internet or other electronic network activity information, commercial information, and inferences drawn from personal information about the individual web pages or products that you view, the purchases you make, what websites or search terms referred you to our Services, the dates and times of your visits, and other information about how you interact with our Services. When you browse our websites and services, we may collect personal data using cookies and similar technologies (e.g., web beacons). (See “Cookies and Tracking Technologies”  below.)
  5. Here is how long we retain your information:
    1. For your account – We will retain your information for at least as long as your account is active, or otherwise as needed to provide you services. If you wish to cancel your account or request that we no longer use your information to provide you with our services or request that we no longer maintain your information, please contact us at info@reputationdefender.com. We will respond to your request within 30 days. We will automatically delete your personal data seven (7) years after termination of your contract with us.
    2. Retention in general – We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, protect our or other’s legitimate interests, and enforce our agreements. When determining the specific retention period, we take into account various criteria, such as the type of service provided to you, the nature of our relationship with you, and mandatory retention periods provided by law and the relevant statutes of limitations.

3. OUR USE AND DISCLOSURE OF INFORMATION

We may use your Personal Information for various purposes. Depending on the type of information we have collected from and about you and the specific Services you use, we will process your personal information in order to:

  1. Respond to your requests for Services or information;
  2. Provide you with updates and information about our Services;
  3. Verify your identity and prevent fraud;
  4. Facilitate your payments (we would like to note that such payments will be processed by our third-party payment processor, not by us);
  5. Help us better understand your interests and needs, in order to improve the Services;
  6. Engage in analysis, research, and reporting regarding the use of our Services or business operations; wherever possible, we only use aggregated, de-identified or anonymized data for this purpose;
  7. Contact you regarding our products, services, surveys or promotions, or products, services, surveys or promotions of companies we partnered with;
  8. Tailor the content and information that we may send, display or market to you, or to deliver content to you;
  9. Provide, manage, and improve the Services and test and create new products, features, and services;
  10. Understand and resolve any technical and security issues reported on our Sites;
  11. Comply with the law and protect the safety, rights, property, or security of Company, the Services, and the general public;
  12. Enforce any legal terms that govern your relationship with us or your use of the Services;
  13. For other purposes compatible with the list above, if that is allowed by applicable laws.

Our primary source for obtaining Personal Information is always going to be you. We may combine this Personal Information (including automatically generated information) with information that we obtain about you from third parties. In any event, we will always use any of your Personal Information (including the “combined” information) in accordance with this Privacy Policy.

4. HOW WE DISCLOSE OR SHARE YOUR INFORMATION

  1. We are a global business and so, it is possible that more than one member of our corporate group is involved in processing of Personal Information. We usually share your information with our parent, subsidiaries, and joint ventures to help coordinate the services we provide to you, enforce our terms and conditions, and promote trust and safety.
  2. We share information with service providers under contract who help with our business operations, such as payment and order processing, fraud investigation, bill collection, hosting, data management and enhancement, marketing, advertising, public relations, security and information management, and analytics. If content generation is included in your services, we may share information with service providers under contract to create, edit, and/or publish such content.
  3. We disclose information that we, in good faith, believe is appropriate to cooperate in investigations of fraud or other illegal activity, to conduct investigations of violations of our Terms of Use, and/or to protect our rights and protect your safety and the safety of others.
  4. We also may disclose information (a) in response to a subpoena, warrant, court order, levy, attachment, order of a court-appointed receiver, or other comparable legal process, including subpoenas from private parties in a civil action, (b) where necessary to defend or protect our rights, or (c) in order to protect ourselves, our customers, or any third party from crime or potential crime.
  5. We disclose information to your agent or legal representative (such as the holder of a power of attorney that you grant, or a guardian appointed for you) if you have one or interact with us through one.
  6. As with any other business, it is possible that we (or our corporate group) could merge with or be acquired by another company in the future. If such a transaction (acquisition) occurs, the successor company would have access to the information maintained by us, including customer account information. Even in that scenario, the processing of your Personal Information would continue to be bound by this Privacy Policy unless and until it is amended.  We note that the sharing here may also occur during the process of diligence (pre-transaction assessment) leading up to the transaction itself.
  7. The functioning of our Services, by its very nature, may require your Personal Information located elsewhere – outside of those Services. Such use may include, but not be limited to, using your information to search information accessible on the internet – information that is both public, as well as contained in private information databases and sites.
  8. The functioning of Services you have requested may, by its very nature, require revealing your Personal Information in order to post review responses, post on social media sites, etc. For example, we may have to disclose your name to a review website in order to post a response to a review.

5. SPECIAL OFFERS AND UPDATES

Using your name and email address, we will occasionally send you information on products, services, discounts, and promotions related to our products. You can sign up for these emails on our registration page during the registration process.  You can unsubscribe from these emails by using the link in the footer. Please see “Choice and Opt Out” for more information.

6. PUBLIC FORUMS

The Site offers publicly accessible blogs. You should be aware that any information you provide in these areas may be read, collected, and used by others who also access them. To request removal of your Personal Information from our blog, contact us at info@reputationdefender.com.

7. THIRD-PARTY LOG IN

You can log into the Site using an Open ID sign-in service provider.. These services will authenticate your identity and provide you the option to share certain Personal Information with us, such as your name and email address, to pre-populate our sign-in form.

8. UPDATING INFORMATION

You may review, correct, update, change, or delete your Personal Information on your ReputationDefender account profile at any time. Simply log into your ReputationDefender account, go to your User Profile, review your Personal Information and, if you wish, edit it with the options provided. If you are unable to edit your Personal Information by logging into your account, please contact us for assistance.  Customer Service is available to assist with this between 6:00 a.m. and 6:00 p.m. Pacific Time.

9. PERSONAL INFORMATION OF THIRD PARTIES THAT WE RECEIVE FROM OUR CUSTOMERS AND CLIENTS

Certain versions of our Services can be provided by companies to the benefit of their employees or other representatives. In that scenario—when we are hired by your company—we get your Personal Information from those companies (our customers).

10. INFORMATION SECURITY

We take reasonable and appropriate physical, technical, and organizational security measures in accordance with applicable laws to protect your personal data against the risk of accidental loss, compromise, or any form of unauthorized access, disclosure, or processing. The relevant security controls are communicated throughout Gen Digital to support the secure development of Services and maintain a secure operating environment. Our security approach includes:

Physical Safeguards

We lock doors and file cabinets, control access to our facilities, implement a clean desk policy, and apply secure destruction to media containing personal data.

Technical Safeguards

We implement and use information security standards, protocols, and technologies, including encryption, intrusion detection, and data loss prevention, and we monitor our systems and data centers to comply with our security policies.

Organizational Safeguards

We conduct regular company-wide as well as role-specific training and awareness programs on security and privacy. If you have any questions about the security of your personal data or the security of the site, or wish to report a potential security issue, please contact security@GenDigital.com. When reporting a potential security issue, please describe the matter in as much detail as possible and include any information that might be helpful.

11. COOKIES AND TRACKING TECHNOLOGIES

  1. As is true of most websites, we gather certain information automatically. This information may include Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, date/time stamp, and/or the pages you visit on our site to analyze trends in the aggregate and/or administer the site. 
  2. We use cookies or similar technologies to analyze trends, administer the website, track users’ movements around the website, and to gather aggregated demographic information.  A cookie is a small text file that is stored on a user’s computer for record-keeping purposes. We use cookies on the Site.  You can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functions on our website or service.
  3. We use both session cookies and persistent cookies. We use session cookies to make it easier for you to navigate the Site and to track whether or not you are logged into the Site. A session cookie expires when you close your browser. A persistent cookie remains on your hard drive for an extended period of time. You can remove persistent cookies by following directions provided in your Internet browser’s “help” file.
  4. We set a persistent cookie to store how you came to the Site and which packages and discounts we are able to offer you upon your registration. Persistent cookies also enable us to track and target the interests of our users to enhance their experience on the Site.
  5. You may adjust your browser settings to refuse or to remove or clear cookies by following the directions provided in your browser settings. If you reject cookies, you will still be able to view the Site, but your ability to use some areas of the Site will be limited. You will be unable to log into the Site if you reject cookies.
  6. In some of our products and services we may use analytics tools provided by third-parties (such as Google Analytics) to identify potential security and performance issues, understand how you use our products so we can improve the product functionality as well as your user experience, and to evaluate and improve our campaigns and communications with you. Specific analytics tools may vary depending on the operating system of the device.
  7. We employ, and our third-party advertising partners employ, a software technology called clear gifs (a.k.a. “Web Beacons” or “Tracking Pixels”), that helps us better manage content on the Site by informing us which content is effective.  Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to learn about the interactions of our users with the Site and our outbound emails. In contrast to cookies, which are stored on a user’s computer hard drive, clear gifs are embedded invisibly on Web pages and are about the size of the period at the end of this sentence. We tie the information gathered by clear gifs to our customers’ Personal Information. We use clear gifs in our HTML-based emails to let us know which emails recipients have opened. This allows us to gauge the effectiveness of certain communications and the effectiveness of our marketing campaigns.
  8. We may sometimes work with third-party platforms to deliver or retarget ads to you; for instance, when you have visited our Site and we would like to re-connect to show you additional content about our services.   This type of advertising is called “interest based” or “personalized” advertising.  If you would like to opt out of receiving such advertising, you may visit the opt out web pages operated by the following industry organizations: the DAA – here, or the NAI – here. 

12. YOUR PRIVACY RIGHTS

Subject to applicable laws, you have the following rights:

  • Delete:  Right to delete or erasure (“right to be forgotten”) of personal data we have collected from or about you in cases stipulated by law, e.g., if there is no legally recognized title on our part for further processing of your personal data (incl. protection of our legitimate interests and rights).
  • Access:  Right to know and access the personal data we have collected about you, to receive a copy of your personal data as well as other information about our data processing practices.
  • Correct: Right to rectify, correct, update, or complement inaccurate or incomplete personal data we have about you.
  • Restrict: Right to restrict the way we process your personal data in certain situations (e.g. if you are contesting the accuracy of your personal data; the processing is unlawful and you request the restriction of its use instead of deletion; we no longer need the personal data for the purposes of the processing, but they are required by you for the establishment, exercise or defense of legal claims; there is a pending verification whether our legitimate grounds override your interests).
  • Withdraw Consent: Right to withdraw your consent to process your personal data. The withdrawal of consent shall not affect the lawfulness of processing based on your consent before its withdrawal.
  • Object: Right to object to our processing of your personal data based on legitimate interest on grounds relating to your particular situation and we are required to assess the processing in order to ensure compliance with all legally binding rules and applicable regulations. In case of direct marketing, we shall cease processing personal data for such purposes after the objection.
  • Object to Automated Individual Decision-Making: Right to object to our processing of your personal data in case of automated individual decision-making.
  • Equal Service: Right not to receive discriminatory treatment for the exercise of your privacy rights, subject to certain limitations.
  • Opt-Out: Right to Opt-Out of the sale of personal data, or the Right to Opt-Out of sharing of personal data for cross contextual advertising. U.S. residents can opt out of personalized advertising as set forth here: Do Not Sell or Share My Personal Information.
  • Portability of Personal Data: Right to obtain a portable copy of your personal data processed by automated means, on the basis of consent, or where it is necessary for the purpose of conclusion and performance of a contract.
  • Lodge a Complaint: Right to lodge a complaint with a supervisory authority if you are not satisfied with the way we have handled your personal data, or any privacy request, or other request that you have raised with us.

How to exercise your access, opt out, and (if applicable) deletion rights

You may exercise your privacy rights by sending an email to dataerasure@reputationdefender.com or by contacting us at 888-720-3332.

For security purposes, we may need verify your identity—in part by requesting certain information from you—when you request to exercise your privacy rights of “access” or “deletion.”  For instance, if you request categories or specific pieces of Personal Information that we have received about you, you may need to confirm your possession of an identifier (such as an email address) or to provide a piece of identification that confirms you are the person you claim to be.

Right to nondiscrimination

We will not deny, charge different prices for, or provide a different level of quality of goods or services if you choose to exercise these rights. 

Authorized agents

You may also designate an agent to make requests to exercise your rights under CCPA as described above. We will take steps both to verify your identity to verify that your agent has been authorized to make a request on your behalf through providing us with a signed written authorization or a copy of a legally sufficient power of attorney.  We likewise may require that you verify your own identity, depending on the type of request you make.

13. LINKED SITES

The Site contains links to other sites that are not owned or controlled by us.  Please be aware that we are not responsible for the privacy practices of such other sites. This Privacy Policy applies only to information collected by the Site.

14. CHOICE AND OPT OUT

  1. As also described above, you may “opt out” of having your Personal Information used for certain purposes when we ask for this information. For example, if you purchase a product/service but do not wish to receive any additional marketing material from us, you can indicate your preference in the Site’s account area.
  2. If you no longer wish to receive our newsletter and promotional communications, you may opt out of receiving them by following the instructions included in each newsletter or communication or by emailing us at info@reputationdefender.com. We also offer an opportunity to opt out of certain communications on the Site via our user account area.

15. CROSS-BORDER TRANSFERS OF PERSONAL DATA

Gen Digital has certified to the EU-U.S. Data Privacy Framework (including its UK extension) and Swiss-U.S. Data Privacy Framework managed by the U.S. Department of Commerce  for the transfer of personal information from the European Economic Area (EEA), the United Kingdom, and Switzerland to the United States. Click here to access the Gen Digital Inc. Data Privacy Framework Notice.

If your personal data originates from the European Economic Area and is transferred to Gen Digital subsidiaries, affiliates, or third-party vendors engaged by Gen Digital or NortonLifeLock Ireland to process such personal data on our behalf located in countries that are not recognized by the European Commission as offering an adequate level of personal data protection, those transfers are covered by alternate appropriate safeguards, specifically Standard Contractual Clauses adopted by the European Commission.

16. CHANGES TO PRIVACY STATEMENT

  1. If we decide to make material changes to our privacy policy, we provide you with reasonable notice, either through an email to your last known email address or by posting those changes to this privacy statement on the Website homepage, prior to the changes taking effect.
  2. You are also responsible for regularly reviewing the Privacy Statement and related documents. We reserve the right to modify this Privacy Statement at any time.

If you have any questions about this Privacy Policy, the practices of Gen Digital with respect to Personal Information, or your dealings with the Site, you can contact us at info@reputationdefender.com, or if you are in the EU or UK, contact our Data Protection Officer at DPO@gendigital.com.

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