PRIVACY POLICY

I. Data controller

II. Data Protection Officer (DPO)

III. Purpose and legal basis for the processing

Your personal data will be processed for the following purposes:

• To manage the pre-contractual and/or contractual relationship with you, including, if appropriate, to monitor and actively manage your devices for the purpose of providing the service, manage complaints and improve customer service, provide technical support, and send you reminders when the software license you have purchased is about to expire.
  In this respect, the fulfillment of the pre-contractual and/or contractual relationship with you constitutes the legal basis for the processing.


• If you do not consent to providing the mandatory and indispensable personal data requested, it will not be possible to fulfill the pre-contractual and/or contractual relationship with you, resulting in the product provision not being formalized.. In any event, you have the right to object to the processing of your personal data for the purpose and in the manner set out above.


• In particular, our products for Android require the following data for its operation:
  
  
  • User contact data. Email addresses are used to create the Panda Account for authorization on the Panda web portals, which enables users to manage their licenses and their devices for anti-theft, parental, and employee control purposes. Email addresses are also used to send welcome emails during the onboarding process and security messages to the users. They can also be used for marketing purposes. Contact information is provided by users at their own discretion.
  
  
  • Location. Anti-theft, Family, and Employee Control features obtain and store the location of the user’s devices to track them and send them alerts in case of entry/exit of control zones. The app needs to use the device's location to provide the said features even when it is closed or not in use. This location information is not shared with third parties or used for advertising purposes, and is only accessible by the account owner, the supervisor users from their devices, and the Web consoles of the Anti-Theft, Family and Employee Control features.
  
  
  • Installed apps. The product uses the list of apps installed on the device to perform an antivirus scan of them for threats and to get the list of installed apps to monitor their use and apply usage restrictions on them for parental/employee control purposes. Application usage statistics. Application usage statistics are obtained so that supervisors can monitor the use of the applications by the supervised devices.
  
  
  • Contacts. The user's contact information is used to block calls from unknown numbers and provide call block reports grouped by contact.
  
  
  • Statistic data/Analytics. Information about the user's interaction with the product is uploaded to optimize the user experience and to detect and correct possible errors when they appear.
  
  
  • Camera. A photo is taken when the user requests it in the context of an anti-theft action on a lost or stolen device.
  
  
  • Unique identifier of the mobile device. This ID is generated by Android and is unique per device up to Android 7, or per device and application signature from Android 8 onwards. It is required to manage and perform actions on a specific device (anti-theft, family, etc.).
  
  
  • Social Account information of new devices installed from Social Media campaigns.
  
  
• To enable the Society to send you offers or advertising and promotional communications by any means (including email) concerning other products or services offered by Panda Security, or to carry out other marketing activities such as sending newsletters to registered users. In this respect, your expressed consent constitutes the legal basis for the processing, should you have granted it. If you do not consent to the processing of your personal data for the purpose set out above, you will not receive any marketing communications from Panda Security.


• To retain your personal data in the event that the contractual relationship is not formalized, for the purpose of managing future requests you may make, and, if appropriate, sending you information improving the conditions of an offer you didn’t contract. In this respect, the Society's legitimate interest in managing and satisfying any future requests or queries you may have constitutes the legal basis for the processing. In any event, you have the right to object to the processing of your personal data if the contractual relationship is not formalized.

IV. Data retention period

V. Recipients of the personal data

VI. International transfers of personal data

VII. Rights available to data subjects

We inform you that you are entitled to exercise the following rights:

(i) Right of access: Right to find out what kind of personal information is being processed, and the processing activities performed on said data;

(ii) Right of rectification: Right to ask for your information to be corrected;

(iii) Right to erasure: Right to have your personal information deleted;

(iv) Right to object: Right to object to the processing of your personal data, for reasons related to your personal situation;

(v) Right to withdraw your consent when your consent is the legal basis for the processing of your personal data;

(vi) Right to restriction of processing: Right to ask for your personal information to stop being processed in certain cases (e.g. If you believe that the personal information about you is incorrect, for a period enabling the controller to verify the accuracy of the personal data); and

(vii) Right to portability: Right to receive a copy of the information which you have provided to the Society in a structured, commonly used and machine-readable format, and right to transmit that data to another controller.