This policy applies to the Company’s employees, contractors and officers.
The Company has a contract with all Data Processors that it uses in compliance with Article 28 & Article 29 of the GDPR, and ensures that all Data Processors are compliant with Data Protection Legislation.
The 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 so the GDPR does not apply. Information collected by third parties is governed by their privacy practices. We encourage you to learn about the privacy practices of those third parties.
This policy applies to Relevant Data received and processed only.
Capitalized terms used in this Policy and not otherwise defined shall have the meanings provided below:
MacPaw Family of Companies – the list of the MacPaw family of companies is as follows:
601 Montgomery Street Suite 1400 San Francisco, CA 94111
9 Tallow Street, Youghal, Co. Cork, P36YE14
MacPaw Labs Ltd.
21 Davidson Road, Croydon, CR0 6DL
Relevant Data – Personal Data and Special Categories of Data are the Relevant Data covered by this policy and as defined in the Data Protection Legislation.
Personal Data – any information relating to an identified or identifiable natural person.
Special Categories of Data – 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.
Processing/Processed – any operation on personal data, whether automated or not.
Information we collect and receive
When you interact with our Sites, 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 that cannot be linked back to you (Non-Personal Data).
MacPaw collects, generates and/or receives the following Information:
Certain data about the devices you use to connect with MacPaw and your use of the Site are automatically logged in our systems, including:
- Contact details, namely, email if provided to MacPaw.
- 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.
- 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 record it in log files. This log data may include the IP address, browser type and settings, the date and time of use, information about browser configuration, language preferences, and cookie data.
- Site Specific Data. This is information about the Site you use and how you use them. We may also obtain data from our third-party partners and service providers to analyze how users use our Site. 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.
- 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 our Site.
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.
Additional information provided to MacPaw
We receive Other Information when submitted to our Site or if you participate in a focus group, contest, activity or event, apply for a job, request support, interact with our social media accounts or otherwise communicate with MacPaw.
Collecting 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. 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 without their permission.
How MacPaw uses your information
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:
- to help us administer our Site, authenticate users for security purposes, provide personalized user features and access, process transactions, conduct research, develop new features, and improve the features, algorithms, and usability of our Site;
- as required by applicable law, legal process or regulation;
- to calculate aggregate statistics on the number of unique devices using our Site;
- to send emails and other communications. We may send you service, technical and other administrative emails, messages and other types of communications if you have provided us with your e-mail address. In addition, we sometimes send emails about new promotional communications or other news. We will only send you marketing information if we receive your consent;
- to investigate and help prevent security issues, fraud and abuse.
If information is aggregated or de-identified so it is no longer reasonably associated with an identified or identifiable natural person, MacPaw may use it for any business purpose.
How we share and disclose information
We only disclose Personal Data to third parties when:
- We use service providers who assist us in meeting business operations needs, including hosting, delivering, and improving our Site. 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.
- We have your explicit consent to share your Personal Data (if required).
- 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/or users of our Site, or to respond to lawful requests by public authorities, including national security or law enforcement requests.
- 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/personallyidentifiable information with third parties for the purpose of enabling them to deliver their advertisements to you.
MacPaw does not sell or rent your Personal Data.
Third parties’ applications and products
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 Sites, 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.
Emailing by MacPaw
From time to time, we may want to contact you with information about announcements, 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.
Data storage, transfer, retention, and deletion
Data storage and transfers
Information submitted to MacPaw will be transferred to, processed, and stored in the United States. We also process your Personal Data in the UK, Republic of Ireland, Ukraine. Data stored and processed by MacPaw may sometimes be moved between these zones (in a secure manner). When you use the Site on your computing device, user content you save will be stored locally on that device and synced with our servers. If you post or transfer any information to or through our Site, you are agreeing to such information, including Personal Data and user content, being hosted and accessed in the United States, the UK, Republic of Ireland and Ukraine.
Duration of information storage
When you give us personal information, we take steps to make sure that it’s treated securely.
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 information, we cannot guarantee the security of any information you transmit to us, and you do so at your own risk. Once we receive your information, we make our best effort to ensure its security on our systems.
We use industry-standard encryption to protect your data in transit. This is commonly referred to as transport layer security (“TLS”) or secure socket layer (“SSL”) technology.
Once we receive your data, we protect it on our servers using a combination of technical, physical, and logical security safeguards. We recommend that you take the appropriate steps to secure all computing devices that you use in connection with our Site.
The Company takes the security of your data very seriously and works to protect your data from loss, misuse and unauthorised access or disclosure.
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 data. The Company holds a log of when staff training was undertaken and updates it on an annual basis.
All breaches will be reported to the relevant supervisory authority within 72 hours, unless the data was anonymised or encrypted or if it has a particularly high risk.
Breaches of this policy by staff, contractors, officers of the Company will be dealt with under the Company’s grievance and disciplinary policy and may lead to a disciplinary sanction.
If MacPaw learns of a security system breach, we may attempt to notify you and provide information on protective steps, if available, through the email address that you have provided to us or by posting a notice on the Site. Depending on where you live, you may have a legal right to receive such notices in writing.
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 Site, namely:
- 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 Site’s functionality. Logs and entire reports are important to analyze user problems, application misfunctions and crashes. 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, Internet Protocol (IP) address, access times, browser type, and language, OS localization- to identify and localize user issues (bugs) and to understand and localize user problems, for the Site’s proper functioning.
- 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 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.
We rely on your consent to process Personal Data:
- to send promotional emails,
- to place cookies on your devices and
- for in-app analytics events and actions, used by us to understand user behaviour, analyze and optimize it.
In some cases, MacPaw may process Personal Data pursuant to legal obligation or to protect your vital interests or those of another person.
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. 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@example.com
- Access your Personal Data report by submitting a request at firstname.lastname@example.org. 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@example.com if you feel the “ground relating to your particular situation” apply. 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.
- Ask us to stop using your Personal Data, 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 Site, even if you unsubscribe from marketing emails.
- Complain to a regulator. 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.
- Request to know more details about the categories or specific pieces of personal information we collect (including how we use and disclose this information), to delete their personal information, to opt out of any “sales” that may be occurring, and to not be discriminated against for exercising these rights.
Your California privacy rights
This section provides additional details about the personal information we collect about California consumers and the rights afforded to them under the California Consumer Privacy Act or “CCPA.”
Subject to certain limitations, the CCPA provides California consumers the right to request to know more details about the categories or specific pieces of personal information we collect (including how we use and disclose this information), to delete their personal information, to opt out of any “sales” that may be occurring, and to not be discriminated against for exercising these rights.
California consumers may make a request pursuant to their rights under the CCPA by emailing: firstname.lastname@example.org.
Data Protection Officer
To communicate with our Data Protection Officer, please email email@example.com.
The Company is not established in the EU and therefore VeraSafe has been appointed as MacPaw’s representative in the EEA for data protection matters, pursuant to Article 27 of the General Data Protection Regulation of the European Union.
To make such an inquiry, please contact VeraSafe using this contact form: https://verasafe.com/privacy-services/contact-article-27-representative/.
Alternatively, VeraSafe can be contacted at:
VeraSafe Czech Republic s.r.o
Prague 1, 11002
We may need to update this Policy to keep pace with changes in our Site, 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 Policy by email (to your most recently provided email address) or post any other revisions to this Policy, along with their effective date, in an easy-to-find area of the Sites, 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 Policy and do not wish your information to be subject to it, you will need to stop using the Site.