CALIFORNIA RESIDENTS
PRIVACY NOTICE SUPPLEMENT
Effective Date : January 1, 2020
Last Reviewed on : January 1, 2020
We are committed to your right to privacy and respecting your ability to control your information.
This supplement (“Supplement”) applies to visitors, users, and others who reside in the State of California (“consumers” or “you”). It is designed to supplement the Malwarebytes Privacy Policy (“Privacy Policy”) to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws. Any terms defined in the CCPA have the same meaning when used in this notice.
I. WHAT PERSONAL INFORMATION DO WE COLLECT?
| We collect and use your personal information for business purposes described in the Privacy Policy.In the past twelve (12) months, we’ve collected the categories of personal information as shown in the table below: | SimplyIn the past twelve (12) months, we’ve collected the types of personal information as shown in the table below: |
| Category | Examples | Collected |
| A. Identifiers. | name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers. | YES |
| B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). | name, address, telephone number, education, employment, employment history.Some personal information included in this category may overlap with other categories. | YES. Education and employment related information is only collected for job applicants. |
| C. Protected classification characteristics under California or federal law. | Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, disability (mental and physical including HIV/AIDS, cancer, and genetic characteristics), sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). | YES, but only where appropriate for job applicants. |
| D. Commercial information. | Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | YES |
| E. Biometric information. | Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. | NO |
| F. Internet or other similar network activity. | Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. | YES |
| G. Geolocation data. | Physical location or movements. | YES |
| H. Sensory data. | Audio and visual recordings. | YES, support calls may be recorded for quality purposes. |
| I. Professional or employment-related information. | Current or past job history or performance evaluations. | YES, where appropriate for job applicants. |
| J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). | Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. | NO |
| K. Inferences drawn from other personal information. | Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. | NO |
II. WE DO NOT SELL YOUR PERSONAL INFORMATION?
| We do not sell your personal data. In the last twelve (12) months, we have not sold any personal information. | Simply We do NOT sell your personal data. |
III. WHAT PERSONAL INFORMATION DO WE SHARE?
| In the preceding twelve (12) months, we have disclosed the following categories of personal information for business purposes, described in the Privacy Policy, to our affiliates, services providers, and third parties who you (or an agent on your behalf ) has authorized us, for a business purpose: | Simply We share limited personal data to third parties where there is a business purpose. |
Category A: Identifiers.
Category B: California Customer Records personal information categories.
Category C: Protected classification characteristics under California or federal law.
Category D: Commercial information.
Category F: Internet or other similar network activity.
Category G: Geolocation data.
Category H: Sensory data.
Category I: Professional or employment-related information.
IV. WE DO NOT DISCRIMINATE AGAINST YOU FOR EXERCISING YOUR RIGHTS
| We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:Deny you goods or services.Charge you different prices or rates for goods or services.Provide you a different level or quality of goods or services.Suggest that any of the foregoing may occur. | Simply We won’t discriminate against (or punish) you for exercising your rights. |
| We may offer certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time. |
V. YOUR RIGHTS AND CHOICES
California residents have the following rights under the CCPA:
| 1. Personal Information Request | ||
| You have the right to request we tell you what personal information we’ve collected about you and how we’ve used it over the past 12 months. Once we receive and verify your request, we will provide you a report showing: – The categories and specific personal information we’ve collected. – The categories of sources for the personal information we collected about you. – Our business purpose for collecting that personal information. – The categories of third parties with whom we share that personal information. – If we sold or disclosed your personal information for a business purpose, two separate lists disclosing: – Sales – identifying the personal information categories that each category of recipient purchased; and – Disclosures for a business purpose – identifying the personal information categories that each category of recipient obtained. | Simply If you submit a request, we will show you what personal information we have of yours. | |
| 2. Deletion Rights | ||
| You have the right to request we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and verify your request, we will delete (and direct our service providers to delete) your personal information from our records. We may deny your deletion request if retaining the information is necessary for us or our service providers to: – Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you. – Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities. – Debug products to identify and repair errors that impair existing intended functionality. – Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law. – Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.). – Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent. – Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us. – Comply with a legal obligation. – Make other internal and lawful uses of that information that are compatible with the context in which you provided it. | Simply We will delete your personal information where you tell us to. In very limited circumstances we may deny your request where continuing to process such personal information is necessary. | |
| 3. How California Residents Can Submit Requests under the CCPA. | ||
| – Online form – via email to us at: ccpa@malwarebytes.com Only you, or your authorized agent acting on your behalf, may make a request related to your personal information under the CCPA. Our services are not directed to children under 18 and we do not knowingly collect information about children under 13. That being said, you may also make a request on behalf of your minor child. You may only make a personal information request twice within a 12-month period. Your request must: – Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative. – Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a request does not require you to create an account with us. We will only use personal information provided in such a request to verify your identity or authority to make the request. | Simply: Submit your requests online by either: 1. completing a form online or 2. via email to ccpa@malwarebytes.com | |
| 4. Response Timing and Format | ||
| We will do our best to fulfil your request within 45 days of submission using the methods described above in Section 3. If we need additional time to fulfil the request, we will let you know in writing why we need more time and how much more time is being requested. The disclosures we provide only cover the 12-month period preceding receipt of your request. Where we are unable to comply with your request, we will explain why we cannot comply. For personal information requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity. We will not charge you for responding to your request unless it is excessive, repetitive, or clearly inappropriate. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request. | Simply: We will do our best to fulfil your request within 45 days of submission. If we need additional time, we will let you know. | |
| 5. Note about Malwarebytes Free | ||
| If you only use our free Malwarebytes product(s) and have not set up a MyAccount, then we do not have your personal information. For such users we have no personal information to provide you with, and we have no personal information to delete. | ||
VI. CHANGES TO THIS CALIFORNIA SUPPLEMENT
| We reserve the right to amend this Supplement at our discretion and at any time. When we make changes to this Supplement, we will notify you by email or through a notice on our website homepage. | Simply: We’ll let you know if we revise this Supplement. |
VII. DISABILITIES
We are committed to ensuring that our website, including this Supplement, is accessible to people with disabilities.
This Supplement is available as a searchable PDF by clicking the “print” link at the top of the page allowing you to either print the document or download it as a PDF. If you are disabled and need additional assistance with this policy or have feedback about our website generally, please contact us at: accessibility@malwarebytes.com
VIII. CONTACT INFORMATION
If you have any questions or comments about this Supplement, our Privacy Notice, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:
Attn: CCPA – Legal
Malwarebytes
3979 Freedom Circle, 12th Floor,
Santa Clara, CA 95054