GDPR-compliant privacy policy

Privacy Policy

Last updated on 14.01.2022

The terms and conditions of this Privacy Policy (hereinafter, “Policy”) apply to any information Doctor Web, Ltd., (hereinafter, “Rights Holder”) has received, receives and/or may receive about the users/visitors/participants (hereinafter, “You”) of any of the Rights Holder's websites, services, promo events and contests, social media groups and communities, subscriptions, computer programs, and other products belonging to the Rights Holder (hereinafter, “Services”) immediately before You use the Services, while You are using the Services or in connection with Your use of the Services, and also after such use.

1. You unconditionally and entirely accept the terms and conditions of the Policy as soon as You start using the Services. If You disagree with the Policy or with any of its terms and conditions, You must cease using the Services. You understand that only adult individuals can use the Services, and, therefore, when starting to use the Services, You confirm that You 1) have attained legal age in accordance with the laws of the country of which You are a national, or 2) that Your agreement with the Policy is given with the permission and in the presence of Your parents or other legal representatives. Unless You have not expressly agreed to the contrary, the Rights Holder proceeds on the basis that You have reached the age of majority.


2. Information which the Rights Holder has received, receives or may receive, as well as its authorised agent in the territory where the Services are distributed (hereinafter, “Information”):
   1. 2.1. The Information provided by You, as well as by the Rights Holder’s certified partners whose information is available on the Rights Holder's website page https://partners.drweb-av.pl/find_partner/ (hereinafter, "Certified Partners"), including when using the Services and creating accounts in the Services. This Information may include, for example, comments You made while using the Services and Your contact information or personal data specified when registering or buying the Services. The Rights Holder does not verify the Information and proceeds on the basis that the Information provided by You or the Certified Partner is reliable and up to date, and was obtained legally and with Your consent. The Rights Holder is not liable for the consequences arising from being provided with unreliable or outdated Information.
   2. 2.2. The Information that is automatically transmitted to the Rights Holder by Your devices through the software installed on those devices while You are using the Services. Such information includes, for example, Your IP address, cookie data, location, Your hardware and software configuration, and information about the actions You take when You are using the Services.
   3. 2.3. The Rights Holder uses and processes, among other things, the following information about legal entities: full name, the email address and phone number of the legal entity’s contact person (contact persons), the name of the legal entity, the legal entity's TIN and KPP, the legal entity's registered address, and the legal entity's address for postal deliveries. By accepting the terms and conditions of this Privacy Policy, the legal entity guarantees to the Rights Holder that the legal entity has the appropriate consents and permissions of its contact persons, if this is necessary in order for the Rights Holder to use and process the Information according to the terms of this Policy.


3. Cookies
   1. 3.1. Cookies are small text files that are temporarily stored on Your computer and allow websites to identify Your computer, for example, during repeat website visits. Cookies do not contain any personal data and are required for the collection of statistical data. They make Your authentication possible with regards to the use of certain Services, which makes it easier for You to navigate the Services and eliminates the need for You to repeatedly enter Your credentials. For technical reasons, authentication for some Services may be impossible without the authorised use of Cookies. You understand and agree that outside technologies used by the Rights Holder, such as website visitor counters, can independently and without the Rights Holder’s knowledge place their own Cookies on Your computer.
   2. 3.2. You understand that it is at Your discretion to allow, prohibit, or restrict the use of Cookies. To do this, You need to adjust the appropriate settings of Your browser—for the software employed by You to visit websites. You may also remove previously received Cookies.
   3. 3.3. The Rights Holder proceeds on the basis that by using the Services and visiting the Rights Holder’s website, You agree to the Rights Holder’s use of Cookies.


4. The purposes for receiving and processing the Information
   1. 4.1. The Rights Holder and its authorised agent in the territory where the Services are being distributed receive and process the Information needed to provide the Services, ensure the security of You and its Services, monitor Your compliance with Service usage rules, render You technical assistance, provide services, develop and improve products and Services, and execute agreements. The Information is also used to collect and summarise statistics, conduct research, and to communicate and engage in other interactions with You (hereinafter, "Interaction").
   2. 4.2. You understand and accept that Information about the composition and configuration of Your hardware and software is needed in order for the Rights Holder to pinpoint any technical problems You have experienced as a result of using the Services and to develop the most effective recommendations for eliminating such problems.
   3. 4.3. You understand and accept that when using the Services to upload files for online antivirus scanning, the full path to the uploaded files on Your device is revealed to the Rights Holder. On the basis of the files and other data provided by You, the Rights Holder has the right to generate signatures and data sets, which can later be stored and used in antivirus databases. You also understand and accept that despite the fact that the Rights Holder uses secure protocols for receiving/transmitting data, the content of the files uploaded for online antivirus scanning may be intercepted and read by third parties at the moment such files are uploaded (before the Rights Holder receives the files) without Your or the Rights Holder’s knowledge. Therefore, the Rights Holder is not liable for the safety of the information contained in files uploaded by You for online antivirus scanning.


5. Personal data of individuals
   1. 5.1. A prerequisite that must be met in order for Services to be provided to You is that the Rights Holder must receive Your personal data and subsequently process it. You give Your consent to having the Rights Holder process Your personal data and perform the following actions with Your personal data: it can be collected, recorded, used, copied, systematised, accumulated, stored, clarified (updated, changed, documented), extracted, transferred (distributed, provided, accessed), blocked, anonymised, deleted, cross-border transferred, and destroyed; and the actions listed above can also be carried out by means of automated processing.
   2. 5.2. The Rights Holder is the data controller. Your personal data is collected by the Rights Holder and its affiliates in accordance with statutory principles relating to the processing of personal data. In some sources of application distribution (hereinafter, "Software") and third-party services, the Rights Holder may not be able to influence the process of sending Your personal data to owners of such services and software distribution sources (for example, Google analytics, Google Play, Yandex Metrica, etc.). You understand and agree to have Your data sent to owners of software distribution sources and third-party services.
   3. 5.3. The Rights Holder collects and processes only those personal data needed to perform contracts or agreements with You, provide services and consultations to You, provide technical support, provide Services and communicate with You and engage in other Interaction, and also for the purposes stated in clauses 5.3.1 and 5.5 of this Policy. For example, if You contact the technical support or email it, the Rights Holder will process the data provided by You while that request is being processed. The Rights Holder does not collect or process personal data that is legally classified as “special categories of personal data”.
      5.3.1. The Rights Holder processes the following personal data of natural persons that has been provided by You and Certified Partners when filling out the Rights Holder’s special forms:
      • a) Your full name — the Rights Holder needs this information to identify You when providing the Services to You, and to provide technical support to You and for other purposes in accordance with clause 5.5 of this Policy;
      • b) Your email address — the Rights Holder needs it to communicate with You when providing Services and technical support to You, including in order to send You service, advertising, and other informational emails in accordance with the terms and conditions of this Policy and other Interaction with You, and other purposes in accordance with clause 5.5 of this Policy;
      • c) Your contact phone number — the Rights Holder needs it as an alternative method of communicating with You in order to maintain Interaction with You in the event You make errors when specifying an email address and to have an additional method of communication, including for sending information and advertising SMS messages to this number, to identify You in messengers and for other purposes in accordance with clause 5.5 of this Policy;
      • d) Your date of birth — the Rights Holder needs it to verify whether You have reached the age of majority, to ensure Your participation in promo events conducted by the Rights Holder, and to congratulate You on Your birthday, and for other purposes in accordance with clause 5.5 of this Policy.
      • e) Your gender and education are provided by You when filling out the user profile form on the Rights Holder's website, optionally, on a voluntary basis (the ability to use the Services does not depend on You providing this data); and the Rights Holder needs it solely to research and form a generalised user profile in order to improve the Services, and to advertise and promote the Services among potential users and other customers.
   4. 5.4. The Rights Holder, within its competence, takes the technical and organisational measures necessary and sufficient to ensure that Your personal data will not be made available to third parties without Your consent and will not be deleted accidentally or as the result of illegal actions.
   5. 5.5. The purposes of processing Your personal data are the purposes specified in clause 5.3.1 of this Policy, and also the following purposes:
      1. 5.5.1. to render services to You, and to conclude and execute any contracts and agreements between You and the Rights Holder,
      2. 5.5.2. to provide You with consultations and/or technical support,
      3. 5.5.3. to provide Services to You,
      4. 5.5.4. to communicate and for Interaction with You, including as a user of Dr.Web antivirus software to ensure that Your information systems are properly protected by the antivirus,
      5. 5.5.5. to provide You with informational materials on computer literacy issues,
      6. 5.5.6. to promote the Rights Holder's Services,
      7. 5.5.7. to provide reference information to You and also to inform You about the technical and functional characteristics of the Services,
      8. 5.5.8. to send advertising messages to You (about new Services and updates to existing ones, notifications on promotions, offers to prolong or resume the Interaction and also to change the terms of such Interaction and other advertising messages) using the communication methods You or a Certified Partner provided, and contact information You or a Certified Partner specified.
   6. 5.6. The place that processes Your personal data, regardless of where You reside/stay, is the Rights Holder’s location—the Russian Federation. The legislation of the Russian Federation in the field of personal data protection may differ from the legislation of the country of Your residence/stay.
   7. 5.7. The storage period for Your personal data is equal to the period needed to execute contracts or agreements with You, render services, consultations, and technical support to You, and provide Services; this storage period is also equal to the period determined by the Rights Holder’s internal regulations and needed to be able to inform You about the technical and functional characteristics of the Services, and also send You advertising messages (notifications and offers to prolong or resume the Interaction).
   8. 5.8. You have the right to request from the Rights Holder (or its authorised person in the territory where the Services are being distributed) information about the personal data being processed, to withdraw Your consent to having Your personal data processed, and to demand termination; You also have the right to ask for Your personal data to be clarified, blocked or destroyed if this personal data is incomplete, outdated, inaccurate, illegally obtained or not necessary for the stated purpose of data processing.
   9. 5.9. The Rights Holder, upon receiving such requests, has the right to take the necessary actions and request, from the person who sent the request, the information necessary to verify that such a person is the subject of the personal data requested by him/her. This measure is aimed at protecting Your personal data from being leaked to third parties and preventing third parties, including other Users, from attempting to gain access to Your personal data.
   10. 5.10. Due to the fact that personal data also statutorily includes data necessary for Your technical identification and necessary for using the Rights Holder’s Services, if You send a request to the Rights Holder to stop processing or delete Your personal data, the contracts and agreements concluded with You (as well as other types of Interaction) cease to operate on the day that Your personal data stops being processed or is deleted in connection with Your expression of Your voluntary will. The termination of contracts and agreements in connection with Your voluntary will means that You cannot use the Rights Holder’s Services from the date of such termination, and also that the Rights Holder has no obligation to compensate You for the unused period of the agreement, contract or Services.
   11. 5.11 The Rights Holder has the right to transfer Your Information to third parties, including to Certified Partners, in the cases specified below:
       • a) You have granted Your consent for such action;
       • b) the transfer is needed within the scope of a particular Service used by You, or in order for You to use the Services, or to provide services to You. This includes but is not limited to investigating Your potential violations;
       • c) the transfer is stipulated by Russian or other applicable legislation under procedures established by the legislation;
       • d) the transfer is needed to ensure the extension of Your rights to use the Services.
   12. 5.12. You understand and accept that the Rights Holder, as well as its authorised agent in the territory where the Services are being distributed, has the right to use the Information in the Services to contact You and to use any comments posted by You via the Services in the Rights Holder’s official social media groups and other communities of the Rights Holder's on the Internet.
   13. 5.13. The validity period of the consent You give to have Your personal data processed by the Rights Holder in accordance with the terms of this Policy is unlimited; however, You have the right to revoke this consent at any time and to request that the Rights Holder stops processing Your personal data by sending a written notice/request to the address specified in the Rights Holder’s contact details (in accordance with clause 7 of this Policy) with the note: "Revocation of consent to have personal data processed" or "Request to stop processing personal data". The revocation of consent to have personal data processed, as well as the request to stop processing personal data, may also entail, in addition to the specified clause 5.10 of this Policy, the deletion of Your account on the Rights Holder’s Internet site/sites, the impossibility of identifying such a person as the user, including as a Dr.Web user, which means that such a person cannot use Dr.Web antivirus programs and receive technical support from the Rights Holder and/or from its Certified Partners.


6. Other conditions.
   1. 6.1. By accepting the terms of this Policy, You directly and expressly agree to receive advertising messages from the Rights Holder, as well as its authorised agent in the territory where the Services are being distributed (about new Services and updates to existing ones, notifications on promotions, offers to prolong or resume the Interaction, and also to change the terms of such Interaction and other advertising messages) by the communication means that You or the Certified Partner indicated (Your contact details). At the same time, You have the right to refuse to receive advertising messages at any time in Your personal account area on the Rights Holder's website.
   2. 6.2. You understand that the information posted in the Services (except when expressly indicated): is not an offer; it cannot be used in situations where there is the risk of a threat to the life and health of people and the risk of any losses or damage (including, but not limited to, for the development of documentation and commercial offers, and for participation in tender procedures).
   3. 6.3. The Rights Holder can change the terms of this Policy without giving prior notice to You. A new version of the Policy comes into force as soon as it is published at company.drweb.com/policy, unless stated otherwise by the new version of the Policy. The current legislation of the Russian Federation applies to this Privacy Policy and the relationship between You and the Rights Holder.


7. The Rights Holder's contact information
   Website: https://www.drweb.com
   Address: 2–12a, 2-12a, 3rd Yamskoye Polye Street, 125124, Moscow, Russia
   PSRN 1047796021723 / TIN 7714533600