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ANTAVIRA PRIVACY POLICY

Publication date: 06/27/2023

The current version is available at: https://antavira.com/, https://antavira.ru/

1. What this privacy policy governs

This privacy policy (hereinafter referred to as the “Policy”) applies to all information, including personal data within the meaning of the applicable law (hereinafter referred to as the Personal Information), which ANTAVIRA LLC and/or its affiliates, including those belonging to the same group as LLC “ANTAVIRA” (hereinafter referred to as “Antavira”) may receive about you in the course of your use of the Antavira Predictive Modeling Platform (hereinafter referred to as the “Platform”), as well as in the course of execution by Antavira / its affiliates of any agreements and contracts concluded with you in connection with your use of the Platform. Antavira may make changes and/or additions to this Policy without your consent.

2. Who processes the personal information

To ensure your use of the Platform, your Personal Information is collected and used by Antavira, including including Antavira Limited Liability Company, a legal entity established under the laws of the Russian Federation and registered at: 121196, Russia, Moscow, st. Vasilisa Kozhina, 6k1, (Antavira LLC), or its affiliate providing the relevant Service in other jurisdictions.

3. What is the purpose of this Policy

Protecting your Personal Information and your privacy is extremely important to Antavira. Therefore, when using the Platform, Antavira protects and processes your Personal Information in strict accordance with applicable law.

4. What type of Personal Information Antavira collects about you

Antavira may collect the following categories of Personal Information about you while using the Platform:

(i) Personal information provided by you when registering (creating an account) or when completing the feedback form, such as your full name, phone number, e-mail address;

(ii) the date and time of access to the Platform;

(iii) information about your activity while using the Platform, as well as files and content stored in Antavira systems;

Antavira does not collect purposefully sensitive personal information (such as racial origin, political opinions, health information, and biometric data).

Antavira does not collect data for the purpose of compiling a “portrait” of the user to the extent that this may significantly affect your rights and freedoms in accordance with applicable law.

5. What are the legal basis and purposes of processing your Personal Information

Antavira is not allowed to process your Personal Information without sufficient legal grounds. Therefore, Antavira will only process your Personal Information if:

(i) processing is necessary for the performance of agreements between you and Antavira, such as the User Agreement for Antavira services https://antavira.com/, https://antavira.ru/, and also includes the operation of the Platform;

(ii) the processing is necessary for compliance with legal obligations;

(iii) in case it is provided by applicable law, the processing is necessary for the legitimate interests of Antavira in the event that such processing does not significantly affect your interests, your fundamental rights and freedoms. Please note that when processing your personal information on this basis, Antavira will always strive to maintain a balance between its legitimate interests and the protection of your privacy.

Antavira processes your Personal Information for its legitimate interests, for example, in the following cases:

(i) to better understand how you interact with our Platform;

(ii) to improve, change, personalize or otherwise improve the Platform for the benefit of all users;

(iii) to offer you other Antavira products and services;

(iv) for specific purposes or as required by applicable law, we may require your separate consent to process your Personal Information. For jurisdictions where consent is recognized as a separate legal basis, you provide such consent by agreeing to use our Sites and/or Services. We hereby inform you and you acknowledge that you have no obligation to provide us with any Personal Information when you use the Platform and such provision is based solely on your free will. However, you acknowledge that without providing Personal Information, we will not be able to provide you with the opportunity to use the Platform.

Antavira always processes your Personal Information for specific purposes and only that Personal Information that is relevant to the achievement of such purposes. In particular, we process your Personal Information for the following purposes:

(i) providing you with access to the Platform;

(ii) to communicate with you to send you notices, requests and information related to the operation of the Platform, to fulfill agreements with you and to process your requests and applications;

(iii) improve the usability of the Platform, as well as to improve other Antavira products, applications and Services;

(iv) creation of new Antavira products, utilities and offerings;

(v) protect your rights and the rights of Antavira;

(vi) collection, processing and presentation of statistical data, big data and other research;

(vii) identifying security threats to the Platform, users, Antavira and/or third parties, including your integrity check in course of entering into agreements while using the Platform;

(viii) arranging the acceptance of Your payments, making payment by You for the use of the Platform.

6. How Antavira Protects Your Personal Information

In most cases, Personal Information is processed automatically without access to it by any of Antavira employees. However, if such access is necessary, it can only be granted to those Antavira employees whose professional tasks require using this information. To protect your Personal information and ensure its confidentiality, all employees must comply with internal policies and procedures regarding the processing of Personal Information. They must also follow all technical and organizational security measures in place to protect your Personal Information.

Antavira has also implemented adequate technical and organisational measures to protect Personal information against unauthorised, accidental, or unlawful destruction, loss, alteration, misuse, disclosure or access and against all other unlawful forms of processing. These security measures have been implemented taking into account the state of the art of the technology, the cost of their implementation, the risks associated with the processing and nature of Personal Information.

7. Who else has access to your Personal Information and to whom it may be shared

Antavira may share your Personal Information with its employees (within the limits specified in Section 6 of this Policy). Antavira may also share your Personal Information with its affiliates. Please note that the level of protection of Personal Information in some countries may not be identical to the level established in your jurisdiction, and by using the Antavira Services, you consent to such transfer.

In all cases. unless otherwise stated by the terms of use of the Platform, Personal Information will be processed only for the purposes set out in Section 5 of this Policy.

Antavira may also transfer Personal Information to third parties not affiliated with Antavira in order to achieve the purposes specified in Section 5 of this Policy. Please note that the level of protection of Personal Information in some countries may not be identical to the level established in your jurisdiction, and by using the Antavira Services, you consent to such transfer.

Such third parties may include:

(i) persons, providing information for discovering security risks to the Sites and Services, users, Antavira and/or third parties, including your integrity check in course of entering into agreements while using the Sites or Services;

(ii) persons involved in organization of the acceptance of your payments and carrying out payment transactions (international payment systems, providers of payment instruments, banks and other financial organizations, etc.).

Antavira may also transfer Personal Information to third parties outside the Antaviraa Group:

(i) to any national and/or international regulatory authority, law enforcement authorities, central or local executive authorities, other official or state bodies or courts in respect of which Antavira is required to provide information in accordance with applicable law upon request;

(ii) to any third party in order to provide legal protection to Antavira or third parties if you violate the Antavira Services User Agreement (https://antavira.com /,  https://antavira.ru /), this Policy or the terms and conditions governing the use of the Platform or in a situation where there is a threat of such violation.

8. Where your Personal Information is stored and processed

Your Personal Information will be stored in the Russian Federation and/or the EEA.

For users fom Russia: Antavira records, systematizes, accumulates, stores, clarifies (updates, changes), extracts personal data of citizens of the Russian Federation using databases located in the territory of the Russian Federation.

For users from the EEA, Switzerland, or Israel: Russia is a jurisdiction outside the European Economic Area that has not been recognized by the European Commission as providing an adequate level of personal data protection. Therefore, Antavira has taken appropriate measures to ensure that such transfer is carried out in accordance with current EU data protection regulations.

In particular, Antavira is guided by the Standard Contractual Clauses approved by the European Commission to ensure an adequate level of protection for your Personal Information transferred to Russia. A copy of these Standard Contractual Clauses is available upon request.

If you are located in a jurisdiction where your consent is required for the transfer of your Personal Information to another jurisdiction, then by using the Platform, you give Antavira your express and unambiguous consent to such transfer or storage and / or processing of information in other specified jurisdictions, including Russia.

9. How long we store your Personal Information

Antavira will keep your Personal Information for as long as necessary to fulfill the purpose for which it was collected or to comply with legal and regulatory requirements.

Unless otherwise required by law or by agreement with you, documents that you store in Antavira will be kept for as long as you have an account, but they can be deleted by you at any time.

If you want any of your Personal Information to be deleted from Antavira’s databases, you can delete the necessary Personal Information yourself through the Platform’s interface (where applicable).

10. Your rights

10.1 What rights do you have

If it is provided by applicable law, you have the right to access your Personal Information processed by Antavira in accordance with this Policy.

If you believe that any of the information that Antavira holds about you is incorrect or incomplete, you can log into your account and correct your Personal Information yourself.

If it is provided by applicable law, you have the right to:

  • learn the information that Antavira keeps about you;
  • request the deletion of your Personal Information or part of it, as well as withdraw consent to the processing of your personal information;
  • request the restrictions on the processing of your Personal Information;
  • request a copy of the Standard Contractual Clauses that permit the transfer of your Personal Information to Russia and are set out in Section 8 of this Policy;
  • object to the processing of your Personal Information, if required by applicable law.

Antavira will comply with these requests in accordance with applicable law.

To the extent permitted by applicable law, you may also have other rights not listed above.

When you use the Platform, the transfer of Personal Information is carried out with your consent, expressing your free will and your interest, (in particular, on the basis of an agreement with you) and is not a legal obligation.

10.2 How you can exercise your rights

To exercise the above rights, please log in to your account, and if there is no special function in the interface, contact Antavira (see section 12 of this Policy).

If you are not satisfied with the way Antavira handles your Personal Information, please let us know and we will investigate your complaint. If you are not satisfied with Antavira’s response, you have the right to file a complaint with the competent authority.

11. Updates to this Policy

This Policy may be subject to amendments. Antavira has the right to make changes at its sole discretion, including, but not limited to, in cases where the relevant changes are related to changes in applicable law, as well as when the relevant changes are related to changes in the operation of the Sites and Services.

Antavira undertakes not to make significant changes, not to impose additional obligations or restrictions on your rights established by this Policy without your notice. You will be notified of such changes. Appropriate notices may be displayed on the Site or Services (for example, via a pop-up window or banner) before such changes become effective or may be sent to you through other communication channels (for example, by e-mail if you have provided us with your Contact details).

12. Questions and suggestions

Antavira welcomes your questions and suggestions regarding the implementation or modification of this Policy. Please use our feedback form located at https://antavira.com/ , https://antavira.ru/.

You can also use this address to send inquiries about the exercise of your rights or complaints regarding the incorrectness of your Personal Information or the unlawfulness of its processing.