Last Modified: February 2024

Privacy Policy Fortect

Our Commitment to Privacy

This privacy policy (“Privacy Policy”) which is an integral part of our End User License Agreement ("EULA") will detail the data collection, processing and privacy practices, in the course of downloading and using our Software and Services offered by Fortect Ltd. ("Company", "we" or "us"). All capitalized terms used but not defied herein, shall have the same meaning as defined in the EULA.

This Privacy Policy will provide transparent information regarding our privacy practices in compliance with the applicable privacy protection laws, as required, according to, and among others, the EU General Data Protection Regulation (“GDPR”).

Please carefully review this Privacy Policy before you download, access or use the Software and the Services.

Contact Details

The Company is considered as the “Data Controller” of the Personal Data (as defined below) collected from you, as further detailed below.

Fortect Ltd.

By Mail: Shlomo Ibn Gabirol St 71, Tel Aviv, Israel

Email address: [email protected]

Data Collection And The Purposes

When downloading, accessing or otherwise interacting with the Software and our Services, we may collect certain types of data. In general, we may collect the following information, depending on how you interact with our Software and Services:

Non-Personal Data

During your interaction with our Software and Services, we may collect aggregated, non-personal non-identifiable information, which may be made available or gathered via your access to and use of the Services (“Non-Personal Data“). We are not aware of the identity of the user from which the Non-Personal Data is collected. The Non-Personal Data being collected may include your aggregated usage information and technical information transmitted by your device, such as: the type of browser or device you use, operating system type and version, language preference, time and date stamp, etc.

Personal Data

We may also collect from you, during your access or interaction with the Software and Services, individually identifiable information, namely information that identifies an individual or may, with reasonable effort, be used to identify an individual (“Personal Data” or “Personal Information”). The types of Personal Data that we collect as well as the purpose for processing such data are specified in the table below.

For the avoidance of doubt, any Non-Personal Data connected or linked to any Personal Data shall be deemed as Personal Data as long as such connection or linkage exists.

Please see below the table which specifies the Personal Data we collect and how we use it:

Data Sets	Purpose Of Processing	Lawful Basis Under The Gdpr
Online Identifiers When you use our Software and Services, we may collect certain technical data, which shall include: Internet Protocol (“IP”) addresses, cookie ID, or any other similar unique online identifiers generated (“Online Identifiers”). Such data is collected through cookies, pixel tags and log files, and includes online usage data, login data (when applicable) and IP address.	We process Online Identifiers to facilitate the functioning of the Software and Services, ensure security, and prevent fraud. Furthermore, we employ Online Identifiers to enhance our Service and improve your overall experience while using the Software and Services; for analytical and statistical purposes, specifically to analyze the and interactions with our Software and Services;	The processing of Online Identifiers for operational, technical, and security purposes (such as fraud detection), is carried out based on our legitimate interest. However, when we process Online Identifiers for analytic purposes, we do so subject to your consent.
Usage Data When utilizing our Software and Services, we collect your browsing data such as: the referring URLs (that is the webpage or ads directed you to our Services), your interaction with the content (including duration of use, click stream, etc.), web page visited, access time and date, activity logs (access, time of usage, etc.) and further data received regarding your use and interaction with the Services ("Usage Data"). While this data is typically gathered as aggregated Non-Personal Data, it is important to note that in certain cases, web browsing data may contain information that could be considered Personal Data	We process Usage Data for the purpose of providing certain features of the Services, enhance your experience and improve our Services and Software. We may use Usage Data for internal analytics and measurement purposes, aiming to gain insights into how our Services are being used. This analysis allows us to enhance the functionality and quality of our Services.	We process Usage Data to fulfill our contractual obligations and provide you the requested Services. Additionally, certain purposes, such as operational and security aspects, are conducted based on our legitimate interest. When collecting Usage Data for analytics and advertising purposes, we process this data based on your consent, which is obtained through the onboarding permissions.
Software Data: Following the Trail, and if the User decide to purchase a License to use our Software, we collect data regarding the User's environment (i.e. the computer our Software is running on) which includes: the operating system the Software is installed on, language preference, the file system in use, Information from the Win Security/Action Center, including security settings and programs installed or in use, and Software's log data. In addition, as part of our services, we collect data about malware, virus, and the status of the optimization and security of User's system, including the vendor's name of the malware program, the data base related to the malware program, Win optimization data, and any related information to detect errors and optimize User's PC ("Software Data").	We process Software Data for the purpose of providing certain features of the Services, enhance your experience and improve our Services and Software. We may use Software Data for internal analytics and measurement purposes, aiming to gain insights into how our Services are being used. This analysis allows us to enhance the functionality and quality of our Services.	We process Software Data to fulfill our contractual obligations and provide you the requested Services. Additionally, certain purposes, such as operational and security aspects, are conducted based on our legitimate interest.
Installed applications and hashes of files	We use Avira SDK, which makes use of Avira Protection Cloud (https://query-api.eu1.apc.avira.com) to improve detection of previously unknown threats using machine learning. When needed and decided by the SDK, hashes and names of files and applications are sent anonymously to the cloud service for processing.	No personal identifiable information is collected and sent as part of this process.
Android Applications	Our Antivirus and Security applications require permission to iterate all installed applications on the device to verify if the applications are malicious or not. Only applications bundle IDs are collected and evaluated.	No personal identifiable information is collected and sent as part of this process.
Payment Details: Following the Installation Process, and subject to your Plan's selection, you may be requested to provide us with your contact and payment details including name, email address, country, and credit card details.	We use this information for billing purpose, for the purpose of enabling you to use the Services. We use Paddle (“Paddle”) as a third-party payment processor to process this information. Consequently, any transactions that are processed by Paddle will be governed by its privacy policy and terms which we recommend that you review.	We process this information for the purpose of performing our contract with you.
Contact Details In the event you contact us with any inquiries, through any means of communication, you will be requested to provide us with certain information such as name, email address, company name (if applicable), and as applicable, your inquiry ("Contact Details").	We will use your Contact Details solely for the purpose of responding to your inquiries. Please note that our correspondence with you may be processed in the event we believe it is required (i.e. provide you further assistance, support, enhance our services, etc.).	We process this Contact Details subject to our legitimate interest.
Career In the event you apply for a job via our website, we will process your CV (and the information included therein), as well as additional information you decide to provide such as your contact information (name, email address, and phone number,).	We will use such data to process your job application and for our internal recruitment management purposes, for further recruitment steps (e.g., interview), and to enable us to comply with corporate governance and legal and regulatory requirements. Following the completion of the recruitment process, we may further retain and store the data (including other interactions with us under such process) as part of our internal record keeping, including for legal defense from any future claim, as well as, where we find applicable and subject to applicable law requirements, to contact you in the future for other job position we believe will suit your qualifications. If you are hired by us, your data may be used in connection with your employment and our corporate management.	We process such information subject to our legitimate interest. Please note, in the event, you send us your CV, your provision of Personal Data in connection with recruiting is voluntary, and you determine the extent of information you provide us. We do not request or require sensitive personal data concerning religion, health, sexual orientation, or political affiliation in connection with recruiting.
Newsletter In the event you sign up to receive our newsletter or other marketing materials, you will be requested to provide your contact details, such as your email address.	We will use this information solely in order to provide you with the content that you have requested to receive.	We process such contact information subject to your consent. You may withdraw consent at any time through the “unsubscribe” link within the email you will receive or by contacting us directly at: [email protected]

We use various technologies to collect and store the information listed above, including cookies, pixel tags, local storage, database and server logs. We use different technologies to process your information listed above, for the purposes listed above.

Please note that the specific processing operation that we perform may vary depending on the purpose of use and lawful basis detailed in the table above. Such processing operation usually includes a set of operations, made by automated means, such as collection, storage, use, disclosure by transmission, erasure or destruction. We may also transfer your Personal Data to third-party countries as further detailed in the "Cross Border Data Transfer" section. The data transfer will be based on the applicable lawful basis as set in the table above.

In addition, we may process the Personal Data to prevent potentially harmful and illegal activities, such as fraud, identity thefts, infringements, and any other misuse of our Software and Services. Moreover, we may use the Personal Data in order to enforce the EULA, as well as protect the security or integrity of our databases and systems. The processing of Personal Data for the above purposes, is subject to our legitimate interests.

Data Sharing

We will share Personal Data collected solely in the events detailed below.

Category Of Recipient	Data That Will Be Shared	Purpose Of Sharing
Service providers	All types of Personal Data	We work with other companies and individuals to help us provide our services ("Third-Party Service Providers"), for conducting the following services: marketing and sales services, analyzing data, outsource consultants, sending communications, advertising services, identifying errors and crashes, training services, etc. According to our agreement with these Third-Party Service Providers, they may have access to your Personal Data, but they are only allowed to use it to provide us with the requested services, and prohibited, from using your Personal Data for any other purposes. Mixpanel and Microsoft PowerBI are 2 examples of Fortect Service providers. Mixpanel's ability to use and share information is governed by the Mixpanel Terms of Use, available at https://mixpanel.com/terms/, and the Mixpanel Privacy Policy, available at https://mixpanel.com/privacy/. Microsoft PowerBI terms of use can be found here https://powerbi.microsoft.com/en-us/api-terms/
Any acquirer of our business	All data	We may share Personal Data, in the event of a any change in the Company control, including by means of merger, acquisition, purchase of all assets, etc. In such event the parties involved in such transaction will assume the rights and obligations as described in this Privacy Policy.
Affiliated Companies	All data	We may share your Personal Data with our affiliated companies, for operation purposes such as, sales, marketing and financial purposes.
Governmental agencies, law enforcements or authorized third parties	All types of data	In exceptional circumstances, we may disclose or allow government and law enforcement officials access to your personal data, in response to a subpoena, or other court order, or in compliance with applicable laws and regulations. Such disclosure or access may occur if we believe in good faith that: (a) we are legally compelled to do so; (b) disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity; (c) such disclosure is required to protect the security or integrity of our Software and Services; or (d) such disclosure is appropriate or required in order to protect the rights, property, or security our users or others.

When we share information with services providers and partners, we ensure they only have access to such information that is strictly necessary for us to provide the Services. These parties are required to secure the data they receive and to use the data for pre-agreed purposes only while ensuring compliance with all applicable data protection regulations (such service providers may use other Non-Personal Data for their own benefit).

Cookies And Similar Tracking Technplogies

The usage of our Software and Services may include implementation of “cookies'' or similar technologies, within the Software and Services.

Cookies are used for many different purposes, including, and not limited to provide the Services and functionalities for users. Cookies enable you to improve your experience while using the Software and interacting with the Services. See more information about cookies at: www.allaboutcookies.org.

Cookies opt-out

You are able to manage your cookies preferences, including the deletion of cookies, approval or decline of certain cookies, and receive notification prior to the store of a cookie. This can be done through your browser’s settings. For more information please review the below links (click according to the browser you are using):

Third party's cookies which are embedded in our Software and Services shall be subject to the applicable third party’s cookie policy. Blocking or erasing certain types of cookies may limit your online experience. Furthermore, disabling cookies will not prevent advertisements from being displayed, however the advertisements will not be personalized.

Cross Border Data Transfer

We may store or process the Personal Data we collect in different territories, including Amazon Web Services based in the United States and therefore any information you share with us may be transferred to and processed in various countries, which may also be different than the country from which you accessed the Software and Services. In such event, we will comply with the law requirements to ensure that your Personal Data receives an adequate level of protection upon its transfer. Notwithstanding the foregoing, where we transfer Personal Data that was collected within the, outside the EEA, we will take appropriate measures to protect the Personal Data and ensure that during the transfer sufficient safeguards are provided, such as pursuant with the EU standard contractual clauses as approved by the European Union (SCCs).

Security Measures

We work hard to protect the Personal Data we process from unauthorized access, alteration, disclosure, or destruction. We have deployed various measures in order to ensure that the Software and the Services will be protected, and in order to comply with applicable laws and industry, such as encryption using SSL, we minimize the amount of data that we store on our servers, restricting access to Personal Data to only those who have a need to know. Note that we cannot guarantee that unauthorized or unintended access to the data will not occur, and we cannot be held responsible for such cases. We make no warranty, express, implied, that we will be able to prevent such access.

If you believe that your privacy rights has been mishandled, or if you become aware of any unauthorized attempt by a third party to access your Personal Data, please reach out to us at [email protected]. In the event of a security incident involving your Personal Data, we will make reasonable efforts to notify you and, if required by applicable law, to the appropriate authorities.

Data Retention

We retain your Personal Data we collect for as long as it is necessary for the aforementioned purposes, all in accordance with applicable laws, or until an individual requested to opt-out.

There are additional circumstances where we may retain your Personal Data for extended periods, such as: (i) fulfilling legal, regulatory, tax, or accounting obligations; (ii) maintaining an accurate record of your interactions with us for handling complaints or disputes; or (iii) if we believe there is reasonable possibility of litigation involving your Personal Data. Please note that unless required by law, we may at our sole discretion, delete or modify information from our systems, without prior notice once we determine it is no longer necessary for the stated purposes.

Your Rights

We acknowledge that each person has different concerns and preferences relating to its Personal Data. Our goal is to be transparent about the information we collect, so each person will have the opportunity to make informed decisions regarding how its data is used.

Depending on the interaction with us, each user may have different rights regarding its Personal Data, including (and depending on user's jurisdiction and the applicable privacy law): (i) The right to access your processed Personal Data; (ii) The right to ensure he accuracy, completeness, and currency of your Personal Data; (iii) The right to request amendments to your Personal Data (correction, deletion, or addition of information); (iv) The right to object to the processing of your Personal Data, where applicable; (v) The right to transfer or “port” your Personal Data; (vi) The right to withdraw consent, subject to legal or contractual restrictions and reasonable notice; and (vii) The right to file a complaint to supervisory authority in applicable jurisdiction, etc.

You may exercise any or all of your above rights in relation to your Personal Data by filling out the Data Subject Request (“DSR”) form available here.

Please note that:

We may request additional information from you when you contact us in order to verify your identity and locate your data.
It may take time to process requests in a way that is consistent with applicable privacy law.
We may reject your request in case you don't provide required information or according to applicable law.

Childrens’ Data

The Software and Services are not directed to children (as defined by applicable data privacy laws). We do not knowingly collect Personal Data from children and do not wish to do so. If we learn that a child is using our Software and Services, we will immediately upon discovering it, discard any information we receive from such user. Please contact us at: [email protected] if you believe that a child has shared any information with us.

Changes And Amendments

We reserve the right to modify this Privacy Policy periodically, solely at our sole discretion. The latest version of the Privacy Policy will always be available on the website, with the “Last Modified” heading, indicating the most recent update. In the event of significant changes that may affect you, we will notify you accordingly and, if required by applicable law, obtain your consent. Any amendments to the Privacy Policy will take effect within 30 days of the revised Privacy Policy being displayed. We encourage you to regularly review this Privacy Policy to stay informed about our latest privacy practices.