We at ElQuench, including our affiliates (“Ultimate System Care”, “we”, “us”, “our”), care deeply about privacy, security, and online safety, all of which are a significant part of our essential mission: to protect users of our products and services (“you” and “your”) from the risks of theft, disruption, and unauthorized access to their online information and activities. This Privacy Policy (“Notice”) is designed to inform you about how ElQuench collect, use, and share your personal data through our website (our “Site”), products, services, and web-based and mobile applications (collectively, the “Services”) or when you interact with us.

When you access or use our Services, you acknowledge that you have read this Notice and understand its contents. Your use of our Services and the Site and any dispute over privacy is subject to this Notice, any applicable Terms of Service (including any applicable limitations on damages and the resolution of disputes), and any applicable End User License Agreement.

As ElQuench grows, our business changes, and we may update this Notice at any time as we deem appropriate to reflect those changes. If there are any material changes to this Privacy Notice, we will notify you by email, in-product notification, or as otherwise required by applicable law. It is important that you check back and make sure that you have reviewed the most current version of this Notice.

This policy applies to ElQuench products and services. Please note, there may be clauses below that do not apply to your use of our website or services.

1. Our Policy’s Aims

1.1 The Privacy Policy applies to Ultimate System Care and unless specified, its subsidiaries, contractors, representatives, agents, and resellers while they are working on our behalf (collectively “we,” “us” or “our”).

1.2 Our Privacy Policy explains the processing of your personal data by us and establishes what information we collect, or which is provided to us, and how we use and protect your personal data in compliance with applicable law.

1.3 Personal data refers to any information relating to an identified or identifiable natural person (“data subject”), where this identification can be made directly or indirectly, by means of identifiers such as your name, identification number, email address, phone number, online identifiers such as cookies in some circumstances, your location, your genetic, economic, cultural or social identity, or other information that is specific to you.

1.4 We do not mean information that only refers to a business corporation or organization. We also do not mean information that has been “anonymized,” either by removing or de-identifying all specific identifiers. Anonymous data is not personal data when the anonymization is irreversible. When we refer to anonymous data, we mean data that cannot be reversed into personal data.

1.5 As a data controller, ElQuench commits itself to protect the privacy of our website visitors and users of our products and services with respect to the processing of your personal data.

1.6 Where we collect and process your personal data, we will limit the collection and retention to what is adequate, relevant, and necessary for our purposes and it will be kept in a form that allows for your identification no longer than necessary for the purpose for which we process your personal data. We refer to this as data minimization.

1.7 Where we store your personal data for longer periods for statistical purposes, as permitted, we will use appropriate safeguards. Applicable law defines ‘statistical purpose’ as any collection of personal data, where the result of processing is for aggregate data, so the personal data we collect from you is anonymized or pseudonymized. For example, the processing of your personal data may be for the business-related process of counting users, products, sales, and various metrics. We also share statistical data that has been anonymized and aggregated geographically and so, cannot be used to identify individuals, with third parties for trend analytics.

1.8 Our policy provides you with the legal bases for the collection of your personal data, lets you know how long personal data is stored and the reasons why, and how in some circumstances, they are necessary to retain. The length of this retention and how you may choose to request that we delete some or all your personal data and the consequences of the deletion are explained in this policy.

1.9 Some of the legal bases we rely on are contractual and service necessity, consent, legitimate interests, and compliance with legal obligations.

1.10 We want you to have the necessary and relevant understanding of how and why we process your personal data so that you can make fully informed decisions on whether to allow us to retain your personal data or delete it.

1.11 We strive to keep the policy easy to understand and transparent, and so we refrain from technical information overload. If you wish to have further details on how we process your personal data, please contact us.

2. Talk to Us about Your Data

2.1 We try to ensure that the users of our products and services always have an open line of communication with us. You can contact us at any time if you have any questions, queries, or requests about your personal data. You have the right to complain to supervisory authorities, should you feel your privacy has been breached, however, we would appreciate it if you reach out to us first before you approach any supervisory authorities or courts. You may submit requests to us at info@ultimatesystemcare.net. We will action your request within 15-days of receiving a request from you concerning any one of your rights as a data subject. Should we be inundated with requests or particularly complicated requests, the time limit may be extended to a maximum of one month. If we fail to meet these deadlines, we would, of course, prefer that you contact us to settle the matter informally.

2.2 We process your personal data where it is lawful and fair for us to do so. The legal bases we rely upon processing your personal data are a contractual necessity, consent, legitimate interests, and compliance with legal obligations.

2.3 There could be instances where you are using our products or services, but we do not have your personal data, even though you have purchased our products or services. These include situations where you purchase our products from our service provider, a reseller, or an app store. Because your relationship in these cases is with that service provider, reseller, or app store, we do not actually have your personal data and will not be able to perform your request to access or delete your information. In such circumstances, please contact your service provider, reseller, or app store where you purchased the products or services, as this person is the primary controller of your personal data.

3. When Does Our Privacy Policy Apply

You should know that our Privacy Policy applies to the following situations and activities:

3.1 Online Activities

Any personal data collected from you when you visit our websites or use our products or services.

3.2 Phone Contacts

Any personal data collected from you when you call us for sales, service, or customer support.

3.3 Offline Contacts

Any personal data collected from you at a “live” or in-person events such as a trade show or promotion.

3.4 Reseller Information

Any personal data, including contact information such as telephone number and email address, collected from our resellers or sub-resellers.

3.5 Other Circumstances

Any personal data collected from you when you contact us by email or by clicking the “report a virus” link on our website or by requesting online service or support or opening a support ticket, or through our media contact or news subscription services, or other occasions.

4. When Does Our Privacy Policy Not Apply

4.1 Third-Party Sites

• Clicking on a thumbnail or profile link on our “Community” pages

This will take you to the third-party site from which the thumbnail or link was imported. By using a user ID from a third-party site, you agree to be governed by the terms and conditions, privacy policy, and data security policy of the third party. You also agree that we are not responsible for any loss or damage you may suffer from your dealings with the third party, or your use of or reliance on any of that party’s content.

• Submitting a search query

When you submit a search query through Ultimate System Care Browser, you are indicating that you consent to have your search query and history transmitted to third party search providers and to being redirected to third-party sites, where the privacy policies of the third parties apply.

• Third-party Links

Third parties may also provide links to other websites and mobile applications (apps). Any sharing of data with third parties through access to and use of third-party advertisements, their linked websites, or mobile apps is not governed by this privacy policy but instead is governed by the privacy policies of those third parties.

• Third-party Privacy Practices

We are not responsible for the privacy practices of third parties. Your use of a third-party site will be governed by the terms and conditions, privacy policy, and data security policy of the third-party site.

5. Disclosing Your Personal Data to Third Parties

5.1 Disclosure to Third Parties

We are required to disclose your personal data to unrelated third parties in limited circumstances:

• Where necessary to satisfy a legitimate government request or order;
• In compliance to a legal requirement by a court of law or in the public interest;
• In response to a third-party subpoena, if we believe on the advice of our attorneys that we are required to respond;
• Where we hire a contractor to perform a service for us, such as product development or market research (but not if doing so would violate the terms of our privacy policy, or laws governing personal data);
• If we obtain your permission; or
• If necessary to defend ourselves or our users (for example, in a lawsuit).

5.2 We are also required in a few limited situations to share our users’ personal information with third parties. For example, if you request a specific service or product from us, and if that product or service is administered by a third party working for us, we may share your personal information with the third party to respond to your request. This third party may also transmit back to us any new information obtained from you in connection with providing the service or product.

5.3 When you contact us or a third-party service provider working on our behalf, our service provider may suggest upgrades to our products or services. Our service provider may also suggest products or service that the service provider offers which are not our products or services. In this case, you will be clearly advised that the product or service is offered by the third party and not by Ultimate System Care, and you will be subject to the terms and conditions, end user license agreement (EULA), and privacy policy of the third-party service provider.

5.4 We offer third-party browsers to new users of certain products, such as our antivirus products.

5.5 We reserve the right to store and use the information collected by our software. We may publish or share that information with third parties that are not part of the Ultimate System Care, but we will only ever do so after anonymizing the data.

6. Sharing of Information Among Ultimate System Care Entities

6.1 Our data collection and management practices do not vary by location. We follow the same “data minimization” procedure with respect to all personal data in our possession, regardless of the jurisdiction from which it was collected, and regardless of whether the data is transferred from one member of the Ultimate System Care Group to another.

6.2 We reserve the right to store and use the information collected by our software and to share such information among the Ultimate System Care Group to improve our current and future products and services, to help us develop new products and services, and to better understand the behavior of our users.

6.3 Any reference in this policy to “ Ultimate System Care Group” means ElQuench, its, direct and indirect, parent companies, and any company that is, directly or indirectly, controlled by or under common control with ElQuench or its parent companies.

7. Storage, Retention, and Deletion of Your Personal Data

7.1 Storage of Information

We store information that we collect on our servers or on the servers of our subsidiaries, affiliates, contractors, representatives, contractors, agents, or resellers who are working on our behalf.

The data on our servers can only be accessed from our physical premises, or via an encrypted virtual private network (“VPN”). Access is limited to authorized personnel only, and company networks are password-protected and subject to additional policies and procedures for security.

7.2 Access by Our Contractors

We or our contractors, subsidiaries, affiliates, representatives, agents, or resellers who are working on our behalf undertake regular maintenance of your personal data. All third parties must agree to observe the privacy of our users and to protect the confidentiality of their personal information. This means your personal data cannot be shared with others, and there must be no direct marketing by third parties.

7.3 Retention and Deletion of Your Personal Data

We retain and delete the various types of personal data we collect in compliance with the legal requirement that personal data be kept in a form that permits identification of our data subjects for no longer than is necessary for the purposes for which the personal data is being processed.

We will not keep your personal data in a form that allows you to be identified for longer than reasonably necessary with regard to the purpose for which the information was collected. We will also anonymize and aggregate data to the extent possible.

In general, we strive to delete or obfuscate Internet Protocol (IP) addresses within 60 days when the purpose for which they were collected has been fulfilled. We may retain online identifiers, location data, and other personal data for statistical purposes as permitted under applicable law.

We may also amend the personal data we keep in such a way that you cannot be identified, for example, by hashing. We may retain a “key” to the hashing, but we will securely store it separately from the hashed data.

We will only keep your personal data for additional periods following the expiration of the purpose for which we collected it when permitted as compatible for our legitimate interests or required by law, for example, tax, contract, secrecy, or criminal laws. Otherwise, your personal data will be automatically deleted from our system once the legal basis for the collection and processing has been fulfilled.

If you are an active paid user, we need to retain your personal data for mailing or billing purposes. If you subscribe to a recurring newsletter, we will keep your information to continue to fulfill your subscription request. In the case of Ultimate System Care Forum, Support Portal, or Ultimate System Care news and blogs, your account data is kept active until you delete it.

If you participate in a giveaway or promotion that we offer, we will retain your data long enough to administer the promotion, plus any additional time that is permitted or required by law.

For the purpose of licensing products that are registered on a periodic basis, we will keep your personal data on the legal basis of contractual necessity for as long as you are actively using the product and thereafter for legal compliance. Thereafter, your personal data will be deleted.

8. Data Security

8.1 Ultimate System Care takes reasonable steps to ensure that your Personal Data is properly secured using appropriate technical, physical, and organizational measures so that they are protected against unauthorized or unlawful use, alteration, unauthorized access or disclosure, accidental or wrongful destruction, and loss.

8.2 We take steps to limit access to your Personal Data to those persons who need to have access to it for one of the purposes listed in this Privacy Statement. Furthermore, we contractually ensure that any third party processing your Personal Data equally provides for confidentiality and integrity of your data in a secure way.

9. Policy Changes

9.1 Updates to our Privacy Policy will occur from time to time and we will publish these changes on our website.

9.2 We suggest that you check our Privacy Policy every so often to keep yourself informed.

9.3 Where the changes are major, we will notify you by email if you have an Ultimate System Care account or through posts on our website.

10. Contacting Us

10.1 If you have any queries about this Privacy Statement or our handling of your Personal Data in general, or if you want to exercise your rights, please email us at info@ultimatesystemcare.net and be sure to indicate the nature of your query.