Effective date:  Jan 18, 2024

This Notice provides information about data we collect, use, and share, and our commitment to using the personal data we collect in a respectful fashion. 

We at iPrivacyLab, CO., including our affiliates (“iPrivacyLab”, “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 Notice (“Notice”) is designed to inform you about how we collect, use, and share your personal data through our website (our “Site”), products, services, and desktop applications (collectively, the “Services”) or when you interact with us.

iPrivacyLab sells products and services directly to consumers (you can find more information about those products here: https://iPrivacyLab.com/products/). This Privacy Notice applies both to the information we collect from you or your device when you download one of our Services and to the information we collect when one of our distribution partners installs our Services on your device.

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 iPrivacyLab 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 Notice applies to all users of our Services across the world. Some users, including residents of the European Economic Area, may have additional rights depending on where they are located, which are described in this Notice.

What Kinds of Information Do We Collect?

In order to provide our services, we collect information. Some information you provide directly to us, some we collect automatically through our Services, and some is collected from third parties. In this Notice, “Personal Data” refers to data that could be used, alone or in combination with other data, to identify you as an individual.

We collect information you provide to us . For example, we collect information when you purchase a product or service, create an account, fill out a form, participate in a contest or promotion, request customer service, or otherwise communicate with us.

The types of Personal Data you may provide include:

• Contact information (such as name, email address, mailing address, and phone number);
• Payment information (including payment card numbers and associated identifiers, billing address, and bank account information);
• Pictures you may choose to upload to the Services, such as profile pictures or “avatars”; and
• Account log-in credentials (which for some Services may include social network credentials).

We may also collect other information from or about you, such as information about what products you purchased, your interests, and demographic information. You may also provide us with additional data. For example, when you use our identity monitoring services, you will have the option to provide your social media log-in information so that we can monitor your social media accounts, or as further set out in the specific products and features below.

We automatically collect information about your interactions with the Services as well as devices on which the Services are installed. In some cases, we automatically collect information about other devices connected to the same network as the device on which the Services are installed.

For example, we may collect and use the following:

• Information about the products you looked at or searched for and the Services you used, including time spent and other statistical information.
• Details about your computers, devices, applications, and networks, including internet protocol (IP) address, cookie identifiers, mobile carrier, Bluetooth device IDs, desktop device ID, mobile advertising identifiers, MAC address, IMEI, Advertiser IDs, and other device identifiers that are automatically assigned to your computer or device when you access the Internet, browser type and language, language preferences, battery level, on/off status, geo-location information, hardware type, operating system, Internet service provider, pages that you visit before and after using the Services, the date and time of your visit, the amount of time you spend on each page, information about the links you click and pages you view within the Services, and other actions taken through use of the Services such as preferences. We may collect this information through our Services or through other methods of web analysis.
• When you use our products to protect your desktop device, we collect geolocation data of the device on which the product is installed.
• Details about your internet, app, or network usage (including URLs or domain names of websites you visit, information about the applications installed on your device, or traffic data); and performance information, crash logs, and other aggregate or statistical information.
• Contents of SMS messages, in order to identify phishing attempts and other potential threats.

In order to provide you with our Services, including to detect and evaluate malware and spam, we may scan, collect, and store data from your files, including emails, attachments, email addresses, metadata, and URLs and traffic data.

We collect this information through our Services and through technologies such as cookies, web beacons or web bugs, and clear GIFs. Please see our Cookie Notice by contact [email protected] for more information about the cookies and similar technologies that we use and the choices available to you.

Specific Products and Features

In addition to the above, we also collect additional data if you choose to use one of the products or features listed below.

• Personal Data Cleanup . If you choose to use this feature, we will regularly scan a list of publicly available data broker sites and tell you which have your data so that you can take steps to try to remove it. To provide you with this service, we will collect addresses, phone numbers, email addresses, the names of your relatives, and information related to your education and employment, if this information is available on those sites. We only collect this data to display to you and will delete it if your subscription expires and you choose not to renew.
• Online Account Cleanup. If you choose to use this feature, we or our service provider, acting on our behalf, will use the Personal Data we collect from you (your email address and the name associated with that email address) to access information from your email in order to find online accounts associated with your email address and help you delete them. The information we collect includes the subject line of emails, sender’s email address, timestamps of email messages received related to the online accounts, the existence of email attachments, and the first line of the email message as presented in your mailbox. We do not otherwise process or collect the content of any email message in your mailbox during this process, nor do we collect any email messages. We will not disclose the information we access in your email mailbox. In some cases, we may use the specific interactions between you and the online account companies with regard to your deletion requests (in a redacted form and without any Personal Data) to train our personal data assistant, so we can provide you with better suggested answers for the deletion request.
• Account Protection – Safe Cards. [This service is provided to you by our trusted service provider. They will collect your name, address, and date of birth in order to verify your identity.] Our payment processors will also collect and store the payment card information you choose to use as the funding source for your safe cards, as well as information related to the safe cards that you generate. For more information on safe cards, please see our Account and Payment Protection Terms of Service, which can be found under Product Terms of Service.
• Information We Collect from Third Parties. We may receive information about you from other sources and combine that information with the information we collect directly. Examples of information we may receive from other sources include: updated delivery or payment information used to correct our records; purchase or redemption information; and customer support and enrolment information. For our identity protection Consumer Products, we also may collect credit or identity information which we use to help prevent and detect fraud.

Location Information

Certain Services may request permission to access your location. Where you grant this permission, we will collect information about your location using GPS, wireless, or Bluetooth technology. You can control access to precise location information through your desktop device settings. We also may look up your IP address to determine your general location.

How Do We Use the Information We Collect?

To Help Protect You. When you install or use one of our Services, it will run in the background of your device or environment to help predict threats and better protect you, your devices, and your information. For example, iPrivacyLab may use information to:

• Analyze data sent to/from your device(s) to isolate and identify threats, vulnerabilities, viruses, phishing attempts, suspicious activity, spam, and attacks, and communicate with you about potential threats;
• Participate in threat intelligence networks, conduct research, and adapt products and services to help respond to new threats;
• Encrypt your data, lockdown a device, or back-up or recover your data;
• Check for Service updates and create performance reports on our Services, to ensure they are performing properly; and
• Look for misuses of your data when you use our identity monitoring products.

To Run Our Business. We also use the information we collect for other business purposes, including to:

• Authenticate your identity and prevent fraud with the use of a validation from third party biometric authentication resident on your device;
• Analyze your behavior to measure, customize, and improve our Site and Services, including developing new products and services;
• Advertise iPrivacyLab products and services that we think may be of interest to you;
• Establish and manage accounts and licenses, including by collecting and processing payments and completing transactions;
• Provide customer support, troubleshoot issues, manage subscriptions, and respond to requests, questions, and comments;
• Communicate about, and administer participation in, special events, programs, surveys, contests, sweepstakes, and other offers and promotions;
• Conduct market and consumer research and trend analyses;
• Enable posting on our blogs, forums, and other public communications;
• Perform accounting, auditing, billing, reconciliation, and collection activities;
• Prevent, detect, identify, investigate, and respond to potential or actual claims, liabilities, prohibited behavior, and criminal activity; and
• Comply with and enforce legal rights, requirements, agreements, and policies.
• Cookies are used to record your interactions with our Site.

Artificial Intelligence

In some cases, we use artificial intelligence (“AI”) to provide services to our customers, assist our developers in creating new services and products, and provide customer support for our services. The AI features use the information we collect to improve the services we provide to you, or to improve the support we provide to you in connection with our services.

Third-Party Advertising. We work with third-party advertising companies to display or deliver ads to you while you are on our Site or using some Services. These third-party advertisers may collect data about your interaction with the Site or Services or others’ sites or services to measure the effectiveness of their ads and to personalize advertising content. See our Cookie Notice to learn more about how iPrivacyLab and these advertising partners use tracking technologies like cookies and the choices available to you. You may opt out of targeted advertising by completing our Individual Data Request form and selecting “I would like to Opt Out of iPrivacyLab selling or sharing my personal data”.

If you have consented to allow our Services to access to your location, our mobile advertising partners may use your location to target advertisements to you. You may use the location settings on your device to withdraw access to information about your location.

Other Uses. We may use Personal Data for which we have a legitimate interest, such as direct marketing, individual or market research, anti-fraud protection, or any other purpose disclosed to you at the time you provide Personal Data or with your consent.

Who Do We Share Personal Data With?

Generally, we disclose the information we collect to provide the Services, to communicate with you, to advertise or promote our Services, to facilitate changes to or transfers of our business, as required by law, or with your consent. We may share Personal information in the following ways:

• With current and future members of the iPrivacyLab family of companies for the purposes described in this Notice;
• With service providers who perform services for us (the list of our sub-processors for Consumer Products is available upon request where required under applicable laws)
• If we believe disclosure is necessary and appropriate to prevent physical, financial, or other harm, injury, or loss, including to protect against fraud or credit risk;
• To legal, governmental, or judicial authorities as instructed or required by those authorities and applicable laws, or in relation to a legal activity, such as in response to a subpoena or investigation of suspected illicit or illegal activities, or where we believe in good faith that users may be engaged in illicit or illegal activities, or where we are bound by contract or law to enable a customer or business partner to comply with applicable laws;
• In connection with, or during negotiations for, an acquisition, merger, asset sale, or other similar business transfer that involves all or substantially all of our assets or functions where Personal Data is transferred or shared as part of the business assets (provided that such party agrees to use or disclose such Personal Data consistent with this Notice or gains your consent for other uses or disclosures);
• With your consent or at your direction, such as when you choose to share information or publicly post content and reviews (for example, social media posts); and
• With persons of your choosing and at your discretion, if the product you are subscribed to allows that functionality.
• We may also share aggregate data that does not identify you or any specific device with third parties.

How Do We Protect Your Data?

We use administrative, organizational, technical, and physical safeguards to protect the Personal Data we collect and process. Our security controls are designed to maintain data confidentiality, integrity, and an appropriate level of availability.

What Choices Do You Have About Your Personal Data?

iPrivacyLab Accounts. If you register a iPrivacyLab Consumer Product, you can access and correct the Personal Data in your profile at any time by logging into your account, or contacting us as described below.

If you have not registered a iPrivacyLab product but one of our products is installed on your device, you may stop iPrivacyLab’s collection of Personal data from your device by uninstalling that product.

To close your account and for other support questions, please visit the iPrivacyLab Customer Service page at https://iprivacylab.com/support-and-feedback/, we’re always ready to offer you the best assistance and service!

Marketing Communications. To stop receiving marketing communications, click on the unsubscribe link in the email you receive from iPrivacyLab to unsubscribe from marketing communications.

If you choose to no longer receive marketing information, iPrivacyLab may still communicate with you regarding transactional, legal or administrative topics, such as security updates, product functionality, and service requests.

Individual Rights in Personal Data

In accordance with applicable law, you may have the right to: (i) request confirmation of whether we are processing your Personal Data; (ii) obtain access to or a copy of your Personal Data; (iii) receive a portable copy of your Personal Data, or ask us to send that information to another organization (the “right of data portability”); (iv) seek correction or amendment of inaccurate, untrue, incomplete, or improperly processed Personal Data; (v) restrict our processing of your Personal Data; (vi) object to our processing of your Personal Data; and (vii) request erasure of Personal Data held about you by us, subject to certain exceptions prescribed by law.

For US residents, depending on applicable laws in your state of residence, you may request to: (1) confirm whether or not we process your personal information; (2) to access, correct, or delete personal information we maintain about you; (3) to receive a portable copy of such personal information; (4) to restrict or opt out of certain processing of your personal information, such as targeted advertising, sale of personal information, or profiling in furtherance of decisions that produce legal or similarly significant effects; and/or (5) to appeal our decision in response to your request. We will respond to your request consistent with applicable law. If you wish to appeal our response, please reach out to us at [email protected], and we will respond in accordance with applicable law. If you are a California resident, please refer to our California Consumer Privacy Act (CCPA) Addendum at the end of this Privacy Notice for additional information that we are providing to you in accordance with the CCPA.

If you would like to exercise any of these rights, please email us at [email protected]. We will process such requests in accordance with applicable laws. To protect your privacy, we may take steps to verify your identity before fulfilling your request, which we do by using the information you provide to us in the Individual Data Request Form. For some requests and where permitted by law, an administrative fee may be charged. We will advise you of any applicable fee prior to performing your request.

How Long Does iPrivacyLab Retain the Personal Data it Collects?

iPrivacyLab will keep your Personal Data for the minimum period necessary for the purposes set out in this Notice, namely (i) for as long as you are a registered subscriber or user of our products or (ii) for as long as your Personal Data are necessary in connection with the lawful purposes set out in this Notice, for which we have a valid legal basis or (iii) for as long as is reasonably necessary for business purposes related to provision of the Services, such as internal reporting and reconciliation purposes, warranties or to provide you with feedback or information you might request.

In addition, if any relevant legal claims are brought, we may continue to process your Personal Data for such additional periods as are necessary in connection with that claim.

Once the abovementioned periods, each to the extent applicable, have concluded, we will either permanently delete, destroy, or de-identify the relevant Personal Data so that it can no longer reasonably be tied to you.

Data Transfers

iPrivacyLab is headquartered in the United States (see Contact Us for addresses), and we have operations, entities, and service providers in the United States and throughout the world. As such, we and our service providers may transfer your Personal Data to, or store or access it in, jurisdictions that may not provide equivalent levels of data protection as your home jurisdiction. We will take steps to ensure that your Personal Data receives an adequate level of protection in the jurisdictions in which we process it.

Residents of the European Economic Area and the United Kingdom

If you are in the European Economic Area (EEA) or the United Kingdom (UK), the following additional disclosures apply.

Data Controller. Where you purchase or download one of iPrivacyLab’s consumer products, iPrivacyLab Ireland Limited acts as the Controller of your Personal Data.

Legal Basis for Processing. When we process your Personal Data, we will only do so in the following situations:

• We need to use your Personal Data to perform our responsibilities under our contract with you (e.g. processing payments for and providing the Services you purchase or request).
• We have a legitimate interest in processing your Personal Data. For example, we have a legitimate interest in processing your Personal Data to provide, secure, and improve our Services, in communicating with you about changes to our Services, and in informing you about new services or products.
• We have your consent to do so.
• We need to process your Personal Data to comply with our legal obligations.

Data Transfers. We transfer Personal Data to countries outside of the EEA or Switzerland through a series of intercompany agreements based on the Standard Contractual Clauses in accordance with EU law and applicable EU regulations.

Individual Rights Requests and Withdraw Consent. You may submit a request to exercise your rights in Personal Data using the mechanisms explained under “What Choices Do You Have About Your Personal Data?” above. If you initially consented to our processing of your Personal Data, you may withdraw your consent using those mechanisms or by contacting us using the contact information below.

Supervisory Authority and Complaints. If you are an EU/EEA Data Subject and have a concern about our practices concerning the processing of Personal Data that we are not able to resolve, you have the right to lodge a complaint with the data protection authority where you reside or in which you work, or in which the alleged infringement occurred, each as applicable, or by contacting the Irish supervisory authority for data protection issues. If you are a UK Data Subject, you have the same rights and may exercise them by contacting the UK Information Commissioner.

Residents of Japan, Argentina, and Canada

If you are a resident of Japan, Argentina, or Canada and you have an inquiry regarding your personal information held by iPrivacyLab, including your personal information collected through your use of our products you may request further information using the Individual Data Request Form.

Residents of California

Your California Privacy Rights – Shine the Light Law

iPrivacyLab does not share information that directly identifies you personally with non-affiliated third parties for non-iPrivacyLab marketing use without your permission.

Please refer to our California Consumer Privacy Act (CCPA) Addendum at the end of this Privacy Notice for additional information that we are providing to you in accordance with the CCPA.

Residents of Nevada

iPrivacyLab does not “sell” information that identifies you personally with non-affiliated third parties as the term “sell” is defined under Nevada law. If you would like to make a request that we not sell identifying information about you in the future, you may make a request using the contact information below.

Public Notice for Transfer of Personal Information

For more details of transfer of Personal Information, please review our public notice on the transfer of personal information, or email us [email protected].

Links to Other Websites

Our Site and Services may contain links to other websites for your convenience and information. These websites may be operated by companies not affiliated with iPrivacyLab. Linked websites may have their own privacy policies or notices, which we strongly suggest you review if you visit those websites. We are not responsible for the content, privacy practices, or use of any websites that are not affiliated with iPrivacyLab.

Contact Us

Click https://iprivacylab.com/support-and-feedback/ to contact us regarding this Privacy Notice or other related Privacy issues or email us [email protected]

California Consumer Privacy Act Addendum

Pursuant to the California Consumer Privacy Act, as amended by the California Privacy Rights Act (“CCPA”), we provide this California Consumer Privacy Act Addendum (the “CCPA Addendum”) to California residents (“consumers” or “you”). This CCPA Addendum supplements the information contained in our Privacy Notice. Any capitalized term used but not defined in this Notice has the meaning given in our Privacy Notice.

This CCPA Addendum does not apply to information we collect about individuals in their capacity as present or former job applicants, employees, contractors, owners, directors, or officers of iPrivacyLab.

Categories of Personal Information

Under the CCPA, “Personal Information” is information that identifies, relates to, or could reasonably be linked with a particular consumer or household. “Personal Information” does not include publicly-available information, deidentified or aggregated information, or information covered by certain sector-specific privacy laws. “Sensitive Personal Information” refers to information that reveals a consumer’s social security, driver’s license, state identification card, or passport number; account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; precise geolocation; racial or ethnic origin, religious or philosophical beliefs, or union membership; contents of mail, email, and text messages unless iPrivacyLab is the intended recipient of the communication; genetic data; and biometric information.

Sources of Personal Information

We obtain the categories of Personal Information listed above (including Sensitive Personal Information) directly from you or from devices on which Services are installed as well as from the following categories of sources: our corporate affiliates, publicly-available databases, third-party business partners, social media sites, and other third-party sources.

Use of Personal Information

We use Personal Information (including Sensitive Personal Information) for a variety of business and commercial purposes, as described in our Privacy Notice.

CCPA Rights and Requests

California residents may make the following types of requests under the CCPA:

Requests to Know, Delete, or Correct

Requests to Know

You may request that we disclose the following information to you about our collection and use of your Personal Information (including Sensitive Personal Information) over the past twelve (12) months or other CCPA-specified period: (1) the categories of Personal Information we collected about you; (2) the categories of sources from which we collected this Personal Information; (3) the categories of Personal Information that we have sold, shared, or disclosed to third parties, (4) the categories of recipients to whom this information was sold, shared, or disclosed; (5) the business or commercial purpose for selling, sharing, or disclosing Personal Information; and (6) the specific pieces of information we collected about you. You may request information collected about you after January 1, 2022, beyond this twelve (12) month period, subject to applicable law.

Requests to Delete

You may request that we delete Personal Information that we have collected from you. We may limit or deny your deletion request in certain cases, in accordance with exceptions specified in the CCPA.

Requests to Correct

You may request that we correct inaccurate Personal Information that we maintain about you, taking into account the nature of the Personal Information and the purposes of the processing of the Personal Information.

How to Submit Requests to Know, Delete, or Correct

You may submit a Request to Know, Request to Delete, and/or Request to Correct by emailing [email protected].

We will verify and respond to your request consistent with applicable law, taking into account the type and sensitivity of the Personal Information subject to the request. We may need to request additional Personal Information from you, such as email address, state of residency, or mailing address, in order to verify your identity and protect against fraudulent requests. If you maintain a password-protected account with us, we may verify your identity through our existing authentication practices for your account and require you to re-authenticate yourself before disclosing or deleting your Personal Information. If you make a Request to Delete, we may ask you to confirm your request before we delete your Personal Information.

Requests to Opt-Out of Sale or Sharing

You may opt-out of the Sale or Sharing of Personal Information by emailing [email protected].

Requests to Limit Use of Sensitive Personal Information

You may request that we limit our use of Sensitive Personal Information that we have collected about you to that which is necessary to perform the services that we provide to you.

To request that we limit our use of your Sensitive Personal Information, please by emailing [email protected].

Authorized Agents

To make a request as an authorized agent on behalf of a California resident, you may use the submission methods noted above. As part of our verification process, we may request that you provide, as applicable, proof concerning your status as an authorized agent, which also may include proof of your registration with the California Secretary of State to conduct business in California; and/or a power of attorney from the California resident pursuant to Probate Code sections 4121-4130;

If you are making a Request to Know, Request to Delete, or Right to Correct on behalf of a California resident and have not provided us with a power of attorney from the resident pursuant to Probate Code sections 4121-4130, we may also require the resident to verify their own identity directly with us; or directly confirm with us that they provided you permission to submit the Request to Know or Request to Delete.

Nondiscrimination

You have the right to be free from unlawful discriminatory treatment for exercising any of your CCPA rights.

Notice of Financial Incentives

From time to time, we may offer a program, benefit, or other offering in exchange for the collection, retention, sale, or sharing of Personal Information to us (collectively, “Financial Incentive”), such as your contact information. Any discount we provide will be based upon our reasonable but sole determination of the estimated value of your Personal Information, taking into consideration, without limitation, estimates regarding anticipated revenue generated from such information, the anticipated expenses which might be incurred in the collection, storage, and use of such information in the operation of our business, and other relevant factors related to the estimated value of such information to our business, as permitted under applicable law. We may provide additional notice of the details of the particular Financial Incentive as required, and participation in any Financial Incentive programs is on an opt-in basis. If you later wish to opt-out of a Financial Incentive program on a going-forward basis, you may submit a request to us using the contact details below.

Contact Us

If you have any questions or requests in connection with this CCPA Addendum or other privacy related-matters, please contact us by emailing [email protected].