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APP PRIVACY STATEMENT

Last revised: September 21, 2018

This App Privacy Statement (this “Privacy Statement”) describes our privacy practices associated with the FinjanMobile InvinciBull ® application (the “App”) whether the App is running on a mobile device or a computer (each a “Device”).

As a provider of an online privacy service, Finjan Mobile, Inc. (“FMI” “we,” “us,” “our”) strives to collect the minimal amount of information necessary to operate the App the associated service.

  • When you register for our service, you are required to provide your name and email address so that we can personalize your experience within our service and communicate with you regarding the App and our service.
  • If you enter any of the sweepstakes, contests and other promotions that we offer from time-to-time (“Promotions”), you will be required to provide some or all of the following information so that we can communicate with you regarding your participation in the Promotion, and for prize fulfillment purposes: name, email address, mailing address, telephone number and any other information requested in connection with the particular Promotion.
  • If you elect to subscribe to our service, we need your billing information.
  • Our service tracks the amount of data that you use, but not the sites that you visit.
  • We collect your Device name and type, the date you register and the dates that you use the App. We link that to your personal information in order to more effectively manage the service we provide to you and for our communications with you.

This Privacy Statement applies only to the App, related services and Promotions.  By using the App, you are agreeing to the collection, storage, processing, sharing and other activities with respect to your information as provided for in this Privacy Statement.  This Privacy Statement does not apply to our website https://www.finjanmobile.com/, which is subject to a different privacy statement.

This Privacy Statement answers the following questions:

What information does FMI collect and how does it use that information?

How does FMI use online tracking methods?

With whom and how does FMI share your information?

May persons under the age of 18 use the App?

How can you correct, delete or obtain a copy of your personal information?

Does this Privacy Statement extend to websites provided by others?

How does FMI secure and safeguard my information and notify me of a data breach?

How may I opt-out of receiving additional marketing materials from FMI?

How does FMI handle changes to this Privacy Statement?

What do I do if I do not believe that my information is being properly handled or I have questions about this Privacy Statement?

What are FMI’s Privacy Shield Commitments?

 

What information does FMI collect and how does it use that information?

Account Information. In order to use the App you must create an account (“Account”).  To create an Account you must be at least 18 years of age and provide your name and email address.

  • We need this information to allow you to activate, manage or use the App and to communicate with you in connection with your Account and your use of the App.
  • If you are unwilling to provide this information, then you will be unable to establish an Account or use the App.

If you choose to register for the App using Google, Facebook or other social networking accounts that we may enable, FMI obtains from that account your name, email address and Google/Facebook ID (as applicable), assuming you give your consent.

  • FMI uses this information in same manner as described above for account information that you provide directly to FMI.

App Usage InformationWe do not track the sites you visit or your activities on sites using the App.  We do record the date that you initially register for the App and each time you use the App we track the date you log-in and, if you use the VPN, the amount of data that you access.  We also track the name and type of each Device you use with the App.

  • We use this information to manage the App, plan for future network demand and to enable free user VPN data usage of the App.
  • We also use this information to provide you tailored information (via email or in-app messaging) on features or alternatives that we believe you may find useful based on how you use the App.

Subscription Payment Information. If you subscribe to a premium version of the App, you will be required to provide billing and payment information.  Such information may be provided to the app store (e.g. Apple Store or Google Play) from which you obtained the App or through the App or Web interface.

  • Information you provide to app stores is subject to the privacy policies applicable to those sites.
  • For payments made through the App or Web interface, FMI transmits that information to its payment processor, Stripe, which only uses it to process the related payment, to improve its service and as otherwise specified in the Stripe privacy policy.
  • Regardless of how you make payment, FMI only receives the amount and date of payment, the item purchased and any other information required to confirm that you made the payment.

Safe Scan.  The “Safe Scan” feature of the App sends each URL you enter in the App to FMI to determine whether or not the URL has been identified as safe, suspicious or dangerous.

  • FMI will send to the App a report describing the results of such analysis along with our grade on the level of safety if using the site.
  • Although FMI will retain the URL and the report, none of this information is associated with any of your personal information. FMI only knows that the virus scanning feature of the App was used with that site; we do not know by whom.

Device Information. FMI’s service providers and data processors may collect information regarding your Devices running the App that may include, as applicable:  IP address, language settings, date/time stamp, mobile device model and type, operating system and Bluetooth versions, network provider and data usage.

  • Our service providers and data processors do not associate any of this information with any personal information.
  • This information is used to operate the App related services and to enable FMI to understand how its customers use the App.

Promotion Entry Information.  In order to enter a Promotion, you will be required to submit certain Personal Information, such as your name, mailing address, telephone number and email address.

  • We need this information in order to communicate with you in connection with your participation in the applicable Promotion, including for entry identification, winner notification and prize fulfillment purposes.
  • If you are unwilling to provide this information, then you will be unable to enter our Promotions.

Personal information” means any data about an identified or identifiable individual, including data that identifies or could be used to identify, locate, track, or contact an individual. Personal information includes both directly identifiable information such as a name, identification number or unique job title, and indirectly identifiable information such as date of birth, unique mobile identifier, or telephone number.

 

How does FMI use online tracking methods?

Anonymous Identifier. The App places a small text file on your Device in order to improve your experience.  This file records if you are logged in and allows you to remain logged in during a session.

 

Analytics Cookies. We use cookies (small text files placed on your Device) in connection with third-party web analytics services (e.g., Google Analytics and Kochava).  We do not provide these analytics services any of your personal information.

  • Analytics cookies allow us to collect information about your Device, including your IP address, and how you use the App and our service
  • We use the information to evaluate your use of the App, including analyzing usage trends across Devices, assisting with fraud prevention, providing certain features to you, auditing and reporting.
  • You may find further information about cookies at: allaboutcookies.org and about how Google uses your data at: www.google.com/policies/privacy/partners/.

 

You cannot disable the cookies.  By using the App, you are agreeing to the placement and use of analytics cookies.

Emails.  Emails we send you may include analytics tools, such as clear GIFs, to capture data such as when you open our message or click on any links or banners our email contains.   This data allows us to gauge the effectiveness of our communications and marketing campaigns.

Do Not Track Signals. FMI does not permit third parties to collect personal information about an App user’s online activities over time and across different web sites.  Since access to the App and its underlying services do not involve access through another browser, “do not track” signals are not sent to the App by other browsers.

 

With whom and how does FMI share your information?

Service Providers. FMI may provide your information to service providers to facilitate, evaluate and improve the App and our related services, provide technical support, or perform other functions in support of FMI’s conduct of its business. In all cases, these service providers’ use of your information will be contractually limited to uses consistent with this Privacy Statement.  The following are the types of service providers to which we may provide your information:

  • Payment Processors: Payment information is transmitted to Stripe, FMI’s payment processor.  The information is only used to process and evidence the related payment, to provide and improve Stripe’s service and as otherwise provided in the Stripe privacy policy.
  • Analytics Providers: We use analytics services, such as Google Analytics and Kochava, to evaluate your use of the App, analyze usage trends across Devices, assist with fraud prevention, provide certain features to you, auditing and reporting. These analytics providers do not identify users individually or associate your IP address with any of the data they hold.  Click these links for a more detailed explanation of how Googleand Kochavamay use your information.
  • System Services: FMI uses third party service providers to operate and enable App capabilities.  These include managing the App infrastructure, storing data, and enabling specific functionality, such as the “Safe Scan” feature. FMI does not provide these service providers access to any of your personal information.  These service providers will only be provided access to the non-personal information needed to provide the services for which they have been engaged.

Anonymized Information. FMI may use anonymous information, which may include information you provided, in connection with marketing the App to third parties.

Successors. Your information, including personal information, may be disclosed and transferred in connection with the sale or transfer of FMI’s business or assets.

  • Such transfer would enable due diligence and/or allow the transferee to operate the business.
  • FMI will ensure that the transferee agrees to protect personal information in accordance with this Privacy Statement as it may be updated.

To Comply with Legal Requirements. FMI may share your information if FMI believes that such sharing is required by applicable law.  We will take commercially reasonable steps to notify you if we are required to provide your personal information to third parties as part of a legal process.  FMI also may use and disclose your information in the prosecution or defense by FMI of any litigation involving FMI that arises out of, or is related to, your use of any FMI product.

International Transfer. FMI may transfer your information to, and store and process your information in, jurisdictions other than the jurisdiction in which you live and/or work. Such other jurisdictions might have laws that treat your privacy differently from the jurisdiction in which you live and/or work. You agree to any such transfer, storage, and/or processing.  If applicable, we commit to comply with the Privacy Shield commitments specified below in connection with such a transfer.

 

May persons under the age of 18 use the App?

No, the minimum age of any user of the App is 18.  If you are under the age of 18, please do not download, register or use the App or supply any personal information to FMI.

 

How can you correct, delete or obtain a copy of your personal information?

The following terms describe how FMI will respond (unless such response is not required by applicable local law) to the indicated requests, unless such response is not required by applicable local law:

  • You may obtain a copy of your personal information by sending an email to FMI at [email protected] requesting that information.
  • You may update or correct you information through the App. You also have the right to request that we update, correct, or delete (assuming that this does not impact the services we are providing to you) your personal information at any time. You also may request that we restrict or cease the processing of your personal information while we make any corrections which you request.  Please note that we may reject requests which risk the privacy of others or are unreasonable or repetitive, or would require disproportionate effort.
  • We may keep your personal information in our live system for up to 1 month following deletion of your Account. Thereafter, your information will be in our archive for up to 6 months.  However, we usually keep your personal information no longer than is reasonably necessary given the purposes for which the information was collected.
  • If we no longer need your personal information to provide services or for other legitimate purposes, you may request that we retain but not otherwise process your personal data to the extent needed in order for you to establish, exercise or defend legal claims.
  • You may receive a copy of your personal information which you provided to FMI in a structured and commonly used machine readable format and you may transfer that information to another data controller. If it is technically feasible, you may request that we transfer the data directly to another controller.  We will comply with your request subject to verifying your identity and provided that it is technically feasible.

 

Does this Privacy Statement extend to websites provided by others?

The App enables you to access websites or other resources not operated by FMI. FMI cannot control the information that you provide the operators of such websites or what they do with the information.  You should obtain and read the privacy statements of those third parties to understand their practices.

 

How does FMI secure and safeguard my information and notify me of a data breach?

FMI uses, and requires that its service providers use, commercially reasonable physical, technical, administrative and other safeguards designed to prevent unauthorized access to, use of, alteration of, or destruction of, your information.  In addition, we limit the use and disclosure of your personal information, and work to ensure that anyone with whom we share such information treats that information with the privacy and security it deserves.

To the extent applicable law requires that FMI notify you that your personal information was, or is reasonably believed to have been, acquired by an unauthorized person, FMI will provide that notice by email (using the latest available address in our records) or as otherwise required by applicable law.

 

How may I opt-out of receiving additional marketing materials from FMI?  

Users who no longer wish to receive newsletters, digital notifications, or promotional materials may opt to not receive such communications by contacting FMI using the information below or by selecting the unsubscribe option included in such communications.  Notwithstanding the foregoing, we may continue to contact you for the purpose of communicating information relating to your participation in a Promotion.  To opt-out of receiving Promotion-related messages from FMI, you must cease participating in all Promotions.  Opting out in this way also means that we will not use your information to personalize communications to you.

  • If, after opting out, you request information from FMI or do certain things that invite us to use your personal information again, FMI will regard you as having opted back in.

How does FMI handle changes to this Privacy Statement? 

We may change this Privacy Statement from time to time. If we change this Privacy Statement in ways that affect how we use your personal information, we will advise you of the choices you may have as a result of those changes. We will also post a notice that this Privacy Statement has changed.

For your convenience, we make prior versions of our Privacy Statements available to you for review.

 

What do I do if I do not believe that my information is being properly handled or I have questions about this Privacy Statement?

If you feel that FMI is not abiding by this Privacy Statement or if you have questions regarding this Privacy Statement, the personal information we process about you, the purpose and nature of the processing, or with whom we share it, please contact FMI’s privacy liaison using the following information:

Privacy Office:
Finjan Mobile, Inc.
2000 University Avenue – Suite 600
East Palo Alto, California 94303
Telephone:  650-285-1918
E-mail: [email protected]

 

What are FMI’s Privacy Shield Commitments? 

The information and data collected, used and disclosed by FMI as described in the foregoing Privacy Statement may include certain personal information about consumers and customers that we receive in the US from the European Economic Area or Switzerland (collectively, “European Personal Data”).  The following Privacy Shield Policy (“Policy”) supplements the above Privacy Statement. If there is any conflict between the terms in this Policy and our Privacy Statement, this Policy shall control. Capitalized terms used but not defined in this Policy are used as defined in the Privacy Statement.

To provide adequate protection for certain European Personal Data received in the US, FMI has elected to self-certify to the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework, each administered by the US Department of Commerce (collectively, the “Privacy Shield”).

FMI adheres to the Privacy Shield principles of: notice, choice, accountability for onward transfer, security, data integrity and purpose limitation, access, and recourse, enforcement, and liability.

For purposes of enforcing compliance with the Privacy Shield, FMI is subject to the investigatory and enforcement authority of the US Federal Trade Commission. For more information about the Privacy Shield, see the US Department of Commerce’s Privacy Shield website located at: https://www.privacyshield.gov. To review FMI’s representation on the Privacy Shield list, see the US Department of Commerce’s Privacy Shield self-certification list located at: https://www.privacyshield.gov/list.

Our Privacy Statement above describes the categories of European Personal Data that we may receive in the US as well as the purposes for which we use that European Personal Data.

FMI is responsible for the processing of European Personal Data we receive, under the Privacy Shield, and subsequently transfer to a third party acting as an agent on our behalf. We comply with the Privacy Shield principles for all onward transfers of personal data from the EU.  We enter into written agreements with those third-party agents and service providers requiring them to provide the same level of protection the Privacy Shield and this Privacy Statement require and limiting their use of the data to the specified services provided on our behalf.  Under certain circumstances, we may remain liable for the acts of our service providers who perform services on our behalf for their handling of your European Personal Data that we transfer to them.

You can direct any questions or complaints about the use or disclosure of your European Personal Data to us at the address provided below.  We will investigate and attempt to resolve any complaints or disputes regarding the use or disclosure of your information within 45 days of receiving your complaint.  If you are unsatisfied with the resolution of your complaint, you may contact JAMS at https://www.jamsadr.com/file-an-eu-us-privacy-shield-or-safe-harbor-claim for further information and assistance.

 

Finjan Mobile, Inc.
2000 University Avenue – Suite 600
East Palo Alto, California 94303
Telephone: 650-285-1918
E-mail: [email protected]

Under certain conditions, more fully described on the Privacy Shield website, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.

You also have the right to seek assistance from the data protection authorities, Click here for EU Data Protection Authorities and click here for Swiss Federal Data Protection and Information Commissioner.