Legal Information

AnchorFree Privacy Shield Notice

AnchorFree Inc. and its U.S. affiliates and subsidiaries (collectively, “AnchorFree”, “we”, “our” or “us”) have created this Privacy Shield Notice (“Notice”) to describe our practices for handling Personal Information in accordance with the EU-U.S. and Swiss-US Privacy Shield Frameworks (collectively, “Privacy Shield”).

AnchorFree has certified to and will adhere to the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework by adopting and implementing the Privacy Shield Principles, which also include a set of Supplemental Principles (collectively, the “Principles”). More information about Privacy Shield can be found at www.privacyshield.gov. Our Privacy Shield certification can be found at www.privacyshield.gov/list.

This Notice supplements the AnchorFree Privacy Policy (www.privacyshield.gov/list). Unless specifically defined in this Notice, the terms in this Notice have the same meaning as in our Privacy Policy. In case of conflict between the Privacy Policy and this Notice, this Notice prevails. In case of conflict between this Notice and the Principles, the Principles will govern.

How We Obtain Personal Information

We obtain and Process Personal Information in different capacities:

  • As a Data Controller, we collect and Process EEA and Swiss Personal Information directly from individuals, either via our publicly available websites, including www.anchorfree.com, our apps, or in connection with our customer, partner, and vendor relationships.

  • As a Data Processor, we process and host EEA and Swiss Personal Information on behalf of and under the instructions of our enterprise customers. In that context, our customers are the Data Controllers.

AnchorFree commits to subject to the Principles all Personal Information received from the EEA and Switzerland in reliance on the Privacy Shield (which includes both types of activities).

Notice

We may receive from the EEA and Switzerland some or all of the information listed in our Privacy Policy. Some of that information may qualify as “personal information” or “personal data” (collectively, “Personal Information”) as defined by Privacy Shield. Our Privacy Policy in combination with this Notice describes our privacy practices.

When we process Personal Information on behalf of our enterprise customers, they determine the categories of data we process, and the purposes of the processing. Accordingly, our customers are responsible for providing notice to individuals.

Data Integrity and Purpose Limitation

AnchorFree may process the Personal Information we receive for the purposes indicated in our Privacy Policy or as you may otherwise be notified. We will not process Personal Information in a way that is incompatible with the purposes for which it has been collected or subsequently authorized by you.

We take reasonable steps to limit the collection and usage of Personal Information to that which is relevant for the purposes for which it was collected, and to ensure that such Personal Information is reliable, accurate, complete and current. We will adhere to the Principles for as long as we retain the Personal Information collected under the Privacy Shield.

When providing our Services as a Data Processor, we Process and retain Personal Information as necessary to provide our Services to our customers, or as required or permitted under applicable law.

Accountability for Onward Transfer of Personal Information

Our Privacy Policy describes the types of third parties we may disclose your Personal Information to, and the purposes of such disclosures. When providing our Services as a Data Processor, we disclose Personal Information as provided in our agreements with customers.

We remain responsible for the Processing of Personal Information received under the Privacy Shield and subsequently transferred to a third party acting as an agent if the agent Processes such Personal Information in a manner inconsistent with the Principles, unless we prove that we are not responsible for the event giving rise to the damage.

We may be required to disclose Personal Information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Data Security

AnchorFree takes reasonable and appropriate measures to help protect Personal Information from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the risks involved in the Processing and the nature of the Personal Information.

Choice

If we intend to use your Personal Information for a purpose that is materially different from the purposes for which it was originally collected or subsequently authorized, or if we intend to disclose it to a third party acting as a controller not previously identified, we will offer you the opportunity to opt-out of such uses and/or disclosures where it involves non-sensitive information or opt-in where sensitive information is involved.

You may choose to change your Personal Information or cancel your account by contacting us as indicated in the “Contact Information” section below. You can also unsubscribe from our marketing communications by following the instructions in the e-mail message, following Apple and Google’s guidance to opt out from push notifications, or visiting your Account Portal if applicable.

Access to Personal Information

Where appropriate, you have the right to access the Personal Information we maintain about you and to correct, amend or delete that information when it is inaccurate or has been processed in violation of the Principles by sending a written request as indicated in the “Contact Information” section below. We will review your request in accordance with the Principles, and may limit or deny access to Personal Information where providing such access is unreasonably burdensome or expensive under the circumstances, where it would violate the rights of someone other than the individual requesting access, or as otherwise permitted by the Principles. We may request specific information from you to confirm your identity. In some circumstances we may charge a reasonable fee for access to your information.

When providing our Services as a Data Processor, we only Process and disclose the Personal Information as specified in our Agreements. Our customers control how Personal Information is disclosed to us and processed, and how it can be modified. Accordingly, if you want to request access, or to limit use or disclosure of your Personal Information we process on behalf of our enterprise customers, please contact the company with whom you have the relationship.

Recourse, Enforcement and Liability

If you have any questions or concerns, please write to us as indicated below. We will investigate and attempt to resolve complaints and disputes regarding use and disclosure of Personal Information in accordance with the Principles.

If an issue cannot be resolved through AnchorFree’s internal dispute resolution mechanism, you may submit a complaint, at no cost, to JAMS (www.jamsadr.com/eu-us-privacy-shield), which serves as AnchorFree’s alternative dispute resolution provider for claims related to the Privacy Shield. For residual complaints not fully or partially resolved by other means, you may be able to invoke binding arbitration as detailed in the Principle.

AnchorFree is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (“FTC”).

Changes to this Privacy Shield Notice

This Notice may be amended consistent with the requirements of the EU-U.S. Privacy Shield Framework. When we update this Notice, we will also revise the “Last Updated” date at the top of this document. Any changes to this Notice will become effective when we post the revised version on our website.

Contact Information

If you have any questions, concerns or complaint regarding our privacy practices please contact us at: Info@anchorfree.com or PO Box 60429, Sunnyvale, CA 94088.

If you’d like to exercise your choices or rights, please contact our Support at support.hotspotshield.com