Enigma Software Group USA, LLC's Privacy Policy and Cookie Policy

Last Revised: October 11, 2023
Effective Date: October 16, 2023

Enigma Software Group USA, LLC, 3000 Gulf to Bay Boulevard Clearwater, FL 33759, USA ("ESG", "we", "us", or "our") is dedicated to establishing a trusting relationship with its users, based on respect for personal identity and information, by promoting the use of fair information practices. This privacy policy covers all Web properties owned and maintained by ESG. This privacy policy also applies to and covers EnigmaSoft Limited ("EnigmaSoft"), a related/affiliated company to ESG, to the extent and based on EnigmaSoft’s handling of the sale of RegHunter 2. EnigmaSoft is also committed to protecting the privacy of users’ data. EnigmaSoft is a company incorporated under the laws of Ireland with company registration number 597114, whose registered office is at 1 Castle Street, 3rd Floor, Dublin 2, D02 XD82, Ireland. (The terms "ESG", "we", "us", or "our" as used in this privacy policy shall also include EnigmaSoft for purposes of the provisions herein relating to RegHunter 2). We want to demonstrate our commitment to our users' privacy and establish our users' trust in our ability to protect their data. Therefore, we are disclosing:

1. What personally identifiable information ESG collects.
2. How ESG uses the information and our legal bases for use.
3. With whom ESG may share user information.
4. What choices are available to users regarding collection, use and distribution of the information.
5. What types of security procedures are in place to protect the loss, misuse or alteration of information under ESG control.
6. How users can correct any inaccuracies in the information.

For any inquiries or questions regarding our privacy practices, you may always contact our Support Team at support@enigmasoftware.com. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.

Information Collection and Use

ESG is the sole owner of the information collected on its web properties. ESG collects information from its users at several different points on our Web sites in accordance with the applicable data protection laws and strictly for the purposes necessary to our business and our users' convenience. Please note that privacy practices relating to SpyHunter 5, a product of EnigmaSoft Ltd., are governed by a separate privacy policy issued by EnigmaSoft Ltd. and available at https://www.enigmasoftware.com/esg-privacy-policy/.

Registration

In order to use ESG services at any level, a user must first complete the registration form. During registration, a user is required to give contact information (such as name and email address), and a unique identifier. We use this information to contact the user about services on our site for which the user has expressed interest.

Order and Payment

We may use a distribution partner(s) and a trusted third party payment processor(s) to help us manage ordering, invoicing and processing of payments for our products and services. When a user pays for a subscription to, or purchases, one of our products or services, the user has to enter information through an online order form. A user, or someone in the user's organization, must provide contact information (such as name, company name, telephone number, email, and billing address) and financial information (such as credit card number and expiration date). We and our distribution partners and third-party payment processors may also collect the user's internet protocol ("IP") address and hardware ID. We may request and receive from the distribution partner and third party payment processor a copy of the payment history between the user and us.

When a user provides their information to our distribution partner or third party payment processor, use of the user's personal data is governed by that third party's terms of service and privacy policy. A link to both the terms of service and to the privacy policy is provided on the purchase form. A user must agree to both of these before they purchase or subscribe to our products and services acquired in conjunction with our distribution partners or third party payment processors.

We may receive a user's financial information (such as the credit card type, expiration date, and the last four digits of the credit card number) from the third party payment processor, along with other personal data. The third party payment processor may also provide us with unique authentication tokens to make payment requests. This information is used to make payment requests or to register the user for an auto-renewing subscription that requires automatic payments in the future.

If you elect to purchase products from us, our affiliates and/or trusted business partners, to facilitate your product purchases we, our affiliates and/or trusted business partners (including third party payment processors may use the payment information or personal data you provided to us to process your purchases).

In order for us to properly fulfill our obligations to users, it may be necessary for us to supplement the information we receive with information from third party sources. For example, we may verify the billing address on credit card transactions. The information obtained from these third party sources is maintained by us in a manner consistent with our Privacy Policy.

As noted in our EULA/TOS and this Privacy Policy, we require users to be of proper legal age, and our practice is not to sell or improperly share the personal information of consumers under 16 years of age.

Information Use

Subject to the provisions in this Privacy Policy and the legal exceptions listed in the Privacy Policy, ESG will not disclose to third parties the email addresses uploaded to our Web sites by our users for the purpose of using ESG products or services. To achieve our past and continuing goals of providing users with improvements on our products and services, as well as up to date technical support, we may from time to time share users’ personal data with our affiliate companies and/or trusted business partners – such as third party payment processors or others. We collect and use the information a user directly provides to us, our affiliates or one of our trusted business partners, such as the information a user provides when they access, use or purchase our products and services, information about how a user accesses, navigates, and uses our products and services, and information a user provides when communicating with us, including for customer support. We may also process and analyse information from the scans a user conducts using our products and services, as further described below.

If a user is using a paid subscription product or service, their username and password are sent and received during each communication for security, authentication and verification purposes and to help resolve billing disputes. Payment card and other financial information are collected by us and our third party payment processors.

To facilitate renewal or reinstatement of a subscription we or our third party payment processors may also retain non-financial contact information and support and scan logs for customers whose licenses have expired.

Your personal data will be kept only for clear and legal purposes. All personal data will be processed fairly and in keeping with the purposes for which it was obtained.

We use your information for the following purposes:

• providing our products and services to you;
• determining your suitability for our products and services, and for personalisation;
• maintaining and improving our products and services, and developing new ones;
• administering and managing the products and services we provide to you, to provide customer support, to authenticate you as a user, to charge you and process payment, investigate disputes and billing queries, collect any amounts you may owe us, and to fulfill orders for our products and services;
• promoting the safety and security of our products and services, our staff, other users and members of the public, and investigating suspicious activity or violations of our policies;
• providing you with information about our products and services and those of our related companies and affiliates;
• conducting surveys (as set out in Part E (Third Party Links and Content)) and analytics to enhance and improve the quality of the products and services we offer; and/or
• as permitted or required by any law or regulation applicable to us or arising from your interaction with us.

Legal Bases

We rely on a number of legal bases to collect, use, share, and otherwise process the information we have about you for the purposes described in this Privacy Policy. These legal bases include:

• as is necessary to enable your use of our website, apps, software, services and other products;
• where you have consented to the processing, if and as may be applicable and/or required or otherwise generally allowed, which you may revoke at any time;
• for us to comply with a legal obligation, a court order, or to exercise legal rights or defend legal claims;
• when necessary to protect your vital interests, or those of others;
• when necessary to ensure performance of a contract;
• where you have made the information manifestly public;
• where necessary in the public interest; and/or
• where necessary for the purposes of our or a third party's legitimate interests.

Our Legitimate Interests

We process your information in furtherance of some or all of the following legitimate interests:

• Keeping the products and services safe and secure: We use your information as it is necessary to pursue our and our customers' legitimate interests in ensuring our products and services are secure, such as by implementing and enhancing security measures and protections, protecting against security breaches, fraud, and spam.
• Providing, improving and developing the products and services: We use your information to provide and further develop the products and services. We do so as it is necessary to pursue our legitimate interests of providing a secure offering to all our customers on a continuing basis.
• Providing seamless services across our group of companies: Where the products and services require the engagement of our affiliates, subsidiaries or related companies, we share your information with them to provide, administer and improve the services and products.

Cookies and Other Tracking Technologies

We and our partners, affiliates and service providers use cookies, beacons, tags, scripts and related technologies (collectively called "Cookies") to provide our products and services to you. By accessing or using our products or services you consent to the use of Cookies in the manner described in this Privacy Policy. Please do not use our products or services if you are not comfortable with the ways in which we use Cookies. 

What is a Cookie?

Cookies are small text files sent from a server and stored to a user’s computer or other device. When a user visits a website or application more than once, the browser sends Cookies back to the website or application, allowing the website or application to recognise the user and remember things like their personalised details and preferences. More information about Cookies and details of how to manage or disable them can be found on https://www.aboutcookies.org.

Do We Use Cookies?

Yes. We may obtain information about your general internet usage by using Cookies that are typically stored on the hard drive of your computer or on other device.

When Do We Use Cookies?

We use Cookies when you navigate or access our products and services. For example, when you return to our website after logging in, Cookies provide information to our website so that the website remembers you. Cookies help us to operate and improve our products and services, to authenticate you, and to deliver a better, more personalised service. 

We also use Cookies when you use the parts of our services that allow you to purchase our products such as our shopping cart function.

What Types of Cookies Do We Use?

We mainly use Cookies for the operation, administration and security of our products and services, to improve our products and services, for analyzing trends, and for fulfilling other legitimate purposes administering our services.

We currently use Cookies for the following purposes:

• Operation of Our Service: We use Cookies to monitor session and status data, to learn how you, and other users, use our services and how well they perform. This allows us to identify errors, learn how our services perform, and improve and develop our services over time. We also use Cookies to remember if you have seen our cookie banner.
• Security: We use Cookies to enable and support our security features, and to help us detect malicious activity and violations of our Terms of Sale and End User License Agreement.
• Preferences: We use temporary 'session' cookies which enables your browser to remember which pages on our website have already been visited and the language you have selected. This information may be used to help us to improve, administer and diagnose problems with our website and servers. 

Third Party Cookies

Some Cookies that have been set on our services may not be related to or controlled by us and may originate from one of our partners, affiliates or service providers. We do not control the use of these Cookies and cannot access them due to the way Cookies work, as Cookies can only be accessed by the party which originally set them.

You should check the applicable third party's website for more information about these Cookies.

How to Refuse the Use of Cookies

You can change your browser or application settings so your device warns you each time a Cookie is sent, or to turn off all Cookies. Each web browser or application is different, so please look at your browser or application "help" menu to learn how to modify your Cookies preferences. However, if you disable Cookies you will not have access to certain features that may make your browsing of our website and use of our services smoother, and some of our services may not be available to you.

If you want to opt out of specific third-party cookies, please consult the applicable third party’s website or privacy policy as well as the cookie settings on your browser.

Most browsers allow you to choose whether you accept cookies or not. We have included links to some of the cookie preference pages of web browsers:

•   Google Chrome: https://support.google.com/chrome/answer/95647
•   Internet Explorer: https://support.microsoft.com/en-ie/help/17442/windows-internet-explorer-delete-cookies
•   Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences
•   Safari: https://support.apple.com/guide/safari/manage-cookies-and-website-data-sfri11471/mac
•   Safari Mobile: https://support.apple.com/en-us/HT201265
•   Opera: https://help.opera.com/en/latest/web-preferences/#cookies

Cookie List

The following is a listing of cookies that are used or may, from time to time, be used across our website(s), services, and products:

Necessary

These cookies are necessary for the overall operation of our websites/services/products and enable you to navigate the websites/services/products.

Source	Cookie Name(s)	Purpose	More Information
EnigmaSoft	autoplay_* ip2country jsCookieCheck redirect_country locale ma_user_* ma_username_* ui_lang	User personalizations, preferences and related settings.	For more information about the EnigmaSoft privacy policy and cookie policy, please visit: https://www.enigmasoftware.com/enigmasoft-privacy-policy/

Advertising

These cookies are generally related to advertising and user metrics and used to improve our delivery of our websites/services/products to you.

Source	Cookie Name(s)	Purpose	More Information
EnigmaSoft	rd_campaign_id rd_media_partner_id rd_tracker_id rw_affiliate_id rw_session_id	Measurement and metrics related to how visitors use, navigate and interact with our website.	For more information about the EnigmaSoft privacy policy and cookie policy, please visit: https://www.enigmasoftware.com/enigmasoft-privacy-policy/
Facebook	_fbp	Generally used to determine the ad or post a user clicked on to arrive at our website.	For more information about the Facebook cookie policy, please visit: https://www.facebook.com/policy/cookies/ For more information about the Facebook privacy policy, please visit: https://www.facebook.com/about/privacy
Google	__Secure-3PAPISID __Secure-3PSID __Secure-3PSIDCC SIDCC HSID SID SAPISID APISID 1P_JAR DV	Generally used to determine the ad a user clicked on to arrive at our website.	For more information about the Google cookie policy, please visit: https://policies.google.com/technologies/cookies For more information about the Google privacy policy, please visit: https://policies.google.com/privacy
DoubleClick by Google	IDE	Generally used to determine the ad a user clicked on to arrive at our website.	For more information about the DoubleClick (Google) cookie policy, please visit: https://policies.google.com/technologies/cookies For more information about the DoubleClick (Google) privacy policy, please visit: https://policies.google.com/privacy To customize your advertising settings with DoubleClick, please visit: https://adssettings.google.com/authenticated
Bing by Microsoft	SRCHHPGUSR ipv6 _EDGE_S _SS SRCHUSR MUID SRCHD SRCHUID _HPVN MUIDB	Generally used to determine the ad a user clicked on to arrive at our website.	For more information about the Bing (Microsoft) privacy / cookie policy, please visit: https://privacy.microsoft.com/en-us/privacystatement To customize your advertising settings with Bing, please visit: https://account.microsoft.com/privacy/ad-settings/
Quora	m-tz m-early_v m-b_strict m-s m-b_lax m-b m-uid m-css_v m-ans_frontend_early_version	Generally used to determine the ad a user clicked on to arrive at our website.	For more information about the Quora cookie policy, please visit: https://www.quora.com/about/cookies For more information about the Quora privacy policy, please visit: https://www.quora.com/about/privacy
LinkedIn by Microsoft	AMCV_* AMCVS_* lidc lissc bcookie lang G_ENABLED_IDPS JSESSIONID bscookie	Generally used to determine the ad a user clicked on to arrive at our website.	For more information about the LinkedIn cookie policy, please visit: https://www.linkedin.com/legal/cookie-policy For more information about the LinkedIn privacy policy, please visit: https://www.linkedin.com/legal/privacy-policy
Twitter	_twitter_sess ct0 guest_id personalization_id gt	Generally used to determine the ad a user clicked on to arrive at our website.	For more information about the Twitter cookie policy, please visit: https://help.twitter.com/en/rules-and-policies/twitter-cookies For more information about the Twitter privacy policy, please visit: https://twitter.com/en/privacy To customize your advertising settings with Twitter, please visit: https://help.twitter.com/en/safety-and-security/privacy-controls-for-tailored-ads
YouTube by Google	YSC VISITOR_INFO1_LIVE	Generally used to determine the ad a user clicked on to arrive at our website.	For more information about the Google cookie policy, please visit: https://policies.google.com/technologies/cookies For more information about the Google privacy policy, please visit: https://policies.google.com/privacy

Performance, Analytics and Research

These cookies generally relate to analytics for us to improve and enhance our delivery and provision of our websites/services/products to users.

Source	Cookie Name(s)	Purpose	More Information
Alexa Analytics	__asc __auc	Measurement and metrics related to how visitors use, navigate and interact with our website.	For more information about the Alexa privacy / cookie policy, please visit: https://www.alexa.com/help/privacy
Google Analytics	_ga _gat_UA-* _gid	Measurement and metrics related to how visitors use, navigate and interact with our website.	For more information about the Google cookie policy, please visit: https://policies.google.com/technologies/cookies For more information about the Google privacy policy, please visit: https://policies.google.com/privacy To opt out of Google Analytics cookies for all websites, please visit: https://tools.google.com/dlpage/gaoptout
Leadfeeder	_lfa	Measurement and metrics related to how visitors use, navigate and interact with our website.	For more information about the Leadfeeder cookie policy, please visit: https://www.leadfeeder.com/cookies-and-tracking/ For more information about the Leadfeeder privacy policy, please visit: https://www.leadfeeder.com/privacy/

Log Files

Like most Web sites, our servers use log files to analyze trends, administer the site, track user's movement in the aggregate, and gather broad demographic information for aggregate use. We may track information that your browser or your use of our product(s) provide us (including certain navigational and/or behavioral data) to help us improve and develop our product(s) and to provide improved services and update information to our users. This information may include Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, date/time stamp, and/or clickstream data. To also improve our products over time and to consider strategies for delivering up-to-date products for users, we use tracking services. These may include Google, Microsoft, Facebook and Alexa. We also from time to time use tracking analytical measures across the use of our products and those of our affiliate companies or trusted business partners in order to provide you with quality products and to improve our products plus to provide you with information about products and services available. We may also use Data to provide you with support and technical assistance. The foregoing information may be linked to your account depending on our different tracking methods for purposes of improving our products and services and supporting your use.

User Content

We may collect user content and/or related data (including navigational and/or behavioral data) which may be transmitted, processed or stored using our product(s). We may also collect information on the files on your device, for example, the file name, file extension, file size and folder name, as well as retrieval and access activity for your data/files.

Device Data

We collect technical information about the type of device you use to access our product(s), such as device type, IP address or hardware ID in order to activate accounts or provide support services.

Flash LSOs

We may use Local Shared Objects (LSOs), such as Flash, to store content information and preferences. Third parties with whom we partner to provide certain features on our Web site or to display advertising based upon your Web browsing activity may use LSOs such as Flash to collect and store information. Various browsers may offer their own management tools for removing HTML5 LSOs. To manage Flash LSOs, please visit https://helpx.adobe.com/flash-player/kb/disable-local-shared-objects-flash.html.

Advertising

You always have a choice as to whether or how you interact with an advertisement (for example, by clicking to learn more about an offer). You agree that during use or access, our products may show you ads for our other products and offers. We may also place ads for our products on various third party websites and platforms, and, as a result, you may see ads for our products when visiting Google, YouTube, Facebook, and/or a variety of other websites and platforms. We may ask the proprietors of these websites/platforms to present our ads to particular demographic groups, for example, women over 25 years of age, or all visitors to a website who are in Ireland. The third party websites/platforms may use information they already have about the user, or may place cookies or similar tracking technologies in the user's browser, in order to decide what ads the user will see, including potentially our ads. If you wish to opt out of interest-based advertising and you are located in the European Union please visit the following URL: https://www.youronlinechoices.eu. If you are located anywhere else please visit the following URL: https://optout.aboutads.info. You will still see ads but the ads you see will likely be less relevant to you and your interests. If a user has any questions or concerns about the ads they see on any of these third party websites/platforms or if they have questions generally about the privacy practices of those sites, we encourage them to consult the privacy policies of those sites or enquire with the proprietors of those sites.

Marketing

With your consent, if and as may be applicable and/or required or as otherwise generally allowed, we may use your information for us, our affiliated companies and/or trusted business/commercial partners to contact you and/or send you promotional/marketing communications and/or contact you directly by email, post, phone, mobile, text message, SMS, or other electronic means for any purpose, including to provide information about various apps, services, products, special offers, discounts, coupons, news, and events which may interest you. You have the right to ask us to stop processing your personal data for direct marketing purposes. If you wish to exercise this right, you can follow our Unsubscribe instructions such as found on our website. "Unsubscribe" instructions or the "Unsubscribe" link in the marketing communications to advise us.

Service Announcements

On rare occasions, it is necessary to send out a strictly service-related announcement. For instance, if our service is temporarily suspended for maintenance we might send users an email. These communications are not promotional in nature.

Customer Service

We communicate with users on a regular basis to provide requested services and regarding issues relating to their accounts. We reply via email or phone, in accordance with the users' wishes.

Spam

ESG has a zero-tolerance policy for abuse.

Information Sharing

We will share your personally identifiable information with third parties only in the ways that are described in this Privacy Policy. We do not sell your personally identifiable information to third parties as we understand that term to be commonly or ordinarily used in our business. Please be aware that courts of equity, such as U.S. Bankruptcy Courts, may have the authority under certain circumstances to authorize the sale or transfer of your personal information to a third party. The information we collect from you may be transferred to third parties in connection with operating our business. It may also be processed by these third parties and/or by our and their respective employees and service providers. We will take steps to ensure that these third parties will only process data in accordance with our instructions, and take appropriate security measures to protect your data. By submitting your information, you agree to this transfer, storing or processing of your personal data by us. We may disclose your information to the following third parties:

• our related companies, subsidiaries, affiliates or our distribution or commercial partners and other businesses we work with;
• our professional advisers in order for them to provide us with advice;
• third party service providers, such as our payment processors, where necessary for them to provide us with services or to provide products and services that you have requested;
• our technology providers, including those which host your data on our behalf and provide certain IT support and IT professional services to us; and/or
• business partners and/or possible acquirers or investors (and our and/or their advisors) in the context of facilitating or implementing a business re-organisation or a transfer/sale of all or part of our assets or business.

Where required or authorised by law, we reserve the right to release personal data without your consent and/or without consulting you, when we believe that this is appropriate to comply with our legal obligations, to protect the security of our products, services, systems and related technologies, to prevent and minimise the effects of fraud, and otherwise to protect our legitimate interests and/or the legitimate interests of our staff, users or members of the public. When using our product(s), you may be redirected via a link to third party websites. Your use of these websites and any associated services will be subject to these third parties’ terms of use, EULA, privacy policies, legal requirements, cookie policies and/or other terms/conditions and policies. Please review the specific privacy policy and terms and conditions of these websites, as we are not responsible for them.

International Data Transfers

We operate on a global basis. Accordingly, your personal information may be transferred and stored in countries outside of your location that are subject to different standards of data protection. We will take appropriate steps to ensure that the transfer of personal information is in accordance with applicable law and is managed carefully to protect your privacy rights and interests and transfers are limited to countries which are recognized as providing an adequate level of legal protection or where we can be satisfied that alternative arrangements are in place to protect your privacy rights. Accordingly, where we transfer your personal information outside ESG or to third parties who may assist us to provide our products, we obtain contractual commitments from them to protect your personal information; or where we receive requests for information from law enforcement or regulators, we consider these requests carefully before any personal information is disclosed. You have a right to contact us for more information about the safeguards that we have put in place to ensure the adequate protection of your personal information when it is transferred as described in the section.

Legal Disclaimer

Though we make every effort to preserve user privacy, we may need to disclose personally identifiable information when required by law wherein we have a good-faith belief that such action is necessary to comply with a current judicial proceeding, a court order or legal process served on our Web site or when we believe in good faith that disclosure is necessary to protect our rights, protect your safety, the safety of others or investigate fraud. For example, ESG may disclose personally identifiable information to law enforcement, other government officials, or third parties in response to criminal or civil subpoenas. In certain situations, ESG may be required to disclose personally identifiable information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Third Party Intermediaries

As noted, we use one or more third parties and/or trusted business partners for credit card/payment processing to bill users for goods and services. These companies do not retain, share, store or use personally identifiable information for any secondary purposes. These companies are authorized to use your personally identifiable information only as necessary to provide these services to us.

Business Transitions

In the event ESG goes through a business transition, such as a merger, being acquired by another company, or selling a portion of its assets, users' personally identifiable information will, in most instances, be part of the assets transferred. Users will be notified prior to a change of ownership or control of their personally identifiable information. If as a result of the business transition, the users' personally identifiable information will be used in a manner different from that stated at the time of collection they will be given a choice not to have their information used in this different manner, as described in the notification of changes section, below.

Links

ESG's Web sites contain links to other sites. Please be aware that ESG is not responsible for the privacy practices of such other sites. We encourage our users to be aware when they leave our sites and to read the privacy policies of each and every Web site that collects personally identifiable information. This privacy policy applies solely to information collected by ESG's Web sites. ESG has advertising and affiliate relationships with dozens of third party sites, which drive interested parties to our sites. Information that is collected on these sites does not fall within the auspices of this policy.

Surveys

Periodically, our site may request information from users via surveys. Participation in these surveys is completely voluntary and the user, therefore, has a choice whether or not to disclose this information. The requested information typically includes contact information (such as name and address), and demographic information (such as zip code). Survey information will be used for purposes of monitoring or improving the use and satisfaction of ESG's services. Users' personally identifiable information is not shared with third parties. Though we may use an intermediary to conduct these surveys, they may not use customers' personally identifiable information for any secondary purposes.

Blog

Our Web site may offer publicly accessible blogs. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request removal of your personally identifiable information from our blog or community forum, contact us at support@enigmasoftware.com. In some cases, we may not be able to remove your personally identifiable information, in which case we will let you know if we are unable to do so and why.

Social Media Widgets

Our Web site includes social media features, such as a Facebook "Like" button and widgets, and a "Share This" button or interactive mini-programs that run on our site. These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our site. Your interactions with these features are governed by the privacy policy of the company providing it.

Security

ESG takes every reasonable precaution to protect its users' information. When users submit sensitive information via ESG's Web sites, their information is protected both online and off-line. When our registration/order forms ask users to enter sensitive information (such as credit card number), that information is encrypted and is protected with an industry-standard encryption protocol – SSL. While on a secure page, such as our paid order form, the lock icon on the bottom of Web browsers such as Microsoft Internet Explorer becomes locked, as opposed to un-locked, or open, when users are just "surfing." While we use SSL encryption to protect sensitive information online, we also employ security measures to protect user-information off-line. All of our users' information, not just the sensitive information mentioned above, is restricted on our servers. Only employees who need the information to perform a specific job (for example, our billing clerks or a customer service representative) are granted access to personally identifiable information. Finally, the servers that store personally identifiable information are in a secure environment. We follow generally accepted standards to protect the personally identifiable information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security. If you have any questions about security on our Web site, you can contact us at support@enigmasoftware.com.

Supplementation of Information

In order for ESG to properly fulfill its obligations to users, it is necessary for us to supplement the information we receive with information from third party sources. ESG verifies the billing address on all credit card transactions and may obtain credit reports for some corporate customers. The information obtained from these third party sources is maintained in a manner consistent with ESG's Privacy Policy.

Correcting/Updating/Deleting/Deactivating Personally Identifiable Information

Upon request, ESG will provide you with information about whether we hold any of your personally identifiable information. If a user's personally identifiable information changes (such as zip code, phone, email or postal address), or if a user no longer desires our service, we provide a way to correct, update or delete/deactivate users' personally identifiable information. You can make the change by accessing your account online or by contacting us by telephone or postal mail at the contact information listed below. We will respond to your request to access within 30 days. We will retain your information for as long as your account is active or as needed to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. As a result, certain data and/or historical customer billing records may be maintained for extended periods, by ESG and by third party payment processing companies. We will not merge your personally identifiable information with non-personally identifiable information for the purpose of online preference marketing without obtaining your permission. We commit to undertaking periodic reviews of the personal information we hold to ensure personal information is not held any longer than is necessary. In some instances, we may delete some of the personal information we hold about you once you stop using our product(s).

Notification of Changes

If we decide to change our privacy policy, we will post those changes in this privacy policy, and other places we deem appropriate, so our users are always aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. We will use information in accordance with the privacy policy under which the information was collected. If, however, we are going to use users' personally identifiable information in a manner different from that stated at the time of collection we will notify users via email or by means of notice on our Web site prior to the change becoming effective. We will also notify users via an in-app mechanism prior to the change becoming effective. Users will have a choice as to whether or not we use their information in this different manner. In addition, if we make a material change in our privacy policy that does not affect user information already stored in our database, we will post a prominent notice on our Web site and via the in-app mechanism notifying users of the change. The General Data Privacy Regulation (EU) 2016/679 ("GDPR") provides additional rights to European Union residents. Those rights include the right to access, correct, transfer to another party, and delete certain personal data processed by us, and the right to complain to EU supervisory authorities. If you are a European Union resident, nothing in this policy affects your rights to rely on any applicable mandatory European Union data protection law, including the General Data Protection Regulation ("GDPR "). As may be applicable, we act as a data controller when we provide products. To the extent and in the event we may serve as a data processor for our affiliates and/or trusted business partners, we will process personal information in accordance with applicable privacy policies or instructions.

Do Not Track ("DNT")

We may not recognize Do Not Track ("DNT") signals from your browser or device. There is not yet a universally accepted standard on how to interpret and respond to DNT signals, which often conflict with other settings. If a standard approach is established, we will re-examine how we can appropriately respond to DNT signals.

Notice to California Consumers/Residents

1. California Consumer Privacy Act of 2018 ("CCPA") Under the CCPA and/or CPRA, California consumers have the following rights towards their personal information:

• right to notice
• right to access
• right to request deletion or to request correction of inaccurate information
• right to opt-out of sales of personal information
• right to equal services and prices

Depending upon individual user circumstances and our business operations, the following rights may exist for California consumers of our products:

Right to notice means a business is required to inform consumers at or before the point of collection of a consumer's personal information of the categories of personal information that will be collected and the purposes for which these categories of personal information will be used. (This Privacy Policy contains information about our practices.)

Right to access means that consumers have the right to request that a business disclose the categories of personal information collected, the categories of sources from which personal information is collected, the business of commercial purpose, the categories of third parties with which the business shares personal information, and the specific pieces of personal information the business holds about a consumer. (This Privacy Policy contains information about our practices.)

Right to request deletion means consumers have the right to request that a business deletes personal information that was collected from the consumer (with certain specific exceptions as permitted by law).

Right to opt-out means the right for consumers to direct businesses to stop selling their personal information to third parties. We do not sell your personal information. We only disclose some of your personal information to offer you the services of Enigma Software Group USA, LLC, our affiliated companies and/or trusted business partners, as explained in this Privacy Policy and/or our applicable EULA/TOS.

Right to equal services and prices prohibits businesses from discriminating against consumers who exercise their CCPA rights. Today, our services in this regard are free.

Should the foregoing CCPA/CPRA rights become applicable, you may make a request to us pursuant to them. Depending on the circumstances, you may also have the right to appoint an authorized agent to make requests under the CCPA/CPRA on your behalf. The right to make an appointment of an authorized agent by you, should it become available, will be conditioned and dependent upon the submission of a letter of authorization appointing an agent and sufficient documentary proof validating such appointment was properly made by you, in forms sufficient to ensure proper application of the law. Once we receive your request, we will verify your identity and authorization to make the request, and proceed, as appropriate, with further action. Note that your rights are subject to certain exceptions and limitations, and we may retain certain personal data to the extent permitted by applicable law.

In the past 12 months, we have disclosed the following categories of personal data to our trusted partners, affiliates and related companies: User Data, Product Data, Website Data, and Third-Party Data.

Should you wish to submit a request to us pursuant to the CCPA/CPRA, or if you should have any questions regarding the CCPA, CPRA, and/or your privacy rights under California law, as well as the foregoing, please contact us at support@enigmasoftware.com or call us at +1 (888) 360-0646 and please type in "CCPA/CPRA Request" in the subject line and in the body of your message.

2. California Shine The Light Provisions

Under California's "Shine the Light" law, California residents who provide certain personal data in connection with obtaining products or services for personal, family, or household use are entitled to request and obtain from us once per calendar year information about the information that we shared with other businesses for their own direct marketing uses. If applicable, this information would include the categories of information and the names and addresses of those businesses with whom we shared information for the immediately prior calendar year. To obtain this information, please contact us at support@enigmasoftware.com or call us at +1 (888) 360-0646 with "Request for California Privacy Information" in the subject line and in the body of your message. We will provide the requested information to you at your email address in response. Please be aware that not all information sharing is covered by the "Shine the Light" requirements, and only information on covered sharing will be included in our response. We may ask for additional information to verify your identity. Consumer Rights Notice. Under California Civil Code Section 1789.3, we hereby provide California residents with the following specific consumer rights information:

• This website is owned and operated by EnigmaSoft Limited/Enigma Software Group USA, LLC.
• Unless otherwise expressly stated, this website is provided without charge.
• To file a complaint regarding this website or to receive further information regarding use of this website, please contact us via email at support@enigmasoftware.com or call us at +1 (888) 360-0646. You also may contact the Complaint Assistance Unit of the Division of Consumer Services of California's Department of Consumer Affairs in writing at 400 R Street, Suite 1080, Sacramento, California 95814 or by telephone at (916) 445-1254 or (800) 952-5210.

Contact Information

If you have any queries, comments or requests about this Privacy Policy or our management of your personal data, and/or your potential GDPR rights, please email us at support@enigmasoftware.com or write to us at the below address. Enigma Software Group USA, LLC Attn: Customer Service Department 3000 Gulf to Bay Blvd. Clearwater, FL 33759 USA Please type or write in the subject line and the body of your request "Privacy Request" and explain the nature of your request.