Effective date: August, 14, 2024
Introduction:
As an antivirus software, Clean Master is committed to help you defend against various viruses
and manage online privacy activities. To do so, we may have to collect some of
your data to provide you with the latest security features.
This Privacy Policy (the “Policy”) describes how [Cheetah Mobile Singapore Pte. Ltd]and its affiliates.
(also referred to as “Company,” “we,” “us,” or “our”), collects, stores, uses and protects your information
when you use our antivirus software “Clean Master for PC” and visit our website at (the “Site”) .In this policy,
the software and the website are collectively referred as “Services”
1. Acceptance of this Policy
By accessing, visiting or using our Services, you warrant and represent that you have read,
understood and agreed to this Policy. If you disagree with anything in this Policy, you must not use or access the Services.
2. Amendments to this Policy
We may periodically make changes to this Policy as we update or expand our Services.
We will notify you of any material changes to this Privacy Policy by notifying you via the email
we have on file for you, or by means of a notice on our Services in advance of the effective date of the changes.
If you do not agree to the changes, you should discontinue your use of the Services prior to the time the modified Policy takes effect.
If you continue using the Services after the modified Policy takes effect, you will be bound by the modified Policy.
Furthermore, we may provide you with “just-in-time” disclosures or additional information about the data collection,
use and sharing practices of specific Services. These notices may provide more information about our privacy practices,
or provide you with additional choices about how we process your personal information.
3. Information We Collected through the Services
In this Policy, the term “personal information” includes any information that identifies or makes an individual identifiable.
When you access or use our Services, we may generally collect the personal information described below.
A. Information You Directly and Voluntarily Provide to Us
| Type of information |
Examples |
What we use it for |
| Billing Information |
Email address, full name, country, payment method, credit card number, credit card security code, phone number，billing name and address or others; |
1) Purchasing a software license and send purchase receipts;
2) Verify a purchaser‘s identity;
3) Preventing financial fraud
|
| Customer Support Information: |
Email address, phone number, name, user feedback or others. |
1) Communicate with a user;
2) Respond to requests for support
|
| Account Information: |
Email address, birthday, friends list, or public profile information. |
1) Create a user account
|
B. Information We Automatically Collected Through the Services
| Type of Information |
Examples |
What we use it for |
| Device Information |
device’s brand, model, operating system, internet connection, hardware; city/country of device; error logs; browser type; software names installed on the device, including the Clean Master software and other antirust softwares |
1) Provide Clean Master service;
2) Improve and enforce our security measures; combat spam, malware, malicious activities or security risks;
3) Monitor the performance of Clean Master service;
4) Optimize Clean Master experience;
5) Conduct anonymized, aggregated analytics to improve Clean Master service performance
|
| Service Information |
usage and event information related to use of our Services, such as referral page; error logs; software configuration information; suspicious file hash; suspicious file name and path, the executable suspicious file, and the last local IP address. |
1) Provide Clean Master services;
2) Monitor the performance of our Service;
3) Optimize Clean Master experience;
4) Conduct anonymized, aggregated analytics to improve Clean Master service performance
|
4. Cookies & Similar Tracking Information:
This article only applies to our website and does not apply to Clean Master software.
There are no advertising or analytic cookies or tracking technology in Clean Master software.
We collect information about you when you visit our website, unless you tell us not to by adjusting your cookie setting.
We use such things as cookies and tracking technologies from our analytic service provider tools (e.g., Google Analytics).
Information collected includes Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referrer URL,
exit pages, the files viewed on our marketing sites (e.g., HTML pages, graphics, etc.), operating system, date/time stamp,
and/or clickstream data. We use cookies and similar tracking technologies to collect information about your interactions with our Site.
For more details about what cookies we use in our website, please visit our
Cookies Policy.
4. How We Use the Information We Collect
In addition to the purposes described in Article 3, we may also process the information from you for specific purposes.
If we use your personal information in any other ways, we will disclose this to you.
These additional purposes include but not limited to:
A.
To enforce terms, agreements or policies.
To ensure your safety and adherence to our terms, agreements or policies,
we may process your personal information to: actively monitor, investigate, prevent and mitigate any alleged or actual prohibited,
illicit or illegal activities on our Services; investigate, prevent, or mitigate violations of our terms and policies;
enforce our agreements with third parties and partners; and, collect fees based on your use of our Services.
We cannot perform our Services in accordance with our terms, agreements or policies without processing
your personal information for such purposes.
B.
To send you Service-related communications.
We use your contact information to send you administrative or account-related information
to you to keep you updated about our Services, inform you of relevant security issues or updates,
or provide other transaction-related information to you. Service-related communications are not promotional in nature.
You cannot unsubscribe from such communications because you could miss important developments relating to your account or
the Services that may affect how you can use our Services.
C.
For security purposes.
We process your personal information to: improve and enforce our security measures; combat spam, malware,
malicious activities or security risks; and to monitor and verify your identity so that unauthorized users do not access
your account with us. We cannot ensure the security of our Services if we do not process your personal information for security purposes.
Designated Countries:
For all purposes listed above, pursuant to the EU General Data Protection Regulation (“GDPR”) or any equivalent
legislation (collectively “Data Protection Laws”), we process the personal information of users located in the European Economic Area (“EEA”),
United Kingdom and Switzerland (collectively, the “Designated Countries”) based on our contract with you.
D.
To maintain legal and regulatory compliance.
We process your personal information to pay our taxes or fulfill our other business obligations,
and/or to manage risk as required under applicable law. We cannot perform the Services in accordance with our legal and regulatory
requirements without processing your personal information for such purposes.
Designated Countries:
Pursuant to the Data Protection Laws,
we process the personal information of users located in the Designated Countries to comply with our legal obligations.
E.
To conduct research and development.
We process information about the way you use and interact with our Services to:
help us improve our Services; build new Services; and build customized features or Services. Such processing ensures your
continued enjoyment of part or all of our Services. Designated Countries: Pursuant to the Data Protection Laws, we process
the personal information of users located in the Designated Countries to satisfy our legitimate interests as described above.
F.
To engage in marketing activities.
We may process your contact information or information about your interactions
on our Services to: send you marketing communications; deliver targeted marketing; inform you about events, webinars,
or other materials, including those of our partners; and, keep you up-to-date with our relevant products and Services.
Transactional communications about your account or our Services are not considered “marketing” communications. In addition,
when you share your friends’ contact information with us, we may reach out to them to invite them to our Services and to
continue receiving our communications. You can opt-out of our marketing activities at any time. Designated Countries:
For users located in the Designated Countries, please see section 9.C. below.
5. How We Share Your Information with Third Parties
We may share your personal information with third parties in the following circumstances:
A.
Employees, Third-Party Processors and Third-Party Service Providers
We disclose your personal information to our employees, contractors, affiliates, distributors, dealers, vendors and suppliers
(“Service Providers”) who provide certain services to us or on our behalf, such as operating and supporting the Services,
analyzing data, or performing marketing or consulting services. These Service Providers will only have access to the personal
information needed to perform these limited functions on our behalf.
Designated Countries:
Pursuant to the Data Protection Laws, we process the personal information of users
located in the Designated Countries based on our contract with you.
B.
Response to Subpoenas or Court Orders or to Protect Rights and to Comply with Our Policies
To the extent permitted by law, we will disclose your personal information if:
-
Required to do so by law, or in response to a subpoena or court order or similar request from judicial authority,
law enforcement authorities or other competent public authorities;
-
We believe, in our sole discretion, that disclosure is reasonably necessary to protect against fraud, to protect the property
or other rights of us or other users, third parties or the public at large; or
-
We believe that you have abused the Services by using it to attack our systems or to gain unauthorized access to our system,
to engage in spamming or otherwise to violate applicable laws.
Designated Countries:
Pursuant to the Data Protection Laws, we process the personal information of users located in the Designated
Countries based on our legal obligations, in the public interest, or your vital interests.
C.
Business Transfers or Bankruptcy
In the event of a merger, acquisition, bankruptcy or other sale of all or a portion of our assets, any personal information
owned or controlled by us may be one of the assets transferred to third parties. We will notify you via email or a prominent
notice within our Services of any change in ownership or uses of your personal information, as well as any choices you may
have regarding your personal information
Other than to the extent ordered by a bankruptcy or other court, the use and disclosure of all transferred personal
information will be subject to this Privacy Policy. However, any personal information you submit or that is collected
after this type of transfer may be subject to a new privacy policy adopted by the successor entity.
Designated Countries:
Pursuant to the Data Protection Laws, we process the personal information of users located in
the Designated Countries based on legitimate interests described above.
D.
Our Affiliates
Based on your consent, we may share some or all of your personal information with our, parent company,
subsidiaries and corporate affiliates, joint ventures, or other companies under common control with us.
Designated Countries:
Pursuant to the Data Protection Laws, we process the personal information of
users located in the Designated Countries based on your consent.
6. Children
We do not knowingly collect personal information from children under 18 years old, unless permitted to do so by applicable law.
Children are not permitted to use our Services unless they provide us with consent from their parent or guardian.
If we become aware that we have unknowingly collected personal information from a child, we will make commercially reasonable
efforts to delete such information in our database. If you are a parent or guardian of a child, and you believe your child has
provided us with their Personal Information on our Services, please contact us immediately at legalnotice@cheetahfun.com .
7. Security
We are committed to ensuring the security of your personal information. We have physical, technical and administrative
safeguards in place to protect the confidentiality of your personal information. In addition, we require that our service
providers handling personal information also maintain appropriate physical, technical and administrative safeguards to protect
the security and confidentiality of the personal information you provide to us.
However, we cannot guarantee the security of your personal information or that loss, misuse, unauthorized acquisition, or alteration of your data will not occur.
We also have no way of protecting any of your personal information that is not in our control, such as any information transmitted via email or wireless connections.
8. Retention of Personal Information.
We will try to limit the storage of your personal information to the time necessary to serve the purpose(s) for which your personal
information was processed, to enforce our agreement, policies or terms, to resolve disputes, or as otherwise required or permitted
by law. Please contact us if you have any questions about our retention periods. While retention requirements can vary by country,
we generally apply the retention periods noted below.
-
Marketing. We store information used for marketing purposes indefinitely until you unsubscribe. Once you unsubscribe
from marketing communications, we add your contact information to our suppression list to ensure we respect your unsubscribe request.
-
Device information and Service on Our Services. We may store any Device information and Service information about your
interactions on our Services indefinitely after your discontinuation for the establishment or defense of legal claims,
audit and crime prevention purposes.
-
Web Behavior Information. We retain any information collected via cookies, clear gifs, webpage counters and other technical
or analytics tools up to one year from expiry of the cookie or the date of collection.
-
Telephone Records. As required by applicable law, we will inform you that a call will be recorded
before doing so. Any telephone calls with you may be kept for a period of up to six years.
9. Information for Residents in the European Economic Area, United Kingdom and Switzerland (the “Designated Countries”)
This section only applies to users of our Services that are located in the European Economic Area, United Kingdom and/or Switzerland (collectively,
the “Designated Countries” ) at the time of data collection. We may ask you to identify which country you are located in when you use some of the Services,
or we may rely on your IP address to identify which country you are located in. Where we rely on your IP address,
we cannot apply the terms of this section to any user that masks or otherwise obfuscates their location information so
as not to appear located in the Designated Countries. If any terms in this section conflict with other terms contained in this Policy,
the terms in this section shall apply to users in the Designated Countries.
A. Our Relationship to You
[ Cheetah Mobile Singapore Pte.Ltd———]
and its affilates are data controllers with regard to any personal information collected from users of its Services.
A “user” is an individual providing personal information to us via our Services, such as by creating an account with our Apps,
signing up for our newsletter(s), or otherwise accessing or using our Services. A “data controller” is an entity that determines
the purposes for which and the manner in which any personal information is processed.
Any third parties that act as our service providers are “data processors” that handle your personal information in accordance with our instructions.
B. Legal bases for processing Personal Information
We describe our legal bases for processing in Section 4 (“How We Use the Information We Collect”) and Section 5
(“How We Share Your Information With Third Parties”) under headings entitled “Designated Countries.” The legal bases on
which we rely on to process your personal information include: your consent to the processing; satisfaction of our legal obligations;
necessity to protect your vital interests; necessity to carry out our obligations arising from any contracts we entered with you or
to take steps at your request prior
to entering into a contract with you; necessity to process in the public interest;
or for our legitimate interests as described in those sections.
C. Marketing Activities
If you are located in the Designated Countries and are a current user, we will only contact you by electronic means (such as email or SMS)
per your communication preferences and/or with information about our Services that are similar to the Services you previously purchased
from us or negotiated to purchase from us.
For new users located in the Designated Countries, we will contact you by electronic means for marketing purposes
only based on your consent or based on your friends’ consent. You can always withdraw your consent or change your marketing
communication preferences at any time and free of charge. To opt out of the emails, please click the “unsubscribe” link in the footer
of marketing emails or contact us at legalnotice@cheetahfun.com . Marketing communications are promotional in nature and do not include
transactional or Service-related communications.
D. Individual Rights
We provide you with the rights described below when you use our Services. Please contact us at legalnotice@cheetahfun.com if you would like to
exercise your rights under applicable law. When we receive an individual rights request from you, please make sure you are ready to verify your identity.
Please be advised that there are limitations to your individual rights. We may limit your individual rights in the following ways:
- Where denial of access is required or authorized by law;
- When granting access would have a negative impact on other's privacy;
- To protect our rights and properties; and
- Where the request is frivolous or burdensome.
Right to withdraw consent.
If we rely on consent to process your personal information, you have the right to withdraw your consent at any time.
A withdrawal of consent will not affect the lawfulness of our processing or the processing of any third parties based on consent before your withdrawal.
Right of access and rectification.
If you request a copy of your personal information that we hold, we will provide you with a copy without undue
delay and free of charge, except where we are permitted by law to charge a fee. We may limit your access if such access would adversely affect the
rights and freedoms of other individuals. You may also request to correct or update any of your personal information held by us, unless you can
already do so directly via the Services.
Right to erasure (the “Right to be Forgotten”). You may request us to erase any of your personal information held by us that:
is no longer necessary in relation to the purposes for which it was collected or otherwise processed; was collected in relation to processing
that you previously consented to, but later withdrew such consent;
or was collected in relation to processing activities to which you object, and there are no overriding legitimate grounds for our processing.
Right to restriction. You have the right to restrict our processing your personal information where one of the following applies:
-
You contest the accuracy of your personal information that we processed. We will restrict the processing of your personal information,
which may result in an interruption of some or all of the Services, during the period necessary for us to verify the accuracy of your personal information;
-
The processing is unlawful and you oppose the erasure of your personal information and request the restriction of its use instead;
-
We no longer need your personal information for the purposes of the processing, but it is required by you to establish, exercise or defense of legal claims; or
-
You have objected to processing, pending the verification whether the legitimate grounds of our processing override your rights.
We will only process your restricted personal information shall with your consent or for the establishment, exercise or defense of
legal claims or for the protection of the
rights of another natural or legal person or for reasons of important public interest. We will inform you if or when the restriction is lifted.
Right to object to processing. You may object to our processing at any time and as permitted by applicable law if
we process your personal information on the legal basis of consent, contract or legitimate interests.
We can continue to process your personal information if it is necessary for the defense of legal claims,
or for any other exceptions permitted by applicable law.
Right to data portability. If we process your personal information based on a contract with you or based on your consent,
or the processing is carried out by automated means, you may request to receive your personal information in a structured,
commonly used and machine-readable format, and to have us transfer your personal
information directly to another “controller”, where technically feasible, unless exercise of this
right adversely affects the rights and freedoms of others.
Notification to third-parties. If we share your personal information with third parties, we will notify them of any requests
for rectification, erasure or restriction of
your personal information, unless this proves impossible or involves disproportionate effort. Upon your request,
we will identify such third parties.
Automated individual decision-making, including profiling. You have the right not to be subject to a decision based solely on
automated processing of your personal information,
including profiling, which produces legal or similarly significant effects on you, unless an exception applies under applicable law.
Right to Lodge a Complaint. If you believe we have infringed or violated your privacy rights, please contact us at
legalnotice@cheetahfun.com
so that we can work to resolve your concerns.
E. Transfer of Personal Information
If you choose to use the Services or provide your information to us, your personal information may be transferred to, processed
and maintained on servers or databases located outside of the country or jurisdiction where you are located. Such countries or
jurisdictions may have data protection laws that are less protective than the laws of the jurisdiction in which you reside. If you do not want your information
transferred to or processed or maintained outside of the country or jurisdiction where you are located, you should not use the Services.
Designated Countries:
We transfer your personal information subject to appropriate safeguards as permitted under the Data Protection Laws.
Specifically, when your personal information is transferred out of the Designated Countries, we have the required contractual provisions for
transferring personal information in place with the third-parties to which your information is transferred. For such transfers, we rely on
legal transfer mechanisms such as Standard Contractual
Clauses or we work with U.S. based third parties that are certified under the EU-U.S. and Swiss-U.S. Privacy Shield Framework.
10. Special Information for California Residents.
We provide a separate
<Privacy Notice for California Consumers> which addresses how we respect California's users' privacy.
If you’re a user resided in California in US, you can visit this policy for more details.
11. How to Contact Us.
If you have any questions about this Privacy Policy, please feel free to contact us by email[legalnotice@cheetahfun.com].