January 15th 2019
When this policy applies?
We have made this policy as short and easy to understand as possible, so please take your time to read it so you can have all the information to decide whether you want to sign up and share your data with Softonic.
The personal data to which we have access is the data that you will voluntarily provide upon sign up as required for the use of certain services. In addition, Softonic has engaged with third party ads partners to provide our newsletter subscribers with relevant ads (currently Taboola and PowerInbox). Subscription to our newsletter is voluntary. Provided you have opted-in to receive our newsletter, our ads partners will collect the following information:
- User’s device, browser and operating system
- Mobile device information (all mobile IDs are hashed)
- IDFAs and /or Android Ad IDs (AAIDs)
- Cookie data that may be read or deployed by ads partners (all cookie IDs/user IDs are hashed)
- Truncated IP Addresses
- Referring website
- User’s language
- How the ads are displayed and whether the user interacted with the Platform
- Web or app behaviour
- Hashed email addresses
You can easily sign up via the available social media sign up options or by filling out the necessary online forms where this option is available. Fields marked with an asterisk (*) are mandatory. Lack to provide the mandatory data will preclude you from signing up.
Who am I sharing my data with and who is the data “controller”?
A data controller is the entity that you provide data with and decides on the purpose of the data, provided your prior consent or other legal basis:
Corporate name: Softonic International, S.A.
Address: MediaTIC building, Calle Roc Boronat, 117, 6th floor, 08018 Barcelona, Spain
Phone number: +34 936 012 700
Email address: email@example.com
Data Protection Officer direct contact: firstname.lastname@example.org
Please do not hesitate to reach us by any of the means above for any question about data protection and privacy.
What are the purposes of the data processing?
- Creation of a community of users interested in software, so you can share your opinion and preferred programs and solutions with other users.
- To show you other users’ opinions about programs or solutions.
- To inform you about reviews, news, tutorials, opinions, all related to the world of software.
- To recommend you software, based on your interests, download history and navigation habits on the website, as well as based on your comments using your Softonic social media profile.
- Provided you have chosen to sign up with your social media profile and you have opted so, we will show you ads, suggest software and customize your experience through the site based on your interest (i.e using your Facebook “Likes”) and customize our newsletter (provided you have opted in to receive our newsletters).
- To study and analyse the information provided, as well as based on information obtained in aggregate format for statistical and analytics purposes via cookies (see our Cookies Policy for more info), in order to evaluate new trends, develop new services or check the result of an ad campaign.
- To send you emails about updates, service announcements or as required to provide you with the subscribed service. This kind of communications do not have a commercial nature and we will inform you on how to unsubscribe on each communication.
- Provided your previous consent, to send you emails regarding the software sector.
- To address you properly on our emails (i.e dear “John Smith”)
- To create a user profile. We will not use your profile for automatic individual decision-making.
- To show you relevant ads on the website, newsletters and web notifications.
- To show you relevant ads in other websites and social networks that may be of your interest (see our Cookies Policy at this regards).
- To check you are above 14 years old, so you can give us a valid consent to provide your data.
- To answer your questions, complaints and provide general support, if you contact us via our support portal, other online forms or directly via email.
- Provided you have voluntarily opted-in to receive our newsletter, you will receive customized ads on our newsletters.
We’ll keep your data as long as we don’t receive a deletion request from you and as long as permitted by Law. You can delete your account at any time via your user area.
What’s the legal basis of the processing?
The legal basis for the processing of your data is your consent and our legitimate interest (customized content and ads on emails)
For children below 14 years old, we require the authorization of parents or guardians for signing up. Please contact us via email to email@example.com if you want your children to subscribe and we’ll provide you further instructions to do so.
Will my data be shared with third parties?
Third-party service providers . Softonic has engaged with several trusted third parties-service providers (data processors) in order to provide the service. For instance, they provide us with services such as hosting, data management or direct marketing related services, so they need to access certain data on as needed strictly basis. Softonic requires all its providers to certify that they have adopted adequate organizational and security measures to comply with our data protection standards and require them to commit to adopt further legal safeguards. Where the relevant provider is located outside the Economic European Area (EEA), we require the adhesion to the US-EU Privacy Shield or the signature of EU standard clauses.
Below you’ll find a list of providers located outside the EEA, the country and the existence of absence of an adequacy decision by the EU Commission (when the EU Commission has determined that a certain country offers sufficient guarantees for the protection of personal data and privacy) and the relevant safeguards adopted.
Google, Inc . U.S. Adequacy decision in the framework of the EU-US Privacy Shield. Google is adhered to the Privacy Shield.
Amazon.com Inc . U.S. Adequacy decision in the framework of the EU-US Privacy Shield. Amazon is adhered to the Privacy Shield.
Fastly , Inc. U.S. U.S. Adequacy decision in the framework of the EU-US Privacy Shield. Oracle is adhered to to the Privacy Shield.
Oracle America Inc. U.S. Adequacy decision in the framework of the EU-US Privacy Shield. Oracle is adhered to to the Privacy Shield.
Salesforce, Inc . U.S. Adequacy decision in the framework of the EU-US Privacy Shield. Salesforce is adhered to the Privacy Shield.
Onesignal , Inc . U.S .Adequacy decision in the framework of the EU-US Privacy Shield. EU Standard Contractual Clauses (Processors)
Powerinbox , Inc U.S. Adequacy decision in the framework of the EU-US Privacy Shield. In process to sign the EU Standard Contractual Clauses (Controllers)
Visit https://www.privacyshield.gov for more info about the Privacy Shield and to check that the above companies are adhered.
Business Transfers : As we continue to develop our business, we might sell or buy other companies, subsidiaries, or business units. In such transactions, user information generally is one of the transferred business assets but remains subject to the promises made in any pre-existing privacy policies (unless, of course, you consent otherwise). Also, in the event that Softonic, or substantially all of its assets are acquired, user information will of course be one of the transferred assets.
Please visit our Cookies Policy to know the data we and third parties process via the usage of cookies and other similar technologies
What rights do I have?
Softonic has created a user area where you can have control over your data, including the ability to request your rights to access, rectify and delete, restrict the processing and to object certain processing (i.e unsubscribe from our newsletter or to withdraw your consent to share your social media interests). In case where you don’t have access to your user area you may send us as email to firstname.lastname@example.org to request your rights.
You can as well unsubscribe from receiving our newsletter at any time by clicking the relevant button at the bottom of the any email we send you.
Furthermore, some ads our third parties display on our email newsletter (currently Taboola and PowerInbox) contains a hyperlink, which you can click and choose to opt-out of receiving content based on your interests. By opting out, our third party ads partners will no longer track you online activity and make personalized recommendations on the opted-out device or browser, but will still provide generic recommendations not tailored to you. Please note that i) opting out of one device or browser will not result in opting out across all connected devices or browsers and ii) this functionality might be not available on all ads you’ll see on our newsletter but remember you can opt-out to receive our newsletter at any time.
If you have subscribed to our web notification service you can opt-out at any time via your web browser following these steps .
Please note that the exercise of your right to erasure or to object to certain data processing will not affect the lawfulness of processing based on your consent before withdrawal.
We will process your data to create a profile that will include the data you provide, along with data related to your behaviour in the web site, how you react to our email campaigns and your social media interest (if you have chosen to share them with us) but will not be used for automatic individual decision-making purposes. This profile will be used to show you customized content and ads that will be more relevant to you. You can also opt-out from this type of processing at any time via your user area.
Visit the Spanish National Data Protection Authority website to learn more about your rights. Be informed that you have the right to lodge a complain before the Spanish National Data Protection Authority specially if we have failed to comply with your request to exercise your rights.
Is my data secured?
We have adopted adequate technical and organizational measures to avoid alteration, loss or unauthorised access to your data: We select only trusted and certified providers that process your data and we take care that they have taken strict measures too. We and our providers also use encryption protocols to access or transfer your data and techniques to anonymize data to mitigate the risks in case of a data leak.
How can I know if you change this policy?
We will inform you sufficiently in advance if there are important changes and require your consent if any of those changes impact your privacy rights.
Last Version 15 January 2019. © Softonic International, S.A. See previous version here.