F-Secure FREEDOME VPN privacy policy

February 2019

In brief

We respect your right to privacy.

  • We encrypt your data traffic.
  • We do not share nor sell any of your traffic.
  • We do not read your traffic.
  • We do not know what traffic is yours.
  • We have no back doors.

In full

This service-specific policy focuses on the items we believe are the most relevant for you. Such items are in particular 1) the type of personal and private data that the service collects, 2) what we use it for, 3) our justification, 4) typical disclosures, and 5) for how long we store it. More information on such topics as well as on other aspects (data subject rights, contact information, etc.) of the processing of your personal data is also available via the embedded links.

What do we collect and what do we do with it?

Your private communications. Our guiding principle is that we do not seek to spy on the exact content of your private communications. We only analyze your communications traffic to provide you the service and to keep your data transfers clean. To be more exact, this means that:

  • we need to process some metadata (such as volume, country, IP address) of your traffic when providing the service to you;
  • as an information security company, we analyze the traffic for suspicious or malicious files and destinations (i.e. URLs);
  • we automatically screen the traffic to inhibit usage that is against our acceptable use policy; and
  • the service collects statistics to give you a view of your browsing history via the service, but we do not connect this information to you.

Service provisioning logging. When the service is taken into use or a license is modified at later stages of the lifecycle, the provisioning log data is collected. This is done in order to enable and diagnose successful provisioning to authorized devices, detect abuse of the service, and as a precaution for disaster recovery in case it is needed. This log contains the IP address of the client, a random device ID generated by the service, the time of access, the country code obtained via a GeoIP lookup of the client IP address, and other similar technical device data.

Service logging. We do not keep any logs about connections established through the VPN service to external addresses. We cannot link the IP address of your browsing destination to you.

To protect the service against fraudulent use, we maintain temporary logs that contain the duration of the VPN sessions, the amount of data transferred, the device ID, public IP address, and host name from where the VPN client connects to our service. Traffic anomalies that look like a potential abuse of our service (such as port scanning, spamming, or DDoS attacks performed by our clients) are detected by our software and will be logged as well. The logs are stored for 90 days prior to deletion, and can be used to deal with any misuse of our service or attacks against us.

Tracker Mapper. With the Tracker Mapper feature, you can choose to log the tracking data of your traffic for 24 hours. The log is required for displaying the blocked tracking attempts as a visual map to you. The Tracker Mapper log will be marked for deletion and detached from the user record once you start a new log, delete it manually, or automatically after 3 days.

Securing your device with Security Cloud.

The service sends queries on potential malicious activity, malicious software, or unwanted applications on protected devices, data traffic, and networks to F-Secure Security Cloud. These queries – such as URLs, file identifiers, and application metadata – cannot be connected to an identifiable user by F-Secure. The Security Cloud data collection is explained in more detail in its dedicated privacy statement.

To protect your privacy, F-Secure separates the above security data from other data collected on your use of the service, anonymize it, and destroy it when it is no longer need it for the purpose.

No back doors. This service and the underlying infrastructure are built to protect you from undesired spying – by governments, criminals, stalkers, or commercial entities. We do not build back doors to our services.

Criminal investigations. F-Secure respects lawful warrants and court orders of the jurisdictions applicable to us. We provide information to the authorities when it is required of us under law, but not otherwise. Such occurrences include investigations and prosecutions of serious crimes and other qualified illegal activities. After all, our goal is to secure your privacy when browsing the web, not securing your anonymity when committing crimes. We carefully review the lawfulness of each request and ensure that our users' constitutional rights to privacy are protected.

Customer relationship data

The Service collects a varying set of data depending on where you download or purchase the service.

Application stores: number of purchased licenses / purchase history for F-Secure products; price and time of purchase; order number; technical environment (e.g. operating system) of your device; unique identifiers (e.g. Android marketing identifier); service statistics per device; other similar non-sensitive device and service data.

F-Secure e-store: In addition to the above; name, email, language, address, country, zip code, Internet Protocol (IP) address, payment type. More detailed information can be found from our e-store.

Service portal: To help you in managing your subscriptions and settings and to help us help you better in case of problems, the following data from all of the devices and users in the subscription is visible to those who share the same subscription: user / device name, profile name, first name, last name.

Operator partner: If you have subscribed to the service via your operator, the data set we collect varies per operator partner, but is limited to the above data. We also exchange some such data as explained below under "Transfers and disclosures".

Support. In cases where we provide you with personal support services, we may need to ask you for additional information.

We use customer relationship data for the following purposes:

  • Customer journey. To identify authorized users and check customer qualifications, process and track transactions such as administering accounts, shipping, invoicing, managing licenses, financial controlling and auditing, and customer support requests.
  • Deliver, fix, and enhance. To deliver our services to you, maintain and develop our services and websites, and to provide help and support for the services.
  • Analyze. To track how our services are acquired and used so that we can improve the services, manage your customer relationship, and approach you with relevant messages.
  • Communicate. To send you information relating to the services, conduct customer surveys, arrange competitions, advertise and market our services to you.
  • Regulatory. To prevent fraudulent activities, remove or stop sharing of illegal or infringing material, and comply with legal or regulatory requirements.

Legal grounds

F-Secure processes your data so that we can provide you with our services that you have made a contract for or are in the process of doing so. Such contracts may be made either directly with F-Secure or with another entity (such as our webstore or operator partner) that has tendered our services to you. Tendering of services may take the form of a purchase or be free of charge.

In the case of data that is not strictly necessary to provide you with the services – but would help F-Secure in providing you with better services in the long run – we collect such data only with your consent.

Learn more

This section gives you a more comprehensive explanation of the legal grounds based on which we process personal data. This complements the exact service-specific legal grounds on which our personal data processing relies for the respective activity.

Client relationship data

By using our services, you are our client. To interact with you and to provide our services to our clients, we must process some data on you. Such processing typically occurs when you communicate with us or our business partners relating to our services, install and use our services, fill out a form or survey, register to use our services, submit information through our web solutions, enter a contest or sweepstakes, register your email address with us, or send us email.

Since we need the data to pursue the above legitimate activities, we have a right to process relevant personal data. This right typically takes place in the form of "contract performance", "legitimate interest", or "consent".

Service data and security data

We need to automatically collect and process relevant data for our services to work, to enhance them, and to provide them to you. The data is processed to:

  1. provide F-Secure services to secure our customers’ networks and devices as well as the confidentiality and availability of the data therein;
  2. enable F-Secure to detect emerging threats and security-relevant trends among all of its customers, so that our services can keep on par with evolving threats;
  3. enable F-Secure to provide a centralized security framework across multiple continents to a large number of customers and partners.

The data processing performed by the services is mandatory for the efficient protection of the device/network and a prerequisite for F-Secure’s capability to provide its contracted services. As such processing is inseparable from the services that we provide to you, this gives us a valid need to process your data and a justification to do so.

For consumer products, this right takes place in the form of "contract performance". For corporate products, this right takes place in the form of "legitimate interest". In some cases, there is also a "legal obligation" to process data for specified purposes.

Analytics data

Where our services collect data that is only needed for the purpose of gaining more insight on how people use the services or how to serve you better, but is not necessary for providing our services, we do so only with your separate consent. You also have the right to withdraw your consent later, should you wish to do so.

We also reuse the above service data and security data for data analytics purposes, based on the legal grounds established above. Data analytics are an integral part of our service delivery, as nearly all F-Secure services are dependent on our infrastructure to properly operate. Our data analytics enables us to direct that infrastructure to support your use of the services.

The legal grounds for data that is solely collected for analytics purposes is "consent".

Secondary uses

In addition to above primary legal grounds for data collection, we may also need to use and/or continue to store data i) to meet a "legal obligation" to process data for specified purposes, or ii) under the grounds of "legitimate interest". For an example list of situations where we may resort to such justifications, see the "Other disclosures" section.

General

We consider you a client of F-Secure, not a client of the individual service. Hence, data collected by different services (e.g. SAFE) and interactions (e.g. contacting support) are combined to your F-Secure account. However, we do not aggregate data against our specific privacy promises (for example, we maintain a hands-off approach to your traffic inside our VPN service).

Transfers and disclosures

If you have subscribed to the service via our partner, such as a teleoperator, that partner may undertake some of the activities listed above in our stead (such as user authentication or communications). We also exchange with the partner such above listed data (e.g. status of your subscription, installation success, service in active use, data collected for resolving a technical support case) as is necessary and proportional. We do the above exchanges to provide you with a smooth customer experience and support services, and to communicate with you in a consistent manner.

With your permission, the partner may also access your account to provide you with customer support.

Learn more

Sales and delivery

We exchange (both disclose and receive) some of your personal data with our distribution partners (resellers of corporate IT services, operators, webstores, etc,), who market, distribute, administer, and support our services. We provide these companies access to such personal data that they may need for their agreed activities. The logic of this data sharing is to provide a seamless customer experience. This includes activities such as customer management, service support, incident management and problem resolution, direct marketing, and invoicing.

Our distribution partners are likely to have a pre-existing customer relationship with you or – in the case of our corporate services – with your employer. Such partners and corporate customers process your personal data as an independent entity, based on their applicable privacy policies. Regardless, our distribution partners and corporate customers must also comply with the agreements and legislation when handling your personal data. Each such entity is by default independently responsible for its own treatment of personal data, for its own purposes.

Subcontracting

We may transfer or disclose some of your personal data to F-Secure group companies and our subcontractors who help us create the services.

Where our clients’ personal data needs to be transferred or disclosed to our subcontractors, we require, in our contracts with them, that they use such information solely for providing their agreed services (for example, to solve a support case, to send it to logistics partners for product delivery, or to send marketing mails on our behalf). We require our subcontractors to process data pertaining to you in a manner that is consistent with our statements herein.

International transfers

F-Secure operates globally. Consequently, some of our affiliates, subcontractors, distributors, and partners are located outside the European Economic Area to ensure the global reach and availability of our services.

When we transfer personal data outside the European Economic Area, we secure such transfers of personal data according to the requirements of the law. We do this by imposing appropriate technical and contractual safeguards on relevant subcontractors and F-Secure group companies, for example by using data transfer clauses that are approved by the European Union – the fixed content of such clauses is available here.

In some cases, we may also accept other mechanisms to justify transfer outside the EEA. Such other justifications include providing data to entities who have registered under the United States’ Privacy Shield program or providing data to entities processing such data in countries with an adequate level of privacy legislation that safeguards the data subject’s rights.

We only do global or cross-border data transfers for a good reason and after assessing the resulting privacy risk.

We store more sensitive customer data within Finland or the European Economic Area and keep it under our own control.

Other uses and disclosures

There are circumstances not covered by this privacy policy where the use or disclosure of personal data may be justified or permitted, or where we may be obligated by applicable laws to disclose information without acquiring your consent or independent of service provisioning.

One example includes complying with a court order or a warrant issued by the authorities in the relevant jurisdiction to compel the production of information.

Similarly, there may be other circumstances where there is a justifiable legitimate interest to disclose limited sets of information to a third party. Examples of such disclosures include cases where we need to protect ourselves against liability or to prevent fraudulent activity, where it is necessary to solve or contain an ongoing problem, or where we need to meet the legitimate information requirements of our insurers or governmental regulatory agencies. In any such action, we will act according to the applicable laws.

We may also need to transfer your personal data as part of a corporate transaction, such as a sale, merger, spin-off, or other corporate reorganization of F-Secure, where the information is provided to the new controlling entity in the regular course of business. F-Secure group discloses and transfers data internally as required by our then current operational model. We do, however, limit the disclosures internally to only those group companies, units, teams, and individuals who have a need to know such information for the intended purposes of processing it.

We weigh each disclosure requirement carefully and take the possibility of such disclosure requests into account when deciding where and how we store your personal data.

Sources

While we collect the majority of the above-mentioned data directly from you or your device, we also receive data from our affiliates, distribution partners (such as operators and retailers), and corporate entities from whom you have purchased the services. Such entities may be our resellers, but also include our external webstore partners. We also acquire some basic personal data (order data on purchases) and aggregate analytical data from app stores in which our services are sold. Such other sources may further include subcontractors who have provided you with support for our services, or advertising partners who have assisted us in conducting our marketing activities.

We do this to create a seamless customer experience and to have the necessary information for solving support cases.

Typical examples of third-party sources are:

  • information on your purchase made in our external webstore,
  • we acquire your credentials from previous sign-in data from our operator reseller partner, so that we can provide our service to you directly,
  • we acquire your contact data from corporate decision-maker registries for marketing purposes, and
  • when you use your social media account to register to our services, we collect the email address from your account to enable us to authenticate your registration and to contact you.

Third parties

Our services are provided in conjunction with our partners and our services and websites may embed or interoperate with third-party services. This privacy document only applies to personal data as long as that data is within F-Secure’s realm of influence. Where your personal data is processed by other entities for their independent purposes, such other party is responsible for processing your personal data in a justified manner in accordance to their policies as well as for fulfilling your rights under data protection laws.

The most prevalent such scenarios are the following:

  • Webstore. Our webstore is partially run by a third-party reseller. While the data you enter in the registration phase is handled under F-Secure policies, our webstore providers’ policies apply to the actual purchase and related activities.
  • Device location queries. When you query the location of your device via our services, the provider of maps needs to process the related geographical data. On the publication date of this policy, F-Secure uses Google maps in our device location and search features. Google privacy policies shall apply accordingly to your use of the features.

Retention

Personally identifiable user data is retained for the duration of an active service subscription plus for the grace period of six months thereafter. This is to allow customers to re-engage their expired subscription. Thereafter, the customer account will be scheduled for removal.

Additionally, some data is subject to more limited data retention practices.

  • Service provisioning log entries are retained for one year, after which they are deleted.
  • Service log events for provisioned devices are retained for three months, after which they are deleted.
  • Tracker Mapper data is retained for 96 hours, after which it is deleted.

If you have purchased the service via our operator partners, the account deletion is controlled by that operator partner. When the partner notifies us that your subscription has been terminated, F-Secure subsequently removes the account and deletes or anonymizes personal data related to the account.

Some operators offering the services are subject to more comprehensive data retention obligations than F-Secure. In such cases we may collect additional service / traffic log data and retain it longer than set out above. The data is collected to assist the operator to comply with local laws and only for this purpose.

Learn more

This text complements the service-specific retention times. The default rule under the law is that personal data should be deleted or anonymized once it is no longer needed for its purpose.

However, some personal data needs to be nonetheless stored for longer periods of varying lengths due to varying reasons.

Typical reasons why we deviate from the primary retention times include the following examples:

  • grace periods and backups (e.g. keeping your personal data stored for a designated time after the end of your subscription, so that we can safeguard the data against erroneous deletion);
  • applicable laws require us to store the data (e.g. to keep track of the purchase and payment of our services);
  • to pursue available remedies or to limit any damages that we may sustain (e.g. due to an ongoing dispute or investigation);
  • to solve or contain a recurring problem or to have enough information to respond to future issues (e.g. your support ticket related to a problem that was not permanently corrected during your customership);
  • to prevent fraudulent activity (e.g. to enforce a ban on our community);
  • your personal data is incorporated to other data for a secondary purpose (e.g. retaining logs);
  • other similar circumstances, where there continues to be a legitimate need for the ongoing storage of personal data.

The final removal of your account may be delayed to avoid disturbing the other interactions you have with us. This is the case when you have an F-Secure account (e.g. you have subscribed to our consumer services with your email address) and also i) have an F-Secure Community account or ii) you continue to subscribe to our marketing messages. The F-Secure Community account deletion policy is set out in its terms of service. You can opt out from our marketing messages at any time.

If you have purchased our service via one of our operator partners, account deletion is controlled by said operator partner. Upon the partner notifying us that your subscription has been terminated, F-Secure subsequently removes the account. This removal leads to the deletion or anonymization of any personal data related to the account.

If we have received your information when providing you with technical support, the information is stored as long as the respective support case remains unsolved. Once solved, the information is gradually deleted or anonymized within two years from closing the case.

Analytics data collected with the user’s consent is retained for statistical purposes and is not deleted on removal of personal data and the user account. After termination of the account, analytics data cannot be linked to any personally identifiable user.

Data that does not contain personal data (e.g. security data and aggregate analytical data) is retained as long as such data continues to be useful for the purpose it was collected.

Analytics

For us to learn when and how you use our service, to enhance it, and to learn how customers find out about the service, the service collects data on installation success, installation and activation paths, performance, operation environment, connections, used features, etc. We do this so that we can create services that are of value to you and our other customers.

To respect our own core privacy promise, we do not have these third-party usage analytics targeting your actual communications traffic.

Learn more

This section outlines our general practices for the collection and processing of data for analytics purposes.

When speaking about F-Secure data analytics, it comprises both reused service data, reused security data, and the data that is collected for analytics purposes to begin with.

We want to give you a more personal customer experience and provide you with even better services in the future. For that we need to track usage patterns and create customer segments. For example, what features are used most, where the service fails, what needs fixing, and how you found out about our services.

What we collect. The data that we process for the purposes of data analytics include things like device identifier and relations between devices / users / user groups, operation environment, service operation time, license type (trial or paid version), device metrics (such as phone model and operating system, language), partial IP address, service errors, problematic files and service performance data, how you interact with our services (such as which features are used and how often), the domain name from which you connect to the service, elements clicked, timestamps, regional location, effectiveness of our in-service messaging, service activation (such as tracking that you have received the related messages and that installation was successful), installation and activation paths, service performance, connections, data routing, quota, and other similar data.

On a practical level, when we ask for your consent in our services’ user interface, it controls whether the following data is sent: i) additional data, like which features are used and how often, and service metrics, and ii) the number of attributes sent in a given data set.

The above relates to your use of our cyber security services. Data analytics running on our websites are described in our website privacy policy.

Opting out. We really appreciate your help in improving our services. However, if you want to minimize all data traffic towards F-Secure, we respect that. Those of our services that employ additional analytics give you the choice on whether to contribute. You can opt out at any time from the subsequent collection of analytical data that is non-essential to our service provisioning.

If you have opted out from all analytics data collection, our messaging directed to you will be based only on the service data collection (the data that we collect in any case to provide you with the services) and some of our messaging is likely to be less relevant.

If you oppose all collection of data from your online life (including our websites), the more wholesale method for preventing online advertisers from profiling your mobile device usage is to reset the advertising identifier from time to time and to turn on the do-not-track setting in your device settings, or to use our privacy product.

Analytics data retention. In our data analytics activities, we combine analytics data with the service data. The resulting combined data set then continues to be processed based on a "legitimate interest". The previously collected analytical data is retained as part of the service statistics, as its retroactive removal would break the statistics. When you cease subscribing to our services (i.e. your account is deleted), the analytical data related to your service use will be reverted to anonymous data, and we are no longer able to associate it with you.

Data exchange. Because of the technical environment (that is, the internet, the app store ecosystem, and social media), we are not able to do all of the collection and activities related to data analytics ourselves. We have to exchange some data (such as "Android marketing identifier" and other like identifiers) with our online analytics and marketing partners to enable our digital analytics and marketing activities. The vast majority of the data that we have on you is not shared with others.

Some of our subcontractors who provide us with analytical capabilities for our products may also create and publish aggregate reports on the data that they have collected. In such cases, the statistics and aggregate reports do not contain any data that could be linked to any individual person.

We do not sacrifice your privacy. Where we differ from most companies doing this is in that we understand how the ecosystem works and go through great pains to select our few partners with care, removing all data that is not absolutely necessary for the above purpose. You can naturally opt out from the collection of analytics data at any time via the service settings.

When we process the data for analytical or statistical purposes, we pseudonymize the data. In other words, our data analysts do not know the individual to which a specific data set refers to. The pseudonymization is only reversed in specified use cases. For example, when we communicate with you, we connect the results – not the full data – of our data analytics to your email address. Another example is that we may use the data to resolve issues you may have with our product, when providing you with technical support services.

We also limit such added analytics only to the surface of our services and keep them at arm’s length from the core privacy areas of our services. For example, we do not have any external analytics in our security cloud or in the traffic inside our VPN service.

Security

Information on the security practices that we employ to keep your data secure.

Learn more

We apply strict security measures to protect the confidentiality, integrity, and availability of your personal data when transferring, storing, or processing it.

We use physical, administrative, and technical security measures to reduce the risk of loss, misuse, or unauthorized access, disclosure, or modification of your personal data.

All personal data is stored on secure servers operated by F-Secure or our partners with access limited to authorized personnel only.

Your rights

Information on your statutory rights and how to contact us.

Learn more

You have the right to the data that we have on you. In particular, you have the following rights to the personal data that we hold on you:

  • Access and rectification. You have the right to ask us what personal data we have on you and to get a copy of the data that we can identify pertaining to you in this context. Should you find any errors (e.g. obsolete information) in such data, we urge you to contact our customer care to resolve the issue. Some of our service portals allow you to update your customer information. For such, you should update any changes to your personal data, for example change of address or email address. If you cannot update the changes yourself, you may inform us of the necessary changes.
  • Objection. You are entitled to object to certain processing of personal data, including for example the processing of your personal data for marketing purposes or when we otherwise base our processing of you on a legitimate interest. In the latter case, you need to establish a legally valid rationale for your objection.
  • Right to be forgotten. You also have the right to request us to cease storing your personal data and erase it. In this case you need to establish a legally valid rationale for your request.
  • Portability. You also have the right to ask for personal data that you yourself have provided – pursuant to a contract or your consent. You may request the data in a structured, commonly used, and machine-readable format and further that the data is transmitted to another controller, where technically feasible.
  • Withdrawing consent. In cases where the processing is based on your consent, you have the right to withdraw your consent at any time via relevant settings. For identifiable service analytics data, you can find the settings in the service user interface. You also have the right to opt out from our marketing communications via the preference center accessible through the link.
  • Restriction. If you establish that the data we have on you is incorrect or we have no legal right to use it, you may request that we cease any further processing of your personal data, and merely keep it in store until the issue is resolved.

You can exercise your rights via our customer care function. The links to contact us are in the "Contact information" section.

Note that there may be situations where our confidentiality obligations, our right of professional secrecy, and/or our obligations to provide our services (e.g. to your employer) may prohibit us from disclosing or deleting your personal data or otherwise prevent you from exercising your rights. Your above rights are also dependent on the legal grounds based on which we process your personal data.

If you have any complaints about how we process your personal data, or would like further information, please contact us at any time. If you feel that we are not enabling your statutory rights, you have the right to lodge a complaint with a supervisory authority. In most cases, this authority is the Finnish Data Protection Ombudsman (www.tietosuoja.fi).

Contact information

If you have any questions or concerns about the matters discussed in our privacy policies, please contact:

F-Secure Corporation
Tammasaarenkatu 7
PL 24
00181 Helsinki
Finland

How to contact us:

  • If you are a client of our consumer line of products, please contact us via f-secure.com/support.
  • If you are a client of our corporate line of products, please contact us via f-secure.com/corporate-support.
  • If you are a client of MWR Infosecurity, please use the contact information at mwrinfosecurity.com/privacy-policy/.
  • You can contact F-Secure’s Data Protection Officer by sending a message to privacy-office@f-secure.com. If you wish to exercise your rights as a data subject, please use the above links instead.

 

General

Information on definitions and change management.

Learn more

Definitions

This is what we mean when we make certain references within this policy.

"Client", "you", refers to a private or corporate user or any other data subjects who buy, register for use, or use our services, whose devices and data traffic are protected by our services, and who may have submitted personally identifiable information to us. This information may have been submitted through the use of our services, websites, telephone, email, registration forms, or other similar channels.

"Personal data" refers to any information on private individuals that is identifiable to them or their family or household members. This information may include names, email and mailing addresses, telephone numbers, billing and account information, and other, more technical information that can be linked to you, your device, or the behavior of either, that we process while providing our services.

"Services" refer to any services or products that are manufactured or distributed by F-Secure, including software, web solutions, tools, and related support services.

"Website" refers to the www.f-secure.com website or any other website that F-Secure hosts or controls, including subsites and browser-based service portals.

Changes

This version of the policy clarifies, updates, and replaces the previous version. To continue keeping this document up to date, we will make changes and additions to this from time to time also in the future.

We will publish the changed policy document on our website or at another interaction point where it has previously been made available. If the changes are significant, we may also notify you by other means. Any changes will apply starting from the date that we publish the revised policy document.