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.
Collected evidence from the organization being assessed
During the PCI DSS or 3DS assessment, we collect evidence from the assessed organization's information systems and related devices. We also conduct documented interviews with customer organization personnel. This data is used to showcase that the organization being assessed has built its security controls to match the requirements of PCI DSS and/or 3DS, and that they are capable of performing security management processes and procedures as is required of them:
The PCI DSS and 3DS security standard requires the assessing organization (F‑Secure) to collect and store assessment-related evidence data for three (3) years. Therefore F‑Secure has a legitimate interest in collecting the evidence data, as it is necessary in order for F‑Secure to provide customers with PCI DSS/3DS-related services.
During assessments, only the necessary amount of personal data is collected in order to fulfill the assessment requirements set by the PCI Security Standards Council.
Evidence data is stored for the needs of the PCI Security Standard Council quality assurance program and to possibly verify F‑Secure's judgement of the performed assessment.
Evidence data is not shared with any external parties, except upon written request to PCI Security Standard Council or their appointed forensics investigators.
F‑Secure further employs its own affiliates and subcontractors so that we can provide our services globally.
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.
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.
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.
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.
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:
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:
The PCI DSS and 3DS security standard requires the assessing organization (F‑Secure) to collect and store assessment-related evidence data for three (3) years. F‑Secure securely destroys the evidence data after this defined retention period has exceeded.
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:
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.
PCI DSS/3DS assessment-related evidence data is stored in a secure document management system, managed by F‑Secure and protected by access controls, firewalls, and other protective measures.
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.
Information on your statutory rights and how to contact us.
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:
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).
If you have any questions or concerns about the matters discussed in our privacy policies, please contact:
How to contact us:
Information on definitions and change management.
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.
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.