F-Secure Freedome for Business privacy policy

May 2018

In brief

Freedome for Business combines VPN surfing with mobile device management, which are both controlled via the management portal. To achieve this:

  • the service encrypts your data traffic from third parties;
  • the focus of data collection is on your device and our service, not you as an individual;
  • much of the collected data is available for your employer's IT administrator, so they can better manage company devices and applications;
  • we collect anonymous security data to protect your device;

The purpose of the service is to secure and manage your device and its connections. The service is not built to monitor employees. The service does not enable F-Secure or your company's IT administrator to follow your movements, view your photos, or see who you call or communicate with, nor are we able to track the sites that you visit through the service.

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.

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 the traffic volume and IP addresses) of your traffic when providing the service to you. To safeguard your privacy, the target IP, port or URL of traffic relayed through the VPN are not stored in a way that they could be later connected to you;
  • we analyze the traffic for suspicious or malicious files and destinations (i.e. URLs); and
  • we automatically screen the traffic to inhibit usage that is against our acceptable use policy.

User data

User data in the management portal

The service collects the following data about you, your device, and use of the service, and makes it available through the management portal:

  • User's name, email, and phone number. This data is linked to your "device ID" that acts as an identifier of the user data in the system.
  • The service version number, device identifiers (e.g. IMEI, model, etc.), subscription key, installation and update date and time, operating system and version, feature status.
  • In addition to the above, the service collects: your mobile device model, as well as the potential jailbreak or root status, service statistics per device such as the virtual location, the aggregate amount of traffic in the VPN tunnel, the amount of traffic scanned, the harmful sites, the number of blocked tracking attempts and blocked website counters.

The collected data varies according to what devices and services you use.

We use this data to operate the services, to manage them (including identifying authorized users and managing licenses), to measure performance, and to further develop, enhance, and improve the service. The data can be used to provide support and problem resolution services.

This data is visible to your company's IT administrator and is also available to F-Secure and through the portal. If the company's IT administration has been outsourced, the data is also available to the outsourcing partner (F-Secure's 'distributor partner'), so that they can provide your company with support and like IT services.

User data in F-Secure systems

In addition to data that is made available in the portal, F-Secure also collects the following data via the service:

  • your device ID, so we can send push notifications to the devices and to combine different types of user data;
  • your device's language, so the service language is consistent with the device language; and
  • we may also collect the battery level, internal memory and SD card memory sizes, and a list of installed applications (to check that the service is installed correctly) for management feature development purposes.

Some jurisdictions require that we collect user devices' public and private IP addresses as well as the start and end time for the VPN tunnel. If we receive a legally valid request, this data can be used to reveal which origin IP was used to connect to a target IP at a given time. It does not compromise the invisibility of your browsing traffic via the service towards F-Secure or your IT administrator, as we do not connect the IP address to you.

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.

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.

PSB privacy policy

The usage of Security Cloud, the roles in which different parties process your personal data, data retention rules, and the legal grounds on which personal data is being processed are described in the F-Secure Protection Service for Business privacy policy.

Security

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

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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.

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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.

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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.