プライバシーポリシー
Effective as of March 1, 2022
The protection of personal data is of particular importance to ESET, spol. s r. o., having its registered office at Einsteinova 24, 851 01 Bratislava, Slovak Republic, registered in the Commercial Register administered by Bratislava I District Court, Section Sro, Entry No 3586/B, Business Registration Number: 31333532 as a Data Controller ("ESET" or "We"). We want to comply with the transparency requirement as legally standardized under the EU General Data Protection Regulation ("GDPR"). To achieve this goal, We are publishing this Privacy Policy with the sole purpose of informing our customer ("End User" or "You") as a data subject about following personal data protection topics:
•Legal Basis of Personal Data Processing,
•Data Sharing and Confidentiality,
•Data Security,
•Your Rights as a Data Subject,
•Processing of Your Personal Data
•Contact Information.
Legal Basis of Personal Data Processing
There are a few legal bases for data processing which We use according to the applicable legislative framework related to protection of personal data. The processing of personal data at ESET is mainly necessary for the performance of the Terms of Use ("Terms") with End User (Art. 6 (1) (b) GDPR), which is applicable for the provision of ESET products or services, unless explicitly stated otherwise, e.g.:
•Legitimate interest legal basis (Art. 6 (1) (f) GDPR), that enables us to process data on how our customers use our Services and their satisfaction to provide our users with the best protection, support and experience We can offer. Even marketing is recognized by applicable legislation as a legitimate interest, therefore We usually rely on it for marketing communication with our customers.
•Consent (Art. 6 (1) (a) GDPR), which We may request from You in specific situations when we deem this legal basis as the most suitable one or if it is required by law.
•Compliance with a legal obligation (Art. 6 (1) (c) GDPR), e.g. stipulating requirements for electronic communication, retention for invoicing or billing documents.
Data Sharing and Confidentiality
We do not share your data with third parties. However, ESET is a company that operates globally through affiliated companies or partners as part of our sales, service and support network. Licensing, billing and technical support information processed by ESET may be transferred to and from affiliates or partners for the purpose of fulfilling the EULA, such as providing services or support.
ESET prefers to process its data in the European Union (EU). However, depending on your location (use of our products and/or services outside the EU) and/or the service you choose, it may be necessary to transfer your data to a country outside the EU. For example, we use third-party services in connection with cloud computing. In these cases, we carefully select our service providers and ensure an appropriate level of data protection through contractual as well as technical and organizational measures. As a rule, we agree on the EU standard contractual clauses, if necessary, with supplementary contractual regulations.
For some countries outside the EU, such as the United Kingdom and Switzerland, the EU has already determined a comparable level of data protection. Due to the comparable level of data protection, the transfer of data to these countries does not require any special authorization or agreement.
We rely on third-party services related to cloud computing provided by Microsoft as a cloud service provider.
Data Security
ESET implements appropriate technical and organizational measures to ensure a level of security which is appropriate to potential risks. We are doing our best to ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and services. However, in case of data breach resulting in a risk to your rights and freedoms, We are ready to notify the relevant supervisory authority as well as affected End Users as data subjects.
Data Subject’s Rights
The rights of every End User matter and We would like to inform you that all End Users (from any EU or any non-EU country) have the following rights guaranteed at ESET. To exercise your data subject’s rights, you can contact us via support form or by e-mail at dpo@eset.sk. For identification purposes, we ask you for the following information: Name, e-mail address and - if available - license key or customer number and company affiliation. Please refrain from sending us any other personal data, such as the date of birth. We would like to point out that to be able to process your request, as well as for identification purposes, we will process your personal data.
Right to Withdraw the Consent. Right to withdraw the consent is applicable in case of processing based on consent only. If We process your personal data on the basis of your consent, you have the right to withdraw the consent at any time without giving reasons. The withdrawal of your consent is only effective for the future and does not affect the legality of the data processed before the withdrawal.
Right to Object. Right to object the processing is applicable in case of processing based on the legitimate interest of ESET or third party. If We process your personal data to protect a legitimate interest, You as the data subject have the right to object to the legitimate interest named by us and the processing of your personal data at any time. Your objection is only effective for the future and does not affect the lawfulness of the data processed before the objection. If we process your personal data for direct marketing purposes, it is not necessary to give reasons for your objection. This also applies to profiling, insofar as it is connected with such direct marketing. In all other cases, we ask you to briefly inform us about your complaints against the legitimate interest of ESET to process your personal data.
Please note that in some cases, despite your consent withdrawal, we are entitled to further process your personal data on the basis of another legal basis, for example, for the performance of a contract.
Right of Access. As a data subject, you have the right to obtain information about your data stored by ESET free of charge at any time.
Right to Rectification. If we inadvertently process incorrect personal data about you, you have the right to have this corrected.
Right to Erasure and Right to Restriction of Processing. As a data subject, you have the right to request the deletion or restriction of the processing of your personal data. If we process your personal data, for example, with your consent, you withdraw it and there is no other legal basis, for example, a contract, We delete your personal data immediately. Your personal data will also be deleted as soon as they are no longer required for the purposes stated for them at the end of our retention period.
If we use your personal data for the sole purpose of direct marketing and you have revoked your consent or objected to the underlying legitimate interest of ESET, We will restrict the processing of your personal data to the extent that we include your contact data in our internal black list in order to avoid unsolicited contact. Otherwise, your personal data will be deleted.
Please note that We may be required to store your data until the expiry of the retention obligations and periods issued by the legislator or supervisory authorities. Retention obligations and periods may also result from the Slovak legislation. Thereafter, the corresponding data will be routinely deleted.
Right to Data Portability. We are happy to provide You, as a data subject, with the personal data processed by ESET in the xls format.
Right to Lodge a Complaint. As a data subject, You have a right to lodge a complaint with a supervisory authority at any time. ESET is subject to the regulation of Slovak laws and We are bound by data protection legislation as part of the European Union. The relevant data supervisory authority is The Office for Personal Data Protection of the Slovak Republic, located at Hraničná 12, 82007 Bratislava 27, Slovak Republic.
Processing of Your Personal Data
Services provided by ESET implemented in our web-based product are provided under the Terms of Use ("Terms"), but some of them might require specific attention. We would like to provide You with more details on data processing connected with the provision of our products and services. We render various services described in the Terms and the product documentation. To make it all work, We need to collect the following information:
ESET as a Processor
•Processing of Data on our Cloud Console. Our cloud console enables You to manage and configure our services and it also functions as a cloud-based authentication server, processing authentication requests from endpoint devices for which You enabled second factor authentication. Various categories of data that are necessary for functioning of our ESET Secure Authentication Cloud Early Access are being processed there to enable provisions of our services to You, while the exact data to be processed depend on authentication methods and components You choose to use and other configurations of the service You make. Cloud console may therefore process data related to your end-users, such as user names and IDs, IP addresses, mobile numbers, email addresses, organizational units as well as data related to your organizational structure (in case You choose automatic syncing of your database containing data on your organizational structure with our cloud console, your login credentials for the database might need to be inputted). Moreover, it may process data necessary for integration and functioning of our product with components that You use and choose to integrate our product with, e.g. Microsoft Exchange Server, Microsoft Dynamic CRM, Identity Provider Connector or RADIUS, data on hardware tokens used by your users (e.g. hard token secret) and data related to your license. To provide you with the reporting functionality as well as with relevant notifications, data related to various events happening in your organization (such as who logged-in, failed logins etc.) as well as about our product (such as errors, license expiry information etc.) need to be processed.
•Please note that depending on properties of the component You choose to integrate with ESET Secure Authentication Cloud Early Access, we may have to process also first-factor information used for authentication, usually user's password, but only to forward it to the competent entity for verification. No passwords of End-Users who use ESET Secure Authentication Cloud Early Access for two-factor authentication are stored in our cloud console nor on other ESET servers.
ESET as a Controller
•Licensing and Billing Data. The name, e-mail address, license key and (if applicable) address, company affiliation and payment data are collected and processed by ESET in order to facilitate the activation of license, license key delivery, reminders on expiration, support requests, license genuineness verification, provision of our services and other notifications including marketing messages in line with applicable legislation or your consent. ESET is legally obliged to keep the billing information for the period of 10 years, however the licensing information will be anonymized no later than 12 months after the expiration of license.
•Update and Other Statistics. The processed information includes information concerning installation process of ESET Secure Authentication Cloud Early Access components that shall be locally installed on your devices and information about the operations, functionality and usage of our products and services, such as operation system, hardware information, installation IDs, license IDs, IP address, MAC address, configuration settings of product are processed for the purpose of provision of updates and upgrades and for the purpose of maintenance, security and improvement of our services and back-end infrastructure.
•This information is kept apart from the identification information required for the licensing and billing purposes since it does not require the identification of End User. The retention period is up to 4 years.
•Technical Support. The contact and licensing information and data contained in your support requests may be required for service of support. Based on the channel You choose to contact us, We may collect your email ad-dress, phone number, license information, product details and description of your support case. You may be asked to provide us with other information to facilitate service of support. The data processed for technical sup-port is stored for 4 years.
Please note that if the person using our products and services is not the End User who has purchased the product or service and concluded the Terms with Us, (e.g. an employee of the End User, a family member or a person otherwise authorized to use the product or service by the End User in compliance with Terms, the processing of the data is carried out in the legitimate interest of ESET within the meaning of Art. 6 (1) f) GDPR to enable the user authorized by End User to use the products and services provided by Us in accordance with Terms.
Contact Information
If You would like to exercise your right as a data subject or You have a question or concern, send us a message at:
ESET, spol. s r.o.
Data Protection Officer
Einsteinova 24
85101 Bratislava
Slovak Republic
dpo@eset.sk