CyberDefender Corporation ("CyberDefender") has adopted this Privacy Policy (the "Policy") to address customers' concerns about privacy and personal information. It applies both to personal identifying information and to other information. Personal identifying information ("PII") is information that is recorded in any form, is about you or pertains to you, and can be connected to you. It includes your name, telephone number, email address, billing address, driver's license number, credit card account information, and social security number. CyberDefender maintains the confidentiality of your PII and only CyberDefender and certain persons and entities working for and with CyberDefender to conduct business with you have access to it. Other information, which is described in more detail below, is information that cannot reasonably be used to identify you, and may be provided by CyberDefender to others for limited purposes.

You may find it helpful to compare our Policy with guidelines issued by organizations such as TRUSTe. TRUSTe is an independent, non-profit organization whose stated mission is to build users' trust and confidence in the Internet by promoting the use of fair information practices. CyberDefender is not a licensee of TRUSTe's privacy program, but we are committed to complying with TRUSTe's guidelines.

If you have questions or concerns regarding the Policy, please contact the CyberDefender.com Privacy Information Department by emailing privacy@cyberdefender.com, by calling (888) 427-9359, or by sending a letter to the CyberDefender.com Privacy Information Department at 617 West 7th Street, Suite 1000, Los Angeles, CA 90017.

CyberDefender voluntarily complies with the requirements of the Safe Harbor framework in connection with the transfer to the United States of PII from countries which are members of the European Union ("EU"). As a result, PII provided by residents of countries which are members of the EU will be subject to the Safe Harbor Principles published by the United States Department of Commerce ("the Safe Harbor Principles"). The Principles can be found at http://www.export.gov/safeharbor.

The Policy describes the following:

• The PII you provide in connection with your purchase of CyberDefender licenses, products and services
• Other information we collect as the result of your use of the CyberDefender websites, including www.cyberdefender.com, www.spywarefordummies.com, www.maxmyspeed.com, www.doublemyspeed.com, and www.mycleanpc.com (collectively, "the Websites")
• How we use the information we collect
• How and with whom we share the information
• How you can opt in or opt out of information collection
• Your ability to access, correct, update and delete your PII

The Information We Collect

PII

In order to open an account with us and to purchase software licenses and technical support services, CyberDefender will collect information including your name, email address, the password to your computer in the event you purchase certain technical support services, telephone number, billing address, and credit or debit card account or electronic funds transfer information. CyberDefender does not collect your driver's license number and collects your social security number only if you elect to provide it in connection with a purchase of the CyberDefender Identity Protection Service.

Other Information

We also collect other information from you when you communicate with us electronically. Like many websites, we use "cookies" to obtain certain information when your Web browser accesses our Websites. Our Websites also automatically receive and record on our server logs information from your browser. More information about our use of cookies and log files appears below.

The information gathered by means of cookies and log files consists of your Internet address (Internet Protocol Address), a referring URL (the web site that you to visit our Websites), your browser type, and information about the length of time you devoted to visiting our Websites. It does not include PII.

We also may collect (with your authorization) the following information about your computer:

• Technical information about the basic configuration and operation of your computer, including operating system version, processor type, disk space, memory space, and number of drivers
• Information about CyberDefender Software on your computer, including the version and when it was installed and upgraded
• Certain events that occur on your computer, including when CyberDefender Software is installed, when CyberDefender software receives threat updates, and when errors occur in CyberDefender Software

This information is sent only to CyberDefender with your approval, and it is stored in an anonymous form that cannot be used to identify you. By way of explanation, although CyberDefender knows, based on the information, that there is a customer with a certain kind of computer that is performing certain functions, CyberDefender does not know the customer's identity. In the event that it is necessary for CyberDefender to learn your identity in order to diagnose certain kinds of problems or to monitor your computer for certain events, you will be asked to authorize CyberDefender to collect the additional information. You can make your selection as to whether CyberDefender may collect this additional information before the software is installed or buy using a control panel included in the software. You can change your selection concerning this feature by using the control panel.

We do not sell or otherwise provide any of this information to third parties and use it only to improve our products and offer better service to our customers.

For a complete list of the information we may collect, click here.

In order to personalize our communications with you and to improve our products and services, we also may ask you to provide consumer satisfaction information and other information regarding your personal and professional interests, your experience with our products and services, and additional contact information. You have the option of choosing not to provide the information.

Our Use of the Information We Collect

CyberDefender uses the information we collect from you to conduct business with you and to understand your interests and requirements so that we can provide the products and services you want. Specifically, we use your PII in connection with fulfillment of orders, to complete payments made by you with your credit or debit card; to manage your account, to renew your subscription(s), to make offers and promotions, to provide information about our products and services that we believe will be important to you, and to help us address any concerns you may have about our products and services. We use your credit or debit card account or electronic funds transfer information only for payment processing and fraud protection, and not for any other purpose.

We employ contractors in our business, including persons who work from time to time in our call centers. The contractors may collect PII from you in the same manner and to the same extent that CyberDefender collects PII from you. The contractors are required, pursuant to agreements they enter into with us, to maintain the security and confidentiality of your PII.

We have business relationships with certain entities that provide services in connection with our business, such as credit and debit card payment processing, and that require access to your PII. Your PII will be provided to them in accordance with the provisions of this Privacy Policy unless we, or they, inform you otherwise and obtain your consent. It is possible that they may provide to CyberDefender certain PII relating to you. In that event, we will handle the PII in accordance with the terms of this Privacy Policy.

We also provide certain information to advertisers and marketers. The information we provide is aggregated before we provide it to advertisers and marketers, and it does not include PII.

If you provide us with your email address when you register as a customer or make a purchase from us, and you do not opt out, we occasionally may send you email with information, recommendations and promotional information about our products and services. At the time you register or make a purchase, you will be given the opportunity to opt into or opt out of this service. If you do not initially choose to opt out, you may still block certain emails from us simply by following the "unsubscribe" instructions that accompany all communications. In addition, we send service and notifications by email to keep you informed about the status of your service orders and account, and to provide updates and technical notices. Some of these communications are required by law, such as communications regarding the automatic renewal of licenses and services you have purchased. Other communications are essential to the management of your account and the continuing functionality of our products and services, and therefore an opt-out option is not available and the communications cannot be blocked.

Your Consent

By purchasing our licenses and services, and by visiting our Websites, you consent to the collection, use and disclosure of your PII and other information by CyberDefender, its officers, directors, and employees, and CyberDefender's agents and contractors, as set forth in this Policy.

The following applies to residents of countries which are members of the European Union ("EU") and other countries. Your PII will be transferred outside the EU and outside the country of your residence, and will be examined, processed and stored in the United States. As a result, third parties, including governments, courts and law enforcement and regulatory agencies, may be able to gain access to your PII under applicable United States laws. By purchasing our licenses, products and services, and by visiting our Websites, you consent to the transfer of your PII outside the EU and your country of residence.

Links

CyberDefender's Websites contain links to other websites that are not owned, operated or controlled by CyberDefender. The links are provided solely for your convenience, and CyberDefender does not endorse the websites or their content. As a result, CyberDefender is not responsible for the manner in which the websites are operated or for the information they provide. It is important to read carefully the privacy policies of the websites, because they may differ materially from ours.

Cookies are unique text files that websites can send to browser software. CyberDefender uses cookies to identify customers and personalize web pages when customers visit our Websites, to record customers' preferences, and to allow us to consider customers' interests and requirements in connection with developing and offering our products and services. CyberDefender also may use cookies to monitor your visits to our Websites in order to collect aggregate information which is not PII. In addition, cookies enable returning visitors to visit our Websites without providing their email addresses and passwords in connection with every visit.

The information we collect with cookies is not sold, rented, or shared with any third parties, and is used solely for analytical purposes. Because of the manner in which we conduct our business, we cannot provide subscription services to potential customers who do not consent our use of cookies or whose browsers are set to reject cookies.

CyberDefender also maintains log files of visitors to our Websites. Log files allow us to manage traffic to our Websites in order that we may provide reliable service to customers and visitors.

The information gathered by means of cookies and log files – your Internet address, the Internet address from which you visited our Websites, your browser type, and information about the length of time you devoted to visiting our Websites – is aggregate information and does not include PII.

Your Comments and Suggestions

We solicit customers' comments and suggestions about our products and services and, on occasion, we use that information to develop customer's testimonials that we use in connection with our advertising and marketing. Testimonials are developed only after we have obtained permission of the person providing the information.

Accessing, Correcting and Updating Your Information

You can access, update or correct your information by contacting CyberDefender Privacy Information Department at privacy@cyberdefender.com

Information Security

All information gathered on our Websites is stored and maintained in secure facilities and access is limited to authorized personnel. Our Websites regularly are subjected to security tests, and we make our best efforts to attempt to ensure that all information collected is secure. PII is protected during communication by HTTPS and SSL security. Credit and debit card account information has multiple layers of security, including encryption in storage and SSL during communication.

It is not possible to eliminate fully security risks associated with electronic communications. In the event that CyberDefender learns of a breach of security that involves your PII, CyberDefender will notify you as required pursuant to applicable law.

Retention of Information

CyberDefender retains your PII for as long as you are a registered subscriber or user of our products and services, and for a reasonable time thereafter.

Confidentiality

CyberDefender maintains the confidentiality of your PII and other information and will not disclose it to third parties except as set forth in this Policy. However, confidentiality does not apply to information: (1) that is publicly available; (2) as to which you consent to disclosure; (3) when disclosure is in connection with the sale of all or part of our business; or (4) when disclosure is necessary for CyberDefender or its officers, directors, employees, agents and contractors to enforce their legal rights pursuant to applicable law.

In addition, CyberDefender reserves the right, in its sole and absolute discretion, at any time, and without notice, to you to disclose to third parties, including law enforcement authorities, any of your information, including PII, that CyberDefender deems appropriate to: (a) comply with any applicable law or regulation, legal process, or governmental request; or (b) prevent possible harm or injury to any person or damage to any property.

Notification of Changes

If we make material (non-editorial) changes to the Policy, we will post information about the changes on our Websites.

The Better Business Bureau Code of Business Conduct

As a Better Business Bureau ("BBB") Accredited Business, CyberDefender is committed to complying with the BBB's Code of Business Conduct, including the requirement to protect your privacy. Detailed information is available at http://www.bbb.org/us/Business-Accredidation/. Complaints may be addressed to the BBB at http://www.bbb.org/us/Business-Complaints/.

Privacy Complaints

In the United States, privacy complaints should be addressed in the first instance to CyberDefender at privacy@cyberdefender.com. Complaints then should be addressed to the BBB at http://www.bbb.org/us/Business-Complaints/.

Pursuant to the Safe Harbor Principles, CyberDefender will attempt to resolve privacy complaints made by residents of the EU. Complaints should be addressed in the first instance to CyberDefender at:

CyberDefender Corporation
617 West 7th Street
Suite 1000
Los Angeles, CA 90017
Attention: Privacy
Email: privacy@cyberdefender.com

Pursuant to the Safe Harbor Principles, CyberDefender will refer unresolved complaints to the BBB EU Safe Harbor, an independent dispute resolution entity. The BBB EU Safe Harbor may be contacted at:

Council of Better Business Bureaus, Inc.
4200 Wilson Boulevard
Suite 800
Arlington, VA 22203
Phone: 703-276-0100
Web: www.us.bbb.org
Email: safeharbor@council.bbb.org