Privacy Policy
We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal data. It also explains your rights in relation to your personal data and how to contact us or supervisory authorities in the event you have a complaint. You should also read our Terms of Service & EULA.
We collect, use and are responsible for certain personal data about you. When we do so we are subject to the UK General Data Protection Regulation (UK GDPR).
Key Terms
It would be helpful to start by explaining some key terms used in this policy:
We, us, our
We are Total Security Limited (trading as totalav), a company registered in England and Wales under company number: 10161957.
Our registered office is at: 16-18 Barnes Wallis Road, Segensworth, Fareham, Hampshire, United Kingdom, PO15 5TT
Personal data
Any information relating to an identified or identifiable individual
Special category personal data
Personal data revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership
Genetic and biometric data (when processed to uniquely identify an individual)
Data concerning health, sex life or sexual orientation
Data subject
The individual who the personal data relates to
Websites
www.totalsecurity.com
Personal data we collect about you
The personal data we collect about you depends on the particular products and services we provide to you and how you interact with our Websites. We will collect and use the following personal data about you:
your name and contact information, including email address and telephone number
your password for your account
data about the products and services you have purchased including your activation code and date of purchase
data and information you may give us where we provide you with technical support and/or remote access support
location data, if you choose to give this to us and you have not disabled this on your device
device information
your IP address and other unique identifiers
your billing information, transaction and payment card information
your contact history, purchase history and saved items
information about how you use our website, IT, communication and other systems
where we provide you with VPN services, connect data, usage data, error analysis data, and product data.
We collect and use this personal data for the purposes described in the section 'How and why we use your personal data' below. If you do not provide personal data we ask for, it may delay or prevent us from providing products and services to you.
How your personal data is collected
We collect most of this personal data directly from you—in person, by telephone, text or email and/or via our website when you sign up for an account. However, we may also collect information:
from cookies on our website—for more information on our use of cookies, please see our Cookie Policy
where you visit our business premises, via our IT systems, e.g.:
from door entry systems and reception logs;
through automated monitoring of our websites and other technical systems, such as our computer networks and connections, CCTV and access control systems, communications systems, email and instant messaging systems;
each time you use our products and services when you:
download the particular product
update information in your control panel
communicate with us by telephone or email
order or download new products and services
register a licence or change your device
complete forms on our website
use our technical support services, including remote access support
How and why we use your personal data
Under data protection law, we can only use your personal data if we have a proper reason, e.g.:
where you have given consent;
to comply with our legal and regulatory obligations;
for the performance of a contract with you or to take steps at your request before entering into a contract; or
for our legitimate interests or those of a third party.
A legitimate interest is when we have a business or commercial reason to use your personal data, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own.
The data below explains what we use your personal data for and why.
Providing products and services to you
To perform our contract with you or to take steps at your request before entering into a contract
Conducting checks to identify our customers and verify their identity
To comply with our legal and regulatory obligations
To enforce legal rights or defend or undertake legal proceedingsDepending on the circumstances:
to comply with our legal and regulatory obligations;
in other cases, for our legitimate interests, i.e., to protect our business, interests and rights;
Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies
To comply with our legal and regulatory obligations
Ensuring business policies are adhered to, e.g. policies covering security and internet use
For our legitimate interests, ie to make sure we are following our own internal procedures so we can deliver the best service to you
For us to perform our contract with you.
Operational reasons, such as improving efficiency, training and quality control
For our legitimate interests, i.e. to be as efficient as we can so we can deliver the best service to you at the best price
Ensuring the confidentiality of commercially sensitive information
Depending on the circumstances:
for our legitimate interests, i.e. to protect trade secrets and other commercially valuable information;
to comply with our legal and regulatory obligations;
Statistical analysis to help us manage our business, eg our financial performance, customer base, product range or other efficiency measures
For our legitimate interests, i.e. to be as efficient as we can so we can deliver the best service to you at the best price
Preventing unauthorised access and modifications to systems
Depending on the circumstances:
for our legitimate interests, ie to prevent and detect criminal activity that could be damaging for you and/or us;
to comply with our legal and regulatory obligations;
Protecting the security of systems and data used to provide the products and services
To comply with our legal and regulatory obligations
We may also use your personal data to ensure the security of systems and data to a standard that goes beyond our legal obligations, and in those cases our reasons are for our legitimate interests, i.e. to protect systems and data and to prevent and detect criminal activity that could be damaging for you and/or us
Updating customer records
Depending on the circumstances:
to perform our contract with you or to take steps at your request before entering into a contract;
to comply with our legal and regulatory obligations;
for our legitimate interests, e.g. making sure that we can keep in touch with our customers about existing orders and new products;
Statutory returns
To comply with our legal and regulatory obligations
Ensuring safe working practices, staff administration and assessments
Depending on the circumstances:
to comply with our legal and regulatory obligations;
for our legitimate interests, e.g. to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you;
Marketing our products services to:
existing and former customers;
third parties who have previously expressed an interest in our services;
For our legitimate interests, ie to promote our business to existing and former customersExternal audits and quality checks to the extent not covered by ‘activities necessary to comply with legal and regulatory obligations’ aboveDepending on the circumstances:
for our legitimate interests, ie to maintain our accreditations so we can demonstrate we operate at the highest standards;
to comply with our legal and regulatory obligations;
To share your personal data with members of our group and third parties that will or may take control or ownership of some or all of our business (and professional advisors acting on our or their behalf) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency
In such cases information will be anonymised where possible and only shared where necessary
Depending on the circumstances:
to comply with our legal and regulatory obligations;
in other cases, for our legitimate interests, ie to protect, realise or grow the value in our business and assets;
How and why we use your personal data—in more detail
More details about how we use your personal data and why are set out below.
Communications with you not related to marketing, including about changes to our terms or policies or changes to the products or other important notices (other than those addressed above)
Addressing and sending communications to you as required by data protection laws, ie:
the UK GDPR or Data Protection Act 2018.
We do this by desktop alerts and live chat, email and (where you have consented) SMS/Text messaging.
Processing is necessary for compliance with a legal obligation to which we are subject (Article 6(1)(c))
your name, address and contact information, including email address and telephone number
your account details (username)
Addressing and sending communications to you about changes to our terms or policies or changes to the products and services or other important notices.
We do this by desktop alerts and live chat, email and (where you have consented) SMS/Text messaging.
Our legitimate interests (Article 6(1)(f)), which is to be as efficient as we can so we can deliver the best service to you
your name, address and contact information, including email address and telephone number (if applicable)
your account details (username)
Processing your order or refund
To provide our products and services to you. For example, anti-virus software. Dealing with your refund.
Processing is necessary for the performance of a contract with you (Article 6(1)(b)) so that we can provide the products and services that you have purchased or provide you with a refund.
your name, address and contact information, including email address and telephone number
your account details (username)
your billing information, transaction information and some payment card information
Verifying your identity
To confirm your identity if you need to contact us about your account or amend your personal data
Processing is necessary for performance of our contract with you (Article 6(1)(b)) or our legitimate business interests in keeping your account secure (Article 6(1)(f)) or else to comply with our legal and regulatory obligations (Article 6(1)(c))
This could consist off the last four digits of your account; your phone number; the full name associated with the account.
Administering your account and billing information
We need to provide you with an account as part of providing our products and services to you and we need to communicate with you to do this and to maintain that account. These communications include (1) notifications of detected problems with the products and services we provide to you; (2) notifications concerning the expiration of your account; (3) activity status reports; (4) service and software upgrade notices; (5) notices concerning new or related products and service from us; (6) notices concerning enhancements to our services; (7) price change notices for the services; (8) notifications regarding suspected unlawful or inappropriate use; (9) auto-renewal notifications and in some cases providing you with refunds and (10) requests for feedback on the our services. We do this by desktop alerts and live chat, email and (where you have consented) SMS/Text messaging. You can correct any factual errors regarding the personal data we hold about you on your control panel or by sending a request to https://help.totalav.com/
Processing is necessary for performance of our contract with you (Article 6(1)(b)) so that you can access important information about the operation of your account and the services we provide to you.
your name, address and contact information, including email address and telephone number;
your account details (username)
your IP address
your billing information, transaction information and some payment card information
Assisting you with our products and services including providing technical and remote access support
Dealing with any technical or other issues you may have and assisting you with those to try and resolve the issue. We do this by desktop alerts and live chat, email and (where you have consented) SMS/Text messaging.
Processing is necessary for the purposes of our legitimate interests (Article 6(1)(f)) or is necessary for the performance of our contract with you (Article 6(1)(b)) It is in our legitimate interest to process your personal data so that we can provide a response to your enquiry and deal with your issue
your name, address and contact information, including email address and telephone number;
your account details (username)
your IP address
Marketing communications with you related to other products or services that may be of interest to you
We may contact you via email, telephone or where you have consented, text message about products and services which may be of interest to you.
Processing is necessary for the purposes of the legitimate interests pursued by the controller (Article 6(1)(f)) or the data subject has given consent to the processing of his or her personal data (Article 6(1)(a)) It is in our legitimate interest to contact you about other products or services that may be of interest so that we can keep you informed about our latest products and services.
your name and email address
your account details (username)
device data
Improving our products and services
Analyse the accuracy, effectiveness, usability, or popularity of our products and services and improve the content and features of the products and services
Processing is necessary for the purposes of our legitimate interests (Article 6(1)(f)). It is in our legitimate business interests to continually improve our products and services.
IP address
device operating system
device information
Special category personal data
We do not knowingly collection any special category data. This is particularly sensitive information about you, for example health information.
How and why we use your personal data—sharing
See 'Who we share your personal data with' for further information on the steps we will take to protect your personal data where we need to share it with others.
Automated Decision-Making
Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. We are allowed to use automated decision-making in the following circumstances:
where we have notified you of the decision and given you 21 days to request us to reconsider the decision;
for performing our contract with you and appropriate measures are in place to safeguard your rights;
in limited circumstances, with your explicit written consent and where appropriate measures are in place to safeguard your rights.
You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, unless we have a lawful basis for doing so and we have notified you.
We do not envisage that any decisions will be taken about you using automated means, but we will notify you in writing if this position changes.
Marketing
We will use your personal data to send you updates (by email, text message, telephone or post) about our products and services including exclusive offers, promotions or new products and services.
We have a legitimate interest in using your personal data for marketing purposes (see above How and why we use your personal data' . This means we do not usually need your consent to send you marketing information. If we change our marketing approach in the future so that consent is needed, we will ask for this separately and clearly.
contacting us at https://help.totalav.com/.
using the ‘unsubscribe’ link in emails or ‘STOP’ number in texts
managing your preferences at https://www.totalav.com/unsubscribe.
We may ask you to confirm or update your marketing preferences if you ask us to provide further products and services in the future, or if there are changes in the law, regulation, or the structure of our business.
We will always treat your personal data with the utmost respect and never share it with other organisations for marketing purposes.
Who we share your personal data with
We routinely share personal data with:
companies within Total Security
third parties we use to help deliver our products and services to you, e.g. payment service providers, https://haveibeenpwned.com/;
third party that assist us processing our mail, communicating with customers and prospective customers on our behalf (including via social media), running promotions, providing IT systems and administrative services and the development and improvement of internal systems and processes
Other companies where we are trialling products and services which we consider may improve our offering to customers and/or our business processes;
Other third parties where you have given your express consent or where we reasonably believe a third party is acting on your behalf.
Our banks
We only allow those organisations to handle your personal data if we are satisfied they take appropriate measures to protect your personal data.
We or the third parties mentioned above occasionally also share personal data with:
our and their external auditors, eg in relation to the audit of our or their accounts, in which case the recipient of the information will be bound by confidentiality obligations;
our and their professional advisors (such as lawyers and other advisors), in which case the recipient of the information will be bound by confidentiality obligations;
law enforcement agencies, courts, tribunals and regulatory bodies to comply with our legal and regulatory obligations;
other parties that have or may acquire control or ownership of our business (and our or their professional advisers) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency—usually, information will be anonymised but this may not always be possible. The recipient of any of your personal data will be bound by confidentiality obligations.
Who we share your personal data with—in more detail
More details about who we share your personal data with and why are set out here https://www.totalav.com/third-party.
Who we share your personal data with—further information
If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).
Where your personal data is held
Personal data may be held at our offices and those of our group companies, third party agencies, service providers, representatives and agents as described above (see above: 'Who we share your personal data with').
Some of these third parties may be based outside the UK. For more information, including on how we safeguard your personal data when this happens, see below: 'Transferring your personal data out of the UK'
How long your personal data will be kept
We will not keep your personal data for longer than we need it for the purpose for which it is used.
Different retention periods apply for different types of personal data.
If you no longer have an account with us or we are no longer providing products and services to you, we will delete or anonymise your account data after seven years. We typically hold other data for two years.
Following the end of the of the relevant retention period, we will delete or anonymise your personal data.
Transferring your personal data out of the UK
Countries outside the UK have differing data protection laws, some of which may provide lower levels of protection of privacy.
It is sometimes necessary for us to transfer your personal data to countries outside the UK. In those cases we will comply with applicable UK laws designed to ensure the privacy of your personal data.
We will transfer your personal data to our service providers located outside the UK. Under data protection laws, we can only transfer your personal data to a country outside the UK where:
in the case of transfers subject to UK data protection law, the UK government has decided the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy regulation’) further to Article 45 of the UK GDPR. A list of countries the UK currently has adequacy regulations in relation to is available here. We rely on adequacy regulations for transfers to the following countries: Isle of Man; New Zealand and Luxembourg.
there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for you; or
a specific exception applies under relevant data protection law.
Where we transfer your personal data outside the UK, we do so on the basis of an adequacy regulation or (where this is not available) legally-approved standard data protection clauses recognised or issued further to Article 46(2) of the UK GDPR. In the event we cannot or choose not to continue to rely on either of those mechanisms at any time, we will not transfer your personal data outside the UK unless we can do so on the basis of an alternative mechanism or exception provided by UK data protection law and reflected in an update to this policy.
Any changes to the destinations to which we send personal data or in the transfer mechanisms we rely on to transfer personal data internationally will be notified to you in accordance with the section on 'Changes to this privacy policy' below.
International transfers of your personal data outside the UK—in more detail
More details about the countries outside the UK to which your personal data is transferred are set out here https://www.totalav.com/third-party.
Transferring your personal data out of the UK—further information
If you would like further information about data transferred outside the UK, please contact us (see 'How to contact us' below).
Your rights
You have the following rights, which you can exercise free of charge:
Access
The right to be provided with a copy of your personal data
Rectification
The right to require us to correct any mistakes in your personal data. You can access the personal data that we collect via your Control Panel. You can correct factual errors in your personal data on your Control Panel or by visiting our Help Center. Please provide sufficient details regarding the error.
Erasure (also known as the right to be forgotten)
The right to require us to delete your personal data—in certain situations
Restriction of processingThe right to require us to restrict processing of your personal data in certain circumstances, e.g., if you contest the accuracy of the data
Data portabilityThe right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations
To object
The right to object:
at any time to your personal data being processed for direct marketing (including profiling);
in certain other situations to our continued processing of your personal data, eg processing carried out for the purpose of our legitimate interests unless there are compelling legitimate grounds for the processing to continue or the processing is required for the establishment, exercise or defence of legal claims
Not to be subject to automated individual decision making
The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you
The right to withdraw consents
If you have provided us with a consent to use your personal data you have a right to withdraw that consent easily at any time. You may withdraw consents by:
visiting our Help Center;
using the ‘unsubscribe’ link in emails or ‘STOP’ number in texts. or
managing your preferences at https://www.totalav.com/unsubscribe
Withdrawing a consent will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn
For more information on each of those rights, including the circumstances in which they apply, please contact us (see 'How to contact us' below) or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights.
If you would like to exercise any of those rights, please:
Email or call us—see below: ‘How to contact us’; and
provide enough information to identify yourself including your full name, address and customer account number and any additional identity information we may reasonably request from you;
let us know what right you want to exercise and the information to which your request relates.
Keeping your personal data secure
We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it. Those processing your personal data will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
How to complain
Please contact us if you have any queries or concerns about our use of your personal data (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.
You also have the right to lodge a complaint with the Information Commissioner in the UK
The UK’s Information Commissioner may be contacted using the details at https://ico.org.uk/make-a-complaint or by telephone: 0303 123 1113.
Changes to this privacy policy
This privacy notice was published on 25 April 2022 and last updated on 25 April 2022.
We may change this privacy notice from time to time—when we do we will inform you via putting a notice in your Control Panel and/or updating our Websites.
How to contact us
You can contact us by post, email or telephone if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.
Our contact details are shown below:
Our contact details
Total Security Limited
16-18 Barnes Wallis Road,
Segensworth,
Fareham,
Hampshire,
PO15 5TT,
United Kingdom
Email: support@totalav.com
Telephone: 0800 357 602 (our telephone lines are open 7 days per week, 24 hours a day).
Using our online chat functionality if you are not an existing customer or you are and you are post annual renewal