Privacy Policy

This Privacy Policy was last changed on 2 March 2023.

1. Who we are

Beijing Qihu Keji Co. Ltd. (“we”) respects your privacy and values the trust you place in us when you share your personal information with us. This policy sets out how we, as data controller, collect and use your personal data, why we use it, with whom we share it, the rights to which you may be entitled and your choices about our use of your personal data.

This policy covers our use of your personal data arising from use of 360 Secure Browser software and our official website (“Website”) https://browser.360totalsecurity.com.

2. Your information

We will collect and use your personal information to allow access to 360 Secure Browser and Website and for other purposes set out in more detail in this section.

Your information may be shared with members of our group and some third parties.

	What we collect	How we use it
1	Information we collect: Features you use in 360 Secure Browser; The crash report ，including the Dump file of the browser process crash and the relevant parameters of the browser crash process, as well as the information about the operating system and environment of the browser.	We use this information, including to: Develop new services; Improve our services; Statistical analysis and research.
2	When upgrading、installing or uninstalling 360 Secure Browser , the browser version number and device information, such as your operating system and environment of the browser., will be sent to 360. When uninstalling, users are asked to fill in the reason for uninstalling; if they do, the relevant information will also be collected on 360's server.	We use this information, including to: Detect potential problems; Develop new services; Improve our services; Statistical analysis and research.
3	Information that we collect through your use of our Website including: Your account information if you register or log in your account on our Website; Date and time of requests; The requests you make; The pages you visit; IP address.	We use this information, including to: Provide our services; Protect the security of your information; Identify issues with our Website; Monitor the way our website is used; Improve our Website.

We will NOT collect the content information of files or non-executable files such as .doc, .pdf, .jpg, etc., NOR any data generated by or transmitted through 360 Secure Browser.

Special Information

Certain types of personal information are more sensitive than others. This “special information” about you includes information about health, disability, race, ethnicity, criminal offences (or alleged offences), political opinions, biometrics or religion. We do NOT collect or use any special information about you.

Third-party data collection

We partner with third parties to display advertising on our software or application or to manage our advertising on other sites, software or applications. Our third-party partners may use cookies or software development kits (SDK) or other similar technologies to provide you advertising not based on your interests or browsing or operation activities. Please refer to Section 7 of this Privacy Policy for more details.

Just like any other third-party website you might access, use of any search engine is subject to the terms of search and privacy policy offered by the specific search engine provider. Some of the web search service available in the application may be provided by partners of CodeFuel Ltd. Including, for example, bing.com. For information on the web search service data collection, please visit the search provider's privacy policy.

3. Why we collect and how long we keep your information

We collect and use your information for a variety of reasons.

Some information is processed because you’ve given your consent to that, such as URL information and website browsing information collected under Internet Protection, which can be set, changed or withdrawn in the Internet Protection in Protection Configuration of the 360 Secure Browser.

We collect other information because we have legitimate business interests, for example, in:

• Understanding how our users use 360 Secure Browser and our Website;
• Delivering our services and communications to you as well as our other users and partners;
• Understanding and responding to user feedback;
• Researching and analysing the services our users want;
• Developing new services and improving our services;
• Understanding the type of products, applications and services our customers use and how they use them;
• Providing security over our business and our customers.

How long we keep your information

We will keep your information for as long as it is reasonably necessary. It will depend on factors such as whether you have an account with us or have interacted with us. We will also routinely refresh our information to ensure we keep it up-to-date.

For clarity, your personal data will be deleted or anonymized when it is no longer needed for its originally stated processing purposes or for any additional compatible purpose for which we may lawfully further process such data.

Automated Individual Decision-Making and Profiling

We do not make automated decisions based on the information we collect and use.

Legal requirements

Your personal data may also be processed if it is necessary on reasonable request by a law enforcement or regulatory authority, body or agency or in the defence of a legal claims. We will not delete personal data if relevant to an investigation or a dispute. It will continue to be stored until those issues are fully resolved.

4. Information we share

We do not sell, lease, rent or give away your personal data. There are certain circumstances where we may transfer your personal data to employees, contractors and to other parties.

• We may share information about you with other members of our group of companies so we can provide the best service across our group. They are bound to keep your information in accordance with this Privacy Policy.Under such circumstances, we will ensure an adequate data protection level by agreements or other arrangements with such members.
• We may also share your information with certain contractors or service providers. They may process your personal data for us, for example, if we use database service providers, advertising agencies, or customer relation management service providers.
  
  Our suppliers and service providers will be required to meet our standards on processing information and security. The information we provide to them, including your information, will only be provided in connection with the performance of their function.

Your personal data may be transferred to other third party organisations in certain scenarios:

• If we’re discussing selling or transferring part or all of our business – the information may be transferred to prospective purchasers under suitable terms as to confidentiality;
• If we are reorganised or sold, information may be transferred to a buyer who can continue to provide services to you;
• If we’re required to by law, or under any regulatory code or practice we follow, or if we are asked by any public or regulatory authority – for example the Police;
• If we are defending a legal claim your information may be transferred as required in connection with defending such claim;
• If we have obtained your explicit consent in advance.

Your personal data may be shared if it is made anonymous and aggregated, as in such circumstances the information will cease to be personal data.

5. Where your information will be stored

Personal data we collected during our service will be stored in the USA, Ireland, or Singapore.

If you are located in the European Economic Area (EEA) or African countries, the personal data we collected and generated will be stored in Ireland.

If you are located in the Americas regions, the personal data we collected and generated will be stored in the USA.

If you are located in Southeast Asia, East Asia or Australia, the personal data we collected and generated will be stored in Singapore.

Some information we collect may be transferred to other countries, such as to our own servers or servers of our database providers in Singapore, and the United States and accessed from China by us and our external IT services providers. These countries may not have equivalent data protection laws to those applicable in the European Union. We do, however, ensure an adequate data protection level by agreements with our data base provider and other arrangements. Please feel free to contact us for further details.

6. Your rights

You may have certain rights in relation to your information including a right to access or to correct the information we hold on you. We’ve listed the rights you have over your information and how you can use them below. These rights will only apply in certain circumstances. They will generally not be available if there are outstanding contracts between us, if we are required by law to keep the information or if the information is relevant to a legal dispute.

• You can ask us to confirm if we are processing your information through the feedback channel in 360 Secure Browser or sending email to our Data Protection Department.
• You can disable User Experience Improvement Program by turning off User Experience Improvement Program through Settings-General-User Experience Improvement Program.
• You can ask us to restrict how we use your personal data.
• You can ask us to stop using your personal data, but only in certain cases.
• You have the right to complain to the relevant supervisory authority.

7. Security

We are committed to keeping your personal data safe. We take reasonable and appropriate administrative, technical, organizational, and physical security and risk management measures in accordance with applicable laws to ensure that your personal data is adequately protected against accidental or unlawful destruction, damage, loss or alteration, unauthorized or unlawful access, disclosure or misuse, and all other unlawful forms of processing of your personal data in our possession.

• We are the first large-scale internet company which appoints the Chief Privacy Officer (“CPO”) in China. CPO is responsible for various affairs related to the users’ personal data that our software and hardware products and services may involve, including formulating privacy policies for various products and services, reviewing the terms of use for the products and services, and supervising implementation of the working principles and data processing mechanism of the products and services. In addition, we have established a department in charge of personal data protection and act under supervision of the public. We transfer and store personal data using encryption to ensure the privacy of such data.
• If you have a 360 account, we may analyse the use time, IP address, and other relevant information for our risk control and management.
• If our application adopts WebView technology, we conduct URL verification on all file agreements used in the WebView and restrict the access to the personal data and SD Card data to avoid the malicious misuse of any private documents and sensitive data of our products without special permission.
• We implement access control mechanism in our service end. We require our employees who may have access to your personal data to obey the principle of data minimization and examine the access list and access records on a regular basis.
• Our server systems used to store your personal data are equipped with strengthened safeguards. We conduct account audit and monitoring on the operation of our servers. Where any security problem of the server systems is reported, we will immediately complete security upgrades for the server systems to ensure the security of our server systems and applications.
• We conduct regular training on the relevant laws and regulations related to personal data protection to strengthen our employees’ awareness of privacy protection.
• If any destruction of our physical, technical or management safeguard measures occurs, we will launch our emergency plan in a timely manner to prevent the spreading effect of the security incident and will report the same to the competent authority in accordance with the relevant laws and regulations. We will also notify you, in a timely manner, of the security incident, potential impacts and the measures we have taken or will take to deal with the incident, in a reasonable and effective way such as pushing notifications and publishing announcements.

8. Changes to the policy

This policy will be changed from time to time.

If we change anything important about this policy (the information we collect, how we use it or why) we will highlight those changes at the top of the policy and provide a prominent link to it for a reasonable length of time following the change.

You can email the Data Protection Department for previous versions, you can get in touch at the following email address: support@360safe.com

10. How to contact us

If you have any questions about this policy please contact our Data Protection Department: 360securitybrowser@360.cn