Antivirus Spark attaches great importance to users' privacy and personal data protection, and rigorously abides by all applicable data protection laws and regulatory requirements. This Privacy Policy elaborates on the types of information we collect during your use of our application, as well as the responsible management and protection measures we adopt for your personal information.
This Privacy Policy (the “Policy”) serves to explain what information Antivirus Spark and its affiliates and subsidiaries (collectively, “we”, “us”, or “our”) collect, and how we use and protect your information when you use any mobile applications that we develop and are available for download in the Google Play Store.
1. Information We Collect
We may have to collect your personal data to provide you with the better weapons and the most up-to-date security. We do not take your trust for granted. We conform our data use to the European Union’s (“EU”) General Data Protection Regulation (“GDPR”), with effect from 7 May 2020. Therefore, in our Privacy Policy, we explain what we do, how we do it, your choices, and how we may need your cooperation to help you stay safe.
i. Device information
We collect your device and network connection information in order to provide you better experience when you use our app. This information depends on the context of your interactions with us, the choices you make, including your privacy settings, and the products and features you use, and may include:
android_id
device_id
model, brand
screen resolution, screen density, screen width and height
network status
application version number, version name
gaid
system version number, version name
ad_id
country
list of installed applications
storage card
wifi status
installed package usage
collect notification bar, etc.
ii. Data about your use of the Services
Number of clicks, landing pages, pages viewed and order of those pages, the amount of time spent on particular pages, the date and time of your request, number of the app opened and some viewed pages, permissions status, whether the function is running normally, such as whether a virus is detected, package name, first open time stamp, app brand, app net status, app model, and system language.
"Log Data" is technical information that is automatically collected by us when you use Application, whether through the use of cookies, web beacons, log files, scripts and e-tags or otherwise, including: Technical information, such as your mobile carrier-related information, configuration information made available by your web browser or other programs you use to access Application, your IP address and your device's version and identification number.
Information about what you have searched for and looked at while using Application, such as web search terms used, social media profiles visited and details of other information and content accessed or requested by you in using Application.
These data will only be passed to the certified third-party statistical platform and our self-built data statistics system. The above information is only used to improve the product experience and will not be sold to any third parties. We will not use this information for purposes other than improving the product experience and ad performance.
iii. Android Ad ID
We use your Android advertising identifier to present you with a personalized advertising experience. It is just used for advertising and analytic. Please keep in mind that the advertising identifier contains no user-sensitive information that may be used to identify you or your device. It is not linked to any personally identifiable information or any persistent device identification.
iv. Designated Countries
For all information listed above, pursuant to the EU General Data Protection Regulation (“GDPR”) or any equivalent legislation (collectively “Data Protection Laws”), we process the personal information of users located in the European Economic Area (“EEA”), United Kingdom and Switzerland (collectively, the “Designated Countries”) based on our contract with you
v. Non-Personal Information
Non-Personal Information is any information that relates to you but from which it is not practicable to directly or indirectly identify you, which may include the information about your devices (such as Your hardware model, operating system version, unique device identifiers, and mobile network information), the list of installed apps on your devices, and technical information about users means of connection to our apps, such as the versions of phone model and other similar information.
vi. Antivirus Engine Provider
The Antivirus engine is powered by Trustlook SDK. Trustlook SDK provides security service and it will record certain information that included user's installed applications. Because it will analyze the app collection, app static & behavior analysis to give the app risk report.
Information collection scope：When you use the virus scanning function, we will collect your installed application list and upload it to a third-party virus database (https://saas.trustlook.com/) for scanning, so as to discover possible security risks in time and better protect the security of your device and your privacy.
we will collect the following installed application information:
App name and package name
App version number and version name
MD5 hash and signature information
Installation path and file details on device storage
Purpose of Data Collection：Through the security engine provided by Trustlook SDK, we upload the above information to the third-party virus database (https://saas.trustlook.com/) for the purpose of: identifying malware, viruses and privacy threats, and generating application security risk assessment reports.
Data Sharing Policy: The collected application information is only shared with Trustlook for security scanning services. We promise not to sell, trade or use data for non-security protection purposes with other third parties.
2. How Do We Use the Information?
2.1 We may use your Information for any purpose as below:
Provide Application and Services (and the features within Application) to you, such as to show to other users in Antivirus Spark such as your connected friends or other users on the platform;
Provide you with advertising and direct marketing that is more relevant to you;
Better understand how you access and use Application, in order for us to improve Application and respond to customer desires and preferences, including for us to provide language and location customization, personalized help and instructions, or other responses to your and other customers' usage of Application;
Help develop our service and provide, maintain, improve and modify the Applications, Services and the Site and develop new services;
Assess the effectiveness of and improve advertising and other marketing and promotional activities on or in connection with Application.
2.2 Collected Information
The types of information we collect vary based on how you interact with our services, your privacy preferences, and the products or features you use. The collected information may include: SDK/API/JS and app version information, browser details, internet service provider, IP address, operating platform, timestamps, app ID, app version, app distribution channel, unique device identifiers, GAID, advertising ID (AD_ID), device model, device manufacturer, device OS version, storage information, screen resolution, screen density, screen dimensions, session start and end time, language, region, time zone, network status (e.g., Wi Fi), disk, CPU and battery usage, list of installed applications, and notification bar related data.
2.3 Sharing of Information
To optimize our products and deliver better user experience, we may share your personal information with trusted third-party service providers and agents acting on our behalf, solely for the purposes stated in this Privacy Policy. For instance, third parties engaged to conduct data analytics may need to access relevant information to perform their assigned services. All such partners are required to strictly comply with our data privacy and security standards.
2.4 Legal Basis for Data Processing
We process your personal information in accordance with the purposes outlined in this Privacy Policy. The lawful grounds for our data processing include:
Performance of contract: To deliver the services you request, as well as to verify your identity and authenticate your access to our applications and services.
Compliance with legal obligations: To abide by applicable laws, accounting regulations and fulfill mandatory disclosures to competent authorities.
Legitimate business interests: To maintain user relationships, safeguard the security of our services, and send you updates about our products and services.
User consent: Where applicable, including placing cookies and sharing information with third parties for advertising activities.
In certain cases, providing your personal information is necessary for us to fully deliver our services and enable all features of our applications.
2.5 Cross-border Data Transfers
Our business operations may involve transferring your personal information to countries or regions outside the European Economic Area (EEA). We implement proper safeguards to ensure overseas recipients are bound by confidentiality obligations, including adopting standard contractual clauses. You may request a copy of these clauses by contacting our support team.
2.6 User Rights & Data Retention
Subject to applicable laws and regulations, you have the right to object to, or request restrictions on the processing of your personal information. You may also submit requests to access, correct, delete or obtain a portable copy of your personal data.
If processing is based on your prior consent, you may withdraw your consent at any time. Withdrawal will not affect the legality of data processing conducted prior to the withdrawal. Please submit all related requests via our contact email: dev.keplenslimited@gmail.com
Please notify us promptly if your personal information is updated or contains errors, so we can revise our records in a timely manner. If you believe our data processing violates relevant laws, you have the right to file a complaint with the local data protection authority.
We retain your personal information only for as long as necessary to provide products and services to you, or as mandated or permitted by applicable laws (including tax and accounting regulations).
3. What Information Do We Share?
As mentioned above, your personal information may be shared with our third-party partners. We may disclose your personal information to our business partners, including publishers, and data tracking companies. These business partners may use your personal information to measure your ad/site interaction, and better understand the site and app traffic usage or user behavior in order to improve their services. Such partners’ use of the information that we disclose to them will be governed by their privacy policies.
4. What Are the Important Permissions We Request?
Depending on the context of your interactions with us, we may ask you to provide certain permissions in order to let our app perform properly. You may choose to opt-out anytime, but please note that not giving us these permissions can result in malfunctioning of our app. The permissions we ask are listed below:
Storage: to read the contents of your storage, and to modify or delete the contents of your storage.
Wi-Fi connection information: to view Wi-Fi connections.
Other:
Receive data over the internet, access all network connections, access app storage information, add and remove app home screen shortcuts, view network connection status, manage running applications, view the list of installed applications, display content over other apps, show persistent notifications in the notification bar, enable Wi-Fi connection and disconnection, run foreground services, expand and collapse status bar elements, and retrieve approximate network-based location data.
5. Legal Basis of Your Personal Data
We process Personal Data for the purposes set out in this Privacy Policy, as described above. Our legal basis to process personal data includes processing that is: necessary for the performance of the contract with you (for example, to provide you with the services you request and to identify and authenticate you); necessary to comply with legal requirements (for example, to comply with applicable accounting rules and to make mandatory disclosures to law enforcement); necessary for our legitimate interests (for example, to manage our relationship with you, to ensure the security of our services, to communicate with you about our products and services); and based on consent by our customers.
In some instances, you may be required to provide us with Personal Data for processing as described above, in order for us to be able to provide you all of our services, and for you to use all the features of our app.
6. Data Processing and Protection
We remove all direct identifiers from the personal data we collect. We adopt various security means including encryption to guard your data against unauthorized access and leakage.
All our partnered third parties are required to keep personal data secure when performing services for us.
7. User Rights
You are entitled to the rights set forth below while using our services. To exercise your legal rights, please contact us via email: dev.keplenslimited@gmail.com. We will require you to verify your identity upon receiving your request.
Please note that your rights are subject to statutory limitations. We may decline or restrict your requests under the following circumstances:
Access is prohibited or permitted to be refused by applicable laws;
Granting access would compromise the privacy rights of other individuals;
For the protection of our legal rights and assets;
The request is unreasonable, repetitive or imposes excessive operational burden.
i. Right to Withdraw Consent
Where we process your personal data based on your consent, you may withdraw such consent at any time. Withdrawal shall not affect the validity of data processing conducted prior to the withdrawal, nor the processing performed by relevant third parties based on your original consent.
ii. Right to Access and Correction
Upon your request, we will provide you with a copy of your stored personal data promptly and free of charge, unless laws allow us to impose a reasonable fee. We may limit your access if it would impair the legitimate rights and freedoms of others. You may also request us to correct or update your personal data, unless you can edit the information directly within our services.
iii. Right to Erasure (Right to be Forgotten)
You may ask us to delete your personal data if:
The data is no longer needed for the original collection and processing purposes;
You have withdrawn your previously granted consent for data processing;
You object to the processing, and we have no prevailing legitimate grounds to continue processing your data.
iv. Right to Restriction of Processing
You have the right to request a restriction on our processing activities in the following situations:
You dispute the accuracy of your personal data. We will suspend relevant processing (which may partially or fully interrupt our services) while we verify the data;
The processing is unlawful, and you choose to restrict data use instead of requesting deletion;
We no longer need the data for service purposes, but you require it to file, pursue or defend legal claims;
You have lodged an objection to processing, pending verification of whether our legitimate interests take precedence over your rights.
While processing is restricted, we may only use your data with your consent, for legal claim proceedings, to protect the rights of other individuals or entities, or for substantial public interests. We will notify you once the restriction is lifted.
v. Right to Object to Processing
In accordance with applicable laws, you may object to our data processing at any time, if the processing is based on your consent, contract performance or our legitimate interests. We may continue processing your data if it is necessary for legal defense or otherwise permitted by law.
vi. Right to Data Portability
If your personal data is processed under a contract, based on your consent, or through fully automated means, you may request to obtain your data in a structured, widely used and machine-readable format. Where technically feasible, you may also ask us to transfer the data directly to another data controller. This right will not be granted if it infringes upon other people’s rights and freedoms.
vii. Notification to Third Parties
If we have shared your personal data with third parties, we will inform them of your requests for correction, deletion or processing restriction, unless it is impractical or requires disproportionate effort. We will also disclose the identities of these third parties at your request.
viii. Automated Decision-Making and Profiling
You have the right to refuse decisions that are made solely through automated data processing (including user profiling) and bring legal or major impacts on you, except where exemptions apply under relevant laws.
ix. Right to File a Complaint
If you believe we have violated your privacy rights, please contact us at dev.keplenslimited@gmail.com, and we will address your issues. You also have the right to submit a complaint to the competent data protection authority in your country of residence, workplace or the place where the alleged infringement occurred.
8. Privacy Rights for California Residents
We have created this supplementary privacy notice to comply with the California Consumer Privacy Act (CCPA) and other applicable California privacy laws. It complements our main Privacy Policy and applies exclusively to users residing in California (referred to as "you" or "consumers").
This section does not apply to users who are not California residents. Non-California users shall refer to our main Privacy Policy.
i. Right to Request Disclosure of Personal Information
Pursuant to the CCPA, you or your authorized representative may submit requests to obtain details about how we collected, used and shared your personal information over the preceding 12 months. The disclosed information will cover: categories of personal data collected, sources of such data, business purposes for collection, and categories of third parties we share your data with.
ii. Right to Delete Personal Information
Under the CCPA, you or your authorized agent may decline the sale or sharing of your personal data, and request deletion of the personal information we have collected and retained. We may retain your data and decline deletion requests in the following circumstances:
To detect security incidents and defend against malicious or illegal activities;
To identify and resolve technical errors affecting normal app functionality;
To protect freedom of speech and other legal rights granted by law;
To conduct internal data uses reasonably consistent with your expectations based on our relationship;
Other scenarios stipulated under the CCPA and California state laws.
iii. How to Exercise Your Rights
To submit a verifiable consumer request and exercise your rights above, please email us at dev.keplenslimited@gmail.com.
Only you or your duly authorized agent may submit verifiable requests regarding your personal data. You may submit information disclosure requests no more than twice within any 12-month period. A valid verifiable request must:
Provide adequate details for us to verify your identity and confirm we hold your personal information;
Clearly describe your request to allow us to process and respond accordingly.
We cannot fulfill your request if we fail to verify your identity.
iv. Response to Your Requests
We aim to respond to all valid verifiable consumer requests within 45 days upon receipt. If an extension is needed (maximum 90 days in total), we will notify you of the reason and new timeline via email, phone or other electronic communication methods.
We do not charge fees for processing standard verifiable requests. We may impose a reasonable fee only if the request is excessive, repetitive or clearly unfounded. If a fee applies, we will explain the reason and provide a cost estimate before proceeding.
v. Non-discrimination
We will not discriminate against you for exercising your rights under the CCPA. Discriminatory practices include refusing service, applying different pricing, providing services of different quality or standard, or implying differential service terms for users who exercise their legal rights.
9. Policy Updates
All collected personal information is governed by the version of Privacy Policy in force at the time of collection. We reserve the right to revise this Policy periodically. We will notify you of material updates or amendments through appropriate channels. Your continued use of our application and services after the Policy takes effect constitutes your acceptance of the revised terms.
10. Contact Information
If you have any questions or concerns about this Privacy Policy, please contact us via the email address below:
Email : dev.keplenslimited@gmail.com.