Qihu 360 Software Co. Ltd ("360"), a company based in [Hong Kong], is the developer of 360 online services ("Services") and computer or mobile security software products ("Software"). We take the privacy of our customers seriously and are committed to safeguarding your privacy while you use our services. This policy (hereinafter the "Privacy Policy") describes the types of information we collect when you use 360's Services and Software, how we may use that information and with whom we may share it. Our Privacy Policy also describes the measures we take to protect the information you share with us. Should you have any questions, please contact our chief privacy executive at [privacy@360safe.com]. Our website may contain links to third party sites which are not subject to the Privacy Policy. 360 does not endorse and is not responsible for the privacypractices or content of the third party sites, and 360 encourages you to read the privacy policy of any third party site you may visit.

PERSONAL USER INFORMATION

In order to provide our services described in the Software License and Service Agreement, we may collect the following "Personal User Information":

Contact Information (including name, address, email address, business address, telephone and fax number)
Personal Details (including birth date, race, gender, sexual orientation, ID card number and social security number)
Internet Access and Use Information (including social network account user names, contacts, chat logs, email messages, search history and web browsing history)
Payment Information (including payment card bank account numbers or passwords, credit card statements, or transaction histories)
Transaction Information (including your purchase history and data relating to use of Services and Software provided by 360)
Correspondence (including any information you provided or were provided through 360 related communication channels, including technical support and customer service)
Photograph (if you share a photograph with us)

We collect the following information in two ways:

Information you give us. You may give us information in a variety of ways, including when you request technical support or customer service, register a product, or give us reviews or feedback. As an example, many of our Services and Software require you to sign up for a 360 Account. When you do, we will ask you to submit certain Personal User Information, like your name, email address, and other contact information. If you want to take advantage of the communication tools we offer, the foregoing information may be publicly visible, including your name and photograph.
Information we get from your use of our Services and Software. We may collect information about the Services and Software that you use and how you use them. This information may include, for instance, information about your device, details about your usage patterns, limited details about your Internet usage stored temporarily to provide our Services and Software, computer files and risks such as malware, and information that may be included in a virus or malware sample that we collect from your computer for review.
- Device information. We may collect device-specific information, including your operating system version, system language, and IMEI number. In order to view the following system information of managed computers for 360 Connect for Android/iOS: operating system, CPU, memory, hard disk, computer name, 360 Total Security will upload the following information to 360 Security Center: CPU model, memory, hard disk, operating system, computer name.
- Log information. When you use our Services and Software, we may automatically collect and store certain information on our servers related to your use of our website or Services and Software to help us improve the quality of our products and service. This may include:
  - The manner in which you use our website or Services and Software, including how frequently you install, use or uninstall our Software and its features.
  - IP address.
Information collected relating to installed programs scanned by Software features. The information uploaded onto our 360 cloud security center ("360 Cloud Security Center") servers for virus scanning and Instant Setup function include: file paths and MD5 checksums of the executable files, installed software names, package names, software signature certificates, and software URLs in conjunction with our filtering feature, which we apply to suspicious URLs when you use 360 Internet Protection (this information is processed with encryption and temporarily stored solely to provide our Services).
- URL information. URLs of websites that you visit will be uploaded to 360 Cloud Security Center servers for phishing and online fraud analysis. Any Personal User Information will be removed from the URLs before they are uploaded. The information is processed with encryption before the upload. In order to receive the critical system event (including system startup, malware activity, risky website visiting, low system disk space ) from managed computers for 360 Connect for Android/iOS, 360 Total Security will upload the following information to 360 Security Center: malware activity, risky website visiting, system startup, disk usage.
- Information relating to upgrades and updates to Software, including the time of the upgrade and the version of the upgrade.
- Unique Serial numbers. When you use certain services, they might have a unique 360 serial number. This serial number and certain information about your installation (for example, the type of operating system on your device) may be sent to 360 when you install or uninstall Software or when Software periodically contacts our servers, such as in a check for automatic updates.
- Local storage. We may collect and store information (including personal information) locally on your device using mechanisms such as browser web storage (including HTML 5) and application data caches. Such information includes: user settings, file whitelist and blacklist used to accelerate file scanning. In order to activate the computer check up for 360 Connect for Android/iOS to remove malware, optimize system performance and clean up system junks, 360 Total Security will upload the following information to 360 Security Center: startup items, system junks and malware detection.
- Error Log Uploading: Software will generate an error log and a DUMP file automatically when an unexpected error occurs or an application crashes. Software will upload the error log and the DUMP file to 360 Cloud Security Center as required to find out the reason that the error occurred or Software crashed and improve the quality of the product. Before uploading the error log and the DUMP file, Software will prompt you to agree to the upload. If you agree, Software will upload the error log and the DUMP file to 360 Cloud Security Center; and if you do not agree, Software will not upload the log. The error log is a record of Software errors and/or crashes. DUMP files are generated by the operating systems (e.g. Windows, Android, and iOS) when a program crashes, and contain the program execution status of the crash, including the time of crash and system information. They do not contain Personal User Information.

USE OF PERSONAL USER INFORMATION

360 uses the Personal User Information it collects in ways that serve your security and privacy needs, including the following:

Provide threat prediction and protection products and services;
Provide security advisories, information and product updates;
Provide recommendations on software/programs;
Conduct research and analysis (for example, market and consumer research, security research and analysis, and trend analysis);
Analyze users’ behavior when using 360's Services and Software to customize users’preferences;
Provide customer support, manage subscriptions and respond to requests, questions and comments;
Communicate about, and administer participation in, special events, programs, surveys, contests, sweepstakes, and other offers and promotions;
Customize, measure, and improve our websites properties;
Analyze and develop new products, services and websites;
Prevent detect, identify, investigate, and protect against potential or actual claims, liabilities, prohibited behavior, and criminal activity;
Comply with and enforce applicable legal requirements, agreements and policies; and
Perform other activities consistent with this policy.

OTHER WAYS THAT WE MAY USE YOUR PERSONAL INFORMATION

360 Account: Depending on the version of Services and Software you have licensed, you may be required to have a current 360 Account ("360 Account") in order to access and use Software and Services. If you do not have a 360 Account, you may be prompted to complete the applicable registration process to create a 360 Account in order to use our Software and Services. We may use the information you provide in your profile relating to your 360 Account across all of the Services and Software we offer that require a 360 Account. If other users already have your email, or other information that identifies you, we may show them your publicly visible profile information, such as your name and photo.
Customer Experience Improvement Program: If you participate in the 360 Customer Experience Improvement Program, 360 will collect usage statistics of each Software as required, which generally includes the installation and use frequency statistics of each featured user. Upon analysis of this data, 360 may improve the quality of Software and release helpful security services to users. The statistics are only taken in connection with 360's Software, and contain no Personal User Information.
Feedback: When you contact 360 with any feedback or for customer service or technical support by email or in any other manner, we may keep a record of your correspondence with us to help solve any issues you might be facing. If you decide to sign up to receive updates or information about Software orServices, or to receive any of our marketing materials, we may use your email address to send you updates, newsletters or marketing materials, we may use your email address to send you updates, newsletters or marketing materials. You may unsubscribe to such communication at any time.

INFORMATION SECURITY

We work hard to protect 360 and our users from unauthorized access to, or unauthorized alteration, disclosure or destruction of, Personal User Information we hold. In particular:

We encrypt the information obtained through provision of many of our Services in accordance with SSL protocol.
Before any information is uploaded to our 360 Cloud Security Center, we will encrypt this information using industry standard encryption methods, including MD5 and SHA1.
We may review our information collection, storage and processing practices, including physical security measures, to guard against unauthorized access to systems whenever we find it appropriate to do so.
We restrict access to your Personal User Information by 360 employees, contractors and agents required to provide our Software and Services. All 360 employees, contractors and agents are subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations.

INFORMATION WE SHARE

We do not share Personal User Information with companies, organizations and individuals outside of 360 unless one of the following circumstances apply:

With your consent. We will only share your personal information with companies, organizations or individuals outside of 360 when we have your specific consent to do so, except when we share your Personal User Information to affiliate businesses or to third-party servicers which provide administrative or other services to us in connection with the Services and Software we offer you.
For external processing. In order to provide the most efficient and up-to-date services, we provide your personal information to our affiliate businesses and to third-party servicers which provide administrative or other services to us in connection with the Services we offer you. We will only disclose your Personal User Information in accordance with our Privacy Policy and any other appropriate confidentiality and security measures as regulated by law. We will ensure that any third party servicers that may come in contact with your Personal User Information will have confidentiality and/or privacy policies equal to or greater than our own.
For legal reasons. To the extent required or permitted by the applicable law, we will share personal information with companies, organizations or individuals that are not affiliated with 360 if we have a good-faith belief that access, use, preservation or disclosure of such information is reasonably necessary to:
Meet any applicable law, regulation, legal process or enforceable governmental request, including a subpoena, warrant or other process issued by a court of competent jurisdiction;
Enforce applicable Terms of Service and/or End User License, including investigation of potential violations;
Detect, prevent, or otherwise address fraud, security or technical issues.
As may be required for purposes of national security; or
Prevent physical, financial or other harm, injury or loss or in connection with an investigation of suspected or actual illegal activity or exposure to legal liability, where 360 believes disclosure is necessary or appropriate.

If 360 is involved in a merger, acquisition or asset sale, we will continue to ensure the confidentiality of any personal information and give users affected by such merger, acquisition or asset sale notice before personal information is transferred or becomes subject to a different Privacy Policy.

Your California Privacy Rights - Shine the Light Law

We do not share your personal information with non-affiliated third parties for their own marketing use without your permission.

CONSENT

We will ask for your consent before using your personal information for any purpose other than those that are set out in this Privacy Policy to the extent permitted by law. We will cease to use any of your Personal User Information for any purpose if you request us to do so.

TRANSPARENCY AND CHOICE IN COLLECTION PROCESS

We understand that our users have different privacy concerns. Our goal is to be clear about what personal information we collect, so that you can make meaningful choices which would affect how your personal information would be used by us. If you choose to not to participate in our use of your Personal User Information, you may close or choose not trigger certain functions of our Software or Services. However, we would like to explicitly point out that if you do so, you will not be able to fully use all of our Software or Services.

ACCESSING AND UPDATING YOUR PERSONAL INFORMATION

If at any time you would like to access or correct your information that we have on file, please send your request to privacy@360safe.com via email. When providing you with or updating your personal information, we may ask you to verify your identity before we can act on your request.

Where we can assist in providing or correcting your information, we will do so for free, except where it would require a disproportionate effort. We aim to maintain our Services and Software in a manner that protects information from accidental or malicious destruction. Because of this, after you delete information from our Services and Software or request deletion of our information, we may not immediately delete residual copies from our active servers and may not remove information from our backup systems.

APPLICATION OF PRIVACY POLICY

Our Privacy Policy applies to all of the website, Services and Software offered by 360 and its affiliates.

ENFORCEMENT

We regularly review our compliance with our Privacy Policy. We also adhere to several self-regulatory frameworks. When we receive formal written complaints, we will contact the person who made the complaint to follow up. We work with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of personal data that we cannot resolve with our users directly.

MODIFICATIONS

Our Privacy Policy may change from time to time. We will post any Privacy Policy changes on this page and. We will not make any material retroactive changes to this Privacy Policy, including for changes involving the use of your Personal User Information, without your affirmative consent.

CHILDREN'S PRIVACY

360 complies with the Children's Online Privacy Protection Act of the United States of America where it applies to our information protection activities. 360 does not knowingly collect personal information from children under the age of 13.

DATA TRANSFER

As our servers are in many countries around the world, we may transfer personal information we obtain to countries other than the country in which the information originally was collected. When we transfer personal information to other countries, we will protect such personal information as described in this Privacy Policy.

AGREEMENT WITH THE PRIVACY POLICY

You expressly consent to 360's processing of information as described in this Privacy Policy when you:

provide information to us through our websites; or
license or download our Software or Services and accept the Terms of Service or End User License.

In addition, through these uses and interactions with 360 Software, Services or websites, you specifically consent to our collection of Personal User Information by automated means, and to our subsequent processing of the Personal User Information in accordance with this Privacy Policy and to the storage and transfer of the Personal User Information to locations wherever 360 and its service providers have facilities.