This document is important. Please read it carefully.
Last Updated: July 26, 2018
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A Note About Children. We do not intentionally gather Information (as defined below) from visitors who are under the age of 13. If a child under 13 submits Information to Dashlane and we learn that the Information is the information of a child under 13, we will attempt to delete the Information as soon as possible. If you believe that we might have any Information from a child under 13, please contact us at firstname.lastname@example.org.
What Information does Dashlane Collect?
Information You Provide. Dashlane collects information that you voluntarily provide on our Site, App and Services. For example:
• Registration Information: When you create a Dashlane account (an “Account”), we ask you to provide an email address that will be used as your login. In addition, you are required to create a “Master Password” used to access your Account. Your Master Password is the basis for the encryption key used in protecting your Encrypted Sensitive Information (see below). Your Master Password is not known to Dashlane and is not stored in any digital form unless you explicitly ask to do so. When you enable specific services, we may collect additional information that you knowingly provide.
• Encrypted Sensitive Information: In order to use the password manager and secure digital wallet elements of the Services you will enter certain information into the App, including highly sensitive information like names, addresses, phone numbers, identity information, credit card information, passwords, receipts for online transactions and secure notes (“Encrypted Sensitive Information”). The Encrypted Sensitive Information is encrypted locally on your device using strong encryption and is backed up on the Dashlane cloud. None of it is viewable to Dashlane because it is encrypted with the Master Password. If you choose to synchronize your Encrypted Sensitive Information with more than one device (each an “Authorized Device” via the Services, the “Sync Function”), the Services are designed to transmit and store the Encrypted Sensitive Information through the Dashlane cloud to the Authorized Device(s) using strong encryption and in a manner that Dashlane will not be able to read.
• Billing information: When you pay for certain services (for example, Premium Services) we will collect all information necessary to complete the transaction, including your name and billing address. Other billing information necessary to complete the transaction, like your credit card information, is collected by our payment processor, but is not made available to Dashlane.
• Anonymous Usage Information: As described in more detail in the “Information Collected Via Technology” section below, during your use of our Services, we automatically collect certain information and technical data about the use of our Services. All Usage Information is Anonymous Information as defined below.
• Feedback: If you provide us feedback or send us an email, we will collect your e-mail address as well as the content of your email in order to communicate with you and send you a reply.
• Miscellaneous Information. We also collect other types of information where: (a) you provide it to us voluntarily, for example, if you contact us regarding support for the Services, or (b) in the manner disclosed by us at the time that such information is being collected.
Information Collected via Technology. Dashlane collects certain forms of information automatically. For example:
• Log Files. As is true of most digital services, we gather certain information automatically and store it in log files. This information may include IP addresses, browser type, Internet service provider (“ISP”), referring/exit pages, operating system, date/time stamp, clickstream data, your mobile device’s connection logs, operating language, operating system country, device identifiers, location data, and the telephone number. We use this information to analyze trends, administer the Site and Services, track users’ movements around the Site, gather demographic information about our user base as a whole, better tailor our Services to our users’ needs, and for the purposes of fraud detection and authentication.
Information Collected from You About Others. If you invite someone to create an Account through the Services (a “Referral”), Dashlane will store the email address of the Referral and the message you have sent, in order to send an email and follow up with the Referral. We rely upon you to obtain whatever consents from the Referral that may be required by law to allow us to access and upload the Referral contact information as required above. You or the Referral may contact us at email@example.com to request removal of this information from our database.
All of the information that is identified as collected in this Section, including the Registration Information, Encrypted Sensitive Information, Billing Information, Anonymous Information and information collected from others is referred to as “Information”.
How does Dashlane use your Information?
In general Dashlane uses your Information to provide the Services, respond to requests that you make, and to aid us in serving you better, including in the following ways:
• facilitate the creation of and to secure your Account on the Dashlane cloud;
• provide you the Services you request;
• identify you as a user in our system and to perform fraud detection and authentication;
• improve the quality and experience when you interact with our Site and Services;
• send you administrative email notifications, such as security or support and maintenance advisories;
• respond to your inquiries and other requests and
• send newsletters, surveys, offers and other promotional materials related to our Services and for other marketing purposes of Dashlane , as permitted by applicable law and subject to your Account preferences.
Creation of Anonymous Information. If we have any information that is identifiable with a particular person, we may create Anonymous Information records from such Information by excluding information that makes the information personally identifiable. We may use Anonymous Information for any purpose and disclose Anonymous Information to third parties. “Anonymous Information” means information that is not (and cannot be) associated with an identifiable natural person.
How does Dashlane share the information it collects?
• Sharing Groups. If you create a Sharing Group, Dashlane will share some or all of your Encrypted Sensitive Information (collectively, “Shared Information” with the Recipients you designate in your Sharing Group. Shared Information will always be shared with all Recipients in a Sharing Group, however, you may restrict or customize access to Shared Information by designating which Recipients are also granted admin privileges over your Shared Information. You may revoke a Recipient’s access to your Shared Information at any time.
• Emergency Contacts. Our Services enable you to designate emergency contacts who we will contact in the event you are unable to access your Account or information therein. If you set an emergency contact, then, upon satisfaction of any conditions you have established as a pre-condition to the release of your Account credentials, Dashlane will disclose such information to the designated emergency contact.
• Fraud Protection. In order to make it less likely that someone will perpetrate a fraud on you, we may provide some portion of the Information, including some Encrypted Sensitive Information, to the financial institution that issued your credit card or other payment information that operates your credit card or payment network (collectively, “Payment Providers”). We provide such Information to the Payment Providers solely for the purpose of assisting them in preventing fraud. We make this information available to Payment Providers using a public-private key so it remains unreadable to Dashlane and its other Service Providers.
Note that Dashlane does not permit its Service Providers to use your Information for any marketing or publicity purposes unrelated to the Services, nor does Dashlane sell or otherwise make available Information to any third party except as set forth herein.
How secure is your Information?
The security of the Information that you enter in the Dashlane App is extremely important to Dashlane. This is why Dashlane implements a variety of security measures, including AES 256-bit encryption designed to prevent unauthorized access, alteration, and use of your Encrypted Sensitive Information. While Dashlane has gone to great lengths to protect your Information, no method of transmission over the Internet, or method of electronic storage, is 100% secure; therefore, Dashlane cannot guarantee its absolute security. In addition, the security of your Information also depends on how you use the Dashlane App and Services and protect the Master Password that enables you to access your Account and decrypt your Encrypted Sensitive Information. We therefore strongly recommend that you carefully read and implement the Dashlane security guidelines available here: https://www.dashlane.com/en/security/.
How can you access and manage your Information?
Changing Your Information. You can access and rectify your Information directly through the Dashlane App. For any question or concern you may have with respect to your Information, you can contact: firstname.lastname@example.org.
Applications. You can stop all collection of information by the App by uninstalling the App from your device or computer. You may use the standard uninstall processes as may be available as part of your desktop or mobile device or via the mobile application marketplace or network.
Questions; Contacting Dashlane; Reporting Violations.
Attn: Legal Department
156 Fifth Avenue, Suite 504
New York, NY 10010