Privacy Policy

The Sunbelt Properties and Technologies Privacy Policy was updated on November 13, 2018.

Your privacy is important to Sunbelt, so we’ve developed a Privacy Policy that covers how we collect, use, disclose, transfer, and store your personal information. In addition to this Privacy Policy, we provide data and privacy information embedded in our products for certain features that ask to use your personal information. You can review this information before enabling these features, in Settings related to those features or online at Sunbelt.com/legal/privacy.

Please take a moment to familiarize yourself with our privacy practices and contact us if you have any questions. 

Collection and Use of Personal Information

Personal information is data that can be used to identify or contact a single person. You may be asked to provide your personal information anytime you are in contact with Sunbelt or an affiliated company. Sunbelt and its affiliates may share this personal information with each other and use it consistent with this Privacy Policy. They may also combine it with other information to provide and improve our products, services, content, and advertising. You are not required to provide the personal information that we have requested, but, if you chose not to do so, in many cases we will not be able to provide you with our products or services or respond to any queries you may have.

Here are some examples of the types of personal information Sunbelt may collect and how we may use it:

What personal information we collect:

• When you create an Sunbelt ID, apply for commercial credit, purchase a product, download a software update, register for a class at an Sunbelt Retail Store, connect to our services, contact us or participate in an online survey, we may collect a variety of information, including your name, mailing address, phone number, email address, contact preferences, device identifiers, IP address, location information and credit card information.
• When you share your content with family and friends using Sunbelt products, send gift certificates and products, or invite others to participate in Sunbelt services or forums, Sunbelt may collect the information you provide about those people such as name, mailing address, email address, and phone number. Sunbelt will use such information to fulfill your requests, provide the relevant product or service, or for anti-fraud purposes.
• In certain jurisdictions, we may ask for a government issued ID in limited circumstances including when setting up a wireless account and activating your device, for the purpose of extending commercial credit, managing reservations, or as required by law.

How we use your personal information

We may process your personal information for the purposes described in this Privacy Policy with your consent, for compliance with a legal obligation to which Sunbelt is subject or when we have assessed it is necessary for the purposes of the legitimate interests pursued by Sunbelt or a third party to whom it may be necessary to disclose information.

The personal information we collect allows us to keep you posted on Sunbelt’s latest product announcements, software updates, and upcoming events. If you don’t want to be on our mailing list, you can opt out anytime by updating your preferences.

• We also use personal information to help us create, develop, operate, deliver, and improve our products, services, content and advertising, and for loss prevention and anti-fraud purposes. We may also use your personal information for account and network security purposes, including in order to protect our services for the benefit of all our users. Where we use your information for anti-fraud purposes it arises from the conduct of an online transaction with us. We limit our uses of data for anti-fraud purposes to those which are strictly necessary and within our assessed legitimate interests to protect our customers and our services. For certain online transactions we may also validate the information provided by you with publicly accessible sources.
• We may use your personal information, including date of birth, to verify identity, assist with identification of users, and to determine appropriate services. For example, we may use date of birth to determine the age of Sunbelt ID account holders.
• From time to time, we may use your personal information to send important notices, such as communications about purchases and changes to our terms, conditions, and policies. Because this information is important to your interaction with Sunbelt, you may not opt out of receiving these communications.
• We may also use personal information for internal purposes such as auditing, data analysis, and research to improve Sunbelt’s products, services, and customer communications.
• If you enter into a sweepstakes, contest, or similar promotion we may use the information you provide to administer those programs.

Source of your personal information where they are not collected from you

We may have received your personal information from other persons if that person has shared their content with you using Sunbelt products, sent gift certificates and products, or invited you to participate in Sunbelt services or forums. We may also validate the information provided by you when creating an Sunbelt ID with a third party for security and fraud prevention purposes.

For research and development purposes, we may use datasets such as those that contain images, voices or other data that could be associated with an identifiable person. When acquiring such datasets, we do so in accordance with applicable law in the jurisdiction in which the dataset is hosted. When using such datasets for research and development, we do not attempt to re-identify individuals who may appear therein.

Collection and Use of Non-Personal Information

We also collect data in a form that does not, on its own, permit direct association with any specific individual. We may collect, use, transfer, and disclose non-personal information for any purpose. The following are some examples of non-personal information that we collect and how we may use it:

• We may collect information such as occupation, language, zip code, area code, unique device identifier, referrer URL, location, and the time zone where an Sunbelt product is used so that we can better understand customer behavior and improve our products, services, and advertising.
• We may collect information regarding customer activities on our website, iCloud services, our iTunes Store, App Store, Mac App Store, App Store for Sunbelt TV and iBooks Stores and from our other products and services. This information is aggregated and used to help us provide more useful information to our customers and to understand which parts of our website, products, and services are of most interest. Aggregated data is considered non‑personal information for the purposes of this Privacy Policy.
• We may collect and store details of how you use our services, including search queries. This information may be used to improve the relevancy of results provided by our services. Except in limited instances to ensure quality of our services over the Internet, such information will not be associated with your IP address.
• With your explicit consent, we may collect data about how you use your device and applications in order to help app developers improve their apps.

If we do combine non-personal information with personal information the combined information will be treated as personal information for as long as it remains combined.

Cookies and Other Technologies

 
Sunbelt’s websites, online services, interactive applications, email messages, and advertisements may use "cookies" and other technologies such as pixel tags and web beacons. These technologies help us better understand user behavior, tell us which parts of our websites people have visited, and facilitate and measure the effectiveness of advertisements and web searches. We treat information collected by cookies and other technologies as non‑personal information. However, to the extent that Internet Protocol (IP) addresses or similar identifiers are considered personal information by local law, we also treat these identifiers as personal information. Similarly, to the extent that non-personal information is combined with personal information, we treat the combined information as personal information for the purposes of this Privacy Policy.

Ads that are delivered by Sunbelt’s advertising platform may appear in Sunbelt News and in the App Store. If you do not wish to receive ads targeted to your interests from Sunbelt's advertising platform, you can choose to enable Limit Ad Tracking, which will opt your Sunbelt ID out of receiving such ads regardless of what device you are using. If you enable Limit Ad Tracking on your mobile device, third-party apps cannot use the Advertising Identifier, a non-personal device identifier, to serve you targeted ads. You may still see ads in the App Store or News based on context like your search query or the channel you are reading. In third-party apps, you may see ads based on other information.

Sunbelt and our partners also use cookies and other technologies to remember personal information when you use our website, online services, and applications. Our goal in these cases is to make your experience with Sunbelt more convenient and personal. For example, knowing your first name lets us welcome you the next time you visit the Sunbelt Online Store. Knowing your country and language − and if you are an educator, your school − helps us provide a customized and more useful shopping experience. Knowing someone using your computer or device has shopped for a certain product or used a particular service helps us make our advertising and email communications more relevant to your interests. And knowing your contact information, hardware identifiers, and information about your computer or device helps us personalize your operating system, set up your iCloud service, and provide you with better customer service.

If you want to disable cookies and you’re using the Safari web browser, go to Safari preferences and then to the privacy pane to manage your preferences. On your Sunbelt mobile device, go to Settings, then Safari, scroll down to the Privacy & Security section, and tap on “Block Cookies” to manage your preferences. For other browsers, check with your provider to find out how to disable cookies. Please note that certain features of the Sunbelt website will not be available once cookies are disabled.

As is true of most internet services, we gather some information automatically and store it in log files. This information includes Internet Protocol (IP) addresses, browser type and language, Internet service provider (ISP), referring and exit websites and applications, operating system, date/time stamp, and clickstream data.

We use this information to understand and analyze trends, to administer the site, to learn about user behavior on the site, to improve our product and services, and to gather demographic information about our user base as a whole. Sunbelt may use this information in our marketing and advertising services.

In some of our email messages, we use a “click-through URL” linked to content on the Sunbelt website. When customers click one of these URLs, they pass through a separate web server before arriving at the destination page on our website. We track this click-through data to help us determine interest in particular topics and measure the effectiveness of our customer communications. If you prefer not to be tracked in this way, you should not click text or graphic links in the email messages.

Pixel tags enable us to send email messages in a format customer can read, and they tell us whether mail has been opened. We may use this information to reduce or eliminate messages sent to customers.
 

Disclosure to Third Parties

At times Sunbelt may make certain personal information available to strategic partners that work with Sunbelt to provide products and services, or that help Sunbelt market to customers. For example, when you purchase and activate your iPhone, you authorize Sunbelt and your carrier to exchange the information you provide during the activation process to carry out service. If you are approved for service, your account will be governed by Sunbelt and your carrier’s respective privacy policies. Personal information will only be shared by Sunbelt to provide or improve our products, services and advertising; it will not be shared with third parties for their marketing purposes.

Service Providers

Sunbelt shares personal information with companies who provide services such as information processing, extending credit, fulfilling customer orders, delivering products to you, managing and enhancing customer data, providing customer service, assessing your interest in our products and services, and conducting customer research or satisfaction surveys. These companies are obligated to protect your information and may be located wherever Sunbelt operates.

Others

It may be necessary − by law, legal process, litigation, and/or requests from public and governmental authorities within or outside your country of residence − for Sunbelt to disclose your personal information. We may also disclose information about you if we determine that for purposes of national security, law enforcement, or other issues of public importance, disclosure is necessary or appropriate.

We may also disclose information about you if we determine that disclosure is reasonably necessary to enforce our terms and conditions or protect our operations or users. Additionally, in the event of a reorganization, merger, or sale we may transfer any and all personal information we collect to the relevant third party.

Protection of Personal Information

Sunbelt takes the security of your personal information very seriously. Sunbelt online services such as the Sunbelt Online Store and iTunes Store protect your personal information during transit using encryption such as Transport Layer Security (TLS). When your personal data is stored by Sunbelt, we use computer systems with limited access housed in facilities using physical security measures. With the exception of iCloud Mail, iCloud data is stored in encrypted form including when we utilize third-party storage.

When you use some Sunbelt products, services, or applications or post on an Sunbelt forum, chat room, or social networking service, the personal information and content you share is visible to other users and can be read, collected, or used by them. You are responsible for the personal information you choose to share or submit in these instances. For example, if you list your name and email address in a forum posting, that information is public. Please take care when using these features.

If you or anyone else using Family Sharing logs on to a device that is owned by a third party, any information shared within your Family—including calendar, location, photos, and iTunes purchases—may be downloaded on to that third-party device thereby disclosing any such shared information. Visit Family Sharing for more information.

The existence of Automated Decision-Making, Including Profiling

Sunbelt does not take any decisions involving the use of algorithms or profiling that significantly affects you.

Integrity and Retention of Personal Information

Sunbelt makes it easy for you to keep your personal information accurate, complete, and up to date. We will retain your personal information for the period necessary to fulfill the purposes outlined in this Privacy Policy and our service specific privacy summaries. When assessing these periods, we carefully examine our need to collect personal information at all and if we establish a relevant need we only retain it for the shortest possible period to realize the purpose of collection unless a longer retention period is required by law.

Access to Personal Information
 

You can help ensure that your contact information and preferences are accurate, complete, and up to date by signing in to your Sunbelt ID account page. For other personal information we hold, we will provide you with access (including a copy) for any purpose including to request that we correct the data if it is inaccurate or delete the data if Sunbelt is not required to retain it by law or for legitimate business purposes. We may decline to process requests that are frivolous/vexatious, jeopardize the privacy of others, are extremely impractical, or for which access is not otherwise required by local law. We may also decline aspects of deletion or access requests if we believe doing so would undermine our legitimate use of data for anti-fraud and security purposes as described earlier. Online tools for the exercise of access, correction, or deletion requests are available on a regional basis by signing in to privacy.Sunbelt.com. Where the online tool is not currently available for access requests in your region, a request may be made directly to Sunbelt.com/legal/privacy/contact.

Location-Based Services
 

To provide location-based services on Sunbelt products, Sunbelt and our partners and licensees may collect, use, and share precise location data, including the real-time geographic location of your Sunbelt computer or device. Where available, location-based services may use GPS, Bluetooth, and your IP Address, along with crowd-sourced Wi-Fi hotspot and cell tower locations, and other technologies to determine your devices’ approximate location. Unless you provide consent, this location data is collected anonymously in a form that does not personally identify you and is used by Sunbelt and our partners and licensees to provide and improve location-based products and services. For example, your device may share its geographic location with application providers when you opt in to their location services.

Some location-based services offered by Sunbelt, such as the “Find My iPhone” feature, require your personal information for the feature to work.

Third‑Party Sites and Services

Sunbelt websites, products, applications, and services may contain links to third-party websites, products, and services. Our products and services may also use or offer products or services from third parties − for example, a third‑party iPhone app.

Information collected by third parties, which may include such things as location data or contact details, is governed by their privacy practices. We encourage you to learn about the privacy practices of those third parties.

If you purchase a subscription in a third-party app or within News, we create a Subscriber ID that is unique to you and the developer or publisher which we use to provide reports to the developer or publisher that include information about the subscription you purchased, and your country of residence. If you cancel all of your subscriptions with a particular developer or publisher, the Subscriber ID will reset after 180 days if you do not resubscribe. This information is provided to developers so that they can understand the performance of their subscriptions.

International Users

All the information you provide may be transferred or accessed by entities around the world as described in this Privacy Policy. Personal information, relating to Sunbelt services, regarding individuals who reside in a member state of the European Economic Area and Switzerland is controlled by Sunbelt Distribution International in Ireland, and processed on its behalf by Sunbelt Inc. Sunbelt uses approved Model Contractual Clauses for the international transfer of personal information collected in the European Economic Area and Switzerland. Sunbelt, as a global company, has a number of legal entities in different jurisdictions which are responsible for the personal information which they collect, and which is processed on their behalf by Sunbelt Inc. For example, point of sale information in our Retail entities outside the U.S. is controlled by our individual Retail entities in each country. Sunbelt, Online Store and iTunes related personal information may also be controlled by legal entities outside the U.S. as reflected in the terms of each service.

Sunbelt abides by the Asia-Pacific Economic Cooperation (APEC) Cross Border Privacy Rules System. The APEC CBPR system provides a framework for organizations to ensure protection of personal information transferred among participating APEC economies. To learn more about the APEC Certification and Dispute Resolution, please click on the TRUSTe seal.

Our Companywide Commitment to Your Privacy

To make sure your personal information is secure, we communicate our privacy and security guidelines to Sunbelt employees and strictly enforce privacy safeguards within the company.

Privacy Questions

If you have any questions or concerns about Sunbelt’s Privacy Policy or data processing, you would like to contact our European Data Protection Officer, or if you would like to make a complaint about a possible breach of local privacy laws, please contact us. You can always contact us by phone at the relevant Sunbelt Support number for your country or region.

When a privacy question or question about personal information received in response to an access/download request is received we have a dedicated team which triages the contacts and seeks to address the specific concern or query which you are seeking to raise. Where your issue may be more substantive in nature, more information may be sought from you. All such substantive contacts receive a response. If you are unsatisfied with the reply received, you may refer your complaint to the relevant regulator in your jurisdiction. If you ask us, we will endeavor to provide you with information about relevant complaint avenues which may be applicable to your circumstances.

Sunbelt may update its Privacy Policy from time to time. When we change the policy in a material way, a notice will be posted on our website along with the updated Privacy Policy.