Last Updated: December 4, 2023
NOTICE AT COLLECTION
- PERSONAL INFORMATION WE COLLECT
- HOW WE USE PERSONAL INFORMATION
- HOW WE DISCLOSE PERSONAL INFORMATION
- YOUR PRIVACY CHOICES AND RIGHTS
- INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION
- RETENTION OF PERSONAL INFORMATION
- SUPPLEMENTAL NOTICE FOR CALIFORNIA RESIDENTS
- SUPPLEMENTAL NOTICE FOR CERTAIN INTERNATIONAL COUNTRIES
- CHILDREN’S INFORMATION
- THIRD-PARTY WEBSITES/APPLICATIONS
- CONTACT US
PERSONAL INFORMATION WE COLLECT
The categories of personal information we collect depend on how you interact with us, our Services, and the requirements of Applicable Laws. We collect information that you provide to us, information we obtain automatically when you use our Services, and information from other sources such as third-party services and organizations, as described below.
- Information You Provide to Us Directly
We may collect the following personal information that you provide to us.
- Account Creation. When you create an account, we may collect information such as name, email address, password, and log-in/display name.
- Purchases. We may collect personal information and details associated with your purchases, including payment information. Any payments made via our Services are processed by third-party payment processors. We do not directly collect or store any payment card information entered through our Services, but it may receive information associated with your payment card information (e.g., your billing details).
- Your Communications with Us. We may collect personal information, such as name, email address, company name, phone number, mailing address, date of birth, gender, interests, product, operating system, order number, or details of your request when you ask for information about our Services, register for our newsletter or mailing list, request customer or technical support, apply for a job, or otherwise communicate with us.
- Surveys. We may contact you to participate in surveys. If you decide to participate, you may be asked to provide certain information which may include personal information. We may present this information to our advertisers and partners, in the form of grouped statistics compiled from our users’ answers to such questions.
- Interactive Features. We and others who use our Services may collect personal information that you submit or make available through our interactive features (e.g., messaging and chat features, commenting functionalities, forums, blogs, and social media pages). Any information you provide using the public sharing features of the Services (referred to herein as “User Content”) will be considered “public,” unless otherwise required by Applicable Laws, and is not subject to the privacy protections referenced herein. Please exercise caution before revealing any information that may identify you in the real world to other users.
- Sweepstakes or Contests. We may collect personal information you provide for any sweepstakes or contests that we offer. In some jurisdictions, we are required to publicly share information of sweepstakes and contest winners.
- Conferences, Trade Shows, and Other Events. We may collect personal information from individuals when we attend conferences, trade shows, and other events.
- Business Development and Strategic Partnerships. We may collect personal information from individuals and third parties to assess and pursue potential business opportunities.
- Job Applications. We may post job openings and opportunities on our Services. If you reply to one of these postings by submitting your application, CV and/or cover letter to us, we will collect and use your information to assess your qualifications.
- Information Collected Automatically
We may collect personal information automatically when you use our Services:
- Automatic Data Collection. We may collect certain information automatically when you use our Services, such as your Internet protocol (IP) address, port number, user settings, MAC address, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, browser, software or device information, and Internet service provider. We may also automatically collect information regarding your use of our Services, such as pages that you visit before, during and after using our Services, information about the links you click, the types of content you interact with, the frequency and duration of your activities, and other information about how you use our Services. In addition, we may collect information that other people provide about you when they use our Services, including information about you when they tag you.
- Location Information. We may collect your precise location information to provide you with enhanced Services.
- BitTorrent Speed Application: BitTorrent Speed is a BitTorrent feature that aims to increase the download speed and efficiency of torrent swarms (i.e., a group of people, which may include you, that own a particular file (or pieces of the file)). For more information about BitTorrent Speed, please click here. By using BitTorrent Speed, we will collect information to operate and improve BitTorrent Speed, including a wallet address (i.e., a public key associated with your wallet) and a private ledger that contains, BTT balance, payments used in the wallet, and timestamps when activity channel is opened and closed.
- uTorrent Lite Application: uTorrent Lite is an app-less torrenting Client that works seamlessly on your browser, allowing you to fetch, assemble and view the immediate next set of torrent file blocks from peers. uTorrent Lite reaches other peers while downloading content, therefore user IP address is exposed to other users. However, uTorrent Lite does not collect or store user IP information. µTorrent Lite will use your browser’s memory to temporarily store torrent file blocks so as to reduce buffering while streaming content. uTorrent Lite also uses Google Analytics to collect product engagement data.
- Cookies. Cookies are small text files placed in device browsers that store preferences and facilitate and enhance your experience. In addition, advertisements displayed on the Sites or in the Software may contain cookies.
- Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded in our Services that collects information about engagement on our Services. The use of a pixel tag allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded.
Our uses of these Technologies fall into the following general categories:
- Operationally Necessary. This includes Technologies that allow you access to our Services, applications, and tools that are required to identify irregular website behavior, prevent fraudulent activity and improve security or that allow you to make use of our functionality;
- Performance-Related. We may use Technologies to assess the performance of our Services, including as part of our analytic practices to help us understand how individuals use our Services (see Analytics below);
- Functionality-Related. We may use Technologies that allow us to offer you enhanced functionality when accessing or using our Services. This may include identifying you when you sign into our Services or keeping track of your specified preferences, interests, or past items viewed;
- Advertising- or Targeting-Related. We may use first party or third-party Technologies to deliver content, including ads relevant to your interests, on our Services or on third-party websites.
See “Your Privacy Choices and Rights” below to understand your choices regarding these Technologies.
- Analytics. We may use Technologies and other third-party tools to process analytics information on our Services. Some of our analytics partners include:
- Information Collected from Other Sources
We may obtain information about you from other sources, including through third-party services and organizations. For example, if you access our Services through a third-party application, such as an app store, a third-party login service, or a social networking site, we may collect basic account information about you from that third-party application or social media provider (such as your name, address, phone number and e-mail address, and other demographic information, like your date of birth, gender, age and interests) that you have made available via your privacy settings.
HOW WE USE PERSONAL INFORMATION
Subject to Applicable Laws, we use personal information for a variety of business purposes, including to provide our Services, for administrative purposes, and to market our products and Services, as described below.
- Provide Our Services
We use personal information to fulfill our contract with you and provide you with our Services, such as:
- Managing your information and accounts;
- Providing access to certain areas, functionalities, and features of our Services;
- Answering requests for customer or technical support;
- Communicating with you about your account, activities on our Services, and policy changes;
- Processing your financial information and other payment methods for products or Services purchased;
- Processing applications if you apply for a job we post on our Services; and
- Allowing you to register for events.
- Administrative Purposes
We use personal information for various administrative purposes, such as:
- Pursuing our legitimate interests such as direct marketing, research and development (including marketing research), network and information security, and fraud prevention;
- Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity;
- Measuring interest and engagement in our Services;
- Short-term, transient use, such as contextual customization of ads;
- Improving, upgrading or enhancing our Services;
- Developing new products and Services;
- Ensuring internal quality control and safety;
- Authenticating and verifying individual identities, including requests to exercise your rights under this policy;
- Debugging to identify and repair errors with our Services;
- Auditing relating to interactions, transactions and other compliance activities;
- Sharing information with third parties as needed to provide the Services;
- Enforcing our agreements and policies;
- Complying with our legal obligations; and
- To provide anonymous reporting for internal and external clients.
- Marketing and Advertising our Products and Services
We may use personal information to tailor and provide you with content and advertisements. We may provide you with these materials as permitted by Applicable Laws.
Some of the ways we market to you may include email campaigns, custom audiences advertising , and “interest-based” or “personalized advertising,” including through cross-device tracking.
If you have any questions about our marketing practices or if you would like to opt out of the use of your personal information for marketing purposes, you may contact us at any time as set forth in “Contact Us” below.
- Other Purposes
We also use your information for other purposes as requested by you or as permitted by Applicable Laws.
- Consent. We may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information or with your consent.
- Automated Decision Making. We may engage in automated decision making, including profiling. BitTorrent’s processing of your personal information will not result in a decision based solely on automated processing that significantly affects you unless such a decision is necessary as part of a contract we have with you, we have your consent, or we are permitted by law to engage in such automated decision making. If you have questions about our automated decision making, you may contact us as set forth in “Contact Us” below.
- Manage Downloads. The BitTorrent Client is a software application on your machine that manages downloads. The BitTorrent Client downloads files quickly by trading pieces with other users who are also downloading (or have downloaded) the same content. Your use of the BitTorrent Client to download files will, in turn, enable other BitTorrent Client users (or users of other clients that communicate using the BitTorrent Client protocol, including clients that are unaffiliated with BitTorrent) to download pieces of those files from you. Although your IP address is associated with your piece of the file, other users will not have access to any other personal information about you.
We do not track which files you transfer with the BitTorrent Client. Merely using the BitTorrent Client does not cause a record of which files you transfer to be kept by BitTorrent or BitTorrent on behalf of any third party.
- De-identified and Aggregated Information. We may use personal information and other information about you to create de-identified and/or aggregated information, such as de-identified demographic information, de-identified location information, information about the device from which you access our Services, or other reports and analyses we create. If we create or receive de-identified information, we will not attempt to reidentify such information, unless required to comply with Applicable Laws or unless we are otherwise permitted to do so by Applicable Laws.
- Share Content with Friends or Colleagues. Our Services may offer various tools and functionalities. For example, we may allow you to provide information about your friends through our referral services. Our referral services may allow you to forward or share certain content with a friend or colleague, such as an email inviting your friend to use our Services. Please only share with us contact information of people with whom you have a relationship (e.g., relative, friend neighbor, or co-worker).
HOW WE DISCLOSE PERSONAL INFORMATION
We disclose personal information to third parties for a variety of business purposes, including to provide our Services, to protect us or others, or in the event of a major business transaction such as a merger, sale, or asset transfer, as described below.
- Disclosures to Provide our Services
The categories of third parties with whom we may share your information are described below.
- Service Providers. We may share your personal information with our third-party service providers who use that information to help us provide our Services. This includes service providers that provide us with IT support, hosting, payment processing, customer service, and related services.
- Business Partners. We may share your personal information with business partners to provide you with a product or service you have requested. We may also share your personal information to business partners with whom we jointly offer products or services.
- Affiliates. We may share your personal information with our company affiliates.
- Other Users/Website Visitors. As described above in “Personal Information We Collect,” our Services allow you to share your profile and/or User Content with other Users/publicly, including to those who do not use our Services.
- Advertising Partners. We may share your personal information with third-party advertising partners. These third-party advertising partners may set Technologies and other tracking tools on our Services to collect information regarding your activities and your device (e.g., your IP address, cookie identifiers, page(s) visited, location, time of day). These advertising partners may use this information (and similar information collected from other services) for purposes of delivering personalized advertisements to you when you visit digital properties within their networks. This practice is commonly referred to as “interest-based advertising” or “personalized advertising.”
- APIs/SDKs. We may use third-party Application Program Interfaces (“APIs”) and Software Development Kits (“SDKs”) as part of the functionality of our Services. For more information about our use of APIs and SDKs, please contact us as set forth in “Contact Us” below.
- Disclosures to Protect Us or Others
We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our, or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.
- Disclosure in the Event of Merger, Sale, or Other Asset Transfers
If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract.
YOUR PRIVACY CHOICES AND RIGHTS
Your Privacy Choices. The privacy choices you may have about your personal information are determined by Applicable Laws and are described below.
- Text Messages. You may opt out of receiving text messages from us by following the instructions in the text message you have received from us or by otherwise contacting us.
- Mobile Devices. We may send you push notifications through our mobile application. You may opt out from receiving these push notifications by changing the settings on your mobile device. With your consent, we may also collect precise location-based information via our mobile application. You may opt out of this collection by changing the settings on your mobile device.
- “Do Not Track.” Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
- Cookies and Personalized Advertising. You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. However, if you adjust your preferences, our Services may not work properly.
Please note that cookie-based opt-outs are not effective on mobile applications. However, you may opt-out of personalized advertisements on some mobile applications by following the instructions for Android, iOS and others.
The online advertising industry also provides websites from which you may opt out of receiving targeted ads from organizations that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy by visiting the Network Advertising Initiative, the Digital Advertising Alliance, the European Digital Advertising Alliance, and the Digital Advertising Alliance of Canada.
Please note you must separately opt out in each browser and on each device.
Your Privacy Rights. In accordance with Applicable Laws, you may have the right to:
- Confirm Whether We Are Processing Your Personal Information (the right to know);
- Request Access to and Portability of Personal Information about you, including: (i) obtaining access to or a copy of your personal information; and (ii) receiving an electronic copy of personal information that you have provided to us, or asking us to send that information to another company in a structured, commonly used, and machine-readable format (the “right of data portability”);
- Request Correction of your personal information where it is inaccurate or incomplete;
- Request Deletion of your personal information;
- Request to Opt-Out of Certain Processing Activities including, as applicable, if we process your personal information for “targeted advertising” (as “targeted advertising” is defined by applicable privacy laws), if we “sell” your personal information (as “sell” is defined by applicable privacy laws), or if we engage in “profiling” in furtherance of certain “decisions that produce legal or similarly significant effects” concerning you (as such terms are defined by applicable privacy laws);
- Request Restriction of or Object to our processing of your personal information; and
- Withdraw your Consent to our processing of your personal information.
If you would like to exercise any of these rights, you may log in and adjust your details via the user account section where applicable. If this does not resolve your request or you would prefer, please contact us as set forth in “Contact Us” below. We will process such requests in accordance with Applicable Laws.
To protect your privacy, we will take steps to reasonably verify your identity before fulfilling requests submitted under applicable privacy laws. These steps may involve asking you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative. Examples of our verification process may include asking you to confirm the email address we have associated with you.
Only you, or someone legally authorized to act on your behalf in certain jurisdictions, may make a request to exercise the rights listed above regarding your personal information. If your personal information is subject to a law that allows an authorized agent to act on your behalf in exercising your privacy rights and you wish to designate an authorized agent, please provide written authorization signed by you and your designated agent using the information found in “Contact Us” below and ask us for additional instructions.
Some laws may allow you to appeal our decision if we decline to process your request. If Applicable Laws grant you an appeal right and you would like to appeal our decision with respect to your request, you may do so by informing us of this and providing us with information supporting your appeal.
If your personal information is subject to the applicable data protection laws of Brazil, the British Virgin Islands, the European Economic Area, Switzerland, or the United Kingdom, you have the right to lodge a complaint with the competent supervisory authority if you believe our processing of your personal information violates Applicable Laws.
- Autoridade Nacionalde Proteçãode Dados (ANPD)
- EEA Data Protection Authorities (DPAs)
- Swiss Federal Data Protection and Information Commissioner (FDPIC)
- UK Information Commissioner’s Office (ICO)
INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION
All personal information processed by us may be transferred, processed, and stored anywhere in the world, including, but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live.
If we transfer personal information which originates in the European Economic Area, Switzerland, and/or the United Kingdom to a country that has not been found to provide an adequate level of protection under applicable data protection laws, one of the safeguards we may use to support such transfer is the EU Standard Contractual Clauses.
For more information about the safeguards we use for international transfers of your personal information, please contact us as set forth below.
RETENTION OF PERSONAL INFORMATION
To determine the appropriate retention period for personal information, we may consider applicable legal requirements, the amount, nature, and sensitivity of the personal information, certain risk factors, the purposes for which we process your personal information, and whether we can achieve those purposes through other means.
SUPPLEMENTAL NOTICE FOR CALIFORNIA RESIDENTS
|Category of Personal Information Collected by BitTorrent
|Category of Third Parties to Whom Personal Information is Disclosed for a Business Purpose
|Category of Third Parties to Whom Personal Information is Sold and/or Shared
A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.
|Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
A name, signature, address, telephone number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
|Protected classification characteristics under California or federal law
Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
Records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
|Internet or other electronic network activity
Browsing history, search history, information on a consumer’s interaction with an internet website, application, or advertisement.
Audio, electronic, visual, thermal, olfactory, or similar information.
|Professional or employment-related information
Current or past job history or performance evaluations.
|Inferences drawn from other personal information to create a profile about a consumer
Profile reflecting a consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
|Personal information that reveals a consumer’s social security, driver’s license, state identification card, or passport number
|Personal information that reveals a consumer’s account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account
|Personal information that reveals a consumer’s racial or ethnic origin, religious or philosophical beliefs, or union membership
|Personal information that reveals the contents of a consumer’s mail, email, and text messages unless BitTorrent is the intended recipient of the communication
The categories of sources from which we collect personal information and our business and commercial purposes for using and disclosing personal information are set forth in “Personal Information We Collect,” “How We Use Personal Information,” and “How We Disclose Personal Information” above, respectively. We will retain personal information in accordance with the time periods set forth in “Retention of Personal Information.”
We “sell” and “share” your personal information to provide you with “cross-context behavioral advertising” about BitTorrent’s products and services.
Additional Disclosures for California Residents
Opting Out of “Sales” of Personal Information and/or “Sharing” for Cross-Context Behavioral Advertising under the CCPA. California residents have the right to opt out of the “sale” of personal information and the “sharing” of personal information for “cross-context behavioral advertising.” California residents may exercise these rights by accessing the “Do Not Share or Sell My Personal Information” prompt and selecting the manner in which their information is shared.
Disclosure Regarding Individuals Under the Age of 16. BitTorrent does not have actual knowledge of any “sale” of personal information of minors under 16 years of age. BitTorrent does not have actual knowledge of any “sharing” of personal information of minors under 16 years of age for “cross-context behavioral advertising.”
Disclosure Regarding Sensitive Personal Information. BiTorrent only uses and discloses sensitive personal information for the following purposes:
- To perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services.
- To prevent, detect, and investigate security incidents that compromise the availability, authenticity, integrity, and or confidentiality of stored or transmitted personal information.
- To resist malicious, deceptive, fraudulent, or illegal actions directed at BitTorrent and to prosecute those responsible for those actions.
- To ensure the physical safety of natural persons.
- For short-term, transient use, including, but not limited to, non personalized advertising shown as part of a consumer’s current interaction with BitTorrent, provided that the personal information is not disclosed to another third party and is not used to build a profile about the consumer or otherwise alter the consumer’s experience outside the current interaction with BitTorrent.
- To verify or maintain the quality or safety of a product, service, or device that is owned, manufactured, manufactured for, or controlled by BitTorrent, and to improve, upgrade, or enhance the service or device that is owned, manufactured by, manufactured for, or controlled by BitTorrent.
- For purposes that do not infer characteristics about individuals.
Non-Discrimination. California residents have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by the CCPA.
Right for minors to remove posted content. Where required by law, California residents under the age of 18 may request to have their posted content or information removed from the publicly-viewable portions of the Services by contacting us directly as set forth in Contact Us below.
SUPPLEMENTAL NOTICE FOR CERTAIN INTERNATIONAL COUNTRIES
- Supplemental Notice for Russia
This Supplemental Notice for Russia only applies to our processing of personal information that is subject to the applicable data protection laws of Russia.
- International Transfers. When transferring personal information which originates in Russia internationally, we will comply with the applicable requirements governing processing of such personal information.
The Services are not directed to children under 16 (or other age as required by local law outside the United States), and we do not knowingly collect personal information from children.
If you are a parent or guardian and believe your child has uploaded personal information to our site without your consent, you may contact us as described in Contact Us below. If we become aware that a child has provided us with personal information in violation of Applicable Laws, we will delete any personal information we have collected, unless we have a legal obligation to keep it, and terminate the child’s account, if applicable.
The Services may contain links to other websites/applications and other websites/applications may reference or link to our Services. These third-party services are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen or approve, and are not responsible for the privacy practices or content of such other websites or applications. Providing personal information to third-party websites or applications is at your own risk.
Geneva Place, Waterfront Drive
P.O. Box 3469
Road Town, Tortola
British Virgin Islands