This Privacy Policy (the “Policy”) explains how we (“we” or “our”) collect, use and share information about you (“user”, “you” or “your”) when you use our applications, websites and all content related to services and products (the “Services”). All references to “Applications” in this Policy refer to our applications, which are available for download on mobile devices from time to time.

1. Our Values and the Purpose of This Policy: We value your privacy and want to be responsible, fair and transparent with you about how we collect and use your personal information. We also want you to understand your rights in relation to your information, which you can find here.

2. Who this Policy Applies to: This Policy applies to users of our applications and those who contact our customer support functions.

3. What this Policy Covers: This Privacy Policy describes the following important topics related to your information:

1). Collection of your personal information and how we use it:

2). The legal basis for our use of your personal information;

3). How and why we share your personal information with others;

4). How long we store your personal information;

5). Your rights;

6). Children;

7). Where we may transfer your personal information;

8). Risks and how we protect the security of your personal information;

9). Changes to this Privacy Policy;

10). Other questions and how to make a complaint.

4. Your right to object: You have various rights regarding our use of your personal information. Two basic rights to note are:

1). You can ask us to stop using your personal information for direct marketing purposes. If you exercise this right, we will stop using your personal information for this purpose.

2). You can ask us to consider any valid objections you have to our use of your personal information when we process your personal information based on our or others' legitimate interests.

5. What you need to do and what you confirm to us: Please read this Privacy Policy carefully to understand how we process your personal information. By interacting with us in the manner set out in this Privacy Policy, including downloading and using any of our Apps, you confirm that you have read and understood this Privacy Policy in its entirety as it applies to you.

Details – Key Information You Should Know

Collection of Your Personal Information and How We Use It

5.1). What Personal Information We Collect About You

a) Our Apps collect the following information about you (which we use as described below):

b) If you agree to receive personalized ads, we collect data about your approximate location and device advertising identifier (IDFA);

c) If you participate in any chat activity on our Apps, we collect your handle and any data you share in messages you post in that chat;

d) If you choose to use Google Connect, and subject to your Google privacy settings, we collect your basic Google profile information.

e) If you contact our customer support features, we collect your email address (and any other information you include in your correspondence with us), including any updates to any such information.

5.2) How we use your personal information

We will collect, use and store the personal information listed above for the following reasons:

a) To help us manage advertising and provide you with advertising and marketing that is relevant to you through our apps, from us and our third-party partners, as described in the "Third-Party Advertising" section below;

b) To record your preferences for advertising and marketing communications;

c) To receive and respond to customer support queries you send us.

5.3) Other uses of your personal information

We also collect, use and store your personal information for the following other reasons:

a) To process any queries or questions you have about how we collect, store and use your personal information, or any requests you may have for a copy of the information we hold about you. We may process your personal information for these purposes even if we do not have a contract with you, as long as it is in our legitimate interests to serve our customers.

5.4). Service Purposes;

(a) For internal company reporting, business management, ensuring adequate insurance coverage for our business, ensuring the security of our company facilities, research and development, and identifying and implementing business efficiencies. We may process your personal information for these purposes where it is in our legitimate interests;

(b) Comply with any proceedings, laws and regulations applicable to us - this may include where we reasonably believe that compliance is in our or others' legitimate interests, and where we are required by law to do so; and

(c) Establish, exercise or defend our legal rights - this may include where we reasonably believe that compliance is in our or others' legitimate interests, and where we are required by law to do so.

6. Legal Basis for Using Your Personal Information

We consider the legal basis for using your personal information set out in this Privacy Policy to be the following:

6.1) Our use of your personal information is necessary to perform our obligations under any contract we have with you (for example, to comply with the Terms of Service for our App);

6.2) You have provided us with your consent. This applies to advertising and marketing materials provided through our App that are tailored to you and your preferences. You can control and withdraw your consent at any time on our App.

6.3) If (6.1) or (6.2) does not apply, our use of your personal information is necessary for our legitimate interests or the legitimate interests of others. Our legitimate interests include:

6.4) operating, developing and growing our business (and the businesses of our group companies), including through the use of advertising revenue to fund our business;

6.5) operating, maintaining and improving our Apps and our marketing optimization efforts;

7. How and why we share your personal information with others

Third-party advertising

7.1). We want to ensure that our advertising and marketing are relevant and interesting to you and our other customers. To do this, we use third-party advertising and technology companies to serve ads and/or provide aggregated data to assist in serving ads when you visit or use our Apps. This includes third-party technology companies that collect your data in order to build a profile of your preferences based on your activities when you visit or use our Apps. We also use these companies to collect your data automatically when you use our Apps to help us identify ads to serve to you and your behavior after seeing those ads.

7.2). Third-party advertising companies collect, store and use data by integrating cookies and other tracking software on our Apps. The relevant data collected by these third parties includes:

a) Data about your device, location, and use of our applications, including IP address, unique device ID, geolocation details, and the user ID we assign to you;

b) Data you provide to us when using our applications, including information about your interactions with advertisements and certain technical information.

7.3). Third-party advertising companies will collect and use your data to provide you with targeted advertisements relevant to you and your preferences with your consent. You can control and withdraw your consent for such targeted advertisements on our applications at any time. If you do not provide or withdraw consent to receive targeted advertisements relevant to you and your preferences, we will still provide you with advertisements when you visit or use our applications, but these advertisements will no longer be customized to you or your preferences.

7.4). We may also share your data with social media or other similar platforms and our advertising partners so that you and others can see relevant advertisements on that platform.

7.5). We may share your personal information with our group companies where it is in our legitimate interests to do so:

a) to enable them to provide you with customer support;

b) for internal administrative and management purposes.

8. We will also disclose your personal information to third parties:

8.1) . When it is in our legitimate interests to operate, develop and grow our business:

8.2). If we or any of our group companies sell or buy any business or assets (or plan to do so), or if we or any of our group companies are acquired or may be acquired, we or our group companies may disclose your personal information to the prospective seller or buyer of such business or assets and their legal, financial and other professional advisers, and that personal information may be one of the transferred assets;

8.3) . If we are under an obligation to disclose or share your personal information to comply with any legal obligation, any lawful request of a government or law enforcement official, and to meet national security or law enforcement requirements or to prevent illegal activities;

8.4) . To establish, exercise, enforce or defend our Terms of Service or any other agreement or respond to any claims, protect our rights or the rights of a third party, protect the safety of any person or prevent any illegal activity;

9. We may also disclose and use anonymous, aggregated reports and statistics about users of our applications for internal reporting or reporting to our group or other third parties. None of these anonymous, aggregated reports or statistics will personally identify our users.

10. Except as expressly detailed above, we will never share, sell or rent any of your personal information to any third party without notifying you and, where necessary, obtaining your consent. If you have given us your consent to use your personal information in a particular way but later change your mind, you should contact us and we will stop doing so.

10.1). How long we store your personal information

We will not keep your personal information for longer than is necessary for the purposes for which the personal information is processed. How long we keep personal information depends on the purposes for which we collected and use the personal information and/or as required to comply with applicable law and to establish, exercise or defend our legal rights.

10.2). Your rights

a). You have certain rights in relation to your personal information. If you would like to know more about these rights or would like to exercise any of them, please feel free to contact us by email at secureproxy.tool@gmail.com. You have the following rights:

b) Right of access. You have the right to access any personal information we hold about you.

c) Right to update your information. You have the right to request an update to any personal information that we are unable to update.

d) Right to delete information. In certain specific circumstances, you have the right to ask us to delete any personal information we hold about you.

e) Right to restrict the use of your information. In certain specific circumstances, you have the right to ask us to restrict the way we process your personal information.

f) Right to data portability. You have the right to ask us to provide your personal information to a third-party service provider.

This right only applies where we use your personal information based on your consent or in performance of a contract; and where our use of your information is carried out by automated means.

g) Right to object. You have the right to ask us to consider any valid objection you have to our use of your personal information when we process your personal information based on our or others’ legitimate interests.

10.3). We will consider all such requests and provide a response within a reasonable period (in any case within one month of your request, unless we tell you that we are entitled to a longer period under applicable law). Please note, however, that certain personal information may not be subject to such requests in certain circumstances. If there are exceptions, we will inform you when responding to your request. We may ask you to provide us with information necessary to confirm your identity before responding to any of your requests.

10.4). Children

a). You must be at least 16 years old to purchase products or services from us. Our website and services are not directed to children under 16 years old and we do not knowingly collect any personal information from children under 16 years old.

b). If you are under 16 years old and we learn that we have inadvertently obtained your personal information from our website or any other source, we will delete that information as soon as possible.

c). If you become aware that we may have inadvertently collected personal information from a child under 16 years old, please contact us at secureproxy.tool@gmail.com.

10.5). Where we may transfer your personal information

a). Your personal information will be used, stored and/or accessed by staff working for us, other members of our group or suppliers outside the EEA. More details on who your personal information may be disclosed to.

b). When we provide any of your personal information to any such non-EEA member of our group or suppliers, we will take appropriate steps to ensure that the recipient adequately protects your personal information

c). More details on the measures we take to protect your personal information in these circumstances.

10.6). Risks and how we protect your personal information

a). The main risk of our processing of your personal information is loss, theft or misuse. This could result in your personal information falling into the hands of others who could use it to commit fraud or disclose information you wish to keep confidential.

b). We are committed to protecting your personal information from loss, theft and misuse. We take reasonable precautions to protect the confidentiality of your personal information, including through the use of appropriate organizational and technical measures. We use industry standard practices such as encryption, firewalls and password protection systems to protect the confidentiality of any personal information we may collect from you.

c). Although we make every effort to protect the personal information you provide to us, the transmission of information via the internet is not completely secure. Therefore, you acknowledge and accept that we cannot guarantee the security of your personal information transmitted to our Application or customer service features, and that any such transmission is at your own risk. Once we have received your personal information, we will use strict procedures and security features to prevent unauthorized access.

11. Changes to Privacy Policy

We may update our Privacy Policy from time to time. Any changes we make to the Privacy Policy in the future will be made available to you through the Privacy Policy, which you can access in our Application. Please check back frequently to review any updates or changes to our Privacy Policy.

12. Other Questions and Complaints

12.1). If you have any questions or complaints about our collection, use or storage of your personal information, or if you wish to exercise any of your rights in relation to your personal information, please contact secureproxy.tool@gmail.com. We will investigate and attempt to resolve any such complaints or disputes regarding the use or disclosure of your personal information.

Last updated: June 5, 2024