To enhance the functioning of your devices and improve your experience online, we collect your data to provide you with the best tools. We do not take your trust for granted so we’ve developed a Privacy Policy that covers how we collect, use, disclose, transfer, and store your personal data.
This Privacy Policy was last updated in Jan 2023.
This Privacy Policy describes how we handle and protect your personal data and the choices available to you regarding collection, process, access, and how to update, correct and delete your personal data. Additional information on our personal data practices may be provided in product settings, contractual terms, or notices provided prior to or at the time of data collection.
Please refer to our Products Policy describing specifics of personal data processing within our products and services available on the brand’s website.
This Privacy Policy is intended for you if you are a user of our products and services.
Personal data refers to any information relating to an identified or identifiable natural person (“Personal Data”).
We may collect data or ask you to provide certain data when you visit and use our websites, products and services. The sources from which we collect Personal Data include:
We do not process special categories of personal data or deduce in any way this type of information from data we collect within our products.
We organize the Personal Data we process into these basic categories: Account Data, and Product Data.
Product Data includes two sub-categories:
These sub-categories differ for each product and service. If you want more detail about Device and Service Data we process on a product basis, please refer to our Products Policy available on our brand’s website.
We use your Personal Data for the following purposes and on the following grounds：
On the basis of fulfilling our contract with you or entering into a contract with you on your request, in order to:
Process your purchase transactions;
Update you on the status of your orders and licences;
Manage your subscriptions and user accounts; and
Provide you with technical and customer support.
On the basis of your consent, in order to:
We will always ask for your consent before any processing that requires it and provide you with necessary information through our Consent Policy or otherwise as applicable.
On the basis of legal obligations, we process your Personal Data when it is necessary for compliance with a legal tax, accounting, anti-money laundering, legal order, sanction checks or other obligation to which we are subject.
On the basis of our legitimate interest we will use your Personal Data to:
For the above mentioned processing operations, we have balanced your interests against our interests. In any case, you have the right to object, on grounds relating to our particular situation, to those processing operations.
Before relying on our legitimate interests, we balanced them against your interests and made sure they are compelling enough and will not cause any unwarranted harm. With respect to the purposes below we consider necessary to explain what our interests are in detail.
Systems, Apps and Network Security
We process Personal Data for network and information security purposes. In line with EU data protection law, organizations have a recognized legitimate interest in collecting and processing Personal Data to the extent strictly necessary and proportionate for the purposes of ensuring network and information security. This primarily covers the ability of a network or of an information system to resist events, attacks or unlawful or malicious actions that could compromise the availability, authenticity, integrity and confidentiality of stored or transmitted data, or the security of the related services offered by, or accessible via those networks and systems.
Both as an organization in our own right, and as a provider of information and communication technologies and services, it is necessary for the functionality of our systems, products and services and in our legitimate interests as well as in our users’, to collect and process Personal Data to the extent strictly necessary and proportionate for the purposes of ensuring the security of our own, and of our users’ networks, devices, and information systems.
The Personal Data we process for said purposes includes:
Depending on the context in which such data is collected, it may contain Personal Data concerning you. However, in such cases, we will process the data concerned only to the extent strictly necessary and proportionate to the purposes of securing your network, device and systems.
We have a legitimate interest for messaging our users about possible security, privacy and performance improvements and products that supplement or improve purchased products.
If you are our customer, we feel a responsibility to inform you about security and utility improvements and possible problems to your device and software that go beyond our product that is installed and provide you with effective solutions relevant to these problems. We thus have legitimate interest to optimize the content and delivery of this type of communication to you so that you will be most likely to find them relevant and non-intrusive at the same time.
We have a legitimate interest to use necessary Personal Data to understand user conversions, acquisitions and campaign performance through various distribution channels, and users’ download, activation and interactions with our products because these analytics help us improve functionality, effectiveness, security and reliability of our products and business activities and develop new products. This processing includes using third-party tools. Please refer to our Products Policy for the list of third-party tools used for the specific products and services.
We do our best to disconnect or remove all direct identifiers from the Personal Data that we use:
Our third-party payment partner will collect your IP address for its billing process; we do not store the IP address from this process.
For free and paid products, your IP address is also processed for the purpose of downloading certain products, product authorization, and preventing fraud.
Please refer to our Products Policy for specific use of IP address by our products and services.
We do not take any decisions solely based on algorithms, including profiling, that would significantly affect you.
We only disclose your Personal Data as described below, within our group, with our partners, with service providers that process data on our behalf and with public authorities, as required by applicable law. Processing is only undertaken for the purposes described in this Privacy Policy and the relevant Products Policy sections. If we disclose your Personal Data, we require its recipients to comply with adequate privacy and confidentiality requirements, and security standards.
We may use contractors and service providers to process your Personal Data for the purposes described in this Privacy Policy and Products Policy. We contractually require service providers to keep data secure and confidential.
Such service providers may include in particular contact centers, professional consultants (including for defence or exercise of our rights), and marketing/survey/analytics/software suppliers.
Sometimes these service providers, for example, our distributors, resellers, and app store partners, will be independent controllers of your data and their terms and conditions, end user license agreements (“EULA”) and privacy statements will apply to such relationships.
To be able to offer our products and services for free, we serve third-party ads of advertising companies in our products for mobile devices. To enable the ad, we embed a software development kit (“SDK”) provided by an advertising company into the product, which then collects Personal Data in order to personalize ads for you.
Please note that only a few of our free products serve third-party ads. You will be asked for consent during the installation process of such a product. For further information, including the exact scope of processed Personal Data and names of relevant products, please refer to our Consent Policy which includes the list of our advertising partners and their privacy policy.
Our websites use cookies to personalize your experience on our sites, tell us which parts of our websites people have visited, help us measure the effectiveness of campaigns, and give us insights into user interactions and user base as a whole so we can improve our communications and products.. While using our websites, you will be asked to authorize the collection and use of data by cookies according to the terms of the Cookie Policy.
In certain instances, it may be necessary for us to disclose your Personal Data to public authorities or as otherwise required by applicable law. No Personal Data will be disclosed to any public authority except in response to:
Like any other company, we too go through its own cycle of growth, expansion, streamlining and optimization. Its business decisions and market developments therefore affect its structure. As a result of such transactions, and for maintaining a continued relationship with you, we may transfer your Personal Data to a related affiliate.
If we are involved in a reorganization, merger, acquisition or sale of our assets, your Personal Data may be transferred as part of that transaction. We will notify you of any such deal and outline your choices in that event, when applicable.
We maintain administrative, technical, and physical safeguards for the protection of your Personal Data.
Access to the Personal Data of our users is limited to authorized personnel who have a legitimate need to know based on their job descriptions, for example, employees who provide technical support to end users, or who service user accounts. In the case of third-party contractors who process personal information on our behalf, similar requirements are imposed. These third parties are contractually bound by confidentiality clauses, even when they leave. Where an individual employee no longer requires access, that individual's credentials are revoked.
We strive to collect no more Personal Data from you than is required by the purpose for which we collect it. This, in turn, helps reduce the total risk of harm should data loss or a breach in security occur: the less data we collect, the smaller the overall risk.
We will hold your Personal Data on our systems for the following periods:
The data we collect from you may be stored, with risk-appropriate technical and organizational security measures applied to it, on in-house as well as third-party servers in the Czech Republic, in the United States, as well as anywhere we or our trusted service providers and partners operate.
In all cases, we follow generally accepted standards and security measures to protect the personal data submitted to us, both during transmission and once we receive it.
You have the following rights regarding the processing of your Personal Data:
The fulfillment of data subject rights listed above will depend on the category of Personal Data and the processing activity. In all cases, we strive to fulfill your request.
We will action your request within one month of receiving a request from you concerning any one of your rights as a Data Subject. Should we be inundated with requests or particularly complicated requests, the time limit may be extended to a maximum of another two months. If we fail to meet these deadlines, we would, of course, prefer that you contact us to resolve the situation informally.
Where requests we receive are manifestly unfounded or excessive, in particular because of their repetitive character, we may either: (a) charge a reasonable fee taking into account the administrative costs of providing the information or communication or taking the action requested; or (b) refuse to act on the request.
For the free versions, we do not and will not maintain, acquire or process additional information solely in order to identify the users of our free products and services. This is simply not necessary for the free versions of our products to be provided to you and function.
This means, when you use a free version of our products and services, you may contact us with a request concerning your Personal Data. Please note, consistent with our privacy by design, privacy by default and minimization practices, we may not be able to identify you in connection with your Product Data about your specific free products and services. If such a situation occurs, please go to your product settings and explore your options.
You can make certain choices about how your data is used by us by adjusting the privacy settings of the relevant product. Please check your product settings to set your privacy preferences there.
We collect and process Personal Data on the territory of the Russian Federation in strict compliance with the applicable laws of the Russian Federation.
We collect and process Personal Data (including sharing it with third parties) only upon the consent of the respective individuals, unless otherwise is provided for by the laws of the Russian Federation. You will be asked to grant your consent by ticking the respective box / or clicking “I accept” button or through similar mechanism prior to having access to the site, and/or when submitting or sharing the Personal Data we may request. We collect and use your Personal Data only in the context of the purposes indicated in the consent to processing of Personal Data.
We (directly or through third-party contractors specifically authorized by us) collect, record, systematize, accumulate, store, actualize (update and amend), extract Personal Data of the Russian Federation citizens with the use of databases located on the territory of the Russian Federation, except as otherwise permitted by Russian data protection legislation. We may process Personal Data of Russian citizens using databases located outside of the Russian Federation subject to compliance with Russian data protection legislation.
We undertake all the actions necessary to ensure security of your Personal Data.
You are legally entitled to receive information related to processing your Personal Data. To exercise this right, you have to submit a request to contacts indicated below in the Contact Us section.
You have the right to revoke the consent at any time by sending us an e-mail at contacts indicated below in the Contact Us section. Once we receive the revocation notice from you we will stop processing and destroy your Personal Data, except as necessary to provision the contract or service to you. However, please note once you have revoked your consent, we may not be able to provide to you the products and services you request, and may not be able to ensure proper work of our products.
We do not transfer your Personal Data to the countries that under Russian law are not deemed to provide adequate protection to the individuals’ rights in the area of data privacy.
We do not offer, sell or otherwise make available our products or services that have access to, collect and process (or allow us to do the same) Personal Data of third parties in the Russian Federation without the consent of such third parties.
If any provisions of this Policy contradict the provisions of this section, the provisions of this section shall prevail.
This section applies to California, USA residents:
Our products are not targeted at minors under 16 years of age. We therefore have no knowledge of any sale of data concerning them.
You have the right to:
Under California Civil Code § 1798.83, we are required to disclose to consumers the following information upon written request: (1) the categories of personal information that we have disclosed to third parties within the prior year, if that information was subsequently used for marketing purposes; and (2) the names and addresses of all such third parties to whom such personal information was disclosed.
We hereby disclose that we have not disclosed any such personal information as defined by the California Civil Code § 1798.83 regarding any California resident during the one-year period prior to the effective date of this Privacy Policy with the exception of:
If your personal information is subject to a sale you have the right to opt out from that sale.
A few of our free products serve third-party ads. You will be asked for consent during the installation process of such a product. For further information, including the exact scope of processed Personal Data and names of relevant products, please refer to our Consent Policy which includes the list of our advertising partners and their privacy policy. You can opt out from this processing by upgrading to a paid version of the same product or by uninstalling the product.
Please note that we do use third-party cookies for our advertising purposes as further described in our Cookie Policy where you can also find instructions on how to opt out of these cookies.
We will respect your decision to opt out for at least 12 months before asking you again to authorize the sale of your personal information.
You can submit your requests using contacts indicated below in the Contact Us section. If you are a California resident under the age of 18, you may be permitted to request the removal of certain content that you have posted on our websites. We will verify your request by matching your email address and, if necessary, other information you provide in your request against the email address and other information we have in our system. You can also designate an authorized agent to exercise these rights on your behalf. We may require that you provide the authorized agent with written permission to act on your behalf and that the authorized agent verify their identity directly with us.
To exercise any of your rights, or if you have any other questions or complaints about our use of your Personal Data and its privacy, You can always reach us by email at secureproxy.tool@gmail.com.
Changes to this Privacy Policy
We reserve the right to revise or modify this Privacy Policy. In addition, we may update this Privacy Policy to reflect changes to our data practices. If we make any material changes we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on this website prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.