[Last Updated: October 31, 2022]
The use of information received from Google API will adhere to the Chrome Web Store User Data Policy including the Limited Use requirements.
If you have any questions or requests regarding the processing of your Personal Data, or would otherwise like to contact us in connection with this Policy, please send us an email to: email@example.com
The first type of information we collect is aggregated, non-identifiable, non-personal information, which may be made available or gathered via the user's use of the Service ("Non-Personal Data"). We are not aware of the identity of the user from which the Non-Personal Data was collected. Non-Personal Data may include technical information automatically transmitted by the user's device such as, type of browser, the type of operating system, access time and date, approximate geographical location, etc.
The second type of information is individually identifiable information, namely information that identifies an individual or entity or may with reasonable effort identify an individual ("Personal Data").
The table below details the Personal Data collected by us, how it is used, and our legal basis for data processing. Note that, under the GDPR we are considered of the Data Controller of the data we collect.
|What type of data we collect?||How do we use it?||Lawful Basis|
|We may collect certain Online Identifiers: Agent Id, UDID, machine ID (such as Android ID) and your IP address ("Online Identifiers").||We will use your IP address to provide the Services as well as to extract the approximate geographical location (i.e., country). We need this information to provide the VPN services, among others.||Performance of a contract.|
|We place cookies on our Website (as further detailed below under Section 5) in order to process Online Identifiers as well as additional information regarding your engagement with the Website. "Website Online Identifiers").||We will use such Website Online Identifiers in order to perform research, conduct associated analytical and statistical activities developing our business and for marketing and purposes.||Consent through cookie notice or other notice.|
We may collect your web browsing data, which includes search engine results page, web pages visited, clicked
stream data, information about the content that was viewed – the ad campaign, information about where the
content was viewed (website or the app or extension) ("Web Browsing Data").
Note that, in most cases the data detailed above is aggregated Non-Personal Data, however, sometimes Web Browsing Data contains terms that could be considered as Personal Data, this is why we filter and scrape this data to remove any Personal Data before it is used.
We do not track or collect information about users' activities across sites or applications, meaning we do not cross information from different apps, websites, your computer, tablet or mobile device.
We will use this data for the purpose of operating and providing our Services, for example, in order to
create a black listing of target websites and provide the "Safe Browsing Mode" alerts feature, blocking ads,
as well as for internal operation purposes and enhancing the Services.
We will further use filtered Web Browsing Data in an aggregated, anonymized manner, for marketing research and commercial use. It is important you understand, we are not interested in knowing who you are, target or profile you. We are interested in completely anonymous insight of how webpages and ads are viewed, whether and when they are clicked ("Insights") and we share these Insights with our partners. These Insights help our partners in their market research and their digital measurements. For example, it helps our partners understand how certain ads and websites are engaged. Our interest in not to produce insight regarding your specific usage but create an aggregated insights regarding the engagement of users with websites.
The Web Browsing Data is used for performance of a contract.
The Insights do not contain any Personal Data and thus do not require a lawful basis. We generally do not (and cannot) identify, or attempt to identify, the individuals about whom we collect the Browsing Data or through the derived Insights.
|If you voluntarily contact us, you may be required to provide us with certain information such as your name and email address.||We will use this data solely to provide you with the support you have requested or response to your
inquiry. We may process the contact history to improve our services, as well as resolve disputes.
We may send you email marketing materials regarding the Services you are currently using or any services we may offer in the future ("Direct Marketing").
Our legitimate interests
Direct Marketing is subject to our legitimate interest, you may opt-out at any time from certain correspondence.
From time to time we may offer Premium Plans, and in such events you may be required to provide our
third-party service providers with additional information such as Card Number, Cardholder Name, etc.
In such events, We may use the following payment service providers ("PSP"):
|We do not store or process any of your payment details. We employ third party payment processors and thus, your payment details will be subject to such third-party payment processors privacy practices.||Performance of a contract.|
If you choose to use our active "safe browsing" feature available on our Mobile App you will be required to enable the accessibility permission ("Permission"). can disable the Permission at any time
|"Safe Browsing Mode" by enabling us to block unwanted websites or apps.||To access the Permission, you will need to actively and explicitly enable it through an in-app permission or the mobile settings. You, therefore the lawful basis is consent. You may withdraw your consent at any time but please note if you disable, the "Safe Mode" feature will not operate properly.|
|IP Address and Network Resources||The Desktop App is a community product and thus, to receive the services, we will collect this data and provide the Residential IP to other users in the community, the same way that you receive them.||Performance of contract.|
We collect the above data from you, in the following ways:
We share your data with third parties, including our service providers that help us provide our Services. You can find here information about the categories of such third-party recipients
|CATEGORY OF RECIPIENT||DATA THAT WILL BE SHARED||PURPOSE OF SHARING|
|Affiliated Company; business partners and customers||Insights||We will share the Insights we produce with our affiliated company, business partners and customers which includes marketing and data analytics companies for commercial purposes. The data we share for this purpose shall not include any Personal Data and will include only aggregated data.|
|Trusted Agents and Service Providers||All data||We may disclose Personal Data to our trusted agents (such as legal counsel) and service providers (including, but not limited to, our Cloud Service Provider, Analytics Service Provider, fraud and security detection providers etc.) so that they can perform the requested services on our behalf. These providers are prohibited from using your Personal Data for any purposes other than providing us with requested services. When we share information with services providers, we ensure they only have access to such information that is strictly necessary for us to provide the Services. These parties are required to secure the data they receive and to use the data for pre-agreed purposes only while ensuring compliance with all applicable data protection regulations (such service providers may use other non-personal data for their own benefit).|
|Any acquirer of our business||All data||We may share Personal Data, in the event of a corporate transaction (e.g., sale of a substantial part of our business, merger, consolidation or asset sale). In the event of the above, our affiliated companies or acquiring company will assume the rights and obligations as described in this Policy.|
|Legal and law enforcement||Subject to law enforcement authority request.||We may disclose certain data to law enforcement, governmental agencies, or authorized third parties, in response to a verified request relating to terror acts, criminal investigations or alleged illegal activity or any other activity that may expose us, you, or any other user to legal liability, and solely to the extent necessary to comply with such purpose.|
We reserve the right to use, disclose or transfer (for business purposes or otherwise) aggregated and processed Non-Personal Data to third parties, including, inter alia, affiliates, for various purposes including commercial use. This information may be collected, processed and analyzed by us and transferred in a combined, collectively and aggregated manner (i.e., your information is immediately aggregated with other users) to third parties
A "cookie" is a small piece of information that a website assigns to your device while you access such website. Cookies are very helpful and may be used for a variety of different purposes. These purposes include help customize your experience, provide us with analytics and for advertising purposes (including personalized advertising).
Note that we do not combine the information collected through the use of third-party tools with any Personal Data collected from you. You may remove Cookies by following the instructions on your device governing the setting of your preferences. Our Cookies do not enable any access to or inspection of other information on your device. If you wish to be notified of when Cookies are placed on your device, you may set your web browser to provide such notices.
The third-party cookies used on our Site are as follows:
|Google Analytics||Analytical and Performance||
For additional information regarding our use of Google products, click here.
|Google Ads||Targeting and Advertising||
For additional information of our use of Google products, click here.
|Analytic, Performance and Targeting and Advertising||https://www.facebook.com/about/privacy/?sId=eead84c9-01f3-4402-b1b2-b19dc38ba2e7|
|Microsoft||Targeting and Advertising||https://privacy.microsoft.com/en-gb/privacystatement|
|Matomo||Analytic and Performance||https://matomo.org/privacy-policy/|
|Bing||Targeting and Advertising cookies||https://privacy.microsoft.com/en-gb/privacystatement|
Most browsers will allow you to erase cookies from your computer’s hard drive, block acceptance of cookies, or receive a warning before a cookie is stored. However, if you block or erase cookies your online experience may be limited.NAI consumer opt-out and the Digital Advertising Alliance’s ("DAA") website - DAA opt-out page.
We do not support Do Not Track ("DNT"). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked. You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.
We retain the information we collect as long as it remains necessary for the purposes set forth above, all in accordance with applicable laws. We may at our sole discretion, delete or amend information from our systems, without providing any notice to you, once we deem it is no longer necessary for our purposes.
We acknowledge that different people have different privacy concerns and preferences. Our goal is to be clear about what information we collect, so that you can make meaningful choices about how it is used. We provide you with the ability to exercise certain choices, rights and controls in connection with your information. Depending on your relationship with us, data protection and privacy laws provide you with some of the following principal rights regarding your Personal Data, including (and depending on your jurisdiction): The right to access your Personal Data that we process; The right to ensure your Personal Data is accurate, complete and up to date; The right to have your Personal Data amended (by correcting, deleting or adding information); The right to object to the processing of your Personal Data, to the extent applicable; The right to withdraw consent, subject to legal or contractual restrictions and reasonable notice; Right to Non-Discrimination and the right to cease sharing or selling your information as such term is defined under the California Privacy Regulations such as the CCPA (as further detailed in the CCPA notice below).
Further, certain rights are available within the App: you may correct, revise and delete information from the App settings at any time, any consent provided may be easily withdraw, therefore we recommend you use the technical solutions we have provided you with to exercise your rights.
While there are inherent risks involved in all data transmissions over the Internet or wireless networks, and other security risks that apply to stored data, and we therefore cannot guarantee the security of your information, we use our best efforts, using industry-standard encryption and security technologies and methods, to collect and store information collected from you in a secure and safe manner.
If you become aware or have any reason to believe that a Child has shared any information with us, please contact us (as detailed below) and we will take reasonable steps to ensure that such information is immediately deleted from our files.
We may process or store Personal Data within the EEA, US, and internationally. In the event of data transfer out of your jurisdiction, we will take appropriate measures to ensure that your Personal Data receives an adequate level of protection as required under applicable law. Further, when Personal Data collected within the EU is transferred outside the EU (and not to a recipient in a country that the European Commission has decided provides adequate protection) it shall be transferred in accordance with the provisions of the standard contractual clauses approved by the European Union.
California residents have certain additional rights, pursuant to California privacy laws, including the CCPA. Under the CCPA, "Personal Information" is defined as any information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household or device. The categories of Personal Information that we collect (and has collected within the last 12 months), are detailed in the table below. Please note that, under the CCPA Personal Information does not include: publicly available information from government records and de identified or aggregated consumer information, information excluded from the CCPA’s scope (e.g., health or medical information covered by applicable laws such as the Health Insurance Portability and Accountability Act of 1996 (HIPAA)); and information covered by certain sector-specific privacy laws (e.g., the California Financial Information Privacy Act (FIPA)).
Note that the term "sale" is defined broadly in the CCPA to include any exchange of data for consideration of any kind.
|Category||Do we collect this data?||Do we disclosure this data for a business purpose?|
|B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).||Yes||Yes|
|C. Protected classification characteristics under California or federal law.||No||No|
|D. Commercial information.||No||No|
|E. Biometric information.||No||No|
|F. Internet or other similar network activity.||Yes||Yes|
|G. Geolocation data.||Yes||No|
|H. Sensory data.||No||No|
|I. Professional or employment-related information.||No||No|
|J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).||No||No|
|K. Inferences drawn from other personal information.||No||No|
In the preceding twelve (12) months, we have not sold Personal Information.
We offer all consumers the same ability to opt-out of the sale of their personal information that is available to California residents under the CCPA. Based on the CCPA’s broad definition of "sale", certain data collected on our site and applications by third parties for purposes of interest-based advertising and social media tools may be a "sale" under the CCPA. You may opt out through the links provided above under the "Cookie" section, or by using our DSR Form.
Further, please note, any commercial use we make of the Insights is filtered of any Personal Information and are not identified. As mentioned above, we are not interested in knowing who you are or any information related to you or your browsing activities, we are interested in understanding how websites are used, which links are clicked, etc.
If you have any questions or concerns regarding privacy issues, or if you wish to be provided with any other information related to our privacy practices, please contact us at:
Urban Cyber Security Inc.
501 Fifth Avenue, New York, NY, 10036.
You can also contact our privacy team at: firstname.lastname@example.org.
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