URBAN Proxy PRIVACY POLICY

[Last Updated: June 25, 2025]

First and foremost, before we dive into the legal details of our privacy policy, we wish to make it clear- We do not want to know your identity and we do not collect data to try and figure out who you are. We don’t require registration of any kind in order to use our services. Of course, we do provide all of the regular privacy policy information to which you are entitled, and we will get to that in a minute. But in case you do not have the time or patience to read through the whole policy, we want to repeat and make that point perfectly clear: We do not want to know your identity, preferences or any information about you personally. Any data collected from you simply by your use of our product will never be used to figure out who you are or to send you targeted ads.

This Privacy Policy (“Privacy Policy”) governs the manner in which we, Urban Cyber Security Inc. (“Urban”, “we” or “us”) process information collected from our users (“you“, “your” or “user“) in connection with their access to or use of our product (“Products”): (i) Urban VPN Proxy browser extension as detailed and defined in our Terms of Use (“Terms”).

All capitalized terms used but not otherwise defined herein shall have the meaning ascribed to them in the Terms. This Privacy Policy explains what information we may collect, how such information may be used or shared with others, how we safeguard it and how you may exercise your rights related to your Personal Data (as such term is defined below), among others, and where applicable, as required according to the EU General Data Protection Regulation (“GDPR”).

If you are a resident of the United States including California, please see the US & CCPA Notice which discloses the categories of personal information collected, purpose of processing, source, categories of recipients with whom the personal information is shared for a business purpose, whether the personal information is sold or shared, the retention period, and how to exercise your rights as a US & California resident.

The use of information received from Google API will adhere to the Chrome Web Store User Data Policy including the Limited Use requirements.

1. Changes to Privacy Policy

Except as otherwise described herein, we may at our sole discretion and at any time amend the terms of this Privacy Policy. Such changes shall be effective upon publication of the amended terms in this Privacy Policy. Your continued use of the Services, following the amendment of the Privacy Policy, constitutes your acknowledgement and consent of such amendments to the Privacy Policy. The last revision will be reflected in the “Last Updated” heading above. In the event of a material change we will make a reasonable effort to provide a notification of such change. We recommend that you periodically review this Privacy Policy, as it may be subject to amendments from time to time.

2. Controller Contact Information

Urban is the controller (as such term defined under the GDPR) or the “business” as defined under the California Consumer Privacy Act (“CCPA”) of the Personal Data, following are the applicable contact information:

Urban Cyber Security Inc.

 501 Fifth Avenue, New York, NY, 10036.

You can also contact our privacy team at: privacy@urban-vpn.com.

Representative for data subjects in the EU and UK:

We value your privacy and your rights as a data subject and have therefore appointed Prighter Group with its local partners as our privacy representative and your point of contact.
Prighter gives you an easy way to exercise your privacy-related rights (e.g. requests to access or erase personal data). If you want to contact us via our representative, Prighter or make use of your data subject rights, please visit the following website. https://prighter.com/q/13252349120

3. What data do we collect?

When you use the Services, we may collect information about you, including:

• Approximate Location: When using the VPN, we need to extract your location in order to provide you with our services
• Online Identifiers: in order to provide you with the services and for certain analytics and marketing purposes we will collect your IP address and other online identifiers.
• Browsing Data: we will process websites you visited and clicked stream data to protect your browsing with the “Anti phishing” and “Malicious Anti malware” features, or where applicable to block malicious ads.
• Contact Information: if you contact us we may need to process your contact information such as email address to respond your inquiry.
• AI Inputs and Outputs.: As part of the Browsing Data, we will collect the prompts and outputs quired by the End-User or generated by the AI chat provider, as applicable.Meaning, we are only interested in the AI prompt and the results of your interaction with the chat AI. Due to the nature of the data involved in AI prompts, some sensitive personal information may be processed. However, the purpose of this processing is not to collect personal or identifiable data, we cannot fully guarantee the removal of all sensitive or personal information, we implement measures to filter out or eliminate any identifiers or personal data you may submit through the prompts and to de-identify and aggregate the data. We process this information as part of the Browsing Data for enhancing the Safe Browsing feature. We also disclose the AI prompts for marketing analytics purposes. Any secondary use of the AI prompts will be performed on a de-identified, filtered, and in most cases even anonymized and aggregated manner, and is subject to your consent. You can withdraw your consent at any time as detailed below through the opt-out options through the App.Our lawful basis for processing the data is (performance of contract or legitimate purposes. Where required we will obtain your consent for certain processing activities.

4. How We Collect Your Information?

We collect the above data from you, in the following ways:

• When you voluntarilychoose to provide us with information, e.g., when you contact us.
• Automatically, when you use our wish to use the “Safe Browsing Mode” or “Anti Phishing” we may collect your Web Browsing Data.

5. With Whom Do We Share Information?

We will not share your personal data with third parties unless we have your consent or there are legal basis for doing so. When disclosing personal data to third parties for processing, we require them to keep your information confidential and to only process it as necessary to fulfill their contractual or legal obligations. We may share your personal data if we sell, transfer, or merge parts of our business or assets, in which case the new owners will assume the rights and responsibilities outlined in this policy. We may also disclose your personal data for reasons of national security, law enforcement, or public interest.

6. Data retention

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.

7. User Rights

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 allow you to exercise certain choices, rights, and controls in connection with your information. Depending on your relationship with us, your jurisdiction and the applicable data protection laws that apply to you, you have the right to control and request certain limitations or rights to be executed.

You may exercise any or all of your above rights in relation to your Personal Data by filling out the Data Subject Request (“DSR”) form available here, and send it to privacy@urban-vpn.com

For additional rights under various jurisdictions, please refer to “Non-EU Privacy Notice”

8. Data Security

We have implemented appropriate technical and organizational measures to protect the confidentiality, security and integrity of the information collected, and to prevent unauthorized access and the use of information contrary to this Privacy Policy. Although we use commercially reasonable efforts to ensure that your information remains secure when maintained by us, please be aware that no security measures are perfect or impenetrable.

9. Children Information

You represent and warrant that you are (i) at least sixteen (16) years of age if you are located in the EEA; or (ii) if you are located in any other geography and you are above the age defined as “child” under applicable laws in your jurisdiction (collectively “Child” or “Children”). If you are under 18, please be sure to read the terms of this Privacy Policy with your parents or legal guardians. The Services are not directed or intended for Children, as defined under applicable law, and we do not knowingly collect or solicit information from children. If we later obtain actual knowledge that a user is considered as a Child under applicable law, we will take steps to immediately delete its Personal Data. We request that such individuals do not provide Personal Data through the Services.

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.

10. Transfer of Data

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.

11. Contact Us

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: privacy@urban-vpn.com.