PRIVACY POLICY

Last Updated: Sep 27, 2018

Please read carefully this Privacy Policy as it affects your obligations and legal rights.

This Privacy Policy is an independent legal document. Your rights and obligations when you use any of Applications are also defined (may be defined) by the following documents (agreements): Terms of Use; any other terms we let you know about. This Privacy Policy may contain links to any document listed above. The absence of one document or all of the listed documents doesn’t affect the validity of this Privacy Policy.

GENERAL CONDITIONS

The Privacy Policy governs the privacy terms of using Applications, general rules of User’s Personal Data collection, processing, distribution, usage and keeping.

We follow all the legal requirements to protect your privacy. Our Privacy Policy is a legal statement that explains what information of yours we will collect when you use the Applications, how the information will be used, and how we will share and protect the information.

EACH USER MUST CAREFULLY READ AND COMPLY WITH THIS POLICY.

By using Applications you confirm that you agree to these Terms of Our Privacy Policy. If you do not agree with this Privacy Policy in general or any part of it, you should withhold from using Applications. You also agree that any information about you collected by us is transferred with your consent.

You provide and guarantee to us the right to process your personal data, including the right to perform the following actions to process your personal data (fully or partially in an automated system): storing, registration, changing, restoring and removing. Also you agree that your personal data is included in the personal data base and any additional notification is not required.

DEFINITIONS

In this Privacy Policy the following terms have meanings as described in the Definition section below:

“Applications” – applications, websites, tools or services, including but not limited:

  • Mobile and desktop applications
    • SurfPro VPN (version for iOS devices)
    • SurfPro VPN (version for Mac)
  • Websites
    • xwavesoft.com

“Personally identifiable information” (hereinafter – “Personal Information” or “Personal Data”) shall mean any information that can be directly associated with a specific person and can be used to identify that person (including the information about Your activities, such as information about Your usage of the Applications, when directly linked to personally identifiable information, including automatically collected). We do not consider Personal Data to include information that has been anonymized so that it does not identify a specific User.

“Controller” (data controller) means a natural or legal person, which determines the purposes and means of the processing of personal data.

“Processor” means a natural or legal person, which processes personal data on behalf of the Controller.

“Owner” (“Applications Owner”) or “Operator” or “we” (“us” or “our”) means a natural or legal person, which owns the exclusive rights for the objects of intellectual property – Applications.

The other terms and notions used in this Policy shall be understood in accordance with the Terms of Use, unless other specified in this Privacy Policy.

AGE RESTRICTION

Applications are not designed for use by anyone under the age of 18 (and even over if the legislation of Your jurisdiction provides acquiring the full dispositive legal capacity of a natural person over the age of 18).

INFORMATION COLLECTION AND PROCESSING

We collect some personal information from registered users. During the registrations users have to input a valid email address and password.

We uses the provided registration information to authenticate users and provide access to the services. We may also use the provided email addresses in order to communicate with our customers. We may send you email messages with notifications about changes to its services, maintenance or promotional materials. You can unsubscribe from the marketing and promotional materials at any time using the corresponding links in the emails. Even if you are unsubscribed, we may contact you via provided email for purchases confirmation, technical support, or any security issues.

We do NOT collect and log any user activities while using any of their VPN services, except the total amount of web traffic for each session and session dates. We also store the information about the amount of connected devices for each account, as the maximum permitted amount is limited.

We may ask you to provide us with some technical non-personal information which may be collected in the background by the applications. The following information may be collected: the user’s ID; the connection attempt time; the connection type; the encryption type; the device type, etc. This information will be used strictly for technical purposes, such as overall system improvement and increase of user experience.

We may track, collect, process and compile non-personal information relating to your usage of the Applications: device information including device model, identifier, version and type of operating system, the application installation ID, title and version number of the application, date of the installation and date when the application was last launched, purchased plan, data about the user behavior in the application, mobile network information, region and locale data. You (as a user) give your voluntary and undoubted consent for the collection and processing specified information relating to your usage of the Applications and its transfer to the third parties in order to implement functioning of the Applications and their appropriate work.

We also collect and store such information as: User requests to support regarding the work of the Applications and their related services, and other issues as well as similar texts of the User requests.

We take reasonable precautions such as policy-based access control to protect the Data in our possession from loss, misuse, and unauthorized access. We follows generally accepted industry standards to protect the Data, both during transmission and once received by us.

THIRD PARTIES

Applications may contain links to third party websites, applications or services. Applications also may have integration with third party websites, applications or services. If You follow one of these links or use integration with any of these websites, applications and or services, please note that they and any services that may be accessible through them have their own privacy policies and that We do not accept any responsibility or liability for these policies or for any Personal Data that may be collected through these websites, applications or services.

We may share your personal information with:

  • service providers under contract who help with parts of our business operations;
  • companies that We plan to merge with or be acquired by (should such a combination occur, We will require that the newly combined entity follow these terms with respect to Your Personal Data);
  • third party identity verification services for fraud prevention purposes;
  • law enforcement, government officials, or other third parties when We are compelled to do so by a subpoena, court order, or similar legal procedure; or We believe in good faith that the disclosure of Personal Data is necessary to prevent physical harm or financial loss, to report suspected illegal activity or to investigate violations of any of Our policies;
  • our Personal Data processing counterparties or agents, hired by or cooperating with Us, whose services are required by Us from the practical point of view;
  • other third parties only with Your prior consent or direction to do so.

We will not provide Your Personal Data to any other Users without Your consent or direction.

THIRD PARTY SERVICES LINKS

https://www.keepsolid.com/privacy

https://www.keepsolid.com/terms

https://www.keepsolid.com/age-certification

PRIVACY POLICY UPDATES

We reserve the right to modify or amend this Privacy Policy at any time. You should review this Privacy Policy frequently. Your continued usage of Applications shall mean your acceptance of those amendments and updates.

CONTACT US

At any time you may require all of Your Personal Data, correction, updating, complete removal or removal of incorrect and or inaccurate data collected by us by sending Us an email to support@xwavesoft.com

If you have any other questions concerning this Privacy Policy, please contact us – support@xwavesoft.com.