LAST UPDATE: June 30, 2021
1.1 Safe-T USA Inc. (“Company,” or “we,” or “us,” or “our”) is committed to safeguarding the privacy of our website and serviced users (“users,” or “you”).
1.3 This policy applies where we are acting as a data controller with respect to your personal data, in other words, where we determine the purposes and means of the processing of that personal data.
2. Types and Uses of Collected Information. We collect two types of information about you, as follows:
2.1 Personally Identifiable Information. Personally Identifiable Information is information that identifies a specific person. When you engage in certain activities via the Company’s Services, including but not limited to creating an account, sending feedback, or otherwise participating in the Company’s Service (collectively, “Identification Activities”), we may ask you to provide certain information about yourself. If you elect to engage in an Identification Activity, we may ask you to provide us with certain personal information about yourself, such as your name, address (including zip code), email address, credit card information, telephone number and/or any other information you provide to us, to process your transaction, send communications pertaining to your transactions, and populate forms for future transactions. Depending on the Identification Activity, some of the information we ask you to provide may be identified as mandatory and some may be identified as voluntary.
2.3 We may disclose Personally and Non-Personally Identifiable Information with regulatory authorities or as required by applicable law. For example, we may disclose personal information to cooperate with regulatory authorities and law enforcement agencies to comply with subpoenas or other official requests, and as necessary to protect our rights or property.
2.4 Information We Retain.
a) We track and store application installation data in order to validate the installation process and reward relevant affiliates/traffic sources.
b) We record and store access logs of our ordering, billing, and support system as well as the CRM (My Account) to track and block fraudulent activities.
c) We keep the bandwidth usage log of data transmitted (upload and download) during your VPN sessions.
d) A time stamp when you connect and disconnect to our VPN service.
The Company DOES NOT monitor nor store any of the data sent or received over the VPN tunnel.
3. How we use your personal data.
In this Section we have set out (a) the general categories of personal data that we may process; (b) the purposes for which we may process personal data; and (c) the legal bases of the processing.
3.1 We may process data about your use of our website and services (“usage data”). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analyzing the use of the website and services. The legal basis for this processing is your consent or our legitimate interests, namely monitoring and improving our website and services.
3.2 We may process your account data (“account data”). The account data may include your name and email address. The source of the account data is you. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is your consent or our legitimate interests, namely monitoring and improving our website and services.
3.3 We may process your information included in your personal profile on our website (“profile data”). The profile data may include your name, address, telephone number, email address, profile pictures, gender, date of birth, relationship status, interests and hobbies, educational details and employment details. The profile data may be processed for the purposes of enabling and monitoring your use of our website and services. The legal basis for this processing is your consent or our legitimate interests, namely monitoring and improving our website and services.
3.4 We may process information that you post for publication on our website or through our services (“publication data”). The publication data may be processed for the purposes of enabling such publication and administering our website and services. The legal basis for this processing is your consent or our legitimate interests, namely monitoring and improving our website and services.
3.5 We may process information contained in any inquiry you submit to us regarding goods and/or services (“inquiry data”). The inquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is your consent or our legitimate interests, namely monitoring and improving our website and services.
3.6 We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website (“transaction data”). The transaction data may include first and last names, an email address to be used as a login, billing contact information, credit card number and a password. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests.
3.7 We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data”). The notification data may be processed [for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is your consent or our legitimate interests, namely monitoring and improving our website and services.
3.8 We may process information contained in or relating to any communication that you send to us (“correspondence data”). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is your consent or our legitimate interests, namely monitoring and improving our website and services.
3.9 We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
3.10 In addition to the specific purposes for which we may process your personal data set out in this Section 3, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
3.11 Please do not supply any other person’s personal data to us unless we prompt you to do so.
4. Providing your personal data to others
4.1 We may disclose your personal data to any member of our group of companies, this means our subsidiaries, our ultimate holding company and all its subsidiaries insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.
4.2 We may use third-party service providers to serve ads when you participate in the Service. These companies may use Non-Personally Identifiable Information about your visits and use of the Services, and visits to other websites or locations to provide, through the use of network tags, advertisements about goods and services that may be of interest to you.
4.3 In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
5. About cookies
5.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
5.2 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
5.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
6. Cookies used by our service providers.
7. Managing cookies.
7.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
7.2 Blocking all cookies will have a negative impact upon the usability of many websites. If you block cookies, you will not be able to use all the features on our website.
8.1 We continuously improve our websites and our products, and we utilize different third-party web analytics tools to help us do so. We are interested in how visitors use our websites, our desktop tools, our mobile applications, what they like and dislike, and where they have problems. Our products, desktop tools and mobile applications use analytical tools to understand feature usage patterns, to enhance and improve your product experience and offer you specific usage tips and guidance. In connection with normal business operations, as well as to increase functionality and enhance your user experience, this usage information may be linked to personal information that we have about individual users. We maintain ownership of this data and we do not share this type of data about individual users with third parties.
8.2 This information is used solely to assist us in maintaining a more effective and useful websites and products for our customers. This data will not be shared with third parties without your prior consent or unless required by law.
9. Your rights.
9.1 In this Section we have summarized the rights that you may have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the applicable regulatory authorities for a full explanation of these rights. Please note that these rights are not absolute and may be subject to our own legitimate interests and regulatory requirements.
9.2 Your principal rights under data protection law in accordance with the Personally Identifiable Data we collect are: (a) the right to erasure; (b) the right to restrict processing; (c) the right to object to processing; (d) the right to complain to a supervisory authority; and (f) the right to withdraw consent.
9.3 In some circumstances you have the right to the erasure of your personal data without undue delay, and at the latest within one month of receiving your valid request. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully process.
9.4 However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defense of legal claims.
9.5 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful, but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defense of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defense of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
9.6 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third-party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defense of legal claims.
9.7 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
9.8 To the extent that the legal basis for our processing of your personal data is: (a) consent; or (b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
9.9 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection.
9.10 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
9.11 To exercise such right, you may contact us at: [email protected]
The Services are not directed to people under the age of eighteen (18) and we do not knowingly collect personal information from people under the age of 18 or any other age that requires a consent or authorization for data processing from the holder of parental responsibility. If you become aware that your child has provided us with personal information without your consent, please contact us at the email address listed below. If we become aware that a person under eighteen (18) has provided us with personal information, we take steps to remove such information and terminate the child’s account.
11. Retaining and deleting personal data.
11.1 Personal data that we process for any purpose or purposes shall be kept until such time as we receive a request for deletion from you.
11.2 Notwithstanding foregoing, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
11.3 Retention periods can vary significantly based on the type of information and how it is used, and our retention periods are based on criteria that include legally mandated retention periods, pending or potential litigation, our intellectual property or ownership rights, contract requirements, operational directives or needs, and historical archiving. When personal data is removed from our systems, it will be deleted or destroyed using appropriate security protocols so that it cannot be reconstructed or read.
12. Notice of Privacy Rights to California Residents. If you are a resident of California, United States, you have the right to send us a written request regarding a list of personal information categories that we may have disclosed to third parties or to which we may have given to third parties, and the details of such third parties. If you are a California resident and would like such a list, please contact us at [email protected] – for all such requests, please indicate “CA Resident” in the subject field of your request and include the name of the Service with respect to which you are requesting the information. You must also include your full name, street address, city, state, zip code and email address. To learn more about your California privacy rights, visit the CCPA Privacy Statement
13. Contact Us. For additional inquiries about the privacy of your information, you may contact us using the contact details below:
Safe-T USA Inc.
51 John F Kennedy Pkwy FL W
Short Hills NJ 07078-2704, United States
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