January 29, 2018
1. User Consent.
2. A Note About Children.
We do not intentionally gather Personal Data from visitors who are under the age of 13.
3. A Note to Users Outside of the United States.
Your Personal Data may be transferred to and processed in the United States. With respect to our collection and processing of Personal Data about individuals in the European Union, we comply with the United States/European Union Safe Harbor Framework as set forth by the U.S. Department of Commerce (“Safe Harbor”) and have certified our adherence to the U.S./EU Safe Harbor Privacy Principles (the “Safe Harbor Principles). For more information regarding Safe Harbor, please visit the United States Department of Commerce Safe Harbor website at http://www.export.gov/safeharbor.
4. Types of Data We Collect.
“Personal Data” means data that allows someone to identify or contact you, including, for example, your name, address, telephone number, e-mail address, as well as any other non-public information about you that is associated with or linked to any of the foregoing data. “Anonymous Data” means data that is not associated with or linked to your Personal Data; Anonymous Data does not, by itself, permit the identification of individual persons. We collect Personal Data and Anonymous Data, as described below.
(a) Information You Provide to Us.
- We may collect Personal Data from you, such as your e-mail address, and password when you create an account to log in to our network (“Account”).
- When you order the Service on our Site or App, we will collect all information necessary to complete the transaction, including your name, payment information, billing information and shipping information.
- We retain information on your behalf, such as files and messages that you store using your Account.
- If you provide us feedback or contact us via e-mail, we will collect your name and e-mail address, as well as any other content included in the e-mail, in order to send you a reply.
- When you participate in one of our surveys, we may collect additional profile information.
- When you post messages on the help forums or message boards of our Site, the information contained in your posting will be stored on our servers and other users will be able to see it.
- We also collect other types of Personal Data that you provide to us voluntarily, such as your operating system and version, product registration number, and other requested information if you contact us via e-mail regarding support for the Service.
- We may also collect Personal Data, such as at other points in our Site or App that state that Personal Data is being collected.
(b) Information Collected via Technology.
- Our servers (which may be hosted by a third party service provider) collect information from you, including your mobile device type, application version, browser type, computer or mobile operating system, Internet Protocol (IP) address (a number that is automatically assigned to your computer or mobile device when you use the Internet, which may vary from session to session), domain name, information about the way you use the application and/or a date/time stamp for your visit of the Site or use of the App or Service.
- If you use the telephony and/or text messaging services available via some of our Apps, we may collect information related to your use of such services, such as the number of minutes used, number of text messages sent, and amount of data plan consumed.
(c) Information Collected from You About Others.
If you decide to invite a third party to create an Account, we will collect your and the third party’s names and e-mail addresses in order to send an e-mail and follow up with the third party. You or the third party may contact us at firstname.lastname@example.org to request the removal of this information from our database.
(d) Information Collected from Social Networking Sites.
5. Use of Your Personal Data.
(a) General Use.
In general, Personal Data you submit to us is used either to respond to requests that you make, or to aid us in serving you better. We will only use Personal Data in ways that are compatible with the purposes for which it was collected or as subsequently authorized by you. We use your Personal Data in the following ways:
- to facilitate the creation of and secure your Account on our network;
- identify you as a user in our system;
- provide improved administration of our Site, App and Service;
- provide the services you request;
- improve the quality of experience when you interact with our Site, App and Service;
- send you a welcome e-mail to verify ownership of the e-mail address provided when your Account was created;
- send you administrative e-mail notifications, such as security or support and maintenance advisories;
- respond to your inquiries related to employment opportunities or other requests; and
- to send newsletters, surveys, offers, and other promotional materials related to our Service and for our other marketing purposes.
(b) VPN Service.
If you are using the Keepsafe Virtual Private Network (VPN) Service (the “VPN Service”), we route all of your Internet traffic through a network provided by Keepsafe and its service providers (the “Keepsafe Network”). If you use our VPN Service, we (i) use your IP address to establish and maintain an encrypted tunnel between your browser or device and the Keepsafe Network and (ii) use your IP address and the IP addresses of websites, services, and applications you view or use to perform automated rules-based traffic management for the purposes of maintaining and improving the VPN Service. The Keepsafe Network is a “no log” network, which means that Keepsafe does not store your IP address when you are using our VPN Service or any information, including IP addresses, about the applications, services or websites you view or use while connected to our VPN Service.
(c) Creation of Anonymous Data.
We may create Anonymous Data records from Personal Data by excluding information (such as your name) that make the data personally identifiable to you. When you use our VPN Service, we may also collect Anonymous Data regarding your aggregate bandwidth usage. We use Anonymous Data to analyze request and usage patterns so that we may improve our Service and for billing, network operations, and support purposes. We reserve the right to use Anonymous Data for any purpose and disclose Anonymous Data to third parties in our sole discretion.
6. Disclosure of Your Personal Data.
(a) Third Party Service Providers.
(b) Affiliates and Acquisitions.
(c) Other Disclosures.
7. Third Party Data Collection.
(a) Information Disclosed to Analytics Companies and Ad Networks.
We may work with analytics companies to help us understand how our Site, our Service and our App are being used, such as the frequency and duration of usage. We may also use third-party advertising companies to serve ads when you visit our Site or App. These companies may use some of the information collected by the Site or the App, including the unique identification ID of your mobile device. To protect the anonymity of this information, we limit data sharing to ensure these companies can’t identify you personally based on the information we provide. These companies may also obtain information about other applications you have downloaded to your mobile device, the mobile websites you visit, your non-precise location information (e.g., you zip code) and other non-precise location information in order to help analyze and service anonymous targeted advertising on the Site and App and elsewhere.
(b) Tracking Cookies.
Some of the analytics companies and third party advertising companies used on this Site may place “tracking cookies” on your computer. If you would like more information about this practice or to opt-out of having this information used by third-party ad servers that are part of the Network Advertising Initiative (“NAI”) or the Interactive Advertising Bureau (“IAB”), please visit:
(c) Third Party Websites.
8. Your Choices Regarding Your Personal Data.
We offer you choices regarding the collection, use, and sharing of your Personal Data.
- We may periodically send you free newsletters and e-mails that directly promote the use of our Site, App or Service. When you receive newsletters or promotional communications from us, you may indicate a preference to stop receiving further communications from us and you will have the opportunity to “opt-out” by following the unsubscribe instructions provided in the e-mail you receive or by contacting us directly (please see contact information below).
(b) Changes to Personal Data.
You may change any of your Personal Data in your Account by editing your profile within your Account. You may request deletion of your Personal Data by us, but please note that we may be required to keep this information and not delete it (or to keep this information for a certain time, in which case we will comply with your deletion request only after we have fulfilled such requirements). When we delete any information, it will be deleted from the active database, but may remain in our archives. We may retain your information for fraud or similar purposes.
9. Security of Your Personal Data.
We are committed to protecting the security of your Personal Data. We use a variety of industry-standard security technologies and procedures to help protect your Personal Data from unauthorized access, use, or disclosure. We also require you to enter a password to access your Account information. Please do not disclose your Account password to unauthorized people. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, while we use reasonable efforts to protect your Personal Data, we cannot guarantee its absolute security.
11. Dispute Resolution.
12. Contact Information.