PRIVACY POLICY

Last Updated: 07/13/2022

IP Security LTD, a legal entity duly registered under the laws of British Virgin Islands at First Floor, Mandar House, Johnson’s Ghut, P.O. Box 3257, Road Town, Tortola, British Virgin Islands, under registration number 2096323 (“Company”, “us”, “our”, and “we”) is the owner of the website https://asocks.com (the "Website") and the system which enable browsing the Internet by redirecting users’ communication through other users’ devices (all together the “System”). We are concerned about your privacy and have designed this Privacy Policy in order to help you (the “User”, “Client”, “You”) decide whether to use the System.

THIS PRIVACY POLICY IS A LEGALLY BINDING AGREEMENT BETWEEN YOU AND US. BY ACCESSING AND USING THE SYSTEM, OR PROVIDING INFORMATION TO US IN OTHER FORMATS, YOU AGREE AND ACCEPT THE TERMS OF THIS PRIVACY POLICY AS AMENDED FROM TIME TO TIME AND CONSENT TO THE COLLECTION, USE AND TRANSFER OF YOUR PERSONAL DATA FOR PROCESSING AS DESCRIBED IN THIS PRIVACY POLICY.

The definitions in the Terms of Service posted on the Website apply to this Privacy Policy unless stated otherwise. In addition to this Privacy Policy please review the Terms of Service which are incorporated herein by reference. In anything not expressly stipulated in this Privacy Policy the Parties shall be governed by the Terms of Service.

For purposes of the Privacy Policy, “Personal Data” or “Personal Information” means any information that identifies or relates to a particular individual which the Client provides to the Company and/or collected about the Client by the Company and/or information the Company obtains from third parties. The definition of Personal Data also includes information referred to as “personally identifiable information” or “personal information” under applicable data privacy laws, rules, or regulations, including the GDPR and the CCPA.

This Privacy Policy is split in the following sections for your comfort:

1. PERSONAL DATA PROVIDED AND PROCESSED.

2. LEGAL BASIS AND USE OF PERSONAL DATA.

3. SHARING CLIENT’S PERSONAL DATA.

4. THIRD PARTIES AND THEIR PRIVACY POLICIES.

5. SECURITY.

6. CLIENT’S RIGHTS.

7. HOW LONG PERSONAL DATA WILL BE PROCESSED.

8. DIRECT MARKETING RIGHTS AND OPT-OUT OPPORTUNITIES.

9. CONTACT INFORMATION.

10. CHANGES TO THIS PRIVACY POLICY.

  1. PERSONAL DATA PROVIDED AND PROCESSED

The Company is responsible for the processing of Personal Data that the Client contributes to the System and for Personal Data that the Company collects in other ways in regard to the Service.

We may collect and process the following types of information:

  • Non-Personal Information. We collect non-personal information about your use of the System to allow us to provide the services and constantly improve them, for security reasons and so that we can audit and track usage statistically. This is information that is unidentified and non-identifiable, which is generated by a user's activity. Such non-personal information may include the following information: browser type, web pages You visit, time spent on those pages, access times and dates, any non-persistent identifiers, session information collected via cookies and similar technologies.

  • Personal Information. It is information that may be of a private or sensitive nature, identifies or may identify You. The Personal Information we collect and retain include your IP address, persistent online identifiers (your full name and email address in case You provide us with this information (when You Register or if you approach us through the "contact us" option), payment and billing information (if you purchase any Pricing Plan) or other information we may ask from time to time as will be required for the services provisioning.

  • Personal Information from Third-Party Applications. The Company also can receive Client’s Personal Data from the Third-Parties Applications, including Payments Processors, involved in System’s maintenance. This means that any information provided by the Client to Third-Parties Applications according to this Privacy Policy can also be transferred to the Company, and further processed and stored by the Company.

If we combine non-personal information with personal information we will treat the combined information as Personal Information. This Privacy Policy as specified above regulates and describes the processes of Personal Information collection, processing, and use.

For avoidance of doubt, any Client’s activity when it uses Residential Proxies is not logged, which means that we have no notion about the webpages visited by the Clients or any actions on such webpages.

1.1 PERSONAL DATA AND INFORMATION PROVIDED BY THE CLIENT

You may provide Personal Data when You:

  • Use the Website. The Client provides Personal Data during Registration, using of the Account and functionalities of Website. Such Personal Data may include:

  • Email address (Login);

  • Password;

  • Information about Client’s cryptocurrency wallet, which is used for changing off the Fees and transfer the amounts due to the Client as a refund and/or under Referral Program;

  • Transactions information;

  • Username under third-party account used for registration (Google, Facebook and etc.);

  • E-mail address under third-party account;

  • Any other information under the third-party account that is available and can be transferred according to the regulations of such third parties.

  • Use Third Parties Applications, including Payment Processors, which may request You to provide the following Personal Data in order provide services enabling Clients to pay the Fees to the Company:

  • Details of Your card or cryptocurrency wallets;

  • Any other information required for the billing (this may include identification documents, including image in photo, copies of any other documents necessary for identification purposes, information deemed necessary to comply with third parties’ legal obligations under applicable financial or anti-money laundering laws (if applicable in any jurisdiction)).

For avoidance of doubt, all questions of data flow, processing, use and storage of Personal Data provided by the Client to the third parties are reflected in respective privacy policies with such third parties. The Company therefore has no responsibility or liability for the activities of these third parties.

  • Communicate to the Company: When You choose the “contact us” option we may ask for and collect the following information:

  • Full name;

  • Phone number;

  • Additional contact information;

  • Any other information that we need to help with your request.

Please note that the Company does not intentionally process any special categories of Personal Data (including any information about your health, race, religion, political views, etc.). The Company kindly recommends the Client remains cautious when sharing this data when using the System, on the websites (forums, commentaries, etc.) and otherwise on the Internet. The Company also does not knowingly collect solicit Personal Data from, or knowingly allow the Clients under 18 years old. If the Company discovers that the Company holds Personal Data relating to the Client under 18 years of age, the Company will promptly delete the Personal Data from the Company’s records. If the Client has reason to believe the Company holds Personal Data relating to a Client under 18 years of age that is not permitted, please contact the Company at e-mail specified in section 10 of this Privacy Policy.

2. LEGAL BASIS AND USE OF PERSONAL DATA

2.1. Personal Data is processed and stored only in compliance with the applicable data protection legislation and by relying on one or more of the following lawful grounds:

Legal Basis

Explanation

Contractual obligations

Personal Data is to be processed to carry out Company’s obligations to maintain the System and render respective services arising from the Terms of Service entered into between the Company and the Client or to take necessary steps for contracting the Client if the Client requests that. Personal Data will be used in order to let the Client to use the System in accordance with the Terms of Service.

Legal obligation

The Company can process Client’s Personal Data, if it’s required by law, specifically in order to assist any authority with their investigation as it may be required by law, to detect and prevent fraud and other illegal or prohibited activities, to comply with applicable financial or anti-money laundering laws (if applicable in any jurisdiction).

Legitimate interest

The Company can use Client’s Personal Data to monitor, analyze and improve the System, the Website’s performance and functionalities.

Consent

By accepting the Terms of Service the Client gives explicit consent to processing of Personal Data listed in this Privacy Policy in the ways and purposed stated herein.

Where the Client has consented to the processing of Personal Data, the Client may withdraw such consent at any time. Please note, however, that in certain circumstances it may be still lawful for the Company to continue processing even where consent has been withdrawn, if one of the other legal bases described above is applicable.


2.2 USE OF PERSONAL DATA

The Company processes the Client’s Personal Data as the Company aims at enabling Client’s use of the System. The Company is trying its best to make the System efficient and convenient. Client’s Personal Data can be used in one or more of the following ways:

  • to perform identification of the Client, so the Client can log in the Account;

  • to carry out our obligations arising from the Terms of Service;

  • to communicate with the Client with the regards to the System, including to send information including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages;

  • to notify the Client about any changes to the System, Terms of Service or other important matters related to the use of the System;

  • to protect against fraudulent, unauthorized or illegal activity;

  • to operate, develop and improve the System;

  • for statistical analysis;

  • to conduct advertising and marketing activity;

  • to conduct surveys and research;

  • to administer the Account and for internal record keeping;

  • to contact the Client on other matters.

3. SHARING CLIENT’S PERSONAL DATA

  1. Personal Data may be transferred to the following categories of processors of Personal Data:

  • companies who technically supplies the System, including server and hosting companies;

  • analytical service companies, advertising partners and other companies with regard to improve the System;

  • Payment Processors;

  • governmental authorities or legal advisors in case criminal or improper behaviour is suspected;

  • persons/companies with which the Company does a business deal, or negotiates a business deal, involving the sale or transfer of all or a part of the Company’s business or assets. These deals can include any merger, financing, acquisition, or bankruptcy transaction or proceeding;

  • auditors and other examination organizations;

  • other actors, if it is necessary for the proper provision of services for the Client and/or if required by the Company according to law or authority’s injunction.

  1. The Company may transfer the Client’s data to Company’s counterparties (partners, affiliates, etc.) in different countries. The Client’s Personal Data may be stored, transferred, and otherwise processed in countries outside of the country of Client’s residence, which are countries within the EEA or granted recognition of adequacy by the European Commission and countries which are not granted recognition of adequacy by the European Commission.

  2. The Company shall protect Personal Data when it is transferred to recipients outside the EEA and take all reasonably necessary steps to ensure that Personal Data is treated securely and in accordance with this Privacy Policy. Nonetheless, the Client confirms that he understands and accepts that these countries may have differing laws granting lower level of protection to Personal Data and that such Personal Data can become subject to the laws and disclosure requirements of such countries, including disclosure to governmental bodies, regulatory agencies and private persons, as a result of applicable governmental or regulatory inquiry, court order or other similar process. For avoidance of doubt, by accepting this Privacy Policy the Client accepts that Personal Data can be transferred to the country which is not granted recognition of adequacy by the European Commission.

4. THIRD PARTIES AND THEIR PRIVACY POLICIES

Company’s Website may contain links to other Third-Party Applications not controlled or operated by the Company. Therefore, the Company cannot be responsible for the protection and privacy of any information which the Client provides whilst visiting such Third-Party Applications and their sites and platforms are not governed by this Privacy Policy.

5. SECURITY

  1. In order to prevent unauthorized access or disclosure, the Company uses effective physical, electronic and managerial procedures to secure Personal Data. The Company does its best to protect the Client’s Personal Data, it’s not possible to guarantee the security of information transmitted to the Website. But once the Company has received Client’s Personal Data, strict procedures and security features to prevent unauthorized access will be used.

  2. The Company also cannot guarantee that loss, misuse, unauthorized acquisition, or alteration of Client’s Personal Data will not occur. The Client confirms that when registering on the Website it is vital to choose a password of sufficient length and complexity, not to disclose login and password to any third parties.

6. CLIENT’S RIGHTS

  1. Taking into consideration the differences in data protection laws which may be applicable to the Client by virtue of the Client’s citizenship, residence and other factors, usually data protection laws grant the data subject (the Client) the following data protection rights which are applicable to this Privacy Policy and Personal Data processing by the Company as well:

6.1.1. Right to information. The Client has the right to request information about the scope of Personal Data processed by the Company by notifying in writing.

6.1.2. Right to access. The Client has the right to receive one (1) copy of the processed Personal Data without any charge. For further demanded copies, the Company will charge the fee.

6.1.3. Right to rectification. The Client has the right to rectify inaccurate Personal Data concerning that Client via a written request.

6.1.4. Right to erasure (“right to be forgotten”) and to restrict processing. The Client has the right to demand deletion or restriction of processing, and the right to object to processing based on legitimate interest under certain circumstances unless the Company has an opposite obligation required by applicable law. In these cases the Company can stop providing opportunity to use the System if it is no longer possible so please consider this when deciding to exercise these rights.

6.1.5. Right to portability. The Client has the right to exercise the right of data portability, which means a right to get Personal Data and transfer these to another controller.

6.1.6. Other rights. The Client has other rights in accordance with this Privacy Policy and applicable laws.

  1. The Client understands and confirms that if law applicable to the Client does not guarantee him any of the rights listed above, the Company is not obliged to fulfill such request.

  2. In order to exercise data processing rights stated in the table above, the Client should send the Company a request via the Company’s support service e-mail specified in section 9 and follow the instructions provided or send the Company such a request directly through the Client’s Account settings (where available).

  3. Please note that in some cases, in order to comply with a request, the Company may ask the Client to provide the Company with some additional information where this is necessary to identify the Client (as specified in clause 1 of the Privacy Policy). The Company undertakes to comply with the Client’s request free of additional charge within one month of receipt, but in some cases this period may be extended by a further two months. The Company has the right to refuse to comply with the Client’s request or charge a reasonable fee if the Client’s request is manifestly unfounded or excessive.

7. HOW LONG PERSONAL DATA WILL BE PROCESSED

  1. The Company retains any of the Client’s Personal Data which the Company collects for as long as the Client’s Account is active according to the Terms of Service, and/or for as long as it is necessary to provide the Client with the System, and while the Company has a valid lawful basis for processing Personal Data. The Company also erases the Client’s Personal Data after reaching the purposes for which the Company collected such data.

  1. Please consider that the Company has the right to continue to retain some of the Client’s Personal Data even after complying with the Client’s request to delete such Personal Data in the following cases:

  • The Company has the lawful basis to further process the Client’s data other than a consent from the Client. As instance, the Company may be required to do so in order to comply with applicable laws (as instance, for tax or accounting reasons, know-your-client, anti-laundering or other legal requirements and obligations);

  • The Client’s Personal Data has been anonymized in the way it cannot be used for identifying the Client, and therefore is no longer the Client’s personal identifiable data.

8. DIRECT MARKETING RIGHTS AND OPT-OUT OPPORTUNITIES

8.1 As the Company is entitled to send the Client direct marketing messages or emails (as specified in clause 2.2.), the Client is entitled to unsubscribe from each of such mailings by exercising the Client’s opt-out rights as specified below. The Client acknowledges that refusal to receive direct marketing messages from the Company does not affect the Company’s right to send the Client other messages, emails or otherwise contact the Client as allowed by virtue of this Privacy Policy.

8.2 If the Client wishes to opt-out the processing of Personal Data regarding certain purposes, the Client should send the Company a request via contact e-mail specified in section 9 of this Privacy Policy.

8.3 Please take into consideration the following:

  • opting-out certain processing purposes may lead to impossibility of providing the Client certain (or even all) functionalities of the System in part (or at all). The Company will take the Client’s best efforts to minimize such System limitations.

  • opt-out opportunity applies only to the processing of Client’s Personal Data based on the Client’s consent (as specified in clause 2.1.), unless otherwise is explicitly stated by the applicable law. The Company reserves the right to process Personal Data based on the other lawful basis such as contractual obligations, legitimate interest or legal obligation, if available by virtue of applicable law, even if the Client has opted out such processing according to the provisions of this Privacy Policy.

9. CONTACT INFORMATION

If the Client has any questions about this Privacy Policy or about use of Personal Data, then the Client may contact the Company at [email protected].

10. CHANGES TO THIS PRIVACY POLICY

10.1 The Company may change this Privacy Policy at any time. If the Company makes any changes, the Company will change the Last Updated date above. The Client undertakes to check such changes by itself. Any updates to this Privacy Policy shall become valid as of publication on the Website (Last Updated date).

10.2 In case of substantial changes, the Company reserves the right to update the Privacy Policy subject to a relevant update notice and refreshing the Client’s consent. Unless the Client agrees with the revised version of the Privacy Policy, the Company reserves the right to suspend use of the System which require the Client’s data processing by the Company.

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