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EASYASVPN (FREE DOWNLOAD)

PROTECT YOURSELF ONLINE WITH A POWERFUL FREE VPN APP FOR MICROSOFT WINDOWS

All rights reserved

Install FreeVPN to hide your Online Identity, encrypt your Internet Connection,
and access geo-blocked websites. Optional sponsored offers might be presented
during the installation process. Free Download.



Terms of Use are followed by our Privacy Policy



==========================

End User License Agreement

==========================

Last updated: June 19th, 2019

This end user license agreement (“EULA”) governs your download and use of the
executable code for the EasyAsVPN software application including any update or
upgrade thereto (“EasyAsVPN” or the “Application” or the “Software”), including
any update or upgrade thereto (“Software”). This EULA forms a binding contract
between you and Secure Privacy Group Limited (the “Company”).

Your use of EasyAsVPN is subject to the terms and conditions set forth in this
End User License Agreement, the Company Terms of Service and Privacy Policy

PLEASE READ THE EULA CAREFULLY. BY ACCESSING OR USING ANY PART OF THE SOFTWARE,
YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTAND AND AGREE TO BE BOUND BY ALL THE
TERMS OF THIS EULA. IF YOU DO NOT AGREE TO THESE TERMS EXIT THIS PAGE OR
APPLICATION AND DO NOT ACCESS OR USE THE SOFTWARE. USE OF THE SOFTWARE IS
EXPRESSLY CONDITIONED UPON YOUR ACCEPTANCE OF THE EULA.

1. Updates to EULA; Integration . We may, in our sole discretion, modify the
terms of this EULA via email or by posting a notice in the application. The
“Last Updated” date at the top the EULA indicates when the latest modifications
were made to the EULA. By continuing to access and use the application you agree
to any such modifications.

2. Grant of License

Subject to the terms and conditions of this License, Company grants you a
limited, personal, non-exclusive, non-transferable, non-sub-licensable and
revocable license to install during the term and solely for your own private
use.

3. Intellectual Property.

3.1 You acknowledge and agree that the Software, including its sequence,
structure, organization, source code and applicable documentation, contains
valuable trade secrets and other intellectual property of Company. The Software
is licensed and not sold to you, and no title or ownership to such Software or
the intellectual property rights embodied therein is granted to you. The
Software is the exclusive property of the Company and all rights in and to the
Software not expressly granted to you in this Agreement are reserved. Nothing in
this EULA will be deemed to grant, by implication, estoppel or otherwise, a
license under any existing or future patents of the Company, except to the
extent necessary for you to use the Software as expressly permitted under this
EULA. You acknowledge and agree that any actual or threatened breach of this
EULA will constitute immediate, irreparable harm to Company for which monetary
damages would be an inadequate remedy, and that injunctive relief is an
appropriate remedy for any such breach or violation.

3.2 This EULA will commence upon your download of the Software and continue in
perpetuity unless terminated earlier as provided herein. This EULA will
immediately terminate upon your breach of any of the terms or conditions set
forth herein. Upon the termination of the EULA, you will discontinue all use of
the Software, promptly destroy or have destroyed the Software and any copies
thereof, and, upon request by Company, certify in writing that such destruction
has taken place. These remedies are cumulative and in addition to any other
remedies which may be available.

3.3 You may not (i) copy, reproduce, change, modify, or create a derivative work
of EasyAsVPN; (ii) remove or in any way obscure any ownership or trademark
notices on EasyAsVPN; (iii) sublicense, sell, rent, lease, transfer, assign,
display, host, outsource, disclose, distribute or otherwise make commercial use
of EasyAsVPN; (iv) circumvent any activation or license key, or other similar
method used to protect EasyAsVPN against unlicensed use, copying or
distribution; (v) post or otherwise make available EasyAsVPN or any portion
thereof, including the activation key, on the Internet or other publicly
available forum; or (vi) export or re-export EasyAsVPN or any underlying
technology in violation of the export laws of the United States, the European
Community or any other applicable laws or regulations.

3.4 You may not copy, decompile, reverse engineer, disassemble, attempt to
derive the source code of, modify, or create derivative works of the Software.
You may not remove, obscure, or alter any copyright notice or other proprietary
rights notices affixed to or contained within the Software. You may not separate
the component programs of the Software for use on different computers or
sublicense, lease, rent, loan, or distribute the Software to any third party.
You may not permit, direct or authorize any third party to take any action with
respect to the Software which is inconsistent with the terms set forth in this
EULA.

5. Prohibited Uses.

5.1 You may not do any of the following while accessing or using EasyAsVPN.

(i) access, tamper with, or use non-public areas of the application, our
computer systems, or the technical delivery systems of our providers;

(ii) probe, scan, or test the vulnerability of any system or network or breach
or circumvent any security or authentication measures;

(iii) access or search or attempt to access or search the application by any
means other than through our currently available, published interfaces that are
provided by us, unless you have been specifically allowed to do so in a separate
agreement with us;

(iv) forge any TCP/IP packet header or any part of the header information in any
email or posting, or in any way use the application to send altered, deceptive
or false source-identifying information; or

(v) disrupt or interfere with the access of any user, host or network,
including, without limitation, sending a virus, overloading, flooding, spamming,
mail-bombing the application, or otherwise creating an undue burden on our
services.

5.2 You may not use manual or automated software, devices, or other processes to
“crawl,” “scrape,” or “spider” the application. You will not decompile, reverse
engineer, or otherwise attempt to obtain the source code of any part of the
application.

5.3 You further agree that you will not access the application by any means
except through the interface provided by Company for access to the application.
Creating or maintaining any link from another application to any page at the
Site, without the prior authorization of Company is prohibited

6. Updates. Company may provide you with Updates from time to time at no charge
during the term of this Agreement. For the purposes hereof, “Update” means any
additional versions of the EasyAsVPN containing technical modifications, updated
information, altered functionality, or any other changes that are intended by
the Company to improve or to add to, delete or otherwise modify any aspect of
the EasyAsVPN. Company may push Updates to you over the Internet via EasyAsVPN
by automatically downloading and installing them from time to time. You agree to
allow EasyAsVPN to receive such Updates as part of your use of the Software.

7. Fees.

7.1 EasyAsVPN is free to download and use.

8. The Software may provide for access to additional services.

8.1 To support our business and to continue to provide you with the Software for
free, we may offer to deliver the Software along with certain additional
in-house and 3rd-party software components. You are not required to download any
additional software to use EasyAsVPN. The software components may include, but
are not limited to:

a. "Idle Resources Mode.” By downloading and installing EasyAsVPN on your
computer, you permit us to direct your DNS settings to our servers or third
party DNS servers and route your internet connection through our VPN servers, so
that you can access different popular streaming services and websites from
anywhere in the world. In exchange, Company at its own discretion has the right
to turn your device into a Networking Peer and enable a local proxy which will
allow our network servers to use your Internet connection and access different
Internet services through it. In the event you uninstall EasyAsVPN, Idle
Resources Mode shall also uninstall. You can also opt out of Idle Reources Mode
while keeping the software installed from the About Menu item.

9. Termination . You may terminate your use of the Software at any time by
uninstalling the Software. You agree that Company may terminate or suspend your
access to the Software, with or without notice, in our sole discretion, at any
time. Following the termination or cancellation of your access to the Software
and/or your account, we reserve the right to delete all your data in the normal
course of operations.

10. Representations. You expressly represent, warrant, and/or acknowledge that:

10.1 The information contained herein is for informational purposes only and is
not intended as or should be construed as advice or recommendations and are not
guaranteed to produce results.

10.2 Company does not warrant or guarantee the suitability or availability of
any material or content, including without limitation any, data, products or
services, found through the Software.

10.3 Company does not screen the authenticity or quality of any material or
content or any provider of material or content, including, data, products or
services found through the Software.

10.4 Company makes no representations or promises regarding any material or
content, and that some of the material or content provided via the Software may
be owned or licensed by Third Parties.

11. Warranties, Disclaimers and Limitations of Liability .

YOU EXPRESSLY UNDERSTAND AND AGREE THAT:

11.1 YOUR USE OF THE SOFTWARE IS AT YOUR SOLE RISK. THE SOFTWARE AND THE
ASSOCIATED MATERIALS AND CONTENT ARE PROVIDED ON AN “AS IS” AND “AS AVAILABLE”
BASIS. EXCEPT AS OTHERWISE EXPRESSLY PROVIDED IN THIS EULA. COMPANY, ITS PARENT,
SUBSIDIARY AND OTHER AFFILIATED COMPANIES, AND THEIR RESPECTIVE OFFICERS,
DIRECTORS, EMPLOYEES, AGENTS AND OTHER REPRESENTATIVES (COLLECTIVELY, THE
“COMPANY PARTIES”), EXPRESSLY DISCLAIM ALL WARRANTIES OF ANY KIND, WHETHER
EXPRESS OR IMPLIED, INCLUDING, BUT NOT LIMITED TO THE IMPLIED WARRANTIES OF
MERCHANTABILITY, FITNESS FOR A PURPOSE AND NON-INFRINGEMENT. WITHOUT LIMITING
THE GENERALITY OF THE FOREGOING, THE COMPANY PARTIES MAKE NO WARRANTY THAT: (I)
THE SOFTWARE WILL MEET YOUR REQUIREMENTS; (II) THE SOFTWARE WILL BE
UNINTERRUPTED, TIMELY, SECURE, OR ERROR-FREE; (III) INFORMATION THAT MAY BE
OBTAINED VIA THE SOFTWARE WILL BE ACCURATE OR RELIABLE; (IV) THE QUALITY OF ANY
AND ALL PRODUCTS, SOFTWARES, INFORMATION OR OTHER MATERIAL, INCLUDING ALL
MERCHANDISE, GOODS AND SOFTWARES, OBTAINED OR PURCHASED BY YOU DIRECTLY OR
INDIRECTLY THROUGH THE SOFTWARE WILL MEET YOUR EXPECTATIONS OR NEEDS; AND (V)
ANY ERRORS IN THE SOFTWARE WILL BE CORRECTED.

11.2 THE COMPANY PARTIES SHALL NOT UNDER ANY CIRCUMSTANCES BE LIABLE FOR ANY
DAMAGES OF ANY KIND ARISING OUT OF, IN CONNECTION WITH OR RELATING TO THE USE OF
OR INABILITY TO USE THE SOFTWARE, INCLUDING ANY LIABILITY: (I) AS A PUBLISHER OF
INFORMATION; (II) FOR ANY INCORRECT OR INACCURATE INFORMATION OR ANY ‘BUG’ OF
THE SOFTWARE; (III) FOR ANY UNAUTHORIZED ACCESS TO OR DISCLOSURE OF YOUR
TRANSMISSIONS OR DATA; (IV) FOR STATEMENTS OR CONDUCT OF ANY THIRD PARTY ON OR
VIA THE SOFTWARE; (V) FOR ANY DISPUTES BETWEEN USERS OF THE SOFTWARE OR BETWEEN
A USER OF THE SOFTWARE AND A THIRD PARTY; (VI) OVERAGE OR EXCESSIVE DATA USAGE
CHARGES BY YOUR ISP OR ANY OTHER PROVIDER; (VII) CLAIMS BY ANY STREAMING SERVICE
PROVIDER RELATED TO ACCESSING SUCH PROVIDERS’ CONTENT BY YOUR INTERNET
CONNECTION, OR (VIII) FOR ANY OTHER MATTER RELATING TO THE SOFTWARE OR ANY THIRD
PARTY. THIS IS A COMPREHENSIVE LIMITATION OF LIABILITY THAT APPLIES TO ALL
DAMAGES OF ANY KIND, INCLUDING ANY DIRECT, INDIRECT, SPECIAL, INCIDENTAL OR
CONSEQUENTIAL DAMAGES, WHETHER BASED ON BREACH OF CONTRACT, BREACH OF WARRANTY,
TORT (INCLUDING NEGLIGENCE), PRODUCT LIABILITY OR OTHERWISE, EVEN IF AN
INDIVIDUAL ADVISES THE COMPANY PARTIES OF THE POSSIBILITY OF SUCH DAMAGES. THE
LIMITATIONS OF LIABILITY SET FORTH HEREIN ARE FUNDAMENTAL ELEMENTS OF THE BASIS
OF THE BARGAIN BETWEEN COMPANY AND YOU. THE PRODUCTS, INFORMATION AND SOFTWARES
OFFERED ON AND THROUGH THE SOFTWARE WOULD NOT BE PROVIDED TO YOU WITHOUT SUCH
LIMITATIONS.

11.3 NOTWITHSTANDING THE FOREGOING, THE SOLE AND ENTIRE MAXIMUM LIABILITY OF THE
COMPANY PARTIES FOR ANY REASON, AND YOUR SOLE AND EXCLUSIVE REMEDY FOR ANY CAUSE
OR CLAIM WHATSOEVER, SHALL BE LIMITED TO THE CHARGES PAID BY YOU DIRECTLY TO
COMPANY VIA THE SERVICE, IF ANY, FOR SERVICES PROVIDED SOLELY AND DIRECTLY BY
COMPANY TO YOU IN THE SIX (6) MONTHS PRIOR TO SUCH CAUSE OR CLAIM.

11.4 YOU AGREE THAT REGARDLESS OF ANY STATUTE OR LAW TO THE CONTRARY, ANY CLAIM
YOU MAY BRING MUST BE FILED WITHIN ONE (1) YEAR AFTER THE CAUSE OF ACTION
OCCURRED OR IT WILL BE PERMANENTLY BARRED.

11.5 SOME JURISDICTIONS DO NOT ALLOW THE DISCLAIMER OF CERTAIN WARRANTIES OR THE
LIMITATION OR EXCLUSION OF LIABILITY FOR CERTAIN TYPES OF DAMAGES. ACCORDINGLY,
SOME OF THE ABOVE DISCLAIMERS AND LIMITATIONS MAY NOT APPLY TO YOU.

11.6 If you are a California resident, you shall and hereby do waive California
Civil Code Section 1542, which says: “A general release does not extend to
claims which the creditor does not know or suspect to exist in his favor at the
time of executing the release, which, if known by him must have materially
affected his settlement with the debtor.”

12. Indemnification. You agree to indemnify, defend and hold harmless the
Company Parties against all claims, demands, causes of action, losses, expenses,
damages and costs (including any reasonable attorneys’ fees), resulting or
arising from or relating to your use of the Software, any activity related to
your account by you or any other person permitted by you, any Content that you
submit to, post on or transmit through the Software, your breach of this EULA,
your infringement or violation of any rights of another, or termination of your
access to the Software. We reserve the right to assume, at our sole expense, the
exclusive defense and control of any such claim or action and all negotiations
for settlement or compromise, and you agree to fully cooperate with us in the
defense of any such claim, action, settlement or compromise negotiations, as
requested by us.

13. Applicable Law and Jurisdiction . Your use of the Software is governed by
and will be enforced under the laws Hong Kong without regard to its conflict of
law provisions. You agree to submit to the personal and exclusive jurisdiction
of the courts located within the above stated jurisdiction. You agree that
printed copies of any and all agreements and/or notices in electronic form are
admissible in any legal or regulatory proceedings. Any such controversy, claim,
suit, injury or damage shall be arbitrated on an individual basis and shall not
be consolidated in any arbitration with any controversy, claim, suit, injury or
damage of any other party. Company may seek any interim or preliminary relief
from a court of competent jurisdiction in the State listed above necessary to
protect its rights pending the completion of arbitration. Each party shall
assume its own costs of arbitration. IN ANY CLAIM, ACTION OR PROCEEDING TO
ENFORCE ANY RIGHT OR OBLIGATION OF THE PARTIES UNDER THE EULA INCLUDING, WITHOUT
LIMITATION, RELATING TO YOUR USE OF THE SOFTWARE, YOU HEREBY WAIVE ANY RIGHT YOU
MAY NOW HAVE OR HEREAFTER POSSESS TO A TRIAL BY JURY.

14. Miscellaneous. This EULA constitute the entire agreement between Company and
each user of the Software with respect to the subject matter of this EULA.

a. If any provision of this EULA shall be deemed unlawful, void or for any
reason unenforceable by a court of competent jurisdiction, the validity and
enforceability of any remaining provisions will not be affected.

b. The failure of the Company Parties to insist upon strict adherence to any
term of this EULA shall not constitute a waiver of such term and shall not be
considered a waiver or limit that party’s right thereafter to insist upon strict
adherence to that term or any other term contained in this EULA. You may not
assign your obligations or rights hereunder to another entity or individual. We
may transfer, assign or delegate this EULA and its rights and obligations
without your consent.

c. We shall have no liability to you hereunder if we are prevented from or
delayed in performing our obligations, or from carrying on our business, by
acts, events, omissions or accidents beyond our reasonable control, including,
without limitation, strikes, lock-outs or other industrial disputes (whether
involving the workforce of us or any other party), failure of a utility service
or transport or telecommunications network, act of God, war, riot, civil
commotion, malicious damage, compliance with any law or governmental order,
rule, regulation or direction, accident, breakdown of plant or machinery, fire,
flood or storm.

d. No agency, partnership, joint venture, or employment is created as a result
of this EULA and you do not have any authority of any kind to bind us in any
respect whatsoever.

e. No action arising out of this EULA or your use of the Software, regardless of
form or the basis of the claim, may be brought by you more than one (1) year
after the cause of action has arisen (or if multiple causes, from the date the
first such cause arose).

15. Customer Service . If you have any comments or questions regarding this EULA
or wish to report any violation of this EULA, you may contact us at the address
below.

Secure Privacy Group Limited

20th Floor, Central Tower

28 Queen's Road Central

Hong Kong

support@secureprivacygroup.com

==============

Privacy Policy

==============

LAST UPDATE: June 19th, 2019

Introduction.

1.1 Secure Privacy Group Limited (“Company,” or “we,” or “us,” or “our”) is
committed to safeguarding the privacy of our website and service users (“users,”
or “you”).

1.2 This Privacy Policy applies to our website at https://easyasvpn.com and
other websites on the internet (the “Sites”) and when you download our EasyAsVPN
software.

1.2 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.

1.3 Terms of Service and End User License Agreement. Use of the Service is
subject to the terms of our Terms of Service and our End User License Agreement
which are hereby incorporated and made part of this Privacy Policy. By using the
Service, you agree to be bound by our Terms of Service and End User License
Agreement.

1.4 Your use of the Service is subject to the terms and conditions set forth in
this Privacy Policy (the “Privacy Policy”).

1.5 We continually strive to find new ways to enhance your experience with the
Service and we may modify this Privacy Policy from time to time to reflect
changes in our privacy practices. You are encouraged to review this Privacy
Policy periodically and to check the “Last Updated” date at the top of the
Privacy Policy for the most recent version. If we make changes to this Privacy
Policy, we will notify you here, by email, or by means of notice through the
Website, the Application, or any other part of the Service in our sole
discretion.

PLEASE READ THIS PRIVACY POLICY CAREFULLY. BY ACCESSING OR USING THE SERVICE,
YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTAND, AND AGREE TO BE BOUND BY ALL THE
TERMS OF THIS PRIVACY POLICY. IF YOU DO NOT AGREE TO SUCH TERMS, EXIT THIS PAGE
AND DO NOT ACCESS OR USE THE SERVICE.

2. Types and Uses of Collected Information. Company collects two types of
information about you:

Company collects two types of information about you:

2.1 Personally Identifiable Information. Personally Identifiable Information is
information that identifies a specific person. When you engage in certain
activities via the Company Service, including but not limited to creating an
account, sending feedback, or otherwise participating in the Company 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 about them to you, and populate
forms for future transactions. When you enroll in the Company Service, we may
also ask you to provide us with additional information, such as credit card
information. Depending on the Identification Activity, some of the information
we ask you to provide may be identified as mandatory and some identified as
voluntary. If you do not provide mandatory information for an Identification
Activity, you will not be permitted to engage in that Identification Activity
with the Company Service. Depending on the Identification Activity, Company
might not re-ask you for Personally Identifiable Information if such are already
stored with us. If you enroll in the Company Service through a third party (such
as Facebook or Google) then Company may receive Personally Identifiable
Information from such third party and by using the Company Service, you consent
to such receipt of Personally Identifiable Information and its use pursuant to
this Privacy Policy by Company.

We may use or share Personally Identifiable Information to provide products
and/or services to enhance the operation of the Company Service, improve our
marketing and promotional efforts, analyze use of the Company Service, improve
the Company Service, and tailor your experience with third parties as provided
below in this Privacy Policy. We may also use Personally Identifiable
Information to troubleshoot, resolve disputes, accomplish administrative tasks,
contact you, enforce our agreements with you, including our Terms of Service and
this Privacy Policy, comply with applicable law, and cooperate with law
enforcement activities.

2.2 Non-Personally Identifiable Information. Non-Personally Identifiable
Information is information that does not identify a specific person. This type
of information may include things like the Uniform Resource Locator (“URL”) of
the website you visited before coming to the Company Service or otherwise
participating in the Company Service, the URL of the website you visit after
leaving the Company Service, the type of browser you are using, your Internet
Protocol (“IP”) address, mobile carrier information, mobile device information,
or general and/or aggregated location data that does constitute Personally
Identifiable Information. We, and/or our authorized Third-Party Service
Providers, may automatically collect this information when you visit or use the
Company Service using electronic tools like Cookies and Web beacons or Pixel
tags, as described below in this Privacy Policy. Most of the other information
we collect for mobile, such as your mobile device identification and mobile
device type, the request type, your mobile carrier, your mobile carrier user
identification, and the content of your request, does not by itself identify you
to Company, though it may be unique or consist of or contain information that
you consider personal. We use Non-Personally Identifiable Information to
troubleshoot, administer the Company Service, analyze trends, gather demographic
information, comply with applicable law, and cooperate with law enforcement
activities. We may also share this information with our authorized Third-Party
Service Providers to measure the overall effectiveness of our products and
services.

2.3 Information We Retain.

(a) We track and store app 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 record access logs of our DNS to find and handle technical issues while
resolving different domains. Those logs are archived every midnight (UTC) and
deleted after 7-days.

(d) We keep access logs for our Smart DNS API, to track which IP addresses
require access to our Proxy servers and grant access. Those logs are archived
every midnight (UTC) and deleted after 7-days.

(e) We keep bandwidth usage log of data transmitted (upload and download) during
your VPN and Proxy sessions.

(f) A time stamp when you connect and disconnect to our VPN service or Proxy
servers.

(g) The IP address used by you to connect to our VPN or Proxy servers.

Company DOES NOT monitor nor store any of the data sent or received over the VPN
tunnel.

3. How we use your personal data.

3.1 In this Section 2 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.

3.2 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.

3.3 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.

3.4 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.

3.5 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.

3.6 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.

3.7 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.

3.8 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.

3.9 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.

3.10 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.

3.11 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.

3.12 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 Service, 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.

5.4 We use cookies for the following purposes:

(a) authentication - we use cookies to identify you when you visit our website
and as you navigate our website.

(b) status - we use cookies to help us to determine if you are logged into our
website.

(c) personalization - we use cookies [to store information about your
preferences and to personalize the website for you.

(d) security - we use cookies as an element of the security measures used to
protect user accounts, including preventing fraudulent use of login credentials,
and to protect our website and services generally.

(e) advertising - we use cookies to help us to display advertisements that will
be relevant to you.

(f) analysis - we use cookies [to help us to analyze the use and performance of
our website and services; and

(g) cookie consent - we use cookies [to store your preferences in relation to
the use of cookies more generally.

6. Cookies used by our service providers

6.1 Our service providers use cookies and those cookies may be stored on your
computer when you visit our website.

6.2 We use Google Analytics to analyze the use of our website. Google Analytics
gathers information about website use by means of cookies. The information
gathered relating to our website is used to create reports about the use of our
website. Google's privacy policy is available at:
https://www.google.com/policies/privacy/.

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:

(a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);

(b)
https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences
(Firefox);

(c) http://www.opera.com/help/tutorials/security/cookies/ (Opera);

(d)
https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies
(Internet Explorer);

(e) https://support.apple.com/kb/PH21411 (Safari); and

(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy
(Edge).

7.2 Blocking all cookies will have a negative impact upon the usability of many
websites.

7.3 If you block cookies, you will not be able to use all the features on our
website.

8. Analytics

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 regulatory authorities for a full explanation of these
rights.

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. 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.

9.4 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.

9.5 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.

9.6 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.

9.7 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.

9.8 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. You may do so in the EU
member state of your habitual residence, your place of work or the place of the
alleged infringement.

9.9 You may also choose to contact our Data Privacy Officer at
info@secureprivacygroup.com

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.

10. Children.

The Service are not directed to people under the age of eighteen (18) or the age
of majority in the jurisdiction where you reside 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 child
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 This Section 11 sets out our data retention policies and procedure, which
are designed to help ensure that we comply with our legal obligations in
relation to the retention and deletion of personal data.

11.2 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.

11.3 Notwithstanding the other provisions of this Section 11, 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.

12. Notice of Privacy Rights to California Residents . California law requires
that we provide you with a summary of your privacy rights under the California
Online Privacy Protection Act (“COPPA”) and the California Business and
Professions Code. As required by COPPA, we will provide you with the categories
of Personally Identifiable Information that we collect through the Service and
the categories of third-party persons or entities with whom such Personally
Identifiable Information may be shared for direct marketing purposes at your
request. California law requires us to inform you, at your request, (1) the
categories of Personally Identifiable Information we collect and what third
parties we share that information with; (2) the names and addresses of those
third parties; and (3) examples of the products marketed by those companies.
COPPA further requires us to allow you to control who you do not want us to
share that information with. To obtain this information, please send a request
by email or physical mail to the address found below. When contacting us, please
indicate your name, address, email address, and what Personally Identifiable
Information you do not want us to share with our marketing partners. The request
should be sent to the attention of our legal department and labeled “California
Customer Choice Notice.” Please allow 30 days for a response. Also, please note
that there is no charge for controlling the sharing of your Personally
Identifiable Information or requesting this notice.

13. Who can I ask if I have additional questions?

For additional inquiries about the privacy of your information, you can contact
us by emailing us at info@secureprivacygroup.com

Secure Privacy Group Limited

20th Floor, Central Tower

28 Queen's Road Central

Hong Kong

support@secureprivacygroup.com

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