Last updated: 26 October 2018

BroVPN Ltd. ("BroVPN", "we" or "us") is the owner of the website BroVPN.io (the" Site") providing the BroVPN software (the" Software") and any related services, content and applications offered by us (collectively referred herein as the "Services"). We are committed to protecting your privacy and have developed this Privacy Policy to help you decide whether to use our Services. By accessing or using the Services, or providing information to us in other formats, you agree to accept the terms of this privacy Policy as may be amended, and agree to the collection and use of information in the manner set forth in this Privacy Policy. We encourage you to read this privacy Policy carefully and review it periodically to understand all of these rules and to be aware of any changes. IF YOU DO NOT AGREE WITH THE TERMS OF THIS PRIVACY POLICY, PLEASE IMMEDIATELY DISCONTINUE USE OF THE SERVICES AND UNINSTALL THE PROGRAM.

What types of data do we collect?

We collect the following types of data when you use our Services:

• Log data: log data may include the following information: browser type, list of visited web pages, time spent on these pages, date and time of access.

• Personal Information: Personal information is information of a private or confidential nature that can identify or identifies you. The personal information we may collect and store includes your IP address, your name and email address, nickname, billing and payment information, or other information we may request from time to time that is required to register and provide the services. When you create an account on the Services, you can use your credentials from third-party websites or services ("Third-party account"), such as Gmail®. This will allow you to link your account on our site to an account on a third-party site. If you select this option, a pop-up window appears with the Third-party account. In order to proceed, you need to agree to the Terms of use and read the information about what types of data we will receive. This information includes your personal information stored in your account on the Third-party site, such as your username, email address, profile picture, date of birth, gender and preferences. Any anonymous information that is directly related to any Personal data is treated by us as Personal Information as long as such connection exists.

• Registration with a social network account. When you register or sign-in to the Services using your accounts in social networks (e.g. Facebook, Google+), we have the access to the basic information of your account in the social network, such as your full name, home address, email address, date of birth, profile picture, friends list, a personal description, and any other publicly available information of your account or the information you agreed to share with us. We will always comply with the rules, conditions and restrictions of the social network platform.

How do we use your information?

We use your information to provide you with the Services. This means that we will use the information to set up your account, provide you with assistance with the Services, provide two-way communication to send updates, marketing suggestions or solve problems you may have, and conduct statistical and analytical research to improve the Services. Information we share We do not rent or sell any Personal Information. We may disclose Personal Information only to other trusted Third party service providers or partners to provide services to you, store information and Analytics. We may also share or disclose Personal Information with our subsidiaries and affiliates. • We may also share your Personal data and other information in special cases where we have reasonable grounds to believe that it is necessary to: (1) comply with law, regulation, subpoena or court order; (2) detect, prevent or otherwise enforce fraud, breach of our policies or resolve technical issues, ensure security; (3) enforce the provisions of this Privacy Policy or any other agreements between you and us, including investigation of possible violations; (4) protect legal rights, property rights or protect us, our partners and affiliates or other users.

Data processing outside the EEA

Please note that some data recipients may be located outside the EEA. In such cases, we may only share information with recipients located in countries as approved by the European Commission to ensure an adequate level of data protection, or enter into legal agreements to ensure an adequate level of data protection.

Security and privacy

We use industry-standard information, tools and security measures, as well as internal procedures and strict guidelines to prevent misuse of information and data leakage. Our employees are responsible for maintaining confidentiality. We use measures and procedures that significantly reduce the risk of data misuse, but we cannot guarantee that our systems will be completely safe. If you become aware of any potential data breach or security vulnerability, you should contact us immediately. We will use all measures to investigate the incident, including preventive measures if necessary.

Your Choices and Rights

We are committed to providing you with the ways to quickly update your information or delete it unless we store that information for legitimate business or legal purposes. When updating your personal information, we may ask you to verify your identity before we can act on your request. If you are a resident of the state of California, USA, you have the right to send us a written request, including a list of categories of Personal Information that we may have disclosed to Third parties or that we may have provided to Third parties, as well as the details about such Third parties. If you live in the European Union, please note that the following rights apply to your Personal Information: (1) to receive confirmation of whether Personal Information relating to you is processed and to access your stored Personal Information together with additional information; (2) To receive a copy of the Personal Information that you directly provide to us voluntarily in a structured, standard machine-readable format; (3) To request the correction of your personal data that are under our control; (4) Request the deletion of your Personal Information; (5) Oppose the processing of Personal Information; (6) Request that we restrict the processing of your Personal Information; (7) File a complaint with the Supervisory authority. However, please note that these rights are not absolute and may be subject to our legitimate interests and regulatory requirements. To exercise this right, you may contact us by e-mail: help@brovpn.io

Retention

We retain your Personal Information for as necessary to the Services and, if necessary, comply with our legal obligations, resolve disputes and enforce our policies. In accordance with applicable regulations, we will maintain records containing customer's Personal Information, account opening documents, communications and everything else as required by applicable laws and regulations. We may correct, supplement or delete incomplete or inaccurate information at any time in our sole discretion.

Cookies

When you use our site, we may store cookies on your computer (and use other tracking technologies, such as web beacons and pixels) to help us tailor our site to you and make it easier to use. A “cookie” is a small text file of data that a website stores on your computer's hard drive (if allowed by your web browser), which can then be retrieved so that we can identify you. Our cookies may store information about your account. You can always refuse the use of cookies if your browser has an appropriate add-on, but this may result in some features of our site not working properly and your online access may be restricted. We also use Google Analytics to collect information about your use of the Site. Google's ability to use and share information collected by Google Analytics about your visits to the Site is limited to the Google Analytics Terms of Service and Google's Privacy Policy.

Limitation of liability

Notwithstanding anything stated in this Security Policy, we are not responsible for the accuracy, correctness or security of any information we collect, store or disclose to you or anyone else. Our Policy applies only to the use and disclosure of information we collect from you. To the extent that you provide your information to other parties or sites on the Internet, different rules may apply to their use or disclosure of the information you provide to them. Accordingly, we encourage you to read the terms and conditions and privacy policies of each third party to whom you choose to provide information.

Change of ownership

In the event of a change of ownership or loss of the control over any part of BroVPN, including the ability to acquire, merge or sell the company, we reserve the right to transfer all or part of the personal and anonymous information we store on our systems. You also acknowledge that in the event of bankruptcy, insolvency or receivership, we cannot control the use and transfer of your personal information.

Changes to this Privacy Policy

This Policy may be revised from time to time at our sole discretion, so please review it regularly. The latest changes will be reflected in the "Last updated" link. Any change to this policy will be posted on the website. Your continued use of the Services after any such changes will be reviewed as you agree to the amended Privacy Policy.

Contact us

If you believe that your confidential data has not been processed in accordance with our Privacy Policy or if you believe that your Personal Information has been compromised by any person in the course of using our Services, please contact BroVPN by email: help@brovpn.io and our privacy officer will immediately consider the appeal. © 2018 BroVPN Ltd. All rights reserved.

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