Digiproxy Privacy Policy
Effective Date: [Insert Date]
1. Introduction and Scope
1.1. Welcome to Digiproxy
("Company," "we," "us," or "our"). We are a Canadian company operating internationally, providing proxy services and data gathering solutions. We value your privacy and are committed to protecting it through our compliance with this policy.
1.2. Privacy Policy (the "Policy")
This Policy is designed to inform you about our practices regarding the collection, use, and disclosure of information that you may provide via our website [Insert Website URL] (the "Website") and any related services, sales, marketing, or events (collectively, the "Services").
1.3. Applicability of This Policy
This Policy applies to all users of our Services globally, including:
- Visitors to our Website;
- Registered users of our proxy services;
- Clients utilizing our data gathering solutions;
- Any individual who communicates with Digiproxy via email, chat, or other means.
1.4. Agreement to This Policy
By accessing or using our Services, you agree to this Privacy Policy. If you do not agree with our policies and practices, your choice is to not use our Services. We encourage you to read this Policy carefully and contact us if you have any questions or concerns.
1.5. International Compliance
This Policy is designed to comply with data protection laws in various jurisdictions, including but not limited to:
- The Canadian Personal Information Protection and Electronic Documents Act (PIPEDA);
- The European Union's General Data Protection Regulation (GDPR);
- The California Consumer Privacy Act (CCPA);
- The UK Data Protection Act 2018;
- Applicable data protection laws in the Middle East.
1.6. Age Restrictions
Our Services are not intended for individuals under the age of 18. We do not knowingly collect personal information from children under 18. If you are under 18, please do not use or provide any information on our Website or through any of its features.
1.7. Definitions
- "Personal Data" means any information relating to an identified or identifiable natural person.
- "Processing" means any operation performed on Personal Data, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
- "User," "you," and "your" refer to the individual accessing or using the Services, or the company, or other legal entity on behalf of which such individual is accessing or using the Services, as applicable.
- "Cookies" are small text files that websites place on your device to store information about your browsing session and preferences.
- "Data Controller" refers to Digiproxy, which determines the purposes and means of processing personal data.
- "Data Processor" refers to any entity that processes personal data on behalf of the Data Controller.
- "Proxy Services" refer to the intermediary server services provided by Digiproxy that facilitate requests between users and other servers.
- "Data Protection Laws" refer to all applicable laws and regulations relating to the processing of Personal Data and privacy.
1.8. Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes to our practices or for other operational, legal, or regulatory reasons. We will notify you of any material changes by posting the new Privacy Policy on this page and updating the "Effective Date" at the top of this document. We encourage you to review this Privacy Policy periodically for any changes.
2. Information We Collect
2.1. Personal Data:
We collect personal data that can be used to identify you, such as:
- Name;
- Email address;
- Phone number;
- Billing address;
- Payment information (e.g., credit card details, PayPal account);
- IP address;
- User account credentials;
- Communication preferences;
- Transaction and usage history;
- Any other information you provide to us directly.
2.2. Non-Personal Data:
We also collect non-personal data that cannot be used to identify you directly, including:
- Browser type and version;
- Operating system;
- Device information (e.g., device model, screen resolution);
- Language preferences;
- Access times and dates;
- Pages viewed;
- Referring website addresses;
- Exit pages and clickstream data;
- Other technical information about your visit to our Website.
2.3. Cookies and Tracking Technologies:
We use cookies, web beacons, pixel tags, and similar tracking technologies to collect information about your browsing activities. These technologies help us:
- Remember your preferences;
- Understand how you use our Services;
- Improve your user experience;
- Provide personalized content and advertisements;
- Analyze trends and gather broad demographic information;
- Administer the Website, track users' movements, and gather demographic information;
- Remember information so that you will not have to re-enter it during your visit or the next time you visit the site;
- Provide custom, personalized content and information;
- Monitor the effectiveness of our marketing campaigns;
- Monitor aggregate metrics such as total number of visitors, pages viewed, etc.
2.4. Types of Cookies We Use:
a) Essential Cookies: These cookies are strictly necessary for the operation of our Website. They enable core functionality such as security, network management, and accessibility. You may disable these by changing your browser settings, but this may affect how the Website functions.
b) Analytical/Performance Cookies: These cookies allow us to recognize and count the number of visitors and see how visitors move around our Website when they are using it. This helps us to improve the way our Website works, for example, by ensuring that users are finding what they are looking for easily.
c) Functionality Cookies: These cookies are used to recognize you when you return to our Website. This enables us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
d) Targeting Cookies: These cookies record your visit to our Website, the pages you have visited and the links you have followed. We will use this information to make our Website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
(For more detailed information about our use of cookies, please refer to our Cookie Policy at [Insert URL].)
2.5. Proxy Usage Data:
As a proxy service provider, we collect and process data related to your use of our proxy services, including:
- IP addresses used;
- Bandwidth consumption;
- Connection timestamps;
- Websites accessed through our proxies (in aggregate form);
- Protocol used (HTTP, HTTPS, SOCKS);
- Number of concurrent connections;
- Geographic location of proxy servers used;
- Error logs and connection status;
- Authentication methods used.
2.6. Data Categories and Sources:
We may collect personal information from you in the course of providing Services, when you use the Website, contact us or request information from us, or as a result of your relationship with any of our personnel or clients. The personal information that we might process includes:
- Contact data: Basic details such as your name, date of birth, role/title, employer, and your contact information.
- Verification data: Screenshots of national identity documents, utility bill details, video data from the video authentication procedure, biometric data for verification.
- Order data: Information relating to the matter on which you are seeking our Services.
- Financial data: Bank details, payment service provider information, payment details, transaction-ID.
- Log data: IP address, location data, traffic data, transaction data, computer or mobile device information, frequency, time, length of visit, and other page interaction data.
- Company details: Commercial register reports, data of or concerning beneficial owners, records or additional information about recent, past, or planned business activities.
- Marketing data: Statistical and marketing data such as number of visitors, frequency, clicks, time, places, target groups, data from cookies and similar technologies.
- Photo, video, and audio data: Photos and other recordings from events, fairs, interviews, office visits, or meetings.
- Hiring data: Data necessary for the recruitment process such as contact details, curriculum vitae, qualifications, police clearance certificate, credit report, national identity documents, links to your portfolio or social media platforms.
3. How We Collect Your Information
3.1. Direct Collection:
We collect information directly from you when you:
- Register for an account;
- Purchase our Services;
- Fill out forms on our Website;
- Correspond with us via phone, email, or chat;
- Participate in surveys or promotions;
- Provide feedback or contact our customer support;
- Apply for a job with us;
- Attend our events or webinars;
- Request technical support;
- Subscribe to our newsletters or marketing communications.
3.2. Automated Collection:
We automatically collect certain information when you visit, use, or navigate our Website. This information does not reveal your specific identity but may include device and usage information, such as:
- IP address;
- Browser and device characteristics;
- Operating system;
- Language preferences;
- Referring URLs;
- Device name;
- Country;
- Location;
- Information about how and when you use our Services;
- Other technical information about your visit to our Website.
This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.
3.3. Third-Party Sources:
We may receive information about you from third-party sources, such as:
- Business partners;
- Subcontractors in technical, payment, and delivery services;
- Advertising networks;
- Analytics providers;
- Search information providers;
- Data brokers or aggregators;
- Identity verification services;
- Publicly available sources;
- Social media platforms;
- Marketing partners.
3.4. Social Media Interactions:
If you choose to interact with us on social media platforms, we may collect information from these interactions. This may include:
- Profile information;
- Interactions with our social media accounts;
- Content you post on our social media pages;
- Information made available by the social media platform based on your privacy settings.
Please note that the information you share on social media is subject to the privacy policies of those platforms. We encourage you to review these policies and adjust your privacy settings on these platforms as needed.
4. How We Use Your Information
4.1. Purposes of Use:
We use the information we collect for various purposes, including:
- Providing, maintaining, and improving our Services;
- Processing transactions and sending related information (e.g., confirmations, invoices);
- Responding to your requests, questions, and feedback;
- Sending you technical notices, updates, security alerts, and support messages;
- Monitoring and analyzing trends, usage, and activities in connection with our Services;
- Detecting, preventing, and addressing technical issues;
- Carrying out our obligations and enforcing our rights arising from any contracts;
- Complying with legal obligations in Canada and other jurisdictions where we operate;
- Personalizing your experience on our Website;
- Conducting research and analysis to improve our products and services;
- Developing new products, services, features, and functionality;
- Communicating with you about promotions, upcoming events, and other news about products and services offered by us and our selected partners;
- Protecting, investigating, and deterring against fraudulent, unauthorized, or illegal activity;
- Verifying your identity and preventing fraud or unauthorized access to your account;
- Facilitating corporate acquisitions, mergers, or transactions;
- Enforcing our terms and conditions and other usage policies.
4.2. Marketing Communications:
We may also use your information to contact you about goods and services that may be of interest to you. If you do not want us to use your information in this way, please adjust your user preferences in your account profile or opt-out using the mechanisms provided in our marketing communications.
4.3. Legal Basis for Processing (GDPR and UK GDPR):
a) Consent: In some cases, we process your data based on your explicit consent, which you can withdraw at any time. Examples include:
- Sending you marketing communications;
- Using certain types of cookies;
- Processing sensitive personal data.
b) Contractual Necessity: We process your data to perform our contractual obligations to you or to take steps at your request before entering into a contract. This includes:
- Providing our proxy services;
- Processing payments;
- Fulfilling orders;
- Providing customer support.
c) Legitimate Interests: We process your data when it is in our legitimate interests to do so and not overridden by your rights. This includes:
- Improving and personalizing our services;
- Protecting against fraud and unauthorized transactions;
- Marketing our products and services to existing customers;
- Analyzing usage of our services to improve them;
- Enforcing our terms of service.
d) Legal Obligation: We may process your data to comply with a legal obligation, such as:
- Responding to lawful requests from public authorities;
- Maintaining tax and accounting records;
- Complying with anti-money laundering regulations;
- Reporting security incidents to relevant authorities.
4.4. Automated Decision-Making and Profiling:
We may use automated decision-making and/or profiling in regard to your personal data for some services and products, for example:
- To determine the level of risk associated with your account or transactions;
- To determine your eligibility for certain types of proxy services;
- To tailor our marketing communications to your preferences.
You can request a manual review of the accuracy of an automated decision if you are unhappy with it. Please see Section 8 for more information about your rights.
5. Disclosure of Your Information
5.1. Disclosure of Aggregated Information:
We may disclose aggregated information about our users, and information that does not identify any individual, without restriction. This may include:
- Statistical data about our users' browsing actions and patterns;
- Data on the usage of certain features of our Services;
- General demographic information.
5.2. Disclosure of Personal Information:
We may disclose personal information that we collect or you provide as described in this privacy policy:
- To our subsidiaries and affiliates;
- To contractors, service providers, and other third parties we use to support our business, including:
- Cloud storage providers;
- Payment processors;
- Analytics services;
- Customer support services;
- Marketing and advertising partners;
- IT and system administration services;
- Professional advisers including lawyers, bankers, auditors, and insurers.
- To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Digiproxy's assets;
- To fulfill the purpose for which you provide it;
- For any other purpose disclosed by us when you provide the information;
- With your consent.
5.3. Other Disclosures:
We may also disclose your personal information:
- To comply with any court order, law, or legal process, including to respond to any government or regulatory request in Canada or other jurisdictions where we operate;
- To enforce or apply our terms of use [Insert URL] and other agreements;
- If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Digiproxy, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
5.4. Third-Party Services:
We use the following third-party services in our operations:
- Payment Processing: Cryptomus for Cryptocurrency, Stripe for Card payments
- Customer Support: [email protected]
These third-party services may have access to your personal information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose. We implement appropriate contractual and technical safeguards to limit access to your personal data and ensure it is handled consistently with this Privacy Policy.
6. Data Security
6.1. Measures Implemented:
We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. These measures include:
- Use of encryption protocols to protect data in transit;
- Storing data on secure servers behind firewalls;
- Regular security audits and penetration testing;
- Strict access controls for employees and contractors;
- Employee training on data protection and security practices;
- Regular backups to prevent data loss;
- Multi-factor authentication for accessing sensitive systems;
- Intrusion detection and prevention systems;
- Regular software updates and patch management;
- Physical security measures for our data centers and offices.
6.2. Your Responsibility:
The safety and security of your information also depend on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We also recommend using a unique password for your Digiproxy account and enabling two-factor authentication where available.
6.3. Security Limitations:
Despite our best efforts, no method of transmission over the Internet, or method of electronic storage, is 100% secure. While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security. In the event that we become aware of a security breach that affects your personal data, we will notify you in accordance with applicable laws.
6.4. Proxy Service Security:
We implement additional security measures specific to our proxy services, including:
- Regular rotation of proxy IP addresses;
- Monitoring for abuse and unauthorized access;
- Encryption of proxy traffic where applicable;
- Real-time threat detection and mitigation systems;
- Anonymization of user data in proxy logs;
- Strict access controls for proxy server management;
- Regular security assessments of our proxy infrastructure.
6.5. Data Breach Notification:
In the event of a data breach that may compromise your personal information, we will:
- Notify you and the relevant authorities as required by applicable laws;
- Provide details of the breach and steps taken to mitigate any potential risks;
- Offer guidance on how you can protect yourself from potential negative consequences;
- Implement additional security measures to prevent similar incidents in the future.
7. Data Retention
7.1. Retention Principles:
We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements in Canada and other jurisdictions where we operate.
7.2. Factors Considered:
To determine the appropriate retention period for personal data, we consider:
- The amount, nature, and sensitivity of the personal data;
- The potential risk of harm from unauthorized use or disclosure of your personal data;
- The purposes for which we process your personal data;
- Whether we can achieve those purposes through other means;
- The applicable legal requirements in various jurisdictions;
- The statute of limitations for potential legal claims;
- Industry standards and best practices for data retention.
7.3. Specific Retention Periods:
Specific retention periods include:
- Account Information: Retained for the duration of your account plus [X] years after account closure;
- Transaction Data: Retained for [X] years for tax and accounting purposes;
- Proxy Usage Data: Retained for [X] months for troubleshooting and abuse prevention;
- Marketing Data: Retained until you unsubscribe or ask us to delete this information;
- Communication Records: Retained for [X] years after the last interaction;
- Website Usage Data: Retained in aggregate form for [X] years for analytics purposes.
7.4. Anonymization:
In some circumstances, we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes. This anonymized data may be used indefinitely without further notice to you for purposes such as:
- Improving our services and user experience;
- Conducting market research and analysis;
- Developing new products and features;
- Creating aggregate statistics about our user base and service usage.
7.5. Data Deletion:
Upon expiration of the retention period, we will securely delete or destroy your personal data using industry-standard methods. This includes:
- Secure overwriting of digital files;
- Physical destruction of storage media;
- Anonymization techniques that prevent re-identification.
7.6. Data Retention Requests:
You may request that we retain your data for a longer period in some circumstances (e.g., for legal claims). If you make such a request, we will retain your data for the period you specify unless prohibited by law.
8. Your Legal Rights
8.1. Rights Regarding Your Personal Data:
Depending on your jurisdiction, you may have the following rights regarding your personal data:
- Right to Access: Request a copy of your personal data.
- Right to Rectification: Correct inaccurate or incomplete data.
- Right to Erasure (Right to be Forgotten): Request deletion of your personal data.
- Right to Restrict Processing: Limit how we use your data.
- Right to Object: Oppose processing based on legitimate interests or direct marketing.
- Right to Data Portability: Receive your data in a structured, machine-readable format.
- Right to Withdraw Consent: Revoke previously given consent for data processing.
- Right to Non-discrimination: Not be discriminated against for exercising these rights.
8.2. Exercising Your Rights:
To exercise these rights, contact us using the information in Section 10. We'll respond within 30 days, or sooner if required by law. We may need to verify your identity before processing your request.
8.3. Fees and Refusal of Requests:
You won't be charged for accessing your personal data or exercising your rights. However, we may charge a reasonable fee or refuse requests that are:
- Manifestly unfounded or excessive;
- Repetitive (more than two requests in a 12-month period);
- Require extended technical efforts to fulfill.
We will inform you of any fees before proceeding with your request.
8.4. California Consumer Privacy Act (CCPA) Rights:
California residents have additional rights under the CCPA, including:
- Right to Know: Learn what personal information we collect, use, disclose, and sell.
- Right to Delete: Request deletion of your personal information, subject to certain exceptions.
- Right to Opt-Out: Opt-out of the sale of personal information (note: we don't sell personal information).
- Right to Non-Discrimination: Receive equal service and pricing from us, even if you exercise your privacy rights.
8.5. European Union General Data Protection Regulation (GDPR) Rights:
EU residents have additional rights under the GDPR, including:
- Right to Lodge a Complaint: File a complaint with your local data protection authority.
- Right to Object to Automated Decision-Making: Contest decisions made solely by automated systems, including profiling, which produce legal or similarly significant effects on you.
8.6. Limitations:
We may not be able to fulfill your request if:
- It would adversely affect others' rights and freedoms;
- The information is necessary for a legal obligation or claim;
- The request is manifestly unfounded or excessive;
- We are legally prohibited from disclosing the information.
We will inform you of any limitations that apply to your request.
9. International Data Transfers
9.1. Transfer of Your Data:
As a Canadian company operating internationally, we may transfer your data to countries outside your residence, including the Middle East, USA, UK, and EU. These countries may have data protection laws that differ from those of your country.
9.2. Safeguards Implemented:
When transferring data internationally, we implement appropriate safeguards:
- Standard Contractual Clauses approved by the European Commission;
- EU-U.S. and Swiss-U.S. Privacy Shield Frameworks (where applicable);
- Binding Corporate Rules for intra-group transfers;
- Compliance with the Canadian Personal Information Protection and Electronic Documents Act (PIPEDA);
- Data Transfer Impact Assessments to evaluate the level of protection in recipient countries;
- Contractual safeguards with third-party recipients of personal data.
9.3. Additional Measures:
For transfers to countries without an EU adequacy decision, we use additional measures such as:
- End-to-end encryption of personal data;
- Pseudonymization or anonymization where possible;
- Strict access controls and data minimization practices;
- Transparency about government access requests in recipient countries.
9.4. Consent to International Transfers:
By using our Services, you consent to these international transfers. We ensure all transfers comply with applicable data protection laws and implement appropriate technical and organizational measures to protect your data.
9.5. Data Localization:
Where required by local laws, we may store certain data within specific jurisdictions. We will inform you if this applies to your data.
9.6. Monitoring and Review:
We regularly monitor the effectiveness of our data transfer mechanisms and will promptly adapt our practices if any issues are identified.
10. Contact Information
10.1. Privacy-Related Inquiries:
- Email: [Insert Privacy Email Address]
- Postal Address: [Insert Mailing Address]
- Phone: [Insert Privacy Hotline Number]
10.2. Data Protection Officer:
[Insert DPO Email Address]
10.3. General Inquiries or Support:
- Email: [Insert General Support Email]
- Phone: [Insert General Support Number]
- Live Chat: Available on our website during business hours
10.4. Urgent Matters Related to Data Breaches or Security Incidents:
- Email: [Insert Security Incident Email]
- Phone: [Insert 24/7 Security Hotline]
10.5. Media Inquiries:
- Email: [Insert Media Relations Email]
- Phone: [Insert Media Relations Number]
We strive to respond to all inquiries within 48 hours, and sooner for urgent matters.
11. Changes to Our Privacy Policy
11.1. Updates to Privacy Policy:
We may update this Privacy Policy periodically to reflect changes in our practices, technologies, legal requirements, and other factors. We'll notify you of significant changes through:
- A prominent notice on our Website;
- Direct email notification (if you've provided your email);
- Updates to the "Effective Date" at the top of this Policy;
- In-app notifications for mobile users;
- Social media announcements on our official channels.
11.2. Continued Use:
We encourage you to review this Policy regularly. Continued use of our Services after changes constitutes acceptance of the updated Policy.
11.3. Material Changes:
For material changes affecting your rights or how we process your data, we'll seek your explicit consent where required by law. This may include:
- Changes to the types of personal data we collect;
- New purposes for processing your data;
- Changes to third parties with whom we share your data;
- Significant changes to our data retention practices.
11.4. Archive of Previous Versions:
We maintain an archive of previous versions of this Privacy Policy, which you can request by contacting us.
11.5. Notification Preferences:
You can adjust your preferences for receiving updates about our Privacy Policy by contacting us or updating your account settings.
12. Limitation of Liability
12.1. Security Measures:
While we implement robust security measures, no method of data transmission or storage is 100% secure. We can't guarantee absolute security of your information.
12.2. User Responsibility:
You transmit personal information at your own risk. We're not responsible for circumvention of privacy settings or security measures on our Website or Services.
12.3. Disclaimer of Liability:
To the fullest extent permitted by law, we disclaim liability for any loss, damage, or injury resulting from:
- Unauthorized access to or use of our servers and other information stored therein;
- Any interruption or cessation of transmission to or from our Services;
- Any bugs, viruses, trojan horses, or the like that may be transmitted to or through our Services;
- Any errors or omissions in any content or for any loss or damage of any kind incurred as a result of the use of any content posted, emailed, transmitted, or otherwise made available via the Services.
12.4. Limitation of Damages:
In jurisdictions where limitation of liability for consequential or incidental damages isn't allowed, our liability shall be limited to the greatest extent legally permissible.
12.5. Exceptions:
This limitation of liability does not affect any liability that cannot be excluded or limited under applicable law, including liability for death or personal injury caused by our negligence or liability for fraud or fraudulent misrepresentation.
13. Data Storage Locations
13.1. Data Storage Overview:
We primarily store data in Canada but may process and store data in other countries where we or our partners operate, including the Middle East, USA, UK, and EU. Specific locations include:
- Primary Data Centers: [Insert locations]
- Backup and Disaster Recovery Sites: [Insert locations]
- Cloud Service Providers: [Insert providers and their locations]
13.2. International Data Transfers:
By providing information to us, you consent to the transfer and processing of your data in these countries. We ensure compliance with applicable data protection laws and implement appropriate safeguards, including:
- Data Processing Agreements with service providers;
- Standard Contractual Clauses for international data transfers;
- Privacy Shield certification (where applicable);
- Local data protection officer appointments where required.
13.3. Data Residency Options:
For clients with specific data residency requirements, we offer options to store data in specific geographic locations. Please contact us for more information about these options and any associated costs.
13.4. Transparency Reports:
We publish annual transparency reports detailing government requests for user data and our responses to these requests.
14. Specific Proxy Service Information
14.1. Data Collection and Processing:
As a proxy service provider, we collect and process additional data related to your use of our services:
- IP addresses used;
- Bandwidth consumption;
- Connection timestamps;
- Websites accessed through our proxies (in aggregate form);
- Protocol used (HTTP, HTTPS, SOCKS);
- Number of concurrent connections;
- Geographic location of proxy servers used;
- Error logs and connection status;
- Authentication methods used.
14.2. Data Retention:
We retain proxy usage data for [X] months for troubleshooting and abuse prevention purposes. This retention period is necessary to:
- Identify and mitigate potential security threats;
- Optimize our proxy network performance;
- Comply with legal and regulatory requirements;
- Respond to user inquiries and support requests.
14.3. Additional Security Measures:
We implement additional security measures specific to our proxy services, including:
- Regular rotation of proxy IP addresses;
- Real-time monitoring for abuse and unauthorized access;
- End-to-end encryption of proxy traffic where applicable;
- IP address masking and anonymization techniques;
- Strict access controls and authentication mechanisms;
- Regular security audits of our proxy infrastructure;
- Automated threat detection and mitigation systems.
14.4. Proxy Service Usage Restrictions:
We enforce specific restrictions on the use of our proxy services to maintain integrity and compliance:
- You agree not to use our proxy services for any illegal activities;
- We prohibit the use of our services for spamming, hacking, or any form of abuse;
- We reserve the right to terminate service to users who violate our terms of use or engage in suspicious activities.
15. Governing Law
15.1. Applicable Law:
This Privacy Policy shall be governed by and construed in accordance with the laws of Canada, without regard to its conflict of law provisions. However, this will not deprive you of any mandatory consumer protections under the law of your country of residence, where applicable.
15.2. Data Protection Compliance:
For users in the European Union, United Kingdom, and other jurisdictions with data protection laws, we comply with applicable legal requirements providing adequate protection for the transfer of personal data to countries outside of the EEA.
15.3. Dispute Resolution:
In the event of any disputes arising from or relating to this Privacy Policy or our data practices:
- We will attempt to resolve the dispute amicably through negotiations;
- If negotiations fail, the dispute shall be subject to the exclusive jurisdiction of the courts of [Insert specific Canadian jurisdiction];
- For EU users, alternative dispute resolution mechanisms may be available through local data protection authorities.
15.4. Applicability of Privacy Policy:
This Privacy Policy does not override any applicable national data privacy laws in countries where we operate.
16. Feedback and Communication
16.1. Providing Feedback:
Your feedback is always welcome and appreciated. If you have any questions, comments, or concerns about our Privacy Policy or practices, please contact us at:
- Email: [Insert Email Address]
- Phone: [Insert Phone Number]
- Mailing Address: [Insert Mailing Address]
16.2. Using Your Feedback:
We value your input as it helps us improve our services and ensure we meet our users' privacy expectations. When providing feedback:
- Be as specific as possible about your concern or suggestion;
- Include any relevant details such as account information or specific interactions with our services;
- Let us know if you require a response and your preferred method of communication.
16.3. Using Feedback for Improvement:
We may use your feedback to:
- Improve our Privacy Policy and data protection practices;
- Enhance our services and user experience;
- Train our staff on privacy and data protection matters;
- Address any specific concerns or issues you raise.
16.4. Marketing Communications:
If you have opted in to receive marketing communications from us, we may occasionally send you updates about changes to our Privacy Policy, new services, or other relevant information. You can opt-out of these communications at any time.
17. Complaints and Dispute Resolution
17.1. Handling Complaints:
If you believe that we have not adhered to this Privacy Policy or if you have any questions or concerns about our privacy practices, please contact us as described in the Feedback section above.
17.2. Complaint Response:
We will make every reasonable effort to address your concerns and remedy any problems you bring to our attention. Our complaint handling process includes:
- Acknowledging receipt of your complaint within 5 business days;
- Assigning a dedicated team member to investigate your concern;
- Providing a substantive response within 30 days;
- Implementing any necessary changes or corrections promptly.
17.3. Regulatory Options:
If you are not satisfied with our response, you may have the right to make a complaint to the privacy regulator or data protection authority in your jurisdiction.
17.4. Data Protection Authorities:
For EU residents, you have the right to lodge a complaint with your local data protection authority if you believe that we have not complied with applicable data protection laws. Key authorities include:
- For the EU: The European Data Protection Supervisor (EDPS)
- For the UK: The Information Commissioner's Office (ICO)
17.5. California Residents:
For California residents, you can file a complaint with the California Attorney General's office if you believe your rights under the CCPA have been violated.
17.6. Alternative Dispute Resolution:
We are committed to resolving disputes in a fair and efficient manner. In some cases, we may suggest mediation or arbitration as alternative methods of dispute resolution. Any alternative dispute resolution process will be conducted in accordance with relevant laws and regulations.
17.7. Record Keeping:
We maintain records of all complaints received, our responses, and any actions taken. These records are regularly reviewed to identify any systemic or recurring problems that may need to be addressed.
18. Acknowledgment and Acceptance
By using our Services, you acknowledge that you have read and understood this Privacy Policy and agree to be bound by its terms and conditions. We encourage you to review this policy regularly as it may change from time to time.