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Luxeproxy
Thank you for choosing us! We are committed to providing you the best services possible. Our Website and Services are provided to you by Fintech agency OÜ, a legal entity, incorporated in Estonia and entered into the E-Business Register on 23.12.2022 under the registration No. 16638667, address: Estonia, Tallinn, Kesklinna linnaosa, Vesivärava tn 50-301, 10152.
We want you to understand what information we collect, how we use it, and with whom we share it. That is why we encourage you to read our Privacy Policy. This will help you use our Services the way you need to.
This Privacy Policy explains how we process your personal data when you visit our Website, log in to your Account and use our Services. Please note that this Privacy Policy will regularly be updated and the updated version will be posted on our Website to reflect any changes in the way we handle your personal data or any changes in applicable laws.
By checking the appropriate box during the registration process (creating an Account), while using our Website or when updating after logging into your Account, you expressly confirm that you have read the Privacy Policy and agree to the data processing described there in.
If you do not agree with any provision of this Privacy Policy in any extent or in any manner, you must not use or must immediately cease using the Website or our Services.
DEFINITIONS
Unless the context requires otherwise, the terms used in this Privacy Policy shall have the meanings indicated below:
Company – the “Company”, “we”, “us”, or “our” means Fintech agency OÜ – a legal entity, incorporated in Estonia and entered into the E-Business Register on 23.12.2022 under the registration No. 16638667, address: Estonia, Tallinn, Kesklinna linnaosa, Vesivärava tn 50-301, 10152.
Client means any person using Company’s Services or Website (the “Client”/“You”). The Client can be a natural person or legal person, represented by a natural person.
Website means luxeproxy.com (the “Website”).
Services – multiple IP address proxy infrastructure solutions, including IP addresses for the Clients to connect to the internet, and access to the Company’s data gathering and proxy management solutions (the “Services”). The Services can be reached and used via Website.
Full list of the Services is indicated on the Website. The Company shall have a right to change the list of Services (modify, update, suspend or terminate Services) from time to time, without any prior notification to the Client.
Account – if You wish to use the Services, you must set up (register) a user account within the Website by filling the registry form and providing certain information and confirmations (e.g., your name and/or organizations’ name, email address, phone number, country of residence, password, billing information, other (if any). The registry form is available at https://panel.luxeproxy.com/auth/register.
Personal data means any information relating to an identified or identifiable natural person (“data subject”); an identifiable natural person is the one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;
Processing means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;
Restriction of processing means the marking of stored personal data with the aim of limiting their processing in the future;
Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements;
Controller means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data;
Processor means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller;
Recipient means a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not;
Third party means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data;
Consent of the data subject means any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her;
Personal data breach means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed;
Genetic data means personal data relating to the inherited or acquired genetic characteristics of a natural person which give unique information about the physiology or the health of that natural person and which result, in particular, from an analysis of a biological sample from the natural person in question;
Biometric data means personal data resulting from specific technical processing relating to the physical, physiological or behavioural characteristics of a natural person, which allow or confirm the unique identification of that natural person, such as facial image sordactyloscopic data;
Data concerning health means personal data related to the physical or mental health of a natural person, including the provision of health care services, which reveal information about his or her health status;
Supervisory authority means an independent public authority which is established by EU Member State and is responsible for monitoring the application of the GDPR;
Cross-border processing means either: (a) processing of personal data which takes place in the context of the activities of establishments in more than one EU Member State of a controller or processor where the controller or processor is established in more than one EU Member State; or (b) processing of personal data which takes place in the context of the activities of a single establishment of a controller or processor in the EU but which substantially affects or is likely to substantially affect data subjects in more than one EU MemberState.
GENERAL PROVISIONS
This Privacy Policy applies to all persons (“data subjects”) who visit the Website or use our Services or otherwise interact with the Company (e.g. business partners, interested parties, service providers, etc.)
The Company acts both as controller and processor of Client’s personal data.
Company’s Website and Services are not meant for anyone under the legal age. The Company therefore does not knowingly collect personal data from minors. So, if you are under 18 years of age/under legal age under the laws imperatively applicable to you, please do not use the Websiteor Services and do not provide us with any personal data.
If you are a representative of a legal person, which is a user of the Company’s Website and/or Services, please be aware that your personal data will be collected too in accordance with this Privacy Policy.
It is your responsibility to ensure that you are authorized to use the Website and/or Services of the Company.
The Companyis registered and offers its services in the EuropeanUnion, and thereforeis subject to the requirements of the EuropeanUnion’s General Data Protection Regulation (GDPR). If you are a user from Canada or Australia, please additionally review the requirements that apply to you in accordance with the requirements of the relevantlaws of such countries: the Canadian Personal Information Protection and Electronic Documents Act (“PIPEDA”) and the Privacy Act 1988 (Cth) of Australia, as amended, respectively.
To ensure proper implementation of data protection requirements and to optimize procedures, the Company has appointed a special person, a Data Protection Officer (DPO), who has the necessary skills and expertise to protect personal data. You may contact DPO directly using the contacts listed below in the relevant section of thisPrivacy Policy.
For the avoidance of doubt, you acknowledge that by using the Website in any manner prior to creating an Account or without logging in you are also bound by this PrivacyPolicy and your personal data may be collected by the Company automatically.
By creating an Account, you expressly consent to receiving direct marketing and advertising material, as well as other electronic communication.
If You disagree to give your consent / wish to withdraw your consent to receive direct marketing and advertising materialin any scope or way, you must either:
·Not complete the creation of the Account, or
·After creation of the Account, withdraw your consent (that was given by creating an Account) by clicking “Unsubscribe” button in the email received from the Company after your Account was created, or
At any other time, withdraw your consent by clicking “Unsubscribe” button indicated in any other email from the Company which was sent by the Company as a direct marketing and/or advertising material.
WHAT TYPES OF PERSONAL DATA DO WE PROCESS?
Please note that we only collect personal data that is necessary for each specific processing purpose described below in relevant section, including providing our Services to you.
The Company may collect personal information from you when you use the Website, contact us or request information from us, as well as in the course of provision of Services to you.
The personal data we collect and process are as follows:
The information we collect on our Website may include anonymous“traffic information”, provided by Google Analytics, that does not identify you personally. This information is statistical in nature and includes information about which pages of the Website visitors of the Company open and how long they stay on a particular page. This provider also provides information about which browser, network or device is used to visit our Website. For more information about Google Analytics and how to opt out of its services, please visit
https://chrome.google.com/webstore/detail/google- analytics-opt-out/fllaojicojecljbmefodhfapmkghcbnh?hl=en.
Where the Company has reasonable doubts concerning the identity of the person making the request, the Company may request you to provide additional information necessary to verify your identity. The Company may also, from time to time, request to update your personal data in order to process only your valid and actual data.
The above-mentioned categories of personal data have been obtained either directly from you (for example, when you create your account) or indirectly from certain third parties (for example, when signing in into account through Google account).
Your decision to provide to us any personal data is voluntary. Therefore, you will not be adversely affected if you do not wish to provide us with your personal data. However, please note that if you do not provide certain information, we may not be able to fulfil some or all of the purposes set forth in this Privacy Policy and you may not be able to use certain tools and systems that require the use of such personal data.
WHAT ABOUT SENSITIVE DATA?
Please note that we do not process personal data revealing your racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data, data concerning health or data concerning your sex life or sexual orientation, or criminal convictions and offences (including information about suspected criminal activities).
PURPOSE AND LEGAL BASIS
Please view below a list of the purposes for which the Company uses your personal data and an overview of the legal basis foreach such purpose.
We process a limited amount of information related to enabling you to access your Account and receive our services (first and last name, telephone number, e-mail address, country of registration, date of account registration, subscription information, encrypted password, your IP address). The legal basis for processing the information is the fulfilment of a contract to which you are a party. Please note that this information is necessary for the performance of the contract and if you do not provide necessary information (or if we are unable to retain it), we may not be able to provide our Services to you.
For communication and customer support, we use e-mail addresses to send important updates and announcements about the use of our services and to respond to inquiries and questions. In addition to your email, we process your inquiry and other data you provide during communication.
When you contact us via Live chat on our website, we see your IP-address. We need this information in order to determine whether this user is connected to our servers and to help them solve problems. The legal basis for processing your personal data is to fulfil the terms of your contract with us (in the case of important communications in connection with our Services) or your consent (in the case of sending a request to our support team).
We also rely on your consent as a legal basis for the processing your personal data. For example, we may ask you to express consent prior to using the Account before it is created or when you are use the Website without logging-in to your Account, as well as in advance, before collecting / processing any other personal data not described in thisPrivacy Policy.
If you have given us your consent to the processing of your personal data, the processing will only occur for the defined purposes and to the extent agreed in the consent.
With your consent, we process data for the following purposes: direct marketing and advertising, Website analysis.
A given consent can be revoked at any time without giving reasons with effect for the future if you no longer agree to the processing. Revoking your consent does not affect the legality of the processing carried out based on your consent up to the point of withdrawal.
Payment-related information: our payment processing partners collect the data necessary to process payments and/or chargeback requests (transaction date, payer IP address, full name of the owner and credit card number). We process only a very small portion of this payment information (part of the credit card number, payer IP address, payment amount and currency, payment date and card expiration date) to address payment-related issues (e.g. fraud prevention). We also collect information about your country of residence, as this is required to calculate VAT/sales tax in that region.
The legal basis for processing personal information is the legal obligation that applies to us (where it is necessary to collect your data in accordance with the law) and our legitimate interest in protecting our rights and interests (where there are other legal processes relating to you).
We are subject to accounting, tax and other legal requirements (in particular, providing information to law enforcement authorities). We may need to collect and store some of your personal data: email address, subscription and payment information, legal documents, etc. in order to protect our rights and legitimate interests.
We guarantee that your personal data will not be sold in any way by the Company.
WHAT ARE COOKIES AND HOW DO WE USE THEM?
Below we explain how we use cookies to recognize you when you visit our Website. In some cases we may use cookies to collect personal data, or that becomes personal data if we combine it with other information.
Cookies are text files containing small amounts of information which are downloaded to your computeror mobile device when you visit a website and allow a website to recognize your device. The use of cookies is standard practice for most websites at the moment. Website owners use cookies in order to make their websites work, or to workmore efficiently, as well as to providereporting information.
You can refuseall cookies, or make your device alert you each time they are used, or use software products that can manage cookiesfor you.
Most browsers allow you to view, delete,and block cookiesfrom websites. In case all cookies are deleted, all Websites’ settings will be reset for you.
You can use the links below to read instructions for managing cookies on popular browsers:
Information on other browsers and device types can be found at http://www.aboutcookies.org/ and http://www.cookiecentral.com/faq/.
However, please note that cookies deletion or blocking may affect for you the interface of our Websiteand make part of the Website’s components unavailable to you.
Cookies can be of the following types:
ddg1
Essential
They are used to
identify the userwhen sending a verification request, duringa DDoS attack or suspicious activity.
1 year
ddg2
Essential
They areused to
identify the userwhen sending a verification request, duringa DDoS attack or suspicious activity.
1 year
ddgid
Essential
They are used to
identify the userwhen sending a verification request, duringa DDoS attack or suspicious activity.
1 year
ddgmark
Essential
They areused to
identifythe user whensending a verification request, during a DDoS attack, or
suspicious activity.
1 day
csrf
Essential
They areused for
authorisation of the user
1 year
session
Essential
They are usedfor
authorisation of the user
1 month
_chatwoot_session
Essential
Used by the
Chatwoot Super Admin panel to persist the user session
1 year
cw_conversation
Essential
This cookie lets Chatwoot persist the conversation when the contact navigates through the webpages or
1 year revisits the website later
HOW LONG DO WE RETAIN YOUR PERSONAL DATA?
The Company will retain your personal data only for as long as necessary. We maintain specific records management and retention policies and procedures, so that personal data are deleted after a reasonable time according to the following retention criteria:
Your personal data may be deleted at your request, unless applicable law requires us to keep certain personal information, including the following situations:
WILL WE SHARE YOUR PERSONAL DATA WITH THIRD PARTIES?
We share your personal data with third parties only for the purposes described above and permitted by applicable law. We never sell your data to anyone.
We may share your personal data with our service providers and professional advisors, public and governmental authorities (only when we are asked to do so and when we are obliged to do so by law) or third parties in connection with the Company’s operation of its business. Such third parties may be located both within the European Economic Area (EAA) and outside of it. In any case, before sharing your personal data, we will take the necessary steps to ensure that your personal data are adequately protected as required by relevant data privacy laws and internal Company’s policies, based on the standards of the GDPR.
In particular, we share your information with service providers that render services to us, including legal services, customer support, payment processing, email deployment, accounting and auditing.These parties may only use or pass on this data in so far as this is necessary to provide services for us or to comply with legal regulations. We contractually obliged these third parties to guarantee the confidentiality and security of your personal data that they process on our behalf.
Main third parties contracted by the Company that may process your personal data are the following:
Please note that any transfers of your personal data from within the EEA to third parties outside the EEA will be:
We may also share your personal data if we are required to do so by law or during legal proceedings, or if we believe that disclosure is necessary to avoid damage or financial loss, or in connection with an investigation into suspected or actual fraudulent or illegal activities.
We may also share your information in connection with a substantial corporate transaction, such as the sale of a website, a merger, consolidation, asset sale, initial public offering, or in the unlikely event of a bankruptcy.
DO WE USE AUTOMATED DECISION-MAKING, INCLUDING PROFILING?
Automated decision making is the process of making decisions by automated means without human intervention. Profiling analyses aspects of a person’s personality, behaviour, interests and habits in order to make predictions or make decisions about them. We assure you that we do not make decisions based solely on automated processing, including profiling, which may have legal consequences for you. In case we would make such a decision in any scope, you shall be entitled to object to it.
WHAT CHOICES CAN YOU MAKE ABOUT HOW WE USE YOUR INFORMATION?
We comply with the GDPR and other privacy laws. The GDPR and other privacy laws provide individuals with certain rights regarding their personal data. The rights you have with respect to your personal data are the following:
Right to access
You may obtain from us the confirmation as to whether or not your personal data are being processed, as well as access to your personal data. The Company provides such information free of charge.
However, where the request is manifestly unfounded or excessive (in particular because of repetitive character), the Company may either:
Right to rectification
If necessary, you can request the correction of incorrect personal data and the completion of incomplete personal data.
Right to erasure
You have the right, without explaining the reason and without undue delay, to have your personal data erased, provided that the following conditions apply:
Right to restriction
You may ask us to restrict the processing of your personal data in whole or in part, if one of the following conditions is met:
Right to objection
You may object to the processing of your personal data. However, this right is not absolute and the Company may demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims.
Where personal data are processed for direct marketing purposes, you have the right to object at any time to processing of your personal data for such marketing, which includes profiling to the extent that it is related to such direct marketing.
Right to portability
You may request to receive your personal data, which you have provided to the Company, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from the Company. You may also request the Company to transmit your personal data directly to another controller named by you, provided that the portability of your personal data technically feasible.
Right to withdraw consent
If we collected and processed your personal data with your consent, you may withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of their processing prior to your withdrawal, nor will it affect the processing of your personal information carried out on lawful processing grounds other than consent.
Please note that if you withdraw your consent, we may no longer be able to offer you our Services. Withdrawing Your consent does not affect the legality of the processing of Your personal data based on Your consent up to the point of withdrawal.
Right to lodge a complain
You have the right to lodge a complaint with a data protection supervisory authority.
To exercise the above rights please contact us by sending an email to privacy@luxeproxy.com.
HOW DO WE PROTECT YOUR PERSONAL DATA?
The Company attaches great importance to your right to privacy and the protection of your personal data. We want you to feel secure when you visit our Website and uses our Services, as well as in the course of all other business transactions with the Company.
The Company maintains the appropriate organizational, physical and technical security arrangements to protect your personal data against unauthorized or unlawful processing and/or against accidental loss, alteration, disclosure or access, or accidental or unlawful destruction of or damage thereto.
We have implemented various security measures, including SSL/TLS encryption for data transmission, hashed passwords, firewalls and regular independent audits. We assigned Data Privacy Officer and conduct regular staff trainings. We also apply network segmentation: the database server is inaccessible to external users. We take all steps reasonably necessary to process your personal data securely.
Please be aware that despite all security measures, our Website and Services may not always be 100% secure. Whenever you provide your information online, there is a risk that it may be intercepted and used by a third party. While we do our best to protect your personal data, we cannot guarantee the security of any information you provide online.By using the Website and Services, you expressly acknowledge and agree that we cannot guarantee the security of data provided by you or received by us through theServices and that any information you provide is at your own risk.
HOW TO CONTACT US?
For the matters regarding this Privacy Policy, as well as regarding any privacy matter you may contact us via email, by sending your inquiry at privacy@luxeproxy.com.
You may contact us via mail, by sending us your letter to our registered address: Estonia, Harju maakond,Tallinn, Lasnamäe linnaosa, Väike-Paala tn 2, 11415.
You may also contact our DPO via email, by sending your inquiry at privacy@luxeproxy.com, or via letter, clearly marked for the attention of the Data Protection Officer, on this address: Estonia, Harju maakond, Tallinn, Lasnamäe linnaosa, Väike-Paala tn 2, 11415.
We will provide a response to your inquiry no later than within one month from the date of its receipt (with the possibility of extension for another two months).
DO WE MAKE UPDATES TO THIS POLICY?
This Privacy Policy is in effect until superseded by a new policy. We may update this Privacy Policy at our discretion. The most currentversion of the Policy is indicated by the date it was last updated at the top of the page. The continuous use of our Website and Services shall be deemed as acceptance and understanding the terms of this Policy as it currently stands.
You shall periodically check and assess the Privacy Policy. Any update of the Privacy Policy comes in force at the moment it is published at the website.
We will not reduce your rights under this Privacy Policy without your explicit consent. Nor will we hide from you any updates regarding any changes to purposes of data processing, transfer of personal data to a third country. If changes are significant, we’ll provide you in advance with a more prominent notice (including by sending an email notification of Privacy Policy changes).
We want you to understand what information we collect, how we use it, and with whom we share it. That is why we encourage you to read our Privacy Policy. This will help you use our Services the way you need to.
This Privacy Policy explains how we process your personal data when you visit our Website, log in to your Account and use our Services. Please note that this Privacy Policy will regularly be updated and the updated version will be posted on our Website to reflect any changes in the way we handle your personal data or any changes in applicable laws.
By checking the appropriate box during the registration process (creating an Account), while using our Website or when updating after logging into your Account, you expressly confirm that you have read the Privacy Policy and agree to the data processing described there in.
If you do not agree with any provision of this Privacy Policy in any extent or in any manner, you must not use or must immediately cease using the Website or our Services.
DEFINITIONS
Unless the context requires otherwise, the terms used in this Privacy Policy shall have the meanings indicated below:
Company – the “Company”, “we”, “us”, or “our” means Fintech agency OÜ – a legal entity, incorporated in Estonia and entered into the E-Business Register on 23.12.2022 under the registration No. 16638667, address: Estonia, Tallinn, Kesklinna linnaosa, Vesivärava tn 50-301, 10152.
Client means any person using Company’s Services or Website (the “Client”/“You”). The Client can be a natural person or legal person, represented by a natural person.
Website means luxeproxy.com (the “Website”).
Services – multiple IP address proxy infrastructure solutions, including IP addresses for the Clients to connect to the internet, and access to the Company’s data gathering and proxy management solutions (the “Services”). The Services can be reached and used via Website.
Full list of the Services is indicated on the Website. The Company shall have a right to change the list of Services (modify, update, suspend or terminate Services) from time to time, without any prior notification to the Client.
Account – if You wish to use the Services, you must set up (register) a user account within the Website by filling the registry form and providing certain information and confirmations (e.g., your name and/or organizations’ name, email address, phone number, country of residence, password, billing information, other (if any). The registry form is available at https://panel.luxeproxy.com/auth/register.
Personal data means any information relating to an identified or identifiable natural person (“data subject”); an identifiable natural person is the one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;
Processing means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;
Restriction of processing means the marking of stored personal data with the aim of limiting their processing in the future;
Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements;
Controller means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data;
Processor means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller;
Recipient means a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not;
Third party means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data;
Consent of the data subject means any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her;
Personal data breach means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed;
Genetic data means personal data relating to the inherited or acquired genetic characteristics of a natural person which give unique information about the physiology or the health of that natural person and which result, in particular, from an analysis of a biological sample from the natural person in question;
Biometric data means personal data resulting from specific technical processing relating to the physical, physiological or behavioural characteristics of a natural person, which allow or confirm the unique identification of that natural person, such as facial image sordactyloscopic data;
Data concerning health means personal data related to the physical or mental health of a natural person, including the provision of health care services, which reveal information about his or her health status;
Supervisory authority means an independent public authority which is established by EU Member State and is responsible for monitoring the application of the GDPR;
Cross-border processing means either: (a) processing of personal data which takes place in the context of the activities of establishments in more than one EU Member State of a controller or processor where the controller or processor is established in more than one EU Member State; or (b) processing of personal data which takes place in the context of the activities of a single establishment of a controller or processor in the EU but which substantially affects or is likely to substantially affect data subjects in more than one EU MemberState.
GENERAL PROVISIONS
This Privacy Policy applies to all persons (“data subjects”) who visit the Website or use our Services or otherwise interact with the Company (e.g. business partners, interested parties, service providers, etc.)
The Company acts both as controller and processor of Client’s personal data.
Company’s Website and Services are not meant for anyone under the legal age. The Company therefore does not knowingly collect personal data from minors. So, if you are under 18 years of age/under legal age under the laws imperatively applicable to you, please do not use the Websiteor Services and do not provide us with any personal data.
If you are a representative of a legal person, which is a user of the Company’s Website and/or Services, please be aware that your personal data will be collected too in accordance with this Privacy Policy.
It is your responsibility to ensure that you are authorized to use the Website and/or Services of the Company.
The Companyis registered and offers its services in the EuropeanUnion, and thereforeis subject to the requirements of the EuropeanUnion’s General Data Protection Regulation (GDPR). If you are a user from Canada or Australia, please additionally review the requirements that apply to you in accordance with the requirements of the relevantlaws of such countries: the Canadian Personal Information Protection and Electronic Documents Act (“PIPEDA”) and the Privacy Act 1988 (Cth) of Australia, as amended, respectively.
To ensure proper implementation of data protection requirements and to optimize procedures, the Company has appointed a special person, a Data Protection Officer (DPO), who has the necessary skills and expertise to protect personal data. You may contact DPO directly using the contacts listed below in the relevant section of thisPrivacy Policy.
For the avoidance of doubt, you acknowledge that by using the Website in any manner prior to creating an Account or without logging in you are also bound by this PrivacyPolicy and your personal data may be collected by the Company automatically.
By creating an Account, you expressly consent to receiving direct marketing and advertising material, as well as other electronic communication.
If You disagree to give your consent / wish to withdraw your consent to receive direct marketing and advertising materialin any scope or way, you must either:
·Not complete the creation of the Account, or
·After creation of the Account, withdraw your consent (that was given by creating an Account) by clicking “Unsubscribe” button in the email received from the Company after your Account was created, or
At any other time, withdraw your consent by clicking “Unsubscribe” button indicated in any other email from the Company which was sent by the Company as a direct marketing and/or advertising material.
WHAT TYPES OF PERSONAL DATA DO WE PROCESS?
Please note that we only collect personal data that is necessary for each specific processing purpose described below in relevant section, including providing our Services to you.
The Company may collect personal information from you when you use the Website, contact us or request information from us, as well as in the course of provision of Services to you.
The personal data we collect and process are as follows:
- Personal details and contact data: when creating a new Account or communicating with the Company(for example, by contacting us via email or Livechat), we may process your basic details, such as first and last name, confirmation that you are a natural person, your relationship to a legal entity (if any), and your contact information, such as phone number, country of residence, email.
- Commercial information: requirements for the Service (expected number of IPs a month, type of purchase, traffic volume, required use duration etc.), history and records of the Services you have obtained from us, correspondence between you and us in relation to the Services when it is sent to a dedicated email or via Livechat.
- Confirmations: confirmations that you agree to the Privacy Policy and the Cookies Policy of the Company.
- Marketing information: the IP-address, first and last name, e-mail address.
- Financial data: in the context of ordering Services and accepting payments, as well as making refunds we might process, for example, bank details, information about the payment service provider, payment details, transaction-ID, etc.
- Log data: during activities in your Account and while using our Services, we might process, for example: IP-address, unique password, created by you (in encrypted form), your location, location data, traffic data, computer or mobile device information, frequency, time, length of visit and other page interaction data, operating system, browser type, device type, unique device identification number, identification cookies, optionally form data, crash reports, performance data, third-party cookies, etc.
- Account information: date and time of Account creation, as well as log-in date and time.
- Information received from third party services: if you log in to your Account through a third-party service, we may receive some information about you and your use of that third party service. For example, if you choose to log in with your Google account, we may receive information from this company, such as your name and email address.
- Information collected by cookies and Google Analytics: when you visit our Website, we collect and use certain data to improve its performance, for example: browser type, the web pages you visited, and time spent on them, access time and dates, unique device identification number, other.
The information we collect on our Website may include anonymous“traffic information”, provided by Google Analytics, that does not identify you personally. This information is statistical in nature and includes information about which pages of the Website visitors of the Company open and how long they stay on a particular page. This provider also provides information about which browser, network or device is used to visit our Website. For more information about Google Analytics and how to opt out of its services, please visit
https://chrome.google.com/webstore/detail/google- analytics-opt-out/fllaojicojecljbmefodhfapmkghcbnh?hl=en.
- Company details. If you use a Services / enter into commercial agreement with the Company as a legal entity, we might process, for example: commercial register reports, data of or concerning beneficial owners, records or additional information about recent, past or planned business activities, other data required to determine / validate the structure, the beneficial ownership or any power of attorney from the company, etc.
- Marketing data: we might process statistical and marketing data, for example: number of visitors, frequency, clicks, time, places, target groups, data from cookies and similar technologies, consumer’s behaviour, interests and preferences, data on market research and target group surveys, etc.
Where the Company has reasonable doubts concerning the identity of the person making the request, the Company may request you to provide additional information necessary to verify your identity. The Company may also, from time to time, request to update your personal data in order to process only your valid and actual data.
The above-mentioned categories of personal data have been obtained either directly from you (for example, when you create your account) or indirectly from certain third parties (for example, when signing in into account through Google account).
Your decision to provide to us any personal data is voluntary. Therefore, you will not be adversely affected if you do not wish to provide us with your personal data. However, please note that if you do not provide certain information, we may not be able to fulfil some or all of the purposes set forth in this Privacy Policy and you may not be able to use certain tools and systems that require the use of such personal data.
WHAT ABOUT SENSITIVE DATA?
Please note that we do not process personal data revealing your racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data, data concerning health or data concerning your sex life or sexual orientation, or criminal convictions and offences (including information about suspected criminal activities).
PURPOSE AND LEGAL BASIS
Please view below a list of the purposes for which the Company uses your personal data and an overview of the legal basis foreach such purpose.
We process a limited amount of information related to enabling you to access your Account and receive our services (first and last name, telephone number, e-mail address, country of registration, date of account registration, subscription information, encrypted password, your IP address). The legal basis for processing the information is the fulfilment of a contract to which you are a party. Please note that this information is necessary for the performance of the contract and if you do not provide necessary information (or if we are unable to retain it), we may not be able to provide our Services to you.
For communication and customer support, we use e-mail addresses to send important updates and announcements about the use of our services and to respond to inquiries and questions. In addition to your email, we process your inquiry and other data you provide during communication.
When you contact us via Live chat on our website, we see your IP-address. We need this information in order to determine whether this user is connected to our servers and to help them solve problems. The legal basis for processing your personal data is to fulfil the terms of your contract with us (in the case of important communications in connection with our Services) or your consent (in the case of sending a request to our support team).
We also rely on your consent as a legal basis for the processing your personal data. For example, we may ask you to express consent prior to using the Account before it is created or when you are use the Website without logging-in to your Account, as well as in advance, before collecting / processing any other personal data not described in thisPrivacy Policy.
If you have given us your consent to the processing of your personal data, the processing will only occur for the defined purposes and to the extent agreed in the consent.
With your consent, we process data for the following purposes: direct marketing and advertising, Website analysis.
A given consent can be revoked at any time without giving reasons with effect for the future if you no longer agree to the processing. Revoking your consent does not affect the legality of the processing carried out based on your consent up to the point of withdrawal.
Payment-related information: our payment processing partners collect the data necessary to process payments and/or chargeback requests (transaction date, payer IP address, full name of the owner and credit card number). We process only a very small portion of this payment information (part of the credit card number, payer IP address, payment amount and currency, payment date and card expiration date) to address payment-related issues (e.g. fraud prevention). We also collect information about your country of residence, as this is required to calculate VAT/sales tax in that region.
The legal basis for processing personal information is the legal obligation that applies to us (where it is necessary to collect your data in accordance with the law) and our legitimate interest in protecting our rights and interests (where there are other legal processes relating to you).
We are subject to accounting, tax and other legal requirements (in particular, providing information to law enforcement authorities). We may need to collect and store some of your personal data: email address, subscription and payment information, legal documents, etc. in order to protect our rights and legitimate interests.
We guarantee that your personal data will not be sold in any way by the Company.
WHAT ARE COOKIES AND HOW DO WE USE THEM?
Below we explain how we use cookies to recognize you when you visit our Website. In some cases we may use cookies to collect personal data, or that becomes personal data if we combine it with other information.
Cookies are text files containing small amounts of information which are downloaded to your computeror mobile device when you visit a website and allow a website to recognize your device. The use of cookies is standard practice for most websites at the moment. Website owners use cookies in order to make their websites work, or to workmore efficiently, as well as to providereporting information.
You can refuseall cookies, or make your device alert you each time they are used, or use software products that can manage cookiesfor you.
Most browsers allow you to view, delete,and block cookiesfrom websites. In case all cookies are deleted, all Websites’ settings will be reset for you.
You can use the links below to read instructions for managing cookies on popular browsers:
- Google Chrome (https://support.google.com/chrome/answer/95647)
- Mozilla Firefox (https://support.mozilla.org/en-US/kb/enhanced-tracking- protection-firefox-desktop)
- MacOS Safari (https://support.apple.com/kb/index? page=search&q=cookies%20safari&locale=en_US)
- Microsoft Internet Explorer(https://support.microsoft.com/en-us/windows/manage-cookies-in-microsoft- edge-view-allow-block-delete-and-use-168dab11-0753-043d-7c16-ede5947fc64d)
Information on other browsers and device types can be found at http://www.aboutcookies.org/ and http://www.cookiecentral.com/faq/.
However, please note that cookies deletion or blocking may affect for you the interface of our Websiteand make part of the Website’s components unavailable to you.
Cookies can be of the following types:
- Persistent cookies – will be stored by a web browser for a specified period of time regardless of whether the browser is opened or closed, unless deleted by the you before the expiration date;
- Session cookies – will expire at the end of your session, when the web browser is closed.
- First-party cookies – placed on your device by the Website, the domain name of which is displayed in the addressbar of the browser.
- Third-Party Cookies – placed on your device by a website, the domain name of which differs from the domain name displayed in the address bar of the browser. Third parties use programming code to collect information about your interaction with our Website, such as the pages you visit, the links you click on and how long you are on our Website.
ddg1
Essential
They are used to
identify the userwhen sending a verification request, duringa DDoS attack or suspicious activity.
1 year
ddg2
Essential
They areused to
identify the userwhen sending a verification request, duringa DDoS attack or suspicious activity.
1 year
ddgid
Essential
They are used to
identify the userwhen sending a verification request, duringa DDoS attack or suspicious activity.
1 year
ddgmark
Essential
They areused to
identifythe user whensending a verification request, during a DDoS attack, or
suspicious activity.
1 day
csrf
Essential
They areused for
authorisation of the user
1 year
session
Essential
They are usedfor
authorisation of the user
1 month
_chatwoot_session
Essential
Used by the
Chatwoot Super Admin panel to persist the user session
1 year
cw_conversation
Essential
This cookie lets Chatwoot persist the conversation when the contact navigates through the webpages or
1 year revisits the website later
HOW LONG DO WE RETAIN YOUR PERSONAL DATA?
The Company will retain your personal data only for as long as necessary. We maintain specific records management and retention policies and procedures, so that personal data are deleted after a reasonable time according to the following retention criteria:
- We retain your personal data necessary to provide you with access to your Account for as long as you use your Account and for no more than 3 years after you stop using it.
- We retain your personal data necessary to provide our Services and analyse and improve the performance of our Website and/or Services and user interactions as long as we have an ongoing relationship with you (in particular, while you have an Account with us).
- We will only keep your personal data required to provide our Services for as long as your Account is active or you use our Services and give us your consent to keep your personal data.
- We retain your personal data necessary for communication and customer support for no longer than 3 years from the date of last contact.
- We retain your personal data for marketing and advertising purposes for as long as you we have an ongoing relationship with you.
Your personal data may be deleted at your request, unless applicable law requires us to keep certain personal information, including the following situations:
- If there is an unresolved issue related to your Account (such as an unresolved claim or dispute), we will retain necessary personal data until such issue is resolved;
- If it is necessary to retain your personal data to comply with our legal, tax, audit and accounting obligations, we will retain only necessary personal information for the period required by applicable law;
- If it is necessary to fulfil our legitimate business interests - for example, to prevent fraud or to ensure the safety of our users.
WILL WE SHARE YOUR PERSONAL DATA WITH THIRD PARTIES?
We share your personal data with third parties only for the purposes described above and permitted by applicable law. We never sell your data to anyone.
We may share your personal data with our service providers and professional advisors, public and governmental authorities (only when we are asked to do so and when we are obliged to do so by law) or third parties in connection with the Company’s operation of its business. Such third parties may be located both within the European Economic Area (EAA) and outside of it. In any case, before sharing your personal data, we will take the necessary steps to ensure that your personal data are adequately protected as required by relevant data privacy laws and internal Company’s policies, based on the standards of the GDPR.
In particular, we share your information with service providers that render services to us, including legal services, customer support, payment processing, email deployment, accounting and auditing.These parties may only use or pass on this data in so far as this is necessary to provide services for us or to comply with legal regulations. We contractually obliged these third parties to guarantee the confidentiality and security of your personal data that they process on our behalf.
Main third parties contracted by the Company that may process your personal data are the following:
- Email deployment –SendGrid by Twillo(Ireland, USA).
- Application analytics and diagnostics – Google Analytics by Google (USA).
Please note that any transfers of your personal data from within the EEA to third parties outside the EEA will be:
- made to those countries, which the European Commission recognizes as countries with an adequate level of data protection (list of countries available here: https://commission.europa.eu/law/law-topic/data-protection/international- dimension-data-protection/adequacy-decisions_en), or
- based on the standard contractual clauses approved by the European Commission (available here: https://ec.europa.eu/commission/presscorner/detail/en/ip_21_2847).
We may also share your personal data if we are required to do so by law or during legal proceedings, or if we believe that disclosure is necessary to avoid damage or financial loss, or in connection with an investigation into suspected or actual fraudulent or illegal activities.
We may also share your information in connection with a substantial corporate transaction, such as the sale of a website, a merger, consolidation, asset sale, initial public offering, or in the unlikely event of a bankruptcy.
DO WE USE AUTOMATED DECISION-MAKING, INCLUDING PROFILING?
Automated decision making is the process of making decisions by automated means without human intervention. Profiling analyses aspects of a person’s personality, behaviour, interests and habits in order to make predictions or make decisions about them. We assure you that we do not make decisions based solely on automated processing, including profiling, which may have legal consequences for you. In case we would make such a decision in any scope, you shall be entitled to object to it.
WHAT CHOICES CAN YOU MAKE ABOUT HOW WE USE YOUR INFORMATION?
We comply with the GDPR and other privacy laws. The GDPR and other privacy laws provide individuals with certain rights regarding their personal data. The rights you have with respect to your personal data are the following:
Right to access
You may obtain from us the confirmation as to whether or not your personal data are being processed, as well as access to your personal data. The Company provides such information free of charge.
However, where the request is manifestly unfounded or excessive (in particular because of repetitive character), the Company may either:
- charge you a reasonable fee taking into account the administrative costs of providing the information or communication or taking the action requested;
- refuse to act on the request.
Right to rectification
If necessary, you can request the correction of incorrect personal data and the completion of incomplete personal data.
Right to erasure
You have the right, without explaining the reason and without undue delay, to have your personal data erased, provided that the following conditions apply:
- The personal data are no longer necessary in relation to the purposes for which they were collected or processed.
- You withdraw your consent on which the processing is based and there are no other legal grounds for the Company to continue the processing.
- You object to processing and there are no overriding legitimate grounds for the Company to continue the processing.
- The personal data have been unlawfully processed.
- The erasure of personal data is necessary to fulfil a legal obligation under law to which the Company is a subject.
Right to restriction
You may ask us to restrict the processing of your personal data in whole or in part, if one of the following conditions is met:
- You contest the accuracy of the personal data (the restriction applies for a period enabling the Company to verify the accuracy of the personal data).
- The processing of your personal data is unlawful, and you refuse to have your personal data erased and request that its use be restricted instead.
- The Company no longer needs your personal data for processing purposes, but you require them for the establishment, exercise or defence of legal claims.
- You have objected to the processing of your personal data, and it has not yet been determined whether the Company’s legitimate grounds outweigh your own.
Right to objection
You may object to the processing of your personal data. However, this right is not absolute and the Company may demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims.
Where personal data are processed for direct marketing purposes, you have the right to object at any time to processing of your personal data for such marketing, which includes profiling to the extent that it is related to such direct marketing.
Right to portability
You may request to receive your personal data, which you have provided to the Company, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from the Company. You may also request the Company to transmit your personal data directly to another controller named by you, provided that the portability of your personal data technically feasible.
Right to withdraw consent
If we collected and processed your personal data with your consent, you may withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of their processing prior to your withdrawal, nor will it affect the processing of your personal information carried out on lawful processing grounds other than consent.
Please note that if you withdraw your consent, we may no longer be able to offer you our Services. Withdrawing Your consent does not affect the legality of the processing of Your personal data based on Your consent up to the point of withdrawal.
Right to lodge a complain
You have the right to lodge a complaint with a data protection supervisory authority.
To exercise the above rights please contact us by sending an email to privacy@luxeproxy.com.
HOW DO WE PROTECT YOUR PERSONAL DATA?
The Company attaches great importance to your right to privacy and the protection of your personal data. We want you to feel secure when you visit our Website and uses our Services, as well as in the course of all other business transactions with the Company.
The Company maintains the appropriate organizational, physical and technical security arrangements to protect your personal data against unauthorized or unlawful processing and/or against accidental loss, alteration, disclosure or access, or accidental or unlawful destruction of or damage thereto.
We have implemented various security measures, including SSL/TLS encryption for data transmission, hashed passwords, firewalls and regular independent audits. We assigned Data Privacy Officer and conduct regular staff trainings. We also apply network segmentation: the database server is inaccessible to external users. We take all steps reasonably necessary to process your personal data securely.
Please be aware that despite all security measures, our Website and Services may not always be 100% secure. Whenever you provide your information online, there is a risk that it may be intercepted and used by a third party. While we do our best to protect your personal data, we cannot guarantee the security of any information you provide online.By using the Website and Services, you expressly acknowledge and agree that we cannot guarantee the security of data provided by you or received by us through theServices and that any information you provide is at your own risk.
HOW TO CONTACT US?
For the matters regarding this Privacy Policy, as well as regarding any privacy matter you may contact us via email, by sending your inquiry at privacy@luxeproxy.com.
You may contact us via mail, by sending us your letter to our registered address: Estonia, Harju maakond,Tallinn, Lasnamäe linnaosa, Väike-Paala tn 2, 11415.
You may also contact our DPO via email, by sending your inquiry at privacy@luxeproxy.com, or via letter, clearly marked for the attention of the Data Protection Officer, on this address: Estonia, Harju maakond, Tallinn, Lasnamäe linnaosa, Väike-Paala tn 2, 11415.
We will provide a response to your inquiry no later than within one month from the date of its receipt (with the possibility of extension for another two months).
DO WE MAKE UPDATES TO THIS POLICY?
This Privacy Policy is in effect until superseded by a new policy. We may update this Privacy Policy at our discretion. The most currentversion of the Policy is indicated by the date it was last updated at the top of the page. The continuous use of our Website and Services shall be deemed as acceptance and understanding the terms of this Policy as it currently stands.
You shall periodically check and assess the Privacy Policy. Any update of the Privacy Policy comes in force at the moment it is published at the website.
We will not reduce your rights under this Privacy Policy without your explicit consent. Nor will we hide from you any updates regarding any changes to purposes of data processing, transfer of personal data to a third country. If changes are significant, we’ll provide you in advance with a more prominent notice (including by sending an email notification of Privacy Policy changes).
The experts at Luxeproxy are always prepared to help you find the ideal solution for any requirement.
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