Privacy Policy

TraceFree Privacy Policy

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TRACEFREE PRIVACY POLICY

This Privacy Policy (“Privacy Policy” or “Policy”) sets forth the privacy practices of TraceFree Corp. (hereinafter called “TraceFree” or “Company”) and applies to users (“user(s)” or “you”) of the TraceFree virtual private browser software (“Software Product”) available through the Company’s website at: www.tracefree.com (“Website”).

This Policy applies to all Services that we offer, and also applies to the Website as well as your use of the Software Product. This Policy does not apply to any website, product or service of any third-party company even if the website links to (or from) our Website or Software Product. Please always review the privacy practices of any third-party company before deciding whether to provide any information. By using our Website or Software Product, you are accepting the practices described in this Policy. If you do not agree with this Policy, please do not visit or use our Website or use the Software Product. Your continued use of our Website or Software Product will signify your acceptance of this Policy.

1. WHAT DATA DO WE COLLECT?

A. Information related to your account (“Personal Data”)

When registering through our Website or Software Product you will be requested to provide certain personal information, such as an e-mail address, and payment information which you submit to us voluntarily when you order or subscribe for our Software Product, as well as when you fill out any of the contact forms on the Website. This information is collected for proper administration of your account and/or subscription and to offer you customer support. Additionally, as part of our fraud detection measures, we shall collect data relating (i) to Website usage information, such as IP address (captured and stored in an anonymized format), approximate location, (ii) transaction information, items purchased, the price paid, billing method, partial credit card information, chargeback requests, cancelled orders. The above mentioned Personal Data is not, at any point, associated with any kind of activity done by the user inside the Software Product.

B. Anonymous Information (“Non-personal Data”)

Additionally, we collect and/or receive and store certain non-personal information (“Non-personal Data”) whenever you interact with us. This exchange of information occurs between your browser and our affiliates or our server occurs automatically upon accessing our pages. Through such exchange we receive Non-personal Data including without limitation, data relating to the browser you are using, mobile/desktop device, general properties and metadata, OS version, preferred language, the date and time of your visit, the referring website and your preferences in our Websites and Software Product during your visit or usage. We collect such statistical information about usage as aggregate data from both the Website and Software Product in order to maintain a better customer experience as well as a high level of quality for the Software Product.

With regards to the Software Product, Non-personal Data is not associated with or linked to your Personal Information. Thus Non-personal Data does not permit the identification of individual persons. Additionally, Non-personal Data do not include any information about the activity performed by the user inside the Software Product, such as browsing history, web content accessed, destinations of VPN traffic, DNS queries and IP addresses. We use this information for internal monitoring, analytics and improvement of our services in the way described in this Policy.

C. Web Browsing Data

Additionally, when a user is utilizing the Software Product, we collect and/or receive and store the user’s traffic data, such as your IP address, browsing history, traffic destination, and connection logs, such as a connection timestamp and session duration.

2. HOW DO WE COLLECT PERSONAL DATA?

Our Website and Software Product contains a registration form (e.g. during payment process or during customer support and review) that will ask users at their discretion to provide us with certain information such as their email address as detailed above. We use this information to create an account, provide services, etc. We do not share this information with third parties, except as detailed below and other than with the people/or associate working with the Software Product or Website. We additionally may use technologies such as cookies, beacons, tags and scripts when visiting our Website.

3. HOW DO WE COLLECT NON-PERSONAL DATA?

We automatically collect anonymous Non-personal Information through different technologies as described below.

A. Website

Our website may use 3rd parties such as Google Analytics and third-party analytics to better understand how you use the Site and ways that we can improve your experience. Through this tool we can see trends of usage of our Website such as total number of unique users, popular webpages or articles by number of total impressions, etc. These third parties use pixels or cookies to measure things such as the average time spent by users on the Site or visited pages so we learn how to improve the Site for you. Additionally, we use third-party optimization companies, which similarly use cookies to provide such services.

B. Software Product

The performance of the Software Product is measured through a series of events sent anonymously to a third-party service which is building aggregate data based on certain trends. A few examples of events are indicatively mentioned below.

Connection Attempt. We collect this information to know the usage request directed to our Software Product on a particular hourly/daily/weekly/monthly interval, the country of origin (but not your source IP address), your Software Product version, etc. This metric allows us to properly adjust our infrastructure according to the demand.

Connection Successful. We collect this information to know how many users per hourly/daily/weekly/monthly intervals successfully established connections to our service. This information correlated with the above event results, is helping our engineers to determine if there are any network issues which might prevent users from starting the service, identify peak hour intervals for our service so we can have the infrastructure scaled to meet the requests, etc.

4. HOW DO WE COLLECT WEB BROWSING DATA?

When a user is utilizing the Software Product, we automatically collect and/or receive and store the user’s traffic data, such as your IP address, browsing history, traffic destination, and connection logs, such as a connection timestamp and session duration. Said Web Browsing Data is collected to comply with applicable regulations.

5. ORDERING OUR SOFTWARE PRODUCT

To order our Software Product you must choose which option works best for you on our pricing page. You will be asked to register to create a secure account by inserting your email account. Thereafter you will be asked to choose your method of electronic payment. The specific information collected varies depending on the payment method you choose.

Please note that the Software Product itself does not process any orders or payments because we work exclusively with payment processors.

Once you chose make an electronic payment, you will be directed to our third-party payment gateways domain. Although this page may have the look and feel of the Website please make sure that you are aware that you are now on our third party payment processor’s site in order to complete your transaction. The name, address, card number, expiration date, and email address will be collected by the applicable, third party payment processor to process your request. Your name and email address will be shared back with us in order for us to provide you with your subscription to the Software Product.

We do not have any access to the credit card information you submitted to our payment processor. The payment processors privacy policy governs the collection and use of the information collected during the check-out process which we recommend you review prior to placing an order or providing any information.

6. WHY DO WE COLLECT YOUR PERSONAL DATA?

We collect the Personal Data for the purpose of:

● Service improvement and personalization of the user experience on Software Product

● The proper administration of our Website and business

● The performance of the contract between you and us and/or taking steps, at you request, to enter into such a contract

● Fraud detection/prevention and improvement of the Software Product

● To send you technical or service-related communications

● To enforce the Terms of Service

● Customer analytics

7. SHARING YOUR DATA

We do not share, sell, rent or trade your Personal Data or Web Browsing Data with third parties other than as disclosed within this Privacy Policy. Furthermore, we may share certain Personal Data with trusted vendors to carry out a transaction you have requested (e.g., sharing card payment information with our credit card processor to obtain payment of fees and to activate your subscription to the Software Product).

In order to assist you if you have questions while using our Website or regarding your order and provide comprehensive customer support, we offer the possibility of technical support via email. For the use of such technical support, you will be requested to provide personal data such as name and email. We will have access to collect and process such personal data solely for the purpose of facilitating communication with you and record-keeping.

We may further collect and possibly share your Personal Data or Web Browsing Data to enforce the Terms of Service. This may be done to prevent a crime or violation of our Terms of Service or to help solve a transgression that has been committed.

We also reserve the right to disclose your Personal Data or Web Browsing Data as required by law and when we believe that disclosure is necessary to protect our rights and/or comply with a judicial proceeding, court order, or legal process served on our Website or Company. Before we disclose such Personal Data or Web Browsing Data as required by law and when we believe that disclosure is necessary to protect our rights and/or comply with a judicial proceeding, court order, or legal process, we will notify you.

Lastly, we may share Non-personal Data associated with the use of our Website and Software Product with 3rd part suppliers for the purposes of optimization of our Website and Services as well customer analytics. These third parties will use Non-personal Data and/or Personal Data relating to your use of our Website and Software Product to evaluate your use of the Website, compile reports on Site activity and provide other Site activity and internet related services, all in accordance with their applicable privacy policy.

8. SECURITY OF YOUR PERSONAL DATA

We follow generally accepted industry standards to protect the Personal Data submitted to us and Web Browsing Data, both during transmission and once we receive it. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your Personal Data and Web Browsing Data, we cannot guarantee its absolute security. If you have reason to believe that your interaction with the Website or Software Product is no longer secure (for example, if you feel that the security of your account has been compromised), please contact us immediately.

During the development of the Software Product and the selection of its service providers, the Company has paid attention to providing a high degree of safety. All data processing centers with which the Company cooperates pass through a compliance process. The Company has generally root access to all its servers and administers them itself.

If you feel that your privacy was treated not in accordance with our Policy, or if any person attempted to abuse our Software Product or acted in an inappropriate manner, please contact us directly at [email protected] Further, in the event of a data breach, in which we discover your Personal Data or Web Browsing Data is at risk, we will notify you immediately through your account or the Website or, if technically possible, by sending you an email.

9. CHILDREN’S PRIVACY

You represent and warrant that you are at least 18 years of age and of legal competence to use our Service. If you are under 18, please be sure to read the Agreement with your parents or legal guardians. We do not use the Service to knowingly solicit data from or market to children under the age of 18. We request that such individuals do not provide Personal Data through our services. If you become aware or have any reason to believe that a child under the age of 18 has shared any information with us, please contact us at: [email protected] and we take reasonable steps to ensure that such information is deleted from our files.

10. DATA RETENTION

We may rectify, replenish or remove incomplete or inaccurate information, at any time and at our own discretion as detailed above. We retain the information we collect for as long as needed to provide the Software Product and to comply with our legal obligations, resolve disputes and enforce our agreements.

11. POLICY UPDATES

If we decide to make changes to our Privacy Policy, at our sole discretion, such changes and updates will be effective immediately upon the display of the revised Privacy Policy. Thus, we encourage you to check this Privacy Policy regularly for updates, so that you are fully informed on how your data is collected and used by the Company and your related rights. The last revision date will be reflected in the “Last Modified” heading. Your continued use of the Software Product following the display of such amendments constitutes your acknowledgement and consent to such amendments to the Privacy Policy and your agreement to be bound by the terms of such amended policy.

If we make material changes to this Privacy Policy, we will notify you through the account or the Website and make best efforts to notify you via email, or by means of a notice on our home page prior to the change becoming effective.

12. CONTACT INFORMATION

TraceFree Virtual Private Browser is owned and operated by TraceFree Corp., a Delaware corporation. Our principal mailing address is: 160 W. Camino Real Suite #206Boca Raton FL 33432.

You can contact us by mail at the address given above, our website contact form, or by email at [email protected]

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