Privacy Policy

This Privacy Policy forms part of, and should be read together with, our Terms and Conditions (the “Terms”). In this Privacy Policy, “Our Sites” means proxidize.com, its subdomains, or any other website that we use to deliver the Software and/or Services as updated from time to time.

If you do not agree to the terms of this Privacy Policy, you should not use our Software, Goods or Services, and you should uninstall any Software you have installed and stop using any Goods or Services we provide.

Proxidize Ltd is the controller and is responsible for your personal data (collectively referred to as "Proxidize", "we", "us" or "our" in this policy).

Our full company details are:

• Full name of legal entity: Proxidize Ltd (incorporated in England with number 13941330)
• Email address: support@proxidize.com
• Postal address: 85 Great Portland Street, London W1W 7LT, United Kingdom.

You can contact us at the above address should you have any questions about this Privacy Policy, or if you would like to exercise any of your rights under applicable data protection laws, which we set out below.

Our Sites may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. Please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as Contact Data. Please check these policies before you submit any personal data to these websites or use these services.

We may collect, use, store and transfer different kinds of personal data about you as follows:

• Identity Data including first name, last name, username or similar identifier, KYC/government issued ID and information within such (e.g. date of birth, gender, marital status), business registration documents.
• Contact Data including email address, phone number, billing address, delivery address, location.
• Financial Data including payment method details (e.g. bank account and billing information).
• Transaction Data including payment details such as purchase history, subscription details, invoice records, payment confirmations.
• Device Data including IP address, type of device used, unique device identifiers (e.g. IMEI, MAC address, mobile phone number used), mobile network information, operating system, browser type.
• Profile Data including account preferences, username and passwords, selected proxy configurations, usage settings, KYC status, software purchase history, your interests, preferences, feedback and survey responses.
• Usage Data includes details of your use of any of our Software or your visits to any of Our Sites including, but not limited to, traffic data and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access, proxy session logs, bandwidth usage, timestamps, feature interactions, error logs.
• Marketing and Communications Data including marketing preferences, newsletter subscriptions, support ticket history, feedback.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Software feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic data).

We collect personal data about you from the following sources:

• Information you give us. This is information (including Identity, Contact, Financial, and Marketing and Communications Data) you provide us by filling in forms on Our Sites, or by corresponding with us (for example, by email or chat). It includes information you provide when you register to use any of Our Sites, download or register Software, subscribe to any of our Services, search for Software or a Service, enter a competition, promotion or survey, and when you report a problem with Software, our Services, or any of Our Sites.
• Information we collect about you and your device. Each time you visit one of Our Sites or use our Software we will automatically collect personal data including Device and Usage Data. We collect this data using cookies and other similar technologies. Please see the Cookies section of this Privacy Policy for further details and information on how you can manage your cookie preferences.
• Information we receive from other sources including third parties. We will receive personal data about you from various third parties as set out below
  
  Device Data from the following parties:
  
  analytics providers;
• advertising networks; and
• search information providers.
• Contact, Financial and Transaction Data from providers of technical, payment and delivery services;
• Identity Data from KYC providers; and
• Device Data from third parties where they have shared access details of their sites.

We use cookies and/or other tracking technologies to distinguish you from other users of the Software or Our Sites and to remember your preferences. This helps us to provide you with a good experience when you use the Software or browse any of Our Sites and also allows us to improve the Software and Our Sites. In this Privacy Policy we use the term “cookies” to refer to cookies and similar technologies such as pixels, tags, SDKs, and local or session storage.

What are cookies?

Cookies are small text files that are stored on your browser or device when you visit a website or use an online service. Cookies may be set by us (first-party cookies) or by third parties (for example, analytics, advertising, or customer support providers) acting on our behalf.

Types of cookies we use

We group the cookies and similar technologies we use into the following categories:

• Necessary cookiesThese are required for Our Sites and the Software to function properly and securely. They include, for example, cookies that let you log in and stay logged in, keep your session secure, balance traffic across our servers, and help us detect fraud or misuse. These cookies are always active and cannot be switched off in our systems, although you may be able to block them using your browser settings. If you do so, some parts of Our Sites or the Software may not work correctly.
• Functional cookiesThese cookies help us to improve your experience by remembering your preferences and settings (such as language, timezone, device type, or the last step you reached in a sign-up or purchase process) and by helping us to understand how Our Sites and the Software are used (for example, which pages are visited most often or where users encounter errors). If you disable these cookies, some non-essential features may not be available or may not function smoothly.
• Marketing cookiesThese cookies help us and our partners to measure and improve the effectiveness of our marketing campaigns and understand how you arrived at Our Sites (for example, via a particular advert or campaign). These cookies are not essential for the core operation of Our Sites or the Software and are generally used only where you have given your consent.

Depending on your location and the applicable data protection laws, we will only set non-essential (Functional and Marketing) cookies with your consent. Where we rely on consent, you can withdraw or change it at any time as described below.

How you can manage cookies

• Cookie banner and Cookie Settings on proxidize.com

When you first visit proxidize.com (including its subdomains), you will see a cookie banner. This allows you to accept or reject non-essential cookies and to choose which categories of cookies (for example, Functional and Marketing) you want to allow.

A “Cookie Settings” button is available on proxidize.com at all times. You can use this button at any time to reopen the cookie settings, review your current choices, and enable or disable non-essential cookie categories. Your updated choices may require you to refresh the page before they take effect.

• Other controls and browser settings

On other parts of Our Sites and within the Software, you may have additional in-product privacy or settings options. In addition, most web browsers allow you to control cookies through the browser settings, including blocking cookies altogether, deleting existing cookies, or setting your browser to alert you before cookies are stored. If you use your browser settings to block all cookies (including Necessary cookies), some parts of Our Sites or the Software may not operate correctly.

Other technologies and third-party services

We also use technologies such as localStorage and sessionStorage for similar purposes to cookies, for example to remember choices you have made, to measure usage and performance or to support certain features. For the purposes of this Privacy Policy, we treat these technologies in the same way as cookies.

Some features of Our Sites and the Software rely on third-party services (for example, booking tools, media players, embedded widgets, analytics and advertising providers). These third parties may set their own cookies and similar technologies when you use those features or view content that is served from their services. Our cookie banner or Cookie Settings panel provides more information about these services and, where required, allows you to control whether they are used.

We update our use of cookies and similar technologies from time to time as we develop and improve Our Sites and the Software. The Cookie Settings panel on Our Sites provides more detailed and up-to-date information about the specific cookies and services we use at any given time, including their purposes and typical retention periods, so that you can make an informed choice about your preferences.

Data protection laws require us to have a legal basis for everything that we do with your personal information falling under one of the following categories:

• Performance of a contract with you: Where we need to perform a contract we are about to enter into or have entered into with you.
• Legitimate interests: We may use your personal information where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and/or enable us to give you the best user experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal information for our legitimate interests. We do not use your personal information for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
• Legal obligation: We may use your personal information where it is necessary for compliance with a legal obligation that we are subject to.
• Consent: We rely on consent where we have obtained your active agreement to use your personal information for a specified purpose, for example in relation to receiving marketing communications from us, participating in optional prize draws, competitions or surveys, or where applicable laws require us to obtain consent for certain advertising, analytics or cookie-related activities.
• Vital Interests: We may process your personal information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.

We use your personal information in a number of different ways and for different reasons. The tables below set out what we do and why.

Purposes for which we will use your personal data

Where we need to collect personal information due to a legal or regulatory obligation, or for performance of a contract, and you do not provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our Services). We will notify you of this at the time.

We may share your personal data with third parties who provide services to us, for example, our IT, communications, KYC, CRM, email and marketing automation, and hosting providers.

The categories of data recipients we may disclose your personal information to are as follows:

Service Providers and Processors. We engage third party service providers, from time to time, including:

• IT & website hosting, KYC, CRM, fulfilment, communications and analytics service providers;
• Professional advisors such as tax, banking, auditing, insurance and legal advisors (for example, as necessary for the establishment, exercise or defence of legal claims or to protect the rights or safety of Our Sites, our Services or us);
• Consultants, insurance companies/claim managers and accountants; and
• Agents, suppliers or sub-contractors, and other associated organisations where they are engaged by us to help deliver a service or product that we have instructed them on.

Relevant parties as part of providing the Software and/or Services. We may disclose personal information where this is necessary to investigate and respond to issues or complaints raised by third-party website operators in relation to activities carried out via our Services (for example, where a website contacts us about potentially unauthorised scraping conducted through our proxy infrastructure).

Third parties in case of a legal requirement. We also disclose your personal information if disclosure is required by law or in the context of an investigation, regulatory requirement, judicial proceeding, court order or legal process (including to law enforcement or competent authorities like the police/tax authorities, such as HMRC in the UK).

Third parties in case of a corporate transaction. In addition, information about our customers and users, including personal information, may be disclosed as part of any merger, sale, transfer of our assets, investment, acquisition, bankruptcy, or similar event, including while engaging with our actual or potential investors.

We may provide anonymous information to analytics and search engine providers to help us improve and optimise our services. We will only share this information in a form that does not directly identify you.

Whenever we transfer your personal data out of the UK or the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data, or
• Where we use certain service providers or transfer your data back to you where you are in a country not deemed to provide an adequate level of protection for personal data, we may use specific standard contractual terms approved for use in the UK and EU which give personal data the same protection it has in the UK and EU.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data.

All information you provide to us is stored on our secure servers. Any payment transactions carried out by us or our chosen third-party provider of payment processing services will be encrypted. Where we have given you (or where you have chosen) a password that enables you to access certain parts of Our Sites, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

We are committed to protecting individuals’ personal information. We put in place appropriate technical and organisational measures to help protect the security of your personal information. However, be aware that no system is ever completely secure.

We have put various safeguards in place to guard against unauthorised access and unnecessary retention of personal information in our systems. These include pseudonymisation, encryption, access, and retention policies. Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.

We will only retain your personal information for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting, or reporting requirements. We may retain your personal information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. For further information about specific retention periods, please contact us.

You have a number of rights under data protection laws in relation to your personal information.

You have the right to:

• Request access to your personal information (commonly known as a "subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
• Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal information in certain circumstances. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal information to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
• You also have the absolute right to object at any time to the processing of your personal information for direct marketing purposes.
• Request the transfer of your personal information to you or to a third party. We will provide to you, or a third party you have chosen, your personal information in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
• Request restriction of processing of your personal information. This enables you to ask us to suspend the processing of your personal information in one of the following scenarios:
• If you want us to establish the data, '‘': s accuracy;
• Where our use of the data is unlawful but you do not want us to erase it;
• Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
• You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

If you wish to exercise any of the rights set out above, please contact us.

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

You have the right to make a complaint at any time to the relevant data protection regulator.  In the UK this is the Information Commissioner’s Office (ICO) (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach any regulator, so in the first instance please contact us.

We may update this Privacy Policy from time to time, for example to reflect changes to our Software, Services, business practices or applicable data protection laws. Any changes we make will be posted on Our Sites and the updated Privacy Policy will be indicated by an updated “Last updated” date at the top of the policy.

If we make any material changes to this Privacy Policy, we will take appropriate steps to bring those changes to your attention. This may include, for example, posting a prominent notice on Our Sites, sending you an email or providing an in-product notification, before the changes take effect, where required by applicable law.

We encourage you to review this Privacy Policy periodically so that you remain informed about how we use, protect and share your personal information. Your continued use of Our Sites, the Software or our Services after any changes to this Privacy Policy have been made will constitute your acknowledgement of the updated Privacy Policy.