Proxytool's Privacy Policy

Effective date: May 1, 2022

At Proxytool OÜ (“Proxytool”), we take your privacy seriously. Please read this Privacy Policy to learn how we treat your personal data. By using or accessing our Services in any manner, you acknowledge that you accept the practices and policies outlined below, and you hereby consent that we will collect, use and share your information as described in this Privacy Policy.

Remember that your use of Proxytool's Services is at all times subject to our Terms of Service, which incorporates this Privacy Policy. Any terms we use in this Policy without defining them have the definitions given to them in the Terms of Service.

Summary of our Privacy Policy

We know, privacy policies are no fun. Here at Proxytool, our goal is to help you save time and make life easy for you. In the course of providing our Services, we will collect certain information about you, which is necessary for us to best achieve that goal. Our intent is to only collect the information we need to provide our Services to you. We will only share your data with third parties to help make our Services a reality. We will not sell your personal information to third parties.

Privacy Policy Table of Contents

What this Privacy Policy Covers

This Privacy Policy covers how we treat Personal Data that we gather when you access or use our Services. “Personal Data” means any information that identifies or relates to a particular individual and also includes information referred to as “personally identifiable information” or “personal information” under applicable data privacy laws, rules or regulations. This Privacy Policy does not cover the practices of companies we don't own or control, or people we don't manage.

Personal Data

Categories of Personal Data We Collect

This chart details the categories of Personal Data that we may collect and may have collected from or about you over the past 12 months. Please note that many of these categories of Personal Data will only be collected if you choose to provide them to us:

Category of Personal Data Examples of Personal Data We Collect Categories of Third Parties With Whom We Share this Personal Data:
Profile or Contact Data - Display name
- Email address
- Phone number
Payment Data - Payment card type
- Payment card number
- Billing name, address, phone number, and email 		- This information is directly processed by our Service Providers (specifically our payment processing partner, currently Paddle). We do not process or store your entire payment card number.
Device/IP Data - IP address
- Host name
- Type of device/operating system/browser used to access the Services 		- Service Providers
- Analytics Partners
Web Analytics - Web page interactions
- Referring webpage/source through which you accessed the Services
- Statistics associated with the interaction between device or browser and the Services 		- Service Providers
- Analytics Partners
Social Network Data - Email address
- User name 		- Service Providers
Geolocation Data - IP-address-based coarse location information - Service Providers
- Analytics Partners
Other Identifying Information that You Voluntarily Choose to Provide - Identifying information in emails, letters, Proxytool messages or support communications you send us
- Proxytool messages, uploaded files, stream descriptions, and other content you provide using our Services (e.g. in a Proxytool client)
- Values of custom profile fields configured by your Proxytool Organization, where you might choose to enter your phone number, job title, birthday, or other biographical details. 		- Service Providers
- Parties You Authorize, Access or Authenticate
Other Identifying Information that Another User Chooses to Provide to You - Messages or other content that other Proxytool users may send you.
- Messages or content that any Proxytool Organization Administrator of a Proxytool community that you may join may provide about you. 		- Service Providers
- Parties You Authorize, Access or Authenticate

Categories of Sources of Personal Data

We collect Personal Data about you from the following categories of sources:

Our Commercial or Business Purposes for Collecting Personal Data

We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated or incompatible purposes without providing you notice.

How We Share Your Personal Data

We disclose your Personal Data to the categories of service providers and other parties listed in this section. We do not sell Personal Data.

We may share any Personal Data that we collect with third parties in conjunction with any of the activities set forth under “Meeting Legal Requirements and Enforcing Legal Terms” in the “Our Commercial or Business Purposes for Collecting Personal Data” section above.

Business Transfers

All of your Personal Data that we collect may be transferred to a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part). Should one of these events occur, we will make reasonable efforts to notify you before your information becomes subject to different privacy and security policies and practices.

Data that is Not Personal Data

We may create aggregated, de-identified or anonymized data from the Personal Data we collect, including by removing information that makes the data personally identifiable to a particular user. We may use such aggregated, de-identified or anonymized data and share it with third parties for our lawful business purposes, including to analyze, build and improve the Services and promote our business, provided that we will not share such data in a manner that could identify you.

Tracking Tools and Opt-Out

The Services use cookies and similar technologies to enable our servers to recognize your web browser, tell us how and when you visit and use our Services, analyze trends, learn about our user base and operate and improve our Services. Cookies are small pieces of data – usually text files – placed on your computer, tablet, phone or similar device when you use that device to access our Services. We may also supplement the information we collect from you with information received from third parties, including third parties that have placed their own cookies on your device(s). Please note that because of our use of cookies, the Services do not support the “Do Not Track” setting available in some browsers. We use the following types of cookies:

You can decide whether or not to accept cookies through your internet browser's settings. Most browsers have an option for turning off the cookie feature, which will prevent your browser from accepting new cookies, as well as (depending on the sophistication of your browser software) allow you to decide on acceptance of each new cookie in a variety of ways. You can also delete all cookies that are already on your device. If you do this, however, you may have to manually adjust some preferences every time you visit our website and some of the Services and functionalities may not work.

To explore what cookie settings are available to you, look in the “preferences” or “options” section of your browser's menu. To find out more information about cookies, including information about how to manage and delete cookies, please visit http://www.allaboutcookies.org/ or https://ico.org.uk/for-the-public/online/cookies/ if you are located in the European Union.

Data Security and Retention

We seek to protect your Personal Data from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures based on the type of Personal Data and how we are processing that data. You should also help protect your data by appropriately selecting and protecting your password and/or other sign-on mechanism; limiting access to your computer or device and browser; and signing off after you have finished accessing your account. Although we work to protect the security of your account and other data that we hold in our records, please be aware that no method of transmitting data over the internet or storing data is completely secure.

We retain Personal Data about you for as long as you have an open account with us or as otherwise necessary to provide you with our Services. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personally.

Personal Data of Children

As noted in the Terms of Service, we do not knowingly collect or solicit personally identifiable information from children under thirteen (13) years of age and children below the minimum age of consent in their country; if you are a child under the age of thirteen (13) or below the minimum age of consent in your country, please do not attempt to register for or otherwise use the Services or send us any personal information. If we learn we have collected personal information from a child under thirteen (13) years of age or below the minimum age of consent in their country, we will delete that information as quickly as possible. If you believe that a child under the age of thirteen (13) or below the minimum age of consent in their country may have provided us personal information, please contact us at support@proxytool.io.

California Resident Rights under CCPA

If you are a California resident, you have the rights set forth in this section. Please see the “Exercising Your Rights” section below for instructions regarding how to exercise these rights. Please note that we may process Personal Data of our customers' end users or employees in connection with our provision of certain services to our customers. If we are processing your Personal Data as a service provider, you should contact the entity that collected your Personal Data in the first instance to address your rights with respect to such data.

If there are any conflicts between this section and any other provision of this Privacy Policy and you are a California resident, the portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following rights apply to you, please contact us at support@proxytool.io.

Access

You have the right to request certain information about our collection, use, and disclosure of your Personal Data over the past 12 months. In response, we will provide you with the following information:

Deletion

You have the right to request that we delete the Personal Data that we have collected about you. Under the CCPA, this right is subject to certain exceptions: for example, we may need to retain your Personal Data to provide you with the Services or complete a transaction or other action you have requested. If your deletion request is subject to one of these exceptions, we may deny your deletion request. Please note that we will not be able to delete messages or other content that you have sent to another Proxytool user. If you request deletion of your account, all such messages and content will be associated with a “Deleted User.” In addition, please note that anyone that you send messages or other content to (or who may otherwise have access to such messages or content through a Proxytool Organization or stream) may have downloaded or copied such messages or content. Proxytool will not be able to delete such downloaded or copied messages or content.

Exercising Your Rights

To exercise the rights described above, you or your Authorized Agent (defined below) must send us a request that (1) provides sufficient information to allow us to verify that you are the person about whom we have collected Personal Data, which may include proof of ownership of the email address associated with your Proxytool account, and (2) describes your request in sufficient detail to allow us to understand, evaluate and respond to it. Each request that meets both of these criteria will be considered a “Valid Request.” We may not respond to requests that do not meet these criteria. We will only use Personal Data provided in a Valid Request to verify your identity and complete your request. You do not need an account to submit a Valid Request. We will work to respond to your Valid Request within 45 days of receipt. We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive or manifestly unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request. You may submit a Valid Request using the following methods:

You may also authorize an agent (an “Authorized Agent”) to exercise your rights on your behalf. To do this, you must provide your Authorized Agent with written permission to exercise your rights on your behalf, and we may require you to confirm to us that you did so.

Personal Data Sales Opt-Out and Opt-In

We will not sell your Personal Data, and have not done so over the last 12 months.

We Will Not Discriminate Against You for Exercising Your Rights Under the CCPA

We will not discriminate against you for exercising your rights under the CCPA. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights under the CCPA.

Other State Law Privacy Rights

California Resident Rights

Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to prevent disclosure of Personal Data to third parties for such third parties' direct marketing purposes In order to submit such a request, please contact us at support@proxytool.io .

Proxytool does not disclose Personal Data to any third parties for the purpose of such parties' direct marketing. However, please note that your Proxytool display name, email address, avatar, and other profile information may be shared with other users within any Proxytool Organization that you join.

Nevada Resident Rights

If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Data to third parties who intend to license or sell that Personal Data. You can exercise this right by contacting us at support@proxytool.io with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account.

European Union Data Subject Rights

EU Residents

If you are a resident of the European Union (“EU”), United Kingdom, Lichtenstein, Norway or Iceland, you may have additional rights under the EU General Data Protection Regulation (the “GDPR”) with respect to your Personal Data, as outlined below.

For this section, we use the terms “Personal Data” and “processing” as they are defined in the GDPR, but “Personal Data” generally means information that can be used to individually identify a person, and “processing” generally covers actions that can be performed in connection with data such as collection, use, storage and disclosure. Proxytool will be the controller of your Personal Data processed in connection with the Services.

If there are any conflicts between this section and any other provision of this Privacy Policy, the provision or portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following applies to you, please contact us at support@proxytool.io. Note that we may also process Personal Data of our customers' end users or employees in connection with our provision of certain services to customers, in which case we are the processor of Personal Data. If we are the processor of your Personal Data (i.e., not the controller), please contact the controller party in the first instance to address your rights with respect to such data.

Personal Data We Collect

The “Categories of Personal Data We Collect” section above details the Personal Data that we collect from you.

Personal Data Use and Processing Grounds

The “Our Commercial or Business Purposes for Collecting Personal Data” section above explains how we use your Personal Data.

We will only process your Personal Data if we have a lawful basis for doing so. Lawful bases for processing include consent, contractual necessity and our “legitimate interests” or the legitimate interest of others, as further described below.

Sharing Personal Data

The “How We Share Your Personal Data” section above details how we share your Personal Data with third parties.

EU and UK Data Subject Rights

You have certain rights with respect to your Personal Data, including those set forth below. For more information about these rights, or to submit a request, please email us at support@proxytool.io. Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need you to provide us with additional information, which may include Personal Data, if necessary to verify your identity and the nature of your request.

Transfers of Personal Data

The Services are hosted and operated in the United States (“U.S.”) through Proxytool and its service providers, and if you do not reside in the U.S., laws in the U.S. may differ from the laws where you reside. By using the Services, you acknowledge that any Personal Data about you, regardless of whether provided by you or obtained from a third party, is being provided to Proxytool in the U.S. and will be hosted on U.S. servers, and you authorize Proxytool to transfer, store and process your information to and in the U.S., and possibly other countries.

Changes to this Privacy Policy

We're constantly trying to improve our Services, so we may need to change this Privacy Policy from time to time. When we do so, we will alert you to any such changes by placing a notice on the Proxytool website, by sending you an email and/or by some other means. Please note that if you've opted not to receive legal notice emails from us (or you haven't provided us with your email address), those legal notices will still govern your use of the Services, and you are still responsible for reading and understanding them. We will generally aim to provide such notice about Privacy Policy changes at least 14 days in advance of the new Privacy Policy taking effect. If you use the Services after any changes to the Privacy Policy have come into effect, that means you agree to all of the changes. Use of information we collect is subject to the Privacy Policy in effect at the time such information is collected.

Contact Information

If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your Personal Data, or your choices and rights regarding such collection and use, please do not hesitate to contact us at:

© Proxytool