PRIVACY POLICY

Last modified: January 3, 2024

Introduction

This Privacy Policy outlines the practices of NetNut Ltd. or any other NetNut affiliate which is a party to an engagement with you (“NetNut”, “we”, “our” or “the Company“) with respect to information collected from users who access our website at https://netnut.io/ (the “Site“) or use our services (together with the Site: “the Services“) or communicate with us in any other way (collectively: “Users“). For the purpose of this policy the term “affiliate” shall mean any person or entity directly or indirectly controlling, controlled by, or under common control with NetNut. For the purpose of this definition, “control” (including, with correlative meanings, the terms “controlling”, “controlled by” and “under common control with”) means the power to manage or direct the affairs of the person or entity in question, whether by ownership of voting securities, by contract or otherwise.

NetNut is constantly concerned about your personal data and privacy, and have drafted this Privacy Policy to help you determine whether to use the Services. By accessing and using the Services, or providing information to us directly or publicly, you agree and accept the terms of this Privacy Policy as amended from time to time and consent to the collection and use of information in the manner set out in this Privacy Policy. 

We encourage Users to carefully read the Privacy Policy and use it to make informed decisions.

In this Privacy Policy you can read about:

• What type of information we collect
• The purposes of use and with whom we share the information
• Our legal basis for processing the information
• User rights
• For how long we retain the information
• How we safeguard the information
• Changes to the Privacy Policy
• How to contact us

What Information we collect?

We collect two types of data and information from Users who access or use our Services. We collect information that identifies an individual or may with reasonable effort identify an individual (“Personal Information”). The Collection of Personal Information varies dependent on the Services that you use, according to the specification below:

Website Visitors

• Device Information: We collect Personal Information from your device. Such information includes geolocation data, IP address, unique identifiers (e.g. MAC address and UUID) and other information which relates to your activity through the Services.
• Contact information: If you choose to register, contact us through our Site, or by any other means, you will be asked to provide us with your name, email address and phone number. You will also be asked to provide additional information such as social channel and your company name (to the extent applicable).

Proxy Service Users

• Contact information: We will collect your name, email address and country of residence.
• When you use our proxy service, we will collect the IP that is originally assigned to your device and the IP address that is assigned to your device through our Services.
• We collect payment and billing information, including method of payment, transaction history and so on.
• We will collect information about domains that you visit while using our services.

Data Collection Services

• Contact information: We will collect your name, email address and social channel.
• We collect payment and billing information, including method of payment, transaction history and so on.
• For specific data collection activities, we may collect your search queries.

We may also collect information that is un-identified and non-identifiable information pertaining to a User(s), which may be made available or gathered via your access to the Services (“Non-personal Information”). We are not aware of the identity of a User from which the Non-personal Information was collected. Non-personal Information which is being collected may include your aggregated usage information and technical information transmitted by your device, including certain software and hardware information (e.g. browser type, language preference, access time, etc.) in order to enhance the functionality of our Services. We may also collect information on your activity on the Services (e.g. clicks, actions, etc.).

If we associate Non-personal Information with Personal Information, we will treat such information as Personal Information.

How is the information used? With whom do we share the information?

We do not rent, sell, or share Users’ information with third parties except as described in this Privacy Policy.

We may use the information for the following:

• Providing you with our Services.
• Communicating with you – If you have contacted us, for any reason, we will use your information to further communicate with you.
• Verifying and authenticating the registration information provided by you.
• Conducting statistical and analytical purposes, intended to improve the Services.
• Inform you of additional products, services or promotions (unless you have opted out of receiving such communications).

In addition to the different uses listed above, we may transfer or disclose Personal Information to our subsidiaries, affiliated companies, and subcontractors.

In addition to the purposes listed in this Privacy Policy, we may share Personal Information with our trusted third-party providers, who may be located in different jurisdictions across the world, for any of the following purposes: 

• Providing you with our Service, including providing a personalized display of our Site;
• Storing and processing such information on our behalf;
• Performing research, technical diagnostics or analytics;

We may also process and disclose information if we have good faith to believe that processing or disclosure of such information is helpful or reasonably necessary to: (i) comply with any applicable law, regulation, legal process or governmental request; (ii) enforce our policies, including investigations of potential violations thereof; (iii) investigate, detect, prevent, or take action regarding illegal activities or other wrongdoing, suspected fraud or security issues; (iv) to establish or exercise our rights to defend against legal claims; (v) prevent harm to the rights, property or safety of us, our users, yourself or any third party; or (vi) for the purpose of collaborating with law enforcement agencies and/or in case we find it necessary in order to enforce intellectual property or other legal rights.

In any case we will conclude that disclosure of Personal Information is necessary, we will only disclose that portion of the Personal Information that is required to satisfy the basis for disclosure. We will share the Personal Information under appropriate safeguards.

Legal Basis for Processing (For EEA users)

If you are an individual from the European Economic Area (EEA), please note that our legal basis for collecting and using your personal information will depend on the personal information collected and the specific context in which we collect it. 

This section lists the applicable legal basis next to each of the processing activities described above:

Data Subject Rights

If you reside in the EU (or in another jurisdiction that affords you with the below rights), you may request to:

• Receive confirmation as to whether or not personal information concerning you is being processed, and access your stored personal information, together with certain supplementary information.
• Receive personal information you directly volunteer to us in a structured, commonly used and machine-readable format.
• Request rectification of your personal information that is in our control.
• Request erasure of your personal information.
• Object to the processing of personal information by us.
• Request to restrict processing of your personal information by us.

However, please note that these rights are not absolute, and may be subject to our own legitimate interests and regulatory requirements. Also, the exercise of some of these rights may make it impossible for us to continue to provide you with our Services.

You also have a right to lodge a complaint with a supervisory authority

If you wish to exercise any of the aforementioned rights, or receive more information, please contact us at Support@netnut.io

Retention

We will retain your Personal Information for as long as necessary to provide our Services, and as necessary to comply with our legal obligations, resolve disputes, and enforce our policies. Retention periods will be determined considering the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time.

We may rectify, replenish, or remove incomplete or inaccurate information, at any time and at our own discretion.

Third party collection of information

Our policy only addresses the use and disclosure of information we collect from you. To the extent you disclose your information to other parties or sites throughout the internet, different rules may apply to their use or disclosure of the information you disclose to them. Accordingly, we encourage you to read the terms and conditions and privacy policy of each third party that you choose to disclose information to.

This Privacy Policy does not apply to the practices of companies that we do not own or control, or to individuals whom we do not employ or manage, including any of the third parties which we may disclose information as set forth in this Privacy Policy.

How do we safeguard your information?

We take great care in implementing and maintaining the security of the Services and your information. We employ industry standard procedures and policies to ensure the safety of the information we collect and retain, and prevent unauthorized use of any such information, and we require any third party to comply with similar security requirements, in accordance with this Privacy Policy. Although we take reasonable steps to safeguard information, we cannot be responsible for the acts of those who gain unauthorized access or abuse our Services, and we make no warranty, express, implied or otherwise, that we will prevent such access.

Corporate transaction

We may share information in the event of a corporate transaction (e.g. sale of a substantial part of our business, merger, consolidation, or asset sale). In the event of the above, the transferee or acquiring company will assume the rights and obligations as described in this Privacy Policy.

Minors

Updates or amendments to this Privacy Policy

We reserve the right to periodically amend or revise the Privacy Policy; material changes will be effective immediately upon the display of the revised Privacy policy. The last revision will be reflected in the “Last modified” section. Your continued use of the Site or services, following the notification of such amendments on our Site, constitutes your acknowledgment and consent of such amendments to the Privacy Policy and your agreement to be bound by the terms of such amendments.

How to contact us

General Data Protection Regulation (GDPR) – European Representative

Pursuant to Article 27 of the General Data Protection Regulation (GDPR), NetNut Ltd. has appointed European Data Protection Office (EDPO) as its GDPR Representative in the EU. You can contact EDPO regarding matters pertaining to the GDPR:

• by using EDPO’s online request form: https://edpo.com/gdpr-data-request /
• by writing to EDPO at Avenue Huart Hamoir 71, 1030 Brussels, Belgium

UK General Data Protection Regulation (GDPR) – UK Representative

Pursuant to Article 27 of the UK GDPR, NetNut Ltd. has appointed EDPO UK Ltd as its UK GDPR representative in the UK. You can contact EDPO UK regarding matters pertaining to the UK GDPR:

• by using EDPO’s online request form: https://edpo.com/uk-gdpr-data-request/
• by writing to EDPO UK at 8 Northumberland Avenue, London WC2N 5BY, United Kingdom