KEEPSOLID, INC. PRIVACY POLICY(ARCHIVED)

Introduction

KeepSolid cares about your Personal Data privacy and is committed to protecting it. This Privacy Policy outlines what information is collected, for what reason, and how your Personal Data is handled when you use our services.

1. What is the Scope of Privacy Policy

This privacy policy statement (“Privacy Policy”) describes how KeepSolid, Inc. and our affiliates (“KeepSolid,” “we,” “us,” or “our”) obtain, use, store, change, disclose, and delete our users’ (“you,” or “your”) Personal Data as it relates to KeepSolid’s Services and KeepSolid’s marketing practices.

This Privacy Policy is a part of and is incorporated into KeepSolid, Inc. End User Agreement between KeepSolid and you. We ask you to read this Privacy Policy carefully as it contains important information on how and why we collect, store, use, and share personal information, your rights in relation to your personal information, and how to contact us in the event you have a privacy concern or complaint.

Please review our other relevant policies and agreements:

END USER AGREEMENT

1.1. What is Personal Data

For the purposes of this Privacy Policy, the term “Personal Data” means any information relating to an identified or identifiable natural person. The term “Personal Data” does not include any information that has been anonymized, such that the natural person to which such information relates is not identifiable.

1.2. What are Services

As described below, the term “Services” means all of KeepSolid’s websites, mobile and other applications, products, services, software, and accompanying documentation.

The term KeepSolid Services covers the following:

• VPN Products that include VPN Unlimited®, VPN Lite, DNS Firewall by KeepSolid, and Private Browser.
• Other Products that include Passwarden®, SmartDNS by KeepSolid, Goals by KeepSolid, and any other KeepSolid Services.

1.3. What are VPN Products

The term “VPN Products”' means all KeepSolid’s Virtual Private Network (VPN) Services, including VPN Unlimited, VPN Lite, DNS Firewall by KeepSolid, and Private Browser.

1.4. What are Other Products

The term “Other Products” means all KeepSolid’s Services except VPN Products. Other Products include Passwarden, SmartDNS by KeepSolid, Goals by KeepSolid, and any other KeepSolid Services.

2. What Personal Data We Collect and How We Collect It

When you interact with our Services, we collect information that could be used to identify you. The amount of Personal Data collected varies depending on the type of our Services. We offer different types of services: VPN Products and Other Products.

We aim to collect the minimum amount of information required to operate our Services.

IMPORTANT: YOUR FAILURE TO PROVIDE CERTAIN PERSONAL DATA MAY MAKE OUR SERVICES OPERATE NOT AS INTENDED OR NOT OPERATE AT ALL FOR YOU. YOUR FAILURE TO PROVIDE CERTAIN PERSONAL DATA MAY ALSO MAKE IT IMPOSSIBLE FOR US TO PROVIDE SOME OF OUR SERVICES TO YOU, BECAUSE OUR SERVICES REQUIRE CERTAIN MINIMUM PERSONAL DATA IN ORDER TO OPERATE AS WE INTEND.

2.1. VPN Products

As stated above, our VPN Products consist of VPN Unlimited, VPN Lite, DNS Firewall by KeepSolid, and Private Browser.

Please note! All our VPN Products follow a strict no-logging policy.

• We do NOT monitor, store, or log your online activities, including your browsing history, connection times, metadata, downloads, server usage, or data content during your session in the VPN Products.
• We also NEVER store or log your IP address after the end of your session in the VPN Products – we always remove your IP address immediately after your session ends.
• We do NOT request your full name for providing our VPN Products. You are only required to provide your email address when you register an account in our VPN Products with Registration.
• If you use the additional functionality called Virtual Private Servers (VPS) we could collect and store the total amount of traffic used and the dates of use only.

At your choice, we offer two options for using our VPN Products: VPNs without Registration and VPNs with Registration. Therefore, the amount of Personal Data that we need to collect for providing you with the VPN service is different, depending on the chosen type of use (with or without registration).

A. VPNs without Registration

When you use our VPN Products without Registration (without creating an account), we collect the following Personal Data:

B. VPNs with Registration

Only upon your registration for and use of our VPN Products, we collect certain Personal Data directly from you, in each case only if applicable. This data includes the following:

2.2. Other Products

As stated above, Other Products include Passwarden®, SmartDNS by KeepSolid, Goals by KeepSolid, KeepSolid Sign, and any other KeepSolid Services.

Upon your registration for and use of our Other Products, we collect the following Personal Data:

2.3. KeepSolid Sign

When you use KeepSolid Sign, we collect the following additional Personal Data from you and from other sources as it relates to documents uploaded and signed using KeepSolid Sign, including:

• Document content and preview;
• Keys used to encrypt documents and related digital certificates;
• Public and encrypted private keys;
• Date and time of taking certain actions, such as logging in/out, viewing, and signing the documents;
• IP address, browser and device information, location information when an action on a document is performed;
• Identification information of the signers of a document, to the extent such settings are available and utilized by the creator of the document; and
• Signature and initials.

We may obtain your Personal Data from other users of KeepSolid Sign. For example, other KeepSolid Sign users may provide us with your name and email address as a recipient of a KeepSolid Sign document. We may also collect identification information about you provided by other users of KeepSolid Sign to verify the identity of the individual accessing a KeepSolid Sign document.

2.4. Goals by KeepSolid

When you use Goals by KeepSolid, we collect the following additional Personal Data from you and from other sources as it relates to your using Goals by KeepSolid, including:

• Objectives content and preview;
• Date that you take certain actions, such as assigning users to the objectives, creating and modifying objectives, key results, teams and tasks; and
• Identification information of the assignees of objectives and other items, to the extent such settings are available and utilized by the owner or other members of the objective.

We may obtain your Personal Data from other users of Goals by KeepSolid. For example, other Goals by KeepSolid users may provide us with your name and email address as an assignee of Goals by KeepSolid objectives and other items. We may also collect identification information about you provided by other Goals by KeepSolid users to verify the identity of the individual accessing Goals by KeepSolid objectives.

2.5. Cookies and Other Tracking Technologies

A cookie is a small text file that a website saves on your computer or mobile device when you visit the website. We use cookies for providing, protecting, and promoting our Services. For more details on cookies and how we use them, please read our Cookies Policy.

2.6. Personal Data that We Collect from Other Sources

We may also collect your payment history regarding our Services (but NOT your payment information) from third-party payment processors, such as Google, Apple, Microsoft, PayPal, Amazon, Stripe, and Paymentwall.

We may also collect Personal Data, such as email, contact information, website and app diagnostics, analytics, etc., from third parties, such as marketing, research, sales lead generator companies, social networks, as well as from any publicly accessible sources.

2.7. Other User Data You May Provide

We may collect any other information that you choose to provide to us by indicating additional profile information, completing a web form, sending us an email, using online chat, forum postings, and any other similar means.

3. How We Use Personal Data

We use your Personal Data on the following legal bases, and for the following purposes:

3.1. Based on your consent

1. Contacting you by any means with offers and other marketing regarding the Services;
2. Accessing your device information relating to your use of the Services, except when we use this Personal Data based on other legal bases; and
3. Analyzing, personalizing, and improving our Services and marketing practices.

3.2. For the performance of a contract, or in order to take steps prior to entering into a contract

1. To process an order you have made and to provide you with the Services for which you paid or which you receive in a free trial;
2. Carry out or exercise our rights and obligations arising from any orders;
3. Accepting, crediting, and tracking payments and any failure to pay related to your use of the Services; and
4. Communicating with you and providing you with support and troubleshooting services related to the Services.

3.3. For compliance with our legal obligations

1. Carry out or exercise our rights and obligations arising from any orders; and
2. In the process of litigation and regulatory investigations, when appropriate or necessary.

3.4. For the purposes of our legitimate interests, or the legitimate interests of our other users and other third parties

1. To process an order you have made and to provide you with the Services for which you paid or which you receive in a free trial;
2. Analyzing, personalizing, and improving our Services and marketing practices, unless our actions in this regard require your specific consent;
3. Direct marketing emails and special offers, unless our actions in this regard require your specific consent;
4. Discovering issues in our Services;
5. Detecting and preventing fraud, illegal activity, and any other activity that infringes upon the legal rights of KeepSolid, our other users, or other third parties;
6. Carry out or exercise our rights and obligations arising from any orders; and
7. In the process of litigation and regulatory investigations, when appropriate or necessary.

4. When and Why We Share Personal Data

4.1. VPN Products Personal Data

We do NOT share, transfer, sell, rent, or disclose in any way to ANY third parties the Personal Data about your application usage and your internet activities of our VPN Products.

As explained in Section 2.1 of this Privacy Policy, we do NOT store or log certain categories of Personal Data (i.e. IP address and operating system) after your VPN session ends; therefore it is impossible for KeepSolid to share such Personal Data with any third parties.

Also as explained in Section 2.1 of this Privacy Policy, we do NOT monitor, store, or log your internet activities (your browsing history, connection times, metadata, downloads, server usage, or data content) while using any of our VPN Products.

If you use the additional functionality called Virtual Private Servers (VPS) we could collect and store the total amount of traffic used and the dates of use only (e.g. March 2021, 98.21 GB).

Therefore, it is impossible for KeepSolid to share, transfer, sell, rent, or disclose in any way to third parties your internet activities.

We do NOT rent or sell to ANY third parties the Personal Data of the users of our VPN products.

4.2. Other Products Personal Data

KeepSolid does NOT sell or rent your Personal Data to any third parties without your consent. We will request and obtain your consent prior to selling or renting your Personal Data to any third parties.

4.3. Additional Provisions

We do need to share some of your Personal Data with our affiliates and third-party service providers for our everyday business purposes, including to:

• Store, transfer, and manage your Personal Data;
• Process your purchases of the Services;
• Manage and service your KeepSolid account;
• Detect and prevent fraud, illegal activity, and any other activity that infringes upon the legal rights of KeepSolid, our other users, or other third parties; and
• Sell and market the Services.

We may share your Personal Data if we are, or propose to be, acquired by or merge with another entity or entities, or if we sell, or propose to sell, all or substantially all of our assets to another entity or entities, in which case we would share your Personal Data with such entity or entities.

We may share your Personal Data when appropriate or necessary to respond to legal process, including lawful: subpoenas from government authorities and/or private entities; court orders; and interrogatories, depositions, and other discovery processes in the context of litigation and regulatory investigations.

We make Personal Data regarding a specific Document available to users of KeepSolid Sign who are listed as Participants on such Document. We require this in order to permit our users to effectively use KeepSolid Sign.

5. Your Rights Regarding Your Personal Data

5.1. General Information

You can limit your sharing and our use of your Personal Data when it is based on your consent. For example, you can control our use of cookies by using the settings of your internet browser. For more details on cookies, please read our Cookies Policy.

Please note! Your limit on our use of Personal Data may cause our Services to appear and function not as intended.

You can also limit our use of your Personal Data for our marketing purposes. For example, you can unsubscribe at any time from direct marketing emails and special offers about KeepSolid Services.

You can manage your Personal Data in the User Office .

5.2. Your Rights

If the laws of some countries apply to you, you may have the right to do the following:

• Request access to your Personal Data;
• Request correction of your Personal Data or supplementation of your Personal Data for completeness;
• Request erasure of your Personal Data under certain circumstances, such as when the Personal Data is processed based on your consent;
• Request restriction of processing of your Personal Data under certain circumstances;
• Request transfer of your Personal Data to another entity under certain circumstances, such as when the Personal Data is processed based on your consent and the processing of your Personal Data is carried out by automated means;
• Withdraw consent to the processing of your Personal Data where the processing is based on your consent, without affecting the lawfulness of processing based on consent before its withdrawal; and
• File a complaint with your local supervisory authority.

RIGHT TO OBJECT

If the laws of some countries apply to you, you may have the “right to object” to our processing of your Personal Data when such processing is based on our, or a third party’s, legitimate interests. We will stop processing your Personal Data, unless:

• We demonstrate compelling legitimate grounds for the processing which overrides your interests, rights and freedoms; or
• Such processing is necessary for the establishment, exercise or defense of legal claims.

If you object, we will stop processing your Personal Data for direct marketing purposes.

In order to request to exercise any of your rights, we may require you to provide us with detailed information about your request. Your rights are also subject to certain other limitations contained in the applicable law.

6. Where and How We Store and Transfer Personal Data

We use appropriate physical, electronic, technical, and organizational measures to secure and protect your Personal Data to ensure a level of security appropriate to the risk. You should understand, however, that no safeguards are guaranteed to prevent unauthorized disclosure and/or use of Personal Data. Because of that, we cannot guarantee or warrant that your Personal Data will never be exposed. We use third-party service providers globally to store and transfer Personal Data. We work with our third-party service providers to put in place adequate protections to ensure the security of Personal Data when it is stored and transferred.

7. How Long We Store Personal Data

We do NOT store certain Personal Data of our VPN Products. Please see Section 2.1 for more details about our “no-logging” policy.

We store some of your Personal Data that we collect from you and from other sources as long as you remain a user of the Services or as long as you have an account with us. We retain Personal Data necessary for compliance with our legal obligations and contractual performance for the longer of: (i) the required time period under applicable law; (ii) or seven years.

8. COPPA

The Children’s Online Privacy Protection Act (“COPPA”) is a United States federal law enacted to give parents increased control over what information is collected from their children online and how such information is used. The law applies to websites and services directed to, and which knowingly collect information from, children under the age of 13. The Services are not directed to children under the age of 13, nor do we knowingly collect information from children under the age of 13. If you are under the age of 13, please do not provide personal information of any kind whatsoever to KeepSolid. If a child provides us with personal information, a parent or legal guardian of that child may contact us to obtain that information and/or delete it from our records by sending an email to [email protected].

9. Changes to Our Privacy Policy

We may make changes to this Privacy Policy (and/or other applicable policies and Addenda) as the applicable laws, relevant technologies, and our data processing practices change. We will notify you of changes to this Privacy Policy (and/or other applicable policies and Addenda) by posting the updated policy on our website and in our applications and other Services.

The changes to this Privacy Policy (and/or other applicable policies and Addenda) shall become effective upon such posting (as indicated by the date following “Last Updated:” at the top of this Privacy Policy and/or other applicable policies and Addenda), or as otherwise required by applicable law. We encourage you to review this Privacy Policy (and other applicable policies and Addenda) on a periodic basis.

The previous version of the Privacy Policy is here .

10. Contact Us

If you have any privacy or Personal Data concerns related to this Policy or any of KeepSolid’s Services, please contact us at [email protected] or at the following address:

KeepSolid Inc., 347 5th Ave, Suite 1402-419, New York, NY 10016, USA