This California Supplemental Privacy Notice (“Notice”) supplements the information in and forms part of the Brosphorus Privacy Policy (“Privacy Policy”). This Notice applies solely to California residents. This Notice applies to all products, services, apps, and websites that link to our Privacy Policy, except where otherwise noted.

1.Your California Privacy Rights

This section describes the various types of information we collect from and about you. This information is not collected in all situations, but only in specific situations. For example, our VPN products only collect a limited amount of information. To understand the context in which collection occurs, see Section 2 (How do we use your information?). More information about some of the mechanisms we use to collect this information, such as cookies, is available in Section 4 (Tracking Technologies & Cookies).

1.1. Do Not Track Signals

Brosphorus currently does not respond to “Do Not Track” signals sent by browsers or mobile apps due to a lack of standardization regarding how that signal should be interpreted. Learn more about Do Not Track.

1.2. Third Party Disclosure Requests

California law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their “personal information” (if any) as defined under California Civil Code 1798.83 for their direct marketing purposes in the prior calendar year, as well as the type of personal information disclosed to those parties. See the “Contact Us” section below for where to send such requests. Note that Brosphorus does not share personal information with third parties for their own direct marketing purposes without your prior consent.

1.3. Opt-Out From Sale

You may have the right to opt out of the “sale” of your personal information as defined by the California Consumer Privacy Act (CCPA). The CCPA broadly defines “sale” such that it may include allowing third parties to receive certain information, e.g. cookies, to deliver personalized advertising on our services.

Brosphorus does not “sell” (as defined by the CCPA) your personal information except in the context of some free versions of our products that are supported by personalized advertising served by Google. Advertising, including personalized advertising, enables us to provide certain of our products for free, to provide offers relevant to you, and, because we believe it’s important that everyone has the opportunity, regardless of their situation, to have secure and private access to the internet. Personalized advertising enables ads to be shown that are more relevant to you.

Advertising, including personalized advertising, enables us to provide you with certain content and services for free and allows us to provide you with offers relevant to you.

Depending on the services you use and how you use them, we may “sell” (as defined by California law) the following categories of personal information for such advertising purposes:

• Identifiers (such as advertising identifiers and cookies)
• Internet or other network or device activity (such as what Brosphorus app you’re using)
• Approximate geolocation information (city level location data)

To opt out of our use of your information for such purposes, e-mail us from info@brosphorus.com. Please note that we do not knowingly sell the personal information of minors under 16 years of age without legally-required affirmative authorization.

You generally do not have a duty to disclose personal data to us unless you have a contractual obligation to us to do so. However, we need to collect and process certain information that is necessary or legally required in order to provide the services to you or otherwise perform our contractual relationships with you.

1.4. Additional Rights

California law may permit you to request that we;

• provide you the categories of personal information we have collected or disclosed about you in the last twelve months, the categories of sources of such information, the business or commercial purpose for collecting or selling your personal information, and the categories of third parties with whom we shared personal information.

This information is provided in this Notice;

• provide access to, or a copy, of certain information we hold about you
• delete certain information we have about you.

You may also have the right to receive information about the financial incentives that we offer to you (if any), and the right to not be discriminated against (as provided for in the CCPA) for exercising certain of your rights.

Certain information may be exempt from such requests under applicable law. For example, we need certain types of information so that we can provide the services to you and for compliance with applicable law.

When you exercise certain rights, we may take reasonable steps to authenticate your identity before fulfilling your request (such as verifying your email address or payment instrument). If you ask us to delete certain information, you may no longer be able to access or use our services.

You are also permitted to designate an authorized agent to submit certain requests on your behalf. In order for an authorized agent to be verified, you must provide the authorized agent with a signed, written permission to make such requests, or a power of attorney. We may also follow up with you to verify your identity before processing the authorized agent’s request.

If you would like further information regarding your legal rights under California law or would like to exercise any of them, please contact us at:

Brosphorus Bilgi Teknolojileri Limited Sirketi

Idealtepe Mahallesi Dik Sokak 13/2
Maltepe/Istanbul - Turkey
info@brosphorus.com
www.brosphorus.com

2.Summary of How we Handle your Personal Information

The California Consumer Privacy Act (CCPA) requires that we make certain disclosures to California residents, including the categories of personal information we collect, the purposes for which we use that information, the categories of sources of personal information, and the categories of third parties with whom we share personal information. This section lays out this information in the manner specified by the CCPA, but it does not differ in substance from the information we provide in our Privacy Policy.

Sources of Personal Information

All the categories of personal information we collect come from the following categories of sources;

• You (either via voluntary submission or automatic collection, such as when you use our services)
• Our affiliates within the Brosphorus family of companies
• Third parties (such as service providers, other users or marketing partners who may refer you to our services, and your organization if you use a product with a business account)

Categories of Personal Information Collected and with Whom we Share It

• Identifiers (such as name account username, email address)
• Commercial information (such as transaction data)
• Financial and transactional data (such as payment instrument details)
• Internet or other network or device activity (such as app usage and interactions with our services)
• Approximate geolocation information (e.g., your city and state based on IP address)
• Professional or employment-related information (if you use a service that we offer to businesses)
• Demographics and statistical information (such as age and gender)
• Customer service information (e.g. support requests)
• Survey responses and other research information
• Other information that identifies or can be reasonably associated with you

Categories of Third Parties with Whom we Share Your Personal Information

The categories of personal information collected, as described above, may be shared with the following categories of third parties:

• Your organization (if you are using a product with a business account)
• Our affiliates within the Brosphorus group of companies
• Third party service providers that perform services on our behalf (e.g. payment processors, analytics providers)
• Third party ad networks (Google,IronSrc etc.)
• Third parties for legal purposes (e.g. in response to legal process)
• Others with your consent or at your direction

More detail about these categories is available in Section 3 of our Privacy Policy.

Categories of Business & Commercial Purposes for Which We Use Your Personal Information

The categories of personal information collected, as described above, are used for the following categories of purposes:

• To provide, maintain, troubleshoot, and support our services.
• For billing and payment purposes.
• To communicate with users and prospective users.
• To improve our services.
• To develop new services.
• To market and advertise our services.
• To prevent harm or liability.
• For legal compliance.

More information about these categories, including examples of use cases, is available in Section 2 of our Privacy Policy.