## Privacy Policy

Last updated: March 26, 2020

Welcome,

At Brosphorus, we believe it’s important that everyone, regardless of their situation, can obtain secure and private access to the internet. We always aim to provide this access without compromising the privacy of our customers. This Privacy Policy describes how we process and handle data provided to Brosphorus in connection with your use of our products, services, apps, and websites that link to this policy (we refer to these collectively as our “services”).

Information security and privacy are at the heart of what Brosphorus values and promotes as a company. As such, we think it’s important to be transparent about how we handle your information. That level of transparency also makes for a lengthy document, but we’ve tried to make it more readable by organizing it into a logical structure and by using plain language.

### Key VPN Product Privacy Points

Anonymity:
When you use a VPN connection, we do not store any information that identifies what you browse, view, or do online via that VPN connection. This also means that we do not have any data to share with law enforcement and government agencies who make requests for information about what you were doing through a VPN connection. The exception is when you choose to communicate with us (such as via chat or email) over a VPN connection and have chosen to identify yourself to us.

Encryption:
All data you send via the VPN connections we facilitate is encrypted. Brosphorus does not inspect or log that data.

Metadata Logs:
Brosphorus logs metadata about connections, such as session durations and bandwidth used, in order to provide and improve our services. However, we do not log any data sent over those connections.

This policy uses the term “personal data” to refer to information that is related to an identified or identifiable natural person and is protected as personal data under applicable data protection law.

Who is Brosphorus?
In this policy, “Brosphorus,” “we,” “us,” and “our” refer to the Brosphorus Bilgi Teknolojileri Limited Sirketi that is responsible for your data.

Business Customers
Some of Brosphorus’s services are offered to businesses. For those services, our customer is a business or other organization who may authorize individual end users to use the services that it has purchased from us. Where an organization is our customer, it may maintain accounts with Brosphorus through which it and its users may submit information (“Customer Data”). That organization typically controls those accounts and any associated Customer Data. In this case, Brosphorus is generally a processor of Customer Data and the organization is the controller.

## 1.What information do we collect about you?

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. Information you provide to us

- Account information. Some services require or allow you to create an account before you can access them. As part of registering for an account, we may collect information such as your name, username, email address, and password.
- Billing and payment information. In order to purchase a service, you may need to provide to us with details such as billing name, billing contact details (street addresses, email addresses), and payment instrument details.
- Identity verification information. Some services require you to verify your identity as part of creating an account to access them. We may collect information such as email addresses or phone numbers for this purpose.
- Communications and submissions. You may choose to provide us with information when you communicate with us (e.g. via email, phone, or chat for support or to inquire about our services), including when you fill out an online form, respond to surveys, provide feedback, post comments to our website, participate in promotions, or submit information through our services.

### 1.2. Information collected when you use our services

- Usage information. We collect information about how you interact with our services, how much bandwidth you use, and when and for how long you use our services.
- Device information. We collect information from and about the device you use to access our services, including about the browsers and Brosphorus apps you use to access our services. For example, we may collect device identifiers, browser types, device types and settings, operating system versions, mobile, wireless, and other network information (such as internet service provider name, carrier name and signal strength), and application version numbers.
- Diagnostic information. We may collect information about the nature of the requests that you make to our servers (such as what is being requested, information about the device and app used to make the request, timestamps, and referring URLs). However, our VPN products do not log any information that associates your identity with your VPN browsing activity. We do not maintain any records that show what you were browsing or accessing through a VPN connection.
- Location information. Unless otherwise expressly stated, we do not collect your location information based on your device’s GPS or other device sensor data. However, we may collect your approximate location by calculating an imprecise latitude and longitude based on your IP address to provide you with better service (e.g. to connect you to the nearest and fastest VPN server).

### 1.3. Information provided to us by third parties

- Referrals. If you are invited to use an Brosphorus service, the person who invited you may submit your personal data, such as your email address or other contact information.
- Third Party Accounts. Some services may allow you to register an account using a third party account (such as a Google or Microsoft account). If you do so, that third party may send us some information about you that they have. You may be able to control what information they send us via your privacy settings for that third party account.
- Threat Information. We receive information from reputable members of the security industry who provide information to help us to provide, develop, test, and improve our services (for example, lists of malicious URLs, spam blacklists, phone number blacklists, and sample malware). Some of this information may contain personal data on an incidental basis.
- Business Customers. Organizations that use our business and enterprise products may submit personal data to facilitate account management and invite individuals to use those products.

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.

## 2.How do we use your information?

We use the information we collect for various purposes described below.

- To provide, maintain, troubleshoot, and support our services. We use your information for this purpose on the basis that it is required to fulfill our contractual obligations to you. Examples: using information about how much bandwidth you use and how long you use our services in order to provide the services in accordance with a plan to which you have subscribed; using threat and device information to determine whether certain items pose a potential security threat; and using usage information to troubleshoot a problem you report with our services and to ensure the proper functioning of our services.
- For billing and payment purposes. We use your information in order to perform billing administration activities and process payments, which are required to fulfill our contractual obligations.
- To communicate with users and prospective users. We use your information to communicate with you, including by responding to your requests, and sending you information and updates about our services. We may do this in order to fulfill our contract with you, because you consented to the communication, or because we have a legitimate interest in providing you with information about our services.
- To improve our services. We want to offer you the best services and user experiences we can, so we have a legitimate interest in continually improving and optimizing our services. To do so, we use your information to understand how users interact with our services. Examples: we analyze certain usage, device, and diagnostic information to understand aggregated usage trends and user engagement with our services (and, for example, invest in technical infrastructure to better serve regions with increasing user demand); we may use device and threat information to conduct spam, threat, and other scientific research to improve our threat detection capabilities; we review customer feedback to understand what we could be doing better.
- To develop new services. We have a legitimate interest in using your information to plan for and develop new services. For example, we may use customer feedback to understand what new services users may want.
- To market and advertise our services. We may use your information to provide, measure, personalize, and enhance our advertising and marketing based on our legitimate interest in offering you services that may be of interest. Examples: we may use information such as who or what referred you to our services to understand how effective our advertising is; we may use information to administer promotional activities such as sweepstakes and referral programs. Note that our VPN products do not use your VPN browsing activity for these purposes and we do not maintain any records that show what you were browsing or accessing through a VPN connection.
- To prevent harm or liability. We may use information for security purposes (such as to investigate security issues or to monitor and prevent fraud) and to prevent abuse. We may do this to comply with our legal obligations, to protect an individual’s vital interests, or because we have a legitimate interest in preventing harm or liability to Brosphorus and our users. For example, we may use account, usage, and device information to determine if an entity is engaging in abusive or unauthorized activity in connection with our services.
- For legal compliance. We internally use your information as required by applicable law, legal process, or regulation. To learn about our practices regarding sharing your information with third parties for legal compliance purposes, see Section 3.1 below. We also use your information to enforce our legal rights and resolve disputes.

## 3.Who do we share your information with and why?

### 3.1. In General

We may disclose your information in the following circumstances;

- In accordance with your instructions or consent. For example, some services may allow you to register an account using a third party account (such as a Google or Microsoft account). If you choose to do so, we will share information with the third party account provider.
- To your business organization (for our business services). If a business customer is providing you with access to our services through a business account, others in that organization may be able to see and manage your account and the information associated with it (such as an administrator).
- For collaborating with others. Some services may provide ways for different users to interact or collaborate with each other. Your information will be shared in connection with those activities if you choose to engage in them.
- Affiliates and third party service providers. To help us provide some aspects of our services, we work with trusted third parties and partners (including affiliated companies in the Brosphorus group). To protect your data, we enter into appropriate confidentiality and data processing terms with these third parties, review their security practices, and limit information sharing to the scope of what they are helping us with.
  Examples of activities that third parties help us with include:

- processing customer payments
- providing analytics about our services
- providing sales and customer support
- maintaining the infrastructure required to provide our services
- delivering our marketing and advertising content

- For security research purposes. A sanitized subset of our threat intelligence data may be shared with selected reputable members of the cybersecurity industry for the purpose of security threat research and facilitating community efforts to improve online security.
- To a new owner. If ownership or control of all or part of our services, assets, or business changes, we may transfer your information to the new owner.
- Aggregated or de-identified data. We may use and share aggregated data and data that is de-identified such that it no longer reveals the identity of an individual user for regulatory compliance, research and analysis, our own marketing and advertising activities and other legitimate business purposes.
- To comply with legal process and the law. We are fiercely protective of the privacy of our users. If you use our VPN products, we protect your privacy by ensuring that we do not log or record online activities that you conduct over a VPN connection in any way that can be tied back to you, meaning that we do not have any data to share with law enforcement and government agencies who make requests for information about what you were doing through a VPN connection. Subject to the foregoing, we may share your information if we are required to do so by applicable law; to comply with our legal obligations; to comply with legal process; and to respond to valid law enforcement requests relating to a criminal investigation, or alleged or suspected illegal activity that may expose Brosphorus, you, or any of our other users to legal liability. If we share your information for these purposes, we limit the information shared to what is legally necessary, and challenge information requests that we believe are unlawful, overbroad, or otherwise invalid.
- To enforce our rights and prevent fraud and abuse. We may share limited amounts of your information to enforce and administer our agreements with customers and users, and to respond to claims asserted against Brosphorus. We may also share your information in order to protect against fraud and abuse against Brosphorus, our affiliates, users and others.

### 3.2. Free Products Only

Displaying Third Party Ads. We do not display third party ads in our paid products. With respect to our free mobile apps and other free products, we may serve third party ads to users in certain regions. Although the money we make from displaying these ads offsets only part of the costs of making these apps and services available for free, we provide free apps because we believe it’s important that everyone has the opportunity, regardless of their situation, to have secure and private access to the internet.

The ads we display in our services are supplied by Google and IronSource, a third party advertising network (“Google Ads & Ironsrc”). To display these ads in our apps, we integrate into them a software development kit (SDK), which consists of software code provided by the ad network.

We do not provide Google Ads and IronSrc with any personal data about you, except for an approximate city-level latitude and longitude which lets them show ads which are more relevant for your approximate geographic location. However, Google Ads & IronSrc may collect information through their SDKs, such as your mobile advertising identifier, IP address, and device information, for the purpose of serving you with “personalized” ads (ads that they think are more relevant to you) and measuring your response to those ads. If you are using a VPN connection, your IP address is hidden from ad networks and replaced with the IP address of our VPN servers. Because we do not provide ad networks with personal data about you (apart from city-level location), Google Ads & IronSrc personalizes ads based on information that they collect from you and that they already have about you – not based on information we share with them.

Google and IronSource collects this information according to the their advertising privacy notice. Where an AdChoices or IronSrc logo appears on an ad, you can click it to learn more about the ad network that provided the ad, its privacy policy, and your choices regarding opting out from any personalized advertising. If you opt out from personalized advertising, you may still see non-personalized ads.

While we request you not to use ad blockers to prevent the display of third party ads because that is how we support our free services, our services are able to continue functioning if you do use ad blockers.

## 4.Tracking Technologies & Cookies

### 4.1. About Tracking Technologies

Brosphorus uses various technologies in our services to help us collect information. For convenience, we refer to these as “tracking technologies,” although they are not always used to track individuals and the information collected is in a non-identifiable form that does not reference any personal data. Tracking technologies include:

Cookies
Cookies are small portions of text that are stored on the device you use to access our services. Cookies enable us (or third parties that we allow to set cookies on your device) to recognize repeat users. Cookies may expire after a period of time, depending on what they are used for.
Pixel Tags / Page Tags / Web Beacons / Tracking Links
These are small, hidden images and blocks of code placed in web pages, ads, and our emails that allow us to determine if you perform a specific action. When you access a page, ad, or email, or click a link, these items let us know that you have accessed that page, opened an email, or clicked a link.

SDKs
SDKs or software development kits are software code provided by our business partners that let our software interact with the services those partners provide. For example, in our free mobile apps, we may use an SDK to enable our app to serve ads from an advertising network. Sometimes these interactions will involve that business partner collecting some information from the device on which the software is run.

### 4.2. Why we use Cookies

We use cookies;

- To provide our services. Some cookies are essential for the proper operation of our services. For example, cookies allow us to authenticate who you are and whether you’re authorized to access a resource.
- To store your preferences. Cookies can store your preferences, such as language preferences or whether to pre-fill your username on sign in forms. We may also use them to optimize the content that we show to you.
- For analytics. Cookies are used to inform us how users interact with our services so we can, as a legitimate interest, improve how they work (such as what screens or webpages you access, and whether our advertising is effective).
- For security. Cookies can enable us and our payment processors to detect certain kinds of fraud.
- For advertising-related purposes. We advertise our services online with the help of third parties who show ads and marketing about us on sites around the internet.

### 4.3. Third Parties

We may allow our business partners to place certain tracking technologies in our services. These partners use these technologies for the following purposes:

- To provide our services. Some business partners who help us to provide our services may use these technologies to support those efforts.
- For Analytics. To help us understand how you use our services.
- For Marketing. To help us market and advertise our services to you, including on third party websites. Cookies are used in connection with this to measure the performance of our advertising, attribute actions you take with our ads with actions you take on our services, deliver ad retargeting (serving ads based on your past interactions with our services), and target ads at similar audiences.
- To Serve Ads. This is relevant to users of our free products only. Ad networks may use these technologies to display ads which they think will be more relevant to you. For more information, please see the “Displaying Third Party Ads” section above.

### 4.4. Your Choices

Our Cookies:

Most web browsers and some mobile devices give you the ability to manage your cookie preferences, including deleting cookies and blocking cookies from being set on those browsers or devices. Visit the “help” section of your browser to understand what controls it gives you over cookies. Note that deleting or blocking certain cookies could adversely impact the proper operation of our services.

Third Party Advertising Cookies:

For information on how to opt out of personalized or interest-based advertising, you can visit the following pages:

- Network Advertising Initiative opt out page
- Digital Advertising Alliance opt out page
- Your Online Choices(for Australian residents)
- Your Online Choices(for EU residents)
  To opt out from Google ad personalization, visit the Google Ads Settings page. These opt out mechanisms are not provided by Brosphorus and we are not responsible for the availability or operation of them. Note that after opting out of personalized advertising you may still see non-personalized ads.
- Google Analytics: We use Google Analytics to help us understand how users use our services. Google makes available a Google Analytics Opt Out Browser Add-On if you do not want to participate in Google Analytics.

## 5.Security

Brosphorus employs a range of administrative, organizational, technical, and physical safeguards designed to protect your data against unauthorized access, loss, or modification. We continuously work to improve such safeguards.

## 6.International Data Transfers

### 6.1. Transfers to Other Countries

Brosphorus may transfer your personal data to countries other than the one in which you reside. We do this to facilitate our operations, and transferees include other Brosphorus group companies, service providers, and partners. Laws in other countries may be different to those that apply where you reside. For example, personal data collected within Switzerland or the European Economic Area (EEA) may be transferred and processed outside Switzerland or the EEA for purposes described in this policy. However, we put in place appropriate safeguards that help to ensure that such data receives an adequate level of protection. You may contact us if you would like more information about such safeguards.

If you change your country of residence, the Brosphorus group company responsible for your data may change accordingly, and your data may be transferred to that other company.

## 7.Data Retention

Brosphorus generally retains your personal data for as long as is needed to provide the services to you, or for as long as you have an account with us. We may also retain personal data if required by law, or for our legitimate interests, such as abuse detection and prevention, and defending ourselves from legal claims. Residual copies of personal data may be stored in backup systems for a limited period as a security measure to protect against data loss.

## 8.Your Rights

Depending on your country of residence, you may have certain legal rights in relation to your personal data that we maintain. Subject to exceptions and limitations provided by applicable law, these may include the right to:

- access and receive a copy of your personal data;
- correct your personal data;
- restrict the processing of your personal data;
- object at any time to the processing of your personal data;
- have your personal data erased;
- data portability;
- withdraw any consent you previously gave to the processing of your data (such as opting out to marketing communications);
- lodge a complaint with a data protection authority;
- request that we provide you with the categories of personal data we collect, disclose or sell about you; the categories of sources of such information; the business or commercial purpose for collecting or selling your personal data; and the categories of third parties with whom we share personal data. This information may also be provided in this Privacy Policy.

Please note your rights and choices vary depending upon your location, and some information may be exempt from certain requests under applicable law.

You may be able to exercise some of these rights by using the settings and tools provided in our services. For example, you may be able to update your user account details via the relevant account settings screen of our apps. You may also be able to opt out from receiving marketing communications from us by clicking an “opt out” or “unsubscribe” link in such communications.

Otherwise, if you wish to exercise any of these rights, you may contact us using the details in the “Contact Us” section below. As permitted by law, we may ask you to verify your identity before taking further action on your request.

## 9.Your California Privacy Rights

For additional information and rights available to California consumers, see the our California Supplemental Privacy Notice.

## 10.Technology Licensing

Brosphorus occasionally licenses its technology to third party partners who may integrate it with applications developed and offered by those partners. Our partners, and not Brosphorus, are responsible for those applications and for determining what data is collected by those applications and how it is processed. Please contact the relevant partner and refer to their Privacy Policy to learn more about how those applications process your personal data.

## 11.Age Restriction

Our services are not intended for and may not be used by minors. In this context, minors are individuals under the age of 16. Brosphorus does not knowingly collect personal data from minors or allow them to use our services. If we discover that we have collected personal data from a minor, we may delete such data without notice. Please note that the legal terms under which we make certain services available may require users to be older than 16 years of age.

## 12.Privacy Policy Updates

Brosphorus may update this Privacy Policy from time to time in accordance with this section for reasons such as changes in laws, industry standards, and business practices. Brosphorus will post updates to this page and update the “Last updated” date above. If we make updates that materially alter your privacy rights, we will also provide you with advance notice, such as via email or through the services. If you disagree with such an update to this policy, you may cancel your services account. If you do not cancel your account before the date the update becomes effective, your continued use of our services will be subject to the updated Privacy Policy.

## 13.Contact Us

We expect this Privacy Policy to evolve over time and welcome feedback from our users about our privacy practices. If you have any questions or complaints about our privacy practices, you can contact us using the following details:

Brosphorus Bilgi Teknolojileri Limited Sirketi

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