ABC INC. (“ABC”, “us”, “we” or “our”) offers services and products that endeavor to assist you (“you”, “your” or “user”) in securely browsing the web. This privacy policy (“Privacy Policy” or “Policy”) governs our data collection and management practices in connection with (“Product Name”).

This Policy lays down all relevant information regarding your rights and choices related to our data collection and management practices. You agree and accept that when you install and/or use Product Name, the provisions of this Privacy Policy apply to you in their entirety and that you have read and understood these provisions. You, further, grant us your express consent to be bound by this Policy.

Applicability

The Product Name is available only for use by US nationals who are eighteen (18) years or above and are living in the United States. Subsequently, this Policy also applies only to such aforementioned individuals. We request you to not engage with and/or install or use Product Name if you do not satisfy these criteria.

Data Collection

Summary: This section describes all elements of data including personal data (defined below) and other data that we collect when you install or use Product Name. Some of these data elements are collected automatically while some are provided by you either (i) in acknowledgment of or in response to the grounds requiring such data elements to enable the functioning of Product Name; or (ii) when you communicate with us in connection with Product Name.

Personal Data refers to any data elements that either directly or in combination with other non-identifying data elements are capable of identifying an individual. Examples for: 

• A. Directly identifiable data elements:  Name, Email Address, telephone number, etc. 
• B. Non-identifying data elements: IP Address, Device location, Zip code, etc.

Data we collect automatically:

IP address (categorised as ‘Identifiers’ under CCPA), device data such as the brand and model of the device, the operating system, browser version, device dimensions and device settings, user agent (this refers to a software that enables your access to web content), your advertising ID (this refers to a unique, resettable code assigned to you for ad personalisation) and data regarding your interaction with the Product Name (categorised as ‘Internet or Network Activity’ under CCPA).

We anonymize information related to your IP address as soon as it is technically possible for us to do so.

Additionally, we, our affiliates, service providers, and other third parties may place cookies, tracking pixels (web beacons), and similar technologies to measure the performance of Product Name and services linked therein. To learn more, please refer Section <___>.

Data you share with us:

Any data element voluntarily shared including without limitation non-identifiable data and Personal Data such as your name, email address (categorised as ‘Identifiers’ under CCPA) where applicable, geolocation (categorised as ‘Geolocation’ under CCPA), where required, and/or applicable, and any communication with us via email, webform or post. We do not use, share or disclose any Personal Data for purposes other than to (i) provide the services offered by us; (ii) respond to you and where possible, resolve your queries or fulfill your requests; or (iii) comply with any legal or statutory obligation(s).

Data we collect from third parties:

Grounds for processing data collected:

Summary: This section describes the lawful basis for processing the data that we collect including but not limited to your consent, performance of a contract between you and us, compliance with legal obligations, protection of vital interests of any individual, and for our legitimate interests and those of third parties with whom it may be necessary to disclose this data.

Processing of your Personal Data is subject to your interaction with and/or use of Product Name, your location at the time of such interaction or use, and the following as and where applicable:

• Consent: We process your Personal Data when you grant us your prior explicit consent for one or more specific purposes; this, however, does not apply, where such processing is subject to our legal obligations or other applicable requirements ;
• Contract: We process your Personal Data where necessary for the performance of any contractual and/or pre-contractual obligations thereof; 
• Legal obligations: We process your Personal Data for compliance with all legal, regulatory, statutory obligations; 
• Legitimate interests:  We process your Personal Data where we have a legitimate interest to pursue our business purposes (including sharing such Personal Data with third parties) and where such legitimate interest is not overridden by your fundamental rights, freedom, or interests.

Certain legislations allow the processing of Personal Data until you object to such processing (by opting out or other available methods), without relying on your consent or any other lawful basis. To know more about whether or not our processing of your Personal Data falls under this exception, please write to us at the contact details mentioned under section <___> below.

Use of data collected

Summary: This section describes the purposes for which we use the data we collect when you use Product Name.

In order to make Product Name available to you, or to meet a legal obligation, we may need to collect and use certain Personal Data. Some of the service offerings may be partially or completely unavailable if you choose not to share the requested information.

The data we collect may be used for the following purposes:

• Create and manage user accounts
• Fulfill and manage orders
• Deliver features and functionalities offered by Product Name 
• Improve products and services to enhance user experience
• Communicate administrative information
• Respond to user inquiries and offer support
• Send marketing and promotional communications
• Deliver targeted advertising
• Enforce terms and conditions, other policies, and legal rights
• Discharge our legal & contractual obligations
• Detect, investigate and prevent abusive, fraudulent, spam, and other malicious activities
• Respond to requests from regulatory/governmental authorities
• Run and operate Product Name
• Internal analysis and reporting

Data Disclosure

Summary: This section describes when and with whom we disclose the data that we collect. We may share your data with our affiliates, service providers, governmental & regulatory authorities, law enforcement agencies, parties involved in ABC’s business restructuring, and other third parties described below.

• Affiliates and Business Partners - We may disclose your data to entities that are owned and/or operated by us (“Affiliates”) and our business partners who are acting on behalf of or working with ABC in a lawful manner. Such Affiliates and business partners who may be located in a country other than the country of your residence, may use your data for their internal processing purposes in accordance with the provisions of this Privacy Policy. For more information on transfer of your data, please refer Section <__>
• Service Providers - We use services offered by third parties including, but not limited to, analytics and performance monitoring, advertising and marketing, payment processing, cloud storage, advisory, accounting, or other services, and may disclose your data to service providers to the extent such disclosure is required for them to deliver their services in connection with Product Name. Some of our service providers may place their own tracking technologies including cookies and web beacons on Product Name to gather data which may include Personal Data for their own research, analysis, and reporting purposes. ABC does not in any way control, govern, or monitor the data collection and processing practices of such service providers and are responsible or liable for any such collection and processing practices including any data breach. For more details on some of these service providers and links to their privacy policies, please refer Section <__>. 
• Governmental & Regulatory authorities; Law enforcement agencies - We may disclose your data to governmental & regulatory authorities or law enforcement agencies to comply with a warrant, court order, subpoena, or other legal requirements and applicable law(s). We may also disclose your data to (i) protect the safety of our users and other individuals in situations involving potential threats to physical safety; (ii) establish and exercise our rights & interests and defend legal claims; and/or (iii) investigate any illegal or fraudulent activities, in accordance with the applicable laws.
• Business restructuring related entities - We may transfer the data we collect, including any Personal Data, to any person or entity in the event of a business restructuring transaction including without limitation, transactions related to reorganization, merger, or acquisition of our business, stock, or assets.
• Others - We may disclose your data to third parties if such disclosure is necessary for the security and protection of user data, Product Name. We may also disclose your data to any relevant third party in order to detect, investigate and prevent abusive, fraudulent, spam, and other malicious activities.

Data Retention, Security, and Transfer

Summary: This section provides details regarding data retention, its security, and international transfers, where applicable. We retain your data for as long as is necessary for the purposes listed in Section <__> above, such data is secured using appropriate organizational and technical safeguards and may be transferred to a different country other than yours where our or our Affiliates’, business partners’ and service providers’ servers are located. The data protection laws of such countries may be different from those of your country.

• Data Retention - We retain your data including your Personal Data (i) for as long as is necessary for the purposes listed in the Policy; (ii) if such retention is permitted under applicable law(s); or (iii) when you explicitly consent to such retention. We may also use any aggregated data derived from or incorporating your Personal Data after you update or delete it, but not in a manner that would identify you personally.
• Data Security - We manage data security compliance by employing appropriate organizational and technical safeguards to limit accidental or unlawful destruction, loss, alteration, unauthorized disclosure, unauthorized access, and other unlawful or unauthorized use of your data. During transit, we safeguard your data using standard encryption technology such as Secured Socket Layer (SSL).Although we take due care and use appropriate measures to secure your data, owing to the risks associated with the exchange of data over the Internet, we are unable to guarantee complete security of your data. 
• Data Transfer - We may transfer your data from a country other than yours to where our or our Affiliates’, business partners’, and service providers’ servers are located. By using Product Name, you (i) acknowledge and agree that the data protection laws of the countries where such data is transferred may vary from those in your country; and (ii) grant us your explicit consent for such transfer.

User Rights

Summary: This section describes your rights and their applicability in connection with Product Name , accorded to you under several data protection laws, and how you can exercise these rights. Under the specific data protection law that may be applicable to you, your rights may include the right not to share your Personal Data; the right to opt-out of the sale of your Personal Data; right to access your Personal Data; right to request rectification or correction; right to request the erasure; right to restrict the processing of your Personal Data; right to object to the processing of your Personal Data; the right to have your Personal Data transferred to a third party; right to withdraw consent; and the right to lodge complaints with Data Protection Authorities. We may need to validate your identity before we can process your requests in relation to these rights.

• California Consumer Privacy Act (CCPA) 
• If you are a California Resident, you have the following rights available to you:
  • You have the right to request that we disclose the categories and specific pieces of personal information (as defined under Section 1798.140. of the CCPA) concerning you, that we have collected and processed. Please refer to the provisions under Sections <___> of this Policy, for this information. Further, you also have the right to receive information regarding:
  • (a) the categories and sources of the personal information that we collect about you, the purposes for which we use your information and with whom such information is shared;
  • (b) in case of sale of personal information or disclosure for a business purpose, two separate lists where we disclose:(i) for sales, the personal information categories purchased by each category of recipient; and(ii) for disclosures for a business purpose, the personal information categories obtained by each category of recipient.
  • Subject to certain exceptions listed under Section 1798.105. of the CCPA, you have the right to request us to delete your Personal Data in connection with Product Name.
  • You have the right to opt-out of the sale of your Personal Data. Should you wish to exercise this right please click here.
  • You have the right to appoint an authorized agent to exercise any of the aforementioned rights, on your behalf, provided that such authorized agent is registered with the California Secretary of State.
  • You have the right to not be discriminated against for pursuing your rights under CCPA.

To exercise these rights, please submit a verifiable request by writing to us at the contact information provided under Section <__> or click here.

In certain cases, we may request for additional information to verify your identity and validate the request. Any data shared with us for verification purposes, will only be used for the said purpose and will not be shared with any third party.

Subject to verification of your requests, we will try to process your request within forty five (45) days of its receipt. However, we reserve the right to request an extension of forty five (45 additional days).

• Shine the Light - In the event we share your Personal Data with third parties for direct marketing purposes, the California Civil Code under Section 1798.83 mandates us  to disclose, upon your request, the names and addresses of third parties who have received such Personal Data along with the categories of Personal Data shared. To exercise this right, please write to us at the contact information provided under Section <__>
• Nevada - Provided we engage in ‘sale’ of ‘covered information’ (as defined under the law), residents of the State of Nevada may request us to opt-out of such sale to third parties intending to further sell or licence such covered information, by writing to us at <Email ID>. We are mandated to process your request within sixty (60) days of its receipt, however, we reserve the right to request an extension of thirty (30) additional days.  
• General Data Protection Regulation Residents of the European Economic Area (EEA), have a set of data protection rights accorded to them under the General Data Protection Regulation 2016/679 (GDPR). Subject to certain exceptions, as an EEA resident, you have the following data protection rights:
  • You have the right to request access to your Personal Data stored with us and be provided with copies of such data in a structured, machine-readable, and commonly used format.
  • You have the right to request us to complete the Personal Data that you believe is incomplete and/or rectify/correct any inaccuracies in such Personal Data.
  • You have the right to object to the processing of your Personal Data. However, in the event such Personal Data is processed for public interest, in the exercise of an official authority vested in us or for the legitimate interests pursued by us, you may object to such processing by providing valid grounds to justify such objection. Please note that should we process your Personal Data for direct marketing purposes, you have the right to object to such processing at any time without any justification. 
  • Under certain scenarios, you have the right to request us to erase your Personal Data.
  • You have the right to restrict us from processing your Personal Data. When you exercise this right, we may continue to store your Personal Data but will not process it further.
  • Where the legal basis for processing your Personal Data is consent, you have the right to withdraw such consent at any time.
  •  While we encourage you to reach out to us to address any concerns you may have regarding our data collection and processing practice, you have the right to complain to a Data Protection Authority about our data collection and processing practices. For more information, please contact your local data protection authority in the European Economic Area (EEA).

To learn more about these rights, please visit https://gdpr-info.eu/. To exercise any of these rights, please write to us at the contact information provided under Section <__> and we will try to respond to such requests within 30 business days from the date of its receipt.

Children’s Privacy

ABC does not knowingly collect data from or pertaining to individuals under the age of 16. Further, we do not knowingly sell Personal Data of or specifically target offers of goods or services to such individuals. If you, in good faith, believe or have actual knowledge of any Personal Data belonging to such individuals that we may have inadvertently accessed, collected or processed, please contact us in accordance with the contact information provided under Section <___>.

Changes to Policy

ABC reserves the right to make updates to this Privacy Policy at any time, at its sole discretion, without the need for prior notice. We invite you to review this Policy frequently to keep yourself abreast of any such changes. Your continued use of Product Name constitutes your unconditional acceptance of and agreement to be bound by any and all changes made to this Policy.

Contact Information

Please contact us at

< Email >

< Address >

Effective Date