Privacy Policy

Summary of Key Points

This summary provides key points from our privacy policy, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below.

• What personal information do we process?
  When you visit, use, or navigate our Services, we may process personal information depending on how you interact with PrivGuard and the Services, the choices you make, and the products and features you use.
• Do we process any sensitive personal information?
  We may process sensitive personal information when necessary with your consent or as otherwise permitted by applicable law.
• Do we receive any information from third parties?
  We do not receive data from third parties unless it is necessary for providing our Services.
• How do we process your information?
  We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law.
• In what situations and with which parties do we share personal information?
  We may share information in specific situations and with specific third parties as described in this policy.
• How do we keep your information safe?
  We have organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure.
• What are your rights?
  Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information.
• How do you exercise your rights?
  The easiest way to exercise your rights is by contacting us at privacy@privguard.dev.

Table of Contents

1. What Information Do We Collect?

Personal Information You Disclose to Us

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You: The personal information we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include:

• Name
• Email address
• Password
• Billing information
• Full name, address, phone number, date of birth, and other identifying information needed for deletion requests
• Questionnaire responses about data privacy preferences and online activities
• Messages sent to our support team

Sensitive Information: When necessary, with your consent or as otherwise permitted by applicable law, we process the following categories of sensitive information:

• Date of birth or other personal identifiers for deletion requests

Payment Data: We may collect data necessary to process your payment if you make purchases, such as your payment instrument number, and the security code associated with your payment instrument. All payment data is stored by Stripe. You can find their privacy notice here: https://stripe.com/privacy.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Questionnaire Data: We collect responses from questionnaires you complete regarding your data privacy preferences and online activities. This data helps us determine which data brokers you may be more vulnerable to and tailor our deletion requests accordingly. We recommend that you do not request deletion of your questionnaire data until you are completely done using our Services.

Information Automatically Collected

Some information—such as your Internet Protocol (IP) address and/or browser and device characteristics—is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity but may include device and usage information, such as:

• Log and Usage Data: Service-related, diagnostic, usage, and performance information our servers automatically collect
• Device Data: Information about your computer, phone, tablet, or other device you use to access the Services
• Location Data: Information about your device's location, which can be either precise or imprecise

2. How Do We Process Your Information?

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

• To facilitate account creation and authentication and otherwise manage user accounts
• To deliver and facilitate delivery of services to the user
• To respond to user inquiries/offer support to users
• To send administrative information to you
• To fulfill and manage your orders
• To request feedback
• To protect our Services
• To identify usage trends
• To comply with our legal obligations
• To determine data broker vulnerability

3. What Legal Bases Do We Rely On to Process Your Personal Information?

We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law.

If You Are Located in the EU or UK:

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on to process your personal information. As such, we may rely on the following legal bases:

• Consent: We may process your information if you have given us permission to use your personal information for a specific purpose
• Performance of a Contract: We may process your personal information when we believe it is necessary to fulfill our contractual obligations to you
• Legitimate Interests: We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests
• Legal Obligations: We may process your information where we believe it is necessary for compliance with our legal obligations
• Vital Interests: We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party

If You Are Located in Canada:

We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent).

4. When and With Whom Do We Share Your Personal Information?

We may share information in specific situations described in this section and/or with the following third parties:

Business Transfers

We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

Service Providers

We work with trusted third-party service providers who help us operate our business:

• Payment processors (Stripe)
• Cloud hosting providers (AWS)
• Email service providers

Companies Targeted in Deletion Requests

Information necessary to process your deletion requests.

5. What Is Our Stance on Third-Party Websites?

We are not responsible for the safety of any information that you share with third parties that we may link to or who advertise on our Services, but are not affiliated with our Services.

The Services may link to third-party websites, online services, or mobile applications and/or contain advertisements from third parties that are not affiliated with us. We do not make any guarantee regarding any such third parties, and we will not be liable for any loss or damage caused by the use of such third-party websites, services, or applications. The inclusion of a link towards a third-party website, service, or application does not imply an endorsement by us.

6. Do We Use Cookies and Other Tracking Technologies?

We do not use cookies or similar tracking technologies on our website.

7. How Do We Handle Your Social Logins?

If you choose to register or log in to our Services using a third-party account, we may have access to certain information about you.

Our Services offer you the ability to register and log in using your Google account details. Where you choose to do this, we will receive certain profile information about you from Google. The profile information we receive may vary, but will often include your name, email address, and profile picture, as well as other information you choose to make public.

In the future, we may add support for Microsoft and Facebook logins, which would function similarly.

We will use the information we receive only for the purposes that are described in this privacy notice or that are otherwise made clear to you on the relevant Services. Please note that we do not control, and are not responsible for, other uses of your personal information by your third-party provider.

8. Is Your Information Transferred Internationally?

Our servers are located in the United States. If you are accessing our Services from outside the United States, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information, in the United States, and other countries.

If you are a resident in the European Economic Area (EEA), United Kingdom (UK), or Switzerland, these countries may not necessarily have data protection laws or other similar laws as comprehensive as those in your country. However, we will take all necessary measures to protect your personal information in accordance with this privacy notice and applicable law.

We implement appropriate safeguards, such as Standard Contractual Clauses, to ensure compliance with international data protection laws.

9. How Long Do We Keep Your Information?

We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements).

For cancelled accounts, we keep data for 90 days to allow request tracking, then permanently delete all personal information. Some data may be retained longer if required by law.

10. How Do We Keep Your Information Safe?

We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure.

We implement industry-standard security measures:

• Encryption: All data is encrypted in transit (TLS 1.2+) and at rest (AES-256)
• Access Controls: Strict employee access controls and regular security training
• Infrastructure: Secure cloud hosting with regular security audits
• Monitoring: 24/7 security monitoring and incident response

11. Do We Collect Information From Minors?

We do not knowingly collect data from or market to children under 13 years of age.

By using the Services, you represent that you are at least 13 or that you are the parent or guardian of such a minor and consent to such minor dependent's use of the Services. If we learn that personal information from users less than 13 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records.

For Family plans, parents or guardians are responsible for managing their children's accounts and providing consent for data processing.

12. What Are Your Privacy Rights?

In some regions, such as the European Economic Area (EEA), United Kingdom (UK), Switzerland, and Canada, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.

In some regions (like the EEA, UK, Switzerland, and Canada), you have certain rights under applicable data protection laws. These may include the right to:

• Request access and obtain a copy of your personal information
• Request rectification or erasure
• Restrict the processing of your personal information
• Request data portability
• Not be subject to automated decision-making
• Object to the processing of your personal information

To exercise these rights, contact us at privacy@privguard.dev.

You have the following rights:

• Access: Request a copy of your personal data
• Correction: Update incorrect or incomplete information
• Deletion: Request deletion of your personal data
• Portability: Request your data in a portable format
• Restriction: Limit how we process your information
• Objection: Object to processing based on legitimate interests

13. Controls for Do-Not-Track Features

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online.

14. Do California Residents Have Specific Privacy Rights?

Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.

California Civil Code Section 1798.83 ("Shine The Light" Law)

You have the right to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year.

CCPA Privacy Notice

PrivGuard collects and shares your personal information for the purposes described in this privacy notice. We do not sell or share personal information for cross-context behavioral advertising.

Your rights with respect to your personal data:

• Right to request deletion: You can ask for the deletion of your personal information
• Right to be informed: Depending on the circumstances, you have a right to know whether we collect and use your personal information, the categories collected, and the purposes
• Right to Non-Discrimination: We will not discriminate against you if you exercise your privacy rights
• Right to Limit Use: We do not process consumer's sensitive personal information

Verification Process: Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system.

15. Do We Make Updates to This Notice?

Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this privacy notice from time to time. The updated version will be indicated by an updated "Last updated" date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification.

We will notify you of any material changes by:

• Posting the updated policy on our website
• Sending you an email notification
• Providing an in-app notification

We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

16. How Can You Contact Us About This Notice?

If you have questions or comments about this notice, you may email us at privacy@privguard.dev.

If you have a complaint about how we handle your data, we would like to hear from you. Please contact us and we will work with you to resolve the matter as quickly as possible.

17. How Can You Review, Update, or Delete the Data We Collect From You?

You have the right to request access to the personal information we collect from you, change that information, or delete it. To request to review, update, or delete your personal information, please contact us at privacy@privguard.dev.