Website Personal Data Policy

March 22nd, 2019

Proxy, Inc. ("Proxy" or "We") respect your privacy and are committed to protecting it through our compliance with this policy.

This policy describes the types of information we may collect from you or that you may provide when you visit the website proxy.com (our "Website") and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This policy applies to information we collect:

  • On our Website.

  • In email, text, and other electronic messages between you and our Website.

It does not apply to information collected by:

  • Us offline or through any other means, including on any other website operated by Proxy or any third party (including our affiliates and subsidiaries).

  • The Proxy ID app. There is a separate policy for our product at https://proxy.com/privacy

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using our Website, you agree to this data policy. This policy may change from time to time (see Changes to Our Data Policy). Your continued use of our Website after we make changes to this Data Policy is deemed to be acceptance of those changes, so please check the policy periodically for updates.

Children Under the Age of 18

Our Website is not intended for children under 18 years of age. No one under age 18 may provide any information to our Website. We do not knowingly collect Personal Information from children under 18. If you are under 18, do not use or provide any information to our Website or through any of its features, register on our Website, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received Personal Information from a child under 18, we will delete that information. If you believe we might have any information from or about a child under 18, please contact us at privacy@proxy.com.

US Residents Only

This Data Policy is intended to cover collection of information on or via our Website from residents of the United States. If you are visiting our Website from outside the United States, please be aware that your information may be transferred to, stored, and processed in the United States where our servers are located and our central database is operated. The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country. Please be assured that we seek to take reasonable steps to ensure that your privacy is protected. By using our Website, you understand that your information may be transferred to our facilities and those third parties with whom we share it as described in this Data Policy.

Information We Collect About You and How We Collect It

We collect several types of information from and about users of our Website, including information:

  • By which you may be personally identified, such as name, e-mail address, telephone number and billing address (for administrator users), any other identifier by which you may be contacted online or offline, or any other data that can be used to identify you ("Personal Information");

  • About your internet connection, the equipment or device you use to access our Website, and usage details.

We collect this information:

  • Directly from you when you provide it to us.

  • Automatically as you navigate through our Website or interact with emails we send you. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.

Information You Provide to Us

The information we collect on or through our Website may include:

  • Information that you provide by filling in forms on our Website. This includes information provided at the time of registering to use our Website or requesting further services. We may also ask you for information when you report a problem with our Website.

  • Records and copies of your correspondence (including email addresses), if you contact us.

  • Your responses to surveys that we might ask you to complete for research purposes.

  • For system administrators, details of transactions you carry out through our Website and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Website.

  • Your search queries on the Website.

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

  • Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.

  • Information about your computer and internet connection, including your IP address, operating system, and browser type.

We may collect Personal Information automatically, or we may tie automatically collected information to Personal Information about you that we collect from other sources or you provide to us. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:

  • Estimate our audience size and usage patterns.

  • Store information about your preferences, allowing us to customize our Website according to your individual interests.

  • Speed up your searches.

  • Recognize you when you return to our Website.

The technologies we use for this automatic data collection may include:

  • Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.

  • Web Beacons. Our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit Proxy, for example, to count users who have opened an email and accessed a link contained in that email.

  • Google Analytics. We use a tool called "Google Analytics" to collect information about use of this Website. Google Analytics collects information such as how often users visit this Website, what pages they visit when they do so, and what other sites they used prior to coming to this Website. We use the information we get from Google Analytics only to improve this Website. Google Analytics collects only the IP address assigned to you on the date you visit this Website, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Although Google Analytics plants a permanent cookie on your web browser to identify you as a unique user the next time you visit this Website, the cookie cannot be used by anyone but Google. Google's ability to use and share information collected by Google Analytics about your visits to this site is restricted by the Google Analytics Terms of Use and the Google Privacy Policy. You can prevent Google Analytics from recognizing you on return visits to this site by disabling cookies on your browser.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any Personal Information:

  • To present our Website and its contents to you.

  • To provide you with information, products, or services that you request from us.

  • To fulfill any other purpose for which you provide it.

  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.

  • To notify you about changes to our Website or any products or services we offer or provide though it.

  • In any other way we may describe when you provide the information.

  • For any other purpose with your consent.

We may also use your information to contact you about our goods and services that may be of interest to you. If you do not want us to use your information in this way, please use the unsubscribe link contained in all promotional emails. For more information, see Choices About How We Use and Disclose Your Information.

Disclosure of Your Information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose Personal Information that we collect or you provide as described in this data policy:

1. To our subsidiaries and affiliates.

2. To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep Personal Information confidential and use it only for the purposes for which we disclose it to them. These may include, but may not be limited to, the following:

  • DCL - We use DCL for many of our logistical tasks. More information about DCL's data practices may be found online at https://dclcorp.com/privacy/

  • Shopify - We use Shopify for many of our e-commerce needs. More information about Shopify's data practices may be found online at https://www.shopify.com/legal/privacy

  • Stripe - We use Stripe for many of our payment processing tasks. More information about Stripe's data practices may be found online at https://stripe.com/us/privacy.

  • Zendesk – We use Zendesk for many of our customer service needs. More information about Shopify's data practices may be found online at https://www.zendesk.com/company/customers-partners/privacy-policy/

3. Shipping companies we use to deliver products you order from us to you.

4. To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Proxy's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by Proxy about our Website users is among the assets transferred.

5. To fulfill the purpose for which you provide it.

6. For any other purpose disclosed by us when you provide the information.

7. With your consent.

We may also disclose your Personal Information:

  • To comply with any court order, law, or legal process, including to respond to any government or regulatory request.

  • To enforce or apply our terms of use https://proxy.com/terms and other agreements, including for billing and collection purposes.

  • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Proxy, our customers, or others.

Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the Personal Information you provide to us. We have created mechanisms to provide you with the following control over your information:

  • Tracking Technologies. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of the Services may then be inaccessible or not function properly.

  • Promotional Offers from Proxy. If you do not wish to have your email address used by Proxy to promote our products or services, you can opt-out by using the unsubscribe link contained in all promotional emails.

Accessing and Correcting Your Information

You may send us an email at privacy@proxy.co to request access to delete any Personal Information that you have provided to us. We may not accommodate a request to delete information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

Your California Privacy Rights

California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our App that are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. Proxy DOES NOT disclose your Personal Information to third parties for their directing marketing purposes.

Data Security

We have implemented measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is encrypted and stored on our secure servers behind firewalls. Any payment transactions will be encrypted using SSL technology.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your Personal Information, including encrypting such transmissions, we cannot guarantee the security of your Personal Information transmitted to our Website. Any transmission of Personal Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained in our Website

Privacy Shield Policy

Proxy recognizes that the European Economic Area (the "EEA"), the UK, and Switzerland have established strict protections regarding the handling of Personal Information, including requirements to provide adequate protection for Personal Information transferred outside of the EEA, the UK, and Switzerland. To provide adequate protection for certain Personal Information received in the US from the EEA, the UK, and Switzerland, Proxy has elected to self-certify to the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework administered by the US Department of Commerce ("Privacy Shield") and is in the process of achieving that self-certification. Proxy adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement, and Liability.

For purposes of enforcing compliance with Privacy Shield, Proxy is subject to the investigatory and enforcement authority of the US Federal Trade Commission. For more information about Privacy Shield, see the US Department of Commerce's Privacy Shield website located at: https://www.privacyshield.gov. To review Proxy's representation on the Privacy Shield list, see the US Department of Commerce's Privacy Shield self-certification list located at: https://www.privacyshield.gov/list.

Personal Information Collection and Use.

Above we describe the categories of Personal Information that we may receive in the US as well as the purposes for which we use that Personal Information. Proxy will only process Personal Information in ways that are compatible with the purpose that Proxy collected it for, or for purposes the individual later authorizes. Before we use your Personal Information for a purpose that is materially different than the purpose we collected it for or that you later authorized, we will provide you with the opportunity to opt out. Proxy maintains reasonable procedures to help ensure that Personal Information is reliable for its intended use, accurate, complete, and current.

Data Transfers to Third-Party Agents or Service Providers. We may transfer Personal Information to our third-party agents or service providers who perform functions on our behalf as described above. Where required by Privacy Shield, we enter into written agreements with those third-party agents and service providers requiring them to provide the same level of protection Privacy Shield requires and limiting their use of the data to the specified services provided on our behalf. We take reasonable and appropriate steps to ensure that third-party agents and service providers process Personal Information in accordance with our Privacy Shield obligations and to stop and remediate any unauthorized processing. Under certain circumstances, we may remain liable for the acts of our third-party agents or service providers who perform services on our behalf for their handling of Personal Information that we transfer to them.

Disclosures for National Security or Law Enforcement. Under certain circumstances, we may be required to disclose your Personal Information in response to valid requests by public authorities, including to meet national security or law enforcement requirements.

Security

As detailed above, Proxy maintains reasonable and appropriate security measures to protect Personal Information from loss, misuse, unauthorized access, disclosure, alteration, or destruction in accordance with the Privacy Shield.

Access Rights

You may have the right to access the Personal Information that we hold about you and to request that we correct, amend, or delete it if it is inaccurate or processed in violation of the Privacy Shield. These access rights may not apply in some cases, including where providing access is unreasonably burdensome or expensive under the circumstances or where it would violate the rights of someone other than the individual requesting access. If you would like to request access to, correction, amendment, or deletion of your Personal Information, you can submit a written request to the contact information provided below. We may request specific information from you to confirm your identity. In some circumstances we may charge a reasonable fee for access to your information.

Binding Arbitration

You may have the option to select binding arbitration for the resolution of your complaint under certain circumstances, provided you have taken the following steps: (1) raised your compliant directly with Proxy and provided us the opportunity to resolve the issue; (2) made use of the independent dispute resolution mechanism identified above; and (3) raised the issue through the relevant data protection authority and allowed the US Department of Commerce an opportunity to resolve the complaint at no cost to you. For more information on binding arbitration, see US Department of Commerce's Privacy Shield Framework: Annex I (Binding Arbitration).

Changes to Our Data Policy

It is our policy to post any changes we make to our data policy on this page with a notice that the data policy has been updated on the Website home page. If we make material changes to how we treat our users' Personal Information, we will notify you by email to the email address specified in your account and through a notice on the Website home page. The date the data policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this data policy to check for any changes.

Contact Information

To ask questions or comment about this data policy and our privacy practices, contact us at: privacy@proxy.com