Privacy Policy

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Version as of May 31, 2019

This Privacy Policy (the “POLICY”) applies to the website vpn.troywell.org, its domains as well as our desktop and mobile browser extensions and application (for instance, relevant iOS, Android and Microsoft apps) (the “WEBSITE”).  The WEBSITE is created and controlled by S Group International Inc., holding all rights over TROYWELL trade mark, as well as by its affiliates (the “Sa”). This POLICY determines the manner in which we (legal entities and individuals operating under TROYWELL brand) (hereinafter, “we”) process personal data collected from users of the WEBSITE (each, a “USER” or “you”).

This POLICY is intended to make our users fully aware of the data we collect, the way it is stored, used, and shared, and our users’ rights in relation to such data and practices. We greatly value our users and their privacy rights, and we encourage all of our users to read and become familiar with this Privacy Policy so that they may understand those rights and how to protect them. This POLICY constitutes an integral part of other legal documents issued by TROYWELL (which may be amended from time to time) relating to the WEBSITE operation and published at https://vpn.troywell.org.

By installing any TROYWELL Products and/or using any of the TROYWELL Services, you acknowledge our collection, storage, use and sharing of your Personal Information and Non-Personal Information in accordance with the terms of this Privacy Policy. IF YOU OBJECT TO THE TERMS OF THIS PRIVACY POLICY, PLEASE DO NOT ACCESS OR USE THE TROYWELL PRODUCTS OR TROYWELL SERVICES.

WHAT DATA WE COLLECT

We may collect from and about you both Personal Information and Non-Personal Information, as follows:

Information You Provide Directly – We may collect information directly from you, including information that identifies or can readily be used to identify an individual (referred to herein as “Personal Information”). This information that we collect directly from you includes:

  • Registration Information. You may register with us directly through https://troywell.org/landing/join/. Registration instructions are provided in our Terms of Use. If you do choose to register, then we will collect from you certain registration information including your name, email address, user name and password. In addition, once you have registered, you may choose to enter certain information about you in your user profile. All of this data, including Personal Information, we receive in relation to your registration is referred to herein as “Registration Information”. Note that registration is not mandatory and you may use the TROYWELL Products and TROYWELL Services without registration.
  • Customer Support Information. You may voluntarily provide us with information when you contact us for customer support – support@troywell.org, such as your name and email address. We will use any Personal Information received for customer support purposes to communicate with and support you, and we will not share it with any third parties, except as reasonably necessary to provide customer support.

Information from Third Parties. We may also receive Registration Information about you if you register through a social network (e.g. Google+, VK, Facebook, and others). This Registration Information may include any information (such as profile picture, public and basic information, status and photos) as provided by you to the applicable social network operator, and which such social network operator permits to be shared with third parties. The data we receive from your social network operator depends on your privacy settings with the social network operator, and we will not post information about you on third party social media sites without your consent. You should review and, if necessary, adjust your privacy settings on third-party websites and services before linking or connecting them to the TROYWELL Products or TROYWELL Service.

Automatically Collected Information. When you install and use the TROYWELL app or TROYWELL desktop browser extension, we also collect from you automatically, and where applicable through the Android accessibility services feature, information related to your use of the TROYWELL Services and your web browsing activity. This information may include, without limitation, the following: 

  • From TROYWELL desktop/mobile extension and desktop app – Internet Protocol Address (trimmed to permanently remove specific location information other than country, city & postal code); device type; operating system and browser; Search engine results page (keyword, order/index of results, link of result, title, description, ads); web pages visited and time stamp of the visit; display ads; the extension’s unique identifier, the extension name, app, or theme, enabled or disabled extension, and TROYWELL user ID.
  • From TROYWELL mobile app (for Android) – Internet Protocol Address (trimmed to permanently remove specific location information other than country, city & postal code); device information (device model name, device ID (permanently and irreversibly encrypted), OS version, whether device is rooted, screen size); information about installed apps (name, id, type, install date, update date, version, time used, whether on home page); applications web connections; and browsing information (browser, web pages visited and time stamp of the visit).
  • From TROYWELL mobile app (for iOS) – Internet Protocol Address (trimmed to permanently remove specific location information other than country, city & postal code); GUID (randomly generated ID number); websites visited; apps in use; and time stamp.

In addition, some of this automatically collected information may be considered “Non-Personal Information,” which is anonymous, aggregated or de-identified information that is not collected together, or otherwise associated by us, with any Registration Information or other Personal Information, if any, that we hold about you. When we automatically collect information, we go to great lengths to make sure that Non-Personal Information remains anonymous, as further described below.

HOW WE USE THE DATA

As a rule, we may collect and process only what it needs and will not share your PERSONAL DATA with any third parties, unless otherwise directly indicated in this POLICY. We may collect and process PERSONAL DATA for the following purposes:

  • to provide our services via WEBSITE or TROYWELL platform; 
  • to elaborate carefully commercial version of our WEBSITE and of TROYWELL services and  to improve, promote the TROYWELL services;
  • for contacting the USER, for managing contacts and sending messages; 
  • for interaction with external networks and platforms; 
  • for registration and authentication, handling payments and infrastructure monitoring; 
  • for analytics, to protect the WEBSITE and USERS;
  • for interaction with support and feedback platforms and for managing support and contact requests; 
  • for USER database management;
  • to run, maintain and operate the WEBSITE (including for provision of services); 
  • for risk management purposes;
  • to run promotion, contest, survey or other WEBSITE features; 
  • to comply with applicable laws or by-laws; 
  • to send USERS information they agreed (or have requested) to receive about topics we consider as interesting for them and to send USERS a service-related announcement (these communications are not promotional in nature).

TROYWELL goes to great lengths, and invests substantial resources, to avoid disclosing Personal Information. This includes the use of various state-of-the art anonymization, data cleaning and aggregation techniques to identify and remove Personal Information from information we collect with the goal of storing only Non-Personal Information.

SHARING COLLECTED DATA WITH THIRD PARTIES

Personal Information. We do not share your Personal Information or Non-Personal Information with third parties, except as follows:

  • third parties such as our services providers (e.g., to provide you support services, authentication services, prevent fraud on our services, administer our promotions, maintain the accuracy of databases) and financial institution partners (e.g., to provide rewards or benefits to you);
  • other USERS – only for the purposes and to the extent necessary for normal TROYWELL services use or function (including for making ratings, etc.) related to the commercial use of TROYWELL services; 
  • affiliated entities within the TROYWELL group; 
  • entities we plan to merge with or be acquired by; 
  • law enforcement, government officials, or other third parties when we believe in good faith that the disclosure of PERSONAL DATA is necessary to prevent physical harm or financial loss, to report suspected illegal activity or to investigate violations of the legal documents published on the WEBSITE; or 
  • other third parties only with your prior consent or direction to do so. 
  • we reserve the right to transfer PERSONAL DATA to a successor that has acquired such rights in result of sale or substantial sale of all of our assets to that successor. 

USER MECHANIC PROTECTION

TROYWELL may request additional permissions to deactivate the third-party desktop/mobile extension during of cooperation with the users to increase protection against unauthorized using of the tracking facilities and user’s cashback. This feature allows us to disable/enable the third-party desktop/mobile extension automatically if such extensions are harmful or damaging to the normal operation of the TROYWELL desktop/mobile extension service. This prevents the negative consequences of incorrect attribution, tracking and, as a consequence, the cashback transfer to users. Such desktop/mobile extension includes: ad blockers, cookie stuffing mechanics and etc. The user may disable / enable this feature at any time through the user interface.

LEGAL OVERVIEW 

By using the WEBSITE, the USER confirms acceptance of this POLICY. Using this WEBSITE means registering for our services or signing in to an existing account, visiting our WEBSITE, accessing our services through our application(s) (if any), connecting to our services using third-party accounts, contacting us for support, participating in our shopping or promotion campaigns and programs.

The PERSONAL DATA we collect allows us to keep you in touch with TROYWELL latest services and product announcements, software updates, etc. 

By accepting this POLICY, you agree to being contacted by us or by our associates or third parties with marketing communications related to the WEBSITE, including launch of its commercial version, regarding various offerings by way of e-mail or SMS or push-notifications (other forms of written communication), any of which you may unsubscribe from at any time by contacting us. 

Before permitting you to use the WEBSITE and if so required by requirements of applicable law, we may require you to provide additional information so that we can verify your identity or address. We may also obtain information about you from third parties such as identity verification services. 

We shall not be required to accept you as a counter-party, including acceptance as a user, and we may be unable to accept you as a client or investor until all Know-Your-Client and Anti-Money-Laundry documentation we require is duly executed and received, if required under applicable laws, and we reserve the right to reject your payments of any nature (donations, investments, payments, etc.) until it has received all necessary documentation, properly completed and duly executed. 

HEREBY you irrevocably declare: 

  • that you have read, understood, found satisfactory and fully accepted this POLICY; 
  • that you confirm that your affirmative consent for processing of PERSONAL DATA is given freely, clearly, specifically and unambiguously;
  • that you consider other legal documents published at WEBSITE and risk warnings and risk disclosures provided in the WEBSITE in any form as an integral part of this POLICY.

COOKIES NOTICE 

TROYWELL may place, view, and/or use cookies, Web server logs, Web beacons, or other electronic tools to collect statistical and other information about your use of the Website. A “Cookie” is a small text file located in a browser directory, that a website assigns and stores on your computer while you are viewing a website.

This information may include information about the IP address of your computer, browser type, language, operating system, your device, geo-location data, the state or country from which you accessed the WEBSITE, the Web pages visited, the date and the time of a visit, the websites you visited immediately before and after visiting the WEBSITE, the number of links you click within the WEBSITE, the functions you use on the WEBSITE, the databases you view and the searches you request on the WEBSITE, the data you save on or download from the WEBSITE and the number of times you view an advertisement.

We also use cookies to save your login email, and if you choose, to save other personal information so you do not have to re-enter it each time you visit the WEBSITE.

You may choose to set web browser to refuse cookies, or to alert when cookies are being sent. If you do so, please note that some parts of the Website may not function properly.

 DATA TRANSFERS, STORAGE AND SECURITY

We may need to transfer your information to our affiliated companies in locations around the world for the purposes described in this Privacy Policy. We may also appoint third party service providers, operating under our instructions, who may need access to your information in connection with their services on our behalf. In these cases, transfers of Personal Information will be done in compliance with applicable data protection laws.

We will take the necessary steps to ensure that any international transfers of Personal Information meet all statutory requirements under applicable data protection law. In particular, when Personal Information collected within the European Economic Area (” EEA “) is transferred outside the EEA, we will take the necessary steps to ensure that the transfer of such information provides adequate safeguards, and you may exercise your rights (where applicable) to receive information on the relevant transfer mechanism.

While there are inherent risks involved in all data transmissions over the Internet or wireless networks, and other security risks that apply to stored data, and we therefore cannot guarantee the security of your information, we use our best efforts, using industry-standard encryption and security technologies and methods, to collect and store information collected from you in a secure and safe manner.

DATA RETENTION

We retain the data collected in accordance with this Privacy Policy for as long as reasonably necessary to fulfill and support our operational and business purposes as described herein, or to comply with any applicable legal request or requirement as set forth herein. With respect to Non-Personal Information, we may choose to retain it for a longer period of time.

YOUR RIGHTS

Where foreseen under applicable law, as is the case within the European Union, you may have the right to ask us to delete Personal Information which you have provided to us (subject to applicable exceptions, such as in order to preserve that information for anticipated litigation or demands from a regulator) or some or all of the following additional rights: the right to obtain information on our use of your Personal Information, the right to obtain a copy thereof, the right to data portability, the right of data rectification, the right to object to the processing of data based on our legitimate interests, the right to restriction of the processing, and the right to withdraw your consent.

In relation to these rights, please contact our Data Protection Officer at support@troywell.org . Note that we may request certain information in order to confirm your identity, and we reserve the right to charge a fee where permitted by law, such as in circumstances where your request is excessive. We will use our best efforts to respond to your request within applicable required timeframes.In addition, you may (subject to applicable law, as is the case within the European Union) have the right to lodge a complaint with a supervisory authority.

Note that you may opt out of the data collection and sharing of Non-Personal Information.

After you opt out, we will no longer automatically collect and share your Non-Personal data in connection with your use of the TROYWELL app or extension.

We may send periodic promotional and informational emails to you, about the TROYWELL Services and other products, services or information we think may interest you. You may opt out of such communications by following the opt-out instructions contained in the email or emailing us at support@troywell.org . Please note that it may take up to ten (10) business days for us to process opt-out requests. If you opt out of receiving promotional and informational emails from us, we may still send you emails about your account or any TROYWELL Services you have requested or received from us.

CHILDREN’S PRIVACY

If you are under 16 years old, you SHALL NOT use the WEBSITE and TROYWELL services. We do not knowingly solicit or collect information from anyone under 16 years old. If we become aware that a person under the age of 16 has provided us with personal information, we will delete it immediately.

THIRD-PARTY LINKS

The TROYWELL Services may contain links to third-party websites and applications, including social networking platforms. Any access to and use of such linked websites and applications is not governed by this Privacy Policy but instead is governed by the privacy policies of those third parties. We are not responsible for the information practices of such third-party websites or applications and encourage you to review the privacy policies provided by such third parties.

CHANGES IN POLICY 

From time to time we may make changes to this POLICY. If we make changes, we will post them on the WEBSITE to notify the USERS thereof. A USER shall acknowledge and comply with all changes to the POLICY when using the WEBSITE after those changes posted. Further use of the WEBSITE (including by simply accessing and reviewing it) means that you accept and agree with any alterations made to this POLICY. You acknowledge and agree that it is your responsibility to review the POLICY periodically and become aware of modifications.

CONTACT DETAILS 

Any questions, comments, requests or complaints concerning this Policy and other materials from the WEBSITE shall be directed to our help desk at support@troywell.org.