For the purposes of this Policy, ‘Personally Identifiable Information (‘PII’) is defined as any information that identifies (whether directly or indirectly) a particular individual, including but not limited to, any encryption or encrypted keys, geolocation information, payment card information for the processing of any payments, and any likes and preferences should you opt for the advertising model. 

‘Anonymous Data’ means data, including aggregated and de-identified data, that is not associated with or linked to your Personally Identifiable Information. Anonymous Data does not, by itself, permit the identification of individual persons. We may create Anonymous Data records from Personally Identifiable Information by excluding information that makes the data personally identifiable to you. We use this Anonymous Data to analyze request and usage patterns so that we may enhance the content of our Services and improve Service navigation. We reserve the right to use Anonymous Data for any purpose and to disclose Anonymous Data to third parties without restrictions.

Please bear in mind that when you provide us information from a third-party platform, the information collected by the third-party platform is subject to the respective third-parties’ privacy practices and policies. The privacy choices you have made on the third-party platform does not apply to our collection and use of the information. This Policy is only applicable to the extent of information collected by us through our Services. We highly encourage you to read the privacy policies of other platforms that may collect your information.

While Santa strives to not collect any PII from you, the data is collected by third-parties to provide an enhanced experience. In the event that such data is collected, if at all, Santa will adhere to the applicable laws and regulations to ensure that your PII is appropriately protected. 

Information collected for the Browser‍

• Browser ID
  Santa collects product usage statistics and telemetry, which is tracked through the Browser ID. 

• Device information 
  We may receive information pertaining to devices, which includes details about the device, device manufacturer, brand, operating system, etc. 

• Usage information 
  We may receive information whenever a potential or existing User installs or uses our Services. 

• News Feed and Search Results 

• Customer Support and Communications with us 

• Crash reports

• Other information, as applicable 

User data is only stored on the browser on the Users’ devices.  Santa does not store any of the PII. Any Anonymous Data collected will be stored on the third party data centres and servers.

We may share or otherwise disclose your Personally Identifiable Information as described below or otherwise disclosed to you at the time of collection.

• Partners and Affiliates: We may share any Personally Identifiable Information we receive with our partners and affiliates for any of the purposes described in this Privacy Policy. 

• Vendors and Service Providers: We may share any Personally Identifiable Information we receive with contractors, vendors, service providers, and other third parties retained in connection with the provision of our Services.

• Marketing: We do not rent, sell, or share Personally Identifiable Information with non-affiliated companies for their direct marketing purposes unless we have your permission.

• Corporate Restructuring: We may share some or all of your Personally Identifiable Information in connection with or during negotiation of any merger, financing, acquisition or dissolution transaction or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets. In the event of an insolvency, bankruptcy, or receivership, Personally Identifiable Information may also be transferred as a business asset. If another company acquires our company, business, or assets, that company will possess the Personally Identifiable Information collected by us and will assume the rights and obligations regarding your Personally Identifiable Information as described in this Privacy Policy.

• Consent: We may share information with your consent.

• As required by Law and Similar Disclosures.

We use reasonable precautions to keep confidential and Personally Identifiable Information disclosed to us secure and do not disclose this information to other individuals or organisations unless required by law, or subject to Clause 5 mentioned herein.

In the case of abuse or breach of security, we are not responsible for any breach of security or for any actions of any third parties which receive the information illegally.

We will not distribute any information to be used in mailing lists, surveys, or any other purpose other than what is required to perform our Services or in accordance with the terms of this Privacy Policy. 

If you choose to restrict the collection or use of your confidential and Personally Identifiable Information, then kindly do not proceed, exit our website and discontinue usage of our services. 

We may retain your Personally Identifiable Information through third parties subject to their privacy policies, as long as you continue to use our Services, have an account with us, or for as long as is necessary to fulfil the purposes outlined in this Privacy Policy. 

You can ask to close your account by contacting us, and we will delete your Personally Identifiable Information on request. Once deleted, we will not have any information available to us through/by the third parties. 

We may, however, retain Personally Identifiable Information for an additional period as is permitted or required under applicable laws, for legal, tax, or regulatory reasons, or for legitimate and lawful business purposes. 

We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information.

However, no security system is impenetrable, and we cannot guarantee the security of our systems 100%. In the event that any information under our control is compromised as a result of a breach of security, we will take steps to investigate the situation and, where appropriate, notify those individuals whose information may have been compromised and take other steps, in accordance with any applicable laws and regulations.

Our Company will have operations in the European Union (‘EU’) and does have affiliated offices including customers and users outside of the EU. Therefore, any Personally Identifiable Information obtained by us for our  Services from  outside of the EU may be transferred to the EU to protect your Personally Identifiable Information from those jurisdictions where the laws and regulations pertaining to data privacy and protection are still developing or have limited scope. 

EU users are advised to read the important information provided below about the transfer of Personally Identifiable Information outside of the EEA.

European Data Protection Rights
If you are located in the European Economic Area (‘EEA’), you will have the rights as described below.

• You may request access to and receive information about the Personally Identifiable Information we maintain about you, update and correct inaccuracies in your Personally Identifiable Information, restrict or object to the processing of your Personally Identifiable Information, have the information anonymized or deleted, as appropriate, or exercise your right to data portability to easily transfer your Personally Identifiable Information to another company.

• You may withdraw any consent you previously provided to us regarding the processing of your Personally Identifiable Information, at any time and free of charge. We will apply your preferences going forward and this will not affect the lawfulness of the processing before you withdrew your consent.
  

• Marketing: We do not rent, sell, or share Personally Identifiable Information with non-affiliated companies for their direct marketing purposes unless we have your permission.

• Corporate Restructuring: We may share some or all of your Personally Identifiable Information in connection with or during negotiation of any merger, financing, acquisition or dissolution transaction or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets. In the event of an insolvency, bankruptcy, or receivership, Personally Identifiable Information may also be transferred as a business asset. If another company acquires our company, business, or assets, that company will possess the Personally Identifiable Information collected by us and will assume the rights and obligations regarding your Personally Identifiable Information as described in this Privacy Policy.

• Consent: We may share information with your consent.

• As required by Law and Similar Disclosures.

If you are located in the European Economic Area, we will comply with applicable EEA data protection law when transferring your Personally Identifiable Information outside of the EEA.

"Santa browser does NOT collect cookies. However please be aware that some third party services and websites you access through the browser may collect cookies. We are not responsible for the Cookies policies of these third parties. We recommend that you review the Cookies policy of any third-party services you interact with to understand their use of cookies and data collection practices".

We strictly DO NOT share, sell, or provide any information to any third parties under any circumstances, any information collected by a VPN service provider is the liability of the VPN provider. 

As the information collected by VPN, all the IP address information is immediately purged and deleted at the point your VPN session is terminated or disconnected. Therefore, we would NOT be liable if you use any VPN services. 

For Private Browser, we may collect and store web browsing history or information, however, this information is not transmitted to the Santa servers. 

If you use Santa to visit a website that wants to determine your location, you will be asked whether you want it to be allowed to know where you are. 

If you click yes to this message, then the website will be sent an approximation of where you are based on your IP address. Your IP address will not be stored by Santa, but it may be stored by the website you have visited. 

Your Personally Identifiable Information may be used as we believe necessary or appropriate to comply with applicable laws (including anti-money laundering (‘AML’) laws and know-your-customer (‘KYC’) requirements), as collected by third parties, lawful requests and legal process, such as to respond to requests from government authorities.

Santa is in compliance in all material respects, and will continue to so comply, with all applicable laws and regulations relating to guarding against terrorism and money laundering, and Santa agrees to comply with the anti-money laundering programs to the extent applicable. 

Your Personally Identifiable Information may be used for compliance purposes to protect, investigate, and deter against fraudulent, unauthorized, or illegal activity.

This Privacy Policy may be updated from time to time for any reason. 

Santa will notify the User of any changes to the Privacy Policy by posting the new Privacy Policy at this link Privacy Policy

The date the Privacy Policy was last revised is identified at the beginning of this Privacy Policy. 

The User is responsible for ensuring that Santa has an up-to-date active and deliverable email address, and for periodically visiting our Services and this Privacy Policy to check for any changes. 

If you have any questions or concerns or complaints about our Privacy Policy or our data collection or processing practices, or if you want to report any security violations to us, please contact us at the following address: contact@santabrowser.com