Privacy Policy

Last updated on • 28th Nov 2022

AD RAK Labs Ltd., Is registered in the BVI with registration number 2089498 and is DBA SANTA Browser. Our registered office is located at craigmuir chambers, road town, Tortola, VG 1110, British Virgin Islands. You can write to us at [email protected] Or reach us on
+973 3872 4554

SANTA Browser (‘Santa’, ‘we’, ‘our’, or ‘us’) is focused on allowing users to earn revenues without compromising on their privacy. When you use Santa’s services, you entrust us with your personal data. Since privacy is one of the cornerstones of Santa, this Privacy Policy is designed to provide complete transparency into the use of data collected by us, including any and all personal data.

This Privacy Policy (‘Privacy Policy’ or ‘Policy’) describes our data practices for information collected through our browser, apps, websites, features and related products and services (collectively, the ‘Services’). The Policy explains how we collect, use, and share information from users of our Services (‘Users’ or ‘You’). 

By using our Services, you agree to our Terms and Conditions (Terms of use) which can be Found on Terms and Conditions and consent to our collection, use, disclosure practices, and other activities as described in this Policy. The Terms of Use are to be read in conjunction with this Policy. If you do not agree and consent, you must stop using our Services.

1. Scope of the policy

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, wallet addresses, 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.

2. What Data we may collect

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 randomly generated Santa Wallet IDs, which includes details about the device, the country of origin, device manufacturer and brand, operating system, etc. 

  • Usage information 
    We may receive information about pertaining to randomly generated Santa Wallet IDs whenever as potential or existing User installs or uses our Services. 

  • Santa Wallet ID

  • News Feed and Search Results 

  • Web monetization settings 

  • Customer Support and Communications with us 

  • Crash reports

  • Other information, as applicable 

3. How is the data Used

We may use the Personally Identifiable Information for the following purposes:

  • Communications with you

  • Ads – depending upon the type of subscription 

  • Providing services

  • Legal obligations and compliance 

  • Personalization 

  • Anonymous Data 

  • Other usage

If you are located in the European Economic Area, we process your Personally Identifiable Information only when we have a valid “legal basis” to do so, including when:

  • Consent: You have consented to the use of your Personally Identifiable Information, for example when required by applicable law to send you marketing communications.

  • Contractual Necessity: We need your Personally Identifiable Information to provide you with the Services, for example, to respond to your inquiries or allow for payment transactions. 

  • Compliance with a Legal Obligation: We have a legal obligation to use your Personally Identifiable Information, for example, to comply with tax and accounting obligations.

  • Legitimate Interests: We or a third party have a legitimate interest in using your Personally Identifiable Information. In particular, we have a legitimate interest in using your Personally Identifiable Information for product development and internal analytics purposes, and otherwise to improve the safety, security, and performance of our Services. 

4. How is the data stored

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.

5. Discloser of the personally identifiable information

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.

6. Controlling your personally identifiable information

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. 

7. Data retention

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. 

8. Data protection & security

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.

9. Cookies Policy

"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".

10. Ads services and Santa rewards

Santa will only collect data when the User accepts the display of Ads Services to earn Santa Rewards. No data shall be collected if the User does not accept the display of Ads or earns Rewards. 

If the User opts for the Santa Rewards, the Ads services are automatically enabled. The Ads services may be personalized for the Users, however the data used for the Ads services would only be stored on the Users’ devices. Santa would not have access to any such data. 

11. VPN Usage

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. 

12. Location

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. 

13. AML Compliance

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.

14. Changes to this privacy policy

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. 

15. Contact us

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: [email protected]

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