Santa is committed to the protection of your Personal Data and respects your privacy on all of its Services on the https://www.santabrowser.com/. In this regard, as far as possible, Santa minimizes the collection, use, disclosure or processing of Personal Data belonging to you or any other individuals accessing, using or interacting with the Services.

To the extent that any Personal Data is collected, used, disclosed or processed by Santa in the course of your access, use or interaction with the Services, such collection, use, disclosure and/or processing shall be conducted in accordance with this Privacy Policy. For the avoidance of doubt, you can browse through and use most of the Services without giving or providing any Personal Data.

Santa is the data controller of the Personal Data processed pursuant to this Privacy Policy and processes such data in compliance with applicable privacy and data protection laws, rules, and regulations, including without limitation, Regulation (EU) 2016/679 (the “GDPR”).

For the purposes of this Privacy Policy, “Personal Data” means any information relating to an identified or identifiable natural person (each a “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

‘Anonymous Data’ means data, including aggregated and de-identified data, that is not associated with or linked to your Personal Data. Anonymous Data does not, by itself, permit the identification of individual persons. We use Anonymous Data to analyze trends, improve navigation and functionality, and facilitate Santa Rewards in a privacy-preserving way.

We are not responsible for our customers’, partners’, and other third parties’ privacy policies or practices, which may differ from ours. We encourage you to review their privacy policies before submitting your Personal Data to them. If you have questions, complaints, or privacy requests, please contact these parties directly.

Please bear in mind that when you provide us Personal Data from a third-party platform, the Personal Data 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 us. This Privacy Policy is only applicable to the extent of Personal Data and other information collected by us through our Services. We highly encourage you to read the privacy policies of other platforms that may collect your Personal Data and information.

Santa prioritizes your privacy and gives you control over your online browsing while offering the opportunity to earn through Santa Rewards. When you first install Santa, you will be prompted to opt into Santa Rewards.

Santa Rewards are entirely optional, only activate for consenting users choosing to participate, and may be enabled or disabled at any time based on your preference.

• With Rewards Disabled: Santa collects limited Personal Data, primarily technical and pseudonymized data. All browsing activity is private.
• With Rewards Enabled: When opting into Santa Rewards, Santa still collects limited Personal Data, primarily technical and pseudonymized data. In addition, in order to facilitate the rewards mechanisms while preserving user anonymity, Santa collects proof of user interaction data on an aggregated and anonymized basis, based on a user’s chosen reward consent settings. Such anonymized data is used to support value generation and fair exchange between users, partners, and advertisers. Your Personal Data remains private and protected, and Santa adheres to a strict privacy-first approach.

Please note that due to our commitment to prioritizing privacy, a small percentage (4-7%) of user interactions may not be tracked. This is not due to a system fault but reflects design choices which favor privacy even if some rewards may not be captured. We continually work to optimize reward tracking without compromising on privacy.

You have the freedom to enable or disable Santa Rewards at any time, ensuring that you remain in control of your browsing experience.

Generally, Santa collects limited Personal Data, primarily technical and pseudonymized data, from you or any user of the Services. However, to the extent that any user provides Personal Data directly or indirectly to us through their use of the Services, Santa will process and handle such information in accordance with this Privacy Policy.

A. Sources of Data Collection

i. Direct Sources

Santa may obtain Personal Data directly from you. For example, we may receive or collect data directly from you when you use or request information about our Services or otherwise communicate or interact with us.

ii. Indirect Sources

We may obtain Personal Data about you from our customers, service providers, partners/resellers, and/or third parties. For example, we may obtain information about you from a third party for purposes of data analytics or our legitimate business purposes.

B. What data do we collect?

Generally, Santa collects limited Personal Data, primarily technical and pseudonymized data, from you or any user of the Services. However, through the various interactions that you may have with the Services, limited types of Personal Data and other information may be collected and processed by us as follows:

i. Santa Rewards related data collection:

The types of data collected depend on your choice to enable or disable Santa Rewards:

With Rewards Disabled:

• We may collect (i) device and browser data; (ii) IP address and security logs, (iii) crash logs and diagnostics, and (iv) support communications you voluntarily send us. We do not collect your browsing history or page content.

With Rewards Enabled:

• We may collect (i) interaction and engagement events (e.g., views, clicks, conversions), (ii) approximate location (country/region), (iii) time-based or frequency-based signals, (iv) pseudonymised cohort IDs, (v) or reward identifiers.
• Anonymous Interaction Data: We collect anonymized interaction data that is then aggregated into cohorts, ensuring user privacy is still maintained while allowing for value generation & exchange between users and advertisers/partners.

ii. Contact and Identification Information:

When you interact with us directly, or communicate or contact us through any of our communication channels (such as email, social media or instant messaging accounts), we collect your name, username/handle, mobile number, email address or other relevant contact information that you provide to us in the course of the interaction or communication (such as information contained in support requests, surveys, feedback, or community messages).

iii. Usage or Technical Data:

When you visit, use, or interact with the Services, the following information may be created and automatically logged on our systems:

• Device Information: The manufacturer and model, operating system, geolocation data, IP address, country/region, browser type, and unique identifiers of the device you use to access the Service. The information we collect may vary based on your device type and settings.
• Usage Information: Information about how you use our Service, such as the types of content that you view or engage with, the features you use, the actions you take, and the time, frequency, and duration of your activities.
• Support or troubleshooting reports: Anonymous crash reports and error logs.

C. Sensitive Personal Data

Do not send or disclose to us any sensitive Personal Data (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or trade union membership, health, biometrics or genetic characteristics, and criminal background) on or through the Services, or otherwise.

D. Anonymous / De-identified / Aggregate Data

Note that Personal Data does not include anonymized, de-identified, or aggregated data. We may anonymize, de-identify, and/or aggregate Personal Data so that such data will no longer constitute Personal Data. We do so to generate other data for our use, which we may use and disclose for any purpose, as it no longer identifies you or any other individual.

A. Lawfulness and Business Purposes of Processing

We may collect, use, and otherwise process Personal Data pursuant to several legal bases and for multiple business and commercial purposes in accordance with applicable law. In this regard, to the extent required by applicable law, we rely on one or more of the following legal bases to process Personal Data:

• Consent
• Contract Performance or Pre-contractual Steps (“Contract Performance”)
• Compliance with a Legal or Regulatory Obligation (“Legal Compliance”)
• Protection of the Vital Interests of an Individual
• Santa’s Legitimate Interests (or a third party’s legitimate interest(s), except where such interests are overridden by your interests or fundamental rights and freedoms, which require protection of Personal Data). Legitimate Interests may include, among others, the processing of Personal Data to the extent strictly necessary and proportionate for the purposes of (a) ensuring network and information security, (b) managing possible criminal acts or threats to public security, (c) preventing fraud, (d) processing that is relevant and appropriate to our relationship and that you could reasonably expect at the time and in the context of the collection of your data.

B. Purposes of Data Processing and Usage

We use data collected through our Services in the following ways:

• Anonymous Interaction Data: Only collected when Santa Rewards are enabled. Shared with partners and advertisers to reward users while preserving their anonymity.
• Service Improvement: We may use aggregated, anonymized data to improve Santa Browser’s functionality, performance and user experience.
• Providing Ads & Other Services: Ads and other services are available to users who enable Santa Rewards.
• Communications With You: With consent, we may use your Contact and Identification Information to send relevant updates about our Services, or to perform obligations in the course of or in connection with allowing you access or use of our Services. For instance: (a) responding to, handling, and processing queries, requests, applications, complaints, and feedback from you; or (b) managing your relationship with us.
• Legal obligations and compliance: We may process your data only when required by legal obligations or when you provide consent. For instance: (a) complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority; (b) any other purposes for which you have provided consent to the use of such information.

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.

A. We respect your privacy and do not sell or share any Personal Data with third parties unless there is a legitimate and legal basis to do so. With Rewards Enabled, only anonymized interaction data is shared with partners specifically for value generation & rewards distribution. All partners are selected based on a shared commitment to user privacy. We may also disclose your Personal Data if you request us to do so or provide your explicit consent for us to do so.

B. When users voluntarily share information with a third-party (ex: while filling out a rewarded survey or connecting your email with a gaming platform) that information is subject to the third party’s privacy policy.

C. 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 to understand their data practices.

D. We may disclose Personal Data if we believe a disclosure is reasonably necessary to (a) comply with any applicable law, regulation, legal process, or governmental request; (b) establish, exercise, or defend legal claims or to enforce applicable contracts, user agreements, or policies, including our Terms of Use; or (c) prevent, detect, and/or protect Santa, others, or the public from harm, fraud, or illegal activities, or a violation of rights.

Generally, Santa stores limited Personal Data, primarily technical and pseudonymized data on its servers. User data remains on the users’ devices. Any interaction data collected with Santa Rewards enabled is anonymized and aggregated for reward purposes.

To the extent that any Personal Data is stored by Santa, such data is securely stored on third-party servers following stringent security protocols. Santa uses commercially reasonable organizational, technical, physical, and administrative measures designed to (a) protect Personal Data from accidental or unlawful loss, alteration, destruction, theft, misuse, and unauthorized access and disclosure, and (b) ensure the confidentiality, integrity, and availability of Personal Data. We follow generally accepted industry standards and best practices to safeguard the Personal Data.

Please keep in mind that no security measures are completely effective, and we encourage you to regularly review your accounts for suspicious activity and carefully guard your credentials.

Generally, Santa collects limited Personal Data, primarily technical and pseudonymized data. With Rewards enabled, data collection is limited to anonymized interaction data, securely stored on the user’s device. Only when needed, this anonymized data is aggregated before being shared to support fair value distribution.

Opting out of Santa Rewards disables ad services entirely, ensuring a private, ad-free browsing experience.

A. We retain anonymized data as needed to provide rewards and improve functionality. Upon disabling Santa Rewards, your data is only retained on your device.

B. We retain Personal Data for as long as necessary for our legal business purposes and/or as lawfully permitted given the purpose(s) for which we obtained it and consistent with applicable law. We use the following criteria to determine our retention periods for Personal Data:

• The type(s) of Personal Data;
• Whether the Personal Data is necessary to continue to provide our Services to you (e.g., contract performance);
• Whether we have a legal or regulatory obligation to retain the Personal Data for a certain period of time;
• Whether we have Legitimate Interests to retain the Personal Data; and/or
• Whether retention is advisable considering our legal position (such as in regard to applicable statutes of limitations, litigation, or regulatory investigations).

C. Santa is committed to ensuring that your information is secure. We employ robust encryption and secure storage practices to protect your information. Although no system can be entirely secure, we actively monitor and improve our security protocols.

D. If a data breach occurs, we will take steps to investigate and notify affected users, in line with applicable data protection and privacy laws.

A. As a global company, Santa may process Personal Data in multiple countries, including the United States of America (USA). Santa may store and process your Personal Data in any country where we have facilities, affiliates or subsidiaries, or in which we engage partners or service providers. By using our Services, or otherwise interacting with us, you understand and acknowledge that we may transfer your Personal Data from your country of residence to other countries, including the USA, which may have data protection laws or rules that are different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies, or security authorities in those other countries may have legal authorization to access or request disclosure of your Personal Data.

B. We may transfer Personal Data subject to this Privacy Policy from the European Union (EU), the European Economic Area (EEA), Switzerland, the United Kingdom (UK), and/or Brazil to a third country, for the purposes described in this Privacy Policy. The European Commission, Switzerland, the UK, and/or Brazil may recognize several third countries as providing adequate levels of data protection (i.e., adequacy decisions) and allow the lawful transfer of Personal Data to such countries. To conduct lawful transfers of Personal Data to third countries without such adequacy decisions, Santa relies on appropriate safeguards, such as the European Commission’s Standard Contractual Clauses (EU SCCs), or the UK’s International Data Transfer Addendum to the EU SCCs. You may obtain a copy of these standard contractual clauses by contacting us in accordance with the “How to Contact Us” section below.

A. Privacy Rights - Global

Depending on the data protection or privacy law applicable to you and your Personal Data, you may be entitled to exercise one or more of the following rights:

• Right to Know about any processing of your Personal Data;
• Right to Access your Personal Data;
• Right to Delete or Erase your Personal Data
• Right to Correct or Rectify Inaccurate, Incomplete, or Outdated Personal Data
• Right to Data Portability
• Right to Restrict Processing of your Personal Data
• Right to Object to Processing of your Personal Data (e.g., direct marketing)
• Right to Withdraw Consent (if the lawful basis of processing is consent)
• Right to Not to Be Subject to a Decision Based Solely on Automated Processing, including Profiling, which Produces Legal Effects Concerning You or Similarly Significantly Affects You*
  *Note that Santa does not engage in such solely automated decision making.
• Right to lodge a complaint with a supervisory (data protection) authority.

B. Privacy Rights - USA

Privacy laws in the USA (i.e., “US State Privacy Laws”) may provide residents of certain US States with one or more of the following rights in relation to Personal Data:

• Right to Confirm and/or Know about any processing of your Personal Data
• Right Access your Personal Data
• Right to Delete your Personal Data
• Right to Correction of Inaccurate or Incomplete Personal Data
• Right to Data Portability
• Right to Withdraw Consent (if the lawful basis of processing is consent)
• Right to Opt Out of Profiling in furtherance of Decisions that Produce Legal or other Similarly Significant Effects Concerning You*
  *Note that Santa does not engage in this type of profiling.
• Right to Opt-out of Selling or Sharing your Personal Data
• Right to Limit use and disclosure of sensitive Personal Data
• Right to Non-discrimination if you exercise a privacy right

C. Exercising your Rights

• To exercise your rights, please contact us at [email protected]. In most cases, there may be limited Personal Data associated directly with you.
• To help us respond appropriately, please make clear the nature of your request (i.e., the privacy right(s) you would like to exercise) and the Personal Data to which it pertains. For your protection, we may only fulfill requests with respect to the Personal Data associated with the particular email address that you use to send us your request. Additionally, we must verify or authenticate your identity and may need you to provide additional information for purposes of verification or authentication before completing your request. We will try to comply with your request as soon as reasonably practicable, but always within the time period required by applicable law.
• Note that we may need to rely on a legal exception in order not to, or to partially, fulfill a privacy rights request, such as to retain certain Personal Data for legitimate business purposes, to comply with legal or regulatory obligations, to establish, exercise, or defend legal claims, and/or to perform a contract. Also, note that regulatory authorities in your country may implement laws, rules, or regulations that restrict your data protection rights.

D. We Do Not Sell Your Personal Data

Santa does not “sell” your Personal Data (as the term “sale” or “sell” is defined under the US State Privacy Laws), and we will not do so without offering you the right to opt out of any such sale.

Cookies are text files placed on your computer to collect standard Internet log information and visitor behavior information. When you visit our websites, we may collect information from you automatically through cookies or similar technology. For further information, visit allaboutcookies.org.

Santa browser does NOT collect cookies for tracking or data collection. However, please be aware that some third-party services and websites you access through the browser may employ the use of cookies. Please refer to the respective privacy policies of these third-party services for their data practices.

We periodically verify that this Privacy Policy is accurate, up-to-date, and comprehensive. We may update and revise this Privacy Policy from time to time to reflect changes in our business activities, our data processing practices, and/or changes in applicable law. If we make material changes to this Privacy Policy, we will revise this Privacy Policy’s “Last updated” date, and in some cases, we may provide you with a more prominent notice. We encourage you to review this Privacy Policy periodically to stay informed about our data processing practices.

The Services are not intended for or directed to anyone under the age of 16 years. We do not knowingly collect personal data of individuals under the age of 16. If you are younger than 16, you should not register with us or use our Services.

If a website requests your location while using Santa, you will have the option to allow or deny this request.

Santa does not share, sell, or provide information from VPN services. Any data collected by a VPN service provider falls under their privacy policies and is solely managed by them. Information collected via VPN sessions is purged at session termination.

If you have any questions about our Privacy Policy, the Personal Data we hold on you, or you would like to exercise one of your data protection rights, please do not hesitate to contact us at: [email protected]

A. Appeal a Denial of a Privacy Rights Request

You may request more information about a denial, in whole or in part, of your privacy rights request or appeal that denial by contacting us at [email protected]

B. How to Lodge a Complaint

To make a complaint about data privacy, please contact us at [email protected]. To help us address the issue effectively, please clearly state the following in your complaint:

• The specific data privacy complaint, along with as much detail as possible, including your country of residence, your understanding of the data privacy infringement and issue(s), and the redress requested;
• Your full name and how we can contact you; and
• Any previous correspondence with us on this specific data privacy issue.

We aim to resolve all issues in a timely manner and in accordance with applicable law. If there is any delay (such as where a more detailed investigation is required), we will try to keep in regular contact with you to ensure that we keep you informed of the progress on your matter.

C. Data Protection Authorities

If you are not satisfied with our resolution of your complaint, you may have the right to lodge a complaint with the competent data protection authority of your country or region where you have your habitual residence or place of work or where an alleged infringement of applicable data protection law allegedly occurs.