Privacy policy

Last updated 13 April 2018

This document (hereinafter – the “Privacy Policy”) explains privacy rules applicable to all information collected or submitted when you access, install or use the SurfShark Services.

You have legitimate concerns about privacy and therefore we expressly describe all processing of private data done by us. We want you to understand what limited information we collect and what may happen to that information when you use any of the SurfShark Services.

Our top priority is customer data security. Operating under the jurisdiction of British Virgin Islands allows us to guarantee our no logs policy. We process only minimal user data, only as much as it is absolutely necessary to maintain our services.

All definitions and capitalized words used in this Privacy Policy are defined in our Terms of Service.

By submitting your personal data to SurfShark, by accepting the SurfShark application’s access to your personal data on Apple iTunes/App Store and/or Google Play, also by accessing, installing and/or using the SurfShark Services you confirm that you have read this Privacy Policy and that you enter into legally binding relationship with SurfShark (hereinafter – „SurfShark“, „we“ or “us”), as well as you agree to be bound by this Privacy Policy. If you disagree with the rules of this Privacy Policy, please do not use the SurfShark Services.

If you have any questions about this Privacy Policy or your privacy, please contact us by email [email protected]

Processing of your data

SurfShark processes user data only to a very limited scope – only as much as it is absolutely required for provision of the SurfShark Services, processing of payments for the SurfShark Services, as well as functioning of the SurfShark website and mobile applications.

SurfShark guarantees a strict no-logs policy for SurfShark services, meaning that your activities using SurfShark Services are provided by automated technical process, are not monitored, recorded, logged, stored or passed to any third party. We do not store connection time stamps, session information, used bandwidth, traffic logs, IP addresses or other data. From the moment a SurfShark.com user connects to a SurfShark server, their Internet data becomes encrypted. Any online traffic coming from user’s device is no longer visible to ISP, third-party snooper or cyber criminals. Further, SurfShark have a strict no logs policy when it comes to seeing user activity online: SurfShark is based in British Virgin Islands, which does not require data storage or reporting, SurfShark is empowered to deny any third party requests.

Anyone may browse our website, install SurfShark application and mobile applications without signing up for the SurfShark Services, however the functionality of the SurfShark Services will be very limited or absent. If you want to engage full functionality of the SurfShark Services, you need to create a user account and provide basic personal data indicated below.

If you choose to create a user account, you must provide the following basic information:

E-mail address. We ask for your e-mail address and password as part of your registration. That ensures that we can communicate with you when we have announcements to make, service updates to advise or errors to report. Valid email address is also needed to retrieve a lost password.

Payment data. You can use payment methods, such as PayPal or credit card. Our payment processing partners collectbasic billing information for payment processing and refund requests.

You must maintain and update this information current, truthful, complete and accurate. You warrant that you are authorized to provide such information. You authorize us to verify your information at any time. If it is found to be untrue, inaccurate, not current or incomplete, we retain the right, in our sole discretion, to suspend or terminate your user account and your access to the SurfShark Services.

In order to maintain the VPN service, the SurfShark also processes limited technical information, which sometimes may be considered personal data, such as the website performance data, server load, webpage accessed, average time spent on it, etc. This information is used for improving the functionality and usability of our website and SurfShark Services. If you decide not to provide this limited information, we will not be able to provide you the SurfShark Services. Said information may also include:

Server load information. We monitor the server performance in order to recommend the most suitable servers to our customers.

Customer service information. SurfShark.com stores inquiries and communications with users through the Contact Us and Community Area pages, unless a user requests to delete the conversation.

Cookies. SurfShark.com uses a few different cookies to improve the user experience on the website:

  • SurfShark.com uses Google Analytics and Optimizely.com cookies for statistical assessment and website performance improvement.
  • We use affiliate and refer-a- friend cookies to identify the customers referred to the Site by our partners/customers, so that we can grant the referrers with commissions.
  • SurfShark.com uses cookies to personalize the content of the Site for users, such as setting the default language.
  • Surfshark.com uses also other cookies, such as Google AdWords, Hotjar, Google Tag manager, which are used to provide better Services to you.

Personal data is processed by SurfShark automatically and manually. Unless expressly noted otherwise, SurfShark or a designated subsidiary in your country shall act as the responsible personal data controller for any data processed. SurfShark uses third party data processors only for processing of payment data, and basic website analytics.

Personal data of underage persons

Persons younger than 18 shall not use the SurfShark Services and provide any personal data to us without the supervision of the parents or guardians. SurfShark shall never knowingly collect personal information from persons younger than 18 and shall not disclose such personal data to third parties without the consent. Based on the above, it is presumed that any person using the SurfShark Services and supplying personal data to us is at least 18 years of age. If a person younger than 18 years old or a person, supplying wrongful data, become known to SurfShark, such person and all their data may be immediately and without any notice withdrawn by suspending their access to SurfShark Services.

Grounds for data processing

Your personal data is processed for the purpose of providing you the best SurfShark services and performance of the contact between you and SurfShark, as provided in our Terms of Service.

SurfShark may use your personal data for direct marketing purposes without separate consent, only as permitted by applicable law.

Your personal data protection rights

You may request us to find out what information we have collected about you, and to request any changes or correction of inaccurate information.

If you disagree with your data processing by SurfShark, you are free not to use the SurfShark Service, and to discontinue using it at any time. You may request us to discontinue processing of your personal data, in which case your data will be processed only as much as it is necessary to effect the discontinuation of your use of the SurfShark Services (e.g., final settlement, or deleting all personal data), or finalizing other SurfShark’s legal relationship with you (e.g. accounting, invoicing, processing refunds).

Due to technical reasons (such as backup copies of the databases) your personal data may be finally deleted only within 60 days or longer, if it is mandated by the statutory requirements.

If you wish to use the SurfShark Services again, you will have to accept and agree to this Privacy Policy
anew.

Term for storing personal data

SurfShark stores limited personal data for the whole period when the SurfShark Services are used and for no longer than 2 years after last use of the App and/or the Services.

Other Terms

Your data is processed under the jurisdiction of British Virgin Islands. If the data is processed by a designated subsidiary in your country, then the domestic law of your country may be applicable at our discretion.

SurfShark would like to remind you that you are yourself responsible for the security of your data. We ask you to be careful when using and storing personal data containing files on your devices, as well as the devices itself. Please ensure that nobody accesses and uses your devices without your consent.

You shall be extra careful and not disclose your personal information to unrelated third parties, since such information may be used in different ways and against your interests, including activities such as fraud, invasion of privacy, identity theft, etc.

In order to ensure security of the personal data, SurfShark employs various administrative, technical and physical security measures, however it is your responsibility to exercise caution and reason when using the SurfShark Services. You will be personally responsible if such action violates any third party’s privacy or any other rights, or any applicable law. Under no circumstances, SurfShark is liable for the consequences of your unlawful activities, your willful and negligent activities violating applicable laws or third party rights, as well as any circumstances, which may not have been reasonably controlled or foreseen.

This Privacy Policy may be modified and updated at any time, at our sole discretion, for any or no reason, and without liability, as indicated below. The date of the most current wording of the Privacy Policy is indicated at the top of the text. We ask all users to ensure that they are familiar with the most current wording of the Privacy Policy. The amendment of the Privacy Policy may be communicated to you by sending an email and/or by publishing the updated Privacy Policy on the SurfShark website. Please consider reviewing the Privacy Policy each time you use the SurfShark Services. Updates of the Privacy Policy come into force as of the moment when they are published.

You may not assign or transfer your rights or obligations under this Privacy Policy to any third party.

The section titles in the Privacy Policy are for convenience only and have no legal or contractual effect.