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principle 1 – accountability
principle 2 – ıdentifying purposes
when you become a user of the service, surfeasy collects, as consideration for your right to use the service, your personal information for the following purposes:
• to compile anonymized and/or aggregated statistics on user behavior and location for study by surfeasy and its customer and/or distribution partners;
• to ensure security, reliability, and quality of service and to avoid any tampering, damages, and/or misuse of our networks, services or website;
• to provide and improve the ongoing service;
• to communicate with you;
• to comply with legal requirements;
• to protect you and surfeasy from error and fraud; and
• for limited marketing purposes.
ıf you access the service via surfeasy’s opera vpn mobile software application, the following also applies:
principle 3 – consent
principle 4 – limiting collection
surfeasy will only collect personal information needed for it to properly conduct its business and only collect it by fair and lawful means. ınformation collected about you via the service may include:
• usage data, like web addresses (but not content of the web pages) and ıp address locations;
• a randomly generated identifier used by surfeasy;
• device type;
• browser type;
• operating system type;
• ıp address with date and time; and
• any other information that you may share with surfeasy through communications with surfeasy via email, telephone, and/or any letters. there may be certain other information that surfeasy may collect in connection with the service for which surfeasy will seek your consent prior to doing so.
principle 5 – limiting use, disclosure, and retention
surfeasy is committed to a high standard of confidentiality and privacy. surfeasy will only use and/or disclose your personal information for the reason(s) it was collected. ın general, surfeasy will not share any of your personal information except for the purpose of fulfilling the service requested, and may share specific personal information with third party service providers engaged to assist us in providing the service requested. these service providers are prohibited from using your personal information for any purpose other than to provide this assistance, and they are required to protect all personal information and comply with the general privacy principles described in this policy. surfeasy may share, sell, and/or distirbute anonymized aggregated usage data with third parties.
principle 6 – accuracy
surfeasy is committed to maintaining the accuracy of your personal information and ensuring that it is complete and up-to-date. ın most cases surfeasy collects your personal information directly from you. ıf you discover inaccuracies in surfeasy’s data, please notify surfeasy to make the necessary changes.
principle 7 – safeguards
your personal information is secure within surfeasy, regardless of the format in which it is held, transmitted, or processed. surfeasy has implemented security controls to protect against unauthorized use, access, alteration, duplication, destruction, disclosure, loss or theft of your personal information. surfeasy maintains physical, electronic and procedural safeguards to protect your personal information. examples of safeguards include restricted access to our information processing and storage areas, limited access to relevant information by authorized persons only, use of passwords, firewall technology, encryption of electronically transmitted information, antivirus software and the use of physical security measures, including secure locks on filing cabinets and doors. surfeasy is also committed to working with you to protect the security of personal information during any transfer to surfeasy. additionally, surfeasy has agreements and controls in place with third party service providers requiring that any information provided to surfeasy be transmitted and safeguarded with the industry’s highest technological security standards in mind.
the privacy officer will conduct periodic reviews of various surfeasy practices to determine compliance with this policy. the privacy officer will make all recommendations necessary to ensure compliance and determine whether any revisions to this policy are required in light of new practices, processes, technologies or other changes.
principle 8 – openness
surfeasy will disclose to you this policy and make information available concerning the policies and practices that apply to the management of your personal information.
principle 9 – ındividual access
ın the course of interacting with surfeasy, you are welcome to review or verify your personal information. surfeasy may need specific information from you to enable surfeasy to search for, and provide you with, the personal information surfeasy holds about you. please note that access to your personal information is in accordance with surfeasy’s retention and access policy.
principle 10 – challenging compliance
any concerns regarding surfeasy’s compliance with this policy can be reported in writing to the surfeasy privacy officer at the address set forth in principle 1. ıf you have concerns about how surfeasy handles your personal information, please note that you may always contact the independent oversight body:
office of the privacy commissioner of canada
place de ville
112 kent street
ottawa, ontario k1a 1h3