This Policy explains how Surfshark B.V., address: Kabelweg 57, 1014BA Amsterdam, the Netherlands ('Surfshark', 'we') processes your personal data. This Policy applies to our use of any and all Data collected by us in relation to your use of the Web Site and any Services or Systems therein.
In this Policy the following terms shall have the following meanings:
"Account": means collectively the personal information, Payment Information and credentials used by Users to access Paid Content and / or any communications System on the Website;
"Content": means any text, graphics, images, audio, video, software, data compilations and any other form of information capable of being stored in a computer that appears on or forms part of this Website;
"Cookie": means a small text file placed on your computer when you visit certain parts of this Web Site. This allows us to identify recurring visitors and to analyse their browsing habits within the Website.
"Data": means collectively all information that you submit to the Website. This includes, but is not limited to, Account details and information submitted using any of our Services or Systems;
"EU GDPR": means Regulation (EU) 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data.
"Services": means the services available to you through this Website, specifically use of the Surfshark B.V. proprietary e-learning platform;
"System": means any online communications infrastructure that Surfshark B.V. makes available through the Website either now or in the future. This includes, but is not limited to, web-based email, message boards, live chat facilities and email links;
"User" / "Users": means any third party that accesses the Website and / or Services;
"Website": means the website that you are currently using (https://learning.surfshark.com/) and any sub-domains of this site unless expressly excluded by their own terms and conditions.
Without limitation, any of the following Data may be collected:
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2.1 name;
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2.2 date of birth;
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2.3 job title & profession;
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2.4 contact information such as email addresses and telephone numbers;
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2.5 demographic information such as post code, preferences and interests;
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2.6 financial information such as credit / debit card numbers;
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2.7 IP address (automatically collected);
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2.8 web browser type and version (automatically collected);
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2.9 operating system (automatically collected);
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2.10 a list of URLS starting with a referring site, your activity on this Web Site, and the site you exit to (automatically collected); and
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2.11 Cookie information (see Clause 10 below).
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3.1 Any personal Data you submit will be retained by Surfshark for as long as you use the Services and Systems provided on the Web Site. Data that you may submit through any communications System that we may provide may be retained for a longer period of up to one year.
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3.2 Unless we are obliged or permitted by law to do so, and subject to Clause 4, your Data will not be disclosed to third parties.
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3.3 All personal Data is stored securely in accordance with the principles of the EU GDPR. For more details on security, see Clause 9 below.
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3.4 Any or all of the above Data may be required by us from time to time in order to provide you with the best possible service and experience when using our Web Site. Specifically, Data may be used by us for the following reasons:
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3.4.1 internal record keeping;
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3.4.2 improvement of our products / services;
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3.4.3 transmission by email of promotional materials that may be of interest to you;
We may, from time to time, employ the services of other parties for dealing with matters that may include, but are not limited to, payment handling, advertising and marketing. The providers of such services do not have access to certain personal Data provided by Users of this Web Site. Any Data used by such parties is used only to the extent required by them to perform the services that we request. Furthermore, any Data that is processed by third parties must be processed within the terms of this Policy and in accordance with the EU GDPR.
Data security is of great importance to us and to protect your Data we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the Data.
Surfshark reserves the right to change this Privacy Policy as we may deem necessary from time to time or as may be required by law. Any changes will be immediately posted on the Web Site and you are deemed to have accepted the terms of the Policy on your first use of the Web Site following the alterations.
If there are any questions regarding this privacy policy you may contact us via this link: https://support.surfshark.com/hc/en-us.
