1. GENERAL INFORMATION
1.2 By visiting the Website and/or using the Services of TURBO4G, you agree to this Policy, any other annexes to the Policy, as well as any other documents referred to in this Policy. You may not use the Website and/or TURBO4G Services if you do not agree with the terms of this Policy.
1.3 If you do not carefully read, do not fully understand, or do not agree with this Agreement, you must immediately leave the Website and stop using TURBO4G’s Services.
1.4 This Policy applies to the people collectively referred to as “Personal Data Subjects” (hereinafter referred to as “Subjects”), namely:
1.4.1. Customer: 1) an individual who has reached the age of 18 and accepts this Agreement on their own behalf, or 2) a legal entity represented by an individual who accepts this Agreement on behalf of such a legal entity, that has placed and paid for an order intending to use the Services. The Subject becomes the Customer from the moment of placing and paying for the order in order to use the Services.
1.4.2. Visitor - an individual who visits the Website but does not use the TURBO4G Services.
1.5 You may be referred to as “you” or the “Subject” in this Agreement.
Review the terms we use in order to fully understand the text and meaning of this Agreement.
2.1 “Form “Order Form” (hereinafter - Order Form) - an online form that allows the Customer to make an order for TURBO4G’s Services on the Website and which specifies the country of proxy servers, the purpose of their use, the version of Internet protocol, number of proxy servers, rental period, as well as the method of authorization and form of payment.
2.2 “Ordering” - online order, which is carried out by filling out the “Order Form” on the Website to place an order for TURBO4G’s Services, and by subsequent payment for the order.
2.3 “Personal Account” - the Customer’s account on the Website through which the Customer can use the Services. Personal Account allows the Customer to track the expiration date of use of the Services, to renew them, to place an order for new Services.
2.4 “Personal Data” – information which are related to an identified or identifiable natural person
2.5 “TURBO4G” - SSV IT PROVIDER ONLINE SERVICES LTD with a registered address at Agias Faneromenis, 143-145 PATSIAS COURT, Flat/Office 201, Larnaca, Cyprus, 6031, whose services are available on the Website.
2.6 “TURBO4G’s Services” or “Services” - provision of the sole access to the Services, which become available to the Customer in the Personal Account within 24 (twenty-four) hours from the moment of the Ordering and paying for the Services.
3. THE SUBJECT OF THE AGREEMENT
You, as the Subject, grant Us the right to receive, store, process, use and disclose Your Personal Data for the primary purpose of enabling the use of the Website and Services.
3.1 This Policy defines how the TURBO4G can obtain, store, process, use and disclose Personal Data provided by the Subject while using the Website and/or Service.
3.2 By using any part of the Website and/or Service, the Subject grants TURBO4G the right to receive, store, process, use and disclose the Subject's Personal Data in accordance with the terms of this Policy.
3.3 The purpose of obtaining, storing, processing and using the Personal Data of the Subject is to provide them the opportunity to use the Site and / or Services, as well as to protect the rights and legitimate interests of the Subjects of Personal Data prescribed by law.
3.4 SSV IT PROVIDER ONLINE SERVICES LTD with a registered address at Agias Faneromenis, 143-145 PATSIAS COURT, Flat/Office 201, Larnaca, Cyprus, 6031, will be the controller of your Personal Data.
4. PRINCIPLES OF DATA PROCESSING
We follow all necessary principles to protect your Personal Data.
4.1 According to the current legislation of Cyprus and Art. 5 of the EU General Data Protection Regulation (GDPR), we adhere to the following principles to protect your privacy:
4.1.1 Principle of lawfulness, fairness, and transparency - we process Personal data lawfully, fairly, and transparently concerning the data subject.
4.1.2 Principle of purpose limitation - we collected personal data for specified, explicit, and legitimate purposes and not further processed in a manner that is incompatible with those purposes.
4.1.3 Principle of data minimization - we collect adequate personal data, relevant and limited to what is necessary concerning the purposes for which we are processed personal data.
4.1.4 Principle of data accuracy - we accurate personal data and, where necessary, keep up to date. We take every reasonable step to ensure that inaccurate personal data, having regard to the purposes for which they are processed, are erased or rectified without delay.
4.1.5 Principle of storage limitation - we keep personal data in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed.
4.1.6 Principle of integrity and confidentiality - we process personal data in a manner that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and accidental loss, destruction, or damage, using appropriate technical or organizational measures.
5. PERSONAL DATA THAT WE COLLECT AND PROCESS
To fulfill our obligations to provide you with the opportunity to use the Website and Services, we may ask you to provide Us with your Personal Data.
5.1 Visitors. TURBO4G may collect record and analyze information of Visitors of our Website.
5.1.1. We collect the email address only when the Visitor wants to contact us in order to use our Services. For that the Visitor uses the online chat of the TURBO4G support service on the Website (hereinafter referred to as the “Online Chat” and the “Support Service”) and/or writes to the e-mail address of the Support Service.
We use the collected Personal Data only to communicate with you. If you don’t want us to collect your Personal Data, please do not use our Online Chat and/or don’t contact our Support Service.
5.1.3. While processing Personal Data of our Visitors, we rely on your consent to the processing of your Personal Data for the purpose of communicating with you. We use such Personal Data in ways you would reasonably expect and which have a minimal privacy impact. You can withdraw your consent at any time by sending us an email to [email protected] with your withdrawal request and your Personal Data will be deleted within seventy-two (72) hours.
5.1.4. If you contact us via Online Chat on our Website, we may record your request and our reply in order to increase the efficiency of the organisation of our Support Service. We keep personally identifiable information associated with your message, such as your name and email (if you provided such data to us), so as to be able to track our communications with you in order to provide you with high quality service.
5.1.5. We also record Usage Data. It is information collected automatically through our Website (or third-party services employed by TURBO4G), which may include:
- the IP addresses or domain names of the computers utilized by the Visitors who use the Website;
- the URI addresses (Uniform Resource Identifier);
- the time of the request;
- the method utilized to submit the request to the server;
- the size of the file received in response;
- the numerical code indicating the status of the server’s answer (successful outcome, error, etc.);
- the country of origin;
- the features of the browser and the operating system utilized by the Visitor;
- the various time details per visit (e.g., the time spent on each page) and the details about the path followed with special reference to the sequence of pages visited; and
- other parameters about the device operating system and/or the Visitors’ IT environment.
5.1.6. We use this information in aggregate to assess the popularity of the web pages on our Website and how we perform in providing content to you. When combined with other information we know about you from previous visits, the data could possibly be used to identify you personally, even if you are not signed into our Website. We use Google Analytics, Google Tag Manager and LinkedIn Analytics to analyze data. Information collected this way is stored for no longer than one year.
5.1.7. Processing of Usage Data is relied on our legitimate interests. It is necessary for managing and running our business efficiently and effectively, providing quality services including website support, developing and improving products, determining who may be interested in them.
5.1.8. Wherever possible, we aim to obtain your explicit consent to process your Personal Data.
5.2 Customers. In order to provide services to our Customers, we collect their personally identifiable information.
5.2.2 During the creation of your account on our Website, you provide us with your email address. This information is used by us to identify our Customers and provide you with services, billing, mailings, notification and support.
5.2.3 We may verify your identity by asking you to submit scan copies of your documents. We process this information on the basis there is a contract between us, and our legitimate interests (prevention of fraud and infringements of intellectual property rights). We use such information to identify our Customers, prevent and detect improper use of intellectual property objects available on the Website, respond to any Customer complaints and comply with any laws and regulations that apply to us. We use such data in ways you would reasonably expect and which have a minimal privacy impact.
5.2.4 We may obtain your Personal Data from third parties such as payment service providers, whose services we use. We may receive your name, telephone number and shortened payment information (4 last digits of your card number).
5.2.5 We process this information on the basis there is a contract between us, or that you have requested we use the information before we enter into a legal contract.
5.2.6 Payment information is never taken by us or transferred to us either through our Website or otherwise. At the point of payment, you are transferred to a secure page on the website of the payment service provider.
5.2.7 Processing of Personal Data for marketing purposes is also relied on the consent obtained from you. We use data in ways you would reasonably expect and which have a minimal privacy impact.
5.2.8 We may store your Personal and other data to the extent and for the period necessary to achieve the purpose specified in this Policy, or within the time limits established by the current legislation of the Republic of Cyprus, international law or the legislation of the country of your residence, or until the moment you request the deletion of this data.
5.2.9 In case your Personal Data is changed, you must provide us with updated data by making appropriate changes to the Personal Account on the Website. If you fail to comply with this requirement, TURBO4G shall not be liable for the adverse consequences associated with the processing of such Personal Data.
6. LAWFUL BASIS OF DATA PROCESSING
We process your Personal Data in accordance with the current legislation of the Republic of Cyprus, the rules applicable to you and the generally recognized principles and norms of international law.
6.1 The personal data of the Subjects are processed in accordance with the generally recognized norms of international law, the laws of the Republic of Cyprus, as well as the norms applicable to you, including but not limited to:
6.1.1 If you are located in the European Union (EU) privacy rights are granted and all processing of Personal Data is performed by regulations and rules following the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons concerning the processing of Personal Data and on the free movement of such data, known as the General Data Protection Regulation (“GDPR”).
6.1.2 If you are located in the United Kingdom, all processing of Personal Data is performed in accordance with regulations and rules following the Data Protection Act 2018 (“DPA 2018”) and UK General Data Protection Regulation (“UK GDPR”).
6.1.3 If you are located in Australia, all processing of Personal Data is performed in accordance with regulations and rules following the Privacy Act 1988.
6.1.4 If you are located in Canada, all processing of Personal Data is performed in accordance with regulations and rules following Personal Information Protection and Electronic Documents Act (S.C. 2000, c. 5) (“PIPEDA”).
6.1.5 If you are located in New Zealand, all processing of Personal Data is performed in accordance with regulations and rules following Privacy Act 2020.
6.1.6 If you are located in California, all processing of Personal Data is performed in accordance with regulations and rules following the California Consumer Privacy Act, Cal. Civ. Code § 1798.100 et seq. (“CCPA”).
6.1.7 If you are located in Brazilia, all processing of Personal Data is performed in accordance with regulations and rules following the Lei Geral de Proteção de Dados (“LGPD”).
6.2 Children’s Online Privacy Protection Act («COPPA») applies to the online collection of personal information by persons or entities under U.S. jurisdiction about children under 13 years of age, including children outside the U.S. (affected person). Data Subjects need to obtain parental consent before providing Personal Data on the Site. If you are a parent or a guardian of a COPPA affected person, you may consent to the collection and use of your COPPA affected person's information. You may withdraw your consent, review your COPPA Personal Data of your subject, ask for it to be deleted and/or not to allow further collection or use of your COPPA data subject at any time by contacting us at: [email protected].
6.3 We process Personal Data as an Operator as specified in Art. 4 GDPR.
7. THE PURPOSE OF DATA PROCESSING
We receive, store, process and use the Personal Data of the Subjects in order to provide you with the opportunity to use the Website and our Services.
7.1 We may use the data collected from you for a variety of purposes, primarily, relating to providing our Services and information about our Services. We may also use the information for such other purposes as otherwise allowed by law. We may use your personal data for such purposes, including, but not limited to:
7.1.1 to provide access to our Website and the Services;
7.1.2 to handle your orders and requests, including requests for technical support and assistance;
7.1.3 to properly fulfill tax-related and accounting obligations imposed by applicable laws;
7.1.5 to personalize your experience with our Service;
7.1.6 to processing payments;
7.1.7 to contact you concerning, and conduct, surveys or polls you choose to take part in and to analyze the data collected for market research purposes;
7.1.8 to conduct internal research and development and to improve, test, and enhance the features and functions of our Service;
7.1.9 meet our internal and external audit requirements, including our information security obligations;
7.1.10 tracking purchases and usage data;
7.1.11 any other purpose as we determine, in our sole discretion, to be necessary or required to ensure the safety and/or integrity of our users, employees, third parties, public, and/or our Services,
7.1.12 or to comply with requirements of any applicable law.
8. CONSENT TO PERSONAL DATA PROCESSING
We obtain your consent before personal data processing
8.1 Consent to Personal Data Processing
8.2 EU Persons Consent to Personal Data processing
8.2.1 If you are an EU Person and to process your Personal Data We need to receive your consent, as it is prescribed by GDPR, We will process your Personal Data only in the case We have received from you a freely given, specific, informed, and unambiguous indication of your wishes by which you signify agreement to the processing of your Personal Data (“Consent”).
8.2.2 You may give your consent by ticking the respective box when you register for an account with our Service. In the case you tick the respective box, you irrevocably and unconditionally consent and agree that We shall be entitled to process your Personal Data as it is indicated by your Consent.
8.2.3Your Consent covers all processing activities with your Personal Data carried out for the same purpose or purposes. When the processing has multiple purposes, your Consent should be deemed given for all of them.
8.3 Non-EU Persons Consent to Personal Data processing
8.3.1 If you are not an EU Person, by transferring to Us your Personal Data via the Software or otherwise, you irrevocably and unconditionally consent and agree that We shall be entitled, in accordance with this Policy:
- to process in any manner, including to collect, store, use, disclose, share and transfer (including cross-border), your Personal Data so provided to Us, as well as your Personal Data collected from your use of the Service (i.e. your Personal Data which We collect automatically and/or from other sources); and
9. THE RIGHTS OF SUBJECTS
Please read this chapter carefully. To exercise any of the above-mentioned rights, You should primarily send a request to our Support Service. We may request additional information necessary to confirm your identity. We may reject requests that are unreasonably repetitive, excessive, or manifestly unfounded.
9.1 Right to access. You may contact us to get confirmation as to whether or not we are processing your personal data. When we process your personal data, we will inform You of what categories of personal data we process regarding You, the processing purposes, the categories of recipients to whom personal data have been or will be disclosed, and the envisaged storage period or criteria to determine that period.
9.2 Right to withdraw consent. In case our processing is based on the consent granted, You may withdraw the consent at any time by contacting us or by using the functionalities of the Website. You can withdraw your consent at any time by replying to the email with your withdrawal and your Personal Data will be deleted immediately. Withdrawing consent may lead to fewer possibilities to use the Website and/or the Services
9.3 Right to object. In case our processing is based on a legitimate interest to run, maintain and develop our business, You have the right to object at any time to our processing. We shall then no longer process your personal data unless for the provision of our services or if we demonstrate other compelling legitimate grounds for our processing that override your interests, rights, and freedoms or for legal claims. Notwithstanding any consent granted beforehand for direct marketing purposes, You have the right to prohibit us from using personal data for direct marketing purposes, by contacting us or by using the functionalities of the Website, or unsubscribe possibilities in connection with our direct marketing messages.
9.4 Right to restriction of the processing. You have the right to obtain from us restriction of processing of your personal data, as foreseen by applicable data protection law, e.g. to allow our verification of the accuracy of personal data after you contest the accuracy or to prevent us from erasing personal data when personal data are no longer necessary for the purposes but still required for your legal claims or when our processing is unlawful. Restriction of processing may lead to fewer possibilities to use the Website and/or the Services.
9.5 Right to data portability. You have the right to receive your personal data from us in a structured, commonly used, and machine-readable format and to independently transmit those data to a third party, in case our processing is based on your consent and carried out by automated means.
10. DATA STORING AND DELETION
We store your Personal Data for as long as needed to provide you with our Service and/or opportunity to use our Website.
10.1 We store your Personal Data for as long as needed to provide you with our Service and/or opportunity to use our Website. We may store Data longer, but only in a way that it cannot be tracked back to you. When Personal Data is no longer needed, we delete it using reasonable measures to protect the Data from unauthorized access or use.
10.4 Storing might be different depending on the territory of collecting the information and the applicable legislation, but We always strive to store the information only as long as it is needed to provide, improve, or personalize our Service.
10.5 We do not intentionally collect or maintain information from persons under the age of 13. If we become aware that we have unknowingly collected personally identifiable information from a child under the age of 13, we will make reasonable efforts to delete such information from our records. If you believe that we may have any information about children under the age of 13, please contact our Support Service [email protected].
11. DATA SECURITY
We care to ensure the security of Personal Data.
11.1 We follow generally accepted industry standards to protect the information submitted to Us, both during transmission and once We receive it. We maintain technical, physical, and administrative security measures to provide reasonable protection for your Personal Data. When We or our contractors process your information, We also make sure that your information is protected from unauthorized access, loss, manipulation, falsification, destruction, or unauthorized disclosure. This is done through appropriate administrative, technical, and physical measures.
11.2 You agree that there is no 100% secure method of transmission over the Internet or method of electronic storage. Therefore, We cannot guarantee its absolute security.
11.3 We never process any kind of sensitive data such as personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, genetic data, biometric data processed solely to identify a human being, health-related data, data concerning a person’s sex life or sexual orientation, criminal offense data.
We work with third-party services providers, who provide website, application development, hosting, maintenance, and other services for us. All data transfers are performed in accordance with the highest security regulations.
12.1 We work with third-party services providers, who provide website, application development, hosting, maintenance, and other services for us. They may be located outside of the EEA. These contractors may have access to, or process Personal Data on behalf of Us as part of providing those services for Us. We limit the information provided to these Service providers to that which is reasonably necessary for them to perform their functions.
12.2 All data transfers are performed in accordance with the highest security regulations. Transfer of Personal Data to countries outside of the European Union may be possible only in the case when We have obtained your consent for it.
12.3 All data processed by Us is stored exclusively in secure hosting facilities located in the EU.
12.5 We may share your personal data with our insurers, our professional advisors (lawyers, bankers, auditors, corporate financiers, and brokers) in connection with the services they provide to us. If we share your personal data with those processors, we will require the recipient to keep it confidential and secure. To provide you (or your organization) with our services, we may provide personal data to the courts, to lawyers advising the other parties to a matter, or other professionals (such as overseas law firms, patent agents, forensic accountants, or barristers).
13. OTHER PROVISIONS
Check out our other provisions to make sure you don't miss anything. If you have any questions, write to our Support Service, we will be happy to answer.
13.3.1 The Policy may be amended or supplemented by us at any time without notifying you. The new version of the Policy comes into force from the moment it becomes available on the Website.
13.3.2 If you continue to use the Website and/or the Services after such amendments and/or supplements to the Policy, you automatically accept them and agree with such amendments and/or supplements.
13.4 Limitation of Liability. We are not responsible for harm or damage suffered by you and / or a third party as a result of an erroneous understanding or misunderstanding of the terms of this Policy. Before accepting the terms of this Policy, any Subject has the right to contact TURBO4G for clarification regarding the provisions of the Policy.
13.5 Severability. If any provision of this Policy is held by a court of competent jurisdiction to be contrary to law, the provision will be deemed null and void, and the remaining provisions of this Agreement will remain in effect.
13.6 Jurisdiction and Disputes Resolution
13.6.1 This Policy, the rights and remedies provided for in this Policy, any claims and disputes related to it and/or TURBO4G, its interpretation or violation, termination or validity, relations arising out of or pursuant to the Policy shall be governed, construed, and interpreted in accordance with the laws of Cyprus. The personal data of the Subjects shall be stored and processed in accordance with the law applicable to such Subjects.
13.6.2 All disputes or disagreements between the parties regarding the execution of the Policy shall be resolved through negotiations. If the Parties do not reach an agreement within 30 (thirty) days, the dispute may be referred to the court at the location of SSV IT PROVIDER ONLINE SERVICES LTD.
13.7 Our details:
E-mail: [email protected]