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By adding this extension to Chrome, you can browse the web from any of our locations, free.Please contact us or see our Privacy Policy for more info

Privacy Policy

Introduction
We take your privacy very seriously. Please read this privacy policy carefully as it contains important information about who we are and how and why we collect, store, use and share your personal data. It also explains your rights in relation to your personal data and how to contact us or supervisory authorities in the event you have a complaint.Controller
Marcode Ltd (“Marcode”, “we”, “us” or “our” in this privacy policy") is the data controller and is responsible for certain personal data about you that we collect and use in order to provide our services (including both our ‘Core’ and ‘Chrome’ products) to the organisation that you represent (our Client) or where you use or browse our website.Contact us
If you have any questions about this policy or about how we handle your data, please contact our data privacy manager as follows: [email protected]You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.We keep our privacy policy under regular review. This version was last updated in January 2025.It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.Third-party links
Our website or our platforms may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website or platform, we encourage you to read the privacy policy of every website you visit.Personal data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:Representatives of ClientsIdentity Data: includes name and job title.
Contact Data: includes business address, email address and telephone numbers, organisation details, where applicable online presence such as LinkedIn profile.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
Profile Data: includes your username, orders made by you on behalf of your organisation, your interests, preferences, feedback.
Technical Data: includes your computer’s Internet Protocol (IP) address, your browser type and version, the pages you visit, the time and date of your visit, the time spent on each page, the device type, operating system, unique device identifiers, device settings, and geo-location data.
Usage Data includes information about how you use our website and products.
Browsing History Data: includes information about websites you visit, searches you conduct, and your online browsing patterns when you use our Chrome extension. This may include complete URLs and page content analysis,
Website browsersTechnical Data: includes your computer’s Internet Protocol (IP) address, your browser type and version, the pages you visit, the time and date of your visit, the time spent on each page, the device type, operating system, unique device identifiers, device settings, and geo-location data.
Usage Data: information about how you use our website, IT, communication and other systems.
Browsing History Data: as described above, when you use our Chrome extension.
We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website or platform feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.We do not collect any “Special Categories” of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.We collect and use this personal data for the purposes described in the section ‘how and why we use your personal data’ below. If you do not provide personal data we ask for, it may delay or prevent us from providing products to you or your organisation.How your personal data is collected
We collect some of this personal data directly from you in person for example by telephone, email and/or via our website or platform. However, we may also collect information from third parties including:from other representatives within your organisation (e.g. when a colleague requests you to collaborate);
from other third parties, such as marketing agencies and LinkedIn, or from entities that contract with the organisation that you represent;
from cookies on our website or platform —for more information on our use of cookies, please see our cookie policy.
through our Chrome extension, which collects browsing history data and may inject searches into your browsing history as part of its functionality for fraud detection purposes.
How and why we use your personal data
Under data protection law, we can only use your personal data if we have a lawful basis e.g.:for our legitimate interests or those of a third party;
in certain cases where you have given consent; or
to comply with our legal and regulatory obligations.
A legitimate interest is when we have a business or commercial reason to use your personal data, so long as this is not overridden by your own rights and interests.The table below explains how and why we use your personal data.What we use your personal data forLawful basisType of dataTo register your organisation as a new ClientNecessary for our legitimate interests (to operate our business)Identity, Contact, Profile, MarketingTo process your organisation’s order as a Client and deliver our products/services.Necessary for our legitimate interests (operate our business)Identity, Contact, Profile, MarketingTo manage our relationship with you and with your organisation and to develop, enhance and improve our business.Necessary for our legitimate interests (to keep our records updated and to study how Clients use our products)Identity, Contact, Profile, MarketingTo administer and protect our business and our website or platform (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)(b) Necessary to comply with a legal obligation© consent.Identity, Contact, Profile, TechnicalTo deliver relevant website content to your organisation and to carry out marketing to your organisation and to make recommendations about goods or services that may be of interest to your organisation.For our legitimate interest, i.e. to develop and grow our businessIdentity, Contact, Marketing, UsageTo use data analytics to improve our website, or platform or products, Client relationships and experiencesNecessary for our legitimate interests (to define types of Clients for our products and services, to keep our website or platform updated and relevant, to develop our business and to inform our marketing strategy)Technical, UsagePreventing and detecting fraud against you or usFor our legitimate interest, ie to minimise fraud that could be damaging for you and/or usTo comply with our legal and regulatory obligations.Identity, ContactTo detect, prevent and investigate online fraud through analysis of browsing patterns and website contentFor our legitimate interests (to protect our clients and their customers from fraud and to maintain the integrity of our services)For the legitimate interests of our clients (to protect their businesses from fraudulent activities)Identity, Contact, Technical, Usage, Browsing HistoryTo inject searches into browsing history as part of our fraud detection and safety functionalityFor our legitimate interests (to enhance our fraud detection capabilities and provide better protection for our clients)Consent (where required by applicable law)Browsing HistoryTo enforce legal rights or defend or undertake legal proceedings, or to provide information required relating to audits, enquiries or investigations by regulatory bodies.To comply with our legal and regulatory obligations;For our legitimate interests, ie to protect our business, interests and rightsto comply with our legal and regulatory obligationsIdentity, Contact, ProfileOperational reasons, such as improving efficiency, training quality control and security of our website or platform.For our legitimate interests , ie to be as efficient as we can so we can deliver the best service to you at the best priceIdentity, Contact, Technical, UsageStatistical analysis to help us manage our businessFor our legitimate interests, ie to be as efficient as we can so we can deliver the best service to you at the best priceTechnical, Usage

Marketing
We may use your personal data to send you marketing communications and updates about our products.You have the right to opt out of receiving marketing communications at any time by clicking on the unsubscribe link within our emails.We will always treat your personal data with the utmost respect and never sell it to other organisations for marketing purposes.Chrome Extension Data Collection and Use
Our Chrome extension collects and processes the following data:Browsing history and Search Terms: The URL of search result pages (including keywords) that may contain fraudulent or non-compliant advertising
Page content: Analysis of webpage content for fraud indicators
The extension may inject searches into your browsing history as part of its privacy and safety functionality. This allows our systems to better identify potentially fraudulent patterns and activities, and helps to prevent search engines and advertising networks from building an accurate profile about your search activity.This data collection is not necessary for the core functionality of the product. If you do not wish to have this data collected, you should not enable or disable the relevant privacy and safety features.Sharing Fraud Detection Results
When our systems detect potential fraudulent or non-compliant advertising activity, we may share examples of these findings with our customers and partners to help stop this activity and improve fraud detection capabilities across our network. These examples are anonymized to the extent possible, removing personal identifiers while retaining the pattern information necessary for fraud prevention.Our anonymization process includes:Removing personally identifiable information such as names, email addresses, and IP addresses
Generalizing location data
Focusing on the technical patterns of fraud rather than individual user information
This sharing is necessary for our legitimate interest in maintaining and improving our fraud detection services. This data collection is not necessary for the core functionality of the product. If you do not wish to have this data collected, you should not enable or disable the relevant privacy and safety features.Affiliate Network Data
In rare cases in order to provide our services, we may inadvertently gather information that contains personal data (for example business contact information embedded in websites that we monitor) due to our integrations with affiliate networks. This information would be stored in our central repository and could be shared with Clients if relevant to the services that we are providing to them. Our lawful basis for processing this information is ‘legitimate interests’ (in order to provide our services to our Clients).Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our website or platform may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy.Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.Who we share your personal data with
We routinely share personal data with:third parties we use to help deliver our products/services, e.g. product analytics tools such as Pendo.io;
third parties we use to help us run our business, e.g. website hosts and IT and systems administrators;
our bank.
our customers and partners, with whom we may share anonymized examples of detected fraud to prevent and mitigate fraud, and to improve overall fraud detection capabilities.
We only allow those organisations to handle your personal data if we are satisfied they take appropriate measures to protect your personal data.We or the third parties mentioned above occasionally also share personal data with:our external auditors, e.g. in relation to the audit of our accounts, in which case the recipient of the information will be bound by confidentiality obligations;
our and their professional advisors (such as lawyers and other advisors), in which case the recipient of the information will be bound by confidentiality obligations;
law enforcement agencies, courts, tribunals and regulatory bodies to comply with our legal and regulatory obligations;
other parties that have or may acquire control or ownership of our business (and our or their professional advisers) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency—usually, information will be anonymised but this may not always be possible. The recipient of any of your personal data will be bound by confidentiality obligations.
How long your personal data will be kept
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.Please contact us: [email protected] if you want further information about how long we will retain your personal data.Transferring your personal data out of the UK/EU
We do not transfer your personal data outside of the EU.Your rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please see below to find out more about these rights.You the right to:Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:If you want us to establish the data’s accuracy.
Where our use of the data is unlawful but you do not want us to erase it.
Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.If you wish to exercise any of these rights please contact [email protected]No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.Policy last updated: March 2025

Supplemental Terms of Service

Our VPN and proxy locations are provided by Proxy Seller. By using our service, you agree to the Supplemental Terms of Service below.

1. GENERAL INFORMATIONPlease read carefully our PUBLIC OFFER for further successful cooperation with us. By using the Services of the https://proxy-seller.com, you automatically confirm your informed consent to this PUBLIC OFFER.1.1 Read this PUBLIC OFFER of PROXY-SELLER (hereinafter referred to as the “Agreement”) carefully, since this Agreement applies to PROXY-SELLER’s Services available on the website located at the https://proxy-seller.com (hereinafter referred to as the “Website”).1.2 By accessing and/or using the Services, you agree to this Agreement, as well as our Return Policy, and conclude a legally binding agreement with SSV IT PROVIDER ONLINE SERVICES LTD (hereinafter referred to as “PROXY-SELLER”), regardless of whether you register your Personal Account or not.1.3 You may be referred to as “you” or the “Customer” in this Agreement.1.4 You have the right to visit the Website and/or use PROXY-SELLER’s Services only if you fully agree with this Agreement. If you use PROXY-SELLER’s Services, this means that you confirm your informed consent to this Agreement, any other appendices to this Agreement related to the use of any PROXY-SELLER’s Services, as well as any other documents referred to in this Agreement, including Return Policy.1.5 If you do not carefully read, do not fully understand, or do not agree with this Agreement or other appendices to this Agreement, you must immediately leave the Website and stop using PROXY-SELLER’s Services.1.6 By accepting this Agreement, you agree with its terms, as well as the terms of any other documents referred to herein. You accept this Agreement when (1) you check the box indicating acceptance of the Agreement at the moment of the creation of your Personal Account, or (2) you complete and confirm the Order Form that refers to this Agreement.1.7 Access to Services is prohibited for such purposes: monitoring their availability, performance or functionality, or for any other benchmarking or competitive purposes.1.8 PROXY-SELLER’s direct competitors are prohibited from accessing the Services, except with PROXY-SELLER’s prior written consent.1.9 This Agreement becomes effective between the Customer and PROXY-SELLER as of the date of the Customer’s acceptance of this Agreement.2. DEFINITIONSReview the terms we use in order to fully understand the text and meaning of this Agreement.2.1 “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.2.2 “Form “Order Form” (hereinafter - Order Form) - an online form that allows the Customer to make an order for PROXY-SELLER’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.2.3 “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 Balance” - the Customer’s Balance in his Personal Account which the Customer may refill in advance and use for the payments for the Services. In case the Customer participates in PROXY-SELLER Affiliate Program, all referral fees shall be also accumulated in his Personal Balance.2.5 “PROXY-SELLER” - SSV IT PROVIDER ONLINE SERVICES LTD with a registered address at Agias Faneromenis, 143-145 PATSIAS COURT, Flat/Office 201, Larnaca, Cyprus, 6031.2.6 “PROXY-SELLER’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.2.7 “Ordering” - online order, which is carried out by filling out the “Order Form” on the Website to place an order for PROXY-SELLER’s Services, and by subsequent payment for the order.2.8 “User” - 1) in case of an individual accepting this Agreement on their own behalf, such an individual, or 2) in case of an individual accepting this Agreement on behalf of a company or other legal entity, an individual who is authorized by such a legal entity (by Customer) to use purchased Services, and to whom the Customer has supplied a user identification and password. Users may include, for example, the Customer, employees, consultants, contractors, and agents of the Customer, as well as third parties with whom the Customer runs a business.3. THE SUBJECT OF THE AGREEMENTThis Agreement governs the PROXY-SELLER’s Services provision to the Customer.3.1 PROXY-SELLER provides the Customer with the Services in the amount and for the period specified in the applicable Order Form, and the Customer is obliged to pay for these Services and use them in accordance with this Agreement and the Terms of Use of PROXY-SELLER’s Services.4. PROVISION OF PROXY-SELLER’S SERVICESWe do our best to make it convenient for you to use our Services, therefore, we can change, update and set restrictions on the use of our Services, carry out preventive maintenance and gain access to your Personal Account without your consent.We endeavor to provide Customers with 24/7 access to the Website under normal circumstances, but we shall not be liable if, for any reason, the Services are unavailable at any time or for any period. Access to the Services may be temporarily terminated without notice due to system failure, maintenance, repair, or for reasons beyond our control.4.1 PROXY-SELLER makes the Services available to the Customer pursuant to this Agreement, namely, provides the Customer with access to the Personal Account: transfers a unique login and password that allows to get sole access to the Services of the list of proxy servers that the Customer has access to.4.2 In order to facilitate the use of the Services by the Customer, PROXY-SELLER may provide the necessary consultations on connecting to the Services and setting up the software via e-mail, telephone or PROXY-SELLER’s support chat.4.3 PROXY-SELLER uses commercially reasonable efforts to make the purchased Services available 24 hours a day, 7 days a week, except for:4.3.1. planned maintenance;4.3.2. any unavailability caused by circumstances beyond PROXY-SELLER’s reasonable control, including, for example, natural disasters, an act of government, flood, fire, earthquake, civil unrest, an act of terrorism, strike or other labour problem, inability to provide the Service due to the fault of third parties (for example, Internet service provider failure or delay or denial of service).4.4 PROXY-SELLER provides the Services in accordance with laws and governmental regulations applicable to PROXY-SELLER’s provision of its Services to its Customers generally (i.e., without regard for Customer’s particular use of the Services), and subject to Customer’s use of the Services in accordance with this Agreement and the applicable Order Form(s).4.5 PROXY-SELLER does not control the activities of the Customer related to its use of the Services, or any other matters related to any services that the Customer provides or receives.4.6 PROXY-SELLER may collect statistical data, including the number of orders and other data related to the general activity of the Customer.4.7 PROXY-SELLER creates the Customer’s Personal Account while Ordering. PROXY-SELLER may create and delete such a Personal Account in case of violation of the terms of this Agreement by the Customer and/or at the Customer’s request.4.8 PROXY-SELLER may change, modify and update the Website without the notification and consent of the Customer.4.9 PROXY-SELLER has the right to set restrictions on the use of the Services based on the type of proxy servers.4.10 PROXY-SELLER may send messages, requests, advertising, informational or other notices to Customers, including notices about the expiration of the use of PROXY-SELLER’s Services.4.11 In order to ensure the security of the Website and the use of the Services by Customers, as well as to improve the quality of the provision of such Services, PROXY-SELLER may carry out preventive maintenance, which may entail the suspension of the Website.4.12 PROXY-SELLER may return the Customer access to its Personal Account in case of hacking, loss, or change of login.4.13 The Customer acknowledges and agrees that, despite the measures taken by PROXY-SELLER, the Website may be compromised, including by hackers, Internet viruses, malware, system and software viruses, etc. Under such circumstances, PROXY-SELLER may take corrective actions it deems necessary at its sole discretion, and the Customer acknowledges and agrees that PROXY-SELLER shall not be liable to the Customer for any damage that it may suffer due to such corrective actions or compromises.4.14 PROXY-SELLER may assign its rights and/or obligations under this Agreement and/or transfer ownership of the Website to third parties without the consent of the Customer.4.15 PROXY-SELLER may, at its sole discretion, require Customers to demand an explanation of the purpose of using a PROXY-SELLER and undergo additional KYC (Know Your Customer) procedures through third-party resources such as, but not limited to, Sumsub. If you do not wish or fail to undergo the above procedures, we reserve the right to refuse your access to the Services.4.16 PROXY-SELLER has the right to refuse or cancel access to the Services, at its sole discretion.4.17 PROXY-SELLER can provide the Customer with the Services only of the proxy type and quantity that PROXY-SELLER has available at the moment of the Ordering. If PROXY-SELLER does not have the Services of quantity that were ordered and paid by the Customer, PROXY-SELLER reserves the right to offer, and the Customer is obliged to make one of the following decisions (at their own discretion):4.17.1. PROXY-SELLER may order proxy servers necessary for the provision of the Service and make them available to the Customer within the period mutually agreed by the parties;4.17.2. PROXY-SELLER may change the country of proxy servers completely or in that part that is not available;4.17.3. PROXY-SELLER can refund the money fully or partly (for that part of the proxy servers that is not available).5. USE OF PROXY-SELLER’S SERVICESPlease do not take actions that may negatively affect the Website and disrupt our operation.5.1 After the Ordering, the Customer can use PROXY-SELLER’s Services, namely:5.1.1. obtain sole access and use the Services of the list of proxy servers to which the Customer has access for the period specified in the Order Form.5.2 The Customer is obliged:5.2.1. to be responsible for Users’ compliance with this Agreement and terms of Order Forms;5.2.2. to comply with all applicable laws and any other contractual terms governing the use of PROXY-SELLER’s Services (and/or any related activities or transactions), including specific legal rules applicable to the Customer;5.2.3. not to take actions that may be considered as a violation of applicable law or international law, as well as any actions that lead or may lead to a disruption of the proper functioning of the Website;5.2.4. to be personally liable for the use of the Services;5.2.5. to be responsible for the accuracy, quality and legality of the Customer’s personal data provided by Users;5.2.6. to make payments in a timely manner and in accordance with the terms of this Agreement and the applicable Order Form;5.2.7. to use commercially reasonable efforts to prevent unauthorized access to or use of the Services by third parties and notify PROXY-SELLER promptly of any such unauthorized access or use;5.2.8. to use the Services only in accordance with this Agreement, Order Forms and applicable laws and governmental regulations;5.2.9. not to take actions that could harm PROXY-SELLER or other Customers, namely:(1) modify, create derivative products, adapt, process, imitate, transfer to other resources, translate, compile, decompile, disassemble the Website (or any part thereof), any content offered by PROXY-SELLER;(2) use robots, web spiders or other automated devices, applications, scripts, algorithms, methodologies or similar processes to access, purchase, modify PROXY-SELLER or in any way reproduce or circumvent PROXY-SELLER’s navigation structure to obtain or attempt to obtain any materials, documents, services or information in ways not permitted to the Customer for general access;(3) impersonate any other person or entity;(4) use PROXY-SELLER and/or the Website to distribute spam, junk mail, fraudulent messages, phishing, chain letters, pyramid schemes, or otherwise engage in unethical marketing or promotional activities;(5) upload to the Website system and software viruses, actual or potentially harmful spyware or hacking programs, destructive or aggressive codes or components, other computer codes, files or applications designed to, or which otherwise could, intercept or destroy or limit the functionality of any computer software, hardware, system or telecommunications equipment, as well as use PROXY-SELLER to design, distribute and/or otherwise transmit or reproduce any of the foregoing;(6) access PROXY-SELLER, accounts of other Customers using any means or technologies (for example, web scraping and automatic collection of information), except through the public interface of PROXY-SELLER in a lawful way;(7) use PROXY-SELLER for benchmarking or similar competitive analysis purposes, or to create a competitive website.Any person who is not a Customer under this Agreement, and who uses the Services and/or the Website, undertakes to follow the procedure for use of PROXY-SELLER’s Services to the same extent as the Customer.5.3 Any use of the Services in breach of the foregoing by the Customer or Users that in PROXY-SELLER’s judgment threatens the security, integrity, or availability of PROXY-SELLER’s Services, may result in PROXY-SELLER’s immediate suspension of the Services, however, PROXY-SELLER will use commercially reasonable efforts under the circumstances to provide the Customer with notice and an opportunity to remedy such breach or threat prior to any such suspension, unless the actions of the Customer led to the need for immediate action on the part of PROXY-SELLER.5.4 Usage Restrictions. The Customer shall not:5.4.1. make any Service available to anyone other than Users, or use any Service for the benefit of anyone other than the Customer, unless expressly stated otherwise in the Order Form or specifically agreed between the Customer and PROXY-SELLER;5.4.2. sell, resell, license, sublicense, distribute, make available, rent or lease any Service, without PROXY-SELLER’s prior written consent;5.4.3. use the Services to store or transmit material that infringes a copyright and/or other intellectual property rights, defamatory or otherwise illegal or harmful material, or to store or transmit material that violates the privacy rights of third parties;5.4.4. use the Services to store or transmit malicious code;5.4.5. interfere with or disrupt the integrity or operation of the Services or third-party data contained therein, take action to expose the vulnerability of the Website or aimed at hacking the Website;5.4.6. attempt to gain unauthorized access to any Service or its related systems or networks;5.4.7. permit direct or indirect access to or use of any Services in a way that circumvents contractual usage restrictions, or use any Services to access or use any of PROXY-SELLER’s intellectual property except as permitted under this Agreement, the Order Form;5.4.8. modify, copy, or create derivative works based on the Service and/or the Website or any part, feature, function or user interface thereof, without PROXY-SELLER’s prior written consent;

5.4.9. frame or mirror any part of the Website and/or any Service, other than framing on the Customer’s own intranets or otherwise for its own internal business purposes, without PROXY-SELLER’s prior written consent;5.4.10. disassemble, remodel, or decompile the Service or access it to:(1) build a competitive product or service;(2) build a product or service using similar ideas, features, functions, or graphics of the Service and/or the Website;(3) copy any ideas, features, functions, or graphics of the Service and/or the Website; or(4) determine whether the Services are within the scope of any patent;5.4.11. register fictitious Personal Accounts to receive payments under the referral program;5.4.12 use the Services to:(1)download materials via torrent clients (uTorrent, BitLord, etc.);(2)distribute intellectual property of others without the knowledge of the copyright holder (video and audio files, software, games, etc.);(3)review, download or distribute pornographic content;(4)create phishing sites;(5)make brute-forcing attacks;(6)commit Internet fraud and other illegal activities.6. REGISTRATION, SECURITY, AND ACCESS TO THE PERSONAL ACCOUNTYou are solely responsible for your Personal Account. Make sure that the information about you is correct and you keep your Personal Account safe.We reserve the right to suspend or terminate the Customer’s Personal Account. Please write to [email protected] if you think that the suspension or termination of access occurred erroneously.6.1 After completing all the necessary actions for the Ordering, the Customer receives a login and password to access the Personal Account. The Customer’s login and password are sent to the e-mail specified by the Customer in the Order Form.6.2 Prior to placing the Ordering, a potential Customer can complete the registration form on the Website and create a Personal Account.6.3 Any individual or legal entity that can be a Customer or User in accordance with this Agreement can create a Personal Account.6.4 In order to create a Personal Account, the Customer must go through the registration process: create a unique login and password, provide an e-mail address.6.5 While registering a Personal Account and using PROXY-SELLER’s Services, it is necessary to provide information. It is recommended to provide valid contact details as PROXY-SELLER may use them to communicate with the Customer.6.6 A Personal Account can be created only once. If the Customer uses two or more types of Services, it continues to use the same Personal Account. Relevant information is entered into the Personal Account for all types of the Services that the Customer uses.6.7 PROXY-SELLER does not recommend posting or storing personal or confidential information in the Personal Account/on the Website and does not bear any responsibility in case of compromise, loss, or damage to any such information.6.8 PROXY-SELLER may change, suspend, terminate access to the Customer’s Personal Account or access to the Website:6.8.1. if the Customer violates the applicable law or international law;6.8.2. if PROXY-SELLER, at its own discretion, determines that the Customer has violated this Agreement;6.8.3. when the use of the Services expires;6.8.4. under other circumstances, if PROXY-SELLER deems it necessary.7. FEES AND PAYMENTPROXY-SELLER provides paid Services. Prices for the Services are determined in accordance with the tariffs available on the Website.7.1 PROXY-SELLER’s Services are paid in advance.7.2 The Customer shall pay all fees specified in Order Form(s). Except as otherwise specified herein or in the Order Form,7.2.1. fees are based on the Services purchased and not actual usage;7.2.2. payment obligations are non-cancelable and fees paid are non-refundable after 72 hours (with the exception of cases specified in Return Policy) from the Ordering;7.2.3. quantities purchased cannot be decreased after payment.7.3 Prices for the Services are indicated in USD, as well as in other currencies (conversion on the Website occurs automatically at the current rate).7.4 Payments are made by the Customer through the online banking or payment systems provided for in the Order Form, which may include credit card, Apple Pay, and any other form of payment that PROXY-SELLER makes available to the Customer from time to time.. In some cases, by prior arrangement, PROXY-SELLER may issue an invoice to the Customer. Alternatively, the Customer may use funds available in his Personal Balance.7.5 The Customer can buy and renew the Services in two ways:7.5.1. One-time payment each time. Through online banking or other payment methods made available in the Personal Account, the Customer can top up his Personal Balance in advance. The Personal Balance may be used to pay for the Services. The Customer can ask for a refund of any monies on his Personal Balance. PROXY-SELLER only utilizes the same bank information that was used to replenish the Personal Balance when returning this money to the Customer. The Customer can withdraw referral commission payments to any bank account.7.5.2. Automatic withdrawal. Customers may agree to the automatic renewal for a Service provision (auto-renewal of the Services). If You as a Customer agree to the auto-renewal of the Services, you agree that PROXY-SELLER will charge the payment method on file on the first day of each billing period for the relevant services, and if the payment method on file becomes invalid due to an expired credit card or other similar reason and PROXY-SELLER is unable to charge You as a Customer on the next billing period, PROXY-SELLER reserves the right to immediately revoke your access to any Services You as a Customer have ordered until you update your payment method. If You as a Customer fail to update your payment method within a reasonable amount of time, PROXY-SELLER may cancel your Personal Account.7.6 The Customer bears all costs for any transfers of funds, including the services of a banking institution and a financial agent.7.7 The Customer is solely responsible for the correctness of payments made by it.7.8 The Customer is responsible for providing PROXY-SELLER with complete and accurate information about the Customer’s payment details, as well as for notifying PROXY-SELLER of any changes in such information. If the Customer’s payment details change, the Customer is solely responsible for payments made using outdated details.7.9 Prices for the PROXY-SELLER’s Services may be reviewed and changed by PROXY-SELLER at its sole discretion unilaterally. New tariffs for the Services take effect from the moment they become available on the Website.7.10 PROXY-SELLER reserves the right to refund paid fees at its sole discretion in case of the Customer’s technical inability to use the Services.8. PROPRIETARY RIGHTS AND LICENSESWe are the sole owner of the Website and all of its components.8.1 Reservation of Rights. Subject to the limited rights expressly granted hereunder, PROXY-SELLER reserves all the rights, titles and interests in and to the Services, including all of their related intellectual property rights. No rights are granted to the Customer hereunder other than as expressly set forth herein.8.2 License by Customer to Use Feedback. The Customer grants to PROXY-SELLER a worldwide, perpetual, irrevocable, royalty-free license to use and incorporate into its services any suggestion, enhancement request, recommendation, correction or other feedback provided by the Customer or Users relating to the operation of PROXY-SELLERS’s Services and/or PROXY-SELLER.8.3 License by Customer to Use Name, Commercial Name, Trademarks, and Logos. The Customer grants to PROXY-SELLER a worldwide, perpetual, irrevocable, royalty-free license to place its name, commercial name, trademarks, and logos on the Website.9. RESPONSIBILITYYou are responsible for your actions, as well as for the settlement of issues relating to claims of third parties against you. We are not responsible for your obligations to third parties.9.1 PROXY-SELLER is not responsible for the Customer’s actions committed as a result of using PROXY-SELLER’s Services, including the Customer’s use of the Services in violation of applicable law or international law, violation by the Customer of its obligations to third parties, etc.9.2 PROXY-SELLER is not responsible and cannot provide any guarantees for the inconsistency of information about the geolocation of IP addresses, identified by the Customer while checking such information on other websites. Such inconsistencies may be explained by outdated databases and other reasons beyond the control of PROXY-SELLER.9.3 PROXY-SELLER is not responsible for the information published by the Customer using the Website.9.4 The Customer agrees to release PROXY-SELLER’s Website and other third-party partners from claims based on negligence on the part of other Customers and third parties.9.5 PROXY-SELLER is not responsible for the behaviour of any other Customers or third parties, as well as for the accuracy, reliability and relevance of the information they provide. PROXY-SELLER is not responsible for any claims, damages or losses related to the use of the Website by the Customer.9.6 PROXY-SELLER is not responsible for the enforcement of this Agreement by the Customer in relation to third parties. Although PROXY-SELLER encourages the Customer to report if the Customer believes that another Customer or a third party has violated this Agreement. PROXY-SELLER reserves the right to investigate and take appropriate actions at its sole discretion.10. CONFIDENTIALITYThis Agreement and the Privacy Policy governs the handling of Confidential Information.10.1 Definition of Confidential Information. “Confidential Information” means all information disclosed by a party (“Disclosing Party”) to the other party (“Receiving Party”), whether orally or in writing, that is designated as confidential or that reasonably should be understood to be confidential given the nature of the information and the circumstances of disclosure.10.1.1. Confidential Information of the Customer includes the Customer’s data.10.1.2. Confidential Information of PROXY-SELLER includes the Services and the terms and conditions of all Order Forms (including pricing).10.1.3. Confidential Information of each party includes business and marketing plans, technology and technical information, product plans and designs, and business processes disclosed by such party and the content of communications between the parties.However, Confidential Information does not include any information that:10.1.4. is or becomes generally known to the public without breach of any obligation owed to the Disclosing Party,10.1.5. was known to the Receiving Party prior to its disclosure by the Disclosing Party without breach of any obligation owed to the Disclosing Party,10.1.6. is received from a third party without breach of any obligation owed to the Disclosing Party, or10.1.7. was independently developed by the Receiving Party.For the avoidance of doubt, the non-disclosure obligations set forth in this “Confidentiality” section apply to Confidential Information exchanged between the parties in connection with the evaluation of additional PROXY-SELLER’s Services.10.2 Protection of Confidential Information. As between the parties, each party retains all ownership rights in and to its Confidential Information. The Receiving Party will use the same degree of care that it uses to protect the confidentiality of its own confidential information of like kind (but not less than reasonable care) to:10.2.1 not use any Confidential Information of the Disclosing Party for any purpose outside the scope of this Agreement;10.2.2 except as otherwise authorized by the Disclosing Party in writing, limit access to Confidential Information of the Disclosing Party to those of its employees and contractors who need that access for purposes consistent with this Agreement and who have signed confidentiality agreements with the Receiving Party containing protections not materially less protective of Confidential Information than those herein.Neither party will disclose the terms of any Order Form to any third party, legal counsel and accountants without the other party’s prior written consent, provided that a party that makes any such disclosure to its legal counsel or accountants will remain responsible for such legal counsel’s or accountant’s compliance with this “Confidentiality” section.Notwithstanding the foregoing, PROXY-SELLER may disclose the terms of any applicable Order Form to a subcontractor to the extent necessary to perform PROXY-SELLER’s obligations under this Agreement, under terms of confidentiality materially as protective as set forth herein.10.3 Compelled Disclosure. The Receiving Party may disclose Confidential Information of the Disclosing Party to the extent compelled by law to do so, provided the Receiving Party gives the Disclosing Party prior notice of the compelled disclosure (to the extent legally permitted) and reasonable assistance, at the Disclosing Party’s cost, if the Disclosing Party wishes to contest the disclosure. If the Receiving Party is compelled by law to disclose the Disclosing Party’s Confidential Information as part of a civil proceeding to which the Disclosing Party is a party, and the Disclosing Party is not contesting the disclosure, the Disclosing Party will reimburse the Receiving Party for its reasonable cost of compiling and providing secure access to that Confidential Information.11. REPRESENTATIONS AND DISCLAIMERS11.1 Representations. Each party represents that it has validly entered into this Agreement and has the legal power to do so.11.2 Disclaimers. Any Service is provided “as is”, and as available exclusive of any warranty whatsoever. Except as expressly provided herein, neither party makes any warranty of any kind, whether express, implied, statutory or otherwise, and each party specifically disclaims all implied warranties, including any implied warranty of merchantability, fitness for a particular purpose or non-infringement, to the maximum extent permitted by applicable law.12. LIMITATION OF LIABILITY12.1 Limitation of Liability. In no event shall the aggregate liability of each party arising out of or related to this Agreement exceed the total amount paid by the Customer hereunder for the Services giving rise to the liability.12.2 PROXY-SELLER shall by no means be held liable for:12.2.1. any problem, fault or error that occurs due to use of the Service in a way that does not comply with the instructions, procedures or other specifications given by PROXY-SELLER or due to breach by the Customer of any of its obligations under the Agreement,12.2.2. problems occurring due to further use of the Service in conjunction with software or hardware that is incompatible with the Customer’s operating system for which the Service has been provided,12.2.3. any loss or corruption or damage of software or data, whatever the cause and origin, if this loss or corruption or damage could have been avoided and corrected if the Customer had put in place a regular backup system,12.2.4. change or design defect in the Customer’s website used in conjunction with the Service,12.2.5. introduction of a computer virus affecting the correct operation of PROXY-SELLER’s Website,12.2.6. the intrusion of a third party into the computer system affecting the correct operation of PROXY-SELLER’s Website,12.2.7. a change in the host or hosting system,12.2.8. a network failure making PROXY-SELLER’s website inaccessible,

12.2.9. an incident concerning the Customer’s technical infrastructure. In any case, in the context of this Agreement, PROXY-SELLER’s financial liability will be limited to one hundred per cent (100%) of the payment paid by the Customer for the Service during the twelve months preceding the occurrence of the event that has generated the damage or loss, it is specified that if one or more events generated the same damage or loss, all these events would then be considered as one single event.13. TERM AND TERMINATIONWe may delete your Personal Account if you request it, if you violate this Agreement, the law, or the rights of third parties, if you cease to be the Customer.13.1 Term of the Agreement. This Agreement becomes effective when the Customer accepts this Agreement and is valid until the term for the provision of all Services under this Agreement expires or until the Services are terminated.13.2 Services Provision Term. The term for the provision of each Service is indicated in the relevant Order Form and is also displayed in the Customer’s Personal Account. Upon the expiration of the term for the provision of the Services, the Customer receives a notification from PROXY-SELLER. At any time prior to the end of the term for the provision of the Services, the Customer can choose the type and amount of the Services that it prefers to renew. The Services can be renewed through the Personal Account by creating a new order. The renewal of the Services will be according to PROXY-SELLER’s applicable list price in effect at the moment of the applicable renewal.13.3 Termination. If the Customer violates the terms of this Agreement, PROXY-SELLER may terminate this Agreement unilaterally and terminate the provision of PROXY-SELLER’s Services.13.4 Surviving Provisions. The sections and subsections titled “General Information”, “Definitions”, “Fees and Payment”, “Proprietary Rights and Licenses”, “Confidentiality”, “Responsibility”, “Disclaimers”, “Limitation of Liability”, “Term and Termination”, “Disputes and Disagreements Resolution” and “Surviving Provisions” will survive in case of any termination or expiration of this Agreement, and the parties’ obligations under section titled “Confidentiality” will survive in case of any termination or expiration of this Agreement for so long as parties retain possession of data of the other party.14. DISPUTES AND DISAGREEMENTS RESOLUTIONIf we have disputes or disagreements with you, we prefer to resolve them through negotiations. If it is not possible to resolve it peacefully, we will refer the disputes to the court at the location of SSV IT PROVIDER ONLINE SERVICES LTD.14.1 All disputes or disagreements between the parties regarding the execution of the Agreement shall be resolved through negotiations.14.2 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.14.3 The rights and remedies provided for in this Agreement, any claims and disputes related to it and/or PROXY-SELLER, its interpretation or violation, termination or validity, relations arising out of or pursuant to the Agreement or related transactions or purchases, are regulated, interpreted and performed in accordance with the laws of Cyprus.15. OTHER PROVISIONSCheck out our other provisions to make sure you don't miss anything. If you have any questions, write to our support team, we will be happy to answer.15.1 Entire Agreement and Order of Precedence. This Agreement is the entire agreement between PROXY-SELLER and the Customer regarding the Customer’s use of the Services and supersedes all prior and contemporaneous agreements, proposals or representations, written or oral, concerning its subject matter. In the event of any conflict or inconsistency among the following documents, the order of precedence shall be:(1) the applicable Order Form,(2) this Agreement.Titles and headings of sections of this Agreement are for convenience only and shall not affect the construction of any provision of this Agreement.15.2 The Agreement may be amended or supplemented by PROXY-SELLER at any time without notifying the Customer. The new version of the Agreement comes into force from the moment it becomes available on the Website.15.3 If the Customer continues to use the Website and the Services after such amendments and/or supplements to the Agreement, the Customer automatically accepts them and agrees with such amendments and/or supplements.15.4 Relationship of the Parties. The parties are independent contractors. This Agreement does not create a partnership, franchise, joint venture, agency, fiduciary or employment relationship between the parties. Each party will be solely responsible for payment of all compensation owed to its employees, as well as all employment-related taxes.15.5 Severability. If any provision of this Agreement 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.15.6 Assignment. Neither party may assign any of its rights or obligations hereunder, whether by operation of law or otherwise, without the other party’s prior written consent (not to be unreasonably withheld); provided, however, either party may assign this Agreement in its entirety (including all Order Forms), without the other party’s consent to in connection with a merger, acquisition, corporate reorganization, or sale of all or substantially all of its assets. Notwithstanding the foregoing, if the Customer is acquired by, sells substantially all of its assets to, or undergoes a change of control in favour of, a direct competitor of the other party, then such other party may terminate this Agreement upon written notice. Subject to the foregoing, this Agreement will bind and inure to the benefit of the parties, their respective successors and permitted assigns.15.7 This Agreement is made in English and it is governed, construed, and interpreted in accordance with the laws of Cyprus.15.8 If you have any questions about our Website or your interaction with this Website, please contact us. We look forward to a successful cooperation!15.9 Our details:SSV IT PROVIDER ONLINE SERVICES LTDE-mail: [email protected]Registered address: Agias Faneromenis, 143-145 PATSIAS COURT,Flat/Office 201, Larnaca, Cyprus, 6031

Terms of Service

TERMS OF SERVICE
Effective Date: March 3, 20251. ACCEPTANCE OF TERMS
By accessing or using the Free VPN Shield proxy connection service (the “Service”), whether through our website, mobile application, desktop client, or any other means, you agree to be bound by these Terms of Service (“Terms”). If you do not agree to these Terms, you must immediately cease all use of the Service. These Terms constitute a legally binding agreement between you and Marcode Ltd (“we,” “us,” or “our”).2. DESCRIPTION OF THE SERVICE
The Service provided by Marcode Ltd is a free connection gateway to a third-party Virtual Private Network or proxy service (“VPN” or “VPN service” herein). Marcode Ltd only facilitates the connection, but the actual VPN service is provided, maintained, and operated entirely by third parties. Your use of the underlying VPN is subject to the terms and conditions of the relevant third-party provider. We do not operate, control, or maintain the VPN infrastructure.3. MODIFICATIONS TO THE TERMS
3.1 We reserve the right to modify, update, or replace these Terms at any time in our sole discretion without prior notice. Any changes will be effective immediately upon posting on our website.3.2 Your continued use of the Service after any such changes constitutes your acceptance of the modified Terms. It is your responsibility to review these Terms periodically for changes.3.3 If you do not agree with the modified Terms, your sole and exclusive remedy is to discontinue using the Service.4. ELIGIBILITY AND REGISTRATION
4.1 You must be at least 18 years of age or the age of legal majority in your jurisdiction (whichever is greater) to use the Service.4.2 By using the Service, you represent and warrant that you meet all eligibility requirements and have the legal capacity to enter into these Terms.4.3 We reserve the right to refuse access to the Service to anyone at any time for any reason whatsoever, in our sole discretion.4.4 You are responsible for maintaining the confidentiality of any login credentials and are fully responsible for all activities that occur under your account.5. USE OF THE SERVICE
5.1 Permitted Use
You may use the Service only for lawful purposes and in accordance with these Terms.
You agree to provide accurate, current, and complete information when prompted and to maintain and update such information as necessary.
You may only use the Service for personal, non-commercial purposes unless explicitly authorized by us in writing.
5.2 Prohibited Conduct
You agree not to misuse the Service or help anyone else do so. This includes, but is not limited to:Using the Service for any illegal or unauthorized purpose
Engaging in any activity that violates local, state, national, or international law
Interfering with or disrupting the integrity or performance of the Service
Attempting to gain unauthorized access to any portion or feature of the Service, or any other systems or networks connected to the Service
Using the Service to transmit any viruses, worms, defects, Trojan horses, malware, or any other destructive items
Engaging in any activity that could disable, overburden, damage, or impair the Service
Circumventing, disabling, or otherwise interfering with security-related features of the Service
Harvesting or collecting email addresses or other contact information from other users
Using automated means, including spiders, robots, crawlers, or data mining tools to download data from the Service
Impersonating another person or entity or falsely stating or misrepresenting your affiliation with a person or entity
Attempting to decompile, reverse engineer, disassemble, or hack the Service
Using the Service to send unsolicited communications, promotions, or advertisements
6. THIRD-PARTY VPN SERVICE DISCLAIMER
6.1 The actual VPN service is provided by the third-party provider SSV IT PROVIDER ONLINE SERVICES LTD, registered at Agias Faneromenis, 143-145 PATSIAS COURT, Flat/Office 201, Larnaca, Cyprus, 6031 (Email: [email protected]). We do not control, endorse, or assume any responsibility for the performance, speed, security, content, privacy practices, reliability, or any other aspect of this third-party VPN service.6.2 Your use of the third-party VPN service is entirely at your own risk and subject to the third-party provider’s own terms and conditions, privacy policy, and practices. We strongly recommend that you review those terms carefully.6.3 Marcode Ltd makes no representations or warranties about the suitability, reliability, availability, or accuracy of any services provided by third parties.6.4 We expressly disclaim all responsibility for any issues, including but not limited to data breaches, service outages, traffic monitoring, or data logging that may occur through the third-party VPN service.7. NO WARRANTY AND DISCLAIMER
7.1 “As Is” and “As Available” Basis
The Service is provided on an “AS IS” and “AS AVAILABLE” basis. Marcode Ltd makes no representations or warranties of any kind, express or implied, regarding the operation, performance, or availability of the Service.7.2 Disclaimers
TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, MARCODE LTD EXPRESSLY DISCLAIMS ALL WARRANTIES AND CONDITIONS OF ANY KIND, WHETHER EXPRESS OR IMPLIED, INCLUDING, BUT NOT LIMITED TO:ANY IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, TITLE, AND NON-INFRINGEMENT
ANY WARRANTY THAT THE SERVICE WILL MEET YOUR REQUIREMENTS OR BE AVAILABLE ON AN UNINTERRUPTED, SECURE, OR ERROR-FREE BASIS
ANY WARRANTY REGARDING THE RELIABILITY, TIMELINESS, ACCURACY, OR QUALITY OF THE SERVICE
ANY WARRANTY REGARDING THE TRANSMISSION OR SECURITY OF DATA OVER THE VPN
ANY WARRANTY REGARDING THE THIRD-PARTY VPN SERVICE OR ANY OTHER THIRD-PARTY PRODUCTS OR SERVICES
ANY WARRANTY THAT THE SERVICE IS FREE FROM VIRUSES OR OTHER HARMFUL COMPONENTS
ANY WARRANTY REGARDING THE PRIVACY, SECURITY, OR SAFETY OF YOUR INFORMATION
7.3 Internet Delays and Disruptions
Marcode Ltd is not responsible for any delays, delivery failures, or other damage resulting from limitations, delays, and other problems inherent in the use of the internet and electronic communications.8. LIMITATION OF LIABILITY
8.1 TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, IN NO EVENT SHALL MARCODE LTD, ITS AFFILIATES, DIRECTORS, OFFICERS, EMPLOYEES, AGENTS, PARTNERS, OR SUPPLIERS BE LIABLE FOR ANY DIRECT, INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, PUNITIVE, OR EXEMPLARY DAMAGES, INCLUDING BUT NOT LIMITED TO DAMAGES FOR LOSS OF PROFITS, REVENUE, GOODWILL, USE, DATA, OR OTHER INTANGIBLE LOSSES, EVEN IF MARCODE LTD HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES, ARISING OUT OF OR IN CONNECTION WITH:YOUR USE OR INABILITY TO USE THE SERVICE
ANY THIRD-PARTY CONTENT OR SERVICES ACCESSED THROUGH THE SERVICE
UNAUTHORIZED ACCESS, USE, OR ALTERATION OF YOUR TRANSMISSIONS OR DATA
STATEMENTS OR CONDUCT OF ANY THIRD PARTY ON THE SERVICE
ANY ACTIONS WE TAKE OR FAIL TO TAKE AS A RESULT OF COMMUNICATIONS YOU SEND TO US
ANY TECHNICAL FAILURES OF THE SERVICE, INCLUDING BUT NOT LIMITED TO SERVER MALFUNCTIONS OR INTERNET DISRUPTIONS
ANY ACTIONS RESULTING FROM THE CONDUCT OF OTHER USERS OF THE SERVICE
8.2 THIS LIMITATION APPLIES REGARDLESS OF THE LEGAL THEORY ON WHICH THE CLAIM IS BASED, INCLUDING CONTRACT, TORT (INCLUDING NEGLIGENCE), STRICT LIABILITY, OR ANY OTHER THEORY.8.3 IN JURISDICTIONS THAT DO NOT ALLOW THE EXCLUSION OR LIMITATION OF LIABILITY FOR CONSEQUENTIAL OR INCIDENTAL DAMAGES, OUR LIABILITY SHALL BE LIMITED TO THE MAXIMUM EXTENT PERMITTED BY LAW.8.4 THE FOREGOING LIMITATIONS WILL APPLY EVEN IF ANY WARRANTY OR REMEDY PROVIDED UNDER THESE TERMS FAILS OF ITS ESSENTIAL PURPOSE.9. INDEMNIFICATION
You agree to indemnify, defend, and hold harmless Marcode Ltd and its affiliates, officers, directors, employees, agents, licensors, and suppliers from and against any claims, liabilities, damages, judgments, awards, losses, costs, expenses, or fees (including reasonable attorneys’ fees) arising out of or relating to:Your use of or access to the Service
Your violation of these Terms
Your violation of any rights of a third party
Your conduct in connection with the Service
Your use of the third-party VPN service
This defense and indemnification obligation will survive these Terms and your use of the Service.10. PRIVACY AND DATA COLLECTION
10.1 Your use of the Service is also governed by our Privacy Policy, which explains how we collect, use, and protect your information. By using the Service, you consent to the data practices described in the Privacy Policy.10.2 Marcode Ltd does not claim any responsibility for the privacy practices of the third-party VPN provider. The third-party VPN provider may collect, use, and disclose your information according to its own privacy policy. We strongly advise you to review both our Privacy Policy and the third party’s privacy policy.10.3 You acknowledge that we do not monitor, control, or log any of your activities while using the third-party VPN service and have no obligation to do so.10.4 You understand and agree that no data transmitted over the internet can be guaranteed to be 100% secure, and we cannot ensure or warrant the security of any information you transmit while using the Service.10.5 Additional Privacy and Safety Features
10.5.1 In addition to the VPN connection service, Marcode Ltd provides several privacy and safety-focused features that may share data with Marcode Ltd in accordance with our Privacy Policy.10.5.2 These additional privacy and safety features are provided by Marcode Ltd only and are separate from the third-party VPN service.10.5.3 You may opt out of any or all of these privacy and safety features at any time, and doing so will not affect your usage of the underlying VPN service.10.5.4 Marcode Ltd takes no responsibility for these additional privacy and safety features working as intended and provides no warranty for their effectiveness, reliability, or availability.10.5.5 All disclaimers, limitations of liability, and other provisions in these Terms apply equally to these additional features.11. TERMINATION
11.1 We reserve the right to suspend, disable, or terminate your access to the Service at any time, with or without notice, for any reason including, without limitation, if we believe that you have violated or acted inconsistently with the letter or spirit of these Terms.11.2 Upon termination, all rights granted to you under these Terms will immediately cease, and you must promptly discontinue all use of the Service.11.3 The provisions of these Terms which by their nature should survive termination shall survive termination, including, without limitation, ownership provisions, warranty disclaimers, indemnity, and limitations of liability.11.4 We shall not be liable to you or any third party for any termination of your access to the Service.12. GOVERNING LAW AND DISPUTE RESOLUTION
12.1 Governing Law
These Terms and your use of the Service shall be governed by and construed in accordance with the laws of England and Wales, without regard to its conflict of law principles.12.2 Dispute Resolution
Any dispute, claim, or controversy arising out of or in connection with these Terms or the Service shall be resolved exclusively by binding arbitration in accordance with the rules of the London Court of International Arbitration and held in Bury St. Edmunds, England.12.3 Waiver of Class Actions
BY AGREEING TO THESE TERMS, YOU WAIVE YOUR RIGHT TO A JURY TRIAL AND TO PARTICIPATE IN A CLASS ACTION, CLASS-WIDE ARBITRATION, OR REPRESENTATIVE ACTION.12.4 Limitation on Time to File Claims
ANY CAUSE OF ACTION OR CLAIM YOU MAY HAVE ARISING OUT OF OR RELATING TO THESE TERMS OR THE SERVICE MUST BE COMMENCED WITHIN ONE (1) YEAR AFTER THE CAUSE OF ACTION ACCRUES. OTHERWISE, SUCH CAUSE OF ACTION OR CLAIM IS PERMANENTLY BARRED.13. INTELLECTUAL PROPERTY
13.1 All content, features, and functionality of the Service, including but not limited to all information, software, text, displays, images, video, and audio, and the design, selection, and arrangement thereof, are owned by Marcode Ltd, its licensors, or other providers of such material and are protected by copyright, trademark, patent, trade secret, and other intellectual property or proprietary rights laws.13.2 These Terms do not grant you any right, title, or interest in the Service or our content, nor any intellectual property rights owned by Marcode Ltd or its licensors.13.3 You agree not to reproduce, duplicate, copy, sell, resell, or exploit any portion of the Service without our express written permission.13.4 Any feedback, comments, or suggestions you may provide regarding the Service is entirely voluntary, and we will be free to use such feedback, comments, or suggestions without any obligation to you.14. SEVERABILITY
If any provision of these Terms is found to be invalid, illegal, or unenforceable by a court of competent jurisdiction, such provision shall be severed, and the remaining provisions of the Terms will remain in full force and effect.15. ENTIRE AGREEMENT
These Terms, together with our Privacy Policy and any other policies or rules referenced herein, constitute the entire agreement between you and Marcode Ltd regarding your use of the Service, superseding any prior agreements between you and Marcode Ltd regarding the Service.16. MISCELLANEOUS
16.1 No Waiver
The failure of Marcode Ltd to enforce any right or provision of these Terms will not constitute a waiver of future enforcement of that or any other provision. The waiver of any such right or provision will be effective only if in writing and signed by a duly authorized representative of Marcode Ltd.16.2 Assignment
You may not assign or transfer these Terms or any rights or obligations hereunder, without our prior written consent, and any attempted assignment or transfer without such consent will be void. We may assign or transfer these Terms, in whole or in part, at our discretion without restriction.16.3 Force Majeure
Marcode Ltd shall not be liable for any failure to perform its obligations hereunder where such failure results from any cause beyond our reasonable control, including, without limitation, mechanical, electronic, or communications failure or degradation, acts of God, terrorism, natural disasters, pandemic, epidemic, or government restrictions.16.4 Export Control
You agree to comply with all applicable export and re-export control laws and regulations, including the Export Administration Regulations maintained by the U.S. Department of Commerce, and trade and economic sanctions maintained by the Treasury Department’s Office of Foreign Assets Control.16.5 Electronic Communications
By using the Service, you consent to receiving electronic communications from us. These communications may include notices about your account and information concerning or related to the Service.16.6 Relationship of the Parties
Nothing in these Terms shall be construed as creating any agency, partnership, joint venture, employment, or franchise relationship between you and Marcode Ltd.16.7 Notices
Any notices or communications required or permitted by these Terms will be in writing and deemed given when delivered personally, sent by email (with confirmation of receipt), or by certified mail to your address on file or the address provided on our website.17. CONTACT INFORMATION
If you have any questions or concerns about these Terms, please contact us at:Marcode Ltd
Unit 82a James Carter Road
Mildenhall, Bury St. Edmunds
England, IP28 7DE
VAT: GB475930362
Company Registration: 15046325
Email: [email protected]
Website: marcode.ai

Supplemental Privacy Policy

GENERAL INFORMATION
For the purposes of this Privacy Policy, we define the term "Customer" as a person who uses the PROXY-SELLER Services, and the term "Visitor" as an individual visiting our Website.1.1 PROXY-SELLER (hereinafter ⎼ “PROXY-SELLER”, “Us”, “We”, and “Our”), realize the importance of ensuring the confidentiality and inviolability of the Personal Data of individuals, therefore we conclude this Privacy Policy with you (hereinafter referred to as the “Policy”). The Policy defines how your Personal Data can be obtained, stored, processed, used and disclosed by PROXY-SELLER while you use the Services of PROXY-SELLER and our website, located at: https://proxy-seller.com (hereinafter ⎼ “Website”).1.2 By visiting the Website and/or using the Services of PROXY-SELLER, 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 PROXY-SELLER 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 PROXY-SELLER’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 PROXY-SELLER Services.1.5 You may be referred to as “you” or the “Subject” in this Agreement.2. DEFINITIONSReview 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 PROXY-SELLER’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 PROXY-SELLER’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 person2.5 “PROXY-SELLER” - 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 “PROXY-SELLER’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 AGREEMENTYou, 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 PROXY-SELLER 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 PROXY-SELLER 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 PROCESSINGWe 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 PROCESSTo 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. PROXY-SELLER 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 PROXY-SELLER 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 PROXY-SELLER), 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; andother 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 By clause 4.15 of the Public offer, you may be required to provide the following data: personal information extracted from a Customer’s identity document, for example, name, document number, date of birth, nationality, type of document, issuing country, expiration date, information embedded in barcodes, QR codes, security chips and features (which will vary depending on the type of document), and the image metadata associated with the image or video of the document. PROXY-SELLER does not receive or process this data. Processing is carried out by the policies of the service as a third party that conducts the KYC process. Please ensure that you have carefully reviewed and agreed to the service’s policy before submitting your data.5.1.9. 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.5.2.1 When you accept our Terms of Use, a contract is formed between you and us. In order to carry out our obligations under that contract we must process the information you give us.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, PROXY-SELLER shall not be liable for the adverse consequences associated with the processing of such Personal Data.6. LAWFUL BASIS OF DATA PROCESSINGWe 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 PROCESSINGWe 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;7.1.4 to detect, investigate, and prevent illegal activities or conduct that may violate the Terms of Use of PROXY-SELLER and this Privacy Policy;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 PROCESSINGWe obtain your consent before personal data processing8.1 Consent to Personal Data Processing8.1.1. By accepting this Privacy Policy, you approve to have reached the age of majority or the legal age in your jurisdiction (generally 18 or older), are solely responsible for all your actions, and fully understand the statements, outlined in this Privacy Policy.8.2 EU Persons Consent to Personal Data processing8.2.1 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 processing8.3.1 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); andto use cookies and web beacons (pixel tags) to collect your Personal Data.9. THE RIGHTS OF SUBJECTSPlease 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 Services9.3 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 DELETIONWe 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.10.2 EU Territory. We store Personal Data as long as it is needed for the provision of our Services and/or opportunity to use our Website. Traffic information is erased or made anonymous when it is no longer needed for the transmission or, in the case of payable Services, up to the end of the period during which the bill may lawfully be challenged or payment pursued. Direct marketing and provision of value-added Service information (including traffic information used for these purposes) are stored as long as the same is necessary for the provision of these activities, or up to the time when a User opts out from such use under this Privacy Policy. Other information is stored for as long as we consider it to be necessary for the provision of our Service and/or opportunity to use our Website. This Section shall not prevent any technical storage or access to information for the sole purpose of carrying out the transmission of a communication or as strictly necessary for us to provide the Service you requested. As explained in the GDPR statement, We strive to anonymize the data when possible. If you decide to exercise your right to erasure, We will also inform our providers to delete all your data.10.3 US Territory. We will retain collected information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by applicable legislation.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 SECURITYWe 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.12. CONTRACTORSWe 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.12.4 We use a third-party payment processor, currently <Paddle, Stripe> (“Payment Processors”) to assist in securely processing your payment information. If you pay with a credit card the payment information that you provide through the Services is encrypted and transmitted directly to the Payment Processor. We do not store your Payment Information and do not control and are not responsible for the Payment Processors or their collection or use of your information. You may find out more about how the Payment Processors store and use your Payment Information by accessing the Payment Processors Privacy Policy.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).12.6 We use Facebook. to measure and increase the effectiveness of our advertising campaigns. For more information on the privacy practices of the Facebook, please visit the Privacy Policy: https://www.facebook.com/business/m/privacy-and-data.12.7 We use Google Analytics to create detailed statistics of website users. The statistics are collected on Google's server; the User only places JS code on the pages of his or her site. The tracking code is triggered when the User opens the page in his or her web browser. For more information on the privacy practices of Google Analytics, please visit the Privacy Policy: https://policies.google.com/privacy?hl=en-US s-privacy-policy/.13. OTHER PROVISIONSCheck 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.13.1 Application of this Policy. This Privacy Policy applies to the Website. Once redirected to another website this Policy is no longer applicable.13.2 Acceptance of this Policy. We assume that all Users have carefully read this document and agree to its content. If one does not agree with this Privacy policy, they should not use this Website.13.3 Changes and Updates to our Policy. From time to time, we may update this Privacy Policy. We encourage You to periodically check back and review this Privacy Policy so that You always will know what data we collect, how we use it, and with whom we share it.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 PROXY-SELLER 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 Resolution13.6.1 This Policy, the rights and remedies provided for in this Policy, any claims and disputes related to it and/or PROXY-SELLER, 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:SSV IT PROVIDER ONLINE SERVICES LTDE-mail: [email protected]Registered address: Agias Faneromenis, 143-145 PATSIAS COURT, Flat/Office 201, Larnaca, Cyprus, 6031