Privacy

Version No 3. December 11, 2023.

This IPRoyal Services FZE LLC Privacy Policy (the “ Privacy Policy “) strives to protect user privacy and information when using any system of IPRoyal Services FZE LLC or being in contractual relationship between IPRoyal Services FZE LLC as a service provider and any natural or legal person as a service user.

BY USING THIS WEBSITE www.iproyal.com (the “ System “), YOU AGREE TO THE PRIVACY POLICY, WHICH MAY GET UPDATED WITHOUT PRIOR NOTIFICATION.

1. General provisions and definitions

1.1 IPRoyal Services FZE LLC is a legal entity, incorporated in the United Arab Emirates, license No 4387, address BLB-BC5-641 (5th floor), AMC - BOULEVARD-B Building, 143 AL HASSAN AL BASRI STREET, JURF 2, Ajman, United Arab Emirates (the “ Company ” / “ us ” / “ we ”).

1.2 Any person using Company’s services/systems is considered to be a client of the Company (the “ Client ” / “ You ”).

1.3 The Company and the Client are legally bound by the Terms and Conditions (the “ Agreement ”) which governs the contractual relationship between the Company as a service provider and the Client, as any natural or legal person, as a service user, or a user of System prior to/without logging-in/creating an account (Account).

1.3.1 The Company provides multiple IP address proxy infrastructure solutions, including IP addresses for the Clients to connect to the internet, and access to the Company’s data gathering and proxy management solutions (the “ Services ”). The Services can be reached and used via System.

1.3.2 The latest version of Agreement shall be available at https://iproyal.com/terms-of-service/ .

1.4 This Privacy Policy shall be applicable and interpreted in line with Agreement. The definitions set out in the Agreement shall be applicable to this Privacy Policy.

1.5 You can contact the Company using a popup chat box in the System, filling a question box in the System in the “About us” section, as well as by sending an email. For the matters regarding this Privacy Policy, as well as regarding any privacy matter, we recommend contacting the Company via email, by sending Your inquiry to privacy@iproyal.com .

1.6 The Company shall have the right to unilaterally modify and/or update the Privacy Policy at any time without notice. The continuous use of the Services/System by the Client shall be deemed as acceptance of Privacy Policy in the last and most updated version. Any Client shall periodically check and assess the Privacy Policy. Any update of this Agreement comes in force at the moment it is published at the System.

1.7 The latest version of the Privacy Policy shall be available at https://iproyal.com/privacy/ .

1.8 By agreeing to the Agreement as per the rules set forth in the Agreement, You are automatically agreeing to the Privacy Policy. For the avoidance of doubt, You acknowledge understanding that by using System in any way prior to creating an Account (Clause 2 of the Agreement) or without logging-in to the System (for example, when browsing the Blog section of the System), You are also bound by this Privacy Policy and Your data/information may be collected by the Company automatically.

1.9 If You disagree to be bound by the Privacy Policy in any scope or way, You must not use or must immediately cease Your use of the Services, System or any part of it, as well as its features and functionalities.

1.10 The Company values the trust that You place in the Company when using Services/System. For this reason, privacy and data security are extremely important to the Company. It is very important to the Company that You feel safe when You visit our System and use our Services, as well as in all other business transactions with the Company. As soon as You use Company’s System/Services, You entrust Company with the processing of Your personal data. The Company wants to offer You the best possible experience with the System to ensure that You can enjoy using Services now and in the future. That is why the Company wants to understand user behavior on the System in order to continuously improve it. The processing of Your personal data is therefore not only necessary for the provision of Services, but also to improve user-friendliness. Therefore, in this Privacy Policy You are informed which personal data the Company collects from You, how the Company processes it and to whom the Company passes it on in detail. In addition, the Company informs you about the precautions it takes to protect Your personal data, what rights You have in this context and who You can contact regarding data protection issues.

1.11 In the light of the above, the Company strives to protect Your privacy and obliges to process Your personal data in accordance with the following rules and principles:

1.11.1 Processing shall be performed lawfully, fairly, and in a transparent manner.

1.11.2 Personal data must be adequate and limited to what is necessary in relation to the purpose for which it is processed.

1.11.3 Personal data shall be accurate and, where necessary, kept up to date.

1.12 This Privacy Policy is prepared in accordance with the United Arab Emirates‘ Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data Protection (the “ PDPL “) and other relevant legal acts, as well as with the best practices and principles of data protection. You can find information on applicable legal acts here: https://u.ae/en/about-the-uae/digital-uae/data/data-protection-laws .

1.13 With regard to the terms used in this Privacy Policy, such as “Processing” or “Controller”, we refer to the definitions of the PDPL.

2. Applicability

2.1 This Privacy Policy applies to all persons who use the System/Services or otherwise interact with the Company (e.g. business partners, interested parties, service providers, etc.); generally those persons who are hereinafter referred to as “Client” or “You”.

2.2 Company’s System and Services are not meant for anyone under the legal age. Only people of legal age are allowed to use System, Services and register for an Account. The Company therefore does not knowingly collect personal data from minors. So, if You are under 18 years of age / under legal age under the laws imperatively applicable to You, please do not use the System/Services and do not provide us with any personal data

2.3 If You are a representative of a legal person, which is a user of the Company’s System/Services, You shall be aware that Your personal data will be collected too in accordance with this Privacy Policy.

2.4 You shall be responsible for making sure You are applicable to use the Company‘s System and/or Services.

3. Controller, its obligations and scope

3.1 For the purposes of applicable data protection law, the Company is typically the “data controller” of any personal information provided to the Company. Very occasionally, the Company might act on specific retainers as a “processor” (by processing personal data only in accordance with the directions of a data controller, or as otherwise permitted by law).

3.2 Privacy Policy shall be applied to the processing of personal data by data controller (the Company) located in the United Arab Emirates processing the personal data of data subjects (You) residing or working within or outside the United Arab Emirates.

3.3 If You have any questions regarding the processing of Your personal data and the exercise of Your rights under the PDPL, You can contact our team: privacy@iproyal.com .

3.4 The Company might require additional identification data from You for certain inquiries (e.g. Passport, ID card, etc.) in order to ensure that Your personal data is only passed on to You.

3.5 The Company, as a data controller (or in some cases – data processor), has the following obligations:

3.5.1 Data transfers. The Company shall not transfer personal data to country or territory outside the United Arab Emirates unless that country ensures an adequate level of protection for the rights and freedoms of data subjects in relation to the processing of personal data.

3.5.1.1 Where adequate level of protection is not ensured, an exemptions shall be made by a) creating adequate protection through appropriate safeguards (for example, by using Standard Contractual Clauses), or 2) by getting data subject‘s explicit consent and making sure the transfer does not conflict with the public security interests of the United Arab Emirates.

3.5.2 Data processing records. The Company shall keep data processing records upon its own decision, unless such record keeping is mandatory legal requirement.

3.5.3 Data protection officer appointment. The company shall assign a data protection officer (the “ DPO ”) to ensure proper data protection requirement implementation and optimization of procedures. The DPO shall be equipped with the skills and know-how for safeguarding personal data.

You can contact Company’s DPO / data protection staff by sending an email to privacy@iproyal.com .

3.5.4 Data breach notification. The Company strives to protect Your personal data in the best way possible. However, sometimes data breaches occur and such events can happen for various reasons.

3.5.4.1 In the case of a data breach that would prejudice the privacy, confidentiality and security of the personal data of a data subject, the Company, as a data controller, immediately upon becoming aware of such breach, shall notify the Data Office of such data breach.

3.5.4.2 The required notification shall include details such as: the nature, category, reasons, approximate number and records of the data breach, a description of the likely consequences of the data breach; and a description of the measures and remedial action taken by the controller to address the data breach.

3.5.5 Data retention. The Company shall not store personal data after the completion of the purpose for which such data was processed unless the identity of the data subject is no longer identifiable through the use of anonymization techniques.

3.5.6 Sensitive personal data protection. In general, the Company does not process any special categories of personal data from Clients. This includes data that reveal racial or ethnic origin, political opinions, religious or ideological convictions or trade union membership, as well as genetic and biometric data. In some cases, during verification, in addition to the actual verification data (e.g. screenshots of ID documents and identification data from them, place of residence, status of politically exposed persons, video data, etc.), biometric data (e.g. personal data resulting from specific technical processing in connection with the physical, physiological or behavioral characteristics of a person and data for the clear identification of a person, e.g. facial images, dactyloscopic data) are recorded. Such processing of biometric data takes place exclusively based on Your express consent, which You can revoke at any time.

3.5.7 Proper agreements between controller and processor. The processor shall perform and implement the processing of personal data based on the instructions of the controller and in accordance with the contracts and agreements entered into between them, which shall specifically set out the scope, subject-matter, purpose and nature of the processing, the type of personal data, and categories of data subjects. The Company, either acting as a controller or the processor, shall make sure beforehand that such agreements are concluded and are proper for planned data processing.

4. Data categories and sources

4.1 The Company may collect personal information from You in the course provision of Services, when You use the System, contact us or request information from us, or as a result of Your relationship with any of our personnel or clients.

4.2 The personal information that we might process includes:

4.2.1 Contact data. When creating a new user Account or communicating with the Company (for example, by contacting our support team), we may process basic details, such as Your name, date of birth, role/title, employer/s, Your relationship to a person, and Your contact information (such as Your email address, physical address, contact numbers).

4.2.2 Verification data. if an Account/other details are verified, also depending on the verification level, we may therefore process, for example: screenshots of national identity documents such as passport, driver’s license, ID card and identification data from these documents, utility bill details for residence verification, data about the status of political exposed persons, video data from the video authentication procedure, biometric data for verification, as well as information collected from publicly available resources to verify the same.

4.2.2.1 The Company always asks You to verify Your identity/other details when the Client:

4.2.2.1.1 Wants to use the PayPal payment option.

4.2.2.1.2 Wants to purchase Static Residential proxies

4.2.2.1.3 Wants to purchase more than a total of 500GB Residential proxies.

4.2.2.1.4 Wants to get access to all Residential proxies IP pool.

4.2.2.1.5 Wants to access blocked websites on the Residential proxies pool.

4.2.2.2 The list indicated in Clause 4.2.2.1. can be changed at the sole discretion of the Company. You should always make sure whether the Service You are ordering / action You want to make in the System requires verification.

4.2.2.3 The Company is using third party service provider for identity verification Idenfy. More information about tool is available here: https://www.idenfy.com/identity-verification-service/ , information about Idenfy’s Privacy Policy is available here: https://www.idenfy.com/privacy-policy/ .

4.2.3 Order data. In the context of ordering Services, we might process information relating to the matter on which You are seeking our Services.

4.2.4 Financial data. In the context of ordering Services and accepting payments, as well as making refunds or processing withdrawals in relation to the Affiliate program (or any other applicable program / offer) we might process, for example: bank details (IBAN, BIC), information about the payment service provider, payment details, transaction-ID, etc.

4.2.5 Log data. During activities on the System (website) and while using Services, we might process, for example: IP-address, Your location, location data, traffic data, transaction data (like deposit, payment, refund withdrawal address), computer or mobile device information, frequency, time, length of visit and other page interaction data, operating system, browser type, device type, unique device identification number, identification cookies, optionally form data, crash reports, performance data, third-party cookies, etc.

At all times when using System / Services, we collect and process the following log data:

4.2.5.1 IP address of first or the last login.

4.2.5.2 Account credentials and other information as per Clause 2 of the Agreement, including date and time of Account creation, as well as log-in date and time.

4.2.5.3 Information collected by cookies and Google Analytics (see Clause 12), for example: browser type, the web pages You visited, and time spent on them, access time and dates, unique device identification number, other. The mentioned data in this Clause might be collected without assigning it to the specific user.

4.2.6 Company details. If You use a Services /enter into commercial agreement with the Company as a legal entity, we might process, for example: commercial register reports, data of or concerning beneficial owners, records or additional information about recent, past or planned business activities, other data required to determine / validate the structure, the beneficial ownership or any power of attorney from the company, etc.

4.2.7 Marketing data. If You visit System or our social media sites, we might process statistical and marketing data, for example: number of visitors, frequency, clicks, time, places, target groups, data from cookies and similar technologies (pixels, ClearGIFs, etc.), consumer’s behavior, interests and preferences, data on market research and target group surveys, etc.

4.2.8 Photo, video and audio data. When we attend or organize events or fairs or conduct interviews with people, or You visit our offices or our meetings and events, we may take photos and other recordings of such events and process photo, video and audio data, as well as data on time, location, participant list, etc. However, we will always inform You separately about any such recordings by photographic or video images and/or audio recordings.

4.2.9 Hiring data. If You apply for a job on our System, social media (for example, via LinkedIn), we may process data that is necessary for the recruitment process, for example: contact details, curriculum vitae, qualifications, police clearance certificate, credit report, national identity documents such as passport, driver’s license and the data from all of these documents, links to Your portfolio or social media platforms, etc.

5. Purpose and legal basis

5.1 All processing is carried out in accordance with the PDPL. We process Your personal data based on at least one of the legal bases mentioned below. If the Company requests the provision of other personal data not described above, this data as well as the purpose and legal basis for the collection and processing will be communicated to the Client at the point of collecting the personal data.

5.1.1 Performance of the contractual obligations under the Agreement. A controller (the Company) / processor may process personal data without the consent of the data subject (You) to which the data relates where processing is necessary for the performance of a contract (the Agreement) to which the data subject is party or in order to take steps at the request of the data subject for entering into, amending or terminating a contract.

5.1.2 Consent. We may ask You to provide Your consent if the data subject’s (Yours) consent is relied upon as a lawful basis for the processing of Your personal data. For example, we may ask You to express consent prior to using the System before the Agreement is concluded or when You are using the System without logging-in, as well as before collecting / processing any other personal data not described in this Privacy Policy.

If You have given us Your consent to the processing of Your personal data, the processing will only occur for the defined purposes and to the extent agreed in the declaration of consent.

A given consent can be revoked at any time without giving reasons with effect for the future if You no longer agree to the processing.

With Your consent, we process data for the following purposes, for example:

• Direct marketing and advertising (e.g., customer satisfaction surveys, newsletters, sweepstakes, and other advertising communications). You express Your consent for direct marketing and advertising by creating an Account. By creating an Account, You confirm understanding that the contact information provided to the Company can be used by the Company for direct marketing and advertising purposes, as well as other electronic communication. By creating an Account, You express your consent to receive various marketing and advertising materials.
• Website analysis and tracking for advertising purposes (see also our Cookie Policy at Clause 12).
• Certain uses of audio, video and photo data (e.g., commercials, interviews, etc.) for marketing and other representing purposes through various channels.
• Automated authentication process (identity verification).
• Application management system, recruitment process and processing of Your application

Revoking Your consent does not affect the legality of the processing carried out based on Your consent up to the point of withdrawal.

5.1.3 Compliance with legal obligations. Processing of personal data may also be necessary to abide by various legal obligations. Such legal obligations include, for example, the following data processing operations: contract management, accounting, and invoicing, monitoring to prevent fraud, misuse, money laundering and terrorist financing, providing information to criminal authorities in context of fiscal criminal proceedings or prosecution to official orders, assessing the working capacity of the employee or the provision of health/social care, etc.

5.1.4 Protection of legitimate interests. Where necessary, data processing can occur beyond the performance of the contract to ensure the legitimate interests of the Company or a third party. Such a legitimate interest includes the following data processing operations:

• Prevention of fraud, misuse (e.g. for illegal purposes), money laundering and terrorist financing.
• Risk management and risk minimization, e.g. through inquiries to credit agencies, debtor directories or providers of business analysis.
• Identification and examination of potentially incorrect or suspicious business cases and access to our websites (e.g. website analysis via Sift Science).
• Data transfer within the Company for internal administrative purposes.
• Account management and processing of general Client requests and inquiries.
• Measures to protect our customers and partners as well as to ensure network and information security; also measures to protect our employees and property, e.g. through video surveillance and external data centers and service providers.
• Processing of inquiries from authorities, lawyers, collection agencies in the context of legal prosecution and enforcement of legal claims in the context of legal proceedings.
• Market research, business management and further development of services and products.
• Processing of statistical data, performance data and market research data via the website, the app or social media platforms (e.g. Facebook, LinkedIn, YouTube etc.).
• Processing of customer preferences (e.g. language, region) via cookies on our website.
• Direct marketing and advertising (e.g. implementation of marketing strategies, targeting of Clients, dispatch of vouchers, advertisement from the Company and its partner companies).
• Use of audio, video and photo data from public spaces (e.g. public events, fairs, etc.) for marketing and other representing purposes on our social media channels or our website.

5.2 The Company may also process personal data without the consent of the data subject to which the data relates where the data has been made public by the data subject (Article 4 of the PDPL).

6. Social media presence and other communication

6.1 The Company maintains social media presences on various platforms (see below) in order to communicate with its active customers, potential customers and interested social media users about Company’s services, products and other news. When accessing such social media platforms, the general terms and conditions and the privacy policies of these operators also apply. We would like to point out that user data can also be processed outside of the United Arab Emirates or the region/location You are in. This can result in risks for users due to different legal frameworks (e.g. the enforcement of data subject rights could be made more difficult).

6.2 As part of the technical process of various social media platforms (e.g. Google, Facebook, Twitter etc.), when You click on a content or a website You are visiting, they find out whether You are logged into Your social media account at the same time. This information is collected by social media platforms and assigned to Your social media accounts, regardless of whether You click on the content of this platform or not. By logging out of Your accounts, You can prevent these companies from associating the collected information with Your accounts.

6.3 The activities of these companies are not controlled by the Company and therefore we do not accept any liability for any damage You may suffer because of the use of Your data by these companies.

6.4 The Company may only process personal data from social media users if they communicate directly with the Company via such platforms (e.g. visitors number, posted articles, likes, direct messages, customer inquiries, comments, etc.). In these cases, the Company is also responsible for processing the personal data collected thereby. In addition to data processing by us, other providers, in particular operators of social networks and platforms, also process personal user data. We have no influence on this data processing and are not responsible for it - the data processing takes place exclusively in the area of responsibility of the other providers.

6.5 For a detailed explanation of the respective processing and the possibilities of objection (opt-out) by providers of social media networks, we refer to the respective privacy policies of the providers (see below). In the case of requests for information and the assertion of data subject rights to data processing by other providers, we point out that these can be asserted with the providers listed below. Only the providers have access to the data of the users and can directly take appropriate measures and provide information.

6.6 The Company uses the following social media accounts in order to engage with You and other third parties:

6.6.1 Discord account – accessible using this link: https://discord.com/invite/asDe2Wb7Af More information about data collected by Discord and Your preferences is available here: https://discord.com/privacy ,

6.6.2 Twitter account – accessible using this link: https://twitter.com/IPRoyal_proxies More information about data collected by Twitter and Your preferences is available here: https://help.twitter.com/en/rules-and-policies

6.6.3 Facebook account – accessible using this link: https://www.facebook.com/IProyal We use Page Insights function to process statistical data from users on Facebook ( https://www.facebook.com/legal/terms/page_controller_addendum ). More information about data collected by Facebook and Your preferences is available here: https://www.facebook.com/privacy/center/

6.6.4 LinkedIn account - accessible using this link: https://www.linkedin.com/company/iproyal More information about data collected by LinkedIn and Your preferences is available here: https://www.linkedin.com/legal/privacy-policy?trk=homepage-basic_footer-privacy-policy

6.6.5 YouTube account – accessible using this link: https://www.youtube.com/@IPRoyalOfficial More information about data collected by YouTube and Your preferences is available here: https://policies.google.com/privacy?hl=en .

6.7 The above indicated list is non-finite and the Company is entitled to change/add social media accounts. The latest and up-to-date list of Company’s social media accounts shall be available at the System’s section “Social”.

6.8 You should always make sure that the social media account is Company’s before submitting or revealing any personal information of Yours while engaging in any social media communication (for example, exchanging messages or leaving a comment).

6.9 You should be aware that SMS / messaging and email services are susceptible to spoofing and phishing attacks and should be careful when reviewing messages that claim to be from the Company. You should always log into Your Account via https://iproyal.com/ , use communication tools in the System or contact us via email by sending an inquiry to the address privacy@iproyal.com . If You are unsure about the authenticity of a communication or notice. Note that phishing attacks often occur despite SMS or email or equivalent services, via search engines or advertisements in search engines or other fraudulent links. The Company takes no responsibility for any loss due to spoofing, phishing, or other equivalent attacks.

7. Your rights

7.1 You shall be entitled to the following rights:

7.1.1 Right to withdraw Your consent and right to opt-out. In all cases You are entitled to object to and suspend to the processing of Your personal data where the processing is performed for direct marketing purposes; and the processing is performed for statistical survey purposes. If You disagree to give Your consent / wish to withdraw Your consent to receive direct marketing and advertising material in any scope or way, You must either:

7.1.1.1 Not complete the creation of the Account, or

7.1.1.2 After creation of the Account, withdraw Your consent (that was given by creating an Account) by clicking “ Unsubscribe ” button in the email received from the Company after Your Account was created, or

7.1.1.3 At any other time, withdraw your consent by clicking “Unsubscribe” button indicated in any other email from the Company which was sent by the Company as a direct marketing and/or advertising material.

7.1.1.4 You have the right to revoke Your consent any time within the methods described in this Privacy Policy or by email to privacy@iproyal.com . Please note that if You withdraw Your consent, we may no longer be able to offer You all of our Services. Withdrawing Your consent does not affect the legality of the processing of Your personal data based on Your consent up to the point of withdrawal.

7.1.1.4.1 By checking the respective box during the registration process (creating an Account) or when updating after logging into Your Account, You expressly confirm that You have read the Agreement together with Privacy Policy and that You agree to the data processing described therein.

7.1.1.4.2 By checking the respective box during the registration process (creating an Account) or when updating after logging into Your Account, You expressly confirm that You have read other policies as indicated in such notice.

7.1.1.4.3 By creating an Account, You expressly consent to receiving direct marketing and advertising material, as well as other electronic communication.

7.1.1.4.4 By checking the respective box (boxes) during the use of System for use of Cookies, You expressly consent to usage of Cookies as indicated in this Policy, the notice and as per Your preferences expressed by checking all/any boxes.

7.1.2 Right prior to the start of processing activities, t o get information on the purpose of the processing, sectors or entities inside or outside the United Arab Emirates with whom Your personal data will be shared, the appropriate safeguards used by the Company in the context of cross-border processing.

7.1.3 Right to obtain additional information upon request, including:

7.1.3.1 confirmation whether we are processing personal data related to You.

7.1.3.2 the types of personal data of the data subject being processed;

7.1.3.3 the decisions taken on the basis of automated processing;

7.1.3.4 the rules and criteria of the periods for which the personal data will be stored and kept; and

7.1.3.5 the measures to be taken upon the occurrence of a data breach.

7.1.4 Right to rectification. You are entitled to obtain the rectification of inaccurate personal data concerning You, and to have incomplete personal data completed.

7.1.5 Right to erasure. You are entitled to request the Company to delete Your personal information if:

7.1.5.1 The personal data is no longer necessary in relation to the purposes for which it was collected or processed; and/or

7.1.5.2 You withdraw Your consent or express objection to processing and there are no legitimate grounds for the Company to continue the processing.

7.1.5.3 The personal data have been illegally processed.

7.1.5.4 The deletion of personal data is necessary to fulfill a legal obligation under law to which the Company is a subject.

7.1.6 Right to receive a copy and have Your personal data transmitted to another controller, if technically feasible. You shall have the right to receive the personal data concerning You that You have provided to us in a structured, commonly used and machine-readable format where the processing is based on Your consent, or is necessary to fulfill a contractual obligation and implemented by automated means. You also shall have the right to have this data transmitted directly to another controller named by You, insofar as this is technically feasible and the rights and freedoms of others are not impaired. The right to data portability can only be exercised if the processing is based either on Your consent or on a (pre)contractual necessity and where the processing is automated. The right to data portability does not apply to processing which is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

7.1.7 Right to object to decisions based on automated processing. The Company usually does not use any personal data for automated decision-making including profiling (e.g. decisions that have legal effects on data subjects, or significantly affecting them in any other way that are based solely on automated processing of personal data including profiling). In case we would make such a decision in any scope, You shall be entitled to object

Additionally, You have the right to object to the processing of Your personal data at any time if the processing is based on Your legitimate interests. If You object to the processing, we will no longer process Your personal data unless we can demonstrate compelling legitimate grounds for the processing that outweigh Your interests, rights and freedoms, or the processing serves to assert, exercise or defend legal claims. The objection does not affect the legality of the processing of Your personal data based on legitimate interests until You withdraw Your consent.

7.1.8 Right to restriction of processing . You shall have the right to request that we restrict processing if one of the following conditions is met:

7.1.8.1 You dispute the accuracy of the personal data (the restriction applies for a period of time that enables the Company to verify the accuracy of the personal data).

7.1.8.2 The processing of Your personal data was unlawful, and You refuse to delete Your personal data and instead request that its use is to be restricted.

7.1.8.3 The Company no longer needs your personal data for processing purposes, but You need them to assert, exercise or defend legal claims.

7.1.8.4 You have objected to the processing of Your personal data, and it has not yet been determined whether the Company’s legitimate grounds outweigh Your own.

7.1.9 Right to lodge a complaint with the Data Office. The United Arab Emirates Data Office acts as the federal data regulator in the United Arab Emirates. The authority was established under United Arab Emirates Federal Decree Law No. 44 of 2021 on the establishment of the UAE Data Office. More information and contact information is available at https://ai.gov.ae/personal-data-protection-law/ .

7.1.10 Right to contact. To exercise any of the above rights, You can send an email to privacy@iproyal.com or a letter to IPRoyal Services FZE LLC, Business Club -BLB-BC5-641 (5th floor), AMC - BOULEVARD-B Building, Ajman Media City, Ajman, United Arab Emirates. Please note that for such inquiries we need further identification data from You (e.g. Passport, ID card, etc.) in order to ensure that Your personal data is only passed on to You. We shall respond to Your inquiry within 30 days from the day of receiving it (with the possibility of two 30-day extensions).

7.2 In all cases we encourage You to contact us directly. We at the Company believe that best decisions can be made by mutual agreement and effort.

7.3 As a general principle of the Company, we process personal data only for the purposes for which they were collected. In exceptional cases, however, we may process Your personal data that we have collected for another purpose. In this case, before the intended processing, we will inform You of this purpose, the duration of the storage of Your personal data, the exercise of data subject rights, the possibility of revoking consent, the existence of a right to complain to the data protection authority, whether the provision of the data was necessary on legal or contractual grounds and possible consequences of non-provision and whether automated decision-making or profiling is carried out.

8. Data security

8.1 The security of data is very important to us and we are committed to protecting the data we collect. We maintain comprehensive administrative, technical and physical measures to protect Your personal data from accidental, unlawful or unauthorized destruction, loss, modification, access, disclosure or use. These measures correspond to the highest international safety standards and are regularly checked for their effectiveness and suitability for achieving the desired safety requirements.

8.2 We have implemented the following technical, physical and organizational measures:

8.2.1 Assigning DPO, staff training.

8.2.2 SSL encryption on our System from which we transfer personal data.

8.2.3 Two-factor authentication (2FA) for System.

8.2.4 Ensuring the confidentiality, integrity, availability and resilience of our System and Services.

8.2.5 Use of encrypted systems.

8.2.6 Pseudonymization and anonymization of personal data.

8.2.7 Entry, access and transfer control for our offices and systems.

8.2.8 Measures of quick restoring of the personal data availability in the event of a physical or technical incident.

8.2.9 Measures for privacy by design and default on our platform such as preventing user enumeration.

8.2.10 Implementation of procedures for the regular review, assessment and evaluation of the effectiveness of the technical and organizational measures to ensure the security of processing, e.g. our bug bounty program.

8.2.11 Internal IT security practices and monitoring, internal communication and fast response approach.

8.2.12 Incident-response management.

8.3 While using System/Services, the Clients are recommended to use two-factor authentication (2FA) for the Account.

8.4 Your personal data may be accessed, transferred and / or stored by employees or suppliers at a destination outside the country in which You are located, whose data protection laws may be of a lower standard than those in the United Arab Emirates. However, we will in all circumstances protect personal data in accordance with this Privacy Policy.

8.5 If we process personal data in a third country (for example, inside the European Union (EU) or the European Economic Area (EEA)) or if this happens in the context of the use of third-party services or disclosure and / or transfer of personal data to third parties, we only transmit personal data to the performance of our (pre)contractual obligations based on our consent, a legal obligation or our legitimate interests. Subject to legal or contractual permissions, we process or have personal data processed in a third country only if the conditions of ensuring an adequate level of protection for the rights and freedoms of data subjects in relation to the processing of personal data are met. This means, for example, that the processing and transmission takes place on the basis of special guarantees, such as compliance with a code of conduct or a certification mechanism as well as binding and enforceable commitments from the recipient in the third country to apply the appropriate guarantees for the protection of the data or compliance with officially recognized special contractual obligations (for example, announced by the European Commission and known as “Standard Contractual Clauses”).

9. Recipients of personal data

9.1 The Company shall only transmit Your personal data to the extent described below or as part of an instruction at the time the data was collected from You. In addition, personal data that we collect about You will not be sold by us or otherwise passed on to third parties.

9.2 Within the Company, those departments or employees will receive Your personal data who need it to fulfill contractual and legal obligations and legitimate interests. We transfer personal data for the purpose of our day-to-day business operations such as account management and other processes You have requested, as well as for the efficient performance of internal administrative activities in a joint manner and for the maintenance and improvement of our products and services.

9.3 To a limited extent, we also transfer personal data to processors who provide services for us such as video authentication services, IT services, legal services, customer support, improvement of our website, performance of contracts, account management, accounting, invoicing, application management, marketing services and sending marketing material. Processors may only use or pass on this data insofar as this is necessary to provide services for us or to comply with legal regulations. We contractually obliged these processors to guarantee the confidentiality and security of Your personal data that they process on our behalf.

9.3.1 Main service providers contracted by the Company that may process Your data:

• Live chat and support service platform, e.g., Zendesk (provided by Zendesk Inc.).
• Marketing, application analytics and diagnostics, e.g., Facebook (provided by Meta Platforms, Inc.), Google (provided by Google), Impact (provided by Impact Tech, Inc.), Iterable (provided by Iterable, Inc.), Salesforce (provided by Salesforce, Inc.), LinkedIn (provided by Linkedin Corporation), X (provided by X Corporation), Baidu (provided by Baidu, Inc.), Microsoft Clarity (provided by Microsoft Corporation), Hotjar (provided by Hotjar, Ltd.), Quora (provided by Quora, Inc.), Cookiebot (provided by Usercentrics, A/S).
• Payment processing / management providers, e.g. Bitlocus (provided by Bitlocus LT, UAB), Simoresta (provided by Simoresta, UAB), CoinGate (provided by Decentralized, UAB), Paddle (provided by Paddle.com Market Ltd.), Stripe (provided by Stripe, Inc.), Alipay (provided by Airwallex (Hong Kong) Limited).
• Others, e.g. iDenfy (provided by iDenfy, UAB), Twillio (provided by Twillio, Inc.), Simoresta (provided by Simoresta, UAB), hCaptcha (provided by Intuition Machines, Inc.).

9.4 We may also transfer Your personal data (i) if we are required to do so by law or during legal proceedings, (ii) if we believe that disclosure is necessary to avoid damage or financial loss, or (iii) in connection with an investigation into suspected or actual fraudulent or illegal activities.

9.5 If the Company acts together with other parties as joint controller (e.g. processing of data for jointly defined purposes within a group of associated entities), we may provide those parties with personal data if applicable and based on at least one of the legal bases mentioned above under Clause 5. In case of a joint controllership, we transfer Your personal data only based on a sufficient agreement with our partners.

9.6 The Company may transmit Your personal data to another person at the request of the person concerned with Your consent for the transfer or for the purpose of fulfilling the contract or in order to take steps at the request of the data subject prior to entering into a contract.

10. Retention period

10.1 Unless otherwise indicated in the notice / consent form, the Company shall keep Your personal information only for as long as necessary to:

10.1.1 To provide You with the Services You have ordered and to ensure proper use of System/Account;

10.1.2 To comply with laws, including mandatory data collection periods.

10.1.3 To support a claim or defense in court or to act in other judicial proceedings.

10.2 In all cases the log data (Clause 4.2.5.) shall be saved for at least 6 months from the moment such data was collected. Log data is kept by the Company after the Account is terminated or suspended for the same period starting from the termination or suspension moment. The Company shall be entitled to keep this data for a longer period if it is necessary for a legitimate purpose.

10.3 In all cases Account data as per Clause 2 of the Agreement, including identification data (if applicable) shall be saved for the whole duration of You being the Client, and for at least 6 month period from the day the Account was terminated.

11. Privacy notice to Clients residing in European Union and California

11.1 If You are a resident of European Union (“ EU ”), please note that:

11.1.1 We are striving to ensure Your rights under The European Union’s General Data Protection Regulation (“GDPR”) . You can find more information on GDPR and Your rights here: https://gdpr.eu/

11.1.2 You are entitled to rights under GDPR, as Article 3.2. of GDPR states that the GDPR applies to organizations that are not in the EU if two conditions are met: the organization offers goods or services to people in the EU, or the organization monitors their online behavior. If You are using System/Services, such a situation falls into the scope of mentioned Article 3.2. of GDPR.

11.1.3 The obligations of the Company may be limited due to the exceptions indicated in the GDPR (like number of employees in the Company).

11.1.4 You can contact the Company’s DPO in case You have any questions or concerns related to this Privacy Policy or GDPR.

11.1.4.1 Please contact us via email, by sending Your inquiry to our Data protection team at privacy@iproyal.com .

11.1.4.2 Please contact us via mail, by sending us Your letter to IPRoyal Services FZE LLC, Business Club -BLB-BC5-641 (5th floor), AMC - BOULEVARD-B Building, Ajman Media City, Ajman, United Arab Emirates.

11.2 If You are a resident of California, please note that:

11.2.1 We are striving to ensure Your rights under California Consumer Privacy Act of 2018 (Cal. Civ. §§ 1798.100–1798.199) and the California Consumer Privacy Act Regulations by the Attorney General (collectively, “CCPA”).

11.2.2 You are entitled to:

11.2.2.1 The right to know what personal information is being collected.

11.2.2.2 The right to know whether the personal information is sold or disclosed, and to whom such information is sold or disclosed.

11.2.2.3 The right to say “no” to the sale of personal information.

11.2.2.4 The right to delete.

11.2.2.5 The right to access personal information; and

11.2.2.6 The right to equal service and price.

11.2.3 Upon Your verified request the Company shall provide the information on Your personal information that was collected within one year period preceding the request:

11.2.3.1 the categories of personal information the Company collected about You;

11.2.3.2 the categories of sources from which the personal information is collected;

11.2.3.3. the business or commercial purpose for which personal information was collected;

11.2.3.4 the business or commercial purpose for collecting or selling the resident’s personal information;

11.2.3.5 categories of third parties with whom the Company shares personal information; and

11.2.3.6 the specific pieces of personal information that the Company collected about You.

11.2.3.7 A copy of stored personal information.

11.2.4 In addition to above, the Company warrants that NO PERSONAL INFORMATION OF YOURS IS BEING SOLD IN ANY WAY BY THE COMPANY. Therefore, the Company does not provide a “Do not sell my personal information” box in the System.

11.2.5 You can contact the Company’s DPO in case You have any questions or concerns related to this Privacy Police or CCPA.

11.2.5.1 Please contact us via email, by sending Your inquiry to our Data protection team at privacy@iproyal.com .

11.2.5.2 Please contact us via mail, by sending us Your letter to IPRoyal Services FZE LLC, Business Club -BLB-BC5-641 (5th floor), AMC - BOULEVARD-B Building, Ajman Media City, Ajman, United Arab Emirates.

11.2.5.3 Additionally, You can contact us by using a popup chat box in the System ( https://iproyal.com/ ), filling a question box in the System in the “About us” section.

11.2.6 The Company shall provide the answer to Your inquiry within terms indicated in this Policy, but in all cases no later than within 45 days of the verifiable request (with the possibility of one 45-day extension).

11.2.7 The following is a list of the categories of personal information that the Company collected about the California residents for a business purpose within the last twelve months. NO COLLECTED DATA WAS SOLD.

11.2.7.1 Account data as per Clause 2 of the Agreement: (i) personal information of the Client / its representative; (ii) name of the company, if the Client is a legal entity; (iii) valid email address; (iv) valid phone number; (v) country of the residence; (vi) unique password, created by the Client; (vii) requirements for the Service (expected number of IPs a month, type of purchase, etc.). (viii) a confirmation that the Client agrees to the Agreement and Privacy Policy of the Company; (ix) A confirmation that the Client / its representative is a natural person.

11.2.7.2 Log data as per Clause 4.2.5., i.e.: (i) IP-address, Your location, location data, traffic data, transaction data (like deposit, payment, refund withdrawal address), computer or mobile device information, frequency, time, length of visit and other page interaction data, operating system, browser type, device type, unique device identification number, identification cookies, optionally form data, crash reports, performance data, third-party cookies, etc.; (ii) at all times when using System / Services, we collect and process the following log data: IP address of first or the last login; account credentials and other information as per Clause 2 of the Agreement, including date and time of Account creation, as well as log-in date and time; information collected by cookies and Google Analytics ((see Clause 12), for example: browser type, the web pages You visited, and time spent on them, access time and dates, unique device identification number, other. The mentioned data in this Clause might be collected without assigning it to the specific user.

11.2.7.3 Other information You may choose to insert in Your billing information.

12. Cookie Policy

12.1 Our System operating now and in the future uses cookies.

12.2 Insofar as those cookies are not strictly necessary for the provision of our System and Services, we will ask You to consent to our use of cookies when You first visit our System.

12.3 Cookies.

12.3.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and stored by the browser. The identifier is then sent back to the server every time the browser requests a page from the server.

12.3.2 Cookies may be either “ persistent” cookies or “ session” cookies : a persistent cookie will be stored by a web browser and will remain valid until its set expiration date, unless deleted by the user before the expiration date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

12.3.3 Cookies may not contain any information that identifies a user personally, but personal data that we store about You may be linked to the information stored in and obtained from cookies.

12.4 Cookies that we use . We use cookies for the following purposes:

12.4.1 Authentication and status - we use cookies to identify You when You visit our System and as You navigate our System, and to help us determine if You are logged into our System/Account.

12.4.4.1 For the purposes of the identification of You as a user we use the following Necessary cookies, that help make our System usable by enabling basic functions like page navigation and access to secure areas of our System. The System cannot function properly without these cookies:

12.4.2 Personalization - we use cookies to store information about Your preferences and to personalize our System for You.

12.4.2.1 For the purposes of personalization we use the following Preference cookies, that enable System to remember information that changes the way the System behaves or looks, like Your preferred language or the region that You are in:

12.4.3 Security - we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to secure our System and Services generally.

12.4.4 Analysis - we use cookies to help us to analyze the use and performance of our System and Services.

12.4.5 Other cookies – we might also use other cookies that are not listed in the clauses above. We reserve the right to amend the list of the usable cookies by amending the respective clauses of this Privacy Policy.

12.4.6 Cookie consent - we use cookies to store Your preferences in relation to the use of cookies more generally.

12.5 Our service providers use cookies and those cookies may be stored on Your computer when You visit our System, for example Google Analytics, Facebook pixel, etc.

12.6 Managing cookies. Most browsers allow You to reject and delete cookies. The methods for doing this depend on the browser and its version. You can however obtain up-to-date information about blocking and deleting cookies via these links:

12.6.4 https://support.google.com/chrome/answer/95647 (Chrome).

12.6.5 https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox).

12.6.6 https://help.opera.com/en/latest/security-and-privacy/ (Opera).

12.6.7 https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer).

12.6.8 https://support.apple.com/en-gb/guide/safari/manage-cookies-and-website-data-sfri11471/mac (Safari).

12.6.9 https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).

12.7 Cookies preferences . You can manage Your preferences relating to the use of cookies on our System.

12.8 Service provider . The Company uses third party service provider Cookiebot consent management platform. It is a plug-and-play compliance solution that detects and controls all cookies and trackers in use on a website, and automatically manages end-user consents. You can find more information here: https://www.cookiebot.com/en/privacy-policy/

12.9 Our details.

The System (this website) is owned and operated by IPRoyal Services FZE LLC. We are registered in the United Arab Emirates under license No 4387, and our registered office is at Business Club -BLB-BC5-641 (5th floor), AMC - BOULEVARD-B Building, Ajman Media City, Ajman, United Arab Emirates. You can contact us via email, by sending Your inquiry to privacy@iproyal.com , support@iproyal.com , or by sending us a letter to our registered address.