MOBILE AND WEB APPLICATION PRIVACY POLICY

Turis Tech Online Private Limited (referred to as “us”, “we” or “our” in this policy) is committed to protecting the rights and privacy of individuals, as well as the privacy, confidentiality and security of the personal information we hold in accordance with any applicable laws, regulations and rules relating to Personal Data (as defined herein) including any decisions, industry-specific or general guidance or notices issued by a regulator from time to time, which includes to the extent applicable, the Personal Data Protection Act 2012 of Singapore or such other similar statutory enactments. We are equally committed to ensuring that all our employees and agents uphold these obligations.

This policy (“Privacy Policy”) document sets out how we may collect, use, disclose, process and manage the Personal Data of users of the TurisVPN mobile and/or web application (“App” or “Services”). It describes what categories of Personal Data we collect, the purposes for which we use those data, the retention period of the Personal Data, your choices regarding how we use Personal Data about you, our security measures, and how your rights to access and correct data about you.

By accessing and/or using the App, you consent to the data collection and use practices described in this Privacy Policy. However, we will not use your Personal Data (1) to send you marketing and promotional communications about our Services, or (2) to post your comments or feedback on the App or Services on any social media maintained by us, unless you have opted in to consent to the same.

This Privacy Policy does not apply to websites, applications and/or other services provided or hosted by third parties.

Effective: Aug 1, 2024

Last Updated: Aug 1, 2024

A. Data Colection

1. “Personal Data” refers to any information that relates direct or indirectly to an individual who is identified or identifiable from that information or from that and other information to which we have or are likely to have access.

2. Data collected directly from users. In order to access and/or use the App, we may ask you for Personal Data to register your user account (“Account”) in the App, to provide Services offered through the App or to carry out a transaction you request. The Personal Data and other information that we collect includes:

(a) Your username, email address and mobile number (if applicable);

(b) Your preferences with respect to receiving marketing and promotional communications;

(c) Your subscription information in connection with our Services, such as your subscription plan, subscription term, subscription ID, subscription frequency, amount, currency, status, auto-renewal status, and information about the features you enable or disable on the App;

(d) Your inquiries about the App or our Services as well as information that assists us in identifying the best Services for you;

(e) Feedback from you about the App or our Services; and

(f) Your preferences with respect to our posting of your comments and feedback about the App or our Services on any social media maintained by us.

3. You are not required to provide this Personal Data or information. However, if you choose not to, certain functions within the App or our Services may not be available.

4. Data collected by our system. Our system collects certain data so that we may provide you with the Services, optimise our customer service to better support you, optimise our marketing and promotional efforts and review our billing information with our service providers. Such data includes:

(a) Device information e.g. device type and ID, mobile device language, operating systems and versions, and mobile network information etc.

(b) Access information e.g. your country details. We delete your access information as soon as practically possible.

(c) General usage information e.g. in-App features usage, Account usage, server usage and server level domain queries. We delete your general usage information as soon as practically possible.

(d) Crash data i.e. App performance data associated with crashes of the App.

5. We respect your privacy and do not retain any information relating to your online activities such as the websites you visit, session information, used bandwidth, network traffic or any other similar information. Do note that if you use a dedicated internet protocol (“IP”) address (a unique IP address assigned exclusively to you), it will encrypt your internet traffic and hide your real IP address and virtual location. However, since it is tied to your email address, certain online activities can be traced back to your Account. Whilst we may collect your access information and general usage information for legitimate business purposes per sections 4, 8 and 9 of our Privacy Policy, we delete them as soon as practically possible.

6. We have a strict no-historical-logs policy. We can do so because we are incorporated in the British Virgin Islands, which does not require such data storage or reporting, and the processes related to the provision of our Services are automated. Additionally, our operational configurations are specifically designed to protect your privacy and minimise any reliance on Personal Data:

(a) None of our employees can access all your Personal Data, save for our system administrator;

(b) Our system is designed to ensure that your online activities are kept private and confidential to you; and

7. With our strict no-historical-logs policy, you may go about your online activities with a peace of mind. We pledge not to sell your data to any third party whatsoever. We are in the business of providing VPN services, not data broking.

8. When you use the App or our Services, we may collect information, including your personal information about the way you act when using the App or our Services and how you use them.

9. We use the data and information collected to, amongst other legitimate business purposes, improve our security measures, to better understand how users access and use the App and how it can be improved to better meet your needs, as well as gauge interest in our Services.

B. Use of Personal Data

10. We may use your Personal Data for the purposes set out below.

11. Services and transactions. We use Personal Data to deliver Services, review our billing information with our service providers, or execute transactions you request such as providing information about our Services, processing orders and payments for our Services, facilitating the use of the App and so forth.

12. Customer service and feedback. We may use information about you and/or collected from you to respond to your customer service requests and feedback, or to take other actions to address your inquiries, or to post your comments or feedback on any social media maintained by us. We will give you the opportunity to opt-in to consent to our posting of your comments or feedback on any social media maintained by us.

13. App improvement and troubleshooting. We may use data about you to improve or enhance the App, including security measures, and related services, or to make the App easier to use by eliminating the need for you to repeatedly enter the same information, or by customising the App viewed through your Account to your preference. We may also use Personal Data and other information for the purposes of troubleshooting, conducting functionality testing and addressing issues regarding the App and its functions.

14. Marketing and promotional communications. With your consent, we may use Personal Data to inform you of Services provided by us. Communications may be done via email, SMS and/or through your Account in the App. When collecting information that might be used to contact you about our promotions and/or Services, we will give you the opportunity to opt-in to receiving such communications.

C. Disclosure of Personal Data

15. Except as described below, Personal Data you provide to us via the App will not be shared without your consent.

16. Disclosure to service providers. We contract with other companies, vendors and service providers to provide services on our behalf such as data processing, processing credit card and other types of payment transactions and data analytics regarding the App. We provide these companies with only those elements of Personal Data they need to deliver those services i.e., the types of Personal Data set out in paragraph 2 above. These companies and their employees are prohibited from using those Personal Data for any other purpose.

17. Disclosure in connection with transactions. In connection with certain transactions, we may disclose some or all of the Personal Data you provide to financial institutions involved in fulfilling the transactions.

18. Disclosure in connection with acquisitions or divestitures. Circumstances may arise where for strategic or other business reasons we decide to sell, buy, merge or otherwise reorganise particular businesses. Such a transaction may involve disclosure of Personal Data to prospective or actual purchasers, or receiving it from sellers. Although it is our practice to seek protection for information in these types of transactions, we cannot guarantee that an entity receiving such data from us in connection with one of these transactions by entering into binding written contract(s) with such prospective or actual purchasers or sellers will comply with the terms of this Privacy Policy.

19. Disclosure for other reasons. We may disclose Personal Data if required to do so by the applicable law or regulation or in the good faith belief that such action is necessary to comply with legal requirements or legal process served on us, to protect and defend our rights or property or those of our employees, agents or customers, to enforce agreement, policy or terms of use, or in urgent circumstances to protect the personal safety of any individual.

D. Security

20. We take appropriate measures to protect your Personal Data from unauthorised access, disclosure, alteration and destruction. However, no method of transmission over the internet or electronic storage is 100% secure and we cannot guarantee absolute security.

21. For websites and Apps to which you log in, it is your responsibility to ensure the security of your passwords and to not reveal this information to others.

E. Retention and Review of Personal Data

22. During the period that your Account is active, save for your access information and general usage information which we delete as soon as practically possible, we will retain your Personal Data and other information collected, unless you expressly request that we delete the information, in which case, certain functions within the App or our Services may not be available. You may submit a written request that we delete your Personal Data and other information collected by sending an email to: [email protected].

23. We may retain the information after your Account is terminated in the following circumstances (subject to the applicable law):

(a) If we are required to retain such information by applicable law or regulation or pursuant to any requirement of any competent authority;

(b) If there is an unresolved issue relating to your Account, such as an outstanding claim or outstanding credit or payment due; and/or

F. International Transfers of Personal Data

24. Personal Data collected by us may be stored and processed in Singapore or where we engage a service provider to perform certain services, in any other country our service providers maintain facilities. When we transfer your information to other countries, we will protect that information to the extent required by law. By choosing to use the App and to provide data through it, you consent to any such transfer of information outside your country.

G. Links to Third-Party Websites or Applications

25. The App may contain links to third-party websites or applications. These websites and applications operate independently from the App and we do not control and are not responsible for the content, security or privacy policy employed by other websites or applications. You should review the privacy policies of those websites and applications to determine how they protect and use Personal Data.

H. Your Rights

26. In some cases, you can access and correct Personal Data provided through the App by going to the page on which you provided the data. You can also request to review and correct Personal Data collected via the App or submit any inquiries or concerns you may have about your Personal Data by sending an email to: [email protected].

27. To the extent required by law, we provide users with:

(a) Reasonable access to the Personal Data they provide; and

(b) The ability to review, correct and delete such Personal Data.

28. You can help us keep your Personal Data accurate by notifying us of any change to your Personal Data, especially your contact information such as your mobile number or email address.

I. Consent for Marketing and Promotional Communications

29. If you have consented to receiving marketing and promotional communications about our Services through electronic mail, your mobile number(s) via SMS and/or through the App, we may from time to time contact you via such channels to provide you information about promotions and/or our Services.

J. Consent for Posting your Comments or Feedback on Social Media Maintained by Us

30. If you have consented to us posting your comments or feedback on the App or Services on any social media maintained by us, we may post such comments or feedback on any social media maintained by us from time to time.

K. Consequences of Consent Withdrawal

31. You may withdraw your consent for us to collect, use or disclose your Personal Data by giving us reasonable written notice.

32. If you withdraw your consent for us to collect, use or disclose your Personal Data for purposes other than purposes in connection with paragraphs 29 and 30 above, we will be unable to provide the Services, the App and/or maintain the operation of your Account. In such event, you may be required to terminate your use of the Services, the App and/or the Account.

33. You may withdraw your consent for your Personal Data to be used for purposes in connection with paragraph 29 above, in which case you will stop receiving marketing and promotional communications about our Services from us via the mode(s) of communication for which you have withdrawn your consent after a period permitted by law or in accordance with our internal policies. Please note that such withdrawal of your consent will not affect our ability to provide you with the Services, the App or to maintain the operation of your Account with us.

34. You may also withdraw your consent for your Personal Data to be used for purposes in connection with paragraph 30 above, in which case we will stop posting your comments or feedback on the App or Services on any social media maintained by us after a period permitted by law or in accordance with our internal policies. Please note that such withdrawal of your consent will not affect our ability to provide you with the Services, the App or to maintain the operation of your Account with us.

L. Contact Us

35. If you have any questions about this Privacy Policy or our handling of Personal Data, please contact us by sending an email to: [email protected].

M. Changes to Privacy Policy

36. We reserve the right to update or modify this Privacy Policy at any time. Any changes will be effective immediately upon posting the updated Privacy Policy on the App. You should review this Privacy Policy regularly to stay informed about our practices regarding your personal information. Your use of the App or our Services after such changes have been posted constitutes your agreement to such changes.