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Privacy Policy


ONAVO, A FACEBOOK COMPANY, RESPECTS YOUR PRIVACY. PLEASE REVIEW OUR TERMS OF SERVICE AND OUR PRIVACY POLICY TO LEARN HOW WE OPERATE AND TREAT THE DATA WE RECEIVE IN CONNECTION WITH PROVIDING OUR SERVICES.

Privacy Policy Effective Date: December 14, 2018

Onavo Inc. and Facebook Israel Limited ("Onavo", "we", or "us") offer the current Onavo mobile applications Protect, and Free VPN + Data Manager, and may introduce future innovative new mobile applications (the "Apps"), as well as the website www.onavo.com and affiliated pages (the "Website"). The Website and the Apps together may collectively be referred to as the "Services". We want you to clearly understand how, pursuant to this Privacy Policy, we use your information when you use our Services, and the rights and options available to you with respect to your information. If you live in the European Economic Area and Switzerland. Onavo Inc. and Facebook Israel Limited are the data controllers responsible for your personal information.

Policy Highlights:

For your convenience, the following section highlights aspects of our Privacy Policy but does not substitute or replace the full Privacy Policy which you can read in full below.

Information Collection After you agree to use our Services, our Services direct your mobile data traffic through or to our servers in order to provide you with our Services. This means we also collect and receive certain information about you including all of your mobile traffic data, and information about your apps usage.

Use of Information We use the information that we collect to provide and improve the Services and services of the Facebook Companies ("Affiliates"), develop new products and services, analyze usage of our Apps and other applications on your device and to support related activities. For more information on how our Services work, please see our FAQs at https://www.onavo.com/faq/

Sharing of Information We share your information with third-party service providers in order to operate, maintain and enhance the Services. We also share your information with our Affiliates, because we use them to host our Services and databases. In addition to hosting your information on this shared infrastructure, our Affiliates use aggregated Onavo information for market and business analytics purposes and to help improve their services - but do not add your Onavo information to a specific user's account on the Affiliate's service.

Cookies and Similar Technologies We use cookies and other technologies to operate our Services, help us better manage content, and improve users' experience.

Third Party Activities Third parties may also use cookies or similar technologies to collect information when you use our Services. The Services may contain links to third party websites or mobile applications, which are not owned or controlled by us and are not governed by this Privacy Policy.

Choice Using the settings we provide, you may opt-out of certain ways Onavo will use your information. To learn more about the controls available to you, see below or visit "Settings" in the Onavo app. .

Data Retention We retain your personal data for as long as necessary to provide you with the Services and for the purposes described in this Privacy Policy. If you no longer want Onavo to process your personal data, you can request that we delete your data by contacting us. Where we can identify your personal data, we will delete it and support you in deleting your Onavo application. For more information on how to do this, please see "Your Rights", below. Onavo will delete the information it holds about you unless we need to retain and use your information to comply with our legal obligations, to resolve disputes, and/or to enforce our agreements.

Security We strive to protect your information and privacy and we implement information security systems and procedures that are intended to secure your information. However, they cannot provide absolute information security.

International Transfers We transfer your personal information to third party service providers and Affiliates based outside the European Economic Area (EEA), including the United States.

Children's Privacy If you are under the age of 13, you may not use any of the Services.

Changes to this Privacy Policy If we make any material changes to this Privacy Policy we will notify you by email, or through prominent notice in our Apps, or by posting a prominent notice on our Website, and give you the opportunity to review the revised Privacy Policy before you choose to continue using our Services.

Information Collection

We receive or collect information about you so that we can operate, provide, improve, understand, customize, support, and market our Services, including when you install our Apps, and access or use our Services. The types of information we receive and collect depend on how you use our Services.

Information You Provide. You can choose to provide us with your email address and name or certain information related to your use of our Services (for example, you may send us an email relating to the performance of our Services or other issues) so that we can provide you with customer support.

Automatically Collected Information. In order to provide you with the Services, we collect information regarding you, your online activities, your usage of apps, and your device or browser when you use the Services. For example, we may collect:
  • Device and Connection Information. Information about your device, including the type of device, its operating system, the mobile carrier or network, IP address, GPS or other general location information, and device identifiers. When you download the Apps, you may permit us to access data on or about your device, including permissions obtained through our Apps or your device (e.g. Google Play on Android).
  • Usage. Information about your mobile applications and data usage, including the applications installed on your device, your use of those applications, the websites you visit, and the amount of data you use.
  • Log Information. . We may receive log information and other data from your device, such as webpage addresses and data fields.

  • Content of Communications. We may receive the content of your mobile data transactions when your mobile data is transferred through our servers.
  • Location Information. We may receive location-related information based on the mobile data traffic we receive when you use our Apps, or based on IP addresses.
  • Information from Cookies and Similar Technologies. Cookies are small pieces of data that are stored on your mobile phone, computer, or other device. Pixels (often used in connection with cookies), are small blocks of code placed in webpages that do things like allow another servers to measure how frequently webpages are viewed and used. We and our partners may use cookies, pixels, SDKs or similar technologies in order to operate and provide the Services. For example, we may use them to make the Services easier or faster to use; customize the Services; collect information for statistical and analytical purposes; verify information; support advertising and related activities; and for information security purposes. We may also use cookies and similar technologies to better understand the functionality of our Apps.
    Your browser or device may offer you control over the use cookies or other technologies when you use the Services. For example, you may be able to set your browser or device to disable, clear, reset or block the use of cookies or similar technologies. Further, your device controls may allow you to opt out of having applications collect location information about your device, or remove the VPN connection that you establish between your device and our servers when you install our Apps, and through which you allow the Apps to transmit your mobile data. Using these controls may, however, complicate, impair or prevent your use of the Services or certain features.
  • Information from Third Parties. We may receive information about you from our third-party partners. For example, we may receive data from third parties that we use for analytics purposes, as described in this Privacy Policy. We are also part of the Facebook family of companies and we receive information from these Affiliates for the purposes described in this Policy.

  • Use of Information

    We, use the information we receive to provide, analyze, improve, and develop new and innovative services for you and our Affiliates ; to communicate with you; and to help protect ourselves or someone else. For example, Onavo uses your information to:

  • Provide, maintain and improve our Services. For example, we process your information to perform certain functions such as helping you monitor your mobile data usage and monitoring active apps on your device. We also use information we receive about you to support our internal operations by activities such as troubleshooting, data analysis, testing, and research.
  • Analyze how you use applications and data. For example, we combine the information that we collect through your use of the Services with information about you that we receive from our Affiliates or third parties to provide market and business analytics and other services to Affiliates.
  • Respond to you when you contact us, for instance if you have a question related to customer support.
  • Support Safety and Security. We use your information for safety and security purposes, including enforcing our Terms of Service, preventing unlawful activities and misuse of the Services, protecting the legal rights, property, safety, and security of you, Onavo, and our Affiliates, and our users, and resolving disputes involving you relating to the Services; and
  • Meet our Legal Obligations. Onavo may also use your personal information to comply with its legal obligations such as to comply with applicable laws and assist law enforcement when we have a good-faith belief that such cooperation is reasonably necessary or meets the applicable legal standards.

  • Legal Bases
    If European Union data protection law applies, we rely on a number of legal bases to lawfully process this information for the purposes described below. For all people who have legal capacity to enter into an enforceable contract, we process your information as necessary in order to provide our Services to you, in accordance with our Terms of Service.

    We may also process your information where necessary to fulfill our (or others) legitimate interests, including our interests in understanding how our Services are being used by obtaining insights into your use of the Services, and providing market and business analytics and other services to Affiliates, unless those interests are overridden by your interests or fundamental rights and freedoms that require protection of personal data.

    How We Share This Information

    We share information we have about you in accordance with this Privacy Policy to provide Services that you have requested, and with:

    Affiliates. We share your information with our Affiliates, because we use them to host our Services and databases. In addition to hosting your information on this shared infrastructure, our Affiliates use aggregated insights from de-identified Onavo data for market and business analytics purposes and to help improve their services - but do not add your Onavo information to a specific user's account on the Affiliate's service.

    Service Providers. We may also share your information with third parties that perform services on our behalf to help us provide, understand, or improve the Services. For example, we may use partners to help host our services and databases, perform analyses or research, send communications on our behalf, or measure the effectiveness of our advertising. Our service providers agree to only use your information in accordance with our agreements with them as well as this Privacy Policy.

    Other Parties When Required By Law or as Necessary to Protect the Services. We may access, use, preserve, and share your personal information with third parties when we have a good faith belief that it is necessary to: (i) respond to legal process and legal requests; (ii) detect, prevent and address fraud and other illegal activity; (iii) enforce our Terms of Service; (iv) protect the rights, property or personal safety of you, Onavo, our users, or the public; (v) provide customer support or assist with technical issues; or (vi) establish or exercise our legal rights or defend against legal claims.

    In Connection With a Merger, Acquisition or Sale of Assets. If we sell all or part of our business, make a sale or transfer of assets, are otherwise involved in a merger or business transfer, or in the event of bankruptcy, we may disclose and transfer your personal information to one or more third parties as part of that transaction.

    Our Services may offer publicly accessible blogs or community forums. Any information you provide in these sections will be public and may be read, collected, and used by anyone who accesses them.

    Choice

    Using the settings we provide, including in the Apps that you install on your device, you may opt-out of certain ways Onavo will use and share the information we receive when you use the Services. To learn more about the controls available to you and how to use them, visit "Settings" in your app.

    These controls let you limit certain uses of information that we collect when you use the Services, but we will still receive and use certain information as necessary to perform the Services as otherwise described in this Policy and the Terms of Service. If you do not want us to receive any information about you, then you should uninstall the Apps and stop using the Services. For more information please see "Your Rights" below.

    Data Retention

    We retain information regarding you and your use of the Services for as long as necessary to provide you with the Services and for the purposes described in this Privacy Policy.

    If you no longer want Onavo to use your information to provide you with the Services, you may close your account.

    If you stop using the Services, you can request that we delete your information by contacting us. For more information on how to do this, please see "Your Rights," below. Upon request, Onavo will delete the information it holds about you unless we need to retain and use your information to comply with our legal obligations, to resolve disputes, or to enforce our agreements.

    We retain your personal data for as long as necessary to provide you with the Services and for the purposes described in this Privacy Policy. If you no longer want Onavo to process your personal data, you can request that we delete your data by contacting us. Where we can identify your personal data, we will delete it and support you in deleting your Onavo application. For more information on how to do this, please see "Your Rights," below. Onavo will delete the information it holds about you unless we need to retain and use your information to comply with our legal obligations, to resolve disputes, and / or to enforce our agreements.

    Please note that in the course of providing the Services, we maintain aggregate or de-idenfied information which we may retain indefinitely.

    Your Rights

    Where EU data protection law applies, you have the right to access, rectify, portability and deletion of your data. You also have the right to object to and restrict certain processing of your data. This includes:
  • the right to object to our processing of your data for direct marketing, which you can exercise by using the "unsubscribe" link in such marketing communications, and
  • the right to object to our processing of your data where we are pursuing our legitimate interests or those of a third party.


  • For assistance with exercising these rights, you can contact us at support@onavo.com.

    Without prejudice to any other rights you may have you also have the right to file a complaint against us with a supervisory authority in the EU Member State which you are based. Click here to find your local supervisory authority.

    Our Data Protection European Representative is FB Representative Services Designated Activity Company. You you can contact them at c/ Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbourd, Dublin 2 Ireland.

    Security

    We maintain adequate safeguards to help protect against loss, misuse, unauthorized access, disclosure, alteration, or destruction of the information we receive. While we strive to protect your information and privacy, no data transmission or storage can be guaranteed to be 100% secure. We cannot guarantee or warrant the security of information you disclose or transmit to us and cannot be responsible for the theft, destruction, misuse, unauthorized access, alteration, or inadvertent disclosure of your information.

    International Data Transfers

    We may store and process your information through third-party or Affiliate hosting services in the United States, European Economic Area ("EEA"), and other international jurisdictions. As a result, we may process your information, including personally identifying information, in a jurisdiction with different data protection laws than your jurisdiction. If you reside outside of the EU, by using the Services, you explicitly and unambiguously consent to the transfer of your information internationally, including but not limited to the United States, for the purposes described in this Privacy Policy.

    Children's Privacy

    If you are under 13, you may not use any of the Services. The Services are not intended for use by, or directed to, persons under the age of 13 and we do not knowingly collect personal information from such persons.

    Your California Privacy Rights

    California law permits residents of California to request certain details about what personal information a company shares with third parties for the third parties' direct marketing purposes. Onavo does not share your personal information with third parties for the third parties' own and independent direct marketing purposes unless we receive your permission. If you have questions about our sharing practices or your rights under California law, please write us at Onavo, Inc., 1601 Willow Road, Menlo Park CA 94025.

    Changes to This Privacy Policy

    We may update this Privacy Policy to reflect changes in our privacy practices. If we make any material changes, we will notify you by contacting you through our services, emailing you (to the address specified in your account, if we have an address for you), or by posting a notice on the Apps or our Website - or by some combination of these methods. In circumstances where you have not provided us with your contact information, we encourage you to periodically review the Website and/or the App for the latest information on our privacy practices.