Last Updated: June 2021

At Convert Master, we prioritize the privacy of our users (“user”, “you”, “your”). We have implemented robust measures and procedures to protect our users from risks such as theft, disruption, and unauthorized access to their online information and activities. We strongly encourage you to read this privacy policy (“Policy”) carefully before using our services.

This Policy is an integral part of the company’s Installer and Software (“Terms”), and it governs the collection, processing, and transfer of data related to your use of the Installer and Software. This is done in accordance with relevant data protection and privacy regulations, including the EU General Data Protection Regulation (“GDPR”) and the California Consumer Privacy Act (“CCPA”).

Terms not defined in this Policy will have the meanings assigned to them in our Terms.

This Policy outlines the types of information Convert Master may collect and process during your use of the Installer and Software, how this information may be used or shared with third parties, how we protect it, and how you can exercise your rights regarding your Personal Data (as defined below).

Before installing, accessing, or using the Installer or Software, we recommend that you thoroughly review this Policy. If you are a California resident, please also review our CCPA Privacy Notice.

Types of Information We Collect

When you use Convert Master’s Installer and Software, we may gather and process the following information about you:

(I) Non-Personal Data: This includes non-identifiable aggregated data, such as technical information transferred from your device. Non-Personal Data does not identify individuals.

(ii) Personal Data: This includes data that identifies or can reasonably identify an individual, such as online identifiers like IP addresses. The collection of Personal Data will adhere to the lawful principles of the GDPR, as follows:

Processing online identifiers for operational and functional purposes.

Processing contact details if you choose to contact the Company, as well as any information provided for the execution of our agreement with you.

If required by relevant laws, processing certain Personal Data will be subject to obtaining your consent.

Below is a list of the types of data that will be collected:

1. Convert Master or our service providers may collect your IP addresses or other unique online identifiers through your use of the Installer and Software. This data is collected to provide and operate our Installer and Software. The IP address will be stored as non-identifiable and will be anonymized immediately after collection.
2. Convert Master may collect technical data when you use our Installer and Software, which may include information such as date and time stamps, device type, operating system, language preference, estimated location, traffic source leading to the Installer, and applications installed on your device. This data is processed to improve the Installer and Software, for operational purposes, and to manage internal statistics.

iii. If the Software installed by the user is a browser extension or a search-related product, Convert Master may collect the User’s search-related data. This data may include URLs of websites visited by the User. Convert Master will collect this data as aggregated Non-Personal Data. However, web browsing data may contain information that could be considered Personal Data. Convert Master will delete this type of data shortly after collection. We will use this data to provide certain features of the Software, such as displaying relevant advertising based on searches.

Legal Basis for Data Processing under the EU GDPR:

This section provides an overview of the data we process, the techniques used, and the reasons for using your information. As outlined in the GDPR, the legal bases for processing your personal data include:

1. Legitimate Interests: We handle certain Personal Data when you access the Product due to our legitimate business interests.
2. Contract Fulfillment: When you contact us, we collect and process your personal details to fulfill our contractual obligations (e.g., using your contact details).
3. Consent: In some cases, we process specific Personal Data with your consent where necessary.

GDPR Compliance and Data Handling:

In compliance with GDPR, we function as the Data Controller for the Personal Data we collect, as described below. When using our Product and/or Software/extension, we may collect your Internet Protocol (IP) address and/or MAC address. Additionally, technical information from your device is collected, such as the device type, operating system (e.g., iOS), statistical data, browser type, preferred language, time of access, approximate location, the URL that directed you to our Product, and installed applications on your device.

We follow industry-standard practices to anonymize IP addresses immediately after they are collected, ensuring they are stored in a form that no longer qualifies as Personal Data.

The collection of IP addresses is crucial for providing services related to our Product and Software/extension. This data enables us to maintain and protect our Product and Software/extension and pursue legitimate interests, such as auditing installations, detecting fraud, ensuring security, and managing business operations (e.g., calculating payments to business partners).

If you decide to contact us via any available communication channels (e.g., email), you will need to provide your contact details, such as your name and email address.

We use this information to respond to your inquiries, offer support, or provide requested services. If necessary, we may retain your communication history for future reference, such as for handling future claims, offering additional support, or improving our services.

California Consumer Privacy Act of 2018 (“CCPA”)  

Categories of Personal Information We Collect and Share

Under the CCPA, Personal Information does not include (i) publicly available information from government records or (ii) information that has been anonymized or aggregated.

In accordance with the CCPA, the following table outlines the categories of Personal Information we collect from you.

Disclosure of Personal Information for Business Purposes

In compliance with the CCPA, we provide the following details regarding the disclosure of Personal Information for business purposes:

Over the past 12 months, the Company has disclosed the following categories of Personal Information for business purposes: (A) Identifiers and (D) Commercial Information. Your Personal Information has been shared with the following categories of third parties for business purposes: (i) Data aggregators, (ii) Service providers, and (iii) Business partners.

When we share Personal Information for business purposes, the third parties are bound by contract to use this data only for fulfilling their contractual obligations and for no other purpose.

Information on the Sale of Personal Information

According to the CCPA, the following details pertain to the sale of Personal Information:

In the last 12 months, the Company has not sold any Personal Information.

Data Sharing

Convert Master does not share Personal Data with third parties except as outlined below:

– Service Providers: We may share your information with third parties to perform the functions of the Installer and Software. We ensure that these providers use your information only to follow our instructions and not for any other purposes.

– Compliance with Laws: Convert Master may share your information if legally required, such as to comply with a court order.

– Corporate Transactions and Affiliates: Convert Master may share your Personal Data with affiliated entities like subsidiaries or parent companies when necessary, and in compliance with relevant laws. For instance, in the event of a corporate transaction (e.g., merger, sale of assets), the acquiring entity will assume the rights and obligations under this Policy.

– Consent: Convert Master may share your information with your consent, and in such cases, your information will be governed by the third party’s privacy policy.

– Online Identifiers: Convert Master may share your online identifiers with business partners for purposes such as calculating payments and detecting fraud.

Data Security

We employ industry-standard technical and administrative measures to secure your Personal Data. However, please note that no transmission of data can be guaranteed to be 100% secure, and we cannot be held responsible for unauthorized access or misuse of the Installer or Software. Convert Master does not guarantee that it can prevent all unauthorized access. If you believe that your Personal Data has been improperly accessed or that your privacy has been violated, please contact us at support@togonetworksltd.com.

Data Transfer

Convert Master may store or process your Personal Data in various locations, including the US. If you reside in the EEA, we will ensure that your Personal Data receives adequate protection as required by applicable law.

Your Rights

Depending on your jurisdiction, privacy laws may grant you certain rights concerning your Personal Information, including:

• The right to access Personal Data
• The right to correct, amend, or delete Personal Data
• The right to request deletion if processing is no longer necessary
• The right to object to data processing
• The right to restrict the processing of your data to ensure its accuracy and completeness
• The right to transfer your data (portability)
• The right to withdraw consent, subject to legal or contractual obligations
• The right to lodge a complaint with a supervisory authority

Depending on local laws, your rights may vary. If you wish to exercise any of these rights, we may request additional information to verify your identity. Processing these requests may take up to one month unless local law requires otherwise. If you do not provide sufficient information, Convert Master may decline your request.

Children

Convert Master’s Installer and Software are not intended for use by children under the age of 16 (or the applicable age as defined by relevant laws). We do not knowingly process data from children. If you suspect that a child has provided us with Personal Information, please contact us at support@togonetworksltd.com. Upon discovery, we will immediately delete such information.

Data Retention

Subject to applicable laws, unless you request otherwise, we will retain your information as long as it is necessary to provide our services, enforce agreements, and meet legal obligations. However, this Policy does not impose an obligation to retain any specific information, and we may choose not to store or may delete data at our discretion.

Do Not Track Disclosure

Our Installer and Software do not respond to Do Not Track signals. For more information, please visit http://www.allaboutdnt.com/.

Policy Updates

The date of the latest revision is listed above. Convert Master reserves the right to modify this Policy at any time. Please review the Policy periodically, as we may make changes that could affect your rights. We will notify you if there are significant changes.

Contact Information

If you have any questions or concerns regarding this Policy, please contact us at support@togonetworksltd.com