Privacy Policy

1. Who is responsible for your information

We act as the controller of personal information processed in connection with the App and the Site. You can reach us about any privacy matter at [TO FILL: email].

2. Your browsing stays on your device

ShieldSurfing is a web browser. Information such as open tabs, browsing history and website data that the App keeps is generally stored locally on your iPhone, and you can remove it using the App's tools for clearing browsing data. Deleting the App generally removes the data it stores locally on your device; copies kept elsewhere, for example in device backups, may be handled by your device settings.

Please keep in mind that the websites you visit, your network operator and your internet service provider may process information about your activity under their own policies, which we do not control.

3. Information we may process

3.1 Information you send us

If you contact us, we receive your email address, the content of your message and any details you choose to include.

3.2 Technical and usage information

To keep the App working and to improve it, we may process limited technical information, such as device model, operating system version, App version, language and region settings, crash reports and general, aggregated information about how App features are used.

3.3 Purchase information

Payments are handled by Apple. We do not receive your full payment card details. We may receive information from Apple and from service providers that help us manage subscriptions, such as a transaction identifier, the product purchased, the purchase date, renewal status and the country of the purchase.

3.4 Website information

When you visit the Site, our hosting provider may process standard technical data such as IP address, browser type and the pages requested, in order to deliver and secure the Site. Optional analytics cookies are used on the Site only if you accept them in the cookie banner.

4. Why we use information and on what legal basis

• Providing the App and its features, including subscriptions you purchase — performance of a contract.
• Keeping the App and Site secure and fixing errors — our legitimate interests.
• Understanding and improving the App and Site using aggregated or limited data — our legitimate interests or, where required, your consent.
• Answering your messages — our legitimate interests or steps taken at your request.
• Meeting legal, tax and accounting obligations — compliance with legal obligations.

Where processing relies on your consent, you may withdraw it at any time. This does not affect processing carried out before withdrawal.

5. Service providers and other recipients

We work with third-party service providers that help us operate the App and the Site, for example for hosting, crash reporting, analytics and subscription management. They may process information on our behalf and according to our instructions. We may also disclose information where required by law, to protect our rights or the safety of users, or in connection with a merger, acquisition or sale of assets.

We do not sell your personal information, as "sale" is defined by applicable law, and we do not intend to share it for cross-context behavioural advertising as that term is defined by applicable law.

6. International transfers

Our service providers may process information in countries other than your own. Where information from the European Economic Area, the United Kingdom or Switzerland is transferred elsewhere, we rely on appropriate safeguards, such as standard contractual clauses approved by the European Commission.

7. How long we keep information

We keep personal information only for as long as it is needed for the purposes described in this Policy, or for longer where the law requires it. Support messages are kept for as long as necessary to handle your request and any follow-up. Purchase records may be kept for the periods required by tax and accounting rules.

8. Your rights

8.1 EEA, UK and Switzerland (GDPR)

You may have the right to access your personal information, to have it corrected or erased, to restrict or object to its processing, to receive it in a portable format, and to withdraw consent. You also have the right to lodge a complaint with your local data protection authority.

8.2 California (CCPA/CPRA)

California residents may have the right to know which categories and specific pieces of personal information we have collected, to request deletion or correction, and to opt out of the sale or sharing of personal information. As described in section 5, we do not sell personal information, or share it for cross-context behavioural advertising, as those terms are defined by applicable law. We will not discriminate against you for exercising these rights.

8.3 How to make a request

Send your request to [TO FILL: email]. We may need to confirm your identity before acting on it, and we will reply within the time limits set by applicable law. You may also use an authorised agent where the law allows.

9. Deleting your data

You can remove browsing data stored by the App on your device at any time using its clearing tools; deleting the App also generally removes data stored locally on your device. To ask us to delete any personal information we hold about you, such as support correspondence, email [TO FILL: email] with the subject "Data deletion". We will delete it unless we are legally required to keep it, and will let you know once the request has been handled.

10. Children

The App and the Site are not directed to children under 13, or under 16 where local law sets a higher age. We do not knowingly collect personal information from children below these ages. If you believe a child has provided us with personal information, please contact us and we will take steps to delete it.

11. Security

We use reasonable technical and organisational measures designed to protect personal information. However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security.

12. Cookies on the Site

The Site uses only the storage needed to remember your cookie choice unless you accept optional analytics. You can change your choice at any time with the "Review cookies" button at the bottom of every page.

13. Changes to this Policy

We may update this Privacy Policy from time to time. When we do, we will change the "Last updated" date above and, where the changes are significant, provide additional notice, for example in the App. Continued use of the App or the Site after an update means the revised Policy applies.

14. Contact

[TO FILL: company]
[TO FILL: address]
Email: [TO FILL: email]