PP

Privacy Policy

At ATOER, we value your privacy and are committed to protecting your personal data. This Privacy Policy explains how we collect, use, store, and secure your information when you use our network proxy, secure tunneling, and related services (“Services”). We comply with relevant data protection laws such as the General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA), and other applicable regulations. Please read this document carefully to understand your rights and how we handle your personal data.

1. Data We Collect

We collect certain types of information to provide and improve our Services, perform necessary billing operations, and comply with legal obligations. This may include:

• Personal Identification Data: Name, email address, billing address, phone number, or other contact information provided during account registration or support inquiries.
• Financial Data: Payment details (e.g., credit card information, PayPal or other payment processor data) necessary to process your transactions. We utilize secure, compliant payment gateways and do not store full credit card numbers on our own servers.
• Technical and Network Data: Device type, operating system, browser type, and limited non-identifying session data (e.g., timestamps or error logs). This helps us troubleshoot technical issues and improve service stability.
• Usage Data: Interactions with our website (e.g., pages visited, account settings modified) or aggregate statistics related to account usage (e.g., overall bandwidth consumption). These metrics are collected to optimize our Services and are generally not linkable to specific user traffic details.
• Marketing and Communication Data: Email preferences, newsletter sign-ups, and other opt-in communications you choose to receive.

2. Legal Basis for Processing Personal Data

We process personal data in accordance with GDPR, CCPA, and other relevant laws. The primary legal bases include:

• Consent: Where you explicitly agree to our processing of your data for certain purposes (e.g., receiving promotional emails).
• Contractual Necessity: Where processing is required to deliver the Services you request (e.g., account setup, billing, and technical support).
• Legal Obligation: Where laws or regulations mandate data collection or retention (e.g., tax regulations, anti-fraud measures).
• Legitimate Interests: Where processing supports our business objectives (e.g., enhancing security, analyzing performance), provided such interests do not override your fundamental rights.

3. International Data Transfers

As a global service provider, we may transfer your data to data centers or service partners located in countries outside your region of residence. Where such transfers occur, we implement appropriate safeguards, such as Standard Contractual Clauses (SCCs), to ensure compliance with GDPR and other applicable standards.

4. Data Retention

We retain personal data only as long as necessary for the purpose(s) for which it was collected, or as required by law. In general:

• Transaction Records: Retained up to 7 years to meet audit and tax obligations.
• Account-Related Information: Retained until you delete your account or request removal, unless law requires an extended period.
• Marketing Consents: Retained until you opt out or withdraw your consent.
• Service Metrics: Generally aggregated or anonymized, retained for performance monitoring and capacity planning.

5. Your Rights

Under GDPR, CCPA, and other applicable laws, you may have the following rights concerning your personal data:

• Right to Access: Obtain a copy of the personal data we hold about you.
• Right to Rectification: Correct or update inaccurate information.
• Right to Erasure: Request the deletion of your data (“right to be forgotten”) under certain circumstances.
• Right to Restrict Processing: Limit how we use your data if you contest its accuracy or object to certain processing.
• Right to Data Portability: Receive your data in a structured, machine-readable format to transfer to another service.
• Right to Object: Object to processing based on legitimate interests or for direct marketing purposes.
• Right to Withdraw Consent: Where processing is based on consent, you can withdraw at any time without affecting prior lawful processing.

To exercise any of these rights, please email [email protected]. We will respond within one month or as otherwise required by law.

6. Data Security

We utilize technical and organizational measures to protect your data from unauthorized access, alteration, or disclosure. These include:

• Encryption: Sensitive information is encrypted in transit (SSL/TLS), and we partner with PCI DSS-compliant payment providers to secure financial data.
• Access Controls: Only authorized personnel with a valid business need can access your data.
• Security Audits: Routine checks, penetration tests, and audits to identify vulnerabilities and ensure compliance with industry standards.

While we strive to protect your data, no system is entirely foolproof. We continually update our security practices to meet evolving threats and maintain best practices.

7. Third-Party Data Sharing and Processors

We may share certain data with trusted service providers to help operate our business or deliver the Services. These parties are contractually obligated to protect your personal data. Examples include:

• Payment Gateways: To securely process your transactions.
• Data Center or Cloud Providers: For reliable and secure hosting of our infrastructure.
• Analytics or Support Tools: To track performance, troubleshoot issues, or respond to customer inquiries.
• Compliance with Law: We may disclose information if required by law or when we believe it is necessary to protect our rights, users, or fulfill legal obligations.

8. No Traffic Logging Policy

To respect user privacy, ATOER enforces a strict No Logs Policy regarding the content of network traffic passing through our proxies or tunnels. This means:

• We do not monitor, record, or store the websites you visit, the data you send or receive, or any other details of your network activity.
• We do not log your real IP address in a way that associates specific online activities with your account. Any minimal connection metadata (e.g., timestamp, server location) is utilized solely to maintain service quality and is not retained in a user-identifiable format.
• We do not engage in deep packet inspection or content analysis of user traffic. Our network function is purely for routing your data through our secure tunnels.

In rare cases, for the purpose of network troubleshooting or addressing abuse reports, we may keep short-lived diagnostic logs. However, these are anonymized or quickly purged, aligning with our commitment to preserve user privacy.

9. Automated Decision-Making and Profiling

We currently do not use automated decision-making or profiling that could significantly affect your legal rights or interests. If this changes, we will update our Privacy Policy accordingly and provide a clear opt-out mechanism where applicable.

10. Cookies and Tracking Technologies

We use cookies and similar tracking technologies on our website for:

• Authentication and Preferences: To maintain your login session and remember your account settings.
• Performance and Analytics: To analyze website usage, page load times, and user pathways, helping us optimize user experience.
• Security: To detect malicious behavior and safeguard your account from unauthorized access.

You can modify your cookie settings in your browser. However, disabling cookies may limit certain features or functionalities.

11. Updates to This Privacy Policy

We periodically review and may revise this Privacy Policy to reflect changes in our practices or legal requirements. Any significant modifications will be posted on this page and, where required, communicated to you (e.g., by email). The latest revision date is 09/07/2024.

12. Contact Us

If you have any questions regarding this Privacy Policy, or if you wish to exercise any of your rights under applicable data protection laws, please reach out to:

• Email: [email protected]
• Phone: +1 5303009992
• Address: ATOER, 1942 BROADWAY ST STE 314C, BOULDER, CO 80302