Last Modified: May 8, 2018

Kinner Lake limited ("Company" or "us" or "our" or "we") respects user’s (“user(s)” or “you”) privacy and is committed to protect their privacy. This Privacy Policy (“Privacy Policy”) sets forth the privacy practices of the Company which applies to users that use its software (“Software”).

We highly recommend you read this Privacy Policy carefully prior to installing accessing or using our Software.

Definitions herein shall have the same meaning as defined in the End User License Agreement (“EULA”).

This Privacy Policy is a part of the Company's EULA (collectively “Terms”) and is a legally binding agreement between the user and the Company. The Terms shall be binding upon any use or attempt to use the Software. By downloading or installing or using the Software, you hereby agree to the Terms and to the access, collection, use and disclosure of certain information, as described in this Privacy Policy.

IF YOU DO NOT AGREE TO THESE TERMS, PLEASE DO NOT DOWNLOAD, INSTALL ACCESS OR USE THE SOFTWARE IN ANY MANNER.

If you have any questions comments or concerns about this Privacy Policy, please contact us at: flowsurfnet@gmail.com.

What Information Do We Collect?

Non-Personal Information:
We may collect two types of information from our users. The first type of information we collect is aggregated, non-identifiable information, which may be made available or gathered via your use of the Software, meaning, we are not aware of the identity of the user from which the Non-Personal Information was collected (“Non-Personal Information”).

The Non-Personal Information collected includes:

  • technical information transmitted by your device such as type of operating system, device type, default browser;
  • your aggregated use of the Software, basically we know if you installed the software;
  • usage statistics;
  • language and the time stamp;
  • approximate geographical location.

Personal Information
The second type of information which may collect is individually identifiable information, namely information that identifies an individual or may with reasonable effort identify an individual (“Personal Information”), the Personal Information we collect through the Software includes the following:

  • Contact Information” – we may receive Contact Information, when you choose to provide us with such information, if and when you contact us for support. Contact Information shall not be stored and shall be deleted immediately after providing you with support.
  • Identifiers” - we may collect certain identifiers such as your IP addresses. Note that, while Identifiers are considered personally identifiable information in many jurisdictions (such as the EEA), there are some jurisdictions in which such data sets are not considered as Personal Information. Thus, we treat such information as Personal Information, in accordance with applicable laws.
  • Search Queries and Browsing History” – we may collect the some of you search history solely upon installation of the Software in order to provide the Services, this data is not stored and, in any event, will be deleted immediately.

In addition, any Personal Information which is combined with Non-Personal Information, the combined information will be treated as Personal Information for as long as it remains combined.

Purpose of Collection and Use

We collect Personal Information for the following purposes:

  • The legitimate interest of operating the Service and for the necessity of providing the service.
  • To detect, prevent, or otherwise address fraud, security or technical issues.
  • To respond to users' support requests and feedbacks.

We collect Non-Personal Information for the following purposes:

  • Operating the service.
  • To improve, refine, customize and develop the Software.
  • To perform research, analytics or for statistical purposes.

Age Limitation

You represent and warrant that, (i) in the event that you are located in the US, you are at least 13 years of age; or if you are located in any other location (except for the US), you are above the age defined as “child” under applicable laws in your jurisdiction (collectively “Child” or “Children”); and (ii) you are of legal competence to enter into this Privacy Policy. If you are under 18, please be sure to read the terms of this Privacy Policy with your parents or legal guardians. The Software is not directed or intended for Children, as defined under applicable law, and we do not knowingly collect or solicit information from children. If we obtain actual knowledge that a User is considered as a Child under applicable law, we will take steps to immediately delete such User’s Personal Information. If you become aware or have any reason to believe that a Child has shared any information with us, please contact us immediately at dpo@flowsurf.net

Sharing Information with Third Parties

Company will not share any Personal Information collected from you with either directly or indirectly with third parties or any of our partners except as follows, and solely if applicable:

  • we may disclose or share Identifiers collected by us (as detailed above), for the purpose of operating our business and providing the Software, as well as to calculate payments and detect fraud, security or technical issues in connection with the Software;
  • we may disclose your Personal Information to third parties when you consent to a particular disclosure. Please note that once you provide such consent, your information and its use shall be subject to other third party’s privacy practices and terms;
  • we will share your Personal Information, solely to the extent needed to comply with any applicable law or permitted by it, regulation, legal process or governmental request (e.g., pursuant to law enforcement inquiries, subpoenas or court orders), or when we believe, in good faith, it is required in order to enforce our policies.
  • we may share Personal Information, in the event of a corporate transaction (e.g. sale of a substantial part of our business, merger, consolidation or asset sale), as well as with our parent company, any subsidiaries, joint ventures, or other companies under a common control. In such event, our affiliated companies or acquiring company will assume the rights and obligations as described in this Privacy Policy.
  • By downloading or installing or using the Software, or by accepting this Privacy Policy, you also consent to the third-party policies, whose products might be offered to you as part of the Service, such as Oath which it’s privacy policy available here: https://policies.oath.com/us/en/oath/privacy/products/searchservices/index.html) ("Third Party's Policies"). Our service providers may also provide ways for you to opt out from or limit their collection of information from and about you, such as detailed above or as follows: https://aim.yahoo.com/aim/us/en/optout/

We may share your Non-Personal Information for the same purposes as detailed above with respect to Personal Information. Further, we may share your Non-Personal Information with third party service provider partners (i.e., Google Analytics, search feed providers, affiliates, customer service, marketing assistance, ad tracking, service functionality and support, etc.) (“Service Providers”) and other third parties in accordance with the terms of this Privacy Policy.

Cookies and Other Technologies

Company and its Service Providers use certain cookies and other technologies (e.g. web beacons, pixels, etc.), when you use the Software. Cookies are small pieces of information that is assigned to your device. Cookies can be used for various different purposes, such as: costume and improve the services, enabling you to navigate between pages efficiently, enable automatic activation of certain features, etc. You can find more information about cookies at www.allaboutcookies.org.

We gather some information automatically, such as your usage data, by ourselves or by using third party service and store it in log files. You may use your device or browser’s settings to disable some cookies. Please note that, if you choose to disable cookies, some features of our Services who rely upon the use of cookies, may not operate properly.

We use Google Analytics cookies, to learn more how Google uses data from our use of Google Analytics Cookie we recommend you review Google’s policies located at: www.google.com/policies/privacy/partners. We also encourage you to review the Google Analytics' currently available opt-outs for the web tool available at: https://tools.google.com/dlpage/gaoptout/.

Further, our third party partners such as Oath may use cookies when you use their services through our software, for more information please review the applicable privacy policy: https://policies.oath.com/us/en/oath/privacy/products/searchservices/index.html

For more information about cookies and your controls in this regard, you may review the following links:

Data Security

Your privacy is very important to us and we are committed to protecting your information from unauthorized access, use or disclosure. We have implemented certain physical, technical and administrative security measures for the Services that comply with applicable laws and industry standards. For additional information regarding our security practices, please see Security.

Company pursues the minimization regarding the amount of data that it stores on its servers. If you feel that your privacy was treated not in accordance with our Privacy Policy, or if any person attempted gain unauthorized access to the Personal Information please contact us at: dpo@flowsurf.net. Further, in the event of a data incident, in which we discover your Personal Information may be at risk, then we will take reasonable efforts to notify you and the applicable authority (if required, subject to applicable laws).

Links to Third Party Content

Our Software may link to Third Party Content (as defined in our EULA), whose privacy practices may differ from ours. Please note that these features are provided by us only as a suggestion. We are not, and won’t be held responsible to privacy practices established by third party providers, thus, we encourage you to carefully read the privacy policies and terms of use of those third parties.

Data Retention

We may rectify, replenish or remove incomplete or inaccurate information, at any time and at our own discretion. We retain the Non-Personal Information we collect for as long as needed to provide the Service and to comply with our legal obligations, resolve disputes and enforce our agreements. Furthermore, we retain Personal Information, we collect for as long as legal permissible, in accordance with applicable laws.

User Rights

If you feel that your privacy was treated not in accordance with our policy, or if any person attempted to abuse the Company please contact us dpo@flowsurf.net directly.

Applicable data protection and privacy laws may provide you with the ability to exercise some user rights regarding your Personal Information collected by the Company (which might be different in each jurisdiction).

(i) if applicable, you may request to access your Personal Information that we hold; (ii) you may request the rectification of your Personal Data that we hold; (iii) you may request the erasure of your Personal Information that we hold (as long as we do not have a legitimate reason for retaining the data); (iv) you may request to restrict processing of your Personal Information; (v) you may object to processing of your Personal Information by us (however, in this event we might not be able to provide you with all features of the Services or the content we provide may not of interest to you); (vi) you may request to exercise your right of data portability; (vii) you may exercise your right to file a complaint to a supervisory authority in your jurisdiction; and (viii) you have the right to withdraw consent.

We value your privacy and control over your information, and therefore you may, at any time, make such request by contacting our Data Protection Officer at: dpo@flowsurf.net. We will respond within a reasonable time, and may require certain information from you in order to verify your identity and locate your data. Note that, the process of locating and deleting the data may take up to one (1) month, in accordance with applicable laws. Data privacy and related laws in your jurisdiction may provide you with different or additional rights related to the data we collect from you, which may also apply.

Data Transfer

We may store or process your Personal Information in the United States or in other countries. If you are a resident of the European Economic Area ("EEA") we will take appropriate measures to ensure that your personal data receives an adequate level of data protection upon its transfer outside of the EEA. If you are a resident of a jurisdiction where transfer of your personal data requires your consent, then your consent to this Privacy Policy includes your express consent for such transfer of your data.

Do Not Track Disclosure

The Software does not respond to Do Not Track signals. For more information about Do Not Track signals, please see: http://www.allaboutdnt.com.

Further Questions?

If you have any general questions about the Software or the information that we collect about you and how we use it, please contact us at: dpo@flowsurf.net

Data protection officer

Please feel free to contact our data protection officer at: dpo@flowsurf.net

Changes to the Policy

WE RESERVE THE RIGHT TO PERIODICALLY AMEND OR REVISE THIS PRIVACY POLICY FROM TIME TO TIME, AT OUR SOLE DISCRETION. THE MOST RECENT VERSION OF THE PRIVACY POLICY WILL ALWAYS BE POSTED. IF WE DO MAKE ANY CHANGES, THE UPDATED DATE AT THE TOP OF THE PRIVACY POLICY WILL BE REFLECTED IN THE “LAST MODIFIED” HEADING. IF WE MAKE ANY MATERIAL CHANGES, THAT WILL SUBSTANTIALLY AFFECT YOUR USE OF THE SOFTWARE OR THE DATA COLLECTION BY US, WE WILL MAKE BEST EFFORTS TO PROVIDE YOU WITH NOTIFICATIONS. WE ENCOURAGE YOU TO REVIEW THE PRIVACY POLICY PERIODICALLY TO ENSURE THAT YOU UNDERSTAND HOW WE COLLECT, USE AND SHARE INFORMATION THROUGH THE SOFTWARE. ANY CHANGES TO THIS PRIVACY POLICY WILL BECOME EFFECTIVE IMMEDIATELY UPON THE DISPLAY OF THE REVISED PRIVACY POLICY. YOUR CONTINUED USE OF THE SOFTWARE FOLLOWING THE DISPLAY OF SUCH REVISED PRIVACY POLICY, CONSTITUTES YOUR ACKNOWLEDGEMENT AND CONSENT OF SUCH AMENDMENTS AND YOUR AGREEMENT TO BE BOUND BY THE TERMS THEREIN.