This Privacy Policy is last updated on September 2, 2022

This Privacy Policy describes the way in which Foxy Upgrader deals with the information and data you provide to us to enable us to manage your relationship with Foxy Upgrader.

We will process any personal information provided to us or otherwise held by us relating to you in the manner set out in this Privacy Policy. Information may be provided via the Foxy Upgrader Website (the "Website") or any other means.

By accepting this Privacy Policy you agree that you understand and accept the use of your personal information as set out in this policy.  If you do not agree with the terms of this Privacy Policy please do not use the Website or otherwise provide us with your personal information.

References in this Privacy Policy to “Foxy Upgrader” (hereinafter referred as “We”, “us” or “our”) shall mean Foxy Upgrader (the “Website” or “Site”). We offer and provide Internet-based premium services. We control the ways your Personal Data is collected and the purposes for which your Personal Data is used by Foxy Upgrader, acting as the “data controller” for the purposes of applicable data protection legislation.

• We protect, according to strict standards of security and confidentiality, all non-public personal information we collect about our customers;
• We maintain physical, electronic and organizational safeguards to protect this information;
• We require any party providing products to us or our customers on our behalf to protect the confidentiality of this information;
• We permit only authorized employees and contractors, including but not limited to Support and Fraud team to have access to non-public information of yours;
• We afford former customers the same protections as existing customers with respect to the use and sharing of their information;

Your Personal Data isn’t just protected by the quality, commitment and high standards of Foxy Upgrader, it’s also protected by law. We can only process your Personal Data when there is a genuine reason to do so and it must meet one of the following:

• contractual relationship
• legal obligation
• your consent to process
• our legitimate interest
• public interest
• your vital interests

When We have a business or commercial reason to process your Personal Data this is referred to as a legitimate interest. Your Personal Data is still protected and We must not process it in a way that would be unfair to you or your interests.

If We do use legitimate interests as a reason to process your Personal Data We will tell you that We are doing so, what our legitimate interests are and provide you with a method to raise any questions or objections you may have. However, compelling grounds for processing such information may over-ride your right to object.

Considering legal obligations undertook to fulfill the contract signed between us and the customers, including and not limited to the legal obligations undertook to comply with laws or regulations that apply to us, and for to be efficient about how We fulfil our legal and contractual duties, We process your Personal Data in order to:

• Manage customer relationship
• Develop and manage our brands, new and existing products and Services for our customers, grow our business
• Create, develop, send and review marketing
• Learn from our customers’ behavior in relation to our product and Services
• To provide support for our products and Services
• To test new products, systems or Services
• To compare and manage our relationship with and the performance of other companies that provide Services to us and our customers
• Deliver quality products and Services to you
• Investigate, resolve and respond to any customer complaints
• Prevent and detect improper use of our systems
• Prevent crime happening
• Detect, investigate and report crime
• Managing risk for us and our customers
• Complying with any laws and regulations that apply to us
• Ensure corporate governance and compliance to all legal and regulatory obligations
• Fulfil our obligations as an accountable and responsible organization
• To exercise our rights set out in agreements or contracts

Internal reporting

If you choose not to provide your Personal Data it may prevent us from meeting legal obligations, fulfilling a contract, or performing Services required to run your account. Not providing your Personal Data may mean We are unable to provide you with products or Services.

The information and data about you which We may (Please, note that the scope of the information provided below is not mandatorily collected/stored/used/processed by us, Foxy Upgrader reserves a right to collect/store/use/process data in certain cases when necessary for the various purposes stated in this Privacy Policy) collect, store, use and process may include but not exceed the following:

1. Personal Information:

1.1. Account details: when you open an account and register to use the Services, you may be asked to provide us certain details about yourself, such as: email address.

1.2. Voluntary information: We also collect information which you provide us voluntarily. For example, when you respond to communications from us, communicate with us via email or share additional information about yourself through your use of the Services, such as on the live chat with the support team.

2. Non-personal Information:

2.1. Log-in history and technical information: In order to enhance the functionality of the Services and to provide you with a better user experience, We collect technical information transmitted by your device, including certain software and hardware information (e.g. the type of browser and operating system your device uses, language preference, access time and the domain name of the Website from which you linked to the Services; etc.).

2.2. Analytic information: We may collect information about your use of the Services, such as applications' usage, log files, user activity (e.g. pages viewed, the amount of time spent on particular pages, online browsing, clicks, actions, etc.), time stamps, alerts, etc. This information is collected for amongst other things troubleshooting errors and bugs as well as for research and analytics purposes about your use of the Services.

2.3. Anonymous information: We may anonymize or de-identify the information collected by the Services or via other means so that the information cannot, on its own, personally identify you. Our use and disclosure of such aggregated or de-identified information is not subject to any restrictions under this Privacy Policy, and We may disclose it to others without limitation and for any purpose, such as for advertising or marketing purposes.

Where it is reasonable for us to do so and not detrimental to your rights and freedoms, We may also collect Personal Data from publicly available sources such as internet searches, social media or broadcast media.

Whenever your data is kept by Foxy Upgrader We will ensure that it is appropriately protected and only for acceptable purposes.

We will keep your data for the period that you are a customer of Foxy Upgrader. If you are no longer a customer of Foxy Upgrader, We will keep your data for 10 years as required to comply with the purposes set out in this policy. Your personal records will be kept even if the customer account is blocked/deactivated/deleted/otherwise no longer active or cannot be deleted for technical reasons.

When necessary for the following purposes, We may share your Personal Data within the Foxy Upgrader group and with other organizations stated below:

• Law enforcement agencies, regulators and other authorities
• Credit reference agencies
• Fraud prevention agencies
• Organizations that introduce you to us
• Third parties you ask us (or permit us) to share your data with
• Third parties necessary to provide products or Services which you have requested

Your personal information may be transferred between the countries and disclosed to other companies within associated or subsidiary companies and to business partners, or successors in title to our business.

We take great care in implementing and maintaining the security of the Services and your information. We have put in place appropriate physical and technological safeguards to help prevent unauthorized access, to maintain data security, and to use correctly the information We collect online. These safeguards vary based on the sensitivity of the information that We collect and store.

We employ industry standard procedures and controls to ensure the safety of our users’ information, such as:

• Secure network topology, which includes intrusion prevention and Firewall systems;
• Encrypted communication;
• Authentication and Access Control;
• External and Internal audit tests, etc.

The Website uses cookies to deliver a better and more personalized Service to users.

Cookies are small text files containing minimum amounts of information which are sent to and stored on your computer, smartphone or other device when you access a Website. Cookies are then sent back to the originating Website on each subsequent visit or to another website that recognizes that cookie.

Cookies are generally used to improve and enhance the user experience. Some of the cookies We use are essential for the Website to operate.

Foxy Upgrader’s use of cookies on the Website falls into the following categories:

• Session Management
• Functionality
• Fraud Prevention
• Tracking
• Analysis

Third party advertising companies/affiliates, that work with us, may also use cookies and related technologies to collect and store Information to provide you with advertisements that are likely to interest you.

You can find more information about cookies at  www.allaboutcookies.org.

We will assist you if you choose to exercise any of your rights over your Personal Data, including:

• Lodging a complaint with any relevant Data Protection Authority
• Access to your Personal Data that We hold or process
• Correction of any Personal Data that is incorrect or out of date
• Erasure of any Personal Data that We process
• Please be noted, that upon your request We can delete any Personal Data after the account is blocked/deactivated/deleted/otherwise no longer active, except email. We reserve the right to keep the email to avoid unlawful registering using the same email, even though, standalone email is not considered as Personal Data
• Personal Data cannot be deleted when the account is temporarily suspended upon your request. We reserve the right to keep the Personal Data in order to match the information when the account is pending to be reopened.
• Asking us to provide you or another company you nominate with certain aspects of your Personal Data, often referred to as “the right to portability”
• The ability to object to any processing data where We are doing it for our legitimate interests
• The ability to contest a decision made entirely by automated processing, to express your point of view and to request that a human review the decision

For more information on these rights you can contact  [email protected]

If you have any concerns, or would like more detail about how We process your Personal Data, you can contact us at [email protected]