Privacy Policy

Last updated: 08 December 2023

Our company (Company, We, Us, Astro) respects and values your (User, You) privacy and does all possible to ensure the safety of Your Personal Data (as defined below).

In this Privacy Policy (Policy) We provide information on the extent of the Personal Data collected, explain to You the reasons for its collection and the way We use it, as well as identify third parties with whom Your data is shared.

This Policy forms part of the Astro License Agreement (Agreement) that can be accessed via the following link https://astroproxy.com/en/license-agreement.

We encourage You to review this Policy carefully and to periodically refer to it so that You understand it and any subsequent changes made to it.

Where You do not agree to any terms and conditions of this Policy, You need to immediately cease using the System.

 

Terms and Definitions

In case any of the words used in the text of the Policy starts from the capital letter it shall be understood and interpreted in the way foreseen by the present section of the Policy.

Astro, Company	The private company incorporated under the laws and regulations of the local authority.
System	A set of information, web forms, software and hardware and intellectual property objects (including computer software, database, graphic interface design, content, etc.) that belong to the Company, can be accessed from various User devices connected to the internet through special web browsing software (browser) at “astroproxy.com” domain, including domains of the following levels, as well as all IP addresses to access the System, and be utilized in accordance with the permitted uses as set out in the Agreement for anonymous use of the internet.
You, User	Individuals and authorized representatives of legal entities that conform to the eligibility requirements foreseen by the Agreement, have a registered Account, use the System.
Account	The set of data recorded in the System under the specific User from the moment of a successful registration and including all User interactions with the System.
Registration Data	The Personal Data of the User provided by the individual to the Company by filling in the registration form to register an Account, the full list of which is provided in the relevant section of the present Policy and Agreement.
Personal Data	Any information that relates to an identified or identifiable living individual that Users provide to Company during Account registration, information which is collected about User automatically by the System, information You shared with the Company, as well as information that Company obtains from third parties.
Personal Data Processing	A wide range of operations performed on Personal Data, including by manual or automated means the collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction of Personal Data.
Verification Services	Third-party platforms which have contractual relationships with the Company for execution of enhanced verification of visitors that would like to get status of the User and already registered Users. Verification Services include Sumsub service that can be accessed at https://sumsub.com.
Third-Party Account	The User's account that is registered on third-party platforms and websites, such as Gmail, Facebook, etc., that per User's confirmation can be used for the registration of an Account within the System.

In case this document uses any terms that have not been defined above or under the remaining part of the document, such terms need to be understood in the way they are interpreted in the Agreement, applicable laws, and regulations and only as a last resort according to common practice.

Acceptance of the Policy

You agree to the Policy provisions regulating the Processing of the Communication Data, Registration Data and Verification Data (as described below) by pressing the button “I agree” during Your Account registration within the System.

You agree to the Policy provisions regulating the Processing of the Log Data (as described below) by placing ☑ next to the box “I have read and accept the terms of the Astro Cookies Policy” during Your first visit of the System website.

In case You at any point do not agree with any provision of this Policy, You shall immediately leave the System website and cease using the System.

What Personal Data Do We Collect?

To enable Your access to the System, We will ask You to provide Us with some important information about Yourself.

During Your use of the System, We may collect the following types of Personal Data:

Type	Personal Data
Communication Data	Your email address; Your username and other information available for the public under Your Third-Party Account; Other contact details that You use to contact Us.
Registration Data	For manual registration: Your email address. To register with a Third-Party Account: Your username under the Third-Party Account; Your email address under the Third-Party Account; As well as any other information under the Third-Party Account that is available and can be transferred according to the regulations of such third parties.
Log Data	Technical Information: The internet protocol (IP) address; Browser type and version; Time-zone setting; Browser plug-in types and versions; Operating system and platform. Usage Data: Page response times; Time spent on those pages; Download errors; Time and dates of visits to certain System pages; Click-stream data; Methods used to browse away from the page; Other data collected via cookies and similar technologies. Please read the Astro Cookies Policy for more information.
Verification Data	Such data type consists of information You provide to Us on Our demand or demands of third-parties, including law authorities, and Our requests essential to verify compliance with the Agreement and regulatory framework, including: Your full name; E-mail address; full legal name, date of birth, age, nationality, gender, signature, email address and home address; passport or other photo identification such as a driver’s license or national identification card, other photographs like selfies; user ID, security questions, authentication data, transaction information, financial information, cryptocurrency or wallet addresses; and Other details of Your privacy required to comply with legal obligations, applicable laws and regulations. We are developing the System consistently. The new features introduced may demand access to Your additional private information. You provide Us Personal Data willingly. The refusal to share Your Personal Data with Us may decrease the service quality and/or lead to System access restrictions.

We are constantly developing the System and may add new features, to get access to which You may be asked to provide Us additional information.

You provide Us with any Personal Data on a voluntary basis. However, where You elect not to share with Us Your Personal Data, We may not be able to serve You as effectively and(or) enable Your access to the System.

What is the purpose of Collecting Personal Data?

We collect the aforementioned Personal Data for the following purposes:

Type	Purpose
Communication Data	To provide You with relevant feedback; To contact You for administrative reasons.
Registration Data	To provide access to the System; To ensure network and information security; To provide User support.
Log Data	To ensure network and information security; To ensure normal functioning of the System; To enhance Your System experience; To indicate the errors and weak points of the System and develop it; For other purposes set out in the Policy.
Verification Data	to ensure the safety of Users, Our safety and the safety of third parties.

We will only use Your Personal Data for the purposes for which We collected it, unless We reasonably consider that We need to use it for another reason and that reason is compatible with the original purpose, or We are obliged to process Your data by applicable laws or court/enforceable orders. Where We need to use Your Personal Data for an unrelated purpose, We will notify You and We will explain the legal basis which allows Us to do so.

Please note, upon receiving Your consent, We may provide You with information related to the System.

How Do We Collect Your Personal Data?

We may collect Personal Data from Users in the following ways:

Type	Collection way
Communication Data	We get access to such Personal Data when You reach Us for any questions before Your Account registration to get customer service or for any other purposes (e.g., by email).
Registration Data	You provide Us with this Personal Data, when (i) You fill in and submit relevant application forms and complete the required steps to register an Account on the System or (ii) elect to use the Third-Party Account for registration of Your account in the System and provide relevant authorizations within the relevant third-party website/network.
Log Data	When You interact with the System, We may collect this Personal Data by using cookies, server logs and other similar technologies. Please read the Astro Cookies Policy for more information.
Verification Data	You provide such Personal Data to Us directly or we obtain it from Third-Party web sources according to the permissions You give Us. Verification of the user is done by the Verification Services mentioned above. We obtain information about you from public databases and ID verification partners for purposes of verifying your identity when you sign up for our Services or use our Services. Our ID verification partners use a combination of government records and publicly available information about you to verify your identity. Such information includes your name, address, status on any sanction lists maintained by public authorities, and other relevant data.

How Long Do We Keep Your Personal Data?

We will keep Your Personal Data for no longer than it is necessary for that purpose or its collection.

Generally, We will retain and delete Your Personal Data as follows:

Type	Retention Period
Communication Data	We keep it until the moment We provided You with feedback.
Registration Data	We keep it strictly throughout the life of Your Account and delete it once the System executes the request to delete Your Account. Where required by applicable law, Personal Data may be retained after the Account is closed within the period prescribed by such laws.
Log Data	We keep it strictly throughout the life of Your Account and delete it once the System executes the request to delete Your Account. Where required by applicable law, Personal Data may be retained after the Account is closed within the period prescribed by such laws
Verification Data	We keep it strictly throughout the life of Your Account and delete it once the System executes the request to close Your Account, however, in any case, not less than it is necessary to achieve the processing objectives. Where required by applicable law, Personal Data may be retained after the Account is closed within the period prescribed by such laws.

Legal Compliance

Please note, that We can keep Your Personal Data for a longer period where it is required by the relevant laws and regulations. Company retains some of the Personal Data after the closure of Your Account in order to deter fraud, by ensuring that persons who try to commit fraud will not be able to avoid detection simply by deleting their account and opening a new account, and to comply with Our legal obligations.

What is the Legal Basis for Processing Personal Data?

The processing of Personal Data is performed in accordance with privacy rights and regulations following the EU General Data Protection Regulation (GDPR), the Agreement and Our local regulations.

Where regulations of the country of Your locations provide for stricter Personal Data standards, the processing of Your Personal Data will be effectuated in accordance with these standards.

Generally, the legal grounds for the Personal Data Processing could be listed as follows:

Your Consent. Insofar as You have granted Us consent to the processing of Personal Data for specific purposes, the lawfulness of such processing is based on Your consent. Giving Us Your consent to the processing of Your Personal Data is voluntary. Any consent granted may be revoked at any time. Please be advised that the revocation shall only have effect for the future. Any processing that was carried out prior to the revocation shall not be affected thereby.

Agreement Performance. It means processing Your data where it is necessary for the performance of an agreement to which You are a party or to take steps at Your request before concluding an agreement. This includes the Agreement.

Our Legitimate Interest. It means Our interest to conduct and manage Our business affairs appropriately and responsibly, to protect the reputation of Our business, and to provide You with the best possible Services and secure experience.

Legal Compliance. We process Your Personal Data where it is necessary for compliance with a legal or regulatory obligation.

 

Do We Transfer or Share Your Personal Data To (With) Others?

We sometimes need to share Personal Data We process with third parties. Please find below the list of the limited third parties with whom We may share Your Personal Data:

1. Business partners, suppliers, and sub-contractors are involved in order to provide You access to the System.
   
   We require all affiliated entities to respect the security of Your Personal Data and to treat it in accordance with the law. We do not allow them to use Your Personal Data for their own purposes and only permit them to process Your Personal Data for specified purposes and in accordance with Our documented instructions.
   
   
2. Courts and(or) government authorities and(or) law enforcement officials in cases where it is required by the laws and regulations.
   
   We will only use and share Your Personal Data where it is necessary for Us to lawfully carry out Our business activities.
   
   
3. Analytics and search engine providers that assist the Company in the improvement and optimization of the System.
   
   We can guarantee You, that We will not sell, exchange, or share with any third parties Your Personal Data without Your expressed consent.
   
   
4. Other Users (IP address).
   If You access the System under the Providing Proxy mode (as it is specified in the Agreement), You grant Us the right to use the IP address of your internet-connected device to provide to other Users who access the System under the Receiving Proxy mode. We ensure that the IP address will be shared with other Users in isolation from Your other personal information, and only upon request.

Do We Transfer Your Personal Data Overseas?

In order to facilitate Our global operations, Our Company may use the services of overseas data processing service providers, unless Your jurisdiction laws and regulations limit such data transfer.

We hereby warrant You that We will only transfer Your Personal Data to countries that have been deemed to provide an adequate level of protection for Personal Data by the European Commission. We will make all possible efforts to ensure protection of Your Personal Data in accordance with this Privacy Policy wherever Your Personal Data is processed and will take appropriate contractual or other steps to protect the relevant Personal Data in accordance with applicable laws.

Where such service providers are not established in a country ensuring an adequate level of protection within the meaning of Regulation (EU) 2016/679, such as the United States, the transfers will be covered by the standard data protection clauses adopted by the European Commission or by another appropriate safeguard mechanism such as the Privacy Shield Framework.

Where You access the System under the Providing Proxy mode, Your IP address may be transferred to other Users, including those who may be located abroad. Therefore, accessing the System under the Providing Proxy mode, You consent to such a transfer.

How Do We Secure Your Personal Data?

We have implemented several technical, organizational, and administrative measures to ensure the confidentiality, integrity, availability, and privacy of Your Personal Data and to protect Your Personal Data from loss, theft, unauthorized access, misuse, alteration, or destruction which are generally accepted by the industry to protect the Personal Data in its possession.

These measures include but are not limited to the implementation of current security technologies: Secure Sockets Layered (SSL) technology to ensure that Your Personal Data is fully encrypted and sent across the internet securely, secure coding principles, and regular penetration testing.

We also use encryption (HTTPS/TLS) to protect data transmitted to and from the System. Transport Layer Security (TLS) is a protocol that provides privacy and data integrity between two communicating applications. It's the most widely deployed security protocol used today and is used for web browsers and other applications that require data to be securely exchanged over a network, such as file transfers, instant messaging, and voice over IP.

Only authorized Company personnel have access to the Personal Data, and these personnel are required to treat the Personal Data as confidential. The security measures in place will, from time to time, be reviewed in line with legal and technical developments.

If You become aware of any potential data breach or security vulnerability, You are requested to contact Us immediately. We will use all measures to investigate the incident, including preventive measures, as required.

Your Rights

Your principal rights as the Personal Data subject include the following:

1. Right to access Personal Data. You may request Us to provide You a copy of Your Personal Data that We have access to. We will provide You with such information within a reasonable period and may require You to compensate for the expenses associated with gathering the information.
2. Right to Personal Data rectification. You may request Us to rectify or update any of Your Personal Data. You can do this with the use of relevant System functionality or by contacting Us directly. The Company reserves the right to reject personal assistance where rectification of Personal Data is available through the System functionality.
3. Right to Personal Data deletion. You may request Us to erase Your Personal Data, subject to applicable law. Please note, that in some cases the System will automatically delete Your Personal Data when You delete Your Account. However, if You delete Your Account, We will not use Your Personal Data for any further purposes, nor share it with third parties, except as required by the law. Please note, that We may not always be able to comply with Your request of erasure for specific legal reasons which will be notified to You, if applicable, at the time of Your request.
4. Right to withdraw consent. To the extent the processing of Your Personal Data is based only on Your consent, You may withdraw Your consent at any time. This will not affect the lawfulness of any processing which was carried out before the withdrawal. Please note, any processing activities that are not based on Your consent will remain unaffected.
5. Right to restrict processing. In some jurisdictions, applicable law may give You the right to restrict or object to Us processing or transferring Your Personal Data under certain circumstances. We may continue to process Your Personal Data if it is necessary for the defense of legal claims, or for any other exceptions permitted by applicable law.

Kindly note that none of the rights is absolute, meaning that they must generally be weighed against Our own legal obligations and legitimate interests. If a decision is taken to override Your request, You will be informed of this by Us along with the reasons for Our decision. To exercise such rights, You may contact Us at [email protected].

Links to Other Websites

The System may contain links to external websites/platforms maintained by Third-Party Service Providers, whose Personal Data and privacy practices are different from Ours.

The Company is not responsible or liable for the Personal Data or privacy practices employed by such third parties. We strongly recommend that You read the privacy statements of all third-party websites before using such websites or submitting any Personal Data or any other information on or through such websites.

Information about children

We intentionally do not collect Personal Data from children under the age of 13 or individuals of any other age where they require consent or permission of their guardians or other authorized persons to permit their Personal Data Processing. Where You are a parent or guardian and become aware of providing by Your child or person under Your guardianship their Personal Data to Us please inform Us immediately. When We become aware that We have collected children's Personal Data without verifying parental consent where necessary, We will take steps to delete their Personal Data from Our servers.

Change of Ownership

You hereby acknowledge and agree that in the event of a change of ownership or control of all or a part of the Company, including without limitation through acquisition, merger, or sale, the Company can transfer all or part of the Personal Data to the successor to the Company.

Policy Amendment

This Policy may be revised, updated and(or) amended at any time without prior notice at the Company's discretion. If such amendments are made, the date when this Policy was updated will be displayed on the first page of the Policy.

You undertake at Your own risk to keep Yourself updated with the Policy amendments. We strongly recommend that You do the following: (i) memorize/make a note of the date of last update provided in the document (e.g. to save its copy) upon the initial registration of Account and any time upon amendment of the Policy, (ii) visit on a regular basis the relevant page of the System website and study the entire Policy in case of change in the update date.

By using the System after the Policy has been amended, You automatically confirm Your consent to the amended Policy. If You do not agree with any amendment of this Policy, You shall immediately cease all use of the System.