Privacy Policy

This privacy statement (“Privacy Policy”) explains the information, collection and use policies of www.privado.com (the “Website”) operated by CodeFuel Ltd. ( “we” or “us” “our”) with respect to your access, use and interaction with the Website or the Privado browser extension (the “Extension” and together with the Website, the “Service” or “Privado”).

Privado provides a secured and private search experience. To ensure your search activity is private, Privado is designed for privacy - it does not store personal information and your search terms are encrypted in the browser history. Moreover, Privado delivers you non-personalized ads.

Please read this Privacy Policy carefully, before using our Service, so you can fully understand our practices in relation to how the Service operates and processes personal and non-personal information.

This Privacy Policy provides you with information about:

  1. What Personal Information Privado Collects
  2. Cookies and Other Technologies
  3. How Privado Uses Information
  4. Security Measures Privado Employs
  5. Sharing Information with Third Parties
  6. Transferring Information from and outside of the European Union
  7. Your Rights
  8. Minors
  9. Notice to Californian Residents – Your California Privacy Rights
  10. Do Not Track
  11. Changes to This Privacy Policy
  12. Contact Privado

The Privado Service does not use tracking technologies such as cookies, web beacons, pixels etc. nor does Privado create user profiles. Privado employs security standards to ensure there is no unauthorized access to any information on its servers. All communications between the Service and our servers is encrypted by HTTPS and TLS protocols. In addition, when using Privado to conduct web search, the search terms are encrypted using the RSA encryption protocol so that they will not be visible in the browser history; Privado also uses local storage to save user settings and preferences.

  1. What Personal Information Privado Collects.

    While you use access or interact with the Service Privado is required to collect the information described below; part of this information may be considered personally identifiable information or personal data as such terms are defined under applicable laws and is necessary to allow us to provide the Service.

    • IP address;
    • User agent string;
    • Search terms.

    In order to prevent “fingerprinting”, Privado stores only the following user agent elements: browser type and operating systems type, while all other user agent elements (such as operating system version, browser version, device version and screen size) are not stored. Privado anonymizes the IP address and only uses an anonymous unique ID which is used for fraud detection purposes and is deleted from the Privado servers after 96 hours. In addition, search terms are encrypted. Information shared with our search partner is further described below under “Sharing Information with Third Parties”.

  2. Cookies and Other Technologies.

    Privado.The Service currently does not use any cookies, anonymous identifiers or other tracking technologies.

  3. How Privado Uses Information; our legal basis to process Information (GDPR only).
    • Provide the Service

    We provide you with search services and functionality including search results of our web search partner, in response to your online search queries. For this purpose, Privado processes your information on the basis of (i) a legitimate interest (i.e. to process the search and provide search results) and/or (ii) the right to disseminate information and the freedom of expression, including the right to receive and impart information and ideas.

    • Detect and prevent fraud on our Service.

    Privado conducts fraud detection on potentially fraudulent and illegal uses of the Service; this fraud detection process is conducted during a period of 96 hours. For this purpose, Privado processes information on the basis of a legitimate interest for preventing fraud.

    • Customer Support.

    We also use support related information you provide us in order to respond to your support inquiries and handle your complaints and feedback. This information is not collected through the Service, but rather it is information you voluntarily provide us when you contact Privado via email or otherwise (such as name, email address and any other information you provide). For this purpose, Privado processes this information on the basis of a legitimate interest (e.g. to process your request, handle your feedback, etc.). We will retain this information for the time it takes to provide you with the support you requested and to handle your complaints. We may keep your information for longer periods in case of disputes and other legitimate reasons described in the next section “Disputes and Enforcement; Applicable law, regulations or Enforceable Governmental Request”.

    • Disputes and Enforcement; Applicable law, regulations or Enforceable Governmental Request.

    We use information and support related information to take action in case of a dispute involving you in connection with the Service and to enforce the terms and conditions applicable to the Service. We also use information to comply with legal and regulatory requirements (e.g., the disclosure of information to law enforcement or tax authorities), and to protect against suspicious or other illegal activities. We will retain such information for the amount of time as required by law to fulfill the above purposes. This may include ensuring that we have an accurate record of your dealings in the event of any complaints or challenges, or if we reasonably believe there is a prospect of litigation relating to your information or dealings.

  4. Security Measures Privado Employs

    We have implemented and will maintain appropriate technical and organizational security measures, policies and procedures designed to reduce the risk of accidental destruction or loss, or the unauthorized disclosure or access to such information appropriate to the nature of the information concerned. As the security of information depends in part on the security of the computer or device you use to communicate with us please be aware that Privado does not control nor responsible for your computer or device security configuration.

  5. Sharing Information with Third Parties.
    • In order to provide the search results, we will need to share IP address, user agent and search terms with our search partner, who provides you with certain aspects of the search services and functionality, including the results of your search queries. Our search partner deletes this information after 96 hours; our search partner’s use of this information is subject to its privacy policy available here https://privacy.microsoft.com/en-US/privacystatement
    • We use Amazon Web Services in servers located in North America and Europe. We use separate servers for the Privado service than servers we use for other services we offer.
    • In order to operate Privado, we grant, on a limited, specific and strict “need to access” basis, access to our parent company and group affiliates. Such intercompany access is covered by an agreement entered into by members of our group (an internal processing agreement) which contractually obliges each member to ensure that information receives an adequate and consistent level of protection.
    • If we are required by law, regulation or competent authority, we may share your information with law enforcement or other competent authorities and any third party as may be required (e.g. to respond to claims or satisfy any legal process, subpoena, or governmental request; or to protect the rights, property, or personal safety of Privado’s users, its partners, or the general public). We will also share this information with our professional advisors in the scope of this purpose.
    • In the event we go through a business transition such as a merger or acquisition by another company, consolidation, change of control, reorganization, or sale of all or a portion of its assets, your information will be among the assets transferred.
  6. Transferring Information from and outside of the European Union

    We will take appropriate steps to ensure that transfers of information are in accordance with applicable laws and carefully managed to protect your privacy rights and interests. To this end, if we as the data controller share your information with our corporate affiliates or third party service providers outside the EEA, we have – prior to sharing your information with such corporate affiliate or third party service provider – established the necessary means to ensure an adequate level of data protection. This may be an adequacy decision of the European Commission confirming an adequate level of data protection in the respective non-EEA country or an agreement on the basis of the EU Model Clauses (a set of clauses issued by the European Commission) or EU - US Privacy Shield certification. We will provide further information on the means to ensure an adequate level of data protection on request.

  7. Your Rights.

    The following rights (which may be subject to certain exemptions or derogations), shall apply to the users of the Service (some of which only apply in certain jurisdictions and/or certain individuals in certain circumstances):

    • You have a right to ask us if we have any information related to you. Your right of access can normally be exercised free of charge. however, we reserve the right to charge an appropriate administrative fee where permitted by applicable law.
    • You have the right to ask us to correct inaccurate or incomplete information concerning you.
    • Right to erasure. The right to obtain the erasure of Information.
    • You have a right to restrict the processing of information, for example in case when we no longer need your such information for the initial purposes for which they were collected.
    • Right to portability. The right to portability allows you to move, copy or transfer information easily from one organization to another.
    • You also have a right to request details of the basis on which your information is transferred outside the European Economic Area, but you acknowledge that data transfer agreements may need to be partially redacted for reasons of commercial confidentiality.
    • You have a right to lodge a complaint with your local supervisory authority if you have concerns about how we are processing information. We ask that you please attempt to resolve any issues with us first, although you have a right to contact your supervisory authority at any time.

    We may ask you for additional information to confirm your identity and for security purposes, before disclosing any such requested information to you or processing your request. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive.

    You can exercise your rights by contacting us – please see the “Contact Privado” section below. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly or inform you if we require further information in order to fulfill your request. In the event that your request, for example, would impact the rights of others, or if we are legally entitled to deal with your request in a different way than initially requested, we will address your request to the maximum extent possible, all in accordance with applicable law.

  8. Minors.

    The Service is not intended for minors in any jurisdiction and you hereby represent that you are not a minor according to you relevant jurisdiction. We reserve the right to request proof of age at any stage, so that we can verify that minors are not using the Service.

    We advise parents and guardians to regularly monitor their children's use of email and other online communications and activities. Control tools that create a safer online environment for children are available from third party online services and software providers. In the event that it comes to our knowledge that a minor is using the Service, we will prohibit and block such a user from accessing the Service and will make all efforts to promptly delete any information with regard to such user, as applicable.

    If you are a parent or guardian who has discovered that your child has submitted his or her information without your consent, please contact us as provided in this Privacy Policy and we will take the necessary steps to remove that information from our database.

  9. Notice to Californian Residents – Your California Privacy Rights.

    California residents who provide us with certain types of personal information (as defined under California Civil Code Section 1798.83 (also known as California’s “Shine the Light” law)) are entitled to request and obtain from us once a calendar year information about the personal information we shared, if any, with other businesses for their own direct marketing use. To make such a request, please contact us through the email or physical address under the “Contact Privado” section below. When making such a request, please ensure that you write in the subject line and the body of your message “Request for California Privacy Information”. Please be aware that not all information sharing is covered by California’s “Shine the Light” law.

  10. Do Not Track.

    Do Not Track is a privacy preference that can be configured in certain web browsers (the "DNT Feature"); the DNT Feature, when enabled on a web browser, signals the websites you visit that you do not want certain information about your visit collected. Privado does not currently respond or recognize DNT Feature signals.

  11. Changes to This Privacy Policy.

    We may, from time to time, change this Privacy Policy. We encourage you to visit and review this Policy frequently to stay informed. Prior to any material change to this Privacy Policy, Privado will present you with a notification (e.g. a pop-up notification or other reasonable means) of such change including information on how you may uninstall the Service (to the extent applicable). Other changes, including amendments made to the Privacy Policy to comply with legal requirements, will become effective immediately upon their initial posting. Privado will also update the "Last updated” date at the bottom of this Privacy Policy. Your continued use of the Service after any change takes effect, will indicate your acceptance of the amended Privacy Policy. If you do not agree with any of the amended terms, you agree that you shall cease any further use of the Service.

  12. Contact Privado.

    If you have any complaints, concerns or questions with respect to any matter covered by this Privacy Policy, you may contact Privado at: info@privado.com or at the following address:

    Data controller:
    CodeFuel Ltd.
    Attention: General Counsel
    10400 NE 4th St, Bellevue,
    WA 98004,
    United States.

    In the EU:

    Attention: General Counsel Luna Arena Herikerbergweg 238 1101 CM Amsterdam
    The Netherlands

Last Updated: November 10, 2019