Merge branch 'correct-description-of-information-collection-in-privac…

…y-policy' of https://github.com/AdguardTeam/LegalDocs into correct-description-of-information-collection-in-privacy-policy

README.md

@@ -10,3 +10,7 @@ to `https://adguard.com/eula.html`.
 Translations need to be done internally and are not stored in this repo.
 On the website we must indicate that the document was translated and point to
 the original version in English language.
+
+See the README file for each website to see how the links to the legal documents should be listed on these websites.
+All links to legal documents in the footer should be arranged alphabetically.
+The same applies to the list of other documents at the end of each legal document.

adguard-dns.io/README.md

@@ -1,8 +1,24 @@
 
 # AdGuard DNS Documents
 
-- [eula.html.md] - AdGuard DNS End User License Agreement.
+- [eula.html.md](eula.html.md) - AdGuard DNS End-User License Agreement.
+- [privacy.html.md](privacy.html.md) - AdGuard DNS Privacy Policy.
 
-- [privacy.html.md] - AdGuard DNS Privacy Policy.
+## List of documents in the footer
 
-- [website.html.md] - AdGuard DNS Website & Cookies Privacy Notice.
+- [EULA](eula.html.md)
+- [Privacy policy](privacy.html.md)
+- [Privacy policy of AdGuard websites](adguard.com/website-privacy.html.md)
+- [Refund policy](https://adguard.com/en/terms-of-sale.html)
+- [Terms and conditions](https://adguard.com/en/terms-and-conditions.html)
+- [Terms of sale](https://adguard.com/en/terms-of-sale.html)
+
+All links to legal documents in the footer should be arranged alphabetically. The same applies to the list of other documents at the end of each legal document.
+
+For example, this is what it should look like when you open the Privacy policy:
+
+- [EULA](eula.html.md)
+- [Privacy policy of AdGuard websites](adguard.com/website-privacy.html.md)
+- [Refund policy](https://adguard.com/en/terms-of-sale.html)
+- [Terms and conditions](https://adguard.com/en/terms-and-conditions.html)
+- [Terms of sale](https://adguard.com/en/terms-of-sale.html)

adguard-dns.io/privacy.html.md

@@ -1,7 +1,7 @@
 
 # AdGuard DNS Privacy Policy
 
-*April 10, 2024*
+*August 6, 2024*
 
 ## Summary
 
@@ -18,7 +18,7 @@ Below, we list all the information we may process via AdGuard DNS and explain wh
 
 ## Who we are
 
-ADGUARD SOFTWARE LIMITED (“We”, “Our” or “Us”) collects and processes your personal data in accordance with this Privacy Policy and in compliance with the applicable data protection laws. This Policy informs you of  your rights and our obligations and explains how, why, and when we process your personal data. Our general principle is to collect only the information necessary to provide you with full functionality of our products and services. We strictly follow the principle of “minimization” when processing your data.
+ADGUARD SOFTWARE LIMITED (“We”, “Our” or “Us”) collects and processes your data in accordance with this Privacy Policy and in compliance with the applicable data protection laws. This Policy informs you of  your rights and our obligations and explains how, why, and when we process your personal data. Our general principle is to collect only the information necessary to provide you with full functionality of our products and services. We strictly follow the principle of “minimization” when processing your data.
 
 ADGUARD SOFTWARE LIMITED is a company registered in Nicosia, Cyprus, registered office is at Klimentos 41-43, KLIMENTOS TOWER, Flat/Office 25, 1061, Nicosia, Cyprus. ADGUARD SOFTWARE LIMITED acts as the data controller when processing your data.
 
@@ -65,13 +65,11 @@ All this data that we process is not shared with any third parties. It is used s
 
 You can also provide us with your consent to process your email for sending marketing messages about our other software or services. You can withdraw your consent any time by unsubscribing from our newsletter via AdGuard Account or by clicking the “Unsubscribe” button or link in the email itself.
 
-**Cookies.** We use our cookies for personalizing the content of the AdGuard DNS website, such as setting the default language. None of the information we may acquire through the use of cookies is considered Personal Data as it does not allow us to identify you. You can always disable or clear cookies in your browser, but please note that some of our services may not function properly without the aid of cookies. Please refer to the Privacy Policy of AdGuard Websites for details: <adguard.com/website-privacy.html>.
+**Cookies.** We use our cookies for personalizing the content of the AdGuard DNS website, such as setting the default language. None of the information we may acquire through the use of cookies is considered Personal Data as it does not allow us to identify you. You can always disable or clear cookies in your browser, but please note that some of our services may not function properly without the aid of cookies. Please refer to the [Privacy Policy of AdGuard Websites](https://adguard.com/website-privacy.html) for details.
 
-**Buying a subscription.** If you purchase  a subscription to Private AdGuard DNS, we’ll use the email address you provide  to send you information about your purchase. We’ll also use your email address to create an account for you. This account will allow you to manage your purchased subscription.
+**Buying a subscription.** If you purchase a subscription to Private AdGuard DNS, we’ll use the email address you provide to send you information about your purchase. We’ll also use your email address to create an account for you. This account will allow you to manage your purchased subscription.
 
-We’ll also use your email address to create an account for you. This account will allow you to manage your purchased subscription.
-
-We conduct all transactions via the Paddle payment provider [Paddle.com Inc.](https://www.paddle.com/) to enable payments if you purchase a subscription to use our software and services. The data processed depends on the payment provider and may include the following:
+We conduct all transactions via the Paddle payment provider [Paddle.com Market Ltd](https://www.paddle.com/) to enable payments if you purchase a subscription to use our software and services. The data processed depends on the payment provider and may include the following:
 
 - Email address
 

adguard-vpn.com/README.md

@@ -1,18 +1,35 @@
 
 # AdGuard VPN Documents
 
-- [eula.html.md] - AdGuard VPN End User License Agreement.
-
-- [policy.html.md] - AdGuard VPN Privacy Policy.
-
-- [ios.html.md] - AdGuard VPN for iOS Privacy Notice.
-
-- [android.html.md] - AdGuard VPN for Android Privacy Notice.
-
-- [mac.html.md] - AdGuard VPN for Mac Privacy Notice.
-
-- [windows.html.md] - AdGuard VPN for Windows Privacy Notice.
-
-- [extension.html.md] - AdGuard VPN Browser Extension Privacy Notice.
-
-- [website.html.md] - AdGuard VPN Website & Cookies Privacy Notice.
+- [eula.html.md](eula.html.md) - AdGuard VPN End-User License Agreement.
+- [policy.html.md](policy.html.md) - AdGuard VPN Privacy Policy.
+- [extension.html.md](privacy\extension.html.md) - AdGuard VPN Browser Extension Privacy Notice.
+- [android.html.md](privacy\android.html.md) - AdGuard VPN for Android Privacy Notice.
+- [ios.html.md](privacy\ios.html.md) - AdGuard VPN for iOS Privacy Notice.
+- [mac.html.md](privacy\mac.html.md) - AdGuard VPN for Mac Privacy Notice.
+- [windows.html.md](privacy\windows.html.md) - AdGuard VPN for Windows Privacy Notice.
+
+## List of documents in the footer
+
+- [EULA](eula.html.md)
+- [Privacy policy](policy.html.md)
+- [Privacy policy of AdGuard websites](adguard.com/website-privacy.html.md)
+- [Terms and conditions](https://adguard.com/en/terms-and-conditions.html)
+- [Terms of sale](https://adguard.com/en/terms-of-sale.html)
+
+All links to legal documents in the footer should be arranged alphabetically. The same applies to the list of other documents at the end of each legal document.
+
+For example, this is what it should look like when you open the Privacy policy:
+
+Other documents:
+
+- [EULA](eula.html.md)
+- [Privacy policy of AdGuard websites](adguard.com/website-privacy.html.md)
+- [Terms and conditions](https://adguard.com/en/terms-and-conditions.html)
+- [Terms of sale](https://adguard.com/en/terms-of-sale.html)
+- Privacy notices:
+    - [AdGuard VPN Browser Extension](privacy\extension.html.md)
+    - [AdGuard VPN for Android](privacy\android.html.md)
+    - [AdGuard VPN for iOS](privacy\ios.html.md)
+    - [AdGuard VPN for Mac](privacy\mac.html.md)
+    - [AdGuard for Windows](privacy\windows.html.md)

adguard-vpn.com/eula.html.md

@@ -94,7 +94,7 @@ The subscription in question becomes blocked at the moment the refund is issued.
 
 5.1. AdGuard Software Limited guarantees a strict no-logging policy for AdGuard VPN services: your activities while using it are not monitored, recorded, logged, stored, or passed to any third party. Keynote: we do not record IP addresses and domain names of sites you visit; we do not record your IP address.
 
-5.2. AdGuard VPN collects and processes very limited user data and has a strong Privacy Policy available at <https://adguard-vpn.com/en/privacy.html> that explains in detail how AdGuard Software Limited handles your personal data in relation to your use of AdGuard VPN and your browsing of the Website.
+5.2. AdGuard VPN collects and processes very limited user data and has a strong Privacy Policy available at <https://adguard-vpn.com/privacy.html> that explains in detail how AdGuard Software Limited handles your personal data in relation to your use of AdGuard VPN and your browsing of the Website.
 
 5.3. Before using AdGuard VPN, you acknowledge that you have read and understand our Privacy policy, which explains what type of information we receive and process, and what might happen to that information, including, without limitation, how such information is shared and used.
 

adguard-vpn.com/privacy.html.md

@@ -1,6 +1,6 @@
 # AdGuard VPN Privacy Policy
 
-*April 10, 2024*
+*August 7, 2024*
 
 ## Summary
 
@@ -30,15 +30,15 @@ Some data that we receive and process may be treated as personal data (“Person
 
 ### When you are using our website
 
-**When you visit our website <adguard-vpn.com> and its subdomains**. For more information about what data is collected, how it is collected, and how you can manage it, please see the AdGuard Website & Cookie Notice available at <adguard-vpn.com/privacy/website.html>.
+**When you visit our website <adguard-vpn.com> and its subdomains**. For more information about what data is collected, how it is collected, and how you can manage it, please see the [Privacy Policy of AdGuard Websites](https://adguard.com/website-privacy.html).
 
 **Account registration**. We process your email address and a hash of the password which you provide to us at the registration. That ensures that you can retrieve your password if needed.
 
 **Sending messages**. We can use your email address to make announcements, inform you of updates and new features in our software or services, provide you with advice, or to communicate with you when reporting errors.
 
 You can also provide us with your consent to process your email for sending marketing messages about our other software or services. You can withdraw your consent any time by unsubscribing from our newsletters via AdGuard Account or by clicking the “Unsubscribe” button or link in the newsletter itself.
 
-**Cookies**. We use our cookies to personalize the content of AdGuard VPN website, such as setting the default language. None of the information we may acquire through the use of cookies is considered Personal Data as it does not allow us to identify you. You can always disable cookies in your web browsing software or clear existing cookies, but please note that some of our services may not function properly without the use of cookies. Please refer to the Website & Cookie Notice for details: <adguard-vpn.com/privacy/website.html>.
+**Cookies**. We use our cookies to personalize the content of AdGuard VPN website, such as setting the default language. None of the information we may acquire through the use of cookies is considered Personal Data as it does not allow us to identify you. You can always disable cookies in your web browsing software or clear existing cookies, but please note that some of our services may not function properly without the use of cookies. Please refer to the [Privacy Policy of AdGuard Websites](https://adguard.com/website-privacy.html).
 
 **Buying a subscription**. We process your email address for billing and payment purposes. If you purchase a subscription to AdGuard VPN, we’ll need to know your contact details to send you information about the purchase.
 
@@ -56,7 +56,7 @@ For the exact data that the payment provider collects about you, please see the
 
 ### When you are using our software
 
-**Sign-in/Account registration**. When signing in to connect the installed app to your account or registering a new account, you need to provide your email address and create a password to initially create a VPN connection. We process this essential data to provide you with the AdGuard VPN service.
+**Sign-in / Account registration**. When signing in to connect the installed app to your account or registering a new account, you need to provide your email address and create a password to initially create a VPN connection. We process this essential data to provide you with the AdGuard VPN service.
 
 **Using our software**. When you choose to use our app, you will provide us your data, including Personal Data. This information, which we must process to ensure the full functionality of AdGuard VPN services, depends on the operating system for which the software is designed. For details, please refer to the corresponding privacy notices.
 
@@ -72,7 +72,7 @@ We store only the number of bytes used by the account, it is not associated with
 
 Additionally, we collect information on the number of instances of our software that have an active VPN connection for both the free and paid versions. We receive this information from our VPN servers through which you establish a VPN connection.  This is also done for the same reason — to make sure the user stays within the agreed-upon limits.
 
-**Diagnostic/Device information**. However, if you experience problems using our software and you give us your permission, we can collect and process some diagnostic information for crash reports and some information about the device used to run our software in order to help you. This can only be done if the user has given us permission to collect crash reports. The exact information we collect and process depends on the AdGuard VPN software you are using. For details, please refer to the corresponding privacy notices.
+**Diagnostic / Device information**. However, if you experience problems using our software and you give us your consent, we will collect and process some diagnostic information for crash reports and some information about the device used to run our software in order to help you. The exact information we collect and process depends on the AdGuard VPN software you are using. For details, please refer to the corresponding privacy notices.
 
 ## What legal bases we use to process your Personal Data
 
@@ -93,7 +93,7 @@ We store your Personal Data in our own data center located in Frankfurt. Your Pe
 For data transfers to other countries, we always implement appropriate safeguards to ensure that your Personal Data always remains safe and that your rights are respected:
 
 - The country or the third party is recognized as providing adequate protection.
-- A valid transfer mechanism is used, such as the Standard Contractual Clauses, and additional measures are implemented where necessary.
+- A valid transfer mechanism is used, such as the Standard Contractual Clauses, and supplementary measures are implemented where necessary.
 - The transfer has your explicit consent.
 - The transfer is necessary for the performance of a contract with you or to take steps requested by you prior to entering into that contract.
 
@@ -125,7 +125,7 @@ You are entitled to exercise the following rights in relation to your Personal D
 
 **Right to object**: The right to object to processing of your Personal Data.
 
-**Right to data portability**: The right to receive provided Personal Data in a structured, commonly used and machine-readable format and to transfer that data to another controller. You can export all Personal Data that we hold about you to a local file from your AdGuard Account at <my.adguard.com>.
+**Right to data portability**: The right to receive provided Personal Data in a structured, commonly used and machine-readable format and to transmit that data to another controller. You can export all Personal Data that we hold about you to a local file from your AdGuard Account at <my.adguard.com>.
 
 **Right not to be subject to a decision based solely on automated processing**, including profiling.
 

adguard-vpn.com/privacy/android.html.md

@@ -1,10 +1,12 @@
 
 # AdGuard VPN for Android Privacy Notice
 
-*April 10, 2024*
+*August 7, 2024*
 
 This Privacy Notice lists all the information that we, Adguard Software Ltd. (“we”, “us”, or “our”), may collect when you use AdGuard VPN for Android and explains why we do it and how we use this information.
 
+This Privacy Notice supplements the AdGuard VPN Privacy Policy available at <https://adguard-vpn.com/privacy.html>, which provides you with the necessary information regarding terms and conditions of data processing by AdGuard.
+
 > **Keynote**:
 >
 > - We do not collect logs on VPN servers and do not know what websites you visit.

adguard-vpn.com/privacy/extension.html.md

@@ -1,10 +1,12 @@
 
 # AdGuard VPN Browser Extension Privacy Notice
 
-*April 10, 2024*
+*August 7, 2024*
 
 This Privacy Notice lists all the information that we, Adguard Software Ltd. (“we”, “us”, or “our”), may collect when you use AdGuard VPN Browser Extension and explains why we do it and how we use this information.
 
+This Privacy Notice supplements the AdGuard VPN Privacy Policy available at <https://adguard-vpn.com/privacy.html>, which provides you with the necessary information regarding terms and conditions of data processing by AdGuard.
+
 > **Keynote:**
 >
 >- We do not collect logs of your activity on VPN servers and do not know what websites you visit
@@ -36,7 +38,7 @@ When we create an account for the user, the following information is sent to our
 - Email address
 - App identifier
 - OS language
-- Marketing consent flag
+- Marketing consent flag indicating whether user has consented to receive marketing emails
 
 **Why we need this information:**
 

adguard-vpn.com/privacy/ios.html.md

@@ -1,10 +1,12 @@
 
 # AdGuard VPN for iOS Privacy Notice
 
-*April 10, 2024*
+*August 7, 2024*
 
 This Privacy Notice lists all the information that we, Adguard Software Ltd. ("we", "us", or "our"), may collect when you use AdGuard VPN for iOS and explains why we do it and how we use this information.
 
+This Privacy Notice supplements the AdGuard VPN Privacy Policy available at <https://adguard-vpn.com/privacy.html>, which provides you with the necessary information regarding terms and conditions of data processing by AdGuard.
+
 > **Keynote**:
 >
 > - We do not collect logs on VPN servers and do not know what websites you visit.
@@ -67,6 +69,7 @@ When you launch AdGuard VPN for iOS for the first time, the following informatio
 - To monitor the number of simultaneous connections
 - To count the number of apps of a certain type and version
 - To communicate with you in your language
+- To integrate with Apple Search Ads
 
 ### Using the app
 
@@ -89,7 +92,7 @@ When you click *Connect*, the app will send your authorization token to AdGuard
 
 You can send messages to support by tapping *Report a bug* or *Request a feature*.
 
-When you submit a report, their email address is sent to our servers. The AdGuard VPN support team may use it for follow-up communication about the issue.
+When you submit a report, your email address is sent to our servers. The AdGuard VPN support team may use it for follow-up communication about the issue.
 
 The following information is also included in the report: