OPERA VPN TERMS OF SERVICE

(Last Updated February 29, 2016)

Please read carefully before using this service.

The Opera VPN service enables users to choose their virtual location by routing their Internet traffic through a virtual private network (the “Service”). The Service is offered by SurfEasy Inc., an Opera company (“SurfEasy”) subject to and in accordance with these Terms of Service and the attached Privacy Policy (collectively, the “Terms”).

SurfEasy, Inc.
488 Wellington Street West
Toronto, Ontario
Canada

OPERA VPN PRIVACY POLICY

(Last Updated February 28, 2017)

This Privacy Policy applies to the Opera VPN service and associated mobile application (“Service”). The Service is provided pursuant to the Opera VPN Terms of Service by SurfEasy, Inc. an Opera company (“Opera”). Opera VPN believes in privacy and online freedom and that it should be very clear how Opera VPN manages and protects its users’ personal information. The term “personal information” as used in this Privacy Policy means information about you that can identify you. For example, your social insurance number, your credit card number, or a picture of you would all be personal information of you. The objective of this Privacy Policy is to provide an overview of the Service and reflect Opera VPN’s commitment to adhere to the legislative requirements of the Personal Information Protection and Electronic Documents Act (PIPEDA), and other applicable privacy legislation in Canada, concerning the handling of the personal information of users of the Opera VPN Service.

OPERA’S COMMITMENT

An important part of Opera VPN’s commitment to users of the Service (“you” or “yours”) is respect for your right to privacy. Opera VPN appreciates the opportunity to provide any of its assistance and services to you and strives to the highest level of service excellence. This means keeping your personal information in strict confidence and being open and transparent regarding our use, disclosure, and practices regarding your personal information.

THE TEN PRIVACY PRINCIPLES

Principle 1 – Accountability

To ensure Opera VPN remains accountable for the manner in which it uses, collects and discloses your personal information, everyone at Opera VPN is responsible for maintaining and protecting the personally identifiable information to which they have access. In addition, Opera, through its subsidiary SurfEasy Inc., has appointed a Privacy Officer, who will be accountable for ensuring its compliance with this Privacy Policy. Questions pertaining to this Privacy Policy or the application of this Privacy Policy may be directed to: Privacy Officer SurfEasy 488 Wellington Street West, Toronto, Ontario, Canada.

Principle 2 – Identifying Purposes

When you become a user of the Service, Opera VPN collects, as consideration for your right to use the Service, your personal information for the following purposes:

• to compile anonymized statistics on user behavior and location for study by Opera VPN and its customers and/or distribution partners;

• to ensure security, reliability, and quality of Service and to avoid any tampering, damages, and/or misuse of our networks, services or website;

• to provide and improve the ongoing Service;

• to communicate with you;

• to comply with legal requirements;

• to protect you and Opera VPN from error and fraud; and

• for limited marketing purposes.

If you access the Service via Opera VPN mobile software application, the following also applies:

• The Opera VPN app may use Google Analytics provided by Google, Inc. to measure app performance. Your IP-address is masked before Google processes the data, and no personally identifiable information is collected. Google’s privacy policy and information regarding opt-out can be found here: [http://www.google.com/intl/en/policies/privacy/](http://www.google.com/intl/en/policies/privacy/) • The Opera VPN app may use Crashlytics crash reporting provided by Crashlytics, Inc. Opera VPN collects crash data and processes it through the Crashlytics service. No personally identifiable data, nor specifically your IP address, is collected by or passed on to Crashlytics. Crashlytics privacy policy is located at [http://try.crashlytics.com/terms/privacy-policy.pdf](http://try.crashlytics.com/terms/privacy-policy.pdf). • The Opera VPN app may use the MixPanel notification solution provided by MixPanel Inc. to notify you of messages via the VPN Apps. No personally identifiable information, nor specifically your data usage, is collected via or passed onto MixPanel. MixPanel’s privacy policy is located at [https://mixpanel.com/privacy/](https://mixpanel.com/privacy/).

Principle 3 – Consent

Most personal information collected by Opera VPN through the Service is compiled when you utilize the Service that we provide to you. Therefore, it is important for you to understand that when you use the Service you give Opera VPN your consent to use your information according to this Privacy Policy. You may, at any time, withdraw your consent which may affect the level and features of Service that we can provide. Otherwise, you can always discontinue using the Service.

Principle 4 – Limiting Collection

Opera VPN will only collect personal information needed for it to properly conduct its business and only collect it by fair and lawful means. Information collected about you via the Service may include:

• usage data, like web addresses (but not content of the web pages) and IP address locations;

• a randomly generated identifier used by Opera VPN;

• Device advertising ID;

• Device type;

• Browser type;

• Operating system type;

• IP address with date and time; and

• Any other information that you may share with Opera VPN through communications with Opera VPN via email, telephone, and/or any letters. There may be certain other information that Opera VPN may collect in connection with the Service for which Opera VPN will seek your consent prior to doing so.

Opera VPN may combine the information it collects in connection with your use of the Service with demographic and other information it collects from third party data providers.

Principle 5 – Limiting Use, Disclosure, and Retention

Opera VPN is committed to a high standard of confidentiality and privacy. Opera VPN will only use and/or disclose your personal information for the reason(s) it was collected. In general, Opera VPN will not share any of your personal information except for the purpose of fulfilling the Service requested, and may share specific personal information with third party service providers engaged to assist us in providing the Service requested. These service providers are prohibited from using your personal information for any purpose other than to provide this assistance, and they are required to protect all personal information and comply with the general privacy principles described in this Policy.

Opera VPN may share, sell, and/or distribute anonymized usage data with third parties.

Other than that we may share some of your personal information with third parties as stated in this privacy policy, we will not share any of your personal information without your consent, unless there is a requirement to do so by law . Opera VPN has a Policy in place that governs the retention of your personal information. We will only retain your personal information for as long as it fulfills its intended purpose, or as legally required.

Principle 6 – Accuracy

Opera VPN is committed to maintaining the accuracy of your personal information and ensuring that it is complete and up-to-date. In most cases Opera VPN collects your personal information directly from you. If you discover inaccuracies in Opera VPN’s data, please notify Opera VPN to make the necessary changes.

Principle 7 – Safeguards

Your personal information is secure within Opera VPN, regardless of the format in which it is held, transmitted, or processed. Opera VPN has implemented security controls to protect against unauthorized use, access, alteration, duplication, destruction, disclosure, loss or theft of your personal information. Opera VPN maintains physical, electronic and procedural safeguards to protect your personal information. Examples of safeguards include restricted access to our information processing and storage areas, limited access to relevant information by authorized persons only, use of passwords, firewall technology, encryption of electronically transmitted information, antivirus software and the use of physical security measures, including secure locks on filing cabinets and doors. Opera VPN is also committed to working with you to protect the security of personal information during any transfer to Opera VPN. Additionally, Opera VPN has agreements and controls in place with third party service providers requiring that any information provided to Opera VPN be transmitted and safeguarded with the industry’s highest technological security standards in mind.

The Privacy Officer will conduct periodic reviews of various Opera VPN practices to determine compliance with this Policy. The Privacy Officer will make all recommendations necessary to ensure compliance and determine whether any revisions to this Policy are required in light of new practices, processes, technologies or other changes.

Principle 8 – Openness

Opera VPN will disclose to you this Policy and make information available concerning the policies and practices that apply to the management of your personal information.

Principle 9 – Individual Access

In the course of interacting with Opera VPN, you are welcome to review or verify your personal information. Opera VPN may need specific information from you to enable Opera VPN to search for, and provide you with, the personal information Opera VPN holds about you. Please note that access to your personal information is in accordance with Opera VPN’s retention and access policy.

Principle 10 – Challenging Compliance

Any concerns regarding Opera VPN’s compliance with this Policy can be reported in writing to the Opera VPN Privacy Officer at the address set forth in Principle 1. If you have concerns about how Opera VPN handles your personal information, please note that you may always contact the independent oversight body:

Office of the Privacy Commissioner of Canada

Place de Ville
Tower B

112 Kent Street

Ottawa, Ontario K1A 1H3
Canada

Tel: 1-800-282-1376