Privacy Policy

Version No 1.1. Last updated April 25, 2024.

This Comet Tech Inc. Privacy Policy (the “Privacy Policy“) strives to protect user privacy and information when using any system of Comet Tech Inc. or being in the contractual relationship between Comet Tech Inc. as a service provider and any natural or legal person as a service user.

BY USING THIS WEBSITE www.marsproxies.com (the “System“), You AGREE TO THE PRIVACY POLICY, WHICH MAY GET UPDATED WITHOUT PRIOR NOTIFICATION.

CY, WHICH MAY GET UPDATED WITHOUT PRIOR NOTIFICATION.

1. General provisions and definitions

1.1. Comet Tech Inc. is a legal entity, incorporated in the Republic of Panama, registration number 155734567, address Advanced Tower Building, First floor, Ricardo Arias Street, Panama City, Republic of Panama (the “Company”/ “Us” / “We”).

1.2. Any person using Company’s services/systems is considered to be a client of the Company (the “Client” / “You”).

1.3. The Company and the Client are legally bound by the Terms and Conditions (the “Agreement”) which governs the contractual relationship between the Company as a service provider and the Client, as any natural or legal person, as a service user, or a user of System prior to/without logging-in/creating an account (“Account”).

1.3.1 The Company provides multiple IP address proxy infrastructure solutions, including IP addresses for the Clients to connect to the internet, and access the Company’s data gathering and proxy management solutions (the “Services”). The Services can be reached and used via the System.

1.3.2 The latest version of the Agreement shall be available at https://marsproxies.com/terms-of-service.

1.4. This Privacy Policy shall be applicable and interpreted in line with the Agreement. The definitions set out in the Agreement shall be applicable to this Privacy Policy.

1.5. You can contact the Company using a popup chat box in the System, as well as by sending an email. For the matters regarding this Privacy Policy, as well as regarding any privacy matter, We recommend contacting the Company via email, by sending Your inquiry to [email protected].

1.6. The Company shall have the right to unilaterally modify and/or update the Privacy Policy at any time without notice. The continuous use of the Services/System by the Client shall be deemed as acceptance of Privacy Policy in the last and most updated version. Any Client shall periodically check and assess the Privacy Policy. Any update of this Agreement comes in force at the moment it is published at the System.

1.7. The latest version of the Privacy Policy shall be available at https://marsproxies.com/privacy/.

1.8. By agreeing to the Agreement as per the rules outlined in the Agreement, You are automatically agreeing to the Privacy Policy. For the avoidance of doubt, You acknowledge understanding that by using the System in any way before creating an Account (Clause 2 of the Agreement) or without logging-in to the System (for example, when browsing the Blog section of the System), You are also bound by this Privacy Policy and Your data/information may be collected by the Company automatically.

1.9. If You disagree to be bound by the Privacy Policy in any scope or way, You must not use or must immediately cease Your use of the Services, System, or any part of it, as well as its features and functionalities.

1.10. The Company values the trust that You place in the Company when using Services/System. For this reason, privacy and data security are extremely important to the Company. It is very important to the Company that You feel safe when You visit our System and use our Services, as well as in all other business transactions with the Company. As soon as You use the Company’s System/Services, You entrust the Company with the processing of Your personal data. The Company wants to offer You the best possible experience with the System to ensure that You can enjoy using Services now and in the future. That is why the Company wants to understand user behavior on the System to continuously improve it. The processing of Your personal data is therefore not only necessary for the provision of Services but also to improve user-friendliness. Therefore, in this Privacy Policy, You are informed which personal data the Company collects from You, how the Company processes it, and to whom the Company passes it on in detail. In addition, the Company informs You about the precautions it takes to protect Your personal data, what rights You have in this context, and who You can contact regarding data protection issues.

1.11. In light of the above, the Company strives to protect Your privacy and is obliged to process Your personal data in accordance with the following rules and principles:

1.11.1. Processing shall be performed lawfully, fairly, and in a transparent manner.

1.11.2. Personal data must be adequate and limited to what is necessary in relation to the purpose for which it is processed.

1.11.3. Personal data shall be accurate and, where necessary, kept up to date.

1.12. This Privacy Policy is prepared in accordance with the Law No. 81 of 2019 on Personal Data Protection of the Republic of Panama (the "PPDPL") and other relevant legal instruments, including regulations issued by the competent authority like the National Authority for Transparency and Access to Information (ANTAI). You can find information on applicable legal acts here: https://www.antai.gob.pa/legislacion/.

1.13. With regard to the terms used in this Privacy Policy, such as “Processing” or “Controller”, We refer to the definitions of the PPDPL.

2. Applicability

2.1. This Privacy Policy is binding upon all persons who engage with the Company, utilizing the System/Services, or interacting with the Company in any capacity (such as business partners, interested parties, service providers, etc.), collectively referred to herein as "Client" or "You".

2.2. The Company's System and Services are expressly intended for individuals of legal age. Only those individuals who have attained legal age are permitted to utilize the System, Services, and register for an Account. The Company explicitly refrains from knowingly collecting personal data from individuals below the stipulated legal age. Therefore, if You are under 18 years of age or below the legal age as mandated by applicable laws, kindly refrain from using the System/Services and abstain from furnishing any personal data to Us.

2.3. Should You act as a representative of a legal entity utilizing the Company's System/Services, be advised that Your personal data will also be subject to collection in accordance with this Privacy Policy.

2.4. It is incumbent upon You to ensure that You meet the requisite eligibility criteria for utilizing the Company's System and/or Services.

3. Controller, Responsibilities, and Scope

3.1. In accordance with applicable data protection laws, the Company typically assumes the role of "data controller" for any personal information provided to it. On rare occasions, the Company may act as a "processor" under specific arrangements, processing personal data strictly in accordance with the directives of a data controller or as permitted by law.

3.2. This Privacy Policy governs the processing of personal data by the data controller (the Company) situated in the Republic of Panama, processing the personal data of data subjects (You) residing or working within or outside the Republic of Panama.

3.3 For any queries regarding the processing of Your personal data and the exercise of Your rights under the PPDPL, please contact our team at [email protected].

3.4. The Company may request additional identification data from You for certain inquiries (e.g., Passport, ID card, etc.) to ensure that Your personal data is only disclosed to You.

3.5. As a data controller (or, in some cases, a data processor), the Company bears the following responsibilities:

3.5.1. Data Transfers: The Company shall not transfer personal data to a country or territory outside the Republic of Panama unless adequate protection for the rights and freedoms of data subjects is ensured. If an adequate level of protection is lacking, exceptions may be made by either establishing protection through appropriate safeguards (e.g., Standard Contractual Clauses) or obtaining explicit consent from the data subject, ensuring that the transfer does not conflict with the public security interests of the Republic of Panama.

3.5.2. Data Processing Records: The Company shall maintain data processing records at its discretion unless mandated by legal requirements.

3.5.3. Data Protection Officer Appointment: The Company shall designate a Data Protection Officer (DPO) to ensure the proper implementation of data protection requirements and the optimization of procedures. The DPO shall possess the necessary skills and knowledge for safeguarding personal data. You can contact the Company's DPO/data protection staff at [email protected].

3.5.4. Data Breach Notification: The Company strives to protect Your personal data in the best way possible. However, sometimes data breaches occur and such events can happen for various reasons. In the event of a data breach compromising the privacy, confidentiality, and security of a data subject's personal data, the Company, as the data controller, shall promptly notify the National Authority for Transparency and Access to Information of such breach. The notification shall include details such as the nature, category, reasons, approximate number and records of the data breach, a description of the likely consequences, and measures taken to address the breach.

3.5.5. Data Retention: The Company shall not retain personal data beyond the purpose for which it was processed, unless the identity of the data subject is no longer identifiable through anonymization techniques.

3.5.6. Sensitive personal data protection. In general, the Company does not process any special categories of personal data from Clients. This includes data that reveal racial or ethnic origin, political opinions, religious or ideological convictions or trade union membership, as well as genetic and biometric data. In some cases, during verification, in addition to the actual verification data (e.g. screenshots of ID documents and identification data from them, place of residence, status of politically exposed persons, video data, etc.), biometric data (e.g. personal data resulting from specific technical processing in connection with the physical, physiological or behavioral characteristics of a person and data for the clear identification of a person, e.g. facial images, dactyloscopic data) are recorded. Such processing of biometric data takes place exclusively based on Your express consent, which You can revoke at any time.

3.5.7. Proper Agreements between Controller and Processor: Whether acting as a controller or processor, the Company shall ensure that agreements defining the scope, subject-matter, purpose, and nature of processing, as well as the type of personal data and categories of data subjects, are concluded and appropriate for planned data processing.

4. Data categories and sources

4.1. Collection of Personal Information: The Company may gather personal information from You in the course of providing Services, when You use the System, contact Us, request information, or as a result of Your relationship with our personnel or clients.

4.2. The personal information that may be processed includes:

4.2.1. Contact Data. When creating a new user Account or communicating with the Company (e.g., contacting our support team), we may process basic details such as Your name, date of birth, role/title, employer/s, country of residence, username, order ID, Your relationship to a person, contact information (email address, physical address, contact numbers).

4.2.2. Verification Data. If an Account/other details are verified, also depending on the verification level, We may therefore process, for example: screenshots of national identity documents such as passport, driver’s license, ID card and identification data from these documents, utility bill details for residence verification, data about the status of political exposed persons, video data from the video authentication procedure, biometric data for verification, as well as information collected from publicly available resources to verify the same.

4.2.2.1. The Company always asks You to verify Your identity/other details when the Client:

4.2.2.1.1. Wishes to utilize the PayPal payment option.

4.2.2.1.2. Intends to acquire ISP Proxies.

4.2.2.1.3. Desires to purchase a total of more than 300GB of Royal Residential proxies.

4.2.2.1.4. Seeks access to the entire IP pool of Ultra Residential proxies.

4.2.2.1.5. Aims to access blocked websites within the Ultra Residential proxies pool.

4.2.2.2. The verification requirements listed in Clause 4.2.2.1 can be modified at the sole discretion of the Company. It is the responsibility of the Client to ensure that the intended Service or action in the System requires verification.

4.2.2.3. Third-Party Verification. The Company utilizes a third-party service provider, Idenfy, for identity verification. More information about Idenfy is available at https://www.idenfy.com/identity-verification-service/, and details about Idenfy's Privacy Policy can be found at https://www.idenfy.com/privacy-policy/.

4.2.3. Order Data. In the context of ordering Services, information related to the matter on which You are seeking our Services may be processed.

4.2.4. Financial Data. In the context of ordering Services, accepting payments, making refunds, or processing withdrawals related to the Affiliate program, the Company may process bank details, information about payment service providers, payment details, transaction IDs and etc.

4.2.5. Log Data. During activities on the System (website) and while using Services, We might process, for example: IP-address, Your location, location data, traffic data, transaction data (like deposit, payment, refund withdrawal address), computer or mobile device information, frequency, time, length of visit and other page interaction data, operating system, browser type, device type, unique device identification number, identification cookies, optionally form data, crash reports, performance data, third-party cookies, etc.

At all times when using System / Services, We collect and process the following log data:

4.2.5.1. IP address of first or the last login.

4.2.5.2. Account credentials and other information as per Clause 2 of the Agreement, including date and time of Account creation, as well as log-in date and time.

4.2.5.3. Information collected by cookies and Google Analytics (see Clause 13), for example: browser type, the web pages You visited, and time spent on them, access time and dates, unique device identification number, other. The mentioned data in this Clause might be collected without assigning it to the specific user.

4.2.6. Company Details. If You use Services or enter into a commercial agreement with the Company as a legal entity, processing may involve commercial register reports, data of or concerning beneficial owners, records about business activities, past or planned business activities, other data required to determine / validate the structure, the beneficial ownership or any power of attorney from the company, etc.

4.2.7. Marketing Data. Visits to the System or social media sites may result in the processing of statistical and marketing data, including the number of visitors, frequency, clicks, time, places, target groups, data from cookies and similar technologies (pixels, ClearGIFs, etc.), consumer’s behavior, interests and preferences, data on market research and target group surveys, etc.

4.2.8. Photo, Video, and Audio Data. When We attend or organize events or fairs or conduct interviews with people, or You visit our offices or our meetings and events, We may take photos and other recordings of such events and process photo, video and audio data, as well as data on time, location, participant list, etc. However, We will always inform You separately about any such recordings by photographic or video images and/or audio recordings.

4.2.9. Hiring data. If You apply for a job on our System, social media (for example, via LinkedIn), We may process data that is necessary for the recruitment process, for example: contact details, curriculum vitae, qualifications, police clearance certificate, credit report, national identity documents such as passport, driver’s license and the data from all of these documents, links to Your portfolio or social media platforms, etc.

5. Purpose and legal basis.

5.1. All processing activities are conducted in adherence to the provisions outlined in the Law of Personal Data Protection of the Republic of Panama (PPDPL). The processing of Your personal data is executed based on at least one of the legal foundations enumerated below. In instances where the Company requests the provision of additional personal data beyond the categories delineated herein, such data, along with the purpose and legal basis for collection and processing, will be communicated to the Client at the juncture of personal data collection.

5.1.1. Performance of Contractual Obligations. Processing of personal data by the controller (the Company) or processor may transpire without the explicit consent of the data subject (You) if such processing is indispensable for the fulfillment of a contractual agreement (the Agreement) in which the data subject is a party or is undertaken to execute actions at the data subject's request for entering into, modifying, or concluding a contract.

5.1.2. Consent. We may ask You to provide Your consent if the data subject’s (Yours) consent is relied upon as a lawful basis for the processing of Your personal data. For example, We may ask You to express consent prior to using the System before the Agreement is concluded or when You are using the System without logging-in, as well as before collecting / processing any other personal data not described in this Privacy Policy.

If You have given us Your consent to the processing of Your personal data, the processing will only occur for the defined purposes and to the extent agreed in the declaration of consent.

The provision of consent can be withdrawn at any time, without the obligation to provide reasons, with prospective effect, should You no longer wish to endorse the processing.

With Your consent, We process data for the following purposes, for example:

• Direct Marketing and Advertising. This pertains to activities such as customer satisfaction surveys, newsletters, sweepstakes, and other advertising communications. Your consent for direct marketing and advertising is explicitly granted through the creation of an Account. By initiating the Account creation process, You affirm Your comprehension that the contact information furnished to the Company may be utilized for direct marketing, advertising endeavors, and other electronic communications. The act of creating an Account signifies Your explicit agreement to receive diverse marketing and advertising materials.
• Website Analysis and Tracking for Advertising (see also our Cookie Policy at Clause 13).
• Certain applications of audio, video, and photo data, encompassing but not limited to commercials, interviews, etc., for marketing and representative purposes through varied channels.
• Automated Authentication Process (Identity Verification).
• Application management system, recruitment process and processing of Your application

Revoking Your consent does not affect the legality of the processing carried out based on Your consent up to the point of withdrawal

5.1.3. Compliance with Legal Obligations. The processing of personal data may be essential for adhering to various legal obligations. Such obligations encompass operations such as contract management, accounting, invoicing, monitoring to prevent fraud, misuse, money laundering, and terrorist financing, providing information to criminal authorities in the context of fiscal criminal proceedings, or complying with official orders. Additionally, it includes activities such as assessing the working capacity of employees or the provision of health and social care, among others.

5.1.4. Where necessary, data processing may extend beyond the execution of a contract to safeguard the legitimate interests of the Company or a third party. Such legitimate interests involve processing operations such as:

5.1.4.1. Prevention of fraud, misuse (e.g., for illegal purposes), money laundering, and terrorist financing.

5.1.4.2. Risk management and minimization through inquiries to credit agencies, debtor directories, or providers of business analysis.

5.1.4.3. Identification and examination of potentially incorrect or suspicious business cases and access to our websites (e.g., website analysis via Sift Science).

5.1.4.4. Data transfer within the Company for internal administrative purposes.

5.1.4.5. Account management and processing of general Client requests and inquiries.

5.1.4.6. Measures to protect our customers and partners as well as to ensure network and information security; also measures to protect our employees and property, e.g. through video surveillance and external data centers and service providers.

5.1.4.7. Processing of inquiries from authorities, lawyers, collection agencies in the context of legal prosecution and enforcement of legal claims during legal proceedings.

5.1.4.8. Market research, business management and further development of services and products.

5.1.4.9. Processing of statistical data, performance data, and market research data via the website, app, or social media platforms (e.g., Facebook, LinkedIn, YouTube, etc.).

5.1.4.10. Processing of customer preferences (e.g., language, region) through cookies on our website.

5.1.4.11. Direct marketing and advertising (e.g., implementation of marketing strategies, targeting of clients, dispatch of vouchers, advertisements from the Company and its partner companies).

5.1.4.3.12. Utilization of audio, video, and photo data from public spaces (e.g., public events, fairs, etc.) for marketing and other representative purposes on our social media channels or our website.

6. Social media presence and other communication.

6.1. The Company maintains active social media accounts on various platforms (refer to the list below) for the purpose of communicating with its current customers, potential customers, and other interested users regarding the Company's services, products, and updates. When accessing these social media platforms, users are subject to the respective terms and conditions and privacy policies of the platform operators. It is important to note that user data may be processed outside the territorial jurisdiction of the Republic of Panama or the user's specific region, potentially exposing users to risks stemming from differing legal frameworks (e.g., challenges in enforcing data subject rights).

6.2. Within the technical processes of various social media platforms (e.g., Google, Facebook, Twitter, etc.), when users interact with content or websites, the platforms ascertain whether the user is simultaneously logged into their social media accounts. This information is collected by the social media platforms and linked to the user's social media accounts, irrespective of whether the user interacts directly with the platform's content. Users can prevent such linkage by logging out of their accounts.

6.3. The Company does not exert control over the operations of these social media platform companies, and as such, bears no liability for any damages users may incur as a result of the companies' use of Your data.

6.4. The Company may only process personal data from social media users if they communicate directly with the Company via such platforms (e.g. visitors number, posted articles, likes, direct messages, customer inquiries, comments, etc.). In these cases, the Company is also responsible for processing the personal data collected thereby. In addition to data processing by Us, other providers, in particular operators of social networks and platforms, also process personal user data. We have no influence on this data processing and are not responsible for it - the data processing takes place exclusively in the area of responsibility of the other providers.

6.5. For a detailed explanation of the respective processing and the possibilities of objection (opt-out) by providers of social media networks, We refer to the respective privacy policies of the providers (see below). In the case of requests for information and the assertion of data subject rights to data processing by other providers, We point out that these can be asserted with the providers listed below. Only the providers have access to the data of the users and can directly take appropriate measures and provide information.

6.6. The Company uses the following social media accounts in order to engage with You and other third parties:

6.6.1. Discord account – accessible using this link: https://discord.gg/jrrMVGEr More information about data collected by Discord and Your preferences is available here: https://discord.com/privacy,

6.6.2. X (Twitter) account – accessible using this link: https://www.twitter.com/Marsproxies More information about data collected by X (Twitter) and Your preferences is available here: https://help.twitter.com/en/rules-and-policies.

6.6.3. Facebook account – accessible using this link: https://www.facebook.com/profile.php?id=61554669451137&sk=about. We use Page Insights function to process statistical data from users on Facebook (https://www.facebook.com/legal/terms/page_controller_addendum ). More information about data collected by Facebook and Your preferences is available here: https://www.facebook.com/privacy/center/.

6.6.4. LinkedIn account - accessible using this link: https://www.linkedin.com/company/marsproxies More information about data collected by LinkedIn and Your preferences is available here: https://www.linkedin.com/legal/privacy-policy?trk=homepage-basic_footer-privacy-policy.

6.6.5. YouTube account – accessible using this link: https://youtube.com/@MarsProxies More information about data collected by YouTube and Your preferences is available here: https://policies.google.com/privacy?hl=en.

6.6.6. Trustpilot account - accessible using this link: https://www.trustpilot.com/review/marsproxies.com. More information about data collected by Trustpilot and Your preferences is available here: https://legal.trustpilot.com/for-reviewers/end-user-privacy-terms.

6.7. The above indicated list is non-finite and the Company is entitled to change/add social media accounts. The latest and up-to-date list of Company’s social media accounts shall be available at the System’s section “Contact and Connect”.

6.8. You should always make sure that the social media account is Company’s before submitting or revealing any personal information of Yours while engaging in any social media communication (for example, exchanging messages or leaving a comment).

6.9. You should be aware that SMS / messaging and email services are susceptible to spoofing and phishing attacks and should be careful when reviewing messages that claim to be from the Company. You should always log into Your Account via https://marsproxies.com/, use communication tools in the System or contact Us via email by sending an inquiry to the address [email protected]. If You are unsure about the authenticity of a communication or notice. Note that phishing attacks often occur despite SMS or email or equivalent services, via search engines or advertisements in search engines or other fraudulent links. The Company takes no responsibility for any loss due to spoofing, phishing, or other equivalent attacks.

7. Your rights

7.1. You possess the following rights:

7.1.1. Right to access. You have the right to access Your personal data stored or subject to treatment in public or private databases. This right includes the right to know the origin, purpose, and intended use of the data.

7.1.2. Right to Withdraw Consent and Opt-Out. In all instances, You retain the entitlement to object to and suspend the processing of Your personal data, particularly when such processing is conducted for direct marketing or statistical survey purposes. Should You disagree with providing consent or wish to withdraw consent for receiving direct marketing and advertising material in any capacity, You must undertake one of the following actions:

7.1.2.1. Choose not to complete the creation of Your Account.

7.1.2.2. After the creation of Your Account, withdraw the consent granted during the Account creation process by selecting the "Unsubscribe" button in the email sent by the Company subsequent to the Account creation.

7.1.2.3. At any other time, withdraw Your consent by selecting the "Unsubscribe" button indicated in any other email sent by the Company as direct marketing and/or advertising material.

7.1.2.4. You reserve the right to revoke Your consent at any time through the methods outlined in this Privacy Policy or by email to [email protected]. It is important to note that withdrawing Your consent may impact our ability to provide You with all of our services. The withdrawal of consent does not affect the legality of processing Your personal data based on Your consent until the point of withdrawal.

7.1.2.4.1. By checking the respective box during the registration process (creating an Account) or when updating after logging into Your Account, You expressly confirm that You have read the Agreement and Privacy Policy and agree to the described data processing therein.

7.1.2.4.2. By checking the respective box during the registration process (creating an Account) or when updating after logging into Your Account, You expressly confirm that You have read other policies as indicated in such notices.

7.1.2.4.3. By creating an Account, You expressly consent to receiving direct marketing and advertising material, as well as other electronic communication.

7.1.2.4.4. By checking the respective box (boxes) during the use of the System for the use of Cookies, You expressly consent to the usage of Cookies as outlined in this Policy, the notice, and in accordance with Your preferences expressed by checking any or all boxes.

7.1.3. Right prior to the start of processing activities, to get information on the purpose of the processing, sectors or entities inside or outside the Republic of Panama with whom Your personal data will be shared, the appropriate safeguards used by the Company in the context of cross-border processing.

7.1.4. Right to Additional Information upon Request. You have the right to obtain additional information upon request, including:

7.1.4.1. Confirmation of whether We are processing personal data related to You.

7.1.4.2. The types of personal data of the data subject being processed.

7.1.4.3. Decisions made on the basis of automated processing.

7.1.4.4. The rules and criteria for the periods during which personal data will be stored.

7.1.4.5. The measures to be taken in the event of a data breach.

7.1.5. Right to rectification. You are entitled to obtain the rectification of inaccurate personal data concerning You, and to have incomplete personal data completed.

7.1.6. Right to erasure. You are entitled to request the Company to delete Your personal information if:

7.1.6.1. The personal data is no longer necessary in relation to the purposes for which it was collected or processed; and/or

7.1.6.2. You withdraw Your consent or express objection to processing and there are no legitimate grounds for the Company to continue the processing.

7.1.6.3. The personal data have been illegally processed.

7.1.6.4. The deletion of personal data is necessary to fulfill a legal obligation under law to which the Company is a subject.

7.1.7. Right to receive a copy and have Your personal data transmitted to another controller, if technically feasible. You shall have the right to receive the personal data concerning You that You have provided to Us in a structured, commonly used and machine-readable format where the processing is based on Your consent, or is necessary to fulfill a contractual obligation and implemented by automated means. You also shall have the right to have this data transmitted directly to another controller named by You, insofar as this is technically feasible and the rights and freedoms of others are not impaired. The right to data portability can only be exercised if the processing is based either on Your consent or on a (pre)contractual necessity and where the processing is automated. The right to data portability does not apply to processing which is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

7.1.8. Right to object to decisions based on automated processing. The Company usually does not use any personal data for automated decision-making including profiling (e.g. decisions that have legal effects on data subjects, or significantly affecting them in any other way that are based solely on automated processing of personal data including profiling). In case We would make such a decision in any scope, You shall be entitled to object.Additionally, You have the right to object to the processing of Your personal data at any time if the processing is based on Your legitimate interests. If You object to the processing, We will no longer process Your personal data unless We can demonstrate compelling legitimate grounds for the processing that outweigh Your interests, rights and freedoms, or the processing serves to assert, exercise or defend legal claims. The objection does not affect the legality of the processing of Your personal data based on legitimate interests until You withdraw Your consent.

7.1.9. Right to restriction of processing. You shall have the right to request that We restrict processing if one of the following conditions is met:

7.1.9.1. You dispute the accuracy of the personal data (the restriction applies for a period of time that enables the Company to verify the accuracy of the personal data).

7.1.9.2. The processing of Your personal data was unlawful, and You refuse to delete Your personal data and instead request that its use is to be restricted.

7.1.9.3. The Company no longer needs Your personal data for processing purposes, but You need them to assert, exercise or defend legal claims.

7.1.9.4. You have objected to the processing of Your personal data, and it has not yet been determined whether the Company’s legitimate grounds outweigh Your own.

7.1.10. Right to lodge a complaint with the National Authority for Transparency and Access to Information. The National Authority for Transparency and Access to Information acts as the federal data regulator in the Republic of Panama. More information and contact information are available at https://www.antai.gob.pa/.

7.1.11. Right to contact. To exercise any of the above rights, You can send an email to [email protected] or a letter to Comet Tech Inc., address Advanced Tower Building, First floor, Ricardo Arias Street, Panama City, the Republic of Panama. Please note that for such inquiries We need further identification data from You (e.g. Passport, ID card, etc.) in order to ensure that Your personal data is only passed on to You. We shall respond to Your inquiry within 10 days from the day of receiving it.

7.2. In all cases We encourage You to contact Us directly. We at the Company believe that best decisions can be made by mutual agreement and effort.

7.3. As a general principle of the Company, we process personal data only for the purposes for which they were collected. In exceptional cases, however, We may process Your personal data that We have collected for another purpose. In this case, before the intended processing, We will inform You of this purpose, the duration of the storage of Your personal data, the exercise of data subject rights, the possibility of revoking consent, the existence of a right to complain to the data protection authority, whether the provision of the data was necessary on legal or contractual grounds and possible consequences of non-provision and whether automated decision-making or profiling is carried out.

8. Data security.

8.1. The security of data is of utmost importance to Us, and We are dedicated to safeguarding the data We collect. We uphold comprehensive administrative, technical, and physical measures to protect Your personal data from accidental, unlawful, or unauthorized destruction, loss, modification, access, disclosure, or use. These measures align with the highest international safety standards and undergo regular assessments for their effectiveness and suitability in meeting the desired safety requirements.

8.2. We have instituted the following technical, physical, and organizational measures:

8.2.1. Appointment of a Data Protection Officer (DPO) and staff training.

8.2.2. SSL encryption on our System for the secure transfer of personal data.

8.2.3. Assurance of confidentiality, integrity, availability, and resilience of our System and Services.

8.2.4. Implementation of entry, access, and transfer control measures for our offices and systems.

8.2.5. Rapid restoration measures for personal data availability in the event of a physical or technical incident.

8.2.6. Measures for privacy by design and default on our platform such as preventing user enumeration.

8.2.7. Adoption of procedures for the regular review, assessment, and evaluation of the effectiveness of technical and organizational measures to ensure processing security.

8.2.8. Internal IT security practices, monitoring, internal communication, and a prompt response approach.

8.2.9. Incident-response management.

8.3. Your personal data may be accessed, transferred, and/or stored by employees or suppliers outside the country in which You are located, and the data protection laws in that location may be of a lower standard than those in the Republic of Panama. Nevertheless, We commit to protecting personal data in all circumstances in accordance with this Privacy Policy.

8.4. If We process personal data in a third country (e.g., inside the European Union (EU) or the European Economic Area (EEA) or if it occurs in the context of using third-party services or disclosing and/or transferring personal data to third parties, We only transmit personal data to fulfill our (pre)contractual obligations based on consent, legal obligation, or legitimate interests. We process or have personal data processed in a third country only when the conditions for ensuring an adequate level of protection for the rights and freedoms of data subjects in relation to personal data processing are met. This entails, for instance, processing and transmission based on special guarantees such as compliance with a code of conduct or a certification mechanism, as well as binding and enforceable commitments from the recipient in the third country to apply appropriate safeguards for data protection or compliance with officially recognized special contractual obligations (e.g., "Standard Contractual Clauses" announced by the European Commission).

9. Recipients of personal data.

9.1. The Company shall transmit Your personal data only to the extent delineated below or as part of an instruction given at the time of data collection from You. Additionally, personal data collected about You will not be sold or otherwise disseminated to third parties.

9.2. Within the Company, those departments or employees will receive Your personal data who need it to fulfill contractual and legal obligations and legitimate interests. We transfer personal data for the purpose of our day-to-day business operations such as account management and other processes You have requested, as well as for the efficient performance of internal administrative activities in a joint manner and for the maintenance and improvement of our products and services.

9.3. To a limited extent, We may transmit personal data to processors providing services such as video authentication, IT services, legal assistance, customer support, website improvement, contract performance, account management, accounting, invoicing, application management, marketing services, and the dispatch of marketing materials. Processors are authorized to use or disclose this data only to the extent necessary for rendering services to Us or complying with legal requirements. We contractually obligate these processors to ensure the confidentiality and security of Your personal data processed on our behalf.

9.3.1. The following are the primary service providers contracted by the Company that may process Your data:

9.3.1.1. Live chat and support service platform, e.g., Zendesk (provided by Zendesk Inc.).

9.3.1.2. Marketing, application analytics and diagnostics, e.g., Facebook (provided by Meta Platforms, Inc.), Google (provided by Google), Iterable (provided by Iterable, Inc.), LinkedIn (provided by Linkedin Corporation), X (provided by X Corporation), Microsoft Clarity (provided by Microsoft Corporation), Hotjar (provided by Hotjar, Ltd.), Quora (provided by Quora, Inc.), Cookiebot (provided by Usercentrics, A/S).

9.3.1.3. Payment processing / management providers, e.g., CoinGate (provided by Decentralized, UAB), Paddle (provided by Paddle.com Market Ltd.), Stripe (provided by Stripe, Inc.).

9.3.1.4. Others, e.g. iDenfy (provided by iDenfy, UAB).

9.4. We reserve the right to transfer Your personal data:

9.4.1. If required by law or during legal proceedings,

9.4.2. If we believe disclosure is necessary to prevent damage or financial loss, or

9.4.3. In connection with an investigation into suspected or actual fraudulent or illegal activities.

9.5. If the Company, in collaboration with other parties, acts as a joint controller (e.g., processing data for mutually defined purposes within a group of associated entities), We may share personal data with those parties if applicable and based on at least one of the legal bases mentioned in Clause 5. In the case of a joint controllership, We transfer Your personal data only based on a comprehensive agreement with our partners.

9.6. The Company may transmit Your personal data to another individual at the request of the concerned person, with Your consent for the transfer or for the purpose of fulfilling the contract or taking steps at the request of the data subject prior to entering into a contract.

10. Retention period.

10.1. Unless otherwise specified in the notice/consent form, the Company will retain Your personal information only for the duration necessary to:

10.1.1. Provide the Services You have requested and ensure the proper use of the System/Account.

10.1.2. Comply with laws, including mandatory data collection periods.

10.1.3. Support a claim or defense in court or participate in other judicial proceedings.

10.2. In all instances, log data (Clause 4.2.5) will be retained for a minimum of 6 months from the moment of its collection. The Company retains log data even after the termination or suspension of the Account for the same period from the termination or suspension date. The Company reserves the right to extend this data retention period if necessary for a legitimate purpose.

10.3. In all cases, Account data as per Clause 2 of the Agreement, including identification data (if applicable), will be retained for the entire duration of Your status as a Client and for a minimum period necessary after termination to comply with legal obligations, or for other legally justifiable purposes. However, we will not retain your data for longer than permitted by law.

11. Privacy notice to Clients residing in European Union and California.

11.1. If You are a resident of European Union (“EU”), please note that:

11.1.1. We are committed to upholding Your rights under the European Union’s General Data Protection Regulation (“GDPR”). Detailed information on GDPR and Your rights can be found: https://gdpr.eu/

11.1.2. You are entitled to rights under GDPR, as Article 3.2. of GDPR states that the GDPR applies to organizations that are not in the EU if two conditions are met: the organization offers goods or services to people in the EU, or the organization monitors their online behavior. If You are using System/Services, such a situation falls into the scope of mentioned Article 3.2. of GDPR.

11.1.3. The Company's obligations may be subject to limitations outlined in GDPR, such as those related to the number of employees in the Company.

11.1.4. For inquiries or concerns regarding this Privacy Policy or GDPR, please contact our Data Protection Officer (DPO):

11.1.4.1. Via email: [email protected]

11.1.4.2. Via mail: Comet Tech Inc. address Advanced Tower Building, First floor, Ricardo Arias Street, Panama City, Republic of Panama.

11.2. If You are a resident of California, please note that:

11.2.1. We are striving to ensure Your rights under California Consumer Privacy Act of 2018 (Cal. Civ. §§ 1798.100–1798.199) and the California Consumer Privacy Act Regulations by the Attorney General (collectively, “CCPA”).

11.2.2. You are entitled to:

11.2.2.1. The right to know what personal information is being collected.

11.2.2.2. The right to know whether the personal information is sold or disclosed, and to whom such information is sold or disclosed.

11.2.2.3. The right to say “no” to the sale of personal information.

11.2.2.4. The right to delete.

11.2.2.5. The right to access personal information; and

11.2.2.6. The right to equal service and price.

11.2.3. Upon Your verified request the Company shall provide the information on Your personal information that was collected within one year period preceding the request:

11.2.3.1. the categories of personal information the Company collected about You;

11.2.3.2. the categories of sources from which the personal information is collected;

11.2.3.3. the business or commercial purpose for which personal information was collected;

11.2.3.4. the business or commercial purpose for collecting or selling the resident’s personal information;

11.2.3.5. categories of third parties with whom the Company shares personal information; and

11.2.3.6. the specific pieces of personal information that the Company collected about You.

11.2.3.7. A copy of stored personal information.

11.2.4. In addition to above, the Company warrants that NO PERSONAL INFORMATION OF YOURS IS BEING SOLD IN ANY WAY BY THE COMPANY. Therefore, the Company does not provide a “Do not sell my personal information” box in the System.

11.2.5. You can contact the Company’s DPO in case You have any questions or concerns related to this Privacy Police or CCPA.

11.2.5.1. Please contact us via email, by sending Your inquiry to our Data protection team at [email protected].

11.2.5.2. Please contact us via mail, by sending us Your letter to Comet Tech Inc. address Advanced Tower Building, First floor, Ricardo Arias Street, Panama City, Republic of Panama.

11.2.5.3. Additionally, You can contact us by using a popup chat box in the System (https://marsproxies.com/).

11.2.6. The Company shall provide the answer to Your inquiry within terms indicated in this Policy, but in all cases no later than within 45 days of the verifiable request (with the possibility of one 45-day extension).

11.2.7. The following is a list of the categories of personal information that the Company collected about the California residents for a business purpose within the last twelve months. NO COLLECTED DATA WAS SOLD.

11.2.7.1. Account data as per Clause 2 of the Agreement: (i) personal information of the Client / its representative; (ii) name of the Company, if the Client is a legal entity; (iii) valid email address; (iv) country of the residence; (v) unique password, created by the Client; (vi) requirements for the Service (expected number of IPs a month, type of purchase, etc.). (vii) a confirmation that the Client agrees to the Agreement and Privacy Policy of the Company; (viii) A confirmation that the Client / its representative is a natural person.

11.2.7.2. Log data as per Clause 4.2.5., i.e.: (i) IP-address, Your location, location data, traffic data, transaction data (like deposit, payment, refund withdrawal address), computer or mobile device information, frequency, time, length of visit and other page interaction data, operating system, browser type, device type, unique device identification number, identification cookies, optionally form data, crash reports, performance data, third-party cookies, etc.; (ii) at all times when using System / Services, We collect and process the following log data: IP address of first or the last login; account credentials and other information as per Clause 2 of the Agreement, including date and time of Account creation, as well as log-in date and time; information collected by cookies and Google Analytics (see Clause 13), for example: browser type, the web pages You visited, and time spent on them, access time and dates, unique device identification number, other. The mentioned data in this Clause might be collected without assigning it to the specific user.

11.2.7.3. Other information You may choose to insert in Your billing information.

12. Limitation of Liability.

12.1. In accordance with MarsProxies' Agreement, while We utilize various security measures to safeguard personal data, You are ultimately responsible for exercising caution and prudence when using Services and System. Any violation of third-party privacy, other rights, or applicable laws resulting from Your usage will fall under Your sole liability. MarsProxies explicitly disclaims responsibility for the consequences of unlawful, intentional, or negligent actions on Your part, as well as unforeseeable circumstances beyond reasonable control. Please refer to the Agreement for further details. The governing law for the Privacy Policy is as outlined in the aforementioned Agreement.

13. Cookie Policy.

13.1. Our System operating now and in the future uses cookies.

13.2. Insofar as those cookies are not strictly necessary for the provision of our System and Services, We will ask You to consent to our use of cookies when You first visit our System.

13.3. Cookies.

13.3.1. A cookie is a small piece of data stored on a user's device by a website. It is designed to remember information about the user, such as preferences or login credentials, and is sent back to the website with each subsequent visit.

13.3.2. Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiration date, unless deleted by the user and (or) by user agent before the expiration date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

13.3.3. Cookies may not contain any information that identifies a user personally, but personal data that We store about You may be linked to the information stored in and obtained from cookies.

13.4. Cookies that We use. We use cookies for the following purposes:

13.4.1. Authentication and status - We use cookies to identify You when You visit our System and as You navigate our System, and to help us determine if You are logged into our System/Account.

13.4.1.1. For the purposes of the identification of You as a user We use the following Necessary cookies, that help make our System usable by enabling basic functions like page navigation and access to secure areas of our System. The System cannot function properly without these cookies (cookie name / purpose / expiry):

- __zlcstore / This cookie is necessary for the chat-box function on the website to function. / Persistent;

- test_cookie / Marketing tracking /1 day;

- __zlcid / This cookie is necessary for the chat-box function on the website to function. / Session;

- CookieConsent / Stores the user's cookie consent state for the current domain / 1 year;

- __cfruid / This cookie is a part of the services provided by Cloudflare - Including load-balancing, deliverance of website content and serving DNS connection for website operators. / Session;

- __zlcstore / This cookie is necessary for the chat-box function on the website to function. / Persistent;

- AWSALBCORS / Registers which server-cluster is serving the visitor. This is used in context with load balancing, in order to optimize user experience. / 7 days.

13.4.2. Personalization - We use cookies to store information about Your preferences and to personalize our System for You.

13.4.2.1. For the purposes of personalization We use the following Preference cookies, that enable System to remember information that changes the way the System behaves or looks, like Your preferred language or the region that You are in:

- __zlcstore / Necessary for the functionality of the website's chat-box function. / Session;

- ZD-store / Registers whether the self-service-assistant Zendesk Answer Bot has been displayed to the website user. / Persistent.

13.4.3. Security - We use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to secure our System and Services generally.

13.4.4. Analysis - We use cookies to help Us to analyze the use and performance of our System and Services.

- c.gif / Collects data on the user’s navigation and behavior on the website. This is used to compile statistical reports and heatmaps for the website owner. / Session;

- sentryReplaySession / Registers data on visitors' website-behaviour. This is used for internal analysis and website optimization. / Session;

- _clck / Collects data on the user’s navigation and behavior on the website. This is used to compile statistical reports and heatmaps for the website owner. / 1 year;

- _clsk / Registers statistical data on users' behaviour on the website. Used for internal analytics by the website operator. / 1 day;

- ZD-suid / Registers statistical data on users' behaviour on the website. Used for internal analytics by the website operator. / Persistent;

- ZD-buid / Unique id that identifies the user on recurring visits. / Persistent;

- CLID / Identifies the first-time Clarity saw this user on any site using Clarity. / 1 year;

- _cltk / Registers statistical data on users' behaviour on the website. Used for internal analytics by the website operator. / Session;

- td / Registers statistical data on users' behaviour on the website. Used for internal analytics by the website operator. / Session;

13.4.5. Other cookies – We might also use other cookies that are not listed in the clauses above. We reserve the right to amend the list of the usable cookies by amending the respective clauses of this Privacy Policy.

- test_cookie / Marketing tracking / 1 day;

- MUID / Identifies unique web browsers visiting Microsoft sites. These cookies are used for advertising, site analytics, and other operational purposes. / 1 year;

- MR / Indicates whether to refresh MUID. / 7 days;

- SRM_B / This cookie identifies unique web browsers visiting Microsoft sites. These cookies are used for advertising, site analytics, and other operational purposes. / 1 year;

- SM / Used in synchronizing the MUID across Microsoft domains. / Session;

- ANONCHK / Indicates whether MUID is transferred to ANID, a cookie used for advertising. Clarity doesn't use ANID and so this is always set to 0. / 1 day;

- pagead/landing / Collects data on visitor behaviour from multiple websites, in order to present more relevant advertisement - This also allows the website to limit the number of times that they are shown the same advertisement. / Session;

- ads/ga-audiences / Used by Google AdWords to re-engage visitors that are likely to convert to customers based on the visitor's online behaviour across websites. / Session;

- _gcl_au / Used by Google AdSense for experimenting with advertisement efficiency across websites using their services. / 3 months;

- _ga_# / Used to send data to Google Analytics about the visitor's device and behavior. Tracks the visitor across devices and marketing channels. / 2 years;

- _ga / Used to send data to Google Analytics about the visitor's device and behavior. Tracks the visitor across devices and marketing channels. / 2 years;

- __zlcmid / Preserves users states across page requests. / 1 year;

- __storejs__ / - / Persistent.

13.4.6. Cookie consent - We use cookies to store Your preferences in relation to the use of cookies more generally.

13.5. Our service providers use cookies and those cookies may be stored on Your computer when You visit our System, for example Google Analytics, Facebook pixel, etc.

13.6. Managing cookies. Most browsers allow You to reject and delete cookies. The methods for doing this depend on the browser and its version. You can however obtain up-to-date information about blocking and deleting cookies via these links:

13.6.1. https://support.google.com/chrome/answer/95647 (Chrome).

13.6.2. https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox).

13.6.3. https://help.opera.com/en/latest/security-and-privacy/ (Opera).

13.6.4. https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer).

13.6.5. https://support.apple.com/en-gb/guide/safari/manage-cookies-and-website-data-sfri11471/mac (Safari).

13.6.6. https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).

13.7. Cookies preferences. You can manage Your preferences relating to the use of cookies on our System.

13.8. Service provider. The Company uses third party service provider Cookiebot consent management platform. It is a plug-and-play compliance solution that detects and controls all cookies and trackers in use on a website, and automatically manages end-user consents. You can find more information here: https://www.cookiebot.com/en/privacy-policy/.

13.9. Our details. The System (this website) is owned and operated by Comet Tech Inc. is a legal entity, incorporated in the Republic of Panama, registration number 155734567, address Advanced Tower Building, First floor, Ricardo Arias Street, Panama City, Republic of Panama. You can contact Us via email, by sending Your inquiry to [email protected], [email protected], or by sending Us a letter to our registered address.