Privacy Policy:

1. Introduction
   At the Pango Group, we believe it’s important that everyone, regardless of their situation, can obtain secure and private access to the internet. We always aim to provide this access without compromising the privacy of our customers. “Pango Group” means and refers to Pango Group, Inc., Pango GmbH, or Intersections, LLC d/b/a Pango Group, and our subsidiaries or affiliate entities (together, herein after referred to as “Pango”, “we”, “us”, or “our”).
   This Privacy Policy describes Pango’s general privacy practices with respect to our browser extension “My Browser Guard” (the “Extension”). This Privacy Policy applies to the access or use of our Extension, and you agree to be bound by this Privacy Policy if you access or use our Extension. If you do not agree with this Privacy Policy or any provisions hereof, please do not use our Extension.
2. What Information Do We Collect About You?
   This section describes the categories of personal data (or ‘personal information’) we may collect from and/or about you.
   2.1. Information You Provide to Us
   Contact Information:
   If you reach out to us and provide your name and email address, we may collect this information solely for the purpose of responding to your inquiry.
   2.2 Information Collected when You use Our Services.
3. Technical Data:
   Some user preferences or settings may be collected automatically by the Extension to enhance functionality. However, this information is stored locally on your device, and we do not have access to it. We do not transmit or store any of this data on our servers.
4. How Do We Use Your Information?
   We use the information we collect for various purposes described in this section. For visitors from the European Economic Area (EEA) or U.K., we also describe, below, our lawful basis for processing personal data.
   To provide, maintain, troubleshoot, and support our Extension. We use your information for this purpose on the basis that it is required to fulfill our contractual obligations to you. Examples include:
   For our digital threat platform, using threat and device information to determine whether certain items pose a potential security threat; and
   Generally, to ensure the proper functioning of the Extension.
   To communicate with users and prospective users. We use your information to communicate with you, including by responding to your requests, and sending you information and updates about our Extension.
   To improve our Extension. We want to offer you the best services and user experiences we can, so we have a legitimate interest in continually improving and optimizing our Extension. To do so, we use your information to understand how users interact with our Extension.
   To implement security measures and prevent harm or liability. We may use information for security purposes (such as to investigate security issues or to monitor and prevent fraud) and to prevent abuse. We may do this to comply with our legal obligations, to protect an individual’s vital interests, or because we have a legitimate interest in preventing harm or liability to us and our users.
   For compliance with legal obligations. We may use your information as required to comply with applicable law or regulation, legal process, or other legal obligation to which we are subject. For example, we may be compelled by a contract or court to provide certain information necessary to our business partners in order to fulfill the terms of a business agreement or our legal obligations. We may also use your information to enforce our legal rights and resolve disputes. To learn more about our practices regarding sharing your information with third parties for legal compliance purposes, see Section 4 below.
5. Disclosure of Information – Who Do We Share Your Information With and Why?
   Legal Disclosures:
   We may share your information when required to comply with a legal obligation or to protect your vital interests or those of another individual. Disclosure may also occur if it is necessary for the establishment, exercise, or defense of legal claims—whether in legal proceedings, regulatory matters, or other dispute resolution processes.
   Search Query Handling:
   Our Extension does not record or log any information related to your search queries. However, to provide relevant search results, your query is sent to Yahoo, which processes the request in accordance with its own data practices. As outlined in Yahoo’s Privacy Policy, Yahoo may store and handle this information. We do not control and are not responsible for how Yahoo—or any other search provider—collects, uses, or manages your data. Such practices are outside the scope of this privacy policy.
6. Cookies and Other Tracking Technologies.
   We use various technologies in our Extension to help us collect certain website or app user information.
   These technologies include:
   Cookies. “Cookies” are small text files that can be placed on your computer or mobile device in order to identify your web browser and the activities of your computer on the Website. Cookies enable Pango or third parties that we allow (such as certain of our authorized service providers) to set cookies on your device to recognize visitors to our websites.
   Pixel Tags / Page Tags / Web Beacons / Tracking Links. These tools allow us to determine if you perform a specific action on a web page or email message. When you access a page, ad, or email, or click a link, these items let us know that you have accessed that page, opened an email, or clicked a link.

Your Choices With Our Use of Cookies:

In general – You have the ability to manage your cookie preferences in your web browser settings, including deleting cookies and blocking cookies from being set on those browsers or devices. Visit the “help” section of your browser to understand what controls it gives you over cookies. Note that deleting or blocking certain cookies could adversely impact the proper operation of our Extension, and, in some cases, some features of the website(s) may not function as a result.
Industry Advertising Choices – For information on how to opt out of personalized or interest-based advertising, you can visit the following pages:

U.S.: Digital Advertising Alliance opt out page
EU or UK: Your Online Choices
For visitors to Pango.co, we currently do not use third party advertising or cookies that enable preferences.
Pango’s Cookie Policy is available here. For more information on a Pango Product website’s use of cookies, visit the respective product specific websites to view its applicable cookie notice or policy terms.
6. Information Security.
We understand the importance of protecting information provided to or collected by us, including personal data, and employ reasonable and appropriate methods (including a range of administrative, organizational, technical, and physical safeguards designed to protect your data such as use of best practices, procedures, policies, training, technology, and oversight) to protect against and reduce the risk of unauthorized access, loss, or release of data. While our controls are strong and we strive to protect your personal information through these various means, we cannot guarantee or warrant the security of the information, as no data security measures can guarantee 100% protection. We recommend you take every precaution in protecting your personal information when you are on the Internet or otherwise. You should change your passwords often, use a combination of letters and numbers when creating passwords, and make sure you use a secure browser.
7. International Data Transfers.
Depending on where you reside, Pango may transfer your personal data to countries other than the one in which you reside. We do this to facilitate our operations, and transferees include other Pango companies, service providers, and partners. Laws in other countries may be different to those that apply where you reside. For example, personal data collected within the U.K., Switzerland or the European Economic Area (EEA) may be transferred and processed in the United States for purposes described in this policy. However, we put in place appropriate safeguards that help to ensure that such data receives an adequate level of protection, which typically includes Pango and corporate recipients executing the Standard Contractual Clauses (aka ‘Model Contracts’) adopted by the European Commission or UK for such transfers to the U.S.
8. Data Retention.
Pango generally retains your personal information for as long as is needed to provide the Services to you. We retain your personal information as reasonably necessary for the respective purpose. We may also retain personal information if required by law, or for our legitimate interests, such as abuse detection and prevention, and defending ourselves from legal claims. Residual copies of personal data may be stored in backup systems for a limited period as a security measure to protect against data loss.
9. Your Rights.
Depending on your state or country of residence, you may have certain legal rights with respect to your personal information, subject to exceptions and limitations provided by applicable laws and regulations.
9.1. General.
In general, you may have the following rights to your personal data:
access and receive a copy of your personal data;
correct your personal data;
restrict the processing of your personal data;
object at any time to the processing of your personal data;
have your personal data erased;
data portability;
withdraw any consent you previously gave to the processing of your data (such as opting out to marketing communications);
lodge a complaint with a data protection authority;
request that we provide you with the categories of personal data we collect, disclose or sell about you; the categories of sources of such information; the business or commercial purpose for collecting or selling your personal data; and the categories of third parties with whom we share personal data. Note some of this information may already be provided in this Privacy Policy.
For clarity, the above describes examples of rights an individual may have. You may have some, but not all of the rights described above, depending on where you reside and what laws and regulations apply to you. Additional U.S. state specific privacy rights are further described below.
You may be able to exercise some of these rights by using the settings and tools provided in our Services. For example, you may be able to update your user account details via the relevant account settings screen of our apps. You may also be able to opt out from receiving marketing communications from us by clicking an “opt out” or “unsubscribe” link in such communications.
Some mobile and web browsers transmit “do-not-track” or “opt-out preference” signals. We currently do not take action in response to these signals. Otherwise, if you wish to exercise any of these rights, you may contact us using the details in the “Contact Us” section below. As permitted by law, we may ask you to verify your identity before taking further action on your request. You may also be permitted to designate an authorized agent to submit certain requests on your behalf. If you do so, you must give the authorized agent written permission to make such requests, or a power of attorney. We may also follow up with you to verify your identity before processing the authorized agent’s request.
9.2 Your California Privacy Rights.
The information provided in this Privacy Policy describes the categories of personal information Pango may collect, process and share with certain service providers and other businesses. If you are a California resident and would like to exercise your rights to receive the specific pieces of information, or other privacy rights applicable to you, please contact us as specified in the ‘Contact Us’ section below.
Pango does not ‘sell’ personal information for our own monetary benefit. However, as the CCPA defines ‘sell’ broadly, some of the advertising services that support our website, marketing efforts, and mobile applications use third party advertising services that may be deemed a ‘sale’ under California law. Please see our terms relating to your choices relating to cookies and the app-specific advertising services listed above to indicate your preferences with respects to ads or cookie usage as applicable.
California residents also have the right to limit the use of sensitive personal information if we use that information for purposes beyond what is needed to provide the services you request or for other reasons specified in the CPPA. As we do not use or disclose sensitive personal information for other purposes without your consent, we do not offer you an option to limit the use of sensitive personal information.
9.3 Other U.S. Only State Specific Privacy Rights
If you are a resident of California, Colorado, Connecticut, Maine, Nevada, Oregon, Texas, Utah, or Virginia, you may have specific or additional rights under your state’s privacy laws.
Depending on the jurisdiction where you reside and the scope of applicability, you may have certain of the following rights with respect to your personal information:
Right to know what personal information we collect, how we use and share it, and how long we keep it. The state laws generally require that we provide you information about the categories of personal information we collect and the purposes for which we collect each category. This Privacy Policy provides details about our collection and usage practices. As described in Section 2 of this Privacy Policy, we collect personal information when you interact with us and use our Extension, from third parties, and from the devices you use. We retain information only as long as reasonably necessary for business, accounting, tax or legal purposes and then securely delete it
Right to access, delete and correct information. You may have the right to request access to your information, or for us to delete or correct your personal information. Please contact us to request that we delete personal information we have about you, or to correct inaccurate personal information we have about you. Unless we need it for reasons specified or permitted by applicable laws or regulations, we will work with you to delete your personal information accordingly. You may also request access to your information, and we will provide the relevant information to you in a portable and readily usable format.
Right to tell us not to use personal information to create profiles about you that we use to inform decisions that have legal or similarly significant effects. We do not use personal information to profile you to further decisions that have legal or similar significant effects.
Right to tell us not to sell personal information or process it for certain targeted advertising purposes. The laws vary in the way they define sale and certain targeted advertising, but generally, they require that we provide you with the ability to limit activities that involve sharing personal information for monetary or other valuable consideration and using personal information about you from your activity across other websites or apps to target ads to you. You can opt out of certain sharing or processing of your personal information by accessing your privacy preferences page for the applicable Product website. We do not currently respond to Do Not Track signals. We do not knowingly sell or share personal information related to children under 16 years of age.
Right to appeal a denial of your request to exercise the privacy rights provided by the state law. Some states allow you to appeal a denial of your request to exercise your privacy rights provided by applicable state law. If you are a resident of Colorado, Connecticut, Oregon, Texas, or Virginia and we deny your request to exercise certain rights pertaining to your personal data, you can appeal the denial of a request to exercise privacy rights by following the instructions listed in the denial communication, by submitting a request through a privacy inquiry to reach@mybrowserguard.com
Right to not be discriminated against. Some state laws ensure that you have the right to not be discriminated against. We do not discriminate against you, or anyone, for your/their exercise of any rights provided to you by applicable state law.
You can exercise your right to know, access, delete, and correct data directly, or, in California, Colorado, Connecticut, Oregon, and Texas, you may appoint an authorized agent to act on your behalf, by submitting a request. You can exercise your right to opt-out of selling and sharing by visiting the applicable privacy preferences page or the cookie banner for the Extension you are using. Note we may require you to verify your identity using the processes we describe in an applicable Product dashboard or the privacy choices page before we fulfill your request.
10. Age Restrictions.
Our Extension is not intended for and may not be used by minors. In this context, minors are individuals under the age of 16 except for our identity and credit monitoring services, which are restricted to those under the age of 18. Pango does not knowingly collect personal data from minors or allow them to use our Extension. If we discover that we have collected personal data from a minor, we may delete such data without notice. Please note that the legal terms under which we make certain Extension available may require users to be older than 16 years of age.
11. Privacy Policy Updates.
Pango may update this Privacy Policy from time to time in accordance with this section for reasons such as changes in laws, industry standards, and business practices. Pango will post updates to this page and update the “Last updated” date above. If we make updates that materially alter your privacy rights, we will also provide you with advance notice, such as via email or through the services. Your continued use of our Extension will be subject to the updated Privacy Policy.
12. Contact Us.
We expect this Privacy Policy to evolve over time and welcome feedback from our users about our privacy practices. If you would like to exercise your rights, have any questions or complaints about our privacy practices, you can contact us using the following details or submit your request to our Help Center:
Pango Group, Inc.
250 Northern Ave, Floor 3
Boston, Massachusetts, 02210
reach@mybrowserguard.com
Pango GmbH
Hansmatt 32, 6370 Stans, Switzerland
reach@mybrowserguard.com
For visitors from the UK or EEA, the GDPR gives you additional rights to contact our Data Protection Officer (DPO). Pango Group has appointed Bird & Bird DPO Services SRL as a DPO for Pango and its services, and may be reached:
by mail at the following address: Bird & Bird DPO Services SRL, Avenue Louise 235 b 1, 1050 Brussels, Belgium.