Human Privacy

Version 1.0 dated 15 May 2017

This Privacy Policy describes our practices regarding your Personal Data at any time you are interacting with our Services via the website snowd.com or via any other software product of our company.

By using or accessing the SNOWD Services, you agree to provide us with your Personal Data in the volume specified in this document and allow us to process the provided data in the manner described below.

The terms of the agreement on collecting, storing and sharing the personal data of the SNOWD users have been developed and tested for compliance with laws in different jurisdictions. By this we wanted to ensure that the use of our means for personal information protection meets your expectations of possible legal consequences. When speaking about the fact that we do not transfer data to third parties, we want to be sure that we will be able to fulfill this condition in case of receipt of a request from special state services. To this end, we describe the present conditions of confidentiality that serve the purposes of promoting freedom of access to information (renunciation of information inequality) and protecting the right to privacy.

1. Disclaimer of storing the following personal user data

SNOWD Inc. officially and with full responsibility declares the refusal to save the following data in any (explicit or implicit) form:

IP address of the snowd.com website visitor;

IP address of the web resource to which the user connects via the SNOWD service;

Identification payment details of the user;

Any information that users transmit or receive when they connect to our service.

We also declare about every possible counteraction against storing of the data listed above by a third party, regardless of its organizational, legal or political affiliation.

2. Responsibility for data processing
2.1 Jurisdiction

Snowd Security OU is registered in Estonia. Servers of our Services have a wide geographical coverage, which imposes an obligation on us to work with different jurisdictions. Taking this into account, we do not store personal information of our clients anywhere except the server located on the territory of Estonia and falling within the jurisdiction of this country.

When using the SNOWD services, you should be aware of our responsibility towards the law of Estonia which allows the intervention of a third party in disclosing the data we are storing (which can only happen by decision of the Court of Estonia).

2. Processing of personal user data

We do not store any other personal data except those described in paragraph 2.2. This means that the servers that are located outside the jurisdiction of the SNOWD registration country do not store any information relating to the user interaction and network activity. Thus, we protect our users' data from leakage in case of intervention by the government of the region, under whose jurisdiction the physical location of the SNOWD equipment falls.

2.1 The definition of “Personal Data”

By "Personal Data" we mean any information about users and their network activity. Personal data includes registration data for accessing the software products and associated network resources of SNOWD Services; any network activity data relating to the settings of the user's Internet connection to the SNOWD servers.

Below is a comprehensive list of data to be stored by the SNOWD servers.

2.2 Description of user registration data

Here we describe the complete list of data necessary for the interaction of a user with the service. We also guarantee the described conditions for saving this data.

Items Usage Source / Saving
E-mail Required. Replaces Login. It serves to identify the user in the Services. Specified by user. Not saved after changing.
Password Required. It serves to identify the user in the Services. Specified by user. / Not saved after changing.
Twitter ID Not required. Used to calculate the bonus within the program "Share Freedom" Specified by user. / Not saved after changing or removing
Applications Required. Types and versions of software products that are installed on user devices. Used to calculate the bonus within the program "Spread The Freedom". Automatic collection / Update history is stored
Limit of free traffic Required. Data on the accumulated traffic limit Automatically updated one month after the first start for unauthorized users / every month after registration in the application.
2.3 Description of the user electronic connections data

Below is a comprehensive list of the data related to the user activity which is stored in our system.

Attention! We do not store or track which resources you visit!
Items Usage Source / Saving
IP address and time of VPN session start / termination Required. Used along with server id and access time to counteract hacker attacks. Automatic collection. Storing for 90 days.
Data volume used within the current month Required. It serves to identify the user in the Services. Automatic collection. Storing during the current month.
2.4 Using of personal data to counteract hacker attacks and other violations of the service usage rules

To counteract hacker attacks and to protect personal data from cracking, we follow the "Terms of Service". We consider applications from a third party about possible violation and issue a warning to the violator. After the consideration of the application about violation of the SNOWD service usage rules the access to the violator account can be blocked. For more information about the rules of using the service and the conditions for access locking, see the section "Terms of Service". To identify a violator, we use IP address and time of connection.

Under no circumstances we will voluntarily give personal data of our users to a third party. And in the case the storage period is over, we exclude such possibility at all, as we can not have this data.

2.5 Account security

By accepting these terms, you recognize the responsibility for keeping passwords for authorization in the SNOWD system. Also, you recognize your responsibility for any actions in the Service under your account. In case you lose control over your account, we recommend you to immediately reset your password. If you find yourself being a victim of hacking and unauthorized using of your account, please notify us immediately.

3. Data processing during the execution of payment transactions

During execution of payment for our service, the processing system requests payment details of bank cards or other registration data (depends on the payment method). We do not save payment data of our users. The billing system SNOWD only receives a response from the processing system about the result of payment transactions. Thus, in our system we only reflect the fact of payment in the form of a financial transaction date and transaction number for each registered account . The transfer of user data at the time of payment is securely protected with an SSL certificate. Our users should be aware that the fact of making a paid operation (which indicates the fact of using the SNOWD service) can be disclosed by the processing system under the pressure of special services.

4. COOKIES data collection and processing policy

The website snowd.com ( hereafter the Site) does not use cookies to collect information about the user. We do not limit access to information or useful functions of the site for users whose browsers do not accept cookies. We do not allow recording of Cookies data by third-party applications (analysis systems, billing, retargeting networks) while visiting our site. We also renounce to use "bugs" to display advertising in retargeting (remarketing) systems or any ads targeting with using cookies.

5.Data processing by the web analytics system

To analyse the attendance of our site, we use the Open Analytics Platform PIWIK which is installed on our own servers. The data access on these servers is restricted to a third party. Storing of the history with the visitor statistics takes place on our servers located in the Seychelles Republic. To store the history of attendance of our site, we use automatic IP anonymization (storing the visitor's IP address as a 2-byte mask, for example: 192.168.ххх.ххх), which allows us to save only the approximate geography of the visit). We also respect the "Do Not Track" policy (http://donotrack.us) and, in case when there the option to prohibit tracking is enabled in the browser settings of a user, we will not take into account and store the user visits in the the analytics system history. In SNOWD applications that you install on your devices, we adhere to the terms of this privacy policy and analyse the data of an impersonal interaction with application interfaces in order to improve the ease of use. We do not use GPS / GLONASS or other technologies to determine the geographical location of your device.

6. Conditions for changes and additions made on this page.

We store the change history of the given document. When making changes, we ensure that there are no contradictions between the new version and the terms of previously published documents. Each document has its version and time (to the nearest minute) from which the new rules come into force. We commit ourselves to notify users about any changes made to this document via e-mail at least one day prior to the date of these changes coming into force.