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Privacy Policy

This Privacy Policy governs the manner in which VPN Observer, Inc., Inc (“VPN Observer, Inc.”) collects, uses, maintains, and discloses information collected from users (each, a “User”) of its www.modernguild.com website and any derivative or affiliated websites on which this Privacy Policy is posted (collectively, the “Website”). VPN Observer, Inc. reserves the right, at its discretion, to change, modify, add, or remove portions of this Privacy Policy at any time by posting such changes to this page. You understand that you have the affirmative obligation to check this Privacy Policy periodically for changes, and you hereby agree to periodically review this Privacy Policy for such changes. The continued use of the Website following the posting of changes to this Privacy Policy constitutes an acceptance of those changes going forward from the date of the revision.

IF YOU ENTER INTO OUR STUDENT PARTICIPATION AGREEMENT, VPN Observer, Inc.’S COLLECTION AND USE OF PERSONALLY IDENTIFIABLE INFORMATION THAT YOU PROVIDE TO VPN Observer, Inc. UNDER THE STUDENT PARTICIPATION AGREEMENT WILL BE GOVERNED BY THE TERMS OF THE STUDENT PARTICIPATION AGREEMENT AND NOT BY THIS PRIVACY POLICY.

1. Privacy

VPN Observer, Inc. believes that every User should know how it utilizes the information collected from Users. The Website is not designed for or directed to children under 13 years of age, and VPN Observer, Inc. does not knowingly collect personally identifiable information from children under 13. Please note that the Website may contain links to other websites. These linked sites may not be operated or controlled by VPN Observer, Inc.. VPN Observer, Inc. is not responsible for the privacy practices of these or any other websites, and you access these websites entirely at your own risk. VPN Observer, Inc. recommends that you review the privacy practices of any other websites that you choose to visit.

VPN Observer, Inc. is based, and the Website is hosted, in the United States of America. If User is from the European Union or other regions of the world with laws governing data collection and use that may differ from U.S. law and User is registering an account on the Website, visiting the Website or otherwise using the Website, please note that any personally identifiable information that User provides to VPN Observer, Inc. will be transferred to the United States. Any such personally identifiable information provided will be processed and stored in the United States by VPN Observer, Inc. or a service provider acting on its behalf. By providing your personally identifiable information, User hereby specifically and expressly consents to such transfer and processing and the uses and disclosures set forth herein.

2. The Information VPN Observer, Inc. Collects

Users browsing the Website without registering an account or affirmatively providing personally identifiable information to VPN Observer, Inc. do so anonymously. Otherwise, VPN Observer, Inc. may collect personally identifiable information from Users in a variety of ways. Personally identifiable information may include, without limitation, (i) contact data (such as first name, last name, phone-number, and e-mail address); (ii) demographic data (such as time zone); and (iii) billing data (such as credit card number and expiration date). If User communicates with VPN Observer, Inc. by e-mail or otherwise or interacts with or uses the features on the Website, any information provided in such communications may be collected by VPN Observer, Inc.. VPN Observer, Inc. may also collect information about how Users use the Website, for example, by tracking the number of unique views received by the pages of the Website, the domains and IP addresses from which Users originate and other information made available via website traffic-analytics services. While not all of the information that VPN Observer, Inc. collects from Users is personally identifiable, it may be associated with personally identifiable information that Users provide VPN Observer, Inc. through the Website or otherwise. VPN Observer, Inc. may use “cookies” or “web beacons” to track how Users use the Website. A cookie is a piece of software that a web server can store on Users’ PCs and use to identify Users should they visit the Website again. Users may adjust their web browser software if they do not wish to accept cookies.

3. How VPN Observer, Inc. Uses Information

VPN Observer, Inc. may use personally identifiable information collected through the Website (i) for the specific purposes for which the information was collected; (ii) to contact Users with e-newsletters and special announcements; (iii) to contact Users regarding information and services offered by VPN Observer, Inc. and other related companies and its trusted affiliates, independent contractors, and business partners; (iv) to contact Users regarding their experiences on the Website; and (v) to otherwise enhance Users’ experience with VPN Observer, Inc. and such affiliates, independent contractors, and business partners. VPN Observer, Inc. may also use information collected through the Website for research regarding the effectiveness of the Website and the business planning, marketing, advertising, and services efforts of VPN Observer, Inc., its trusted affiliates, independent contractors, and business partners. VPN Observer, Inc. may also use the aggregate data, with any information that could be used to identify an individual or individual firm removed, collected through the Website to perform statistical analysis of the aggregate data. VPN Observer, Inc. may publish statistical analysis of the aggregate data.

4. Disclosure of Information

VPN Observer, Inc. may disclose personally identifiable information collected from Users to its employees and related companies, if any, and trusted affiliates, independent contractors, and business partners who will use the information for the purposes outlined above, as necessary to provide the services offered by VPN Observer, Inc. and to provide the Website itself, and for the specific purposes for which the information was collected. VPN Observer, Inc. may disclose personally identifiable information if required to do so by law enforcement or governmental agencies or in response to subpoenas, court orders, or other legal processes, to establish, protect, or exercise VPN Observer, Inc.’s legal or other rights or to defend against a legal claim or as otherwise required or allowed by law. VPN Observer, Inc. may disclose personally identifiable information in order to protect the rights, property, or safety of User or any other person. VPN Observer, Inc. may disclose personally identifiable information to investigate or prevent a violation by User of any contractual or other relationship with VPN Observer, Inc. or the perpetration of any illegal or harmful activity. VPN Observer, Inc. may also disclose aggregate, anonymous data based on information collected from Users to sponsors, investors, and/or potential partners. Finally, VPN Observer, Inc. may disclose or transfer personally identifiable information collected from Users in connection with or in contemplation of a sale of its assets or business or a merger, consolidation, or other reorganization of its business.

5. Security of Information

Information about Users that is maintained on VPN Observer, Inc.’s systems is protected using commercially reasonable security measures. However, no security measures are perfect or impenetrable, and VPN Observer, Inc. cannot guarantee that the information submitted to, maintained on, or transmitted from its systems will be completely secure. VPN Observer, Inc. is not responsible for the circumvention of any privacy settings or security measures relating to the Website by any Users or third parties.

6. Correcting, Updating, Accessing or Removing Personal Information

If User’s personally identifiable information changes (such as e-mail address or zip code), or if User no longer desires to receive non-account specific information from VPN Observer, Inc., VPN Observer, Inc. will endeavor to provide a way to correct, update, and/or remove that User’s previously-provided personal data. This can be done by emailing a request to VPN Observer, Inc. at Contacts page. Additionally, Users may request access to the personally identifiable information as collected by VPN Observer, Inc. by sending a request to VPN Observer, Inc. accordingly. Please note that in certain circumstances, VPN Observer, Inc. may not be able to completely remove User’s information from its systems. For example, VPN Observer, Inc. may retain User’s personal information for legitimate business purposes, if it may be necessary to prevent fraud or future abuse, for account recovery purposes, if required by law, or as retained in VPN Observer, Inc.’s data backup systems or cached or archived pages. All retained personally identifiable information will continue to be subject to the terms of the Privacy Policy to which User has previously agreed.