THE OTHER DAY we wrote about further suspicious things about Startpage, which had been grabbed by a mass surveillance company that also owns Dogpile, WebCrawler, MetaCrawler and maybe lots more. The whole thing triggered a nerve when they made up something called ‘Privacy One Group’ -- Orwellian doublespeak or newspeak for sure. It's part of a spying company, System1.
"It's part of a spying company, System1."But wait, it gets worse...
"System1 has a "privacy" browser in the Google Play Store," a reader told us. It's called Hushbrowser. "See the linked app page there and the associated privacy policy. If that's what System1 considers a privacy product..."
The link to the privacy policy (of the 'app') leads to a broken page (screenshot to the right), but if one goes to the site one can find the full text, which is a year old.
Let's look/consider how the "app" presents itself: "Hush Browser is a mobile web browser for Android that keeps you in control of your session data. With user-first privacy in mind, we set out to create a super lightweight, fast web browser that gives you an easy way to remove your data. Most browsers hide this deep within app settings accessible through confusing user flows, but we wanted to make this functionality front and center, both on-demand in the main menu and automatically every time you close the app."
Now let's look at the actual policy and annotate it with a yellow marker:
Privacy Policy
Last modified: May 15, 2018
System1 LLC respects your privacy and we are committed to protecting it through our compliance with this policy. This policy also applies to our subsidiaries Infospace Holdings LLC and Qool Media Holdings LLC.
Our services include our websites and applications that link to this privacy policy. This policy describes the types of information we may collect from you or that you may provide when you use our services and our practices for collecting, using, maintaining, protecting, and disclosing that information.
This policy applies to information we collect:
- When you use or interact with our services.
- In your email, text, and other electronic messages with us.
- Through our mobile and desktop applications.
Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our services. By accessing or using our services, you agree to this privacy policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of our services after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.
EU-US Privacy Shield and Swiss-US Privacy Shield
System1 LLC, and certain of its controlled US affiliates, Infospace Holdings LLC and Qool Media Holdings LLC, comply with the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland. System1 has certified that it adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability. If there is any conflict between the policies in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.
To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/
System1 is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).
Children Under the Age of 13
Our services are not intended for children under 13 years of age. No one under age 13 may provide any information to or through our services. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information through our services. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at:
Attn: Privacy Officer
1501 Main Street
Suite 201
Venice, CA 90291
Contact System1
Information We Collect About You and How We Collect It
We collect several types of information from and about users of our services, including information:
- by which you may be personally identified, such as name, postal address, e-mail address, telephone number, or any other identifier by which you may be contacted online or offline ("personal information");
- that is about you but individually does not identify you, such as your IP address, referral data, and browser and platform type; and/or
- about your internet connection, the equipment you use to access our services and usage details.
We collect this information:
- Directly from you when you provide it to us.
- Automatically as you use our services. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.
- From third parties, for example, our business partners.
Information You Provide to Us
The information we collect through our services may include:
- Information that you provide by filling in forms through our services. This includes information provided at the time of registering to use our services, subscribing to our service, posting material, or requesting further services. We may also ask you for information when you report a problem with our services.
- Records and copies of your correspondence (including email addresses), if you contact us.
Information We Collect Through Automatic Data Collection Technologies
As you use our services, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:
- Details of your use of our services, including traffic data, location data, logs, and other communication data and the resources that you use on our services.
- Information about your computer and internet connection, including your IP address, operating system, and browser type.
We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking).
The information we collect automatically is statistical data and does not include personal information, but we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our services and to deliver a better and more personalized service.
The technologies we use for this automatic data collection may include:
- Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our services. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our services.
- Flash Cookies. Certain features of our services may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our services. Flash cookies are not managed by the same browser settings as are used for browser cookies.
- Web Beacons. Portions of our services may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that allow us, for example, to count users who have visited pages and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
We do not collect personal information automatically, but we may tie this information to personal information about you that we collect from other sources or you provide to us.
Third-Party Use of Cookies and Other Tracking Technologies
Some content or applications, including advertisements, on our services are served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our services. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.
We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see Choices About How We Use and Disclose Your Information.
How We Use Your Information
We use information that we collect about you or that you provide to us, including any personal information:
- To present our services and its contents to you.
- To provide you with information, products, or services that you request from us.
- To fulfill any other purpose for which you provide it.
- To provide you with notices about your account, including expiration and renewal notices.
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
- To notify you about changes to our services.
- To allow you to participate in interactive features on our services.
- In any other way we may describe when you provide the information.
- For any other purpose with your consent.
We may use the information we have collected from you to enable us to display advertisements to our advertisers' target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.
Disclosure of Your Information
We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.
We may disclose personal information that we collect or you provide as described in this privacy policy:
- To our subsidiaries and affiliates.
- To contractors, service providers, and other third parties we use to support our business.
- To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.
- To fulfill the purpose for which you provide it.
- For any other purpose disclosed by us when you provide the information.
- With your consent.
We may also disclose your personal information:
- To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
- If we believe disclosure is necessary or appropriate to protect our rights, property, or for our safety, and that of our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
- Under certain circumstances, we may be required to disclose your personal information in response to valid requests by public authorities, including to meet national security or law enforcement requirements.
- System1’s accountability for data it receives pursuant to the EU-US and Swiss-US Privacy Shield and subsequent transfer of that data to third parties is detailed in the Privacy Shield Principles. In cases of onward transfer to third parties of data of EU or Swiss individuals received pursuant to the EU-US or and Swiss-US Privacy Shield, System1 is potentially liable. In particular, System1 remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process the personal data on its behalf do so in a manner inconsistent with the Principles, unless System1 proves that it is not responsible for the event giving rise to the damage.
Choices About How We Use and Disclose Your Information
We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:
- You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.
- For some of our products, we use Google Analytics Advertising Features, including Remarketing with Google Analytics, Google Display Network Impression Reporting, DoubleClick Platform integrations, and Google Analytics Demographic and Interest Reporting. For information about Google Analytics currently available opt-outs, please click here.
- Some of our products may include advertisements from Microsoft. To learn more about information collected by Microsoft, please click here. You can opt-out of Microsoft’s personalized advertising services by following the instructions found here.
- We do not control third parties' collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can also generally opt-out of receiving personalized ads from third party advertisers and ad networks who are members of the Network Advertising Initiative (NAI) or who follow the Digital Advertising Alliance’s Self-Regulatory Principles for Online Behavioral Advertising by visiting the opt-out pages on the NAI site and DAA site.
- System1 acknowledges that EU and Swiss individuals have the right to access the personal information that we maintain about them. An EU or Swiss individuals who seeks access, or who seeks to correct, amend, or delete inaccurate data, should direct their query to here. If requested to remove data, we will respond within a reasonable timeframe.
- We will also provide an EU or Swiss individuals with opt-out or opt-in choice before we share their data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized.
- To limit the use and disclosure of your personal information, please click here.
Accessing and Correcting Your Information
We desire to keep you in control of the personal information you provide to us. Accordingly, you can review, correct, change, or remove the personal registration information you provide to us and that we control. To choose not to receive future communications from us, please contact System1.
You may also send us an email here to request access to, correct, or delete any personal information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
Data Security
We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our services. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the services.
Dispute Resolutions
In compliance with the EU-US and Swiss-US Privacy Shield Principles, System1 commits to resolve complaints about your privacy and our collection or use of your personal information. European Union or Swiss individuals with inquiries or complaints regarding this privacy policy should first contact System1 here
System1 has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit http://www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint.
Under certain conditions, more fully described on the Privacy Shield website https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint, you may invoke binding arbitration when other dispute resolutions procedures have been exhausted.
Changes To Our Privacy Policy
It is our policy to post any changes we make to our privacy policy on this page. If we make material changes to how we treat our users' personal information, we will let you know through a notice in our services. The date the privacy policy was last revised is found at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting this privacy policy to check for any changes.
Contact Information
To ask questions or comment about this privacy policy and our privacy practices, contact us at:
Attn: Privacy Officer
1501 Main Street
Suite 201
Venice, CA 90291
Contact System1