We, MWELT LIMITED, Registration number: 15888300, registered at Suite 1, 46 Dorset Street, London, United Kingdom, W1U 7NB ("we", "us" and "our") offers a range of different services through its software, including, but not limited to, "CtrlWeb Mobile Browser" (the "Browser"). This Privacy Policy (the "Privacy Policy") describes the types of information we collect, as well as how we manage, process, and store your data when you use our Software.
- Acceptance. Applicability. Our role
1.1. By accessing or using our Software and/or our Services, you acknowledge that you have read, understood, and agree to be bound by the terms of this Privacy Policy.
1.2. Unless otherwise defined herein, all capitalized terms used in this Privacy Policy shall have the meanings assigned to them in the Terms.
1.3. This Privacy Policy applies to our Software and/or our Services provided by us and our affiliates, except where a specific product or service is subject to its own separate privacy policy.
1.4. This Privacy Policy does not apply to services offered by other companies, organizations, or individuals, including products or websites that may be displayed through our Browser or linked from our Services. It also does not govern the data practices of companies advertising our Software and/or our Services, which may use cookies or other technologies to deliver their offerings and targeted advertisements.
- General provisions
2.1. Registration is not required to access or use our Software and/or our Services.
2.2. We do not request any personally identifiable information, such as your email address, except when you choose to contact our support team.
2.3. We do not log or record your IP address.
2.4. Our VPN servers do not store any access logs.
2.5. Our VPN infrastructure may temporarily process your IP address to establish a connection. This data is not logged, stored, or linked to any browsing activity.
2.6. We do not record URLs or any other information regarding the websites you visit.
2.7. We do not have access to your cookies or saved passwords.
2.8. We do not have access to the files you download.
2.9. AI-related requests are proxied and cannot be attributed to specific users.
2.10. Your queries are not used to train AI models.
2.11. Any feature requiring attribution will be clearly marked.
2.12. We implement technical and organizational measures to safeguard your privacy across all our Software and our Services. Where information is collected, it is only for lawful purposes and never includes data that personally identifies you unless expressly provided by you.
- Collected data
3.1. You are not required to provide any personal information to download or use our Software and/or our Services. When you download and/or use our Software and/or our Services, we may automatically receive standard information from your web browser and/or our Browser, including but not limited to: browser type, language preferences, referring website, and the date and time of each visitor request. This information is collected to help us better understand how our Software and/or our Services are used. From time to time, we may process such data for statistical purposes, for example, to compile and publish aggregated reports on website usage trends.
- Manually entered information
4.1. Occasionally, we may conduct surveys. Participation in such surveys is entirely voluntary. If you choose to participate, we may collect additional information that you provide, such as your email address. Information voluntarily submitted in surveys may be processed by third-party service providers engaged by us, whose access to personal data is strictly limited to what is necessary for the provision of their services and is governed by confidentiality obligations.
4.2. If you contact our support team, we may request additional information necessary to address and resolve your inquiry. Such information may include, but is not limited to, your operating system and version, as well as any other technical or account-related details that may assist us in diagnosing and resolving the issue.
- Automatically collected data
5.1. When you use our Software and/or our Services, certain technical data is automatically transmitted by your device, such as your IP address, device specifications, and language settings. This information is used solely on a temporary basis to deliver content, ensure the security of our Services, and verify that you are not an automated bot. We do not permanently store or associate your IP address or any unique identifiers with your searches or website visits. Instead, your IP address is anonymized in the format 1.2.3.XXX, which prevents us from recording or linking your activity to you.
- VPN Services
6.1. Our VPN services are provided solely to protect user privacy, security, and browsing confidentiality.
6.2. We do not collect, log, or store browsing activity, traffic data, or connection history.
6.3. No user data is sold, used for advertising, or disclosed to third parties for any purpose.
6.4. A non-personal technical identifier (Device ID) may be processed only to enable VPN connectivity and validate subscription status. This identifier cannot be used to identify any individual.
6.5. Our VPN infrastructure is operated with the support of a service provider that acts strictly as a data processor under our instructions. The provider does not use or disclose any information for its own purposes.
6.6. We commit that no data collected through the VPN functionality will ever be sold, used for profiling or advertising, or disclosed to third parties for any commercial purpose.
- Underage persons' data
7.1. Our Software is not intended for individuals under the age of 18. We do not knowingly or intentionally collect personal information from minors. If we become aware that we have inadvertently collected personal data from a minor in violation of applicable data protection laws, we will take all reasonable steps to delete such information promptly and securely.
- Use of collected data
8.1. In general, personal data you provide to us is used to respond to your inquiries, feedback, and/or requests, as well as to enhance the quality of our Software and/or our Services. Personal data may be processed for the following purposes:
• to improve the management and operation of our Browser;
• to enhance your overall experience with our Browser;
• for editorial purposes and to respond to user feedback;
• to conduct statistical analyses of user preferences;
• to refine content and assist in the development of new products or features;
• to send newsletters, surveys, special offers, and other promotional materials related to our Software and/or our Services, as well as for other marketing purposes;
• to disclose your information to third parties where required to do so by applicable laws or regulations;
• to publish user testimonials on our website, which may include your first name, if you have voluntarily provided it for this purpose.
8.2. We may also contact you to inform you about updates, enhancements, or new features of our Software and/or our Services, to notify you of special promotions, or to invite you to participate in surveys. You may opt out of receiving such communications at any time by following the unsubscribe instructions provided in our messages or by contacting us directly.
8.3. We may use the information we collect for statistical analysis and to generate reports. For example, to identify potential technical issues or monitor service performance. All such analyses are conducted in an aggregated and anonymized manner, ensuring that no individual user can be identified or tracked.
- Data protection
9.1. We are committed to safeguarding the security and confidentiality of your personal information. In accordance with Article 32 of the GDPR and other applicable data protection laws, we implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk, including measures to prevent unauthorized access, use, alteration, dissemination, or disclosure of your personal data.
9.2. Access to user data is strictly controlled and limited to a small number of authorized personnel, each of whom is bound by confidentiality and data protection obligations. Our security protocols are regularly reviewed, tested, and updated to address evolving threats and industry best practices.
9.3. While we take all reasonable and proportionate steps to protect your personal information, you acknowledge that no method of transmission over the Internet or method of electronic storage can be guaranteed to be entirely secure. Accordingly, although we strive to provide maximum protection, we cannot warrant or guarantee the absolute security of your personal data.
- Your rights of data subjects
10.1. As a data subjects, you have specific rights concerning your personal data, which may be exercised by submitting a request via email to [email protected]. These rights include, but are not limited to:
• the right to confirmation regarding the existence of personal data processing;
• the right to access personal data, in accordance with applicable legislation;
• the right to request the correction of incomplete, inaccurate, or outdated personal data;
• the right to data portability;
• the right to request the deletion of personal data when processed on the basis of consent, or when such data is unnecessary, excessive, or processed in violation of applicable legislation;
• the right to request information regarding the sharing of personal data;
• the right to revoke consent, where applicable.
10.2. We will assess each request and determine the most appropriate means of complying with it. However, in certain circumstances permitted or required by law, such as where processing is necessary to fulfill a legal obligation or a contractual commitment, we may be unable to comply with a request in whole or in part.
10.3. For security purposes, requests submitted via [email protected] will only be fulfilled once we have verified the identity of the requester. We may require additional information or documentation to confirm the identity and authority of the data subject. Any such data provided for verification will be securely stored and deleted after the applicable legal retention period for the lawful exercise of rights has expired.
10.4. We encourage you to keep your personal data accurate and up to date. You may review and update your information at any time, subject to verification of your identity when required.
10.5. Due to technical limitations, it may be difficult or impossible to verify whether you have ceased using our Software and/or our Services. For mobile applications in particular, it is currently not feasible to confirm whether an app has been uninstalled. In such cases, we reserve the right to delete the personal data you have provided if you have not used our Software and/or our Services for a prolonged period.
- Disclosure
11.1. We may disclose information in the following circumstances:
• compliance with legal obligations: In response to a subpoena, court order, investigative demand, or a lawful request from law enforcement, regulatory authorities, or other governmental agencies; to establish, exercise, or defend our legal rights; or as otherwise required by applicable law. Where legally permissible, we may notify you of such requests, but we are not obligated to do so;
• to prevent harm or illegal activity: Where we reasonably believe disclosure is necessary or appropriate to investigate, prevent, or take action regarding suspected unlawful activities, fraud, or other misconduct; to protect the rights, property, or safety of our organization, users, employees, or others; or to enforce our Terms, agreements, or policies;
• business transactions: In connection with a significant corporate transaction such as a merger, acquisition, divestiture, reorganization, consolidation, asset sale, or in the unlikely event of bankruptcy, including disclosure to prospective or actual purchasers, subject to applicable confidentiality requirements;
• statistical and anonymized data: We may share aggregated, anonymized, and non-personally identifiable information with the public, partners, or other third parties for purposes such as analyzing trends and usage patterns.
- Third-party service providers
12.1. We may engage third-party service providers to perform services on our behalf (such as customer support or technical infrastructure). These providers act strictly as data processors under our instructions and are prohibited from using the data for any other purpose. In accordance with Article 28 of the GDPR, all service providers processing personal data on our behalf act as "Data Processors". Such services may include, without limitation, customer support, data analysis, and the provision, maintenance, or enhancement of our website's functionality and features. These service providers are bound by contractual obligations to use your personal information solely for the purpose of providing such services to us and are prohibited from disclosing or using it for any other purpose.
12.2. Access to personal information is strictly limited to individuals and entities who require such access in order to perform their designated duties, and always in alignment with the purpose for which the data was originally collected. Some of these service providers may operate or store data outside your country of residence. In such cases, we implement additional safeguards—such as the use of Standard Contractual Clauses or equivalent legal mechanisms—to ensure that your personal data is afforded an adequate level of protection, consistent with applicable data protection laws and regulations.
12.3. Service providers are bound by a written agreement that:
• requires them to process personal data only on our documented instructions;
• obligates them to ensure that persons authorized to process personal data are bound by confidentiality obligations;
• requires them to implement appropriate technical and organizational measures to ensure data security;
• prohibits them from engaging other processors without our prior written consent;
• requires them to assist us in fulfilling our obligations to respond to data subjects' rights requests, ensure compliance with data security, and cooperate with supervisory authorities;
• mandates the deletion or return of all personal data at the end of their service provision;
• requires them to make available all information necessary to demonstrate compliance with applicable data protection laws.
- International data transfer
13.1. In certain circumstances, we may transfer limited personal information (such as your email address) to jurisdictions outside the country in which it was originally collected. This may occur, for example, because we operate servers in multiple locations worldwide. While your device will ordinarily connect to the nearest available regional server (e.g., a European server if located in Europe, or a U.S. server if located in the United States), you may connect to servers in other jurisdictions when using features such as VPN. In addition, because our Software is distributed globally, authorized team members located in various countries may access servers as required to operate, maintain, or improve our Software and/or our Services.
13.2. In all such cases involving cross-border transfers, we ensure adequate safeguards in compliance with articles 44-50 of the GDPR and comply with applicable legal requirements to ensure your personal information remains adequately protected.
13.3. The legal basis upon which we process your personal data will typically be one or more of the following:
• legitimate interests: Where processing is necessary to pursue our legitimate business interests or those of a third party, provided such interests are not overridden by your fundamental rights and freedoms;
• consent: Where you have provided your consent to the processing. You may withdraw your consent at any time without affecting the lawfulness of processing carried out prior to such withdrawal;
• contract performance: Where processing is necessary to perform a contract with you or to take steps at your request prior to entering into a contract;
• legal or regulatory obligation: Where processing is required to comply with a legal or regulatory obligation to which we are subject.
- End of data processing
14.1. This Privacy Policy applies throughout the period in which we store personal data. We retain and maintain your information: (a) for as long as required by law; (b) until the conclusion of personal data processing, as described below; or (c) for as long as necessary to protect our legal rights. For example, we may process your data during applicable statutory limitation periods or as needed to comply with legal or regulatory obligations.
14.2. The processing of personal data will terminate, when:
• the purpose for which the personal data was collected has been fulfilled, and the data is no longer necessary or relevant to that purpose;
• the data subject requests deletion of their personal data;
• a legal order or requirement mandates deletion.
14.3. Upon termination of processing, personal data will be deleted, except in cases where applicable law or this Privacy Policy requires retention.
- California Consumer Privacy Act notice
15.1. Effective January 1, 2020, the California Consumer Privacy Act of 2018 ("CCPA") grants California residents ("Consumers") specific rights regarding their personal information, as defined under the CCPA. In addition to the rights outlined in this Privacy Policy and subject to applicable CCPA exceptions, Consumers have the right to:
• opt out of the sale of their personal information, should such a sale occur;
• be informed about certain details concerning our collection and use of their personal information;
• request the deletion of certain personal information we have collected;
• appoint an authorized agent to exercise CCPA rights on their behalf, provided the agent presents a duly executed notarized power of attorney and sufficient information to verify the Consumer's identity and locate their information in our systems;
• not be discriminated against for exercising their CCPA rights.
15.2. We will not deny California residents the use of our Services, neither will we provide a different level or quality or services for exercising any of their CCPA rights, unless as permitted under the CCPA.
- Changes
16.1. We may revise, update, or amend this Privacy Policy from time to time. Any changes will be posted on our website https://ctrlweb.app, with the effective date clearly indicated. By continuing to use our Software and/or our Services after any such changes, you acknowledge and agree to review the Privacy Policy periodically and remain informed of any modifications. If you do not agree to the updated Privacy Policy, you should discontinue use of our Software and/or our Services.
For any questions, requests, or complaints regarding the processing of personal data, please contact us at [email protected].
Last updated: 26th of August, 2025
