VPN Policy

This VPN Policy applies to all VPN Implementations (as defined below) distributed by Publisher (and, if distribution is expressly authorized by search provider, Publisher’s Syndication Partners) in connection with the Agreement. Unless otherwise defined herein, all capitalized terms have the meaning given in the Agreement. For the avoidance of doubt, other search provider Policies may also apply to VPN Implementations.

  1. VPN Implementations – Definition. “VPN Implementations” refer to any Implementation that directly incorporates a virtual private network service or functionality (“VPN Feature”), which VPN Feature allows users to establish a private connection, through the use of tunneling protocols (TCP/IP or UDP-based protocols), across a public or otherwise unencrypted network. VPN Implementations consist of “Partial VPN Implementations” and “Full VPN Implementations”.
  2. Partial VPN Implementations. “Partial VPN Implementations” refer to the subset of VPN Implementations for which the user agent and the full, unencrypted Internet Protocol (IP) address of the user is passed to search provider for each Query and each click on a Paid Result.
    1. Feed for Partial VPN Implementations. Partial VPN Implementations must use the delivery mechanism specified by search provider, as may be updated from time-to-time at search provider’s sole discretion. Currently, the only approved delivery mechanism for Partial VPN Implementations is the XML feed with beacon.
    2. Requirements for Partial VPN Implementations. Partial VPN Implementations must adopt the methodology specified by search provider (including, without limitation, any technical documentation provided by search provider) for passing the aforementioned user agent and user IP address for each Query and/or “click event” (i.e., user click on a Paid Result), which methodology may be updated from time-to-time at search provider’s sole discretion.
  3. Full VPN Implementations. “Full VPN Implementations” refer to the subset of VPN Implementations for which the user agent or the full, unencrypted IP address of the user is not passed to search provider for each Query and each click on a Paid Result.
    1. Marketing/Promotion. Full VPN Implementations must not be prominently promoted to users during the installation flow or within the Implementation itself.
    2. Enablement. Publisher must comply with search provider’s traffic set-up and enablement process, as may be updated by search provider from time-to-time, prior to any distribution of such VPN Implementation. Publisher must separate out the traffic for each VPN Implementation, with (i) VPN Feature-enabled traffic on a single non-billable source tag and (ii) VPN Feature-disabled traffic on a different single billable source tag. Traffic blending between non-billable source tags and billable source tags and grouping traffic from multiple VPN Implementations into a single source tag are strictly prohibited.
    3. VPN Traffic Cap. Publisher must comply at all times with the VPN Traffic Cap of 3% for each Full VPN Implementation, which VPN Traffic Cap may be updated from time-to-time by search provider. “VPN Traffic Cap” refers to the maximum percentage of VPN Feature-enabled traffic for a particular Full VPN Implementation measured against the combined, total traffic of that same Full VPN Implementation. For clarity, the “VPN Traffic Cap” is measured at the Full VPN Implementation-level, and not at the Partner- or Syndication Partner- level.