Privacy Policy and Terms of Service form one agreement
The policy asks you to read it together with the Terms of Service. Surfshark says the two documents together are a single, legally binding agreement between you and Surfshark.
Supporting quotations
This Privacy Policy should be read alongside our Terms of Service. Together, these two documents create a single, legally binding agreement between you and Surfshark.
Qualifications & exceptions
The Terms of Service are only linked; their text is not part of this document.
Not stated here
What the linked Terms of Service say, and whether anything in them changes how this policy applies, is not shown in this source.
Legal Rights & Agreement Rules · Context
Highlighted summaries are only helpful guides
Surfshark says the policy is lengthy, so it added highlighted short breakdowns. It describes them as helpful guides that make the legal language easier to understand.
Supporting quotations
These highlighted bits will do precisely that! Think of them as helpful guides — they'll make the legal language easier to understand.
Qualifications & exceptions
The text calls the highlights guides; it does not say whether they have legal effect separate from the full text.
Not stated here
Whether the highlighted breakdowns are binding, or only the full policy text, is not stated.
Legal Rights & Agreement Rules · Company practice
Continued use counts as agreeing to the policy
By continuing to use the website or the services you agree to the current Privacy Policy. Surfshark asks you not to use its services and website if you do not agree with the policy or any of its provisions.
Supporting quotations
By continuing to use our Website and / or Services, you agree to the terms of the current Privacy Policy.
We kindly request that you refrain from using our Services and Websites if you do not agree with this Privacy Policy or any of its provisions.
Qualifications & exceptions
Agreement is tied to the current version of the policy.
The wording is a request ("We kindly request") that you refrain from using the services if you disagree.
Legal Rights & Agreement Rules · Company commitment
Surfshark may change the policy; only significant updates get advance notice
Surfshark may amend the policy from time to time. For significant updates it says it will tell you ahead of time through the website or by email. The date of the latest update is shown at the top of the policy; this version says it was last updated on 2026.10.12.
Supporting quotations
We may need to amend the Privacy Policy from time to time. If there are any significant updates, we'll let you know ahead of time through our Website or by email. You'll always find the date of the latest update at the top of the Privacy Policy.
Last updated: 2026.10.12
Qualifications & exceptions
Advance notice is promised only for "significant" updates, not for every change.
Notice goes through the Website or by email.
Not stated here
What counts as a significant update, and how far ahead notice is given, are not defined.
Whether less significant changes take effect without any notice is not stated; the policy only says the latest update date is shown at the top.
Legal Rights & Agreement Rules · Company practice
EEA transfers rely on Standard Contractual Clauses or adequacy decisions
Surfshark says it uses Standard Contractual Clauses approved by the European Commission to transfer personal data from the EEA to countries outside the EEA, for example the USA, or it transfers personal data to countries the European Commission has recognized as ensuring an adequate level of data protection. The policy links to the Commission pages describing these.
Supporting quotations
we use Standard Contractual Clauses approved by the European Commission (you can access it here) to transfer your personal data from the EEA to other countries outside the EEA territory (e.g., the USA) or we transfer personal data to countries that the European Commission has recognized as ensuring an adequate level of data protection
Qualifications & exceptions
The mechanisms named are for transfers from the EEA.
The USA is given as an example of a destination outside the EEA.
Not stated here
The text does not say what safeguards apply to transfers that do not originate in the EEA.
The linked Commission pages are not part of this source.
Legal Rights & Agreement Rules · Company commitment
Law enforcement disclosures: legal obligation, and a Transparency report page
For disclosures to law enforcement authorities or courts, the policy gives the legal ground as legal obligation. Surfshark says its Transparency report page will display if it is ever asked to make such a disclosure.
The ground stated for this category is a legal obligation.
Not stated here
The text does not say how quickly or in what detail the Transparency report is updated.
Legal Rights & Agreement Rules · User right or choice
Right to complain to the UK ICO or an EU supervisory authority
If you are located in the UK you have the right to lodge a complaint with the Information Commissioner's Office. If you are located in the EU, you have the right to lodge a complaint with the relevant Supervisory Authority.
Supporting quotations
Right to lodge a complaint If you are located in the UK, you have the right to lodge a complaint with the Information Commissioner’s Office. If you are located in the EU, you have the right to lodge a complaint with the relevant Supervisory Authority.
Qualifications & exceptions
Depends on whether you are located in the UK or the EU.
Not stated here
The text does not say what complaint route applies elsewhere.
Legal Rights & Agreement Rules · Context
The Cookie Policy is an integral part of this Privacy Policy
Surfshark says you can check which cookies it uses in its Cookie Policy, and that the Cookie Policy is an integral part of this Privacy Policy.
Supporting quotations
You can check what cookies we use in our Cookie Policy which is an integral part of this Privacy Policy.
Qualifications & exceptions
The Cookie Policy is a separate linked document whose text is not part of this source.
Not stated here
The linked Cookie Policy's text is not supplied here, so this card cannot say what it contains or whether it changes anything stated in this document.
Legal Rights & Agreement Rules · Restriction or exception
The English version prevails over translations
Surfshark says the English version of the policy prevails. Translations may be provided but may not be fully up to date or comprehensive, and if the English and a translated version conflict, the English version always takes precedence.
Supporting quotations
The English version of this Privacy Policy prevails.
While translations of this Privacy Policy may be provided in other languages, they may not be fully up-to-date or comprehensive. Thus, in case of any conflict between the English version and the translated versions of this Privacy Policy, the English version shall always take precedence.
Qualifications & exceptions
Applies to conflicts between the English version and translations.