Last updated
Jan 1st, 2020

Privacy Policy

The protection of your personal data is very important to us, and we understand our responsibilities to handle your personal data with care, to keep it secure and to comply with legal requirements.


1. Privacy policy contents

This Privacy Policy describes how we handle and protect your personal data and the choices available to you regarding collection, process, access, and how to update, correct and delete your personal data. Additional information on our personal data practices may be provided in product settings, contractual terms, or notices provided prior to or at the time of data collection


2. What data do we collect?

2.1 User Activity Data

While a user’s device is tunneled through VPN, we collect some information about how they’re using it. We record what protocol VPN used to connect, how long the device was connected, how many bytes were transferred during the session, and what city, country, and ISP the connection came from. For some domains (but very few, and only popular ones) or server IP addresses (e.g., known malware servers) that are visited, we also record how many bytes were transferred to it. (But never full URLs or anything more sensitive. And only domains of general interest, not all domains.)

Geographical location and ISP info are derived from user IP addresses, which are then immediately discarded.

We consider user activity data the most sensitive category of data. We never, ever share this data with third parties. We keep user activity data for at most 60 days, and then we aggregate it and delete it. Backups of that data are kept for a reasonable amount of time.

2.2 Aggregated Data

Data is “aggregated” by taking a lot of sensitive user activity data and combining it together to form coarse statistical data that is no longer specific to a user. After aggregation, the user activity data is deleted.

Aggregated data is much less sensitive than activity data, but we still treat it as potentially sensitive and do not share it in this form.

2.3 Shareable Aggregated Data

When sharing aggregated data with third parties, we make sure that the data could not be combined with other sources to reveal user identities. For example, we do not share data for countries that only have a few VPN users in a day. We make sure that the data is anonymized.

We also never share domain-related information with third parties.


3. Children’s privacy

You represent and warrant that you are at least 13 years of age and of legal competence to use our Service. If you are under 18, please be sure to read the Agreement with your parents or legal guardians. We do not use the Service to knowingly solicit data from or market to children under the age of thirteen (13). We request that such individuals do not provide Personal Data through our services. If you become aware or have any reason to believe that a child under the age of 13 has shared any information with us, please contact us and we take reasonable steps to ensure that such information is deleted from our files.


4. Why do we collect your personal data?

We collect the Personal Data for the purpose of:

  1. Service improvement and personalization of the user experience
  2. The proper administration of our Website and business
  3. The performance of the contract between you and us and/or taking steps, at you request, to enter into such a contract
  4. Scientific research, fraud detection/prevention and improvement of the Service
  5. To notify you of our new services or changes to our existing Services
  6. To send you technical or service-related communications
  7. To verify identity, assist with identification of users, and to determine appropriate services;
  8. To communicate with you and send you important notices or personalized messages, such as communications about purchases and changes to our terms, conditions, and policies
  9. To monitor, evaluate and analyze trends, data, transactions, usage and activities in connection with our products and services


5. Sharing your personal data

We may share your data with other affiliate companies in or outside Europe. We may also share your data with third parties, to help manage our business and deliver services. These third parties may from time to time need to have access to your personal data. These third parties may include:

  • Service providers or partners, who perform functions on our behalf such as fulfilling orders, delivering packages, sending postal mail and e-mail, removing repetitive information from customer lists, analyzing data, providing marketing assistance, providing search results and links (including paid listings and links), processing credit card payments, and providing customer services or other activities as necessary part of the functioning in our product or service. Such third parties may handle your information on behalf of us. If you don’t wish to allow their access and processing, please contact us to make your notice. If you share your data through one of our websites or devices with a third party account such as Facebook, Google+ or Twitter, your personal data will be managed respectively by one of those third parties. Please review the third party’s privacy policy, as their data processing will not be covered by this Policy;
  • Our regulators, including regulators and law enforcement or investigation agencies in the E.U., U.S., China, and around the world;
  • Other third parties, for the purposes of detecting, preventing or otherwise addressing fraud, security or technical issues (such as cyber-attack, or other illegal or immoral acts), targeting at or related to protecting against harm to the rights, property or safety of our users or us, our affiliates, employees or the public;
  • Solicitors and other professional services firms (including our auditors).

Also, if we were to sell part of our businesses or assets, as required by applicable laws or agreed with relevant parties, we would need to transfer your personal data to the purchaser in case of carrying out relevant deals such as merger, acquisition or asset transfers.


6. How long do we keep your personal data?

We will retain your personal data for as long as is reasonably necessary. In some circumstances we may retain your personal data for longer periods of time, for example where we are required to do so to meet legal, regulatory, tax or accounting requirements.

In specific circumstances we may also retain your personal data for longer periods of time so that we have an accurate record of your dealings with us in the event of any complaints or challenges, or if we reasonably believe there is a possibility of legal action relating to your personal data or dealings. Where your personal data is no longer required we will ensure it is either securely deleted or stored in a way which means it will no longer be used by the business.


7. What are your rights?

Your principal rights under data protection law in relation to your Persona Data are:

  1. The right to access and information which is provided to you through your account;
  2. The right to rectification;
  3. The right to erasure;
  4. The right to restrict processing;
  5. The right to object to processing;
  6. The right to data portability;
  7. The right to complain to a supervisory authority; and
  8. The right to withdraw consent.

We provide you with the ability to exercise certain choices and controls in connection with our treatment of your Personal Data. Depending on your relationship with us, these choices and controls may include, access to the Personal Data collected about you that we hold; correcting, updating or deleting the information associated with you that we hold; and in the event, you wish to opt out from the data collection or you are not able to exerciser your rights through your account please contact us. In the event you make such request, note that we may require certain information from you in order to verify your identity and locate your data and that the process of locating and deleting the data may take reasonable time and effort. Data privacy and related laws in your jurisdiction may provide you with different or additional rights related to the data we collect from you, which may also apply.


8. How we protect your personal data?

We implement a variety of security measures to maintain the safety of your personal information when you place an order

We offer the use of a secure server. All supplied sensitive/credit information is transmitted via Secure Socket Layer (SSL) technology and then encrypted into our Payment gateway providers database only to be accessible by those authorized with special access rights to such systems, and are required to keep the information confidential.

After a transaction, your private information (credit cards, financials, etc.) will not be stored on our servers.


9. Contact and complaints

If there are any questions regarding this privacy policy you may contact us using the information below.

Email address: johnsonbercow@gmail.com