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Kemal Allan

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Aug 5, 2024, 12:11:24 AM8/5/24
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Thispolicy describes who we are, how we collect, handle and protect your personal data and the privacy rights and choices available to you regarding the access, correction and deletion of your personal data.

This policy does not apply to service data which may be collected by different products, such as an antivirus app, or to the operation of cookies on our website. For information on how we handle website cookies, please visit our Cookies Policy.


When you create an account with us (note: this is necessary in order for you to use the VPN service), we will need some information about you. This is the personal data that is created and stored for the management of your account:


All of the above data is stored for as long as you use our service, as it is necessary for us to provide it. However, your Account Data is not paired with your activity usage. You can request a copy of your account data through support.


We rely on third-party payment processors to handle your product purchases. You can find out which provider we are working with for the point of purchase you chose (for example our website, an app store, etc) by looking at your transactional email or receipt.


These providers are in the position of independent controllers and may collect a variety of information about you to complete the purchase. All of them are PCI-compliant or the equivalent and are prohibited from using your personal data for anything but facilitating your payment and subscription management or as otherwise described in their applicable terms of service and privacy policy.


On our side, billing data is stored for as long as you continue to use our service, and for up to 10 years after that because of our legal obligations. If legal obligations change, or we need to resolve disputes and enforce our agreements, we may be obliged to keep this data longer than that.


To analyze application events from our VPN clients in order to understand how our services function, or how stable or successful they are, we rely on our own analytics tools as much as possible. Here are the third-party tools we use, how we use them, and their privacy policies:


Personal data is information that relates to an identified or identifiable natural person, such as the personal data necessary to provide you with our service, to create and manage your account, to handle your product purchases, to communicate with you, to optimize and improve our service, and to comply with our legal obligations.


On the basis of legal obligations, we process your personal data when it is necessary for compliance with a legal tax, accounting, anti-money laundering, legal order, or other obligation to which we are subject.


When you use our service, you may be using servers located in a variety of different countries. However, there is a difference between use and storage. What little information that gets generated by your use of our infrastructure does not get stored outside of the EU region.


There may be some instances where, as a matter of necessity, we need to transfer data outside of these two jurisdictions. When we process the data within our group, regardless of where we are, we always implement the same level of data protection afforded by the GDPR to all personal data we process. Where we cooperate with third parties which are involved in data processing, we legally bind any party we deal with to adhere to those high levels of protection with adequacy decision or standard contractual clauses approved by the European Commission, and to ensure your rights are protected in accordance with this Privacy Policy.


The intra-group transfers within the Gen Digital Group are covered by the EU-U.S. Data Privacy Framework, UK Extension to the EU-U.S. Data Privacy Framework and Swiss-U.S. Data Privacy Framework as set forth by the U.S. Department of Commerce regarding the transfer of personal information from the European Economic Area (EEA), the United Kingdom, and Switzerland to the United States. Check here to access the Gen Digital Inc. Data Privacy Framework Notice.


In all cases, we follow generally accepted standards and security measures to protect the personal data submitted to us, both during transmission and once we receive it. We always strive to protect your data to the maximum extent we can.


Concerning storage or retention periods, the specific terms applicable to the various types of data used for various purposes are noted in their respective sections. After these periods elapse, we will delete this data and no longer use it for that specific purpose.


As we are part of the Gen Group, information may be shared with members of the Gen Group in order to execute on the provisions of this service, for direct marketing, business operations or to help our product development. In all cases, they are subject to the terms of this Privacy Policy.


Like any other consumer brand, we too go through our own cycle of growth, expansion, streamlining and optimization. Our business decisions and market developments therefore affect our structure. As a result of such transactions, and for maintaining a continued relationship with you, we may transfer your Personal Data to a related affiliate.


If we are involved in a reorganization, merger, acquisition or sale of our assets, your Personal Data may be transferred as part of that transaction. We will notify you of any such deal and outline your choices in that event, when applicable. Information including personal data relating to our business may be shared with other parties in order to evaluate and conclude the transaction. This would also be the case if we were required by law to make such changes.


We will action your request within one month of receiving a request from you concerning any one of your rights as a data subject. Should we be inundated with requests or particularly complicated requests, the time limit may be extended to a maximum of another two months.


Where requests we receive are manifestly unfounded or excessive, in particular because of their repetitive character, we may either: (a) charge a reasonable fee taking into account the administrative costs of providing the information or communication or taking the action requested; or (b) refuse to act on the request.


Please note, consistent with our privacy by design, privacy by default and minimization practices, we may not be able to identify you in connection with the service data collected by our VPN. If such a situation occurs, please go to your product settings and explore your options.


Access to the personal data of our users is limited to authorized personnel who have a legitimate need to know based on their job descriptions, for example, employees who provide technical support to end users, or who service user accounts. In the case of third-party contractors who process personal data on our behalf, similar requirements are imposed. These third parties are contractually bound by confidentiality clauses, even when they leave. Where an individual employee no longer requires access, that individual's credentials are revoked.


We store your personal data in our database using the protections described above. In addition, we utilize up-to-date firewall protection for an additional layer of security. We use high-quality antivirus and anti-malware software, and regularly update our virus definitions. Third parties who we hire to provide services and who have access to our users' data are required to implement privacy and security practices that we deem adequate.


Access to user information in our database by Internet requires using an encrypted VPN, except for email which requires user authentication. Otherwise, access is limited to our physical premises. Physical removal of personal data from our location is forbidden. Third-party contractors who process personal data on our behalf agree to provide reasonable physical safeguards.


We reserve the right to revise or modify this Privacy Policy. In addition, we may update this Privacy Policy to reflect changes to our data practices. If we make any material changes we will notify you by email (sent to the e-mail address specified in your account), product notification or by means of a notice on this website prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.


Cookies are small text files that are placed on your computer or device by websites that you visit or HTML-formatted emails you open to make our websites work, or to make them work more efficiently, to understand the effectiveness of our emails, and confirm that you received the necessary communications. You can find more about cookies here.


Cookies may also be placed on our websites by third parties to deliver tailored information and content that may be of interest to you, such as promotions or offerings, when you visit third-party websites after you have left ours. We do not permit these third parties to collect personal data about you (e.g., email address) other than that collected using such cookies unless such data is provided to the third party in their role as a service provider acting solely on our behalf.


Another way in which you can communicate your cookie preferences to us is to change the cookie settings in your browser. In some browsers you can set up rules to manage cookies on a site-by-site basis, giving you more fine-grained control over your privacy. We do note, however, that not all browsers across all platforms may support this functionality.


Preference cookies enable a website to remember information that changes the way the website behaves or looks, such as your preferred language or the region that you are in. De-selecting these cookies may result in improper functionality and setting of the website.


Marketing cookies are used to track visitors across websites. The intention is to display ads that are relevant and engaging for the individual user and thereby more valuable for publishers and third party advertisers. De-selecting these cookies may result in seeing advertising that is not as relevant to you.

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