Privacy Policy

Welcome

At VPN Cloud, we place a strong emphasis on security and privacy. Transparency is key to understanding how we handle your information and data. This Privacy Policy outlines the processes and practices related to data processing when using our products, services, apps, and websites linked to this policy (collectively referred to as "our services").

In this policy, the term "personal data" pertains to information related to an identifiable natural person, protected as personal data under applicable data protection laws.

Who We Are

This policy governs the data processing practices of VPN Cloud app.

Throughout this policy, "we," "us," and "our" refer to the specific company responsible for providing you with our services, as listed above. For mobile apps, you can determine the relevant company by checking the app's download page or reviewing its terms of service.

1. What Information Do We Collect About You?
2. This section outlines the types of information we collect from and about you. Please note that not all information is collected in every situation. To understand when collection occurs, refer to Section 2 (How Do We Use Your Information?). Additional details about the mechanisms we use to collect this information, such as cookies, are available in Section 4 (Tracking Technologies & Cookies).

1.1. Information You Provide to Us

● Account information: Some services require or allow you to create an account. During registration, we may collect information like your name, username, email address, and password.

● Billing and payment information: To purchase a service, you may need to provide details such as billing name, billing contact details (e.g., street addresses, email addresses), and payment instrument details.

● Identity verification information: Certain services may require identity verification during account creation. For this purpose, we may collect information such as email addresses.

● Communications and submissions: You may choose to provide information when communicating with us, filling out online forms, responding to surveys, offering feedback, participating in promotions, or submitting information through our services.

1.2. Information Collected When You Use Our Services

● Usage information: We collect data on how you interact with our services, including bandwidth usage, usage duration, and access times.

● Device information: Information from and about the device you use to access our services. This includes device identifiers, browser types, device settings, operating system versions, network information (e.g., internet service provider name, carrier name, signal strength), and application version numbers.

● Diagnostic information: Data about the nature of requests made to our servers, such as request details, device and app information, timestamps, and referring URLs. Notably, we do not log information that associates your identity with your VPN browsing activity.

● Location information: Your location data may be collected from sources like your device's GPS or inferred based on your IP address.

1.3. Information Provided by Third Parties

● Referrals: If you are invited to use our service, the person who invited you may submit your personal data, such as your email address or contact information.

● Third-Party Accounts: Some services may allow you to register an account using third-party accounts (e.g., Google or Microsoft). In such cases, the third party may share information about you with us.

● Threat Information: We may receive data from reputable members of the security industry to help improve our services, including lists of malicious URLs, spam blacklists, phone number blacklists, and sample malware. Some of this information may contain personal data incidentally.

In most cases, you are not obligated to disclose personal data to us unless you have a contractual obligation to do so. However, certain information is necessary for us to provide services or fulfill contractual obligations.

We utilize the information collected for various purposes, as described below:

● To provide, maintain, troubleshoot, and support our services: We use your information to fulfill our contractual obligations to you. This includes providing services based on your subscribed plan, using threat and device information to assess security risks, optimizing server selection based on location data, and troubleshooting service-related issues.

● For billing and payment purposes: Information is used to perform billing activities and process payments, necessary to fulfill contractual obligations.

● To communicate with users and prospective users: We use your information for communication, responding to your requests, and sending updates about our services. This may be done to fulfill our contract with you, with your consent, or based on our legitimate interest in keeping you informed.

● To improve our services: We continuously aim to enhance our services and user experiences. To achieve this, we analyze user interactions, usage patterns, and diagnostic data. This analysis guides improvements in various areas, from infrastructure enhancements to security updates and customer feedback.

● To develop new services: We use data to plan and create new services. Customer feedback helps us identify potential new offerings.

● To market and advertise our services: Data may be used to provide, measure, personalize, and enhance advertising and marketing, serving you with relevant content. This is based on our legitimate interest in offering services of potential interest. We do not use your VPN browsing activity for advertising purposes, and we do not maintain records of your VPN activity.

● To prevent harm or liability: Information may be used for security purposes, such as investigating security issues and preventing fraud. This is done to comply with legal obligations, protect vital interests, or serve our legitimate interest in safeguarding our users and services.

● For legal compliance: Information is used as required by applicable law, legal processes, or regulations. See Section 3.1 for more information on sharing information with third parties for legal compliance purposes.

1. Who Do We Share Your Information With and Why?
2. 3.1. In General
3. We may disclose your information in the following scenarios:

● In accordance with your instructions or consent: For instance, some services allow registration through third-party account provider.

● Affiliates and third-party service providers: We collaborate with affiliates and trusted third parties to facilitate certain aspects of our services. To protect your data, we establish appropriate confidentiality and data processing terms, review their security practices, and limit data sharing to the scope of their assistance. Examples include payment processing, analytics, customer support, infrastructure maintenance, and advertising content delivery.

● To a new owner: If ownership or control of all or part of our services, assets, or business changes, your information may be transferred to the new owner.

● Aggregated or de-identified data: We may use and share aggregated and de-identified data, which does not reveal individual identities, for regulatory compliance, research, analysis, marketing, and other legitimate business purposes.

● To comply with legal process and the law: We take privacy seriously and do not log or record online activities conducted through a VPN connection in a way that can be traced back to you. However, we may share information when legally required, such as responding to valid law enforcement requests related to criminal investigations or suspected illegal activity.

● To enforce our rights and prevent fraud and abuse: Limited information may be shared to enforce agreements, respond to claims, protect against fraud and abuse, and uphold our legal rights.

3.2. Displaying Advertisements

In certain regions, we may display ads to users. These ads are supplied by advertisers with whom we have relationships or third-party advertising networks like Google. To display third-party ads in our apps, we integrate a software development kit (SDK), consisting of software code provided by the ad network.

We provide limited personal data to these third-party advertising networks to enable personalized ad delivery and measure ad performance. Information collected may include your mobile advertising identifier, IP address, and device information. If you are using a VPN connection, your IP address is concealed from ad networks and replaced with the IP address of our VPN servers.

Each advertising network collects data in accordance with its privacy policies. When you encounter an AdChoices logo on an ad, you can click it to learn more about the ad network, its privacy policy, and opt-out options for personalized advertising. We encourage you not to use ad blockers to support our free services, as these ads help us maintain our offerings. Our services will continue to function if you choose to use ad blockers.

1. Tracking Technologies & Cookies
2. 4.1. About Tracking Technologies
3. Various technologies are employed in our services to collect information, referred to as "tracking technologies." While not always used to track individuals, these technologies gather information in a non-identifiable form that does not reference personal data. Tracking technologies include:

Cookies

These are small text snippets stored on your device when accessing our services. Cookies enable recognition of repeat users and may expire after a certain period, depending on their purpose.

Pixel Tags / Page Tags / Web Beacons / Tracking Links

These are hidden images and code blocks placed in web pages, ads, and emails to determine if specific actions have been taken.

SDKs (Software Development Kits)

SDKs facilitate interaction between our software and services provided by business partners. For example, some mobile apps use an SDK to display ads from an advertising network.

4.2. Why We Use Cookies

Cookies serve several purposes:

● To provide our services: Certain cookies are essential for service operation, such as user authentication.

● To store your preferences: Cookies may store settings like language preferences or autofill data.

● For analytics: Cookies help us understand user interactions and improve service functionality.

● For security: Cookies aid in fraud detection and prevention.

● For advertising-related purposes: Cookies are used in marketing and advertising to measure performance, attribute actions, deliver ad retargeting, and target similar audiences. Notably, your VPN browsing activity is not used for advertising purposes, and we do not maintain records of your VPN activity.

4.3. Third Parties

Our business partners may use tracking technologies in our services for purposes like providing our services, analytics, marketing, and serving ads. These partners include:

● Our affiliates

● Third-party service providers

● Third-party ad networks (e.g., Google)

● Third parties for legal compliance

4.4. Your Choices

● Our Cookies: Most web browsers and some mobile devices allow you to manage your cookie preferences, including deleting or blocking cookies. Refer to your device's "help" section for controls over cookies. Note that deleting or blocking certain cookies may impact service functionality.

● Third-Party Advertising Cookies: To opt out of personalized or interest-based advertising, visit:

○ Network Advertising Initiative opt out page

○ Digital Advertising Alliance opt out page

○ Your Online Choices (for Australian residents)

○ Your Online Choices (for EU residents)

To opt out of Google ad personalization, visit the Google Ads Settings page. These opt-out mechanisms are provided by third parties, and we are not responsible for their availability or operation. After opting out of personalized advertising, you may still see non-personalized ads.

● Google Analytics: Google Analytics Opt Out Browser Add-On is available if you do not want to participate in Google Analytics.

1. Security
2. We employ administrative, organizational, technical, and physical safeguards to protect your data against unauthorized access, loss, or modification. Our ongoing efforts aim to enhance these safeguards continually.
3. International Data Transfers
4. We may transfer your personal data to countries other than your country of residence to support our operations. Transferees include our group companies, service providers, and partners. Different countries may have different laws governing data protection. While transferring data, we implement appropriate safeguards to ensure it receives an adequate level of protection. If you need more information about these safeguards, please contact us.
5. Data Retention
6. We typically retain your personal data as long as necessary to provide services or maintain your account. We may also keep data for legal compliance, abuse prevention, and defense against legal claims. Residual copies of personal data may exist in backup systems. When data is no longer needed, we securely delete or store it to prevent further use.
7. Your Rights
8. Depending on your country of residence, you may have certain legal rights regarding your personal data, including:

● Accessing and obtaining a copy of your data

● Correcting your data

● Restricting data processing

● Objecting to data processing

● Erasing your data

● Data portability

● Withdrawing consent (e.g., opting out of marketing communications)

● Filing a complaint with a data protection authority

● Requesting information about categories of personal data we collect, disclose, or sell; the sources of such data; the purpose of collecting or selling your data; and the categories of third parties with whom we share it. This information may also be found in this Privacy Policy.

You may exercise some rights using our service settings and tools. For instance, you can update user account details in our apps. To opt out of receiving marketing communications, use the "opt-out" or "unsubscribe" links in these communications.

To exercise other rights, contact us through the "Contact Us" section below. We may verify your identity before acting on your request.

1. Your California Privacy Rights
2. This section pertains exclusively to California residents.

9.1. Do Not Track Signals

We do not currently respond to "Do Not Track" signals from browsers or mobile apps due to a lack of standardization on their interpretation.

9.2. Third-Party Disclosure Requests

California law permits California residents to request a list of third parties with whom we have shared their personal information for direct marketing purposes in the preceding year, along with the types of information disclosed. Refer to the "Contact Us" section below for requesting this information. We do not share personal information for third-party direct marketing without your prior consent.

9.3. Opt-Out From Sale

Under the California Consumer Privacy Act (CCPA), you may have the right to opt out of the "sale" of your personal information. We do not "sell" your personal information as defined by the CCPA, except in certain versions of our products that support personalized advertising. Personalized advertising helps us offer some of our products for free, provide relevant offers, and ensure broad access to secure and private internet usage. Opting out of the "sale" of your information may impact your ability to access some services.

Depending on the services you use and how you use them, we may "sell" (as defined by California law) the following categories of personal information:

● Identifiers (e.g., advertising identifiers and cookies)

● Internet or other network or device activity (e.g., app usage)

● Approximate geolocation information

To opt out of the "sale" of your information for advertising purposes, visit our "Do Not Sell My Personal Information" page. We do not knowingly sell the personal information of minors under 16 years of age without legally-required affirmative authorization.

9.4. Additional Rights

California law may grant you the following rights:

● Requesting disclosure of categories of personal information collected or disclosed in the past 12 months, sources of such information, purposes for collecting or selling your information, and categories of third parties with whom we shared it. This information is available in this Privacy Policy.

● Accessing or obtaining copies of your information

● Deleting your information

You may also be entitled to receive information about financial incentives offered (if any) and protections against discrimination (as provided in the CCPA) for exercising your rights. Certain information may be exempt from your requests under applicable law. For example, we need certain data to provide services and comply with the law.

To request more information about your rights or exercise them, contact us using the details in the "Contact Us" section below.

9.5. Summary of Personal Information Handling

The California Consumer Privacy Act (CCPA) requires specific disclosures to California residents, including categories of personal information collected, purposes for using this information, categories of sources, and categories of third parties with whom we share personal data. While this section presents this information as mandated by the CCPA, it aligns with the rest of the policy in substance.

Sources of Personal Information

All categories of personal information we collect originate from these sources:

● You (voluntarily or automatically when using our services)

● Third parties (e.g., service providers, users, or marketing partners who refer you to our services)

Categories of Personal Information Collected and Shared

The categories of personal information collected, as described earlier, may be shared with the following categories of third parties:

● Our affiliates

● Third-party service providers

● Third-party ad networks (e.g., Google)

● Third parties for legal purposes

Categories of Business & Commercial Purposes for Using Personal Information

The categories of personal information collected, as described earlier, are used for these categories of purposes:

● Providing, maintaining, troubleshooting, and supporting our services

● Billing and payment purposes

● Communicating with users and prospective users

● Improving our services

● Developing new services

● Marketing and advertising our services

● Preventing harm or liability

● Legal compliance

1. Age Restrictions
2. Our services are intended for adults, and minors (individuals under 16 or a lower age as applicable by law) are not allowed to use them. We do not knowingly collect data from minors or permit their use of our services. If we become aware of data collected from a minor, we may delete it without notice.
3. Privacy Policy Updates
4. We may update this Privacy Policy to comply with changes in laws, industry standards, and business practices. Any updates will be posted on this page along with the "Last updated" date. If an update significantly changes your privacy rights, we will make reasonable efforts to inform you, as appropriate, and obtain your consent where required.
5. Contact Us
6. For questions, concerns, or requests related to this Privacy Policy or our data practices, please contact us at:

Email: privacy@cloud-vpn.co

We will respond to your inquiry in a timely manner, following applicable laws.

If you are a California resident, you can also reach out to us using the following methods:

Mail:

VPN Cloud Inc.

Attn: Legal Department

[Address]

[City, State, ZIP Code]

Email: privacy@cloud-vpn.co

Please include your full name, contact information, and the nature of your request so that we can address it appropriately.

For European Union (EU) residents:

If you are located in the EU and have concerns about your data privacy, you have the right to contact your local data protection authority.

1. Data Protection Officer
2. We have appointed a Data Protection Officer (DPO) who can be contacted at:

Email: dpo@cloud-vpn.co

Our DPO is responsible for overseeing our data protection efforts and compliance with this Privacy Policy. If you have questions or concerns about our data practices, you can reach out to the DPO for assistance.

1. Glossary
2. This section provides definitions for key terms used in this Privacy Policy:

● "Advertising Identifier" refers to a unique identifier for a mobile device, used to deliver personalized advertising.

● "Affiliate" means a company related to us by common ownership or control.

● "App" or "Mobile App" refers to our applications for mobile devices.

● "Personal Data" or "Personal Information" denotes any data related to an identifiable natural person, as defined by applicable data protection laws.

● "Pixel Tags" or "Web Beacons" are small, transparent images placed in emails and web pages to monitor user actions.

● "SDK" stands for "Software Development Kit," which allows developers to access features and functionalities when building applications.

● "Third Party" refers to a person or entity other than us or you.

● "VPN" stands for "Virtual Private Network," a technology that creates a secure, encrypted connection over a less secure network, such as the internet.

Last updated: September 28, 2023