“GDPR” means the General Data Protection Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data.
“EEA” includes all current member states to the European Union and the European Economic Area.
“Process”, in respect of personal data, includes to collect, store, and disclose to others.
TABLE OF CONTENTS
- PERSONAL DATA CONTROLLER
- CATEGORIES OF PERSONAL DATA WE COLLECT
- FOR WHAT PURPOSES WE PROCESS PERSONAL DATA
- UNDER WHAT LEGAL BASES WE PROCESS YOUR PERSONAL DATA (Applies only to EEA-based users)
- WITH WHOM WE SHARE YOUR PERSONAL DATA
- HOW YOU CAN EXERCISE YOUR PRIVACY RIGHTS
- AGE LIMITATION
- INTERNATIONAL DATA TRANSFERS
- CALIFORNIA PRIVACY RIGHTS
- DATA RETENTION
- HOW “DO NOT TRACK” REQUESTS ARE HANDLED
- CONTACT US
PERSONAL DATA CONTROLLER
VPN MOBAPPS LIMITED, a company registered under the laws of the Republic of Cyprus, having its registered office at Florinis 7, Greg Tower, 2nd Floor, 1065, Nicosia, Cyprus, will be the controller of your personal data.
CATEGORIES OF PERSONAL DATA WE COLLECT
We collect data you give us voluntarily (for example, email address, name, approximate age, level of language knowledge, learning goals, interests, time zone). We also collect data automatically (for example, your IP address).
Data you give us
If you contact our support teams you may provide us with your email address.
Data we collect automatically:
Data about how you found us
We collect data about your referring app or URL (that is, the app or place on the Web where you were when you tapped/clicked on our ad).
Device and Location data.
We may collect data from your device. Examples of such data include: language settings, IP address, time zone, type and model of a device, device settings, operating system, Internet service provider, mobile carrier, hardware ID, and Facebook ID.
- Data about how you found us
- Data you give us
FOR WHAT PURPOSES WE PROCESS YOUR PERSONAL DATA
We process your personal data:
To provide our Service
This includes enabling you to use the Website in a seamless manner and preventing or addressing Service errors or technical issues. As a result of such processing, we will use your email, for example, to send you the purchased product or to render services ordered through our Website.
To provide you with customer support
To enforce our Terms and Conditions of Use and to prevent and combat fraud
We use personal data to enforce our agreements and contractual commitments, to detect, prevent, and combat fraud. As a result of such processing, we may share your information with others, including law enforcement agencies (in particular, if a dispute arises in connection with our Terms and Conditions of Use).
To comply with legal obligations
We may process, use, or share your data when the law requires it, in particular, if a law enforcement agency requests your data by available legal means.
- To provide our Service
UNDER WHAT LEGAL BASES WE PROCESS YOUR PERSONAL DATA
In this section, we are letting you know what legal basis we use for each particular purpose of processing. For more information on a particular purpose, please refer to Section 3. This section applies only to EEA-based users.
We process your personal data under the following legal bases:
- your consent;
to perform our contract with you;
Under this legal basis we:
- Provide our Service (in accordance with our Terms and Conditions of Use)
- Provide you with customer support
for our (or others') legitimate interests, unless those interests are overridden by your interests or fundamental rights and freedoms that require protection of personal data;
We rely on legitimate interests:
- to enforce our Terms and Conditions of Use and to prevent and combat fraud
Our legitimate interests for this purpose are enforcing our legal rights, preventing and addressing fraud and unauthorised use of the Service, non-compliance with our Terms and Conditions of Use.
- to comply with legal obligations.
WITH WHOM WE SHARE YOUR PERSONAL DATA
We share information with third parties that help us operate, provide, support our Service. The types of third parties we share information with include, in particular:
We share personal data with third parties that we hire to provide services or perform business functions on our behalf, based on our instructions. We may share your personal information with the following types of service providers:
- cloud storage providers
Law enforcement agencies and other public authorities
We may use and disclose personal data to enforce our Terms and Conditions of Use, to protect our rights, privacy, safety, or property, and/or that of our affiliates, you or others, and to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, or in other cases provided for by law.
Third parties as part of a merger or acquisition
As we develop our business, we may buy or sell assets or business offerings. Customers’ information is generally one of the transferred business assets in these types of transactions. We may also share such information with any affiliated entity (e.g. parent company or subsidiary) and may transfer such information in the course of a corporate transaction, such as the sale of our business, a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.
- Service providers
HOW YOU CAN EXERCISE YOUR RIGHTS
To be in control of your personal data, you have the following rights:
Accessing / reviewing / updating / correcting your personal data. You may review, edit, or change the personal data that you had previously provided on the Website by sending us an email at email@example.com.
You may also request a copy of your personal data collected during your use of the Website at firstname.lastname@example.org.
Deleting your personal data. You can request erasure of your personal data by sending us an email at email@example.com.
When you request deletion of your personal data, we will use reasonable efforts to honor your request. In some cases, we may be legally required to keep some of the data for a certain time; in such event, we will fulfill your request after we have complied with our obligations.
Objecting to or restricting the use of your personal data. You can ask us to stop using all or some of your personal data or limit our use thereof by sending a request at firstname.lastname@example.org.
Additional information for EEA-based users
If you are based in the EEA, you have the following rights in addition to the above:
The right to lodge a complaint with supervisory authority. We would love you to contact us directly, so we could address your concerns. Nevertheless, you have the right to lodge a complaint with a competent data protection supervisory authority, in particular in the EU Member State where you reside, work or where the alleged infringement has taken place.
The right to data portability. If you wish to receive your personal data in a machine-readable format, you can send respective request at email@example.com.
We do not knowingly process personal data from persons under 16 years of age. If you learn that anyone younger than 16 has provided us with personal data, please contact us firstname.lastname@example.org.
INTERNATIONAL DATA TRANSFERS
In particular, if we transfer personal data originating from the EEA to countries with not adequate level of data protection, we use one of the following legal bases: (i) Standard Contractual Clauses approved by the European Commission (details available here), or (ii) the European Commission adequacy decisions about certain countries (details available here).
CALIFORNIA PRIVACY RIGHTS
California’s Shine the Light law gives California residents the right to ask companies once a year what personal information they share with third parties for those third parties' direct marketing purposes. Learn more about what is considered to be personal information under the statute.
To obtain this information from us, please send an email message to email@example.com which includes “Request for California Privacy Information” on the subject line and your state of residence and email address in the body of your message. If you are a California resident, we will provide the requested information to you at your email address in response.
HOW “DO NOT TRACK” REQUESTS ARE HANDLED
Effective as of: 1st October 2020