Privacy Policy

Welcome

This Privacy Policy describes how we process and handle data provided to us in connection with your use of our products, services, apps, and websites that link to this policy (we refer to these collectively as our “services”).

This policy uses the term “personal data” to refer to information that is related to an identified or identifiable natural person and is protected as personal data under applicable data protection law.

Who are we?

In this policy, “we,” “us,” and “our” refers to the Inspiritum Ltd company that provides you with the services and is responsible for handling your data in accordance with this policy.

1. 1. What information do we collect about you?

   This section describes the various types of information we collect from and about you. This information is not collected in all situations, but only in specific situations. To understand the context in which collection occurs, see Section 2 (How do we use your information?). More information about some of the mechanisms we use to collect this information, such as cookies, is available in Section 4 (Tracking Technologies & Cookies).

   1. 1.1. Information you provide to us

      • Communications and submissions. You may choose to provide us with information when you communicate with us (e.g. via email for support or to inquire about our services), including when you fill out an online form, respond to surveys, provide feedback, participate in promotions, or submit information through our services.

   2. 1.2. Information collected when you use our services

      • Usage information. We collect information about how you interact with our services, such as how much bandwidth you use, and when and for how long you use our services.

      • Device information. We collect information from and about the device you use to access our services. For example, we may collect device identifiers, browser types, device types and settings, operating system versions, mobile, wireless, and other network information (such as internet service provider name, carrier name and signal strength), and application version numbers.

      • Location information. We may collect your location information based on your IP address.

   3. 1.3. Information provided to us 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 other contact information.

      • Third Party Accounts. Some services may allow you to register an account using a third party account (such as a Google or Microsoft account). If you do so, that third party may send us some information about you that they have. You may be able to control what information they send us via your privacy settings for that third party account.

      • Threat Information. We may receive information from reputable members of the security industry who provide information to help us to provide, develop, test, and improve our services (for example, lists of malicious URLs, spam blacklists, phone number blacklists, and sample malware). Some of this information may contain personal data on an incidental basis.

   You generally do not have a duty to disclose personal data to us unless you have a contractual obligation to us to do so. However, we need to collect and process certain information that is necessary or legally required in order to provide the services to you or otherwise perform our contractual relationships with you.

   We use the information we collect for various purposes described below.

   • To provide, maintain, troubleshoot, and support our services. We use your information for this purpose on the basis that it is required to fulfill our contractual obligations to you. Examples: using information about how much bandwidth you use and how long you use our services in order to provide the services in accordance with a plan to which you have subscribed; using threat and device information to determine whether certain items pose a potential security threat; using location information to connect you to the nearest and fastest VPN server; and using usage information to troubleshoot a problem you report with our services and to ensure the proper functioning of our services.

   • For billing and payment purposes. We use your information in order to perform billing administration activities and process payments, which are required to fulfill our contractual obligations.

   • To communicate with users and prospective users. We use your information to communicate with you, including by responding to your requests, and sending you information and updates about our services. We may do this in order to fulfill our contract with you, because you consented to the communication, or because we have a legitimate interest in providing you with information about our services.

   • To improve our services. We want to offer you the best services and user experiences we can, so we have a legitimate interest in continually improving and optimizing our services. To do so, we use your information to understand how users interact with our services. Examples: we analyze certain usage, device, and diagnostic information to understand aggregated usage trends and user engagement with our services (and, for example, invest in technical infrastructure to better serve regions with increasing user demand); we may use device and threat information to conduct spam, threat, and other scientific research to improve our threat detection capabilities; we review customer feedback to understand what we could be doing better.

   • To develop new services. We have a legitimate interest in using your information to plan for and develop new services. For example, we may use customer feedback to understand what new services users may want.

   • To market and advertise our services. We may use your information to provide, measure, personalize, and enhance our advertising and marketing based on our legitimate interest in offering you services that may be of interest. Examples: we may use information such as who or what referred you to our services to understand how effective our advertising is; we may use information to administer promotional activities such as sweepstakes and referral programs. Our VPN products do not use your VPN browsing activity for these purposes and we do not maintain any records that show what you were browsing or accessing through a VPN connection.

   • To prevent harm or liability. We may use information for security purposes (such as to investigate security issues or to monitor and prevent fraud) and to prevent abuse. We may do this to comply with our legal obligations, to protect an individual’s vital interests, or because we have a legitimate interest in preventing harm or liability to us and our users. For example, we may use account, usage, and device information to determine if an entity is engaging in abusive or unauthorized activity in connection with our services.

   • For legal compliance. We internally use your information as required by applicable law, legal process, or regulation. To learn about our practices regarding sharing your information with third parties for legal compliance purposes, see Section 3.1 below. We also use your information to enforce our legal rights and resolve disputes.

2. 3. Who do we share your information with and why?

   1. 1. 3.1. In General

      We may disclose your information in the following circumstances:

      2. • In accordance with your instructions or consent. For example, some services may allow you to register an account using a third party account (such as a Google or Microsoft account). If you choose to do so, we will share information with the third party account provider.

         • Affiliates and third party service providers. To help us provide some aspects of our services, we work with our affiliates and trusted third parties. To protect your data, we enter into appropriate confidentiality and data processing terms with these third parties, review their security practices, and limit information sharing to the scope of what they are helping us with. Examples of activities that third parties help us with include:

           • processing customer payments

           • providing analytics about our services

           • providing sales and customer support

           • maintaining the infrastructure required to provide our services

           • delivering our marketing and advertising content

           • serving advertising content

         • To a new owner. If ownership or control of all or part of our services, assets, or business changes, we may transfer your information to the new owner.

         • Aggregated or de-identified data. We may use and share aggregated data and data that is de-identified such that it no longer reveals the identity of an individual user for regulatory compliance, research and analysis, our own marketing and advertising activities and other legitimate business purposes.

         • To comply with legal process and the law. We are fiercely protective of the privacy of our users. For our VPN products, we protect your privacy by ensuring that we do not log or record online activities that you conduct over a VPN connection in any way that can be tied back to you, meaning that we do not have any data to share with law enforcement and government agencies who make requests for information about what you were doing through a VPN connection. Subject to the foregoing, we may share your information if we are required to do so by applicable law; to comply with our legal obligations; to comply with legal process; and to respond to valid law enforcement requests relating to a criminal investigation, or alleged or suspected illegal activity that may expose us, you, or any of our other users to legal liability. If we share your information for these purposes, we limit the information shared to what is legally necessary, and challenge information requests that we believe are unlawful, overbroad, or otherwise invalid.

         • To enforce our rights and prevent fraud and abuse. We may share limited amounts of your information to enforce and administer our agreements with customers and users, and to respond to claims asserted against us. We may also share your information in order to protect against fraud and abuse against us, our affiliates, users and others.

   2. 3.2. Displaying Advertisements

      We may serve ads to users in certain regions. The ads we display in our services are supplied either by advertisers we have relationships with or by third party advertising networks such as Google. To display third party ads in our apps, we integrate into them a software development kit (SDK), which consists of software code provided by the ad network.

      We provide limited personal data about you to such third party advertising networks to enable them to provide their services. For example, some of these advertising networks may collect information through their SDKs, such as your mobile advertising identifier, IP address, and device information, for the purpose of serving you with “personalized” ads (ads that they think are more relevant to you) and measuring your response to those ads. If you are using a VPN connection, your IP address is hidden from ad networks and replaced with the IP address of our VPN servers.

      Each advertising network collects this information according to their privacy policies. Where an AdChoices logo appears on an ad, you can click it to learn more about the ad network that provided the ad, its privacy policy, and your choices regarding opting out from any personalized advertising. If you opt out from personalized advertising, you may still see non-personalized ads.

      While we request you not to use ad blockers to prevent the display of third party ads because that is how we support our free services, our services are able to continue functioning if you do use ad blockers.

3. 4. Tracking Technologies & Cookies

   1. 4.1. About Tracking Technologies

      We use various technologies in our services to help us collect information. For convenience, we refer to these as “tracking technologies,” although they are not always used to track individuals and the information collected is in a non-identifiable form that does not reference any personal data. Tracking technologies include:

      Cookies

      Cookies are small portions of text that are stored on the device you use to access our services. Cookies enable us (or third parties that we allow to set cookies on your device) to recognize repeat users. Cookies may expire after a period of time, depending on what they are used for.

      Pixel Tags / Page Tags / Web Beacons / Tracking Links

      These are small, hidden images and blocks of code placed in web pages, ads, and our emails that allow us to determine if you perform a specific action. When you access a page, ad, or email, or click a link, these items let us know that you have accessed that page, opened an email, or clicked a link.

      SDKs

      SDKs or software development kits are software code provided by our business partners that let our software interact with the services those partners provide. For example, in certain of our mobile apps, we may use an SDK to enable our app to serve ads from an advertising network. Sometimes these interactions will involve that business partner collecting some information from the device on which the software is run.

   2. 4.2. Why we use Cookies

      We use cookies:

      • To provide our services. Some cookies are essential for the proper operation of our services. For example, cookies allow us to authenticate who you are and whether you’re authorized to access a resource.

      • To store your preferences. Cookies can store your preferences, such as language preferences or whether to pre-fill your username on sign in forms. We may also use them to optimize the content that we show to you.

      • For analytics. Cookies are used to inform us how users interact with our services so we can, as a legitimate interest, improve how they work (such as what screens or webpages you access, and whether our advertising is effective).

      • For security. Cookies can enable us and our payment processors to detect certain kinds of fraud.

      • For advertising-related purposes. We advertise our services online with the help of third parties who show ads and marketing about us on sites around the internet.

   3. 4.3. Third Parties

      We may allow our business partners to place certain tracking technologies in our services. These partners use these technologies for the following purposes:

      • To provide our services. Some business partners who help us to provide our services may use these technologies to support those efforts.

      • For Analytics. To help us understand how you use our services.

      • For Marketing. To help us market and advertise our services to you, including on third party websites. Cookies are used in connection with this to measure the performance of our advertising, attribute actions you take with our ads with actions you take on our services, deliver ad retargeting (serving ads based on your past interactions with our services), and target ads at similar audiences.

      • To Serve Ads. Ad networks may use these technologies to display ads which they think will be more relevant to you. For more information, please see the “Displaying Advertisements” section above.

   4. 4.4. Your Choices

      • Our Cookies: Most web browsers and some mobile devices give you the ability to manage your cookie preferences, including deleting cookies and blocking cookies from being set on those browsers or devices. Visit the “help” section of your mobile device to understand what controls it gives you over cookies. Note that deleting or blocking certain cookies could adversely impact the proper operation of our services.