Last Updated: February 1,2022
In this Notice, the term “personal data” refers to information that is related to an identified or identifiable natural person.
This Notice applies to the following VPN products: RoboVPN For ease of reference, in this notice we use the term “VPN browsing activity” to refer to online activities you conduct via VPN connections initiated with our VPN products. This includes what you are browsing, viewing, or doing online via the VPN connection.
For individual customers, we want to make sure you are aware of how we use your personal data in accordance with fair and lawful practices. You generally do not have to disclose personal data to us unless you require us to perform certain services for you. 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. Some of our services are offered to businesses. For those services, our customer is a business or other organization who may authorize individual end users to use the services that it has purchased from us. Where an organization is our customer, it may maintain accounts with us through which it and its users may submit information (“Customer Data”). That organization typically controls those accounts and any associated Customer Data. This means that we are a processor of Customer Data and the organization is the controller.
To help us provide some aspects of our services, we work with trusted third parties and partners (including affiliated companies in the Safe-T group). Examples of activities that third parties help us with include processing customer payments; providing analytics about our services; providing sales and customer support and maintaining the infrastructure required to provide our services. In order to continuously improve the levels of service we provide, we may collect information about your use of our services to monitor for problems and look for opportunities to make improvements. Such information may include:
We do not record your VPN browsing activities in any way that can be associated back to you. When you use a VPN connection, we do not store any information that identifies what you browse, view, or do online via that VPN connection. The exception is when you choose to communicate with us (such as via chat or email) over a VPN connection and have chosen to identify yourself to us. While we log what domain names that users visit (but not full URLs), we do not log them in combination with anything that identifies an individual or device.
Data over our VPN connections is encrypted, and we do not inspect or record the contents of what you are browsing, viewing, or doing through them (unless, of course, you are using the VPN connection to communicate with us). For your protection, we may block access to certain resources that are known to be malicious. When you access a site through a VPN connection, your IP address appears to that site as the IP address of one of our VPN servers. Such IP addresses are used by multiple users and we do not record the actual IP addresses of users who use those IP addresses, therefore we are not able to connect activity originating from a those IP address to activity conducted by any individual user.
In order to monitor, support and optimize our VPN services, our VPN products log the duration of VPN sessions and the bandwidth consumed and the domains that have been accessed by our users, on an anonymized basis, therefore we do not know which user accessed which domain. In addition, because we do not require users to register an account to use some of our products and need a way to distinguish between different users and carry out the activities above, our VPN products also log device hashes, which are used to identify devices and associate them with other data we collect (such as for measuring bandwidth use, providing support, understanding how you interact with our VPN, and other analytics and marketing purposes). Device hashes are not linked to VPN browsing activity.
While we do not log or otherwise record IP addresses in connection with your VPN browsing activity, we do collect and use IP addresses to comply with legal process and the law. If you use 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.
We may license our technology to third party partners who may integrate it with applications developed and offered by those partners. Such partners are solely responsible for those applications and for determining what data is collected by those applications and how it is processed.
If you have any questions or complaints about our privacy practices, you can contact us at [email protected] .