VPN servers in Russia collects some Personal Data from its Users.
This document contains a section dedicated to California consumers and their privacy rights.
This document contains a section dedicated to Virginia consumers and their privacy rights.
This document contains a section dedicated to Brazilian Users and their privacy rights.
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Personal Data: Tracker; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Usage Data
Personal Data: Application opens; Application updates; device information; number of sessions; operating systems; session duration
Personal Data: various types of Data as specified in the privacy policy of the service
Personal Data: crash data; device information; Universally unique identifier (UUID)
In addition to any opt-out feature provided by any of the services listed in this document, Users may follow the instructions provided by YourOnlineChoices (EU), the Network Advertising Initiative (US) and the Digital Advertising Alliance (US), DAAC (Canada), DDAI (Japan) or other similar initiatives. Such initiatives allow Users to select their tracking preferences for most of the advertising tools. The Owner thus recommends that Users make use of these resources in addition to the information provided in this document.
The Digital Advertising Alliance offers an application called AppChoices that helps Users to control interest-based advertising on mobile apps.
Users may also opt-out of certain advertising features through applicable device settings, such as the device advertising settings for mobile phones or ads settings in general.
Local networks - 02137, Ukraine, Kyiv, PO BOX #19
Owner contact email: [email protected]
Local networks - 02137, Ukraine, Kyiv, PO BOX #19
Owner contact email: [email protected]
Among the types of Personal Data that VPN servers in Russia collects, by itself or through third parties, there are: Universally unique identifier (UUID); crash data; device information; Tracker; Usage Data; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); number of sessions; session duration; Application opens; Application updates; operating systems.
Complete details on each type of Personal Data collected are
provided in the dedicated sections of this privacy policy or by specific
explanation texts displayed prior to the Data collection.
Personal
Data may be freely provided by the User, or, in case of Usage Data,
collected automatically when using VPN servers in Russia.
Unless
specified otherwise, all Data requested by VPN servers in Russia is
mandatory and failure to provide this Data may make it impossible for
VPN servers in Russia to provide its services. In cases where VPN
servers in Russia specifically states that some Data is not mandatory,
Users are free not to communicate this Data without consequences to the
availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Any
use of Cookies – or of other tracking tools – by VPN servers in Russia
or by the owners of third-party services used by VPN servers in Russia
serves the purpose of providing the Service required by the User, in
addition to any other purposes described in the present document and in
the Cookie Policy, if available.
Users are responsible for any third-party Personal Data obtained, published or shared through VPN servers in Russia and confirm that they have the third party's consent to provide the Data to the Owner.
The Owner takes appropriate security measures to prevent
unauthorized access, disclosure, modification, or unauthorized
destruction of the Data.
The Data processing is carried out using
computers and/or IT enabled tools, following organizational procedures
and modes strictly related to the purposes indicated. In addition to the
Owner, in some cases, the Data may be accessible to certain types of
persons in charge, involved with the operation of VPN servers in Russia
(administration, sales, marketing, legal, system administration) or
external parties (such as third-party technical service providers, mail
carriers, hosting providers, IT companies, communications agencies)
appointed, if necessary, as Data Processors by the Owner. The updated
list of these parties may be requested from the Owner at any time.
The Owner may process Personal Data relating to Users if one of the following applies:
In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
The Data is processed at the Owner's operating offices and in any
other places where the parties involved in the processing are located.
Depending on the User's location, data transfers may involve
transferring the User's Data to a country other than their own. To find
out more about the place of processing of such transferred Data, Users
can check the section containing details about the processing of
Personal Data.
Users are also entitled to learn about the legal basis of Data
transfers to a country outside the European Union or to any
international organization governed by public international law or set
up by two or more countries, such as the UN, and about the security
measures taken by the Owner to safeguard their Data.
If any such transfer takes place, Users can find out more by checking
the relevant sections of this document or inquire with the Owner using
the information provided in the contact section.
Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.
Therefore:
The Owner may be allowed to retain Personal Data for a longer
period whenever the User has given consent to such processing, as long
as such consent is not withdrawn. Furthermore, the Owner may be obliged
to retain Personal Data for a longer period whenever required to do so
for the performance of a legal obligation or upon order of an authority.
Once the retention period expires, Personal Data shall be deleted.
Therefore, the right of access, the right to erasure, the right to
rectification and the right to data portability cannot be enforced after
expiration of the retention period.
The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following: Infrastructure monitoring, Advertising, Analytics and Content performance and features testing (A/B testing).
For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data”.
Personal Data is collected for the following purposes and using the following services:
In addition to any opt-out feature provided by any of the services listed in this document, Users may follow the instructions provided by YourOnlineChoices (EU), the Network Advertising Initiative (US) and the Digital Advertising Alliance (US), DAAC (Canada), DDAI (Japan) or other similar initiatives. Such initiatives allow Users to select their tracking preferences for most of the advertising tools. The Owner thus recommends that Users make use of these resources in addition to the information provided in this document.
The Digital Advertising Alliance offers an application called AppChoices that helps Users to control interest-based advertising on mobile apps.
Users may also opt-out of certain advertising features through applicable device settings, such as the device advertising settings for mobile phones or ads settings in general.
Users may exercise certain rights regarding their Data processed by the Owner.
In particular, Users have the right to do the following:
Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.
Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.
Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.
The User's Personal Data may be used for legal purposes by the
Owner in Court or in the stages leading to possible legal action arising
from improper use of VPN servers in Russia or the related Services.
The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.
In addition to the information contained in this privacy policy, VPN servers in Russia may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.
For operation and maintenance purposes, VPN servers in Russia and any third-party services may collect files that record interaction with VPN servers in Russia (System logs) or use other Personal Data (such as the IP Address) for this purpose.
More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.
VPN servers in Russia does not support “Do Not Track” requests.
To
determine whether any of the third-party services it uses honor the “Do
Not Track” requests, please read their privacy policies.
The Owner reserves the right to make changes to this privacy policy
at any time by notifying its Users on this page and possibly within VPN
servers in Russia and/or - as far as technically and legally feasible -
sending a notice to Users via any contact information available to the
Owner. It is strongly recommended to check this page often, referring to
the date of the last modification listed at the bottom.
Should the changes affect processing activities performed on the basis
of the User’s consent, the Owner shall collect new consent from the
User, where required.
This part of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the business running VPN servers in Russia and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).
The provisions contained in this section apply to all Users (Users are referred to below, simply as “you”, “your”, “yours”), who are consumers residing in the state of California, United States of America, according to the "California Consumer Privacy Act of 2018" (the "CCPA"), as updated by the "California Privacy Rights Act" (the "CPRA") and subsequent regulations. For such consumers, these provisions supersede any other possibly divergent or conflicting provisions contained in the privacy policy.
This part of the document uses the term “personal information“ as defined in the California Consumer Privacy Act (CCPA/CPRA).
In this section we summarize the categories of personal information that we've collected, used, sold, or shared and the purposes thereof. You can read about these activities in detail in the section titled “Detailed information on the processing of Personal Data” within this document.
We have collected the following categories of personal information about you: identifiers and internet information.
We do not collect sensitive personal information.
We will not collect additional categories of personal information without notifying you.
We may use your personal information to allow the operational functioning of VPN servers in Russia and features thereof (“business purposes”). In such cases, your personal information will be processed in a fashion necessary and proportionate to the business purpose for which it was collected, and strictly within the limits of compatible operational purposes.
We may also use your personal information for other reasons such as for commercial purposes (as indicated within the section “Detailed information on the processing of Personal Data” within this document), as well as for complying with the law and defending our rights before the competent authorities where our rights and interests are threatened or we suffer an actual damage.
We won’t process your information for unexpected purposes, or for purposes incompatible with the purposes originally disclosed, without your consent.
Unless stated otherwise inside the “Detailed information on the processing of Personal Data” section, we will not retain your personal information for longer than is reasonably necessary for the purpose(s) they have been collected for.
We collect the above-mentioned categories of personal information, either directly or indirectly, from you when you use VPN servers in Russia.
For example, you directly provide your personal information when you submit requests via any forms on VPN servers in Russia. You also provide personal information indirectly when you navigate VPN servers in Russia, as personal information about you is automatically observed and collected.
Finally, we may collect your personal information from third parties that work with us in connection with the Service or with the functioning of this Application and features thereof.
For our purposes, the word “third party” means a person who is not any of the following: a service provider or a contractor, as defined by the CCPA.
We disclose your personal information with the third parties listed in detail in the section titled “Detailed information on the processing of Personal Data” within this document. These third parties are grouped and categorized in accordance with the different purposes of processing.
For our purposes, the word “sale” means any “selling, renting, releasing, disclosing, disseminating, making available, transferring or otherwise communicating orally, in writing, or by electronic means, a consumer's personal information by the business to a third party, for monetary or other valuable consideration”, as defined by the CCPA.
This means that, for example, a sale can happen whenever an application runs ads, or makes statistical analyses on the traffic or views, or simply because it uses tools such as social network plugins and the like.
For our purposes, the word “sharing” means any “sharing, renting,
releasing, disclosing, disseminating, making available, transferring, or
otherwise communicating orally, in writing, or by electronic or other
means, a consumer's personal information by the business to a third
party for cross-context behavioral advertising, whether or not for
monetary or other valuable consideration, including transactions between
a business and a third party for cross-context behavioral advertising
for the benefit of a business in which no money is exchanged”, as
defined by the CCPA.
Please note that the exchange of personal information with a service
provider pursuant to a written contract that meets the requirements set
by the CCPA, does not constitute a sale or sharing of your personal
information.
We sell or share your personal information with the third parties listed in detail in the section titled “Detailed information on the processing of Personal Data” within this document. These third parties are grouped and categorized in accordance with the different purposes of processing.
You
have the right to opt out of the sale or sharing of your personal
information. This means that whenever you request us to stop selling or
sharing your personal information, we will abide by your request.
Such requests can be made freely, at any time, without submitting any verifiable request.
To fully exercise your right to opt out, you can contact us at any time using the contact details provided in this document.
For a simplified opt-out method you can also use the privacy choices link provided on VPN servers in Russia.
If you want to submit requests to opt out of the sale or sharing of personal information via a user-enabled global privacy control, like the Global Privacy Control (“GPC”), you are free to do so and we will abide by such request. The GPC consists of a setting or extension in the browser or mobile device and acts as a mechanism that websites can use to indicate they support the GPC signal. If you want to use GPC, you can download and enable it via a participating browser or browser extension. More information about downloading GPC is available here.
We use any personal information collected from you in connection with the submission of your opt-out request solely for the purposes of complying with the opt-out request.
Once you have opted out, we are required to wait at least 12 months before asking whether you have changed your mind.
You have the right to request that we disclose to you:
You also have the right to know what personal information is sold or shared and to whom. In particular, you have the right to request two separate lists from us where we disclose:
The disclosure described above will be limited to the personal information collected or used over the past 12 months.
If we deliver our response electronically, the information enclosed will be "portable", i.e. delivered in an easily usable format to enable you to transmit the information to another entity without hindrance – provided that this is technically feasible.
You have the right to request that we delete any of your personal information, subject to exceptions set forth by the law (such as, including but not limited to, where the information is used to identify and repair errors on VPN servers in Russia, to detect security incidents and protect against fraudulent or illegal activities, to exercise certain rights etc.).
If no legal exception applies, as a result of exercising your right, we will delete your personal information and notify any of our service providers and all third parties to whom we have sold or shared the personal information to do so – provided that this is technically feasible and doesn’t involve disproportionate effort.
You have the right to request that we correct any inaccurate personal information we maintain about you, taking into account the nature of the personal information and the purposes of the processing of the personal information.
You have the right to opt out of the sale or sharing of your personal information. You also have the right to request that we limit our use or disclosure of your sensitive personal information.
We will not discriminate against you for exercising your rights under the CCPA. This means that we will not discriminate against you, including, but not limited to, by denying goods or services, charging you a different price, or providing a different level or quality of goods or services just because you exercised your consumer privacy rights.
However, if you refuse to provide your personal information to us or ask us to delete or stop selling your personal information, and that personal information or sale is necessary for us to provide you with goods or services, we may not be able to complete that transaction.
To the extent permitted by the law, we may offer you promotions, discounts, and other deals in exchange for collecting, keeping, or selling your personal information, provided that the financial incentive offered is reasonably related to the value of your personal information.
To exercise the rights described above, you need to submit your verifiable request to us by contacting us via the details provided in this document.
For us to respond to your request, it’s necessary that we know who you are. Therefore, you can only exercise the above rights by making a verifiable request which must:
We will not respond to any request if we are unable to verify your identity and therefore confirm the personal information in our possession actually relates to you.
Making a verifiable consumer request does not require you to create an account with us. We will use any personal information collected from you in connection with the verification of your request solely for the purposes of verification and shall not further disclose the personal information, retain it longer than necessary for purposes of verification, or use it for unrelated purposes.
If you cannot personally submit a verifiable request, you can authorize a person registered with the California Secretary of State to act on your behalf.
If you are an adult, you can make a verifiable request on behalf of a minor under your parental authority.
You can submit a maximum number of 2 requests over a period of 12 months.
We will confirm receipt of your verifiable request within 10 days and provide information about how we will process your request.
We will respond to your request within 45 days of its receipt. Should we need more time, we will explain to you the reasons why, and how much more time we need. In this regard, please note that we may take up to 90 days to fulfill your request.
Our disclosure(s) will cover the preceding 12-month period. Only with regard to personal information collected on or after January 1, 2022, you have the right to request that we disclose information beyond the 12-month period, and we will provide them to you unless doing so proves impossible or would involve a disproportionate effort.
Should we deny your request, we will explain you the reasons behind our denial.
We do not charge a fee to process or respond to your verifiable request unless such request is manifestly unfounded or excessive. In such cases, we may charge a reasonable fee, or refuse to act on the request. In either case, we will communicate our choices and explain the reasons behind it.
This part of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the controller running this Application and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).
The provisions contained in this section apply to all Users (Users are referred to below, simply as “you”, “your”, “yours”), who are consumers residing in the Commonwealth of Virginia, according to the “Virginia Consumer Data Protection Act" (the "VCDPA"), and, for such consumers, these provisions supersede any other possibly divergent or conflicting provisions contained in the privacy policy.
This part of the document uses the term “personal data” as defined in the VCDPA.
In this section, we summarize the categories of personal data that we've processed and the purposes thereof. You can read about these activities in detail in the section titled “Detailed information on the processing of Persona Data” within this document.
We have collected the following categories of personal data: identifiers and internet information
We do not collect sensitive data.
We will not collect additional categories of personal data without notifying you.
To find out why we process your personal data, you can read the sections titled “Detailed information on the processing of Personal Data” and “The purposes of processing” within this document.
We won’t process your information for unexpected purposes, or for
purposes incompatible with the purposes originally disclosed, without
your consent.
You can freely give, deny, or withdraw such consent at any time using the contact details provided in this document.
We share your personal data with the third parties listed in detail in the section titled “Detailed information on the processing of Personal Data” within this document. These third parties are grouped and categorized in accordance with the different purposes of processing.
For our purposes, the word "third party" means "a natural or legal
person, public authority, agency, or body other than the consumer,
controller, processor, or an affiliate of the processor or the
controller" as defined by the VCDPA.
For our purposes, the word “sale” means any “exchange of personal
data for monetary consideration by us to a third party“ as defined by
the VCDPA.
Please note that according to the VCDPA, the disclosure of personal data
to a processor that processes personal data on behalf of a controller
does not constitute a sale.
As specified in the “Detailed information on the processing of Personal
Data” section of this document, our use of your personal information may
be considered a sale under VCDPA.
You have the right to opt out of the sale of your personal data. This means that whenever you request us to stop selling your data, we will abide by your request. To fully exercise your right to opt out you can contact us at any time using the contact details provided in this document.
We use any personal data collected from you in connection with the submission of your opt-out request solely for the purpose of complying with the request.
For our purposes, the word "targeted advertising" means "displaying advertisements to you where the advertisement is selected based on personal data obtained from your activities over time and across nonaffiliated websites or online applications to predict your preferences or interests" as defined by the VCDPA.
To find out more details on the processing of your personal data for targeted advertising purposes, you can read the section titled “Detailed information on the processing of Personal Data” within this document.
You have the right to opt out of the processing of your personal data for targeted advertising. This means that whenever you ask us to stop processing your data for targeted advertising, we will abide by your request. To fully exercise your right to opt out you can contact us at any time, using the contact details provided in this document.
We use any personal data collected from you in connection with the submission of your opt-out request solely for the purposes of complying with the opt-out request.
You may exercise certain rights regarding your data processed by us. In particular, you have the right to do the following:
To exercise the rights described above, you need to submit your request to us by contacting us via the contact details provided in this document.
For us to respond to your request, we need to know who you are.
We will not respond to any request if we are unable to verify your identity using commercially reasonable efforts and therefore confirm that the personal data in our possession actually relates to you. In such cases, we may request that you provide additional information which is reasonably necessary to authenticate you and your request.
Making a consumer request does not require you to create an account with us. However, we may require you to use your existing account. We will use any personal data collected from you in connection with your request solely for the purposes of authentication, without further disclosing the personal data, retaining it longer than necessary for purposes of authentication, or using it for unrelated purposes.
If you are an adult, you can make a request on behalf of a minor under your parental authority.
We will respond to your request without undue delay, but in all cases and at the latest within 45 days of its receipt. Should we need more time, we will explain to you the reasons why, and how much more time we need. In this regard, please note that we may take up to 90 days to fulfill your request.
Should we deny your request, we will explain to you the reasons behind our denial without undue delay, but in all cases and at the latest within 45 days of receipt of the request. It is your right to appeal such decision by submitting a request to us via the details provided in this document. Within 60 days of receipt of the appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied you may contact the Attorney General to submit a complaint.
We do not charge a fee to respond to your request, for up to two requests per year. If your request is manifestly unfounded, excessive or repetitive, we may charge a reasonable fee or refuse to act on the request. In either case, we will communicate our choices and explain the reasons behind them.
This part of the document integrates with and supplements the
information contained in the rest of the privacy policy and is provided
by the entity running VPN servers in Russia and, if the case may be, its
parent, subsidiaries and affiliates (for the purposes of this section
referred to collectively as “we”, “us”, “our”).
The provisions
contained in this section apply to all Users who reside in Brazil,
according to the "Lei Geral de Proteção de Dados" (Users are referred to
below, simply as “you”, “your”, “yours”). For such Users, these
provisions supersede any other possibly divergent or conflicting
provisions contained in the privacy policy.
This part of the document uses the term “personal information“ as it is defined in the Lei Geral de Proteção de Dados (LGPD).
We can process your personal information solely if we have a legal basis for such processing. Legal bases are as follows:
To find out more about the legal bases, you can contact us at any time using the contact details provided in this document.
To find out what categories of your personal information are processed, you can read the section titled “Detailed information on the processing of Personal Data” within this document.
To find out why we process your personal information, you can read the sections titled “Detailed information on the processing of Personal Data” and “The purposes of processing” within this document.
You have the right to:
You will never be discriminated against, or otherwise suffer any sort of detriment, if you exercise your rights.
You can file your express request to exercise your rights free from any charge, at any time, by using the contact details provided in this document, or via your legal representative.
We will strive to promptly respond to your requests.
In any case,
should it be impossible for us to do so, we’ll make sure to communicate
to you the factual or legal reasons that prevent us from immediately,
or otherwise ever, complying with your requests. In cases where we are
not processing your personal information, we will indicate to you the
physical or legal person to whom you should address your requests, if we
are in the position to do so.
In the event that you file an access or personal information processing confirmation
request, please make sure that you specify whether you’d like your
personal information to be delivered in electronic or printed form.
You will also need to let us know whether you want us to answer your
request immediately, in which case we will answer in a simplified
fashion, or if you need a complete disclosure instead.
In the
latter case, we’ll respond within 15 days from the time of your request,
providing you with all the information on the origin of your personal
information, confirmation on whether or not records exist, any criteria
used for the processing and the purposes of the processing, while
safeguarding our commercial and industrial secrets.
In the event that you file a rectification, deletion, anonymization or personal information blocking request, we will make sure to immediately communicate your request to other parties with whom we have shared your personal information in order to enable such third parties to also comply with your request – except in cases where such communication is proven impossible or involves disproportionate effort on our side.
We are allowed to transfer your personal information outside of the Brazilian territory in the following cases: