Last updated July 24, 2020
Thank you for choosing to be part of our community at VPN Now, Inc.
(“Company”, “we”, “us”, or “our”). We are committed to protecting
your personal information and your right to privacy. If you have any
questions or concerns about our notice, or our practices with
regards to your personal information, please contact us at:
When you visit our mobile application, and use our services, you
trust us with your personal information. We take your privacy very
seriously. In this privacy notice, we seek to explain to you in the
clearest way possible what information we collect, how we use it and
what rights you have in relation to it. We hope you take some time
to read through it carefully, as it is important. If there are any
terms in this privacy notice that you do not agree with, please
discontinue use of our Apps and our services.
This privacy notice applies to all information collected through our
mobile application, ("Apps"), and/or any related services, sales,
marketing or events (we refer to them collectively in this privacy
notice as the "Services").
Please read this privacy notice carefully as it will help you make
informed decisions about sharing your personal information with us.
1. WHAT INFORMATION DO WE COLLECT?
Information automatically collected
In Short: Some information — such as IP address
and/or browser and device characteristics — is collected
automatically when you visit our Apps.
collect certain information when you visit, use or navigate the
Apps. This information does not reveal your specific identity (like
your name or contact information) but may include device and usage
information, such as aggregate bandwidth usage, Internet and data
traffic, destination websites or IP addresses, originating IP
addresses, device characteristics, operating system, language
preferences, referring URLs, device name, country, location,
information about how and when you use our Apps and other technical
information. This information is primarily needed to maintain the
security and operation of our Apps, and for our internal analytics
and reporting purposes. However, no log is maintained regarding this
information as it is a real-time process.
businesses, we also collect information through cookies and similar
Information collected through our Apps
In Short: We may collect information regarding your
geo-location, mobile device, push notifications, when you use our
If you use our Apps, we may also collect the
• Geo-Location Information. We may
request access or permission to and track location-based information
from your mobile device, either continuously or while you are using
our mobile application, to provide location-based services. If you
wish to change our access or permissions, you may do so in your
• Mobile Device Access. We may request
access or permission to certain features from your mobile device,
including your mobile device's bandwidth usage, temporary usage
data, destination websites or ip addresses, and other features. If
you wish to change our access or permissions, you may do so in your
• Mobile Device Data. We may automatically
collect device information (such as your mobile device ID, model and
manufacturer), operating system, version information and IP
• Push Notifications. We may request to send you push
notifications regarding your account or the mobile application. If
you wish to opt-out from receiving these types of communications,
you may turn them off in your device's settings.
Information collected from other sources
In Short: We may collect limited data from public
databases, marketing partners, and other outside sources.
may obtain information about your from other sources, such as public
databases, joint marketing partners, as well as from other third
parties. Examples of the information we receive from other sources
include: social media profile information; marketing leads and
search results and links, including paid listings (such as sponsored
links). We will inform you about the source of information and the
type of information and the type of information we have collected
about you within a reasonable period after obtaining the personal
data, but at the latest within one month.
2. HOW DO WE USE YOUR INFORMATION?
In Short: We process your information for purposes based on
legitimate business interests, the fulfillment of our contract with
you, compliance with our legal obligations, and/or your consent.
use personal information collected via our Apps for a variety of
business purposes described below. We process your personal
information for these purposes in reliance on our legitimate
business interests, in order to enter into or perform a contract
with you, with your consent, and/or for compliance with our legal
obligations. We indicate the specific processing grounds we rely on
next to each purpose listed below.
We use the information
we collect or receive:
To send you marketing and
promotional communications. We and/or our third party marketing
partners may use the personal information you send to us for our
marketing purposes, if this is in accordance with your marketing
preferences. You can opt-out of our marketing emails at any time
(see the "WHAT ARE YOUR PRIVACY RIGHTS" below).
targeted advertising to you. We may use your information to develop
and display content and advertising (and work with third parties who
do so) tailored to your interests and/or location and to measure its
Request Feedback. We may use your
information to request feedback and to contact you about your use of
To protect our Services. We may use your
information as part of our efforts to keep our Apps safe and secure
(for example, for fraud monitoring and prevention).
enforce our terms, conditions and policies for Business Purposes,
Legal Reasons and Contractual.
To respond to legal
requests and prevent harm. If we receive a subpoena or other legal
request, we may need to inspect the data we hold to determine how to
To deliver services to the user. We may use your
information to provide you with the requested service.
respond to user inquiries/offer support to users. We may use your
information to respond to your inquiries and solve any potential
issues you might have with the use of our Services.
other Business Purposes. We may use your information for other
Business Purposes, such as data analysis, identifying usage trends,
determining the effectiveness of our promotional campaigns and to
evaluate and improve our Apps, products, marketing and your
experience. We may use and store this information in aggregated and
anonymized form so that it is not associated with individual end
users and does not include personal information. We will not use
identifiable personal information without your consent.
3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?
In Short: We only share information with your consent, to comply
with laws, to provide you with services, to protect your rights, or
to fulfill business obligations.
We may process or share
data based on the following legal basis:
• Consent: We may
process your data if you have given us specific consent to use your
personal information in a specific purpose.
Interests: We may process your data when it is reasonably necessary
to achieve our legitimate business interests.
• Performance of
a Contract: Where we have entered into a contract with you, we may
process your personal information to fulfill the terms of our
• Legal Obligations: We may disclose your information
where we are legally required to do so in order to comply with
applicable law, governmental requests, a judicial proceeding, court
order, or legal process, such as in response to a court order or a
subpoena (including in response to public authorities to meet
national security or law enforcement requirements).
Interests: We may disclose your information where we believe it is
necessary to investigate, prevent, or take action regarding
potential violations of our policies, suspected fraud, situations
involving potential threats to the safety of any person and illegal
activities, or as evidence in litigation in which we are
More specifically, we may need to process your
data or share your personal information in the following
• Vendors, Consultants and Other Third-Party
Service Providers. We may share your data with third party vendors,
service providers, contractors or agents who perform services for us
or on our behalf and require access to such information to do that
work. Examples include: payment processing, data analysis, email
delivery, hosting services, customer service and marketing efforts.
We may allow selected third parties to use tracking technology on
the Apps, which will enable them to collect data about how you
interact with the Apps over time. This information may be used to,
among other things, analyze and track data, determine the popularity
of certain content and better understand online activity. Unless
described in this Policy, we do not share, sell, rent or trade any
of your information with third parties for their promotional
• Business Transfers. We may share or transfer your
information in connection with, or during negotiations of, any
merger, sale of company assets, financing, or acquisition of all or
a portion of our business to another company.
Advertisers. We may use third-party advertising companies to serve
ads when you visit the Apps. These companies may use information
about your visits to our Website(s) and other websites that are
contained in web cookies and other tracking technologies in order to
provide advertisements about goods and services of interest to you.
collect and store your information.
and similar tracking technologies (like web beacons and pixels) to
access or store information. Specific information about how we use
such technologies and how you can refuse certain cookies is set out
5. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
In Short: We may transfer, store, and process your information in
countries other than your own.
Our servers are located
in. If you are accessing our Apps from outside, please be aware that
your information may be transferred to, stored, and processed by us
in our facilities and by those third parties with whom we may share
your personal information (see "WILL YOUR INFORMATION BE SHARED WITH
ANYONE?" above), in and other countries.
If you are a
resident in the European Economic Area, then these countries may not
have data protection or other laws as comprehensive as those in your
country. We will however take all necessary measures to protect your
personal information in accordance with this privacy notice and
European Commission's Standard
Such measures implementing the
European Commission's Standard Contractual Clauses for transfers of
personal information between our group companies and between us and
our third-party providers, which require all such recipients to
protect personal information that they process from the EEA in
accordance with European data protection laws. Our Standard
Contractual Clauses can be provided upon request. We have
implemented similar appropriate safeguards with our third party
service providers and partners and further details can be provided
EU-U.S. Privacy Shield Framework:
particular Company complies with the EU-U.S. Privacy Shield
Framework as set forth by the U.S. Department of Commerce regarding
the collection, use, and retention of personal information
transferred from the European Union to the United States and has
certified its compliance with it. As such, Company is committed to
subjecting all personal information received from European Union
(EU) member countries, in reliance on the Privacy Shield Framework,
to the Framework’s applicable Principles. To learn more about the
Privacy Shield Framework, visit the U.S. Department of Commerce’s
Privacy Shield List.
Company is responsible for the
processing of personal information it receives, under the Privacy
Shield Framework, and subsequently transfers to a third party acting
as an agent on its behalf.
With respect to personal
information received or transferred pursuant to the Privacy Shield
Framework, Company is subject to the regulatory enforcement powers
of the U.S. FTC. In certain situations, we may be required to
disclose personal information in response to lawful requests by
public authorities, including to meet national security or law
6. WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?
In Short: We are not responsible for the safety of any information
that you share with third-party providers who advertise, but are not
affiliated with, our websites.
The Apps may contain
advertisements from third parties that are not affiliated with us
and which may link to other websites, online services or mobile
applications. We cannot guarantee the safety and privacy of data you
provide to any third parties. Any data collected by third parties is
not covered by this privacy notice. We are not responsible for the
content or privacy and security practices and policies of any third
parties, including other websites, services or applications that may
be linked to or from the Apps. You should review the policies of
such third parties and contact them directly to respond to your
7. HOW LONG DO WE KEEP YOUR INFORMATION?
In Short: We keep your information for as long as necessary to
fulfill the purposes outlined in this privacy notice unless
otherwise required by law.
We will only keep your
personal information for as long as it is necessary for the purposes
set out in this privacy notice, unless a longer retention period is
required or permitted by law (such as tax, accounting or other legal
requirements). No purpose in this policy will require us keeping
your personal information for longer than 90 days.
we have no ongoing legitimate business need to process your personal
information, we will either delete or anonymize it, or, if this is
not possible (for example, because your personal information has
been stored in backup archives), then we will securely store your
personal information and isolate it from any further processing
until deletion is possible.
8. HOW DO WE KEEP YOUR INFORMATION SAFE?
In Short: We aim to protect your personal information through a
system of organizational and technical security measures.
have implemented appropriate technical and organizational security
measures designed to protect the security of any personal
information we process. However, please also remember that we cannot
guarantee that the internet itself is 100% secure. Although we will
do our best to protect your personal information, transmission of
personal information to and from our Apps is at your own risk. You
should only access the services within a secure environment.
9. WHAT ARE YOUR PRIVACY RIGHTS?
In Short: In some regions, such as the European Economic Area, you
have rights that allow you greater access to and control over your
personal information. You may review, change, or terminate your
account at any time.
In some regions (like the European
Economic Area), you have certain rights under applicable data
protection laws. These may include the right (i) to request access
and obtain a copy of your personal information, (ii) to request
rectification or erasure; (iii) to restrict the processing of your
personal information; and (iv) if applicable, to data portability.
In certain circumstances, you may also have the right to object to
the processing of your personal information. To make such a request,
please use the contact details provided below. We will consider and
act upon any request in accordance with applicable data protection
If we are relying on your consent to process your
personal information, you have the right to withdraw your consent at
any time. Please note however that this will not affect the
lawfulness of the processing before its withdrawal.
you are resident in the European Economic Area and you believe we
are unlawfully processing your personal information, you also have
the right to complain to your local data protection supervisory
authority. You can find their contact details here:
and similar technologies: Most Web browsers are set to accept
cookies by default. If you prefer, you can usually choose to set
your browser to remove cookies and to reject cookies. If you choose
to remove cookies or reject cookies, this could affect certain
features or services of our Apps.
10. CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating systems and mobile
applications include a Do-Not-Track (“DNT”) feature or setting you
can activate to signal your privacy preference not to have data
about your online browsing activities monitored and collected. No
uniform technology standard for recognizing and implementing DNT
signals has been finalized. As such, we do not currently respond to
DNT browser signals or any other mechanism that automatically
communicates your choice not to be tracked online. If a standard for
online tracking is adopted that we must follow in the future, we
will inform you about that practice in a revised version of this
11. DO WE MAKE UPDATES TO THIS POLICY?
In Short: Yes, we will update this policy as necessary to stay
compliant with relevant laws.
We may update this privacy
notice from time to time. The updated version will be indicated by
an updated “Revised” date and the updated version will be effective
as soon as it is accessible. If we make material changes to this
privacy notice, we may notify you either by prominently posting a
notice of such changes or by directly sending you a notification. We
encourage you to review this privacy notice frequently to be
informed of how we are protecting your information.
12. HOW CAN YOU CONTACT US ABOUT THIS POLICY?
If you have questions or comments about this policy, you may email
HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
Based on the laws of some countries, you may have the right to
request access to the personal information we collect from you,
change that information, or delete it in some circumstances. To
request to review, update, or delete your personal information,
please contact us at: email@example.com. We will respond to
your request within 30 days.