We recognize that persons who access and/or use (“you” or “Users”) our app and other related services, including but not limited to customer supporting, marketing and advertising, (collectively, the “Services”) value their privacy.
i) the data collected from you and the ways we collect your data, ii) the reasons why we collect your data, iii) to whom we disclose your data, and iv) the options you have about your personal data.
Any terms not defined herein but defined in the Terms of Service shall have the meaning ascribed thereto in the Terms of Service.
1. Data provided by you
To use the Services, you may directly provide certain personally identifiable information to us, such as:
2. Data collected automatically
· Data about your Account · Mobile device identifiers (e.g. your device ID, IMEI) · Data about your device (e.g. device name, operating system, browser type, language, and third-party data statistics like Google Analytic) · Data we collect with cookies, and similar technologies · Data about your use of the Services (e.g. number of clicks)
1. To provide the Services
To provide the Services, we process data necessary to
· Create Accounts · Allow you to use VPNova’s Services · Operate the Services · Verify and confirm payments · Provide and deliver products and services that you request · Send service-related communications to you
2. To improve and optimize the Services
To provide better Services to you, we have a legitimate interest to collect and process necessary data to
· Update and develop the Services · Manage and update your Account · Develop and improve your experience · Manage the relationship with you · Customize your service experience · Respond to your comments and questions and provide support to you · Provide offers in the Services as well as in other websites and services · Send related information (e.g. updates, security alerts, support messages) to you
3. To carry out activities related to advertisements and marketing
To send you personalized advertising and marketing materials, we may use the information collected from you such as ad identifiers, country, gender, language. We may also use various third-party advertising and marketing partners to assist us on our behalf and may share information collected from you with such third parties for this purpose.
We may also use various third party advertising and marketing partners to assist us on our behalf and may share information collected from you with such third parties for this purpose.
Hence, we have a legitimate interest to process necessary data to
· Deliver, target and improve our advertising and marketing materials · Pass the information collected from you to third-party advertising and marketing partners
We encourage you to review the privacy policies of our third party advertising and marketing partners so that you can understand how these third parties collect, use and share your information. We are not responsible for the privacy policies of any third party whether accessed through the Services or otherwise.
For information on how to opt-out from receiving personalized advertising and marketing materials, see section 'The options you have about your personal data” below.
4. To secure the Services
Ensuring the security in the course of performing the Services is a top priority for us. We take appropriate security and technical measures to protect your information from unauthorized access, loss and misuse. To achieve this purpose, we also request our suppliers who process personal information on our behalf to take appropriate security measures.
In order to keep the Service safe and fair, to fight fraud and to ensure acceptable use otherwise, we have a legitimate interest to process necessary data to
· Analyze and monitor use of the Services · Moderate and monitor data usage · Prevent cheating, crime or fraud · Take action against fraudulent or misbehaving users · Pass your information to agencies or organizations in charge of crime and fraud prevention and repression
Despite our efforts, we cannot guarantee the absolute security of your personal data, nor can we ensure the security of any of the communication facilities provided by us. We recommend that you exercise caution when disclosing any information through the Services. In particular, please note that any personally identifiable information or personally sensitive data that you communicate or disclose to any user in connection with the Services may be collected and used by others. As such, you should take care of the information shared online.
5. To analyze, research and test
In all of the above cases and purposes, we may use analytic tools, which may include third party’s analytic tools, to carry out research, surveys, and analysis, to create reports for use, to track potential problems of the Services.
6. To obtain your consent
With your consent, we may process personal data for additional purposes.
1. Opt out of advertising and/or marketing materials
You may opt out of receiving advertising and/or marketing communications by following the instructions in such communications.
2. Access and correct the personal data we hold about you You have the right to access and correct your personal data.
3. Other rights
You also have the right to have your personal data deleted, object how we use or share your personal data, and restrict how we use or share your personal data. You can always withdraw your consent.
If you have questions about data protection or any requests for resolving issues with your personal data, we encourage you to primarily contact us through e-mail: email@example.com, so we can reply to you more quickly. We will respond to all requests within a reasonable time frame.
The use of the App and Services and this Agreement is governed by and shall be construed and enforced under the laws of Singapore, without applying any conflicts of law principles that would require the application of the law of any other jurisdiction. You agree to submit to the personal non-exclusive jurisdiction in Singapore and any other court of competent jurisdiction chosen by us.
In the event of any dispute arising out of or in connection with this Agreement, including any question regarding its existence, validity or termination, (a “Dispute”), we strongly encourage that a resolution first is sought through our Customer Support service.
You agree that in the event that a resolution is not obtained through our Customer Support service, such Dispute shall be referred by you and may be referred by us to and finally resolved by arbitration in Singapore in accordance with the Arbitration Rules of the Singapore International Arbitration Centre ("SIAC Rules") for the time being in force, which rules are deemed to be incorporated by reference in this clause. The Tribunal shall consist of three (3) arbitrators, with you appointing one (1) arbitrator and us appointing one (1) arbitrator and the third arbitrator to be selected by the two (2) arbitrators so appointed. The language of the arbitration shall be English.
Notwithstanding any of the foregoing, you agree that we are entitled to submit such Dispute for resolution through any other dispute resolution mechanism including the courts of any jurisdiction and we shall further be entitled to seek any injunctive or other equitable relief in the event of any breach or anticipatory breach by you, without any obligations of providing any bond or surety or proof of damages.
You irrevocably waive all rights to seek any injunctive or other equitable relief or to enjoin or restrain the operation or exploitation of the Services or any part thereof. You further irrevocably waive all rights to a class or representative action or as a named or unnamed member in a class, consolidated, representative or private attorney general action.
The Services are not intended to be accessed by persons under the age of 13, nor do we knowingly collect or solicit personal data therefrom. In the event that we learn that we have inadvertently gathered personally identifiable information from persons under the ages set out below, we will take commercially reasonable measures to ensure that such information is removed from our records.
We use commercially reasonable physical, managerial, and technical safeguards to preserve the integrity and security of your personal information. We cannot, however, ensure or warrant the security of any information you disclose on, through or within the Services and you do so entirely at your own risk. Please note that we cannot guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.
If we learn of a security systems breach, we may attempt to notify you electronically so that you can take appropriate protective steps. We may post a notice in the app if a security breach occurs.
If you create an Account with the VPNova, you will be required to select a password that can be changed at any time after you first log into the Account by using your current password. You are solely responsible for maintaining the confidentiality of your password and are fully responsible for all activities that occur under your Account and password or your account with any other third party service. Users agree to (i) notify us immediately if you are aware or reasonably suspect of any unauthorized use of your Account or password or of any unauthorized access of the Services through your Account, and (ii) ensure that you exit from your Account at the end of each session.
1. In the event that we are acquired by or merged with another entity, we reserve the right, in any of these circumstances, to transfer the information or assign our rights to the information that we have collected from our Users as part of such merger, acquisition, sale, or other change of control.
2. In the event of our insolvency, reorganization, receivership, winding-up or assignment for the benefit of creditors, or the application of laws or equitable principles affecting creditors' rights generally, we may not be able to control how your personal information is treated, transferred, or used.
via email to firstname.lastname@example.org.
Last updated October 10, 2018