We are the sole owners of the information collected on this Site, through the Software or Services. We only have access to/collect information that you voluntarily give us. Unless you ask us not to, we may contact you via email in the future to tell you about specials, new products or services.
“Personal Data” – data that directly, or when used in conjunction with other provided data, enables the identification of a specific individual.
“Non-Personal Data” – data in a form that does not, on its own, permit direct association with any specific individual.
“Pseudonymisation” – replacing any identifying characteristics of data with a pseudonym, or, in other words, a value which does not allow the data subject to be directly identified.
“Anonymisation” – processing data with the aim of irreversibly preventing the identification of the individual to whom it relates.
“Regulation” – Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (General Data Protection Regulation).
“Law” – data protection and other laws and regulations of state of California, USA applicable to the subject matter, and Regulation as determined above.
Types and Use of Information Collected
Contact Information: When you access or otherwise use, register / sign up for the Software, we may collect certain contact information from you, such as your email address and name (if applicable) to help you with your experience (collectively, "Contact Information"). This information is required by us to verify your identity and set up your Services.
Billing information: We may receive certain information concerning billing from digital distribution platforms (e.g. App Store, Google Play), where you pay for our Services (if applicable to you). This information may include your country, currency of payment, your email connected to the payment account on relevant digital distribution platform, status of payment. We do not store such information and receive it from digital distribution platforms in incrypted form for the sole purpose of verification of successful payment from you for the Services (if applicable to you).
Service Information (obtaining information through a legitimate interest): in order to provide Services to you and to improve your experience, we may collect information that is absolutely necessary for us to know to provide you with the Services or is created, provided by you in connection with your use of the Services (collectively, “Service Information”), including location (real-time geographic location), network information, IP-address, device ID, device info, connection timestamp within using of the Software. Service Information may include Personal Data. We use Service Information to provide Services and improve Software, as well as to market our Services to you in a more personalized manner.
In addition to the uses described above, information collected from you when you use the Software, register or sign up for the Software, sign up for our newsletter, respond to a survey or to our marketing communication, browse with the use of the Software, or use Services or its features in any way, we may use in the following ways.
We may use any information collected from you (Personal and Non-Personal Data): (i) to personalize user's experience and to allow us to deliver the type of content and product offerings in which you are most interested; (ii) to improve the Software in order to better serve you and/or to provide Services more effectively; (iii) to ensure continuous improvement and development of the Software; (iv) to administer the Software and accompanying Services and to diagnose possible problems; (v) to send periodic emails regarding your order or our other products and services.
If we do combine Non-Personal Data with Personal Data the combined information will be treated as Personal Data for as long as it remains combined.
We use Software and Service information to understand and analyze trends, to administer the Software, to learn about user behavior using the Software, to improve our product and services, and to gather demographic information about our user base as a whole. We may use this information in our marketing and advertising services.
In some of our email messages, we use a “click-through URL” linked to content on our website (https://WasabiVPN.com/) or the Software. When customers click one of these URLs, they pass through a separate web server before arriving at the destination page on our website or the Software. We track this click-through data to help us determine interest in particular topics and measure the effectiveness of our customer communications. If you prefer not to be tracked in this way, you should not click text or graphic links in the email messages.
To the extent possible, all the information collected, is collected anonymously in a form that does not personally identify you and is used to provide and improve location-based products and services.
We can delete Personal and Non-Personal Data any time we consider it appropriate and in compliance with the purposes we collected it for, unless we are required by law or Regulation to store such information for particular period of time.
Disclosure of Information
We may use third party (processor, contractor, affiliate, partner, contractors, suppliers, vendors etc.) to perform certain business-related functions. Examples of such functions include, but are not limited to: data storage services, database maintenance services, and payment processing (if applicable). When we use such third party to perform services on our behalf, we will only provide them with access to Personal Data that they need to perform their specific function. We will make sure that each third party will be required by contract to keep such Personal Data confidential, make necessary steps to protect such Personal Data and not to use it for any purpose other than providing services to us and other provisions as required by law and Regulation.
Before transferring any Personal Data to third party (processor, contractor, affiliate, partner, contractors, suppliers, vendors etc.) we shall make reasonable check of such third party regarding its compliance with law and Regulation. We will make commercially reasonable efforts to store Personal Data of individuals in the regions where they live or operate in cases if we are required by law or Regulation to do so (e.g. Personal Data of EU citizens in EU or countries acknowledged by relevant authority as having appropriate level of data protection). If storing of Personal Data in such way is not commercially reasonable, we will ensure that third party processors are bound by agreement which contains obligations of the processor to provide at least minimum necessary level of security and other provisions as required by law or Regulation (e.g. as required by approved model data processing agreements adopted by relevant data protection authority). As well, we will ensure that such agreement contains obligation of processor to adopt necessary provisions into his agreements with sub-processors (if any). Herein you give us your free unambiguous consent to store your Personal Data (and Non-Personal Data, if applicable) outside of your country of residence (registration, domicile, center of vital interests, economic region, etc.).
We may disclose Personal Data if required to do so by law (Regulation) or to comply with a legal obligation, or if we believe in good faith that such action is necessary to: (i) protect our rights or property and our customers or (ii) protect the property or safety of users of the Software and the accompanying services, legal owners of the Software; or any third party. If we will be required by law to disclose any of your Personal Data, we will use reasonable efforts to provide you with notice of that disclosure requirement, unless we are prohibited from doing so by statute, court or administrative order.
Please note that your non-personally identifiable information (Non-Personal Data) may be provided to other parties for marketing, advertising, statistics or other uses. This is not linked to any Personal Data that can identify any individual person.
By refusal to provide data necessary for registration, you refuse to receive our Software and Services.
In case you act as an agent for a third party during registration or use of our Site/Software/Services you should be duly authorized to provide us with necessary amount of the data of such third party. By registering, you represent and warrant that you are duly authorized.
However, no method of transmission or method of electronic storage is 100% secure. We do not guarantee that the data stored during your use of the Software and Services is invulnerable to hacking and will not be subject to a security breach. We make no warranty, guarantee, or representation that the Software or the Services are or will be protected from all viruses, security threats or other vulnerabilities or that your Personal Data and Non-Personal Data will always be secure.
To make sure your Personal Data is secure, we communicate our privacy and security guidelines to our employees and strictly enforce privacy safeguards within the company. Only employees who need your Personal Data to perform a specific job (e.g. billing or customer service) are granted access to relevant personally identifiable information (Personal Data). All of our employees sign relevant NDA and our security system is designed to ensure possibility of identification of all the employees who had access / accessed Personal Data of our users.
Your obligations regarding security of your data are the following: not to disclose your contact information and other data which allows/enables unauthorized access to the Software or any other actions connected to the Software on your behalf; make reasonable efforts to secure your actions in Internet and your use of the Software and Services. You are solely responsible for the correctness, appropriateness fullness etc. of the provided data and warrant to us that you have all rights to provide us with such data.
Links to Other Sites
Information collected by third parties, which may include such things as location data or contact details, is governed by their privacy practices. We encourage our users to be aware when they go through such Linksand to read the privacy statements of any other site that collects personally identifiable information (Personal Data).
Surveys & Contests
From time-to-time, we may request information via surveys or contests. Participation in these surveys or contests is voluntary and you may choose whether or not to participate and therefore disclose this information. Information requested may include contact information (such as name and address), demographic information (such as zip code, age level) and business information (types and amounts of Services used, targeting specifications). Survey information will be used for purposes of monitoring or improving the use and satisfaction of this site, and to notify the winners and award prizes (if any).
We understand the importance of taking extra precautions to protect the privacy and safety of children accessing the Software. Children under the age of 16, or equivalent minimum age in the relevant jurisdiction, are not permitted to use the Software, unless their parent/guardian provided verifiable consent or as part of the child account creation process. If we learn that we have collected the Personal Data of a child under 16, or equivalent minimum age depending on jurisdiction, outside the above circumstances we will take steps to delete the information as soon as possible.
You acknowledge and voluntarily agree that we have no obligation of sending you via email or otherwise any notification regarding such change, though we have right to do so if consider it appropriate.
Your Access to and Control Over Information
We store your Personal Data for 3 month and make a revision of it after that period. During such revision, we may either delete all of your Personal Data or keep it collected for the next 3 month if: we are providing you Services; you use Software; we are in the middle of dispute or you are our debtor; such information is still necessary for the purposes we collected it. We can delete your Personal Data any time and not wait for 3 month period to end if purpose we collected it for no longer apply. We make no warranties your Personal Data will be available for any specific period of time (3 month, or less or more etc.). Please consider, that we have no obligations to notify you when deleting your Personal Data and can do it at our sole discretion.
In cases of breach of security which lead to unauthorized access to your Personal Data, we: will let you know about this incident without undue delay as soon as we become aware of such breach and make all reasonable efforts to minimize the harm and restore necessary safety measures. We can notify (inform) you about breach of your Personal Data at our sole discretion in the following ways we consider most appropriate: via your contact email, by phone, in your personal account, in national news, on our website or any other way which allows you to make necessary steps to minimize the possible harm without undue delay. Such notification will include general information about the breach, possible risks and our steps to minimize them – to the extent possible in relevant circumstances. You are solely responsible to notify your third parties if their Personal Data is part of such breach (if your are the one who provided such information to us). Our notifications shall not constitute our acknowledgment of any kind of fault (guilt, liability) for the breach.
Other Provisions as Required by Law
Do Not Track Signals
We do not respond to Do Not Track (DNT) signals due to the purpose of VPN software and our necessity to know your location and other pointed information in order to provide Services. As well, be aware that some third party sites where you may access using the Software do keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you.
Notice for Minors
Questions and Complaints
If you have any questions, concerns or complaints regarding the way we collect and handle your information, please contact us by info@WasabiVPN.com