Privacy Policy

This Privacy Policy describes how SOFTPOST LLC, a legal entity registered under the law of State Nevada, USA (“Company” or “we” hereby) uses and shares Information that is collected by us or provided by you when you visit our Site, access and use the Software or Services. This Privacy Policy also tells you about your rights and choices with respect to your Personal Data, and how you can reach us to update your Data or get answers to questions you may have about our privacy practices. Definitions not expressly highlighted inhere shall have the meaning as pointed in Terms of Use located at https://WasabiVPN.com/terms.php

By using the Software and/or Services or accessing our Site you become subject to this Privacy Policy and agree to the collection and use of Information, including Personal Data, to the extent permitted by applicable law or Regulation and in accordance with this Privacy Policy for processing, collecting, transmitting and storing of your Personal Data and Non-Personal Data in order to provide you with the most efficient services and user experience, improving of our Software, Services and Site, track the behavior of users during their use or browsing through our Services and Site, statistical purposes, purposes of performing our obligations (e.g. Agreements, Insertion Orders etc.) and other purposes pointed herein as well as to share with the other governmental and non-governmental authorities whenever they have the right to demand disclosure of such Information (including Personal Data – if this is permitted and to the extent permitted by applicable law or Regulation), as well as for our use of Cookies. We may collect, use, transfer, and disclose the Information (as applicable) for any purpose pointed in this Privacy Policy.

This Privacy Policy may be subject to change in the future. Every time we make changes, we will publish a new version of the Privacy Policy at this page and will point the date of revision.

Please, read the provision of this Privacy Policy very carefully and if you have any questions contact us via email pointed herein. By accessing or using the Site, the Software and/or the Services, you agree to all the conditions pointed herein and give us your free unambiguous consent to act with your Personal Data as pointed in this Privacy Policy.

Note to Users Resident in the European Economic Area: This Privacy Policy will govern use of your personal Information if you choose to use our Site, Software and/or Services. However, you may have specific rights as European Union data subjects, as described below.

“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.

“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.

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 encrypted form for the sole purpose of verification of successful payment from you for the Services (if applicable to you).

Software Information: We may use other technical means to collect and analyze certain information about how you use the Software. This technical information includes Internet Protocol (IP) addresses, browser information, internet connection status (wifi/mobile). We may also keep a record of how long your device has been connected using our Software. It can also be used to help us understand your preferences based on previous or current Software activity, which enables us to provide you with improved Services. As well it can help us compile aggregate data about traffic and interaction with the Software, thus we will be able to provide You with better user experiences and tools in the future. We treat information collected by such other technical means as Non-Personal Data. However, to extent that Internet Protocol (IP) addresses or similar identifiers are considered Personal Data by local law, we also treat these identifiers as Personal Data. Similarly, to extent that Non-Personal Data is combined with Personal Data, we treat the combined information as Personal Data for the purposes of this Privacy Policy.

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.

Other Information: you may provide us with Information when you interact with us in other ways, such as when you submit requests or questions to us via forms or email (e.g., support forms, sales forms, user research participation forms, surveys, blog subscription); information you provide in connection with our contests and/or research studies in which you choose to participate; beta testing; and requests for customer support and technical assistance (collectively, “Other Information”). Participation in our surveys, filling our forms etc. is voluntary and you may choose whether or not to participate and therefore disclose this information. Such information will be used for purposes of monitoring or improving the use and satisfaction of our Site, Software and Services and to notify the winners and award prizes (if any).

In addition to any Information that you choose to submit to us, we and our third-party service providers may use a variety of technologies that automatically (or passively) collect certain Information whenever you visit or interact with our Site or while using our Software and/or Services.

Tracking technologies that may be used to collect Information from your interactions with the Service, Site and/or Software include, without limitation, the following:

Cookies and Similar Technologies Information: we use “cookie” technology for lots of essential things — like helping you log in and tailoring your experience while using our Site, Software, Platform or Services. We may also use Cookies to better understand how you interact with the Site and our Service, to monitor aggregate usage by our users and web traffic routing on the Site, to improve the Site and our Service, to help us understand your preferences based on previous or current Site and/or Software activity, which enables us to provide you with improved Services.

We may also automatically record certain information from your device by using various types of similar technologies, including “clear gifs” or “web beacons.”

Automatically collected information may include your IP address or other device address or ID, web browser and/or device type, the web pages or sites that you visit just before or just after you use the Site, Service, the pages or other content you view or otherwise interact with on the Service, and the dates and times that you visit, access, or use the Service.

We treat Information collected by Cookies and other similar technologies as Non-Personal Data. However, to the extent that Internet Protocol (IP) addresses or similar identifiers are considered Personal Data by law or Regulation, we also treat these identifiers as Personal Data. Similarly, to the extent that Non-Personal Data is combined with Personal Data, we treat the combined Information as Personal Data for the purposes of this Cookie Policy, our Privacy Policy and compliance with applicable Law and Regulation.

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 will use your Contact, Software and Service Information to provide Services, and provide you with access to the Software you have downloaded/ordered, as well as support services, technical updates or updates on changes in our usage policies. We may also use your Contact Information to send you company updates and marketing offers when permitted by law and/or when you have agreed. You may refuse or revoke your consent to use Personal Data for the above purposes at any time by terminating a subscription, deleting the Software and/or contacting us via the email address provided in this Privacy Policy.

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.

We may collect, use, transfer, and disclose Non-Personal Data for any purpose pointed in this Privacy Policy.

Software and Service information may be aggregated and used to help us provide more useful information to our customers and to understand which parts of the Software are of most interest. This information may be used to improve the relevancy of results provided by the Software. Aggregated data is considered Non-Personal Data for the purposes of this Privacy Policy and will not be associated with your IP address or other Personal Data.

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.

We use Cookie and Similar Technologies Information to remember your settings and preferences to provide you with a more personalized experience while using our Site, Platform, Software or Services; to deliver advertisements and make them more relevant and meaningful to you, and to track the efficiency of our advertising campaigns on our Site, Software or Services (if any); to run the Site and to identify and prevent security risks.

We may also use the third-party services by placing Cookies of certain providers to help us analyze and improve our Site, Platform, Software or Services. Such third-party services are pointed below.

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 your Information 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.

Note to Users Resident in the European Economic Area: If you are located in the European Economic Area or Switzerland, we may process your Personal Data for the abovementioned purposes when:

We pay particular attention to the protection of your Personal Data. We may disclose the Personal Information we collect about you as described below or otherwise share your information with the following entities, including those outside the European Union or the European Economic Area:

Internal Concerned Parties. We may share your Information with companies, who are our subcontractors, as well as with our employees, in order to provide you with the Software, the Services and/or the Sites. Our employees have limited access to your Information on a “need to know” basis and are bound with non-disclosure contractual obligations.

Service Providers. 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, payment processing. 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.

Our third party service providers are based mainly in the European Economic Area (EEA) and USA. If you are located in the EEA or Switzerland, when transferring your Personal Data outside the EEA or Switzerland, we will comply with applicable legal requirements for the transfer of Personal Information to countries outside of the EEA or Switzerland and make sure that our third party service providers can guarantee a high level of Personal Data protection. These guarantees may include, e.g. use of standard contractual clauses adopted by the Commission (EU) or participation in the “Privacy Shield” program established by Commission Implementing Decision (EU) 2016/1250 of 12 July 2016 on the adequacy of protection provided by the EU-US Privacy Shield.

Service	Service Provider	Purpose	Link to Service Provider’s Privacy Policy	Type of Personal Data
Google Analytics	Google, LLC; Alphabet Inc. (parent company)	Analyzing Data for marketing purposes and improvement of the Software and Services	https://policies.google.com/privacy?hl=en	End user’s location and IP address, device ID, lifestyle information, contact information, purchase list
AdMob	Google, LLC; Alphabet Inc. (parent company)	Advertising services, marketing purposes	https://policies.google.com/privacy?hl=en	End user’s location and IP address, device ID, lifestyle information, contact information, purchase list
Facebook Pixel	Facebook, LLC	Analyzing Data for marketing purposes and improvement of the Software and Services	https://www.facebook.com/about/privacy	End user’s location and IP address, device ID
Hetzner Online	Hetzner Online GmbH	Data storage and database maintenance services	https://ru.hetzner.com/hosting/legal/datenschutz	All categories of Information
Servers.com	Servers.com	Data storage and database maintenance services	https://www.servers.com/legal/privacy-policy	All categories of Information

We may also share your Information with other service providers for the abovementioned purposes, with which we will establish cooperation.

Compliance with laws and law enforcement entities. We cooperate with government and law enforcement officials or private parties to enforce and comply with the law. To the extent permitted under applicable law and Regulation, we may disclose any Information about you to government or law enforcement officials or private parties as we believe is necessary or appropriate to investigate, respond to, and defend against claims, for legal process (including subpoenas), to protect the property and rights of Company or a third party, to protect us against liability, for the safety of the public or any person, to prevent or stop any illegal, unethical, fraudulent, abusive, or legally actionable activity, to protect the security or integrity of the Service, Site or Software and any equipment used to make the Service available, or to comply with the law. We also may be required to disclose an individual’s Personal Data in response to a lawful request by public authorities, including to meet national security or law enforcement requirements. 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 applicable law, statute, court or administrative order.

Business Transfers. We reserve the right to sell, transfer or otherwise share some or all of our assets, including Personal Data, in connection with, including but not limited to, a merger, acquisition, reorganization, sale of assets, or similar transaction, or in the event of insolvency or bankruptcy. You acknowledge that such transfers may occur and that any acquirer or successor of ours may continue to use your Personal Data as set forth in this Privacy Policy. You will have the opportunity to opt out of any such transfer if the new entity’s planned processing of your information differs materially from that set forth in this Privacy Policy.

Other Third Parties. We may also make certain Non-Personal Data available to third parties for various purposes, including for business or marketing purposes or to assist third parties in understanding our users’ interest, habits, and usage patterns for certain programs, content, services, advertisements, promotions, functionality available through the Service, statistics and other use. This is not linked to any Personal Data that can identify any individual person.

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). However, please, note that some data recipients may be located outside the EEA and Switzerland, as it was mentioned above. By submitting your Personal Data, 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 will comply with applicable legal requirements for the transfer of Personal Data to countries outside of the EEA or Switzerland. In such cases we will transfer your data only to such countries as approved by the European Commission as providing adequate level of data protection, or enter into legal agreements ensuring an adequate level of data protection. As well, we will ensure that such agreement contains obligation of processor to adopt necessary provisions into his agreements with sub-processors (if any). Moreover, before transferring any Personal Data to a 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.

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.).

In order to use Software and receive Services, a user must first complete the registration form. During registration, a user is required to give certain information as described above in this Privacy Policy. In addition to the purposes pointed above, this information is used to contact you about the products/services on our Site in which you have expressed interest. At your option, you may also provide additional information about yourself, but it is not required.

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.

We will maintain industry-standard physical, electronic and procedural safeguards designed to protect data in our possession from loss, misuse, any use not pointed in this Privacy Policy and unauthorized access. Wherever we collect Personal Data, we make all commercially reasonable efforts to provide the necessary level of Encryption/Anonymisation/Pseudonymisation, as required by applicable law or Regulation. We can provide such security measures by using third parties (e.g. processors, contractors etc.).

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.

A. the right to express and withdraw consents, including reading or registering cookies,

C. the right to access your Data, including obtaining a copy of the Data to be processed (in written, or by providing access to your Personal Data on our server (other type of storage), or sending it to you by email or on CD/DVD/other device, or in other applicable way, etc.);

D. the right to rectify (correct) your Personal Data if your Data in our possession is inaccurate or incomplete;

E. the right to delete your Data if your Data is no longer necessary for the purpose for which it was collected, and Company has no grounds for its processing, e.g. based on your consent or legal obligation. Moreover, you may ask to delete your Data at any time, but in such case it may lead to impossibility to use our Site, Service, Software and/or may lead to termination of our contractual relations with you (if any);

F. the right to transfer your Data provided to us by you in a machine-readable format, e.g. if you want to share it with another service provider;

However, please note that these rights are not absolute, and may be subject to our own legitimate interests and regulatory requirements.

In addition to the abovementioned rights, you also have the right to lodge a complaint with a competent supervisory authority subject to applicable law.

You also have the right to express your concern regarding our data policies. In order to exercise this right you should send relevant request via email pointed in this Privacy Policy.

If you wish to exercise any of the aforementioned rights, or receive more information, please contact us via email pointed in this Privacy Policy.

In order to fulfill your request, we are required to verify your identity so that your data does not go to an unauthorized person. In case if you send a relevant request on behalf of company (in cases where Personal Data may be applicable to the company as pointed in Law and/or Regulation), we should be sure you are duly authorized to receive such data about such company. As a way of example, but not limited to: if you send request from the same email you used during registration and with the same signature you usually use in your emails (if there were any between us), we reasonably consider that it is you, who asks for your Personal Data. In cases if you use other email address, or Company asks data about itself through other employee (not the one who registered on the Site/signed up for the Services) we shall ask for additional verification (unless such additional emails/persons were pointed as trustworthy during registration).

Company, within one month of receiving your request, shall provide you with information about the actions taken in connection with your request. If necessary, the deadline for your request can be extended up to 60 days due to the complex nature of the request or the number of requests.

In cases, if you found out that someone illegally provided us with your Personal Data, let us immediately know about this via our contact email pointed in this Privacy Policy. Upon your request, we will delete your Personal Data without undue delay, but in any case within one month from the day of receipt of your request (or 60 days due to the complex nature of the request or the number of requests). We will only retain such copies of the information as are necessary for us to comply with law and Regulation for such cases.

If your request turns out to be unreasonable or excessive, in particular due to its repeated nature, we may request a reasonable fee for the fulfillment of the request or refuse to take action in connection with the request.

In cases of breach of security which lead to unauthorized access to your Personal Data, we: will let you and the relevant Data Protection Authority 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 the Site 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 you 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.

We will retain your Personal Data for as long as necessary to provide our Services, provide access to our Software/Site, and as necessary to comply with our legal obligations, resolve disputes, and enforce our policies. Retention periods will be determined taking into account the type of Information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused Information at the earliest reasonable time. We make commercially reasonable efforts to store your Personal Data no longer than for 3 months. After such period, we make a revision of it. However, as it was mentioned above, we may delete your Personal Data at any time before such 3-month period terminates, in case if purpose we collected it for is no longer applies. We make no warranties your Personal Data will be available for any specific period of time (3 months, 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.

Please, notice that under applicable regulations, we may keep records containing client/customer/user Personal Data, billing information, communications and anything else as required by applicable laws and regulations or on a basis of legitimate interest (e.g. for defending our interests).

For the convenience of our users the Software and/or emails may contain links to other sites, which are subject to different privacy policies. This Privacy Policy will not apply to other sites, software or accompanying services. Please be aware that we are not responsible for the content or privacy practices of such 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 Links and to read the privacy statements of any other site that collects personally identifiable information (Personal Data).

We understand the importance of taking extra precautions to protect the privacy and safety of children accessing Site and/or Software. Children under the age of 16, or equivalent minimum age in the relevant jurisdiction, are not permitted to use Site and/or Software, unless their parent/guardian provided verifiable consent or as part of the child account creation process (if this type of account is applicable). We do not knowingly collect Personal Information from children under 16, or equivalent minimum age depending on jurisdiction. 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, unless we are obliged to keep such data in order to comply with Law and/or Regulation.

If at any time a parent/guardian needs to access, correct, or delete such Information, he may contact us through email pointed in this Privacy Policy.

Do Not Track Signals. We do not track you by ourselves over time and across third-party websites to provide targeted advertising and therefore respond to Do Not Track (DNT) signals in a way that we use the usual types of tracking systems that are a standard practice in advertising, e.g. Google AdWords. As well, be aware that some third party sites 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. We offer interactive Software, which allows you to post content to share publicly or with friends. At any time, you can delete or remove content you have posted using the deletion or removal options within our Software. If you have questions about how to remove content in a specific service or if you would like additional assistance with deletion you can contact us via email pointed in this Privacy Policy. Although we offer deletion capability for Software, you should be aware that the removal of content may not ensure complete or comprehensive removal of that content or information posted through the Software.

You should acknowledge that deleting/stop of use of the Software does not automatically mean that we have no of your Personal Data or that we as well deleted all of your Personal Data we have. In order to have your Personal Data deleted you should contact us via email pointed in this Privacy Policy.

Whenever we make an update of this Privacy Policy it will be available on our Site (https://WasabiVPN.com/privacy.php) with the mark “new version updated ...”.

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 (e.g. in the event that the modifications materially alter your rights or obligations hereunder).

You can access the new version of Privacy Police from the same day as it comes to affect – so you have the time to make a decision regarding the further use of our Site and Software. As well, we can make a draft of new Privacy Policy available in advance if we will consider it appropriate.

You acknowledge that and voluntarily give us the right to change also the purpose of using, collecting and proceeding of your Personal Data and this changes will be pointed in the new version of our Privacy Policy and won’t require any additional approval from you. If you won’t agree to the new purposes of processing, you should contact us via email pointed in this Privacy Policy with the relevant statement and immediately stop using Software and Services. You are advised to check for updates regularly. Your continued use of the Service after the revised Privacy Policy has become effective indicates that you have read, understood and agreed to the current version of this Privacy Policy.

This Privacy Policy does not create rights enforceable by third parties or require disclosure of any Personal Data relating to users of the Site.

If you have any questions, concerns or complaints regarding the way we collect and handle your Personal Data, or if you have any thoughts or questions about this Privacy Policy, or regarding contact person (representative) for compliance with law and Regulation please contact us by info@WasabiVPN.com

PRIVACY POLICY