[Last Revised: January 24, 2020]
We have included below information regarding which data is collected and how we process and use your data, however before we get into that we would like to explain the basis for such processing:
1) If you sign up for any of our Services, we process your Personal Data (as defined below) in order to perform our contract with you;
2) If we have a legitimate interest in processing data, such as online identifiers (i.e., IP addrss) required in order to provide and operate our Services;
3) We will also process your Personal Data where you have provided us with consent to do so.
The first type of information we collect is aggregated, non-identifiable, non-personal information, which may be made available or gathered via the user's use of the Service (“Non-Personal Data”). We are not aware of the identity of the user from which the Non-Personal Data was collected.
The second type of information is individually identifiable information, namely information that identifies an individual or entity or may with reasonable effort identify an individual (“Personal Data”).
If we combine Personal Data with Non-Personal Data, the combined data will be treated as Personal Data for as long as it remains combined.
The table below details the data collected and how it is used:
|What type of data we collect?||How do we use it?|
When you use the Services, we will collect your IP address.
Web Browsing Data
We collect the URLs of visited websites which in most cases is aggregated Non-Personal Data, however, sometimes Web Browsing Data contains terms that could be considered as Personal Data. This data is deleted a short period following collection.
|We will use this data for the purpose of operating our Services, and internal operation purposes.|
If you voluntarily contact us, you may be required to provide us with certain information such as your name and email address.
|We will use this data solely to provide you with the support you have requested or response to your inquiry. We may process the contact history in order to improve our services, as well as resolve disputes.|
When you use the Service, we will collect Non-Personal Data, such as technical information automatically transmitted by the user's device (for example, type of browser, the type of operating system, access time and date, approximate geographical location, etc.).
|We use this data solely to provide and enhance our Services and to enable operation of the Services.|
We collect the above data from you, in the following ways:
Whenever technically possible and required under applicable law, we will ask for your consent to collect your Personal Data and offer you the choice to opt-out.
We do not sell, trade, or rent users' Personal Data to other parties. We may share information solely in the following events:
|Data Sets||Retention Period|
|Online Identifiers||IPs collected for location purposes are deleted immediately following to the completion of use (not stored). However, note that, if you use our VPN for desktop, the IP collected is necessary for the purpose of providing the Services, and thus, will be deleted solely following completion of such purpose (meaning when you delete the VPN application and cease use of the Services).|
|Contact Details||Deleted Immediately following the completion of your request.|
|Technical Information||For as long as needed to perform the Services.|
Notwithstanding the above, in some circumstances we may retain the information we collect for longer periods, for example, when we are required to do so in accordance with legal, tax and accounting requirements. In addition, we may also retain your Personal Data for longer periods if we reasonably believe, at our discretion, that we need to obtain an accurate record of your correspondence or any dealing with us, for example, in the event of any complaints, all, in compliance with applicable laws.
Data protection and privacy laws provide you with the ability to exercise some rights regarding your Personal Data that we hold (which might be different in each jurisdiction) such as; right to access your Personal Data; right of rectification; the right to erasure of your Personal Data; right to restrict processing of your Personal Data; the right to object to processing of your Personal Data; data portability; the right to file a complaint to a supervisory authority (in the event you are EEA resident); and, the right to withdraw consent. For more information, please review our Data Subject Rights Overview.
If you wish to exercise any or all of the above rights, please fill out the Data Subject Request (“DSR”) form available here, and send it to our Data Protection Officer at: email@example.com and let us know that you wish to exercise your right of access and specify what Personal Data you would like to receive.
Where we are not able to provide you with the information for which you have asked, we will endeavor to explain the reasoning for this and inform you of your rights, including the right to complain to the supervisor authority. We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any such information in accordance with applicable law. In addition, the process of locating and deleting the data may take up to one (1) month (following the receipt of the validation proof we require) in accordance with applicable law.
Data privacy and related laws in your jurisdiction may provide you with different or additional rights related to the data we collect from you, which may also apply.
Further, in the event of a security incident, in which we discover your Personal Data may be at risk, we will take reasonable efforts to notify you and the applicable authority (if required, subject to applicable laws).
If you become aware or have any reason to believe that a Child has shared any information with us, please contact us (as detailed below) and we will take reasonable steps to ensure that such information is immediately deleted from our files.
We may process or store Personal Data within the EEA, US, and internationally, therefore you hereby accept and agree that by accessing and using our Services from outside the United States, your information may be transferred to, stored, and processed in the United States. If you are a resident of the European Economic Area (“EEA“) we will take appropriate measures to ensure that your Personal Data receives an adequate level of data protection upon its transfer outside of the EEA.
Our Service does not respond to Do Not Track signals. For more information about Do Not Track signals, please see: http://www.allaboutdnt.com.
Urban Cyber Security
501 Fifth Avenue, New York, NY, 10036.
You can also contact our privacy team at: firstname.lastname@example.org.
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