UrbanVPN Privacy Policy

[Last Updated: April 25, 2022]

This Privacy Policy ("Privacy Policy") governs the manner in which we process information collected from our users ("you", "your" or "user") in connection with their access to or use of our website available at: https://www.urban-vpn.com ("Website") and our products ("Products"): (I) Urban VPN browser extensions, Urban Adblocker browser extensions, Urban Shield browser extension and Urban Anti-Malware Safe Browsing extension (collectively "Extensions"); (II) Urban VPN mobile application available on iOS and Android ("Mobile App") and (III) Urban VPN Desktop EXE software for Windows and Mac ("Desktop App") all as detailed and defined in our Terms of Use ("Terms").

All capitalized terms used but not otherwise defined herein shall have the meaning ascribed to them in the Terms. This Privacy Policy explains what information we may collect, how such information may be used or shared with others, how we safeguard it and how you may exercise your rights related to your Personal Data (as such term is defined below), among others, and where applicable, as required according to the EU General Data Protection Regulation ("GDPR").

The use of information received from Google API will adhere to the Chrome Web Store User Data Policy including the Limited Use requirements.

If you have any questions or requests regarding the processing of your Personal Data, or would otherwise like to contact us in connection with this Policy, please send us an email to: privacy@urban-vpn.com

1. Amendments

Except as otherwise described herein, we may at our sole discretion and at any time amend the terms of this Privacy Policy. Such changes shall be effective upon publication of the amended terms in this Privacy Policy. Your continued use of the Services, following the amendment of the Privacy Policy, constitutes your acknowledgement and consent of such amendments to the Privacy Policy. The last revision will be reflected in the "Last Updated" heading above. In the event of a material change we will make a reasonable effort to provide a notification of such change. We recommend that you periodically review this Privacy Policy, as it may be subject to amendments from time to time.

2. Data we collect and purpose of use

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. Non-Personal Data may include technical information automatically transmitted by the user's device such as, type of browser, the type of operating system, access time and date, approximate geographical location, etc.

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").

The table below details the Personal Data collected by us, how it is used, and our legal basis for data processing. Note that, under the GDPR we are considered of the Data Controller of the data we collect.

What type of data we collect? How do we use it? Lawful Basis
We may collect certain Online Identifiers such as Agent Id, UDID, machine ID (such as Android ID) and your IP address ("Online Identifiers"). We will use your IP address to provide the Services as well as to extract the approximate geographical location (i.e., country). We need this information to provide the VPN services, among others. Performance of a contract.
We place cookies on our Website (as further detailed below under Section 5) in order to process Online Identifiers as well as additional information such as your use of the Website, analytics, etc. "Website Online Identifiers"). We will use such Website Online Identifiers in order to perform research, conduct associated analytical and statistical activities developing our business and for marketing and purposes. Consent through cookie notice or other notice.
We may collect your web browsing data, such as search engine results page, web pages visited, clicked stream data, etc. ("Web Browsing Data").

Note that, in most cases the data detailed above is aggregated Non-Personal Data, however, sometimes Web Browsing Data contains terms that could be considered as Personal Data.

We will use this data for the purpose of operating and providing our Services, for example, in order to create a black listing of target websites and provide the "Safe Browsing Mode" alerts feature, blocking ads, as well as for internal operation purposes and enhancing the Services. Performance of a contract.
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 to improve our services, as well as resolve disputes.

We may send you email marketing materials regarding the Services you are currently using or any services we may offer in the future ("Direct Marketing").

Our legitimate interests

Direct Marketing is subject to our legitimate interest, you may opt-out at any time from certain correspondence.

From time to time we may offer Premium Plans, and in such events you may be required to provide our third-party service providers with additional information such as Card Number, Cardholder Name, etc.

In such events, We may use the following payment service providers ("PSP"):

We do not store or process any of your payment details. We employ third party payment processors and thus, your payment details will be subject to such third-party payment processors privacy practices. Performance of a contract.
Android Permissions:
If you choose to use our active "safe browsing" feature available on our Mobile App you will be required to enable the accessibility permission ("Permission"). can disable the Permission at any time
"Safe Browsing Mode" by enabling us to block unwanted websites or apps. To access the Permission, you will need to actively and explicitly enable it through an in-app permission or the mobile settings. You, therefore the lawful basis is consent. You may withdraw your consent at any time but please note if you disable, the "Safe Mode" feature will not operate properly.
IP Address and Network Resources The Desktop App is a community product and thus, to receive the services, we will collect this data and provide the Residential IP to other users in the community, the same way that you receive them. Performance of contract.
3. How we collect your information?

We collect the above data from you, in the following ways:

  • When you voluntarily choose to provide us with information, e.g., when you contact us.
  • Automatically, when you use our Services, for example, when you use the Website, we may assign your device with a Java Script code and when you use our Mobile App (for Android), and wish to use the "Safe Browsing Mode" we may collect your Web Browsing Data through the Android accessibility services feature as described below.
4. With whom do we share information?

We may share information solely in the following events:

  • For security and fraud detection.
  • As required by law or regulation.
  • In the event of a merger and acquisition.
  • With trusted partners and third parties, including our affiliated companies, who assist us in operating the Services and conducting our business. Note the data is filtered and cleaned on the client side and we make best efforts to ensure the raw data does not include and Personal Data or unique identifiers.
5. Cookies & Tracking Technologies

When you use our Website, we or our third-party service providers may use cookies and other similar tracking technologies or methods of web and mobile analysis to gather, store, and track certain information related to your access of, activity and interaction with our Website. You can find out more information about cookies at www.allaboutcookies.org.

A "cookie" is a small piece of information that a website assigns to your device while you access such website. Cookies are very helpful and may be used for a variety of different purposes. These purposes include help customize your experience, provide us with analytics and for advertising purposes (including personalized advertising).

Note that we do not combine the information collected through the use of third-party tools with any Personal Data collected from you. You may remove Cookies by following the instructions on your device governing the setting of your preferences. Our Cookies do not enable any access to or inspection of other information on your device. If you wish to be notified of when Cookies are placed on your device, you may set your web browser to provide such notices.

The third-party cookies used on our Site are as follows:

Cookie Purpose Privacy Policy/Opt Out
Google Analytics Analytical and Performance http://www.google.com/policies/privacy/partners https://policies.google.com/technologies/managing?hl=en https://tools.google.com/dlpage/gaoptout/ For additional information regarding our use of Google products, click here.
Google Ads Targeting and Advertising http://www.google.com/policies/privacy/partners https://tools.google.com/dlpage/gaoptout/ For additional information of our use of Google products, click here.
Facebook Analytic, Performance and Targeting and Advertising https://www.facebook.com/about/privacy/?sId=eead84c9-01f3-4402-b1b2-b19dc38ba2e7
Microsoft Targeting and Advertising https://privacy.microsoft.com/en-gb/privacystatement
Matomo Analytic and Performance https://matomo.org/privacy-policy/
Bing Targeting and Advertising cookies https://privacy.microsoft.com/en-gb/privacystatement

Most browsers will allow you to erase cookies from your computer’s hard drive, block acceptance of cookies, or receive a warning before a cookie is stored. However, if you block or erase cookies your online experience may be limited.

Please see the following links for more information with respect to how you can block or erase cookies via your particular browser: Google Chrome; Firefox; Internet Explorer; Safari; Edge; Opera.

6. Data retention

We retain the information we collect as long as it remains necessary for the purposes set forth above, all in accordance with applicable laws. We may at our sole discretion, delete or amend information from our systems, without providing any notice to you, once we deem it is no longer necessary for our purposes.

7. User Rights

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.

If you wish to exercise any or all of the above rights, please send it to our Data Protection Officer at: privacy@urban-vpn.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.

8. Data Security

While there are inherent risks involved in all data transmissions over the Internet or wireless networks, and other security risks that apply to stored data, and we therefore cannot guarantee the security of your information, we use our best efforts, using industry-standard encryption and security technologies and methods, to collect and store information collected from you in a secure and safe manner.

9. Children Information

You represent and warrant that you are (I) at least sixteen (16) years of age if you are located in the EEA; or (II) if you are located in any other geography and you are above the age defined as "child" under applicable laws in your jurisdiction (collectively "Child" or "Children"). If you are under 18, please be sure to read the terms of this Privacy Policy with your parents or legal guardians. The Services are not directed or intended for Children, as defined under applicable law, and we do not knowingly collect or solicit information from children. If we later obtain actual knowledge that a user is considered as a Child under applicable law, we will take steps to immediately delete its Personal Data. We request that such individuals do not provide Personal Data through the Services.

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.

10. Transfer of Data

We may process or store Personal Data within the EEA, US, and internationally. In the event of data transfer out of your jurisdiction, we will take appropriate measures to ensure that your Personal Data receives an adequate level of protection as required under applicable law. Further, when Personal Data collected within the EU is transferred outside the EU (and not to a recipient in a country that the European Commission has decided provides adequate protection) it shall be transferred in accordance with the provisions of the standard contractual clauses approved by the European Union.

11. Additional Rights of California Users

California residents have certain additional rights, pursuant to California privacy laws, including the CCPA. Under the CCPA, "Personal Information" is defined as any information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household or device. The categories of Personal Information that we collect (and has collected within the last 12 months), are detailed in the table below. Please note that, under the CCPA Personal Information does not include: publicly available information from government records and de identified or aggregated consumer information, information excluded from the CCPA’s scope (e.g., health or medical information covered by applicable laws such as the Health Insurance Portability and Accountability Act of 1996 (HIPAA)); and information covered by certain sector-specific privacy laws (e.g., the California Financial Information Privacy Act (FIPA)).

As required under the CCPA, we will update this Privacy Notice every 12 months. The last revision date will be reflected in the "Recently Updated" heading located at the top of this Privacy Policy.

Note that the term "sale" is defined broadly in the CCPA to include any exchange of data for consideration of any kind.

Category Do we collect this data? Do we disclosure this data for a business purpose?
A. Identifiers. Yes Yes
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). Yes Yes
C. Protected classification characteristics under California or federal law. No No
D. Commercial information. No No
E. Biometric information. No No
F. Internet or other similar network activity. Yes Yes
G. Geolocation data. Yes No
H. Sensory data. No No
I. Professional or employment-related information. No No
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). No No
K. Inferences drawn from other personal information. No No

In the preceding twelve (12) months, the Company has not sold Personal Information.

12. Contact Us

If you have any questions or concerns regarding privacy issues, or if you wish to be provided with any other information related to our privacy practices, please contact us at:

Urban Cyber Security Inc.
501 Fifth Avenue, New York, NY, 10036.
You can also contact our privacy team at: privacy@urban-vpn.com.

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