UrbanVPN Privacy Policy

[Last Revised: March 26, 2019]

This Privacy Policy (“Privacy Policy”) governs the manner in which we process information collected from our users (”you”, ”your” or ”user”) in connection with the access to or use of our browser extension, our website available at: https://www.urban-vpn.com and the Services, all as detailed and defined in our Terms of Use (“Terms”).

1. Lawful basis

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.

2. 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 Revised" 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.

3. 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.

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?
Online Identifiers
When you use the Services, we will collect your IP address.
We will use your IP address in order to provide the VPN Services as well as in order to extract the approximate geographical location (i.e., country). Not that, we use MaxMind’s services for the purpose detailed above, which its privacy policy is available here.
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.
Contact Information
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.
Technical Data
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.
4. How we collect your information?

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

  • Automatically, Non-Personal Data may be automatically transmitted by the user's device. When furthermore, when using our Service, we may assign your device with a Java Script code, to collect the data detailed in the table above.
  • When you voluntarily choose to provide us with information, e.g., when you contact us.

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.

5. With whom do we share information?

We do not sell, trade, or rent users' Personal Data to other parties. We may share information solely in the following events: 

  • We will share your information, solely to the extent needed to comply with any applicable law or regulation (including our policies and agreements), solely to the extent needed to establish or exercise our rights to defend against legal claims or to prevent harm to the rights, property or safety of us, our users, yourself or any third party or for the purpose of collaborating with law enforcement agencies or in case we find it necessary in order to enforce intellectual property or other legal rights.
  • We may share your information, in the event of a corporate transaction (e.g. sale of a substantial part of our business, merger, consolidation or asset sale). In the event of the above, our affiliated companies or acquiring company will assume the rights and obligations as described in this Privacy Policy.
  • We may share Personal Data with our trusted service providers only to the extent required to fulfill the purposes of providing our Services.
6. Data retention
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.

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. 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: dpo@display.io 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

Your privacy is very important to us and therefore we use security techniques to prevent your information from being accessed without authorization, improperly used or disclosed, unlawfully destructed or accidental loss, as detailed in our Information Security Policy. If you believe that your privacy was treated not in accordance with this Privacy Policy, or you have reasonable concern with that any person attempted to abuse our Service, please contact us at: privacy@urban-vpn.com.

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).

9. Children information

You represent and warrant that you are (i) at least thirteen (13) years of age if you are located in the US; (ii) at least sixteen (16) years of age if you are located in the EEA; or (iii) if you are located in any other GEO 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, 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.

11. Do Not Track Disclosure

Our Service does not respond to Do Not Track signals. For more information about Do Not Track signals, please see: http://www.allaboutdnt.com.

12. Contacting us

If you have any comments or questions about this Privacy Policy, please contact us at:

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




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