UrbanVPN Privacy Policy

[Last Updated: March 16, 2023] 

First and foremost, before we dive into the legal details of our privacy policy we wish to make it clear- We do not want to know your identity or any other personal information about you and we do not collect data to try and figure out who you are. We don’t require registration of any kind in order to use our services. Of course, we do provide all of the regular privacy policy information to which you are entitled, and we will get to that in a minute. But in case you do not have the time or patience to read through the whole policy, we want to repeat and make that point perfectly clear: We do not want to know your identity, preferences or any information about you personally. Any data collected from you simply by your use of our product will never be used to figure out who you are or to send you targeted ads, and will not be shared with or sold to any other parties for those purposes. 

This Privacy Policy (“Privacy Policy”) governs the manner in which we, Urban Cyber Security Inc. (“Urban”, “we” or “us”) 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”), and how Urban Ltd. may share this information with Urban’s affiliated company, that processed certain raw data (as further detailed below) to create Insights (as defined below) . These Insights are commercially used and shared with Business Partners. For more information, please see the BiScience Privacy Policy    

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”). 

If you are a California resident, please see the CCPA Notice here 

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

  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. 

  1. Controller Contact Information  

Urban is the controller (as such term defined under the GDPR) or the “business” as defined under the California Consumer Privacy Act (“CCPA”) of the Personal Data, following are the applicable contact information:  

Urban Cyber Security Inc. 

 501 Fifth Avenue, New York, NY, 10036.  

You can also contact our privacy team at: privacy@urban-vpn.com. 

Representative for data subjects in the EU and UK: 

We value your privacy and your rights as a data subject and have therefore appointed Prighter Group with its local partners as our privacy representative and your point of contact.
Prighter gives you an easy way to exercise your privacy-related rights (e.g. requests to access or erase personal data). If you want to contact us via our representative, Prighter or make use of your data subject rights, please visit the following website. https://prighter.com/q/13252349120 

  1. 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 the Data Controller of the data we collect. 

What type of data we collect?  How do we use it?  Lawful Basis 
Approximate Location: 

When using the VPN, we need to process your IP address.  

We extract the approximate geographical location (i.e., country). We need this information to provide the VPN services.   Performance of a contract. 
Online Identifiers:  

When you access and interact with our website, we collect certain online identifiers such as Cookie ID, IP address or similar unique online identifiers generated, advertising ID, tags (“Online Identifiers”).  

We process such data through our or third party cookies and tracking technologies for analytic, marketing purposes. In addition, we process such data for operation, security and fraud prevention purposes.  

  •  
Where we collect such data for analytic and advertising purposes, we process the data based on your consent which we will obtain through our cookie notice and consent management.  You may withdraw consent at any time by using the cookie preference settings. 

Where we collect such data for operation and security, we process your data based on our legitimate interest.  

Browsing Data and Insights:  

We may collect your web browsing data, which includes search engine results page, the web pages and checkout pages you visited, clicked stream data, information about the content that you viewed (the ad campaign), information about where you viewed the content (website or the app or extension) and the products viewed, searched, added to the cart, and purchased. This will include information, regarding the price, product name, currency, quantity, taxes, delivery details (regular or express) payment method, discount value of the product you viewed and searched. (“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, this is why we filter and scrape this data to remove any Personal Data before it is used.  

 

We do not track or collect information about users’ activities across sites or applications, meaning we do not cross information from different apps, websites, your computer, tablet or mobile device. 

 

We share the Web Browsing Data with our affiliated company.  

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.  

 

We will further use filtered Web Browsing Data in an aggregated, anonymized manner, for marketing research and commercial use. It is important you understand, we are not interested in knowing who you are, target or profile you. Instead, we are interested in creating aggregated marketing insights on how ads and web pages are viewed and whether and when they are clicked (“Insights”) and we share these Insights with our Business Partners for commercial use (as detailed below). 

 

These Insights help our Business Partners in their online marketing strategies. For example, it helps them to understand how certain ads on certain websites are engaged. Our interest is not to produce insights on your specific browser usage on an individual level.    

The Web Browsing Data is used for performance of a contract.  

 

The Web Browsing Data is shared with our affiliated company based on consent. You can withdraw consent at any time through the app settings  or by contacting us, as detailed below.  

 

The Insights do not contain any Personal Data and thus do not require a lawful basis. We do not (and cannot) identify, or attempt to identify, the individuals we derived the Insights from. However, we seek your consent to process the Web Browsing Data to share and create the Insights through a pop in notice on the apps or extensions.  

 

Communication:  

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”). 

General quires are processed based on legitimate interests, customer support is subject to fulfilling out contract with you. 

 

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

Subscription:  

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. By allowing us to provide the Residential IP you acknowledge that the Residential IP may cause your device to operate slower and reduce your device security Performance of contract. 

 

  1. 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.   

 

  1. With whom do we share information? 

We share your data with third parties, including our service providers that help us provide our Services. You can find here information about the categories of such third-party recipients.  

CATEGORY OF RECIPIENT  DATA THAT WILL BE SHARED  PURPOSE OF SHARING 
B.I Science (2009) Ltd., our affiliated company   Web Browsing Data   We share the Web Browsing Data with our affiliated company that then users this aggregated raw data to create the Insights. For more information, please see the BiScience Privacy Policy. 
companies active in the advertising and marketing sector such as data analytics, market measurement and marketing companies (“Business Partners”)  Insights  We will share the Insights we produce with our Business Partners for commercial use. The data we share for this purpose shall not include any Personal Data and will include only aggregated data.  
Service Providers  

 

 

All data  We may disclose Personal Data to our trusted agents (such as legal counsel) and service providers (including, but not limited to, our Cloud Service Provider, Analytics Service Provider, fraud and security detection providers etc.) so that they can perform the requested services on our behalf. These providers are prohibited from using your Personal Data for any purposes other than providing us with requested services. When we share information with services providers, we ensure they only have access to such information that is strictly necessary for us to provide the Services. These parties are required to secure the data they receive and to use the data for pre-agreed purposes only while ensuring compliance with all applicable data protection regulations (such service providers may use other non-personal data for their own benefit). 
Any acquirer of our business  All data  We may share Personal Data, 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 Policy. 
Legal and law enforcement  

 

Subject to law enforcement authority request.  We may disclose certain data to law enforcement, governmental agencies, or authorized third parties, in response to a verified request relating to terror acts, criminal investigations or alleged illegal activity or any other activity that may expose us, you, or any other user to legal liability, and solely to the extent necessary to comply with such purpose. 

 

We reserve the right to use, disclose or transfer (for business purposes or otherwise) aggregated and processed Non-Personal Data to third parties, including, inter alia, affiliates and Business Partners, for various purposes including commercial use. This information may be collected, processed and analyzed by us and transferred in a combined, collectively and aggregated manner (i.e., your information is immediately aggregated with other users) to third parties. 

  1. 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  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  www.google.com/policies/privacy/partners 

https://tools.google.com/dlpage/gaoptout. For additional information of our use of Google products, click here. 

Hotjar  Analytic, Performance and Targeting and Advertising   https://www.hotjar.com/legal/policies/privacy/ 

https://help.hotjar.com/hc/en-us/articles/115011789248-Hotjar-Cookies 

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. 

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. You may set your browser to block all cookies, including cookies associated with our Services, or to indicate when a cookie is being used by us, by adjusting the privacy and security settings of your web browser. Please refer to the support page of your browser to learn more about how you can adjust your privacy and security settings. Additionally, you may opt out of certain Advertisers’ cookies and browser-enabled, interest-based advertising at the Network Advertising Initiative’s (“NAI”) website- NAI consumer opt-out and the Digital Advertising Alliance’s (“DAA”) website- DAA opt-out page. 

 

We do not support Do Not Track (“DNT“). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked. You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser. 

 

  1. 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. 

 

  1. User Rights 

We acknowledge that different people have different privacy concerns and preferences. Our goal is to be clear about what information we collect so that you can make meaningful choices about how it is used. We allow you to exercise certain choices, rights, and controls in connection with your information. Depending on your relationship with us, your jurisdiction and the applicable data protection laws that apply to you, you have the right to control and request certain limitations or rights to be executed.  

You may exercise any or all of your above rights in relation to your Personal Data by filling out the Data Subject Request (“DSR”) form available here, and send it to privacy@urban-vpn.com  

For California, Virginia and Colorado residents, please see our CCPA Notice 

 

Further, certain rights are available within the App: you may correct, revise and delete information from the App settings at any time, any consent provided may be easily withdraw, therefore we recommend you use the technical solutions we have provided you with to exercise your rights. 

 

  1. 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. 

 

  1. 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. 

 

  1. 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. 

  1. 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: 

 

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