VPN99 understands that your privacy is important to you and that you care about how your information is used and shared online. We respect and value the privacy of everyone who visits Our Site and will only collect and use information in ways that are useful to you and in a manner consistent with your rights and Our obligations under the law.
1. Definitions and Interpretation In this Policy the following terms shall have the following meanings:
Account means an account required to access and/or use certain areas and features of Our Site;
Cookie means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in section 12, below;
Our Site means website https://vpn99.net;
Wales and EU Cookie Law means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended in 2004, 2011 and 2015;
GDPR means European Union’s (“EU”) 2016/679 General Data Protection Regulation which came into effect from 25 May 2018 We/Us/Our/Company/ Data Controller/VPN99 means VPN99, a limited company registered in England under LP019029, whose registered address is Suite 10338 45 Salisbury Road, Cardiff, Wales, CF24 4AB .
User/You/Your/Customer means the data subject in according with the GDPR definitions.
2. Information About Us
Our Site, vpn99.net is owned and operated by VPN99, a limited company registered in England under LP019029, whose registered address is Suite 10338 45 Salisbury Road, Cardiff, Wales, CF24 4AB.
3. Scope – What Does This Policy Cover?
4. What Data Do We Collect?
• email address;
• financial information such as credit / debit card numbers (gathering via third-patry payment gateway - see the section 7 below);
• IP address (automatically collected);
• web browser type and version (automatically collected);
• operating system (automatically collected);
• a list of URLs starting with a referring site, your activity on Our Site, and the site you exit to (automatically collected)
5. How Do We Use Your Data?
• All personal data is stored securely in accordance with the GDPR. For more details on security see section 6, below.
• We use your data to provide the best possible services to you. This includes:
• Providing and managing your Account;
• Providing and managing your access to Our Site;
• Personalising and tailoring your experience on Our Site;
• Supplying Our services to you;
• Personalising and tailoring Our services for you;
• Responding to communications from you;
• Supplying you with email (you may unsubscribe or opt-out at any time by clicking ‘unsubscribe’ button within the mail);
• Market research;
• Analysing your use of Our Site and gathering feedb
• Processing of your personal data is based on Article 6(1) lit. b GDPR because it’s necessary for the performance of a contract to which the data subject is party in according with VPN99 Terms and Conditions of use.
• With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email AND/OR telephone with information, news and offers on Our services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, as amended in 2004, 2011 and 2015.
• Advertisers whose content appears on Our Site may engage in what is known as “behavioural advertising” – advertising which is tailored to your preferences, based on your activity. Your activity is monitored using Cookies, as detailed below in section 12. You can control and limit your data used in this way by adjusting your web browser’s privacy settings. Please note that We do not control the activities of such advertisers, nor the information they collect and use. Limiting the use of your data in this way will not remove the advertising, but it will make it less relevant to your interests and activities on Our Site.
• Under GDPR we will ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights. We will only process your personal data if at least one of the following basis applies:
• you have given consent to the processing of your personal data for one or more specific purposes;
• processing is necessary for the performance of a contract to which you are a party or in order to take steps at the request of you prior to entering into a contract
• processing is necessary for compliance with a legal obligation to which we are subject
• processing is necessary to protect the vital interests of you or of another natural person;
• processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; and/or
• processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.
6. How and Where Do We Store Your Data?
• We only keep your data for as long as We need to in order to use it as described above in section 5, and/or for as long as We have your permission to keep it. In any event, We will conduct an annual review to ascertain whether we need to keep your data. Your data will be deleted if we no longer need it in accordance with the terms of our Data Retention Policy
• Your data will only be stored within the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland and Liechtenstein).
• Data security is of great importance to Us, and to protect your data We have put in place suitable physical, electronic and managerial procedures to safeguard and secure data collected through Our Site
• Notwithstanding the security measures that We take, it is important to remember that the transmission of data via the internet may not be completely secure and that you are advised to take suitable precautions when transmitting to Us data via the internet.
7. Do We Share Your Data?
We may contract with third parties to supply services to you on Our behalf. These may include payment processing, delivery of goods, search engine facilities, advertising and marketing. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law. We currently contract with:
1. Orange-pay (We provide the following information: name and payment details)
We use third-party payment gateway provided by OrangePay, international company that provides processing services for electronic payments in the sphere of internet-acquiring. OrangePay is regulated by Czech National Bank and conforms to all norms of financial operations management. Payments are processed as follows:
1) The customer submits his credit card for payment.
2) OrangePay manages the complex routing of the data on behalf of the merchant through the following steps/entities.
3) OrangePay passes the secure transaction information via a secure connection to the Service Provider. The Merchant Bank’s Processor submits the transaction to the credit card network (like Visa or MasterCard). The credit card network routes the transaction to the bank that issued the credit card to the customer.
4) The issuing bank approves or declines the transaction based on the customer’s available funds and passes the transaction results back to the credit card network. The credit card network relays the transaction results to the merchant bank’s processor. The processor relays the transaction results to OrangePay.
5) The issuing bank approves or declines the transaction based on the customer’s available funds and passes the transaction results back to the credit card network. The credit card network relays the transaction results to the merchant bank’s processor. The processor relays the transaction results to OrangePay.
6) The merchant delivers goods or services to the buyer.
7) The issuing bank sends the appropriate funds for the transaction to the credit card network, which passes the funds to the merchant’s bank. The bank then deposits the funds into the merchant’s bank account. This is called ‘settlement’, and typically the transaction funds are deposited into the merchant’s primary bank account within two to four business days.
OrangePay address is: Praha - Nusle, Štětkova 1001/5, PSČ 140 00
OrangePay has taken the following measures to protect your personal data:
– Security software, such as a virus scanner and firewall.
– TLS1.2 or higher (formerly SSL).
– Anti-Fraud Security Service. Filtration of fraud payments includes a number of parameters for transaction analysis. Safety parameters are due to individual adjustments subject to project requirements. System complies with PCI DSS Level 1 and allows 3-D Secure settings for various parameters. More information about the data processing details during the payment process you can see at the OrangePay official website – https://orange-pay.com .
2. Zendesk (We provide the following information: name and email address)
Zendesk, Inc., a software development company, provides SaaS products for organizations. Its flagship product is Zendesk Support, a system for tracking, prioritizing, and solving customer support tickets across various channels. The company also offers Zendesk Chat, a live chat software to connect with customers on Websites, in applications, and on mobile devices; Zendesk Talk, a cloud-based call center software; Zendesk Guide, a knowledge base that for customer self-service and support agent productivity; Zendesk Message, a customer messaging software; and Zendesk Explore that makes customer data accessible across an organization. In addition, it operates a developer platform that allows organizations to extend the functionality of its family of products, integrate into internal and third-party systems, and customize the experience for their employees and customers. It has operations in the United States, Europe, the Middle East, Africa, and internationally.
Zendesk, Inc. is headquartered in San Francisco, California:
1019 Market Street San Francisco, CA 94103
3. Sendpulse (We provide the following information: name and email address)
SendPulse is a platform which offers multiple channels of communication with customers: email, web push notifications, SMS and Viber. Also it provides reporting capabilities and AB test tools.
4. ActiveCampain (We provide the following information: name and email address).
ActiveCampaign, LLC (“ActiveCampaign”) provides a marketing platform which offers which offers multiple channels of communication with customers: email, SMS, website messaging, Facebook custom audiences. It allows us to reach our customers with all the related services and to understand how their customers interact with those communications and other content, how to customize marketing based on their customers’ interests.
ActiveCampaign is headquartered in:
1 North Dearborn Street, Chicago, IL 60602 USA
5. Google Analytics
On this website, the controller has incorporated the segment of Google Analytics (with the anonymizer feature). Google Analytics is a web analytics service that tracks and reports website traffic. Web analytics is the collection, gathering, and analysis of data about the behavior of visitors to websites. A web analysis service collects, inter alia, data about the website from which a person has come (the so-called referrer), which sub-pages were accessed, or how regularly and for what duration a sub-page was seen. Web analytics are for the most part utilized for the advancement and optimization of a website and with a goal to carry out a cost-benefit analysis of Internet advertising. Google Analytics places a cookie on the information technology system of the user. By this particular cookie with specific settings Google is enabled to analyze the use of our website. The cookie is used to store personal information, such as the access time, the location from which the access was made and the frequency of visits of our website by the data subject. With each call-up to one of the individual pages of this Internet site, which is operated by the VPN99 and into which a Google Analytics component was integrated, the Internet browser on your information technology system will automatically submit data through the Google Analytics component for the purpose of online advertising and the settlement of commissions to Google. During this procedure, Google gathers knowledge of personal information such as your IP address which helps to understand the origin of visitors and clicks.
The operator of the Google Analytics component is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, United States
More information available at: https://policies.google.com/privacy
• We may compile statistics about the use of Our Site including data on traffic, usage patterns, user numbers, sales and other information. All such data will be anonymised and will not include any personally identifying information. We may from time to time share such data with third parties such as prospective investors, affiliates, partners and advertisers. Data will only be shared and used within the bounds of the law.
• In certain circumstances We may be legally required to share certain data held by Us, which may include your personal information, for example, where We are involved in legal proceedings, where We are complying with the requirements of legislation, a court order, or a governmental authority. We do not require any further consent from you in order to share your data in such circumstances and will comply as required with any legally binding request that is made of Us.
8. What Happens If Our Business Changes Hands?
• In the event that any of your data is to be transferred in such a manner, you will not be contacted in advance and informed of the changes
9. How Can You Control Your Data?
• When you submit information via Our Site, you may be given options to restrict Our use of your data. We aim to give you strong controls on Our use of your data (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails and by managing your Account.
10. Your Right to Withhold Information and Your Right to Withdraw Information After You Have Given it
• You may access certain areas of Our Site without providing any data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.
• You may withdraw your consent for Us to use your personal data as set out in section in 5 at any time by contacting Us using the details set out in section, and We will delete Your data from Our systems. However, you acknowledge this may limit Our ability to provide the best possible services to you.
11. How Can You Access Your Data?
You have the legal right to ask for a copy of any of your personal data held by Us (where such data is held). Please contact Us for more details at email@example.com , or using the contact details below in section 14. Alternatively, please refer to Our Data Protection Policy.
12. What Cookies Do We Use and What For?
• By using Our Site you may also receive certain third party Cookies on your computer or device. Third party Cookies are those placed by websites, services, and/or parties other than Us. We use third party Cookies on Our Site. For more details, please refer to section 5, above, and to section 12 below. These Cookies are not integral to the functioning of Our Site.
• All Cookies used by and on Our Site are used in accordance with current English and EU Cookie Law.
• Before any Cookies are placed on your computer or device, you will be shown a pop-up requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling Us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Site may not function fully or as intended. You will be given the opportunity to allow only first party Cookies and block third party Cookies.
• Certain features of Our Site depend on Cookies to function. EU Cookie Law deems these Cookies to be “strictly necessary”. Your consent will not be sought to place these Cookies. You may still block these Cookies by changing your internet browser’s settings as detailed below in section 12, but please be aware that Our Site may not work as intended if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.
• Our Site uses analytics services provided by third-parties developers. Website analytics refers to a set of tools used to collect and analyse usage statistics, enabling Us to better understand how people use Our Site. This, in turn, enables Us to improve Our Site and the services offered through it. You do not have to allow Us to use these Cookies, as detailed below, however whilst Our use of them does not pose any risk to your privacy or your safe use of Our Site, it does enable Us to continually improve Our Site, making it a better and more useful experience for you. You may remove these Cookies and prevent future use of them by following the steps set out below in section 12.
• You can see all the cookies we’re using, choose to enable or disable Cookies and change or withdraw your consent at our Cookie declaration page or in your internet browser. Most internet browsers also enable you to choose whether you wish to disable allcookies or only third party cookies. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
• You can choose to delete Cookies at any time however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.
• It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.
13. Summary of Your Rights under GDPR Under the GDPR, you have:
• the right to request access to, deletion of or correction of, your personal data held by Us;
• the right to complain to a supervisory authority;
• be informed of what data processing is taking place;
• the right to restrict processing;
• the right to data portability;
• object to processing of your personal data;
14. Automated Decision-Making and Profiling
We do not use personal data for the purposes of automated decision-making and those decisions have a legal (or similarly significant effect) on You. We currently profile your personal data for the purposes indicated in section 5.
15. Data Protection Officer