1- DATA COLLECTED by the vpn app and website :
1.1.1 When you register new account on the app :
- Email adress ==> to send you purchase receipts and reset password .
- Username ==> to manage your account and facilitate your login into the service.
- Password ==> to protect the account
- Expiration date ==> to tell us until when the account is valid
When registering, you need to provide your email address, username and create a password to initially create a VPN connection. We collect this essential data to provide you with the VPN service.
1.1.2 When you use the vpn service on the app :
For the duration of your connection the following is stored in server's memory. This data is immediately discarded when you disconnect:
- IKEv2 username ==> to troubleshoot for support and abuse handling.
- Time of connection ==> to troubleshoot for support and abuse handling.
- Amount of data transferred ==> to plan for new network capacity and server improvements.
- IP address ==> to troubleshoot for support and prevent abuse of our service.
The following data is stored in a central location:
- Number of parallel connections at any given time ==> prevent rampant abuse and account sharing.
- A counter is incremented that stores total number of bytes downloaded/uploaded in a 30 day period.
The following data is NOT stored :
- Originating IP address.
- Browsing history.
- Transferred data.
1.2 When you are using the website
- Email address and a hash of the password which you use at the registration. That ensures that you can retrieve your password if needed, and that we can communicate with you when we have any announcements to make, service updates to advise or errors to report.
- Cookies for personalizing the content of LocVPN website for users, such as setting the default language. None of the information we may acquire through the use of cookies is considered Personal Data by the standards of GDPR as it does not allow to identify you. You can always disable cookies on your web browsing software or clear existing cookies, but please note that some of our services may not function properly without the aid of cookies.
- Billing and payment information. If you purchase a subscription to LocVPN, we’ll need to know your contact details. FYI: we conduct all transactions via 2checkout payment provider.
2 - DATA SHARED by the vpn app and website :
- We do not sell or share your personal information to third parties but we uses third party data processors only for processing of payment data, and basic website and app analytics:
* Google Firebase Analytics and crash report on iOS and Android: https://policies.google.com/privacy
Firebase Google tool helps us to improve application stability, pinpoint things that don’t work, and improve your experience. Its implementation doesn’t contain any information that can personally identify you
We rely on third-party payment processors to handle your product purchases. You can find out which provider we are working with for the point of purchase you chose (for example our website, an app store, etc) by looking at your transactional email or receipt.
This is the list of payment processors we cooperate with and their privacy policies:
* 2Checkout - https://www.2checkout.com/legal/privacy/
* Google Play - https://policies.google.com/privacy?hl=en-US
* Apple iTunes - https://www.apple.com/legal/privacy/en-ww/
These providers are in the position of independent controllers and may collect a variety of information about you to complete the purchase. All of them are PCI-compliant or the equivalent and are prohibited from using your personal data for anything but facilitating your payment and subscription management or as otherwise described in their applicable terms of service and privacy policy.
Some of that billing data may be shared with us in order to detect and prevent fraud, help with customer support, or used as a record of your payment for accounting, taxation, and invoicing purposes. This data is what we call “billing data” and it includes your name, address, email address, the product (subscription you purchased) and for how long, and payment information.
Your payment provider will process your credit card number, but it is not shared with us.
On our side, billing data is stored for as long as you continue to use our service, and for up to 10 years after that. If legal obligations change, or we need to resolve disputes and enforce our agreements, we may be obliged to keep this data longer than that.
- Our goal is to collect and retain the least amount of data. However we have to collect and retain some data, such as email address and billing information, which allows for you to continue using the VPN service.
- You have the right to request, review, and request deletion of your personal data by mail at [email protected].
3 - Change to the privacy policy :
- The current policy is available on the Website and apps and relevant services.