Original document version — November 10, 2022. This date refers to the original policy, not a review of how the apps currently operate. Before installing, also read the Data safety section and privacy policy in your chosen app’s listing.
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01Core principles
This policy describes how the service processes personal data as a data controller.
The original policy’s core principle is to preserve user anonymity: not to store activity logs or metadata and to keep data retention to a minimum.
However, personal data may be processed when making payments, including by bank transfer, PayPal, Swish or Stripe, and when sending support emails or problem reports.
If the service is used for illegal purposes, we may revoke the license key and restrict access.
02Payment data
Payment information is processed to provide the service, issue refunds and maintain accounting records.
- For service provision and refunds, the legal basis for processing is the service’s legitimate interest. The original policy states that this interest takes precedence over the user’s rights regarding the relevant data.
- For accounting, the legal basis is compliance with a legal obligation.
Some payment data is retained for the period required by applicable local law. Unless the law or the described terms require otherwise, data is kept no longer than necessary for the purpose of processing. Once the mandatory retention period ends, it is permanently deleted.
The original policy recommends avoiding payment by bank transfer.
03Support requests
When you contact us by email, we process your address and the information you include in your message.
For reports sent through the app or client, the original policy provides for removing software logs, email addresses, IP addresses and paths containing confidential information. Do not include personal data in your problem description.
Emails and problem reports received by email or through social media are processed to answer questions, troubleshoot issues and help users. The legal basis is the service’s legitimate interest; the original policy states that it takes precedence over the user’s rights regarding the relevant data.
Once an issue is resolved or a request is closed, related emails and reports are archived and removed from the inbox. After six months, all emails and reports sent to support are automatically and permanently deleted from inboxes, sent folders, deleted items, trash and archives.
04Third-party recipients
Personal data is shared only with providers that deliver services on our behalf, and only for the purposes described above. The original document lists email and payment service providers bound by confidentiality obligations.
05App monitoring
The original policy names Sentry, a monitoring service provided by Functional Software, Inc. It is used to monitor app components, improve performance, carry out maintenance and troubleshoot issues.
The categories of personal data processed depend on the features and implementation of these services, which filter app activity. The original policy does not provide a specific list of categories.
06Where data is stored
The original policy provides for storing personal data only in the European Union and European Economic Area (EU/EEA), with no routine transfers to third countries.
If such a transfer occurs in an exceptional case, we ensure there is a legal basis and provide the user with the necessary information.
07Automated decision-making
No automated decision-making, including profiling, takes place.
08Children’s data
In accordance with the US Children’s Online Privacy Protection Act (COPPA) and related regulations, we do not knowingly collect or store personal data from children under 13.
09App-specific information
Each app on Google Play has a Data safety section and a link to its privacy policy. The information in the listing applies to that app; the version of the general document provided here does not replace it.
If the information differs or you want to clarify which terms apply to your app version, contact support.
10Version and questions
The original policy was last updated on November 10, 2022. The policy may change; a new version must be published. This rendering does not establish a new effective date for the document.
Questions about the current version and data processing can be sent to support@vpnhub.ltd or to support on Telegram.