This document, known as the “Privacy Notice” provides an explanation of the privacy regulations that apply to the collection and submission of Personal Data and other information when you access or use Services and Website (https://ultravpn.tech/), regardless of the device (computer, mobile phone, tablet, etc.) you use.

The Data Controller (as defined below) responsible for processing your Personal Data, as outlined in this Privacy Notice, is [COMPANY NAME], [REGISTRATION ADDRESS], [COMPANY REG NUMBER]; email: [email protected] (“we”, “us” or “our”).

1. DEFINITIONS

As used herein, the following terms are defined as follows:

Term Definition

Data Controller A natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data.

Personal Data Data that identifies an individual or relates to an identifiable individual. This includes information you provide to us, information which is collected about you automatically, and information we may obtain from third parties.

Services Services provided by us as described in the relative Terms and Conditions of the Website.

2. Processing OF YOUR PERSONAL DATA

2.1.Information you provide to us

In order to create an account and access our Services, we will kindly request certain information from you. This data is to provide the Services (e.g., your email address is needed to open an account). Please note that if you fail to provide the required data, we will be unable to offer you our Services.

We may process the following categories of Personal Data:

Category of Personal Data Types of Personal Data

Account Information When you register, we request your name, username, email address and password, which are necessary for creating your account.

Payment information This information is required to collect payments for the Services. Our payment processing partners handle basic billing information for payment processing and refund requests (e.g., purchase date, credit card owner’s full name, credit card information, etc.).

Communications We use your email address and correspondence to respond to your requests or inquiries.

2.2. Information we collect automatically

Category of Personal Data Types of Personal Data

Access logs Like most websites on the internet, our Website collect access logs (such as IP address, browser type, operating system) to ensure the secure, reliable, and robust performance of our Services.

Cookies Cookies are typically small text or image files that are placed on your device when you visit our Website. Some cookies are essential for the smooth operation of our Website, while others are used to enhance functionality, analyze aggregated usage statistics for improving performance, and support advertising efforts.

3. How We Use Personal data

Below we provide an explanation of how we use your Personal Data. Kindly note, that we do not use automated processing and profiling which produces legal effects concerning you or similarly significantly affects you.

Purpose of processing Legal basis

Creating and administering your account on the Website. Performance of a contract

Providing services and processing payments. This involves processing payments for the Services rendered, managing subscriptions, and facilitating transactions to enable users to access and utilize the desired Services. Performance of a contract

Communicating with individuals and responding to their inquiries and requests. Providing customer support. Performance of a contract

Legitimate interests (e.g., to improve our Services)

Ensuring security and preventing fraud. This includes identifying and preventing fraudulent activities, unauthorized access, and other security threats to protect the rights and interests of users and maintain the integrity of the services. Compliance with our legal obligations

Legitimate interests (for example, to detect and prevent fraud)

Conducting market research, analysis, and customer surveys. Improving and personalizing the user experience. Legitimate interest (for example, to improve our Website)

Providing you with promotions. This includes offering rewards and other incentives. Consent (where required by applicable law)

Legitimate interest (for instance, to create promotions you may be interested in)

4. SHARING YOUR PERSONAL DATA

We may disclose your Personal Data to third parties as specified in this Privacy Notice:

Category Description

Service Providers We engage third-party service providers to assist us with various operations, including payment processing, email automation, website and app diagnostics, analytics, and more. Consequently, some of these service providers may process Personal Data such as:

• Payment service providers, website hosting providers, IT security providers, email service providers, and analytics providers;
• Professional service providers, for the purpose of seeking professional advice.

As required by law In certain situations, we may be legally obligated to disclose personal data to comply with applicable laws, regulations, or legal processes. This may involve providing Personal Data to government or law enforcement authorities, regulatory bodies, or other public or private entities authorized by law.

Business transfer In situations involving the sale or potential sale of our business or corporate restructuring, such as mergers, acquisitions, consolidations, asset sales, reorganizations, or similar events, there may be instances where we need to share your personal data. However, rest assured that even in such circumstances, we will uphold the confidentiality of your Personal Data.

5. CROSS-BORDER TRANSFERS OF PERSONAL DATA

We may store, access, and transfer Personal Data globally. We assess cross-border data transfers and implement appropriate safeguards to ensure that your Personal Data remains protected in accordance with this Privacy Notice.

Measure Description

Adequacy decision If your Personal Data is transferred to countries outside the European Economic Area (EEA), we ensure the recipient country has received an adequacy decision from the European Commission. For more information about adequacy decisions, click here.

Appropriate safeguards To transfer personal data to recipients lacking an adequacy decision, we may utilize standard contractual clauses that have been approved by the European Commission or other legally recognized transfer mechanisms. For more information about standard contractual clauses, click here.

6. RIGHTS RELATED TO YOUR PERSONAL DATA

Please note that different jurisdictions have various data protection laws that grant privacy rights to you as a data subject. Subject to applicable data protection laws, you may have the following rights:

Right Description

Deletion Request the erasure of your Personal Data.

Access Know and access the Personal Data collected by us about you.

Rectification Correct, update, or supplement inaccurate or incomplete Personal Data held by us.

Objection Object to the processing of your Personal Data based on our legitimate interests (e.g., for marketing purposes).

Portability Request a copy of your Personal Data in a structured, commonly used, and machine-readable format or, if technically feasible, transmit your Personal Data to another controller (only applicable when our processing is based on your consent and carried out by automated means).

Restriction Restrict the processing of your Personal Data (when legally justified).

Withdraw consent Withdraw your previously provided consent to processing activities.

Lodge a complaint Exercise your rights by contacting us directly or, if necessary, file a complaint with a supervisory authority.

To exercise any of these rights, please contact us via the provided email address: [email protected]. 

You will not be charged for exercising your rights, and we have one month to respond to your request.

7. COUNTRY-SPECIFIC PROVISIONS

For users in the European Economic Area (EEA):

If you reside in EEA countries, you can exercise your rights as outlined in the European Union’s General Data Protection Regulation (GDPR) by contacting us at the provided email address: [email protected].

For Users in California:

If you are a resident of California, you can exercise your rights as granted by the California Consumer Privacy Act (CCPA) by contacting us at [email protected].

Please note that we do not sell, share, lease, or rent your personal information, as defined in the CCPA.

8. COOKIES

A Сookie is a small data file that the Website requests your browser to store on your device, enabling it to retain information about you, such as your language preference or login details. The cookies we utilize include:

Category Description

Essential Cookies These cookies are crucial for enabling users to navigate the Website and access its features. They do not gather information for marketing purposes or remember your internet browsing history.

Functional Cookies These cookies enhance the Website’s functionality and personalization. They may be set by us or third-party providers whose services are included on our pages. If you disable these cookies, some or all of these services may not function properly.

Performance Cookies We employ Google Analytics cookies to collect aggregated data on how visitors use the Website. This information helps us understand how our Website is being utilized.

Marketing Cookies These cookies deliver content that is tailored to your interests and preferences. They can be used to display targeted advertisements and measure the effectiveness of advertising campaigns.

Most modern web browsers allow you to view and manage the cookies stored on your device through their cookie settings. Here are some links that provide guidance on managing your cookie preferences:

• General Cookie Information;
• Firefox Settings;
• Safari Settings;
• Google Chrome Settings;
• Opera Settings.

9. DATA SECURITY

We maintain strict controls over the Personal Data we collect. Our dedicated IT security team has implemented appropriate physical, technical, and organizational measures to safeguard your information against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, access, and other unlawful forms of processing.

10. DATA RETENTION

We retain your Personal Data only for as long as necessary to provide you with our Services or as long as we have another legitimate basis for doing so, but not longer than permitted or required by law.

When determining the appropriate retention period, we consider factors such as the quantity, nature, and sensitivity of the Personal Data, the purposes for which we process it, and any legal requirements mandating specific retention periods.

11. CHILDREN’S DATA

We do not knowingly collect or request Personal Data from individuals under the age of 18. If you are under 18, please refrain from providing any Personal Data about yourself to us. In the event that we become aware of collecting and processing Personal Data from a child under 18, we will promptly delete that data.

12. LINKS TO OTHER WEBSITES

Our Website may contain links to other websites, that have different privacy practices than ours. If you access any of these websites through the provided links and/or submit your Personal Data to them, your information will be processed according to their established procedures and governed by their respective privacy policies.

13. HOW TO COMPLAIN

If you wish to file a complaint, please contact our designated privacy contact using the contact information provided in this Privacy Notice.

If you are unsatisfied with our response or feel that your complaint has not been adequately resolved, you have the right to lodge a complaint with the appropriate data protection authority. This is especially applicable in the country where you usually reside, work, or where you believe a violation has occurred.

14. UPDATES TO THE PRIVACY NOTICE

We continuously develop our Services and Website, introducing new features or making modifications. Therefore, there may be occasions when we need to amend the Privacy Notice. If such amendments significantly affect the processing of your Personal Data, we will inform you of the changes in advance through reasonable means (e.g., notifications via applications, our Website, or email).

It is recommended that you regularly review this Privacy Notice to stay informed of any changes.

Version published: 1.0

Date published: May 30, 2023