PrivadoVPN Privacy Policy

Last Updated: October 21, 2021

The PrivadoVPN Privacy Policy (“Policy”) applies to the applications, websites and online products and services (the “Services”) provided by Privado Networks AG (“we”). By visiting our websites or creating an account to use our Services and ticking the “I agree”-box, you agree to this Policy. If you do not agree to this Policy, you may not use our Services.

This Policy informs the customers and users (“you” or “user”) of our Services of how we collect, process and store personal data. We strive to collect only the minimal data required to provide the Services.

Data Controller:

Privado Networks AG in Zug, Switzerland, is the controller for the data processing pursuant to this Policy. You can notify us of any data protection related concerns using support@privado.io.

Data that we collect (data that you provide to us):

1. Account Creation: We collect minimal data when you create an account. This is data that you provide to us, including your email address and your username.
2. Payment Information: We use third party payment processors to facilitate payment for the Services. These third party payment processors are located in Switzerland and the EU. If you utilize a credit card, this information will be collected by the payment processor. We do not collect or store your credit card number. The specific information collected varies based on your choice of payment method. We recommend using Bitcoin when subscribing to our Services for maximum security.
3. Support: We do collect and keep data that you share with us regarding support issues or customer requests. We may use third parties for support reporting purposes.

How we use data that you provide to us:

1. To communicate with you regarding support issues and to send you technical notices.
2. To communicate with you regarding billing issues and to send you administrative messages.
3. To communicate with you and send you information about products, updates, services, promotions, events, contests and other news regarding the Services we think will be of interest to you and announcements regarding the Services.

You may opt out from receiving any marketing or promotional emails by following the opt-out procedures that are explained in the email. Alternatively, you may go to support@privado.io opt out of our internal marketing or promotional emails.

Data we collect automatically when you use our Services

When you use our Services, we may collect the following information:

1. Mobile Applications: We collect information regarding which application version(s) you have activated for troubleshooting and assisting with support issues. We may also collect anonymous, aggregate statistics, such as the type of operating systems and devices that are most commonly used, including total number of installs, total number of uninstalls and the number of active users over a period of time.
2. Mobile Analytics Software: We use self-hosted Sentry crash reporting tools to send us crash reports so we can provide bug fixes and address technical issues rapidly.
3. Mobile Identifiers: We use mobile identifiers provided by iOS and Android devices. These identifiers do not contain your email address or name. Mobile identifiers provide us with statistics related to marketing or channel partners. Users may turn-off or reset Mobile Identifiers at any time. iOS users should review Apple’s support page at support.apple.com/en-us/HT205223. Android users should review Google’s support page at support.google.com/android/answer/3118621?hl=en.

Please note that the anonymized mobile applications data is fully anonymized and is unable to be tied to a user of our Services. We collect the information to provide a fast and secure experience.

4. Information collected by cookies, pixels & other similar technologies:
   • Cookies, pixels and other similar technologies are usually small text or image files that store and provide information about your visit to our websites. We use cookies to improve the user experience of our website. We use analytics providers, like Google, which set cookies when you visit our websites.
   • We use cookies for a number of reasons, like helping us see which features are most popular, counting visitors to a page, improving our users' experience, keeping our services secure, and generally providing you with a better experience.
   • To prevent your data from being used by Google Analytics, you can install Google’s opt-out browser add-on.
   • For information on how our advertising partners allow you to opt out of receiving ads based on your web browsing history, please visit youronlinechoices.eu. Users in the United States should please visit optout.aboutads.info.

Any Cookies that are utilized will not contain personally identifying information such as your email address and they do not track your activity outside of our websites.

Information collected on social media or blogs: We may collect information on our blog via our websites or through our social media accounts, including but not limited to Facebook, Reddit and Twitter. Any communication you provide to us on external social media accounts is done at your own risk and without guarantee of privacy. If you post a comment on one of our blogs or websites, please contact us if you want it deleted.

External Links: Our Services may contain links to other websites or other services of interest. We are not responsible for the content or material on any website that we link to, as these external sites and services are governed by their own terms and privacy policies.

Bandwidth utilized & free versions

We measure the amount of bandwidth utilized by users of the Services. Free versions may have a limited data transfer amount. Subscribers that paid for Services will be provided with unlimited data transfer. The total sum of data transferred is not identifiable for a user’s behavior. We measure bandwidth utilized in order to improve our services. We do not log any data sent over the connections.

Combination and further use of data

We combine the data we collect about you and use this information for various purposes, including to:

• provide and improve our products and services;
• process your transactions;
• send you technical notices and support and administrative messages;
• communicate with you about products, services, promotions, events and other news and information we think will be of interest to you;
• personalize our Services, including by providing content or features we think will be of interest to you;
• facilitate contests and promotions and process and deliver prizes;
• monitor and analyze trends and usage in connection with our Services;
• detect and prevent fraudulent transactions and other illegal activities, comply with our legal obligations and protect the rights and property of Privado and others; and
• carry out any other purpose described to you at the time the information was collected.

Disclosure of data

We only disclose the limited data we have on record (i.e., email address & username) when compelled by the Swiss authorities. Data requests from foreign authorities must be approved by the Swiss authorities.

We are unable to supply any information for requests related to a PrivadoVPN user’s browsing history, traffic destination, data content, IP addresses, or DNS queries. This information does not exist.

Right to access, rectification, object, portability and erasure

You can directly access, delete, edit or export personal data processed by us in your use of the Services or object to our processing of your data. You can also email our support team at support@privado.io to make a request.

Data retention

We store the data we collect about you for as long as necessary for the purposes for which we originally collected it. We may retain certain information for legitimate business purposes or as required by the laws of Switzerland. The data is stored in Switzerland and the EU.

Data security

Data security is a core pillar of our business. Our infrastructure and secure servers are contained in fully locked and 24-7 monitored data facilities that are best in class.

Even if a regulatory authority physically seizes a PrivadoVPN server (assuming it could break the disk encryption) there would be no logs or information that could be tied an individual user.

Changes to this Policy

We reserve the right to review and change this Policy at any time. We will notify users about any such changes. Continued use of our Services will be deemed as acceptance of such changes.