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Privacy Policy

Last Updated: April 4,2024

This RoboVPN privacy policy (the “Policy”) outlines what Personal Information is collected by NetNut Ltd. and any of its affiliates (“RoboVPN”, “we”, “us” or “our”), how we use such Personal Information, the choices you have with respect to such Personal Information, and other important information.

We keep your Personal Information personal and private. We will not rent, share, or otherwise disclose your Personal Information to anyone except as necessary to provide our Services (as defined below) or as otherwise described in this Policy.

For the purpose of this Policy, “Personal Information” shall mean individually identifiable information, namely information that identifies an individual or may with reasonable effort identify an individual. If we associate Non-personal Information with Personal Information, we will treat such information as Personal Information.

This Policy applies to RoboVPN's collection, use, and disclosure of the Personal Information of the following categories of individuals: Website/App Visitors: Individuals who visit our Website or mobile application and who may volunteer certain personal data (such as their email address) to receive communications from RoboVPN. For the purposes of this Policy, “Website” shall refer collectively to https://www.robovpn.com/#, including RoboVPN's mobile application, and as well as any other websites that link to this Policy.

INFORMATION WE COLLECT

  • Contact information. In connection with the Service(s), you may provide us with various types of information, including Personal Information, such as your name and email address.
  • Payment information To the extent we will offer a paid service,in connection with purchasing of said Service(s), you may also provide us with payment information, such as payment details and billing address, which is collected through a third-party providing a payment mechanism (e.g., a payment processor, Apple Pay, or a similar means of payment) (each, a “Payment Processor”) and is retained by the Payment Processor. IP address: RoboVPN processes but generally does not store users originating IP addresses when connected to our service and therefore cannot identify users when provided IP addresses of our servers. Additionally, RoboVPN cannot disclose information about the applications, services or websites our users consume while connected to our Services; as RoboVPN does not store this information. It may be necessary to temporarily maintain usage data to provide the Service and assist in debugging a problem with the Service. This usage data may include such information as the date and time of your login and the IP addresses you visited. This information is not retained once the troubleshooting is resolved;
  • Additionally, we perform automated rules-based traffic management for the purposes of maintaining and improving our service. Applying these rules may require real-time analysis of Internet and data traffic including destination websites or IP addresses, originating IP addresses. However, please note that under certain circumstances and subject to RoboVPN's sole discretion we may collect information about domains that you visit while using our Service, for the purposes of preventing abuse of the Service, enforcing our terms of use and complying with legal obligations. .
  • Communication information and voluntary information When you contact us, we keep a record of your communication to help solve any issues you might be facing. We may use your email address to inform you about our services, such as letting you know about upcoming changes or improvements.
  • Non-Personal Information When you use our Services, we also collect device-specific information, such as your hardware model, operating system version, unique device identifiers, and mobile network information. This information is associated with your device using a randomly generated unique identifier.
  • As part of the use of the Services, you may have the option to become a "peer" in the Company's network ("Peer"). This would basically mean that you will share your device's resources, mainly its IP address, in order to serve other members of the Company's network. If you decide to become a Peer, we will collect such Personal Information as needed to operate the Service. Such Personal Information will include the IP address information as provided above.

HOW WE USE YOUR INFORMATION

RoboVPN only processes Personal Information in a way that is compatible with and relevant for the purpose for which it was collected or authorized. We may use the Personal Information we collect to:

  • Provide, operate and maintain the Website and the Services;
  • Promote, protect and improve our Website and Services, to develop new services;
  • Improve your user experience and the overall quality of our Services;
  • Personalize the Website and Services, including by providing features or content that match your interests and preferences;
  • Process and complete transactions, and send you related information, including purchase confirmations and invoices;
  • Send transactional messages, including responses to your comments, questions, and requests; provide customer service and support; and send you technical notices, updates, security alerts, and support and administrative messages;
  • Send commercial communications, in accordance with your communication preferences, such as providing you with information about products and services, features, surveys, newsletters, offers, promotions, contests, and events about us and our partners; and send other news or information about us and our partners;
  • Monitor and analyze trends, usage, and activities in connection with the Website and Services and for marketing or advertising purposes;
  • Comply with legal obligations as well as to investigate and prevent fraudulent transactions, unauthorized access to the Services, and other illegal activities;

HOW WE SHARE YOUR PERSONAL INFORMATION

Except as otherwise detailed in this Policy, we do not sell, trade, or otherwise transfer Personal Information. In addition to the purposes listed in this Privacy Policy, we may share Personal Information with our trusted third-party providers, who may be located in different jurisdictions across the world, for any of the following purposes: Website hosting partners and other parties who assist us in operating our Website and Service, conducting our business, or serving our users ("Service Providers"). These Service Providers may only process Personal Information pursuant to our instructions and in compliance both with this Policy and other applicable confidentiality and security measures and regulations. In addition to sharing with Service Providers as described above, we may also share your information with others in the following circumstances: With other subsidiaries or affiliate companies of RoboVPN; In the event of a merger, sale, change in control, or reorganization of all our part of our business; When we are required to disclose personal information to comply with the law, respond to subpoenas, investigations by law enforcement agencies, court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims; Where we have a good-faith belief sharing is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our policies, or as otherwise required to comply with our legal obligations;

LEGAL BASIS FOR PROCESSING (FOR EEA USERS)

If you are an individual from the European Economic Area (EEA), please note that our legal basis for collecting and using your personal information will depend on the personal information collected and the specific context in which we collect it. This section lists the applicable legal basis next to each of the processing activities described above: Processing Legal Basis Provision of Services (including processing of payments and device data) and Support Performance of our contractual obligations towards you Compliance with our legal obligations Our legitimate interests Verifying and authenticating the registration information Performance of our contractual obligations towards you Compliance with our legal obligations Our legitimate interests Conducting statistical and analytical purposes Our legitimate interests Inform you of additional products, services or promotions Your consent Our legitimate interest investigate, detect, prevent, or take action regarding illegal activities or other wrongdoing, suspected fraud or security issues; establish or exercise our rights to defend against legal claims; prevent harm to the rights, property or safety of us, our users, yourself or any third party; collaborating with law enforcement agencies Compliance with our legal obligations Our legitimate interests

TRACKING TECHNOLOGIES

We, as well as certain third parties, may use cookies and other information gathering technologies such as browser web storage (including HTML 5) and application data cache ("Tracking Technologies"). In addition, these Tracking Technologies allow us and third parties to automatically collect information about you (such as your IP address, device unique identifiers and your online behavior), for analytics purposes. Third party Tracking Technologies are governed by each third party's specific privacy policy, not this one. We are currently using the following Tracking Technologies: Appsflyer SDK and Google Firebase SDK.

INTERNATIONAL INFORMATION TRANSFERS

Please note that our businesses, as well as our trusted partners and Service Providers, are located around the world. Any information that we collect (including your Personal Information) is stored and processed in various jurisdictions around the world, for the purposes detailed in this Privacy Policy, including in jurisdiction which may provide different rights, with respect to personal information, than the rights provided in the jurisdiction in which you reside. Where necessary under applicable law, we ensure, through contractual measures, that processing of personal data will be adequately safeguarded.

DATA SUBJECT RIGHTS

If you reside in the EU (or in another jurisdiction that affords you with the below rights), you may request to: Receive confirmation as to whether or not personal information concerning you is being processed, and access your stored personal information, together with certain supplementary information. Receive personal information you directly volunteer to us in a structured, commonly used and machine-readable format. Request rectification of your personal information that is in our control. Request erasure of your personal information. Object to the processing of personal information by us. Request to restrict processing of your personal information by us. However, please note that these rights are not absolute, and may be subject to our own legitimate interests and regulatory requirements. Also, the exercise of some of these rights may make it impossible for us to continue to provide you with our Services. You also have a right to lodge a complaint with a supervisory authority If you wish to exercise any of the aforementioned rights, or receive more information, please contact us at [email protected]

PERSONAL INFORMATION RETENTION

We will retain your personal information for as long as necessary to operate our Website or provide the Services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our policies. Retention periods shall be determined taking into account the type of information that is collected and the purpose for which it is collected for, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time.

NOTE FOR MINORS

We do not knowingly collect or solicit Personal Information from anyone under the age of consent (as determined under the applicable laws where the individual resides; “Age of Consent”). By accessing, using or interacting with our Website or Services, you certify to us that you are not under the Age of Consent. If we learn that we have collected Personal Information from an individual under the Age of Consent without verification of parental consent, we will delete that information upon discovery. If you believe that we might have any information from or about an individual under the Age of Consent, then please contact us through the contact details available below.

CHANGES TO THIS POLICY

We reserve the right to change this Policy at any time, so please re-visit this page frequently. All changes to this Policy are effective as of the stated "Last Updated", and your continued use of the Website or Services after the Effective Date will constitute acceptance of, and agreement to be bound by, those changes.

CONTACT INFORMATION

If you have any questions about this Privacy Policy, please contact us at: [email protected]